ML20214X398

Rev 10 to Operating QA Manual for Facility

ML20214X398
Person / Time
Site:	Callaway
Issue date:	06/30/1987
From:	UNION ELECTRIC CO.
To:
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ML20214X326	List: ML20214X325 ML20214X398
References
NUDOCS 8706160455
Download: ML20214X398 (129)

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r OPERATING QUALITY ASSURANCE MANUAL (OQAM) TABLE OF CONTENTS Section Title Page Table of Contents i l l Policy / Introduction iii Effective Page Listing v l 1.0 Organization 1 2.0 Quality Assurance Program 8 3.0 Design Control 13 4.0 Procurement Document Control 19 5.0 Instructions, Procedures, and Drawings 23 6.0 Document control 25 7.0 Control of-Purchased Material, Equipment, 28 , and Services-8.0 Identification and Control of Materials, 36 Parts, and Components 9.0 Control of Special Processes 38 10.0 Inspection 39 11.0 Test Control 42 12.0 Control of Measuring and Test Equipment 45 13.0 Handling, Storage, and Shipping 48 14.0 Inspection, Test, and Operating Status 50 15.0 Nonconforming Materials, Parts, or 51 Components 16.0 Corrective Action 54 17.0 Quality Assurance Records 56 18.0 Audits 59

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c-Section Title Page Appendix A OQAM Conformance to Applicable NRC A-1 Regulatory Guides l Figure A . Union Electric Organization-l Figure B Operating Organization f i i l i I

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OQAP POLICY / INTRODUCTION It is the policy of-Union Electric Company (UE) to develop, implement, and maintain an Operating . Quality Assurance Program (OQAP) for utilization facilities regulated by provisions of a Nuclear Regulatory Commission (NRC) operating license and amend-ments thereto. The QA Program shall be applied to those activi-ties affecting quality (safety-related) regarding structures, systems, and components necessary to assure:

1. The integrity of the reactor coolant pressure boundary,

2. The capability to shut down the reactor and maintain it in a safe shutdown condition, or

3. The capability to prevent or mitigate the consequences of accidents which could result in off-site exposures comparable to the guideline exposures of NRC Regula-tions 10 CFR 100.

These activities include operational testing, operations, maintenance, refueling, and modifications. Control over these activities as they affect quality shall be to the extent consis-tent with their importance to safety. UE Company has established an organization to implement the OQAP as documented in policy, manuals, and procedures. Specific OQAP requirements and corresponding organizational responsibili-ties are specified in - the Operating Quality Assurance Manual (OQAM). The OQAP involves the proper functioning of many disciplines and activities. Functions, departments, groups, committees and other organizational subdivisions shall control activities affecting quality through implementation of appropriate written procedures or instructions. Documentation shall be maintained to provide objective evidence of program implementation and effec-tiveness. The OQAP shall comply with 10 CFR 50, Appendix B - " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" and follow the guidance of the Regulatory Position of Regulatory Guide 1.33. Clarifications, alternatives, and excep-tions to this Regulatory Position are described in Appendix A of the OQAM. An eighteen (18) section format is employed with a discussicn of how corresponding criteria of 10 CFR 50, Appendix B are satisfied. The responsibility for formulating, authorizing, and assur-ing implementation of the UE Company OQAP rests with the Vice President-Nuclear. The Policy and resultant QA Program are mandatory for Callaway Plant operational phase activities. Accordingly, personnel shall be made cognizant of QA Program

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req'tiirements and responsibilities applicable to' their individual activities and interfaces. By the signatures of the undersigned, this OQAM is approved , and those UE personnel whose activities are within the purview of the OQAP are responsible for its implementation in accordance with the requirements described herein. b) Donald F. Schnell [w f Dit'A 1987 Vice President-Nuclear 4$ ads. ,n L 8,1971 Andrew P.MieuhaKen / Date Manager, Quality Assurance

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p , OQAM EFFECTIVE PAGE LISTIWG Page No. .Re v . i 10 il 10 111 10 IV 10' y 10 vi 10 vii 10 Sections 1 10 2 10 3 10 4 10 5- 10 6 10 7 10 8 10 9 10 10 10 11 10 12 10 13 9 14 10 l 15 9 16 10 17 10 18 10 . 19 9 20 9 21 9 22 9 23 9 24 e 9 l 25 s 10 26 I 9 27 - 9 28 9 29 10 30 10 31 9 32 9 33 ' 9 34 9 35 9 36 + 9 37 9 l 38 10 39 9 40 9 i l 41 10

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r- . _ , OQAM EFFECTIVE PAGE LISTING Page No. Rev. 42 10 43 10 44 10 45 10 46 9 47 9 48 9 49 9 50 9 51 9 l 52 10 53 9 54 10 55 10 56 9 57 9 58 9 59 9 l 60 10 61 9 62 10 63 10 Append ix A-1 9 A-2 10 A-3 10 A-4 10 A-5 10 A-6 10 A-7 10 A-8 10 A-9 10 A-10 10 A-11 10 A-12 10 A-13 10 A-14 10 A-15 10 A-16 10 A-17 10 A-18 10 A-19 10 A-20 10 A-21 10 A-22 10 A-23 10 A-24 10 A-25 10 A-26 10 4

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v , j 1 OQAM  ! EFFECTIVE PAGE LISTING Page No. Rev. A-27 10 ' A-28 10 A-29 10 A-30 10 Figures Figure A 10 Figure B 10 ! -vil- Rev . 10 6/87 } _ _ _ _ _ _ . _ , . -- __-___.___. ~.--._ , _ --._ .., _ . - __ _ . ..._ _ _._ .,

OPERATING QUALITY ASSURANCE MANUAL (OQAM) I 1.0 ORGANIZATION 1.1 UE has established an organization for Quality Assurance activities. This Section identifies the organizational structure; management positions and responsibilities; and delegation of authority for the development, implementation and maintenance of the Operating Quality Assurance Program (OQAP). UE shall retain responsibility for the establish-ment and execution of the OQAP, although certain Program activities may be delegated to others. The organization responsible for implementing appropriate portions of the OQAP is shown in Figure A of the OQAM. The Callaway Plant operating organization is shown in Figure B of the OQAM. 1.2 The Executive Vice President is responsible to the Presi-dent of UE Company for the establishment and implementation of the Quality Assurance Program requirements. He has ultimate responsibility for quality assurance, engineering, construction, and operation of the Callaway Plant. 1.3 Under the Executive Vice President, the Vice President, l Nuclear is responsible for initiating the Quality Assurance Program, formulating the policy, and authorizing and assuring Program implementation. He is responsible for directing activities within the Nuclear Function which support the engineering, construction, testing, and opera-tion of the Callaway Plant and coordinating support activi-ties performed by others who are not under his direct administrative control. He has corporate responsibility for the operation and physical control of the Callaway Plant. 1.4 The Assistant to the Vice President, Nuclear reports to the Vice President, Nuclear and is responsible for high level management activities as directed by the Vice President, l Nuclear. The Assistant to the Vice President, Nuclear is responsible for Nuclear Records and Information Services (NRIS). The Nuclear Records and Information Services organization includes the Superintendent, NRIS, the Super-intendent, Administration-Services and the Superintendent, Administration-Records. The Superintendent, NRIS, the Superintendent, Administration-Services, and the Superin-tendent, Administration-Records report directly to the l Assistant to the Vice President, Nuclear. Rev. 10 6/87

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                                  ~
 ~l-    1.5  The Manager,    Quality Assurance reports to the General Manager, Quality Systems. on Quality Assurance Program matters. The General Manager, Quality Systems reports to the Executive Vice President for administrative matters.

QA Program matters are. reported to the _ Executive Vice , l President through the Vice President, Nuclear. l 1.6 .The Manager,- Quality Assurance reports to the General l Manager, Quality-Systems who is responsible for the admin- , istrative control- (hire / fire and salary review) ~ of the Manager, Quality Assurance. .The Manager, Quality Assurance is responsible for directing the overall Quality Assurance r Program for UE including Program development, maintenance, and verification of implementation. . The Manager, Quality Assurance has sufficient authority, organizational freedom, and independence from undue influence from, or responsibil-ity . for, cost and schedule that he can effectively assure  ; compliance with OQAP requirements as they control Callaway Plant and offsite -quality activities. He maintains a Quality Assurance staff and provides them technical direc-tion and administrative guidance. He is responsible for establishing and implementing a comprehensive audit pro-gram. The qualifications of the Manager, Quality Assurance are at least equivalent to those specified in ANSI /ANS-3.1-1978, " Selection and Training of Nuclear Power Plant Personnel," Section 4.2.4. l 1.7 The Manager, Quality Assurance is located at the Callaway Plant and provides technical direction and administrative guidance to the Superintendents, Quality. Assurance. l 1.8 The Superintendent, Operations Support, QA and the Superin-tendent, Technical Support, QA are located at the Callaway Plant. These Superintendents each direct Supervising Engineers who have primary duties for assuring implementa-tion of the OQAP at the Callaway Plant. The activities of the groups reporting to the Superintendent,- Operations

            . Support, combined with the activities of the groups report-ing to the Superintendent,       Technical Support,     assure implementation of the OQAP at the Callaway Plant.

l 1.9 The qualifications of both the Superintendent, Operations Support and the Superintendent, Technical Support are at least equivalent to those specified in ANSI /ANS-3.1-1978,

              " Selection and Training of Nuclear Power Plant Personnel,"

Section 4.4.5. Rev. 10 6/87

p-OQAM l 1.10 The Superintendent, Quality Engineering, QA, is located at the General Offices and directs Supervising Engineers. The Supervising Engineers have primary duties involving the audit and surveillance of supplier quality activities, engineeridg, procurement, and other support activities at the General Offices. l 1.11 General quality assurance indoctrination and training for the Nuclear Function is the responsibility of UE Nuclear Operations (UENO), Training. The Quality Assurance Divi-

     ,      sion is responsible for specific QA training as requested by Nuclear Function organizations.

l 1.12 The Manager, Quality Assurance, the Superintendents, Quality Assurance, and Supervising Engineers in the Quality Assurance Division are authorized by the Vice President, Nuclear to stop work on ongoing quality activities in accordance with approved procedures. During the operating phase they have the authority to stop unsatisfactory work during repair, maintenance, and refueling activities and the authority to recommend to the Manager, Callaway Plant stop work affecting the continuation of Plant operation. Other stop work authority shall be delineated in proce-dures. The continuance of an activity which would cover up - a deficiency and preclude identification and correction, or increase the extent of the deficiency is subject to stop-work action by the Quality Assurance Division. The Manag-er, Quality Assurance, and the Superintendents, Quality Assurance have no duties or responsibilities unrelated to QA that would prevent their full' attention to QA matters. l 1.13 The authorities and duties of persons and organizations performing quality assurance functions shall be clearly established. Such persons have sufficient authority and organizational freedom to identify quality problems; to initiate, recommend, or provide solutions; and to verify corrective action. Assurance of quality by checking, auditing, inspecting, or otherwise verifying Program activities shall be by personnel other than the individual or group performing the specific activity. 1.14 The General Manager, Engineering (Nuclear) reports directly to the Vice President, Nuclear and is responsible for engineering, licensing, fuel, project services, procurement other than that associated directly with operations, and an independent overview of Plant safety. He provides adminis-trative coordination between the various departments under his direction to assure effective operation of the various disciplines involved in the offsite support and onsite overview of Callaway Plant. Rev. 10 6/87 l

n OQAM l 1.15 The Manager, Nuclear Safety and Emergency Preparedness (NSEP) . reports directly to the General Manager, Engineering l (Nuclear) and is responsible for providing a constant independent overview of nuclear Plant safety. He directs the Supervising Engineer, Independent Safety Engineering Group '(ISEG) and the Supervisor, Emergency Preparedness (EP). l 1.16 The Supervising Engineer, ISEG and staff evaluate Callaway Plant operations from a safety perspective and compare Callaway operating experience with that of plants of similar design. In addition, they assess the' conformance of Plant performance to safety requirements. The Supervi-sor, EP and staff have overall responsibility for the development and maintenance of the Emergency Preparedness Program. This includes onsite and offsite emergency , preparedness, coordination of the Plant Radiological Emergency Response Plan with State and ~ local emergency . plans,. and the planning and execution of emergency drills and emergency plan exercises. A communication path exists between the Manager, NSEP and the Vice President, Nuclear for matters having immediate or significant safety implica- . tions, thus providing a direct path to contact management personnel having corporate responsibility for Callaway Plant, r 1.17 The Manager, Nuclear Engineering reports directly to the I General Manager, Engineering (Nuclear) and directs a staff ' of engineers (as described in Callaway-SA FSAR Section 13.1) whose primary function is to provide offsite techni-cal support to the operation of Callaway Plant. 1.18 The Manager, Nuclear Fuel reports directly to the General Manager, Engineering (Nuclear) and has overall responsibil-ity for UE nuclear fuel cycle activities including respon-sibility for procurement of fuel cycle goods and services, and for incore fuel management. 1.19 The Manager, Nuclear Services reports directly to the + General Manager, Engineering (Nuclear) and is responsible for providing administrative and management support; for cost forecasting, status reporting, and budgeting matters; and for managing, directing, coordinating, and administer-ing construction and modification work as assigned. He is responsible for direction of the Nuclear Function General Offices clerical activities. i l 1.20 The Coordinator Nuclear Development reports directly to the - General Manager, / Engineering (Nuclear) and is responsible for generic nuclear matters. He maintains an awareness of advanced nuclear activities outside UE as well as being the administrative contact with the Institute of Nuclear Power l Operations (INPO). Rev. 10 6/87

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p OQAM 1.21 The Principal Health Physicist reports directly to the General Manager, Engineering (Nuclear) and provides a corporate level overview and guidance in the formulation and ' implementation of applied radiation protection pro-grams. He reviews the radiological safety programs for compliance with Federal and State standards and regula-tions. 1.22 The Superintendent, NRIS reports directly to the Assistant to the Vice President, Nuclear and is responsible for the direction of the Nuclear Records and Information Services (NRIS) organization at the Callaway Plant and for Document Control at the General Offices. l 1.23 The Superintendent, Administration-Records is a member of the NRIS and is responsible for the processing of documents and records related to safety, quality assurance, radiation exposure, and training activities of the Plant. l 1.24 The Superintendent, Administration-Services is a member of NRIS and is responsible for site clerical, stenographic and word processing activities to facilitate Plant operation. 1.25 The General Manager, Nuclear Operations reports to the Vice President, Nuclear and is responsible for the activities of the Callaway Plant Operations Department and the Operations Support Department. This responsibility includes the safe, legal and efficient operation and maintenance of the Callaway Plant and protecting the health and safety of the public and Plant personnel. He assures a high level of quality is achieved in the Plant operations and support activities. l 1.26 The Manager, Callaway Plant reports directly to the General , Manager, Nuclear Operations and is responsible for the safe, legal, and efficient operation and maintenance of the callaway Plant. He controls Plant functions and implements the OQAP through the Assistant Manager, Operations and Maintenance, the Assistant Manager, Technical Services, and l the Superintendent, Planning and Scheduling (see Figure B l of the OQAM). He has the primary responsibility for reactor operation and safety. l 1.27 The Manager, Operations Support reports to the General Manager, Nuclear Operations and is responsible for Plant support activities including training, materials manage-i ment, outages, security, quality control, and compliance i activities required to support the Callaway Operating License. He controls Plant support activities and imple-

ments the OQAP through the Assistant Manager, Support i Services, the Assistant Manager, Materials, and the Super-intendent, Outages. Within the Callaway Plant organ-Rev. 10 6/87 i

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OQAM ization, the QC Supervisor reports to the Superintendent, l Compliance who reports to the Assistant Manager, Support Services. The Quality Control Group performs work activity

                                                                         't inspections, receipt inspection as described in Section 7, and nondestructive examinations and is not involved in those activities performed by others which are considered
           " inspections" unto themselves, e.g., surveillance testing, initial startup testing, and I&C, Radiation Protection, and Chemistry group activities. Activities considered to be inspections unto themselves are covered by QA audits and QA surveillances as discussed under Section 18. The QC Super-visor has no duties or responsibilities unrelated to quality control that would prevent his full attention to quality control matters.

l 1.28 The Superintendent, Personnel Development reports directly to the General Manager, Nuclear Operations and is responsi-ble for assisting in areas of labor relations, organiza-tional and personnel development, and other matters under the guidance of UE Company policies. l 1.29 The Purchasing Agent reports directly to the Vice President (or Director) , Supply Service who in turn reports to the Executive Vice President. The Purchasing Agent is respon-sible for commercial aspects involved in procurement of materials, systems, components, and services (excluding engineering services and certain nuclear fuel cycle-related procurements) not delegated to others which are employed in support of the operating Callaway Plant. l 1.30 The Manager, Mechanical Engineering reports to the Vice President (or Director) , Engineering and Construction who in turn reports to the Executive Vice President. The Manager, Mechanical Engineering provides technical support, as necessary, to the Nuclear Engineering staff. The Chief Draftsman, who reports to the Manager, Mechanical Engineer-ing provides drawing preparation and revision support, as requested, for design performed by Nuclear Engineering or other UE organizations. l 1.31 The Manager, Electrical Engineering reports to the Vice President (or Director) , Engineering and Construction. The Manager, Electrical Engineering provides technical support, as requested, to the Nuclear Engineering staff. l 1.32 Other UE functions may provide safety-related services which augment and support selected Program activities. These organizations shall be required to implement controls consistent with the OQAP requirements applicable to their scope of activities. The coordination of these activities l is the responsibility of the Vice President, Nuclear. Rev. 10 6/87

OQAM l 1.33 Safety review committees shall be established to provide an independent review of those items required by the Callaway Plant Technical Specifications. These committees, the Onsite Review Committee (ORC) and the Nuclear Safety Review Board (NSRB), are described in the Administrative Controls l Section of the Callaway Plant Technical Specifications. 0 Rev. 10 6/87

OQAM 2.0 QUALITY ASSURANCE PROGRAM 2.1 UE Company has established an OQAP which controls activi-o ties affecting quality. The Program encompasses those quality activities necessary to support the operating phase of the Callaway Plant and shall comply with 10 CFR 50, Appendix B - " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" as described herein and with the Regulatory Position of Regulatory Guide 1.33. Commitments, clarifications, alternatives, and exceptions to the Regulatory Position of Regulatory Guide 1.33 are stated in Appendix A of this OQAM. In addition, the OQAP has incorporated the commitments made in responding to applicable NRC questions. The text of the NRC questions applicable to the OQAP, along with the responses, are maintained as a QA Record separate from the OQAM. The Vice President, Nuclear has initiated the Program and formulated the policy in addition to authorizing Program implemen-tation. This responsibility has been established by the Executive Vice President who is responsible to the Presi-dent of UE Company for establishing and implementing the Quality Assurance Program requirements. 2.2 Lines of authority and responsibility have been established from the highest management level through intermediate levels and to the General Manager, Nuclear Operations and the onsite operating organization. These relationships shall be documented and updated, as appropriate, in the form of organization charts, functional descriptions of departmental responsibilities, and position guides for key personnel having direct operating, support, or audit responsibility. Where specific responsibilities are assigned within the OQAP, the prescribed individual shall retain the overall responsibility; however, subject to applicable regulatory constraints, authority may be dele-gated to subordinates. Considering these same regulatory constraints, the authority of a subordinate may always be assumed by a superior. 2.3 Updating and revision of the OQAP as described in this OQAM shall be in accordance with the applicable requirements of 10 CFR 50.54 (a) and 10 CFR 50.71. 2.4 The pertinent requirements of the OQAP apply to all activi-ties affecting the safety-related functions of those structures, systems, and components that prevent or miti-

     .                                   gate the consequences of postulated accidents that could cause undue risk to the health and safety of the public.

The safety-related structures, systems and components are identified in Table 3.2-1 of the Callaway-SP Final Safety Analysis Report (FSAR). This list includes structures, systems, and components identified during the design and construction phase and may be modified as required during Rev. 10 6/87

o OQAM operations consistent with their importance to safety. Modifications to this list require the approval of the Manager, Quality Assurance and the Manager, Nuclear Engi-neering and shall be issued and controlled in accordance with Section 6. The development, control, and use of computer programs to be used in safety-related activities are within the scope of the OQAP. The degree of controls applicable to each computer program shall be consistent with the program's importance to safety-related activities. Consumables which could affect the form, fit or function of safety-related structures, systems, and components, al-though not listed in Table 3.2-1 of the Callaway-SP FSAR, are also under the control of the OQAP. l 2.5 The OQAP shall be implemented throughout the operating life of the Callaway Plant. Activities affecting quality shall be accomplished under suitably controlled conditions. Con-trolled conditions include the use of appropriate equip-ment; suitable environmental conditions for accomplishing the activity, such as adequate cleanness; and assurance that all prerequisites for the given activity have been satisfied. 2.6 Consistent with the schedule for accomplishing quality activities, the OQAP shall be established and documented by written policy, program manual, and procedure manuals. Persons conducting safety-related activities shall be responsible to implement approved procedures. The OQAP shall utilize the following document types to describe Program objectives:

1. Operating Quality Assurance Program Policy / Introduction Statement The Operating Quality Assurance Program Policy state-ment establishes governing principles in accordance with the requirements of 10 CFR 50, Appendix B.

The Operating Quality Assurance Program Policy state-ment and any revisions thereto shall be approved by the Vice President, Nuclear. l

2. Operating Quality Assurance Manual (OQAM)

The OQAM contains a delineation of the Policy state-ment, quality assurance requirements, assignment of responsibilities, and a definition of organizational interfaces. The OQAM is the written description of the l OQAP. Approval of the OQAM is by the Vice President, Nuclear and the Manager, Quality Assurance. Rev. 10 6/87

P OQAM

3. Callaway Plant Operating Manual The callaway Plant Operating Manual consists of a multi-volume set of Plant operating procedures prepared or reviewed by the unit staff with the aid of other SNUPPS utilities, Nuclear Engineering, the Lead A/E, the NSSS Supplier, and Fuel Fabricator. These proce-dures are controlled, approved, and issued in accor-dance with Administrative Procedures contained within the Manual. This Manual includes administrative controls consistent with those required by Regulatory Guide 1.33.

Administrative procedures which apply to the entire unit staff, and revisions thereto, shall be reviewed by the Callaway Plant Onsite Review Committee (ORC) and the Quality Assurance Division. The final approval of Administrative Procedures and revisions thereto shall be by the Manager, Callaway Plant. The review and approval of other Plant operating procedures and revisions thereto shall be in accordance with approved Administrative Procedures which implement the require-monts of the Tect nical Specifications.

4. Union Electric Quality Assurance Procedures Manuals The Quality Assurance Procedures Manuals consist of a set of procedures prepared by various responsible UE Departments or Functions. These procedures are ap-proved by the various Department or Function Heads and serve to implement the requirements specified herein regarding the Quality Assurance Division and offsite quality activities necessary to support the operation of Callaway Plant.

Procedures within the Union Electric Quality Assurance Procedures Manuals and revisions thereto shall be reviewed by the Quality Assurance Division. Final approval of procedures and revisions to these Manuals is by the responsible Department, or Function Head, and the Manager Quality Assurance. 2.7 UE Company may employ the safety-related services of arenitect engineers, NSSS suppliers, fuel fabricators, constructors, and others which provide or augment UE efforts during the operating phase. These organizations shall be required to work under a quality assurance program whose controls are consistent with the scope of their effort. This does not preclude any organization from working under the UE OQAP. The quality assurance program of outside organizations shall be subject to review, evaluation and acceptance by the UE Company Quality Assur-ance Division prior to the initiation of safety-related Rev. 10 6/87

c OQAM work. Vendor programs and procedures shall also meet UE's commitment to USNRC Generic Letter 83-28. l 2.8 Disputes which may arise between QAuor QC personnel and personnel in other UE organizations which cannot be re-solved shall be referred to the next higher level of management for resolution. Disputes which cannot be resolved through these levels shall be resolved ultimately by the Executive Vice President. l 2.9 Preservice (PSI) and inservice (ISI) inspection, testing, and examination activities may be performed by outside organizations. These inspections and other operating phase

          " code" activities shall comply with the requirements of the applicable Code Edition and Addenda of the ASME Boiler and Pressure Vessel Code. This compliance includes the inde-pendent third-party inspection coverage of " code" items by an Authorized Nuclear Inspector.

l 2.10 General indoctrination and training programs shall be developed for personnel performing safety-related activi-ties to assure that responsible functions, departments, and individuals are knowledgeable regarding quality policy and requirements of applicable manuals and procedures. The requirements for training of Callaway Plant personnel are described in Section 13.2 of the Callaway-SA FSAR. The training of permanent Plant personnel is the responsibility of the Superintendent, Training. UE personnel performing complex, unusual, or hazardous work shall be instructed in special indoctrination or briefing sessions. Emphasis shall be on special requirements for safety of personnel, radiation control and protection, unique features of equipment and systems, operating constraints, and control requirements in effect during performance of work. Train-ing shall be conducted as required to, as a minimum, meet the requirements of UE's commitment to Regulatory Guide 1.8 (ANSI /ANS 3.1), Regulatory Guide 1.33 (ANSI N18.7), other Regulatory Guides as endorsed in OQAM Appendix A, and other regulatory requirements. Records of training shall be maintained as described in Section 17. Where required by code or standard, personnel are trained or qualified according to written procedures in the principles and techniques of performing specific activities. Special equipment, environmental conditions, skills, or processes shall be provided as necessary for the effective implemen-tation of the OQAP. l 2.11 An audit system shall be established to assure management is advised of Program effectiveness. The implementation and effectiveness of the OQAP shall be assessed through an audit program of quality activities which includes design, procurement, modification, and operation. The Manager, Quality Assurance is responsible for a system of planned Rev. 10 6/87

OQAM audits to assure OQAP compliance, with a frequency commen-surate with the Program aspect's safety significance and in accordance with the requirements of Section 18. He is 1 responsible for conducting audits of offsite and onsite activities. Deficiencies identified during the audit process are reported to responsible management of the organization involved in the resolution and follow-up to assure corrective action. i l 2.12 The Vice President, Nuclear provides for an independent assessment of the scope, implementation, and effectiveness of the OQAP to assure compliance with policy, commitments, and the requirements of 10 CFR 50, Appendix B as set forth in this OQAM. This assessment shall be conducted biennial-ly and may be by representatives of other utilities, outside consultants, or UE management representatives. In addition, various reports are tsaued to the Vice President, Nuclear on a periodic basis to assist his independent assessment of the OQAP (e.g., semiannual QA report, and periodic QA audit reports). l 2.13 Implementation of OQAP controls over activities affecting quality assures achieving the objective of the UE Company OQAP to provide management with adequate confidence that activities affecting quality regarding the design, instal-lation, modification, and operation of the Callaway Plant are performed consistent with policy. Documentation of the accomplishment of OQAP objectives is maintained in the form of records of data and other information as necessary to support operation, maintenance, repair, modification, refueling, and inservice inspection. l 2.14 UE Management has established standards of performance which exceed those set forth by the Regulatory Agencies. As a management initiative in this area, UE has defined the word "must" to impose management directed performance standards in excess of and in addition to established Regulatory directed performance. From the viewpoint of UE employees and UE contractors, there is no difference in the degree of compliance mandated by use of the words "shall" or "must." Compliance with actions initiated by use of either "shall" or "must" is audited and surveilled by the QA Division. Failure to implement a "must" mandated activity requires corrective action in the same way as failure to implement a "shall" mandated activity. However, from an external viewpoint, internally imposed "must" requirements (i.e., those in excess of Regulatory require-ments) are not intended to be subject to enforcement action. "Must" is defined in Appendix A of this OQAM under Regulatory Guide 1.74. Rev. 10 6/87

m S OQAM Modifications to structures, systems, and components shall consider, as a minimum, the design bases described in the

 .          Callaway-SP and the 'Callaway-SA FSAR and the Technical Specifications. -Design criteria documents which are newly-issued or modified in the course of design or design changes    shall be reviewed by a        superintendent in the Nuclear Engineering Department for seismic and. quality group classification and selection of quality standards.

Design criteria documents consist of original Plant design criteria, system descriptions and other documents defining design input which change the Plant as described - in the FSAR. 3.8 Design activities shall include the correct translation of regulatory requirements and design bases into specifica-tions, drawings, written procedures, and instructions (design _ outputs) that define the design. Design analyses regarding reactor physics, stress, thermal, hydraulic, radiation, and accident analyses used to produce design output documents, shall be sufficiently detailed to permit an _ independent review by a technically qualified person. Analyses shall specify purpose, method, assumptions, design requirements, references, and units. When computer codes are employed, only verified codes shall be used in safe-ty-related design and design changes. 3.9 Procedures shall specify requirements for the review and approval of design changes by the organizations or individ-uals that performed the original design or Nuclear Engi-neering. Design control activities, including design changes, may be delegated to others provided they have access to background and technical information. Design control measures for design revisions shall be coinmensurate l with those applied to the original design. 3.10 Design activities shall also include: 1) reviewing the applicability of standards; 2) reviewing commercial or previously approved materials, parts or equipment for suitability of application; 3) reviewing the compatibility of materials used in the design; 4) reviewing the accessi-bility of equipment and components for inservice inspec-tion, maintenance, and repair; 5) specifying criteria for

            . inspection and test / retest; and 6) reviewing and approving procedures for special procesces.

3.11 The design process shall establish controls for releasing design documents which are technically adequate and accu-rate in a controlled manner with a timely distribution to responsible individuals and groups. Documents and revi-sions shall be controlled through the use of written procedures by the issuer, distributor, and user to prevent Rev. 10 6/87

o OQAM 3.14 Design verification, if other than by qualification testing of a prototype or lead production unit, shall be completed prior to release for procurement, manufacturing, construc-tion or . to another organization for use in other design activities. In those cases where this timing cannot be met, the design verification may be deferred, providing the justification for this action is documented and the por-tions of the design output documents based on the unveri-fled data are appropriately identified and controlled. Without verification, site activities associated with a design or design change must not proceed past the point where the installation would become irreversible (i.e., require extensive demolition and rework). The design verification shall be complete prior to relying upon the component, system, or structure to perform its safety-related function. 3.15 Action shall be initiated to correct errors found in the design process. Errors and deficiencies identified in approved design documents shall be documented and the process of their correction (i.e., review and approval) shall be controlled. These actions shall assure that changes to design or installed components are controlled. 3.16 Requests for design changes affecting safety-related structures, systems, and components may be originated by the unit staff, Nuclear Fuel or Nuclear Engineering. Design changes shall be processed by Nuclear Engineering. Design changes engineered by the site Nuclear Engineering group shall be the responsibility of the Assistant Manager, Nuclear Engineering. Design change efforts assumed by the General Offices Nuclear Engineering group shall be the responsibility of the Manager, Nuclear Engineering. l 3.17 Independent of the responsibilities of the design organiza-tion, the requirements of the Onsite Review Committee (ORC) and the Nuclear Safety Review Board (NSRB) as defined in the Technical Specifications shall be satisfied. Design changes require a safety evaluation which shall be reviewed by the ORC and approved by the Manager, Callaway Plant. In addition, changes in the facility as described in the FSAR which involve a change in the callaway Plant Technical Specifications incorporated in the license or an unreviewed safety question require review and approval by the NSRB and the Nuclear Regulatory Commission prior to implementation. When design is performed by an outside organization, UE shall perform or coordinate a review of the design for operability, maintainability, inspectability, FSAR commit-ment compatibility, test and inspection acceptance criteria acceptability, and design requirements imposed by Plant generating equipment. Rev. 10 6/87

F 00AM

 . l' 3.18    Safety evaluations which consider the effect of the design as described:in the design documents, shall be performed by the -responsible UE engineering organization or outside organization (s). These evaluations.shall include the basis for the determination - that the design change does not involve an unreviewed. safety question. As deemed necessary by the. evaluating organization, detailed analyses shall be performed to ' support._the bases of safety evaluations.

Safety evaluations approved by the Manager or Assistant Manager, Nuclear Engineering or outside organization are. submitted to the ORC. Changes involving the substitution of equivalent hardware require safety evaluations to assure that the design requirement changes a're consistent with and do not alter the design criteria specified in existing design documents. The engineering approval of design documents and safety evaluations prepared by. outside organizations shall be'by the outside organization. l 3.19 The ORC shall review design change safety evaluations to recommend final approval of. design changes. Design changes-which involve an unreviewed safety' question or a change in the-Technical Specifications shall be forwarded to the NSRB for- review. An application for amendment of the license shall be submitted to the Nuclear Regulatory Commission for approval pursuant to 10 CFR 50.90. l 3.20 The NSRB shall review safety evaluat' ions to verify that changes did not iqvolve unreviewed safety questions. l 3.21 Procedures and instructions related to equipment or systems that are modified shall be reviewed and updated to reflect the modification prior to placing the equipment or systems in operation to perform safety-related functions. Plant personnel shall be made aware of changes affecting the performance of their duties through procedure revisions, or specific training in the operation of modified equipment or systems, or other appropriate means. l 3.22 Records shall be maintained which reflect current design including safety analyses, safety evaluations, design change installation procedures, material identification documents, procurement documents, special process docu-ments, equipment and installation specifications, and as-built drawings. Rev. 10 6/87

OQAM l 3.23 Drawings shall be prepared under a drawing control system which provides for checking methods and review and approval requirements. Drawings shall be subject to reviews by the responsible design organization for correctness, confor-mance to design criteria, and compliance with applicable codes and standards. Rev. 10 6/87 .

OQAM 6.0 DOCUMENT CONTROL 6.1 Documents and their revisions which control all activities affecting safety-related structures, systems, and compo-nents shall be prepared, reviewed by knowledgeable individ-uals, and approved by authorized personnel prior to release or issuance in accordance with written approved procedures. 6.2 Functions, departments, and organizations responsible for OQAP implementing documents shall be required to provide the necessary review and approval for instructions, proce-dures, specifications, and drawings. Reviews and approvals shall assure that issued documents are adequate, author-ized, include proper quality and technical requirements, and are correct for intended use. Individuals or groups responsible for preparing, reviewing, and approving documents and revisions thereto shall be identified in written procedures. Specifically, the QA Division shall review Administrative Procedures as described in Section 2.6; the QC, Group shall review maintenance and modification procedures; and the QC Group is responsible for the preparation of inspection procedures and/or checklists to support maintenance and modification activities. Collec-tively, these reviews by the QA Division and the QC Group determine:

1. The need for inspection, identification of inspection personnel, and documentation of inspection results; and

2. That the necessary inspection requirements, methods, and acceptance criteria have been identified.

6.3 Changes to documents shall be reviewed and approved by the same function, department, group, or organization that performed the original review and approval; however, UE may assume or delegate this responsibility. The reviewing organizations shall have access to pertinent background information upon which to base their approval and shall have adequate understanding of requirements and intent of the original document. 6.4 Documents relating to the UE OQAP shall be controlled to an Work Requests (WRs) and preventive maintenance requests (PMRs) may contain instructions to workers. However, WRs and PMRs are not considered " maintenance procedures" which require QC review. When required, the assignment of inspection points for work authorizing documents is performed by Planning Department personnel based on established criteria. Rev. 10 6/87

OQAM idocumentation, 'or other suitable . means; 3) suppliers of commercial- grade items able to - be ordered solely on . the basis 'of published product descriptions (catalog informa-tion); and 4)- outside . organizations working under-the UE OQAP. Regardless of the basis for the acceptability of the: procurement _ source, prior to the issuance of a~ purchase order or execution of a contract or ESA, a verification of the supplier /outside organization's acceptability shall be documented. Except in unusual circumstances (e.g. replace-ment parts are needed to preclude the development of some unsafe or undesirable condition), an evaluation of a Supplier's acceptability as a procurement source shall be accomplished prior to award. In the case of. purchase orders, the supplier shall be verified as an acceptable procurement source for the item or service being procured. Purchase orders may be issued prior to an assessment of suppliers' capability provided a prohibition on . safe-ty-related work is imposed. Such suppliers may be released to begin safety-related work when evaluated to be an acceptable procurement source. 7.4 To support the ' control of purchased material, copies of purchase orders and other appropriate procurement documents shall be forwarded to the applicable receiving or accep-tance point. Departments receiving or utilizing . procured  ! items or services shall establish measures to maintain and control procurement documents until the items or services are received and accepted. These documents shall-include purchase orders, drawings and specifications, approved changes, and other related documents. 7.5 Without any further evaluation,the suppliers to UE or its agents during the design and construction phase may be regarded as qualified procurement sources for replacement parts during the first three years of Callaway's operating phase as the procurement source evaluation measures em-ployed previously have identified these suppliers as qualified procurement sources. Callaway's operating phase began en June 11, 1984 with issuance of the Operating License. , 7.6 Procurement source evaluation and selection involves the Quality Assurance Division and the originating organiza-tion. The evaluation and selection process shall be specified in Quality Assurance Division procedures and may vary depending on the complexity and relative importance to safety of the item or service. Nuclear Engineering, Nuclear Fuel, Nuclear Services, the unit staff or other organizations may be requested to provide input to the qualification evaluations of suppliers. Suppliers of hardware and services which are manufactured prior to o award, considered a commercial grade item, or implemented Rev. 10 6/87

OQAM under-the:OQAP do not require pre-award source evaluation audits which attest to a suppliers capability as a procure-ment source. l ' 7. 7 - Procurement source evaluations shall consider one or more of'the following:

1. Experience.of users of identical.or similar products of

                                              'the prospective supplier. NRC Licensee Contractor and Vendor Inspection Program -(LCVIP) reports, ASME Certif-icates       of Authorization,                                       Coordinating Agency                            for Supplier 3 valuation                                      (CASE)          register                 listings,          UE records accumulated. in previous procurement actions, and UE product; operating. experience may be used in this evaluation.                            Supplier history shall. reflect recent capability. Previous favorable quality experience with suppliers may: 'be an adequate basis for judgements attesting to their capability. When an LCVIP letter of confirmation or the CASE register listing is. used to establish a supplier's . acceptability as a procurement source, the documentation shall identify the " letter" or " audit" use'd.

2. An evaluation ~.of the supplier's currentsquality records supported . by documented qualitative and. quantitative

                                                                                                               ~

e information which can be objectively evaluated. _ This - may. include-review and evaluation of the supplier's QA P r o g r a m ,' . M a d u a l , and Procedures, as appropriate; ' and ! responses to questionnaires.

3. A source evaluation of - the supplier's technical and

.; a quality capability as determined by a direct evaluation

. (audit. or surveillance) of facilities, personnel and

• _S Quality Assurance Program implementation.  ;

7.8 Procurement sour'ce evaluations involve a review of techni-and quality assurance Technical cal considerations. considerations include the design or manufacturing capabil-f- O ity. and technical ability of suppliers to produce or provide the design, service, item, or component. Quality i ~ Assurance considerations include one of the previously defined methods of supplier evaluation and a consideration 4

                              - of changes in a supplier's Quality Assurance Program or i

capabilities. The measures employed to evaluate a suppli-er's continued acceptability as a procurement source (after the initial source' evaluation) are described in Section 18. 7.9 Nuclear Engineering, Quality Assurance, Nuclear Fuel, Nuclear Services, Nuclear Safety and Emergency Prepared-ness, and the unit staff perform bid evaluations in accor-

                                ~ dance with documented                                      procedures.                      These organizations shall initiate and coordinate bid evaluation activities for those proposals received in response to procurement docu-Contracts initiated for nuclear ments initiated by them.

Rev. 10 6/87

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                                          .OQAM 9.O   CONTROL'OF SPECIAL PROCESSES 19.1    Special' processes are fabrications,                                            tests,   and final preparation processes which require the qualification of
              . procedure,1 technique r and personnel and which are performed                                                    I in accordance with applicable codes and standards. Special                                                       I processes require in-process controls in addition.to final
              -inspection to assure quality.

9.2 Epecial processes include such activities as welding,. heat treating, nondestructive . examination, the application of specialized coatings, and chemical cleaning, and shall be accomplished .under . controlled conditions by qualified

               . personnel in accordance with the technical requirements of applicable codes,      standards,                       specifications,                    or. .other special requirements to which UE is committed.                                             Qualified-personnel and approved procedures shall be employed.

Procedures for'special processes shall be qualified as part of their approval process; personnel qualifications shall be certified;~ and equipment shall be qualified prior to use. The responsible Plant Department Head shall assure that personnel performing special processes are . qualified and are employing approved procedures. Procedures shall also be . established for recording evidence of acceptable accomplishment of special processes using qualified proce-dures,- ' equipment, and personnel. The Quality Control organization shall be responsible for assuring that person-nel performing nondestructive examinations are qualified , and are employing approved procedures. Nondestructive examination (NDE) personnel shall be qualified in accor-dance with procedures established to meet the requirements of the Code Edition and Addenda to which UE is committed at the time the NDE is performed. When non-code NDE is performed, personnel shall be qualified to the version of SNT-TC-1A used to meet'UE's current commitment to the ASME B&PV Code. 9.3 Special process equipment that.may require periodic adjust-ment and whose performance cannot be verified through direct monitoring of appropriate parameters shall be [ !- subject to the controls described in Section 12. L L 9.4 Qualified outside organizations may be employed to perform L [ special~ processes-onsite and shall be required to conform to the requirements described herein. Special process l procedures ~ submitted by ' these organization (s)' in accordance with procurement document requirements shall receive a technical review by the responsible engineering organiza-tion and 'a quality review by the Quality Assurance Divi-i sion. r L: Rev. 10 i 6/87 _ . . , _ . . _ . . . . - - , - _ , , . ~ . _ _ _ , _ , ,_ ,a

OQAM testing, as appropriate, shall be employed as a means of verifying l suitable performance subsequent to a component replacement _or repair. 10.12 Instructions, procedures, and supporting documentation shall be provided to inspection personnel for use prior to performing inspection activities. Inspection results shall be documented. Procedures-shall prescribe the review and approval authority for inspection results. 10.13 Nuclear Engineering shall be responsible for assuring the development of preservice and inservice (PSI /ISI) inspec-tion programs; .the reference PSI /ISI examination plans for ASME Code Class 1, 2, and 3 systems and components includ-ing steam generator eddy current examination; the NDE procedures required by the reference plans; and the initial updating of the reference plans and procedures to reflect "as-built" conditions and the technical requirements of the applicable Code Edition and Addenda prior to the issuance of the inservice inspection plans and procedures. 10.14 Nuclear. Engineering shall be responsible for assuring the development of the inservice testing program plan for pumps and valves, the test procedures. required by this plan, and

          ,the  securing of consulting services      in this area.      In addition Nuclear Engineering      shall be responsible      for administering and- performing      the PSI /ISI' program   and implementing the examination and testing plans developed within the Nuclear Function. They are also responsible for updating the reference plans and NDE procedures subsequent to the   issuance of the     inservice inspection plans     and procedures. . The services of an outside organization may be l        secured to conduct the PSI /ISI examinations.

s t l i r l' Rev. 10 6/87

OQAM 11.0 TEST CONTROL 11.1 Testing shall be performed to demonstrate that safety-related structures, systems, and components will. perform satisfactorily in service. Testing programs include such tests as initial startup testing, surveillance tests, ISI pump and valve tests, and other tests, including those associated with Plant maintenance, modification, procedure changes, failure analysis, and the acceptance of purchased material. A test is performance of those steps necessary to determine that systems or components function in accor-dance with predetermined specifications. 11.2 Testing programs shall be established to demonstrate item or system performance. Testing shall be performed in accordance with written procedures which incorporate or reference the requirements and acceptance limits contained l in applicable Callaway Plant Technical Specifications, drawings, instructions, procurement documents, specifica-tions, codes, standards, and regulatory requirements. 11.3 Administrative procedures, test procedures, or checklists shall include: provisions for assuring all prerequisite conditions are met; test equipment calibration require-ments; testing method instructions; limiting conditions and acceptance / rejection criteria; and data collection and test result approval requirements. 11.4 Personnel within the various UE organizations may perform testing activities including implementing test procedures and the evaluation and reporting of test results. The assignment of Plant testing personnel shall be under the direction and control of the General Manager, Nuclear Operations. The qualification of QC testing personnel shall be defined in three levels of capability as described in ANSI N45.2.6. Other members of the unit staff perform-ing " testing" activities shall have appropriate experience, training, and retraining to assure competence in accordance with ANSI /ANS-3.1. Testing assignments shall be consistent with the qualification of an individual. In instances where the education and experience recommendations are not met by QC testing personnel who are to be certified to ANSI N45.2.6, UE shall demonstrate by documented results of written examinations and. evaluations of actual work profi-ciency that individuals possess comparable or equivalent competence. 11.5 A program shall be established to assure testing activities are performed by personnel trained and qualified to a capability necessary for performance of the activity. Plant procedures and procurement documents shall prescribe the qualification requirements for testing personnel. The Rev. 10 6/87

OQAM Superintendent, Training shall be responsible for providing related technical and quality training for UE personnel who perform testing. 11.6 Personnel from outside organizations or UE personnel who are not members of the unit staff who perform other testing activities associated with safety-related items at the Callaway Plant shall either be certified as required by ANSI N45.2.6 or they shall meet the education and experi-ence requirements applicable to the equivalent position on the unit staff for the activities which they are perform-ing. 11.7 When contractors or vendors are retained to perform work activities or to provide services associated with safety-related items at the Callaway Plant, the qualification of testing personnel and the conduct of tests associated with that contracted work activity or service shall meet the requirements stipulated in the applicable procurement documents. As an example, if a vendor were contracted to conduct testing of the main steam line safety valves at the Callaway Plant, then the persons performing the testing / valve settings would be qualified as required by the vendor's quality assurance program unless otherwise speci-fled in the applicable procurement documents. 11.8 Test results shall be documented, reviewed, and approved by qualified individuals or groups. Equipment found to be deficient shall be identified in accordance with Section

14. Surveillance test procedure results which fail to meet l the requirements and acceptance criteria of Callaway Plant Technical Specifications shall be documented and reviewed in accordance with Section 15. Deficiencies identified as nonconforming shall be processed in accordance with Section 15.

11.9 Review and approval of tests and experiments not described in the FSAR shall be conducted as specified in the Callaway Plant Technical Specifications and 10 CFR 50.59. 11.10 Provisions shall be established for the performance of surveillance testing to assure that the necessary quality of systems and components is maintained, that facility operations are within the safety limits, and that limiting conditions for operation can be met. The testing frequency l shall be as prescribed in the Callaway Plant Technical Specifications. The provisions for surveillance testing shall include the preparation of a surveillance testing schedule (s) which reflects the status of in-plant surveil-lance tests. Qualified personnel shall perform surveil-lance tests. Rev. 10 6/87

r OQAM-l _11.11 Appropriate tests . shall . also be performed subsequent. to Plant modificaticns, maintenance or significant operating procedure changes to confirm expected results. Tests provide a level of confidence in structure, system o ro. component operation or functional acceptability. l 11.12 When required by procurement documents, testing shall be employed as a means of purchased material and equipment acceptance. Acceptance testing of this nature shall be performed during _ receiving inspection or subsequent to installation in accordance with-Section 7. I 11.13 Equipment failure or malfunction analysis testing may also be performed. The causes of malfunctions shall be investi-gated, evaluated, and recorded. Experience with malfunc-tioning equipment and similar components shall be reviewed and evaluated to determine whether a like kind replacement component can be expected to perform its function reliably. i I f Rev. 10 6/87

OQAM 4 12.0 CONTROL OF MEASURING AND TEST EQUIPMENT 12.1 Measuring and test equipment utilized in activities affect-ing quality shall be controlled in accordance with written procedures or instructions. The procedures for calibration and control shall address the identification of test equipment, calibration techniques, calibration frequencies, maintenance control, and storage requirements. The equip-ment subject to these controls includes: (1) M&TE (port-able measuring instruments, test equipment, tools, gages, and non-destructive test equipment used in measuring and inspecting safety-related structures, systems, and compo-nents) ; (2) reference standards (primary, secondary, trans-fer, and working) ; and (3) permanently installed process instrumentation (PI). 12.2 M&TE and reference standards shall be tagged or labeled indicating the date of calibration and the due date for recalibration. 12.3 Permanently installed process instrumentation shall be afforded the control measures described herein consistent with the surveillance testing program and preventive maintenance program. 12.4 The calibration and control program established at the Callaway Plant shall assure that M&TE, reference standards, and PI maintain their required accuracy. The Assistant Manager, Operations and Maintenance is responsible for l assuring the program establishment. Program implementation is the responsibility of the appropriate Department Heads. 12.5 M&TE, reference standards, and PI shall be utilized by various organizations as required to perform tests or other special operations. Each organization shall be responsible for assuring that the M&TE or reference standards it uses have been calibrated. Outside organizations using M&TE or reference standards at the Callaway Plant in activities affecting quality shall be required to implement a UE reviewed and accepted calibration and control program incorporating the applicable requirements of this Section. Vendors who do not perform onsite activities need not have a program that addresses items 8 and 9 of Section 12.6, unless specified in procurement documents covering the vendor's services. When a vendor or contractor has been evaluated as acceptable to provide products or services in accordance with the measures defined in Sections 4 and 7 of this OQAM, the requirement to have a UE reviewed and accepted calibration program shall be deemed fulfilled. Other UE organizations (e.g. relay testing, battery test-ing) using M&TE or reference standards at the Callaway Plant in activities affecting quality shall be required to implement a calibration and control program consistent with Rev. 10 6/87

OQAM 15.5 Material nonconformance disposition categories shall include:

1. "Use as is" or " acceptable" (including conditional releases)

2. " Reject" or "not acceptable, scrap or return to vendor"

3. " Rework" in accordance with approved procedures

4. " Repair" in accordance with approved procedures 15.6 Material nonconformances which would impact the conduct of a test shall be corrected or resolved prior to initiation of the test on the item. The decision to proceed with the testing of a system or subsystem with outstanding material nonconformances shall consider the nature of the nonconfor-mance, its effect on test results, and the need for supple-mental tests or inspections after correction of the noncon-formance. These evaluations shall be documented.

15.7 Plant and other UE organization's procedures shall pre-scribe measures for the control and disposition of UE purchased items and services identified by outside organ-izations as nonconforming. Procurement documents shall specify those nonconformances to be submitted to UE for approval of the recommended disposition. As specified in procurement documents, actions taken in response to these nonconformances shall be documented and forwarded to UE along with the hardware and accompanying quality verifica-tion documentation. Nuclear Engineering shall be responsi-ble for assuring the processing of supplier-recommended dispositions for Plant initiated procurements. Similarly, other UE or outside organizations shall approve or be requested to provide a technical evaluation regarding supplier-recommended dispositions of nonconformances regarding procurements they initiate. An approved disposi-tion of a nonconformance which allows a reduction in the requirements of a safety-related structure, system, or component, shall be treated as a design change subject to the controls prescribed in Section 3. 15.8 The Manager, Operations Support shall have material noncon-l formance summaries prepared semiannually and analyzed for potential adverse quality trends. These summaries shall be sent to the Quality Assurance Division for an independent review. The results of this review shall be reported to management. 15.9 Significant nonconforming conditions involving a defect or material noncompliance in a delivered component or service which could create a substantial safety hazard shall be reported to the Nuclear Regulatory Commission pursuant to the requirements of 10 CFR 21. Rev. 10 6/87

OQAM 16.0 CORRECTIVE ACTION 16.1 Measures shall be established to assure that conditions adverse to quality are promptly identified, reported, and corrected. Nonconformances shall be controlled in accor-dance with the requirements described in Section 15. 16.2 Conditions adverse to quality which impede the implementa-l tion or reduce the effectiveness of the Operating QA Program shall be controlled by the measures described herein. Adverse conditions may include noncompliance with procedural requirements; reportable occurrences required by regulations; adverse nonconformance trends; or deficiencies identified in the OQAP. Procedures shall provide instruc-tions for identifying, reporting, and initiating corrective action to preclude recurrence of adverse conditions. Within the UE corrective action program, a Request for Corrective Action (RCA) may be employed to document adverse conditions (such as those described above) within or between Nuclear Function Departments. A Corrective Action Report (CAR) shall be employed to document more significant adverse conditions, such as a recurring condition for which past corrective action has been ineffective or a signifi-cant breakdown in administrative and managerial control systems which could result in a system designed to prevent or mitigate serious events not being able to perform its intended function. Each of the Nuclear Function Managers is responsible for developing and implementing a program l for identifying and controlling adverse conditions. As a minimum each program shall provide for developing and l analyzing trends on a semiannual basis. An RCA may not need to be issued when corrective action is being monitored by an alternate, documented program. 16.3 Corrective action documents shall be transmitted to the responsible organization. The responsible organization shall investigate the findings and identify the cause(s) of the deficiency, and specify and initiate the action (s) necessary to correct the conditions and prevent recurrence. 16.4 Nuclear Engineering shall review documented conditions adverse to quality which involve design deficiencies or design changes which are recommended as corrective action. The ORC shall review adverse conditions identified at the Plant on CARS. Nuclear Fuel should review documented conditions adverse to quality for fuel-related issues. 16.5 The corrective action documents shall be closed out by verifying the implementation and adequacy of corrective action. Summaries of corrective action documents shall be reviewed for the effectiveness of the corrective actions taken and analyzed for potential adverse quality trends. These summaries and analyses shall be sent to the Quality Rev. 10 6/87

l

                                 .OQAM Assurance Division for an independent review. The results of this review shall be reported to management.           The Quality Assurance    Division  shall   periodically   prepare summaries of CARS and submit them to the NSRB and appropri-ate levels of management.

l 16.6 The Quality Assurance Division shall close out CARS by verifying the implementation and adequacy of corrective action. Copies of completed CARS shall be transmitted to l management to keep them apprised of conditions adverse to quality. 16.7 The close-out of corrective action documents shall be accomplished as promptly as practicable but shall occur l only af ter the corrective action taken has been verified. Verification may be accomplished through direct observa-tions, written communications, re-audit, surveillances, or other appropriate means. It is understood that the term

         " corrective action" includes remedial action necessary to correct the deficiency, as well as corrective action necessary to preclude recurrence.       The nature of the deficiency may be such that remedial actions need to be l      taken immediately whereas development and implementation of corrective action to preclude recurrence may take substan-tially longer.

16.8 Requests for Corrective Action (RCAs) or Correction Action Reports (CARS) and other corrective action documents which record defects in basic components or deviations from technical requirements in procurement documents shall be reviewed for reporting applicability under 10 CFR 21 and other Federal reporting requirements. Rev. 10 6/87

T OQAM specific training which develop competence for performing audits or surveillances. Training records shall provide a history of QA personnel training, evaluations, qualifica-tion, certifications, and retraining. ., 18.4 Personnel in the Quality Assurance Division shall be qualified in accordance with the requirements prescribed in Quality Assurance Division procedures. Lead Auditor qualification requirements shall include education or professional status, previous work experience or training, training received through UE, on-the-job performance and participation in surveillances or audits as an auditor, a qualification examination, and other factors applicable to auditing not defined by procedure. The qualification certification of Lead Auditors shall be based on an evalua-tion of these factors by the Manager, Quality Assurance. The maintenance of proficiency by Lead Auditors shall be accomplished by active participation in the audit process; a review of Program, codes, standards, procedures and other document revisions related to the OQAP; or participation in training programs. The Manager, Quality Assurance shall provide for annual assessments of each Lead Auditor to determine proficiency. As long Es a Lead Auditor is performing satisfactorily and is maintaining proficiency, there is no limit on the period of certification. However if at anytime the Lead Auditor's performance is evaluated as being unacceptable, Lead Auditor certification shall be rescinded. In addition the failure to maintain proficiency for a period of two years or more shall be basis for Lead Auditor certification revocation. If certification is rescinded or revoked, requalification shall be required prior to recertification. 18.5 The Manager, Quality Assurance shall be responsible for assuring the implementation of a comprehensive system of planned audits to verify compliance with the OQAP. The Manager, Quality Assurance has sufficient authority and organizational freedom to schedule and perform both inter-nal and external audits. He has the organizational respon-sibility to measure and assure the overall effectiveness of the OQAP and is independent of the economic pressures of production when opposed to safety or quality. The Manager, Quality Assurance has direct access to the Vice President, Nuclear and the General Manager, Quality Systems. The General Manager, Quality Systems has direct access to the Executive Vice President. 18.6 The Manager, Quality Assurance is responsible to the General Manager, Quality Systems for assuring the OQAP is being ef fectively implemented for operating activities and supervises superintendents, Quality Assurance who direct full attention to this effort. The Manager, Quality Assurance shall be knowledgeable and experienced in nuclear Rev. 10 6/87

OQAM 18.12 Applicable elements of suppliers' quality assurance pro-grams shall be audited (post-award) on a triennial basis. Audits generally should be initiated when sufficient work is in progress to determine whether the organization is complying with the established quality assurance provi-sions. Subsequent contracts or contract modifications which significantly enlarge the scope of activities by the same supplier shall be considered in establishing audit requirements. In addition, the need for a triennial audit may be precluded upon evaluation and documentation by the QA Division that the results of mini-audits performed during source inspection and source surveillance activities confirm the adequacy and implementation of the supplier's QA Program. 18.13 Supplementary to audits, annual evaluations of suppliers shall be performed which take into account, as applicable:

1) the review of supplier furnished documents such as certificates of conformance, nonconformance notices, and corrective actions; 2) results of previous source verifica-tions, audits, and receiving inspections; 3) operating experience of identical or similar products furnished by the same supplier; and 4) results of audits from other

   .       sourCOs.

18.14 Audits shall also be conducted when: 1) significant changes are made in functional areas of the Quality Assur-ance Program such as significant reorganization or proce-dure revisions; or 2) when it is suspected that the quality of the item is in jeopardy due to deficiencies in the Quality Assurance Program; or 3) when a systematic, inde-pendent assessment of Program effectiveness is considered necessary; or 4) when it is necessary to verify implementa-tion of required corrective action. The NSRB shall selec- , tively review audit reports of onsite audits. The NSRB shall also periodically review the onsite audit program as developed by the Quality Assurance Division, to assure that audits are being performed in accordance with Callaway Plant Technical Specification requirements and the OQAP. Appropriate levels of management shall be provided copies of internal and external audit reports. The audits l described in the Callaway Plant Technical Specifications which are performed under the cognizance of the NSRB shall be conducted by the Quality Assurance Division. 18.15 Audits shall be conducted using written plans in accordance with Quality Assurance Division procedures. The procedures require evaluation of work areas, activities, processes, goods, services, and the review of documents and records for quality-related practices, procedures, and instructions to determine the effectiveness of the implementation of the l OQAP and compliance with 10 CPR 50, Appendix B and the l l Callaway Plant Technical Specifications. The audit plan Rev. 10 6/87

~ OQAM j shall identify the audit scope, the requirements, the activities to be audited, organizations to be notified, the applicable documents, the schedule, and the written proce-dures or checklists as appropriate. The audit plan and any necessary reference documents shall be available to the audit team members. 18.16 An audit team consists of one or more auditors. A Lead Auditor shall be appointed Audit Team Leader. The Audit Team Leader shall be responsible for the written plans, checklists, team orientation, audit notification, pre-audit conference, audit performance, post-audit conference, reporting, records, and follow-up activity to assure corrective action. Any adverse findings shall be reported in a post-audit conference with team members and the audited organization subject to the clarification of Section 4.3.3 of ANSI N45.2.12 in Appendix A. When a post-audit conference is held it shall be, to discuss items and arrive at a general agreement on the identification of the findings. Formal audit reports shall be prepared and submitted to the audited organization within thirty days after the post-audit conference or last day of the audit, whichever is later. 18.17 Audit results shall be periodically reviewed by the Quality Assurance Division for quality trends and overall Program effectiveness. Results of these reviews shall be reported to appropriate management in periodic summary reports of audit activities. l l l l 1 Rev. 10 6/87

OQAM APPENDIX A UE may use additional non-Callaway employees or contract personnel to augment the unit staff. These persons may or may not report to the Manager-Callaway Plant. These groups include, but are not limited to, UE personnel from other plants as well as supplemental HP and I&C technicians and QC inspectors. When used to perform safety-related activities, these personnel shall meet the education and experience requirements of ANSI /ANS 3.1 - 1978 for equivalent positions or else they shall meet the requirements for certification as inspection, examination or testing personnel as set forth in UE's commitment to ANSI N45.2.6-1978 given elsewhere in this Appendix. REGULATORY GUIDE 1.28 REVISION 2 DATED 2/79 Requirements (Design Construction) Quality Assurance Program and (Endorses ANSI N45.2-1977) DISCUSSION: This Regulatory Guide is not applicable to the operating phase. REGULATORY GUIDE 1.30 INITIAL ISSUE DATED 8/72 Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electronic Equipment (Safety Guide 30) (Endorses ANSI N45.2.4-1974/IEEE 336-1971) DISCUSSION: UE complies with the recommendations of this Regulatory Guide with the following clarifications: l For maintenance and modification activities UE shall comply with the Regulatory Position established in this Regulatory Guide in that QA programmatic / administrative requirements included therein (subject to the clarifications below) shall apply to these maintenance and modifi-cation activities even though such requirements may not have been in effect originally. Technical requirements associated with the mainte-nance and modifications shall be equal to or better than the original requirements (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection requirements) , or as required to preclude repetition of defects. Specific clarifications for ANSI N45.2.4 - 1972 are indicated below by sections.

 ' Section 1.4 - Definitions in this Standard which are not included in ANSI N45.2.10 shall be used; definitions which are included in ANSI N45.2.10 shall be used as clarified in UE's commitment to Regulatory Guide 1.74.

Section 2.1 - Planning requirements, as determined by engineering, shall be incorporated into modification procedures. Engineering actions performed in accordance with this Section of the Standard are A-2 Rev. 10 6/87

OQAM APPENDIX A conducted with QA/QC involvement and are subject to QA audit. Proce-dures for these activities receive a cross-disciplinary review as well as review by the Onsite Review Committee (QA is a permanent member of this committee) . For other activities, QA audits and surveillances, and QC inspection activities assure QA/QC involvement. Section 2.3 - Procedures and Instructions shall be implemented as set forth in OQAM Sections 2, 3, 5, 10 and 11 and by compliance with the Callaway Plant Technical Specifications and Regulatory Guide 1.33 (ANSI N18.7) as set forth in this Appendix in lieu of the requirements set forth here. When compliance with an NRC accepted program (e.g., Callaway Plant Technical Specifications) is referenced, UE has substi-tuted the NRC accepted program for applicable regulatory requirements in lieu of the general requirements of the Quality Assurance program standards. Section 2.4 - Results shall be implemented as set forth in OQAM Sections 10, 11 and 17 and by compliance with ANSI N18.7 as set forth in this Appendix in lieu of the requirements set forth here. In every caso either identical or equivalent controls are provided in the sections of the referenced Standards or documents. Section 2.5.2 - Calibration and Control covers three classes of instrumentation used by UE: (1) M&TE (portable measuring instruments, test equipment, tools, gages, and non-destructive test equipment used in measuring and inspecting safety-related structures, systems, and components); (2) reference standards (primary, secondary, transfer, and working) ; and (3) permanently installed process instrumentation (PI). With respect to the first sentence, M&TE and reference standards shall be included in a calibration program and shall either be calibrated at prescribed intervals or shall be calibrated prior to use. With respect to the last sentence, personnel shall be trained and proce-dures shall require that the calibration label or tag shall be re-viewed to determine calibration status prior to use: This label or tag shall be considered to clearly identify equipment which is out of calibration. Lack of a label or tag shall require the organization responsible for calibrating the M&TE to review records and affix a new label or tag based on calibration data. M&TE and reference standards shall comply with sentences 2, 3 and 4. With respect to the 3rd sentence, UE uniquely identifies each safety-related item of permanently installed process instrumentation. This identification provides traceability to calibration data. These actions are UE's alternative to the tagging or labeling of items to indicate the calibration date and the identity of the person who performed the calibration. Permanently installed process instrumenta-tion shall comply with sentonces 1, 2, and 5. Section 3 - Preconstruction Verification shall be implemented as follows: (1) shall be required only for modifications (2) shall be implemented with the clarification that " approved instruction manuals" A-3 Rev. 10 6/87

k OQAM APPENDIX A shall be interpreted to mean the manuals provided by the supplier as required by the procurement order - these manuals are not necessarily reviewed and approved, per se, by UE: (3) no special checks shall be required to be made by the person withdrawing a replacement part from the warehouse - equivalent controls are assured by compliance with Regulatory Guide 1.38 (ANSI N45.2.2) as set forth in this Appendix; and, (4) shall be complied with as determined by engineering or by individual technicians as part of the modification process. Engineer-ing actions performed in accordance with this Section of the Standard are conducted with QA/QC involvement and are subject to QA audit. Procedures for these activities receive a cross-disciplinary review as well as review by the Onsite Review Committee (QA is a permanent member of this committee). For other activities, QA audits and surveillances, and QC inspection activities assure QA/QC involvement. Section 4 - Installation shall be implemented as stated and as fol-lows: Engineering actions performed in accordance with this Section of the Standard are conducted with QA/QC involvement and are subject to QA audit. Procedures for these activities receive a cross-disciplinary review as well as review by the Onsite Review Committee (QA is a permanent member of this committee). For other activities, QA audits and surveillances, and QC inspection activities assure QA/QC involvement. Section 5.1 - Inspections, including subsections 5.1.1, 5.1.2, and the first sentence in 5.1.3, shall be implemented as set forth in OQAM Section 10. The inspection program shall incorporate, as determined by engineering and QC, those items listed in thica subsections. The remaining sentence in 5.1.3 is covered in equivalent detail in UE's commitment to Regulatory Guide 1.33 ( ANSI N18. 7) , Section 5.2.6; the requirements as set forth in that commitment shall be implemented in lieu of the requirements stated here. In every case either identical or equivalent controls are provided in the Sections of the referenced Standards or documents. Section 5.2 - Tests, including subsections 5.2.1 through 5.2.3, shall be implemented as set forth in 00AM Sections 3 and 11. In some casos Surveillance testing may be used to meet the appropriate requirements of this Section. Section 6 - Post-construction Verification is not generally considered applicable at operating facilities because of the scope of the work and the relatively short interval between installation and operation. Where considorod necessary by engineering or QC, the elements de-scribed in this Section shall be used in the development and implemon-tation of inspection and testing programs as described in OQAM Soc-tions 3, 10 and 11. Section 7 - Data Analysis and Evaluation shall bo implomonted as stated heroin after adding the clarifying phrase "Whero used" at the beginning of the paragraph. This clarification accounts for the fact that some testing will not gonorato " Data" as such. A-4 Rev. 10 6/87

r i

 '                                      OQAM j                                     APPENDIX A Section 8 - Records shall be implemented by conformance with OQAM Section 17 and Regulatory Guide 1.88 (ANSI N45.2.9) as set forth in this Appendix.

REGULATORY GUIDE 1.33 REVISION 2 DATED 2/78 Quality Assurance Program Requirements (Operation) (Endorses ANSI N18.7-1976/ANS 3. 2) DISCUSSION: UE complies with the recommendations of this Regulatory Guide with the following clarifications: Paragraph C.3 of Regulatory Guide 1.33 (and Section 4.3.4 of ANSI N18.7 which it references) shall be implemented as required by the l applicable Callaway Plant Technical Specifications which define

     " Subjects Requiring Independent Review."

Paragraph C.4.a of Regulatory Guide 1.33 (and Section 4.5 of ANSI N18.7 which it references) shall be implemented as required by the l applicable callaway Plant Technical Specifications which define the

     " audit program" to be conducted. The audit program is further defined and shall be implemented as required by the commitment to Regulatory Guide 1.144 (ANSI N45.2.12) as stated in this Appendix.

Paragraph C.5.d of Regulatory Guide 1.33 (and Section 5.2.7.1 of ANSI N18.7 which it references) shall be implemented by adding the clarify-ing phrase "When determined by engineering" in front of the fourth sentence of the fifth paragraph. It is not always practicable to test parts prior to use. For modifications where these requirements are l not considered practicable, a review in accordance with the provisions l of 10 CFR 50.59 shall be conducted and documented. Engineering

actions performed in accordance with this Section of the Regulatory Guide are conducted with QA/QC involvement and are subject to QA audit. Procedures for these activities receive a cross-disciplinary l review as well as review by the Onsite Review Committee (QA is a permanent member of ORC) . For other activities, QA audits and sur-veillances, and QC inspection activities assure QA/QC involvement.

Paragraph C.5.e of Regulatory Guide 1.33 and Section 5.2.13.4 of ANSI N18.7 which it references shall be implemented subject to the same clarifications made for Regulatory Guide 1.38 (ANSI N45.2.2). i Paragraph C.S.f of Regulatory Guide 1.33 (and Section 5.2.19(2) of ANSI N18.7 which it references) shall be implemented with the substi-tution of the word "practicablo" for the word "possible" in the last , sentence. The action referenced in this Section is the responsibility I of the callaway Plant Operating Organization, and includes QA/QC involvement. QA is involved through audit and survoillance activi-l ties. QC is involved in maintenance inspection activition. l A-5 Rev. 10 l 6/87

OQAM APPENDIX A Paragraph C.S.g of Regulatory Guido 1.33 (and Section 5.2.19.1 on ANSI N18.7 which it references) shall be implemented with the addition of the modifier "normally" after each of the verbs (should) which the Regulatory Guide converts to "shall." It is UE's intent to fully comply with the requirements of this paragraph, and any conditions which do not fully comply shall be documented and approved by manage-ment personnel. Management personnel includes QA through cross-disciplinary reviews and through QA permanent membership on the Callaway Onsite Review Committee. QA has and shall conduct audits or surveillances of preoperational testing. In casos where conditions do not fully comply, the reason for the exception shall also be document-ed. The documentation shall be retained as litatimo records. With regard to Section 3.4.2 of ANSI N18.7 - 1976 titled Requirements for the Onsite Operating Organization: Training standards referenced , in this Section are implemented as described in this Appendix's commitments to Regulatory Guide 1.8 (ANhI/ANS 3.1) and Regulatory Guide 1.58 (ANSI N45.2.6-1978) or as otherwise included as part of the Callaway operating license. UE's methods of documenting and otherwise meeting the remainder of the requirements of this Section are set l forth in OQAM Section 2, in the Callaway Plant Technical Specifica-tions, and in other licensing c:ommitments. Some of UE's technical support organizations are physically located at the callaway sito. Therefore the second sentence of this Section shall be implomonted as follows: " Initial incumbents or replacomonts for members of the onsite or offsite technical support organizations shall have appropriato experienco, training and retraining to assure that necessary competence is maintained in accordance with the provi-sions of ANSI /ANS 3.1 - 1978 as committed to in the 00AM." With rogard to Section 4.1 of ANSI N18.7 - 1976 titled General: The UE audit program shall be implomonted in accordance with and to moot the requiroments of Regulatory Guide 1.144 (ANSI N45.2.12) as endorsed l in this Appendix, 00AM Section 18, and the Callaway Plant Technical Specifications. With regard to Section 4.2 of ANSI N18. 7 - 1976 titled Program Do-scription: Two aspects are addressed in this Sections audits and indopundant reviews. The indopondant review program shall be implo-monted as required by the Technical Specifications. The UE audit program shall be described in accordance with and to meet the require-monts of Regulatory Guido 1.144 (ANSI N45.2.12) as endorsed in this l Appondix, the Callaway Plant Technical Specifications, and OQAM Section 18. With rogard to Section 4.3 of ANSI N18.7 - 1976 titled Indopondant Review Process: The requirements of this Section, including of its subparts, shall be mot by compliance with the Technical Specification requiromonts and the OQAM. With regard to Section 4.5 of ANSI N18.7 - 1976 titled Audit Programs The UE audit program shall bo implomonted in accordanco with and to A-6 Rev. 10 6/87

00AM APPENDIX A meet the requirements of Regulatory Guide 1.144 (ANSI N45.2.12) as l endorsed in this Appendix, the 00AM, and the Callaway Plant Technical Specifications. With regard to Section 5.1 of ANSI N18.7 - 1976 titled Program De-scription: The fourth sentence in this Section requires a " summary document." UE's OQAM is organized in accordance with the 18 criteria of 10 CFR 50, Appendix B. UE interprets this OQAM and applicable Regulatory Guides as endorsed in this Appendix to fulfill the require-ments for a " summary document." With regard to Section 5.2.2 of ANSI N18.7 - 1976 titled Procedure Adherence: The temporary change requirements of this Section are delineated in the Technical Specifications for activities occurring af ter the operating License (OL) is issued; the requirements of the l Callaway Plant Technical Specifications shall be used to control temporary changes. With respect to Section 5.2.6 of ANSI N18. 7 - 1976 titled Equipment control UE shall comply with the " independent verification" require-ments based on the definition of this phrase as given under our commitment to Regulatory Guide 1.74 in this Appendix. Since UE sometimos uses descriptive names to designato equipment, the sixth paragraph, second sentence is replaced with: " Suitable means include identification numbers or other descriptions which are trace-i able to records of the status of inspections and tests." The first sentence in the seventh paragraph shall be met after clari-fying " operating personnel" to mean trained employoos assigned to, or under the control of, Plant management at Callaway. With regard to Section 5.2.7 of ANSI N18.7 - 1976 titled Maintenance and Modification: UE shall interpret the word " original" in the first sentonce of this Section to modify ONLY the words " design bases." This interpretation is to assure that original inspection requirements are only required for modifications and maintenance that are similar in natura and extent to original construction activities. This makes this Section consistent with Section 5.2.17 of the Standard. Opera-tional inspection requirements shall be in accordance with UE's commitment to Section 5.2.17 of the Standard and, in conjunction with the use of qualified maintenance personnel and approved procedures, shall assuro quality at least as good as tho original quality. Sinco some omorgency situations could arise which might proclude proplanning of all activities, UE shall comply with an alternate to "Except in the first aantonco in the second paragraph which roads: omorgoney or abnormal operating conditions where immediato actions are required to protect the health and safety of the public, to protect equipmont or personnel, or to provent the datorioration of Plant conditions to a possibly unsafo or unstable level, maintonance or modification of equipmont shall be peoplanned and performed in accor-danco with writton proceduros. Where writton procoduron would bo A-7 Rev. 10 6/87

OQAM APPENDIX A required and are not used, the activities that were accomplished shall be documented af ter-the-f act and receive the same degree of review as if they had been preplanned." With regard to Section 5.2.7.1 of ANSI N18.7 - 1976 titled Maintenance Programs: UE shall comply with the requirements of the first sentence of the fifth paragraph, where practical. This clarification is needed since it is not always possible to promptly determine the cause of the malfunction. UE shall initiate proceedings to determine the cause, and shall make such determinations promptly, where practical. QA is involved via both audits and surveillances, and QC is involved in inspection of maintenance inspection activities. With regard to Section 5.2.8 of ANSI N18.7 - 1976 titled Surveillance Testing and Inspection Schedules In lieu of a " master surveillance schedule," the following requirement shall be met: " Schedules shall be established reflecting the status of in-plant surveillance tests and scheduled inspections." With regard to Section 5.2.9 of ANSI N18.7 - 1976 titled Plant Securi-ty and Visitor Control: The requirements of the Security Pler, shall be implemented in lieu of those general requirements. When colspliance with an NRC accepted program (e.g., Callaway Security plan) is refer-enced, UE has substituted the NRC accepted program for applicable regulatory requirements in lieu of the general requirements of the Quality Assuranco program standards. With regard to Section 5.2.10 of ANSI N18.7 - 1976 titled Housokeep-inq and cleanliness control: The requirements of this Section, beginning with the last sentence of the first paragraph and continuing through the end of the Section, shall be implemented as described in UE's commitments to Regulatory Guido 1.39 (ANSI N45.2. 3) and Regulato-ry Guido 1.37 (ANSI N45.2.1) as set forth in this Appendix. In every case oither identical or equivalent controls are provided in the Sections of the reference standards or documents. With regard to section 5.2.13.1 of ANSI N18.7 - 1976 titled Procure-mont Document control UE shall comply with the following sentence in lieu of the last santonce of the referenced Section. Where changos are made to the technical or quality specifications on procuremont documonts, they shall be subject to engincoring and QA review. With regard to Soction 5.2.17 of ANSI N18.7 - 1976 titled Inspection: Inspections may not require generation of a separato inspection report. Inspection requiromonta may be integrated into appropriato proceduros or other documents with the procedure or document serving as the record. However, records of inspections shall be identifiable and retriovable. A-8 Rev. 10 6/87

r i OQAM APPENDIX A With regard to Section 5.2.18 of ANSI N18.7 - 1976 titled Control of Special Processes: UE shall comply with the following sentence in lieu of the last sentence of the referenced Section. I For special processes not covered by existing codes or standards, or where item quality requirements exceed the requirements of established codes or standards, personnel, equipment and procedure qualification shall be defined by .l engineering. i With regard to Section 5.3.5(4) of ANSI N18.7 - 1976 titled Support-ing Maintenance Documents: UE may choose to include material from vendor manuals in any of throo ways. (1) The applicable section of a manual may be duplicated, referenced in, and attached to the proce-dure. (2) The procedure may reference the technical manual or a specific section; the manual may then be used in conjunction with the l procedure for performing the activity. (3) The material, either as originally written or as modified by the procedure's author, may be reproduced within the body of the proceduro. In options (1) and (2) above, the material shall be considered as having received "the same level of review and approval as operating procedures" by virtue of the review and approval of the maintenanco proceduro. In option (2), the manual shall be available when the procedura is being considered for approval. In option (3), this material receivos the same review and approval as the procedure since it is part of the proceduro. In any of the options, Union Electric is NOT reviewing and accepting the l entiro manual. UE reviews and accepts that portion of each vendor manual that is used by UE. With regard to Section 5. 3. 9 of ANSI N18.7 - 1976 titled Emergoney Proceduros UE's Energenci Procedures are in the format specified by the NRC in the Callaway Safety Evaluation Report, as required for issuance of the Operating Licenso, in lieu of the requirements given here. ! With regard to Section 5.3.9.2 of ANSI N18.7 - 1976 titled Events of l Potontial Emorgoney: The licensing FSAR identified natural occurrenc-os which affect the Callaway Plant. Thorofore, UE shall interpret item (11) to mean the natural occurrences which woro ovaluated in the licensing FSAR. With rogard to Soction 5.3.9.3 of ANSI N18.7 - 1976 titled Procodures i for Implomonting Emorgoney Plan: UE's NRC accepted Emergency Plan shall bo implomonted in lieu of the requirements in this Section. When complianco with an NRC accopted program (e.g., Callaway plant . Radiation Emorgency Rosponso Plan) is referenced, UE has substituted I the NRC accepted program for applicable regulatory requirements in i lieu of the gonoral requiromonts of the Quality Assuranco Program standards. l A-9 Rov. 10 l 6/87 L

OQAM APPENDIX A _ REGULATORY GUIDE 1.37 INITIAL ISSUE DATED 3/73 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants (Endorses ANSI N45.2.1-1973) DISCUSSION: UE complies with the recommendations of this Regulatory Guide with the following clarifications: l For maintenance and modification activities UE shall comply with the Regulatory Position established in this Regulatory Guide in that QA programmatic / administrative requirements included therein (subject to the clarifications below) shall apply to these maintenance and modifi-cation activities nven though such requirements may not have been in offect originally. Technical requirements associated with maintenance and modifications shall be equal to or better than the original requirements (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection requirements), or as required to preclude repetition of defects. Specific clarifications for this Regulatory Guide and ANSI N45.2.1 - 1973 are indicated below by Sections. With regard to Paragraph C.3 of Regulatory Guide 1.37: The watdr quality for final flushing of fluid systems and associated components shall be at least equivalent to the quality of the operating system water except for the oxygen and nitrogen content; but this does not infer that chromates or other additives, normally in the system water, are added to the flush water. With regard to Paragraph C.4 of Regulatory Guide 1.37: Expendable materials, such as inks and related products; temperature indicating sticks; tapes; gummed labels; wrapping materials (other than polyeth-ylono); water soluble dam materials; lubricants; NDT penetrant materi-als and couplants, dessicants, which contact stainless steel or nickel alloy surfaces shall not contain lead, zinc, copper, morcury, cadmium and other low melting points metals, their alloys or compounds as basic and ossential chemical constituonts. No more than 0.1 percont (1,000 ppm) halogens shall be allowed where such elements are loachable or where they could be released by breakdown of the com-pounds under expected environmental conditions. With regard to Section 5 of ANSI N45.2.1 - 1973 titled Installation cleaning: The recommendation that local rusting on corrosion resis-tant aiLoys be romoved by mechanical methods is interpreted to mean that local rusting may be removed mechanically, but the use of other romoval means is not orocluded, as datormined by engineering or Chemistry. Engineering actions performed in accordance with thin Section of the Standard are conducted with QA/QC involvement and are subject to QA audit. Proceduros for thoso activition receive a cross-disciplinary review as well as review by the Onsite Review A-10 Rev. 10 6/87

OQAM APPENDIX A Committee (QA is a permanent member of this committee). For other activities, QA audits and surveillances, and QC inspection activities assure QA/QC involvement. REGULATORY GUIDE 1.38 REVISION 2 DATED 5/77 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Water-Cooled Nuclear Power Plants (Endorses ANSI N45.2.2-1972) DISCUSSION: UE complies with the recommendations of this Regulatory Guide with the following clarifications: With regard to Section 1.4 of ANSI N45.2.2 - 1972 titled DeGnitions:

                                                                   ~

Definitions in this Standard which are not included in AN5l N45.2.10 shall be used; definitions which are included in ANSI N45.: .10 shall be used as clarified in UE's commitment to Regulatory Guide *. 74. With regard to Section 2.1 of ANSI N45.2.2 - 1972 titled Planning: (First sentence) The specific items to be governed by the Standard shall be identified in Callaway-SP FSAR Table 3.2-1, which lists those structures, systems and components to which the UE QA Program is applied. With regard to Section 2.3 of ANSI N45.2.2 - 1972 titled Results: The specific methods for performing and documenting tests and inspections are given in OQAM Sections 10 and 11. The requirements in these Sections shall bo implemented in lieu of the general requirements here. In overy case either identical or equivalent controls are provided in tho sections of the referenced Standards or documents. With regard to Section 2.4 of ANSI N45.2.2 - 1972 titled Personnel Qualifications: Specific requirements for personnel qualifications J are not forth in the OQAM description and in the commitments in this Appendix. These requirements shall be implemented in lieu of the general requirements stated in this Section. In every case either identical or equivalent controls are provided in the sections of the referenced Standards or document. With regard to Section 2.7 of ANSI N45.5.2.2 - 1972 titled Classifica-tion of Items: UE may chooso not to explicitly use the four level classification system. Howevor, the specific requirements of the Standard that are appropriato to each class are generally applied to the items suggestod in each classification and to similar items, as datormined by ongincoring. Engineering actions performed in accor-danco with this soction of the Standard are conducted with QA/QC involvemont and are subject to QA audit. Proceduros for those activi-tion rocoivo a cross-disciplinary review as well as review by the Onsite Review Committoo (QA is a permanent member of this committoo) . For other activition, QA audits and surveillancos, and QC inspection activities assuro QA/QC involvemont. A-11 Rev. 10 6/87

OQAM APPENDIX A With regard to Section 3.2.1 of ANSI N45.2.2 - 1972 titled Level A Items: As an alternate to the requirements for packaging and contain-erizing items in storage to control contaminants (Items (4) and (5)), UE may choose a storage atmosphere which is free of harmful contami-nants in concentrations that could produce damage to stored items, as determined by engineering. Similarly (for Item (7)) UE may obviate the need for caps and plugs, as determined by engineering, with an appropriate storage atmosphere, and may choose to protect weld-end preparations and threads by controlling the manner in which the items are stored. These clarifications apply whenever items (4), (5) or (7) are subsequently referenced and to Section 3.5.1 titled Caps and Plugs and Section 3.4 titled Methods of Prevention. Engineering actions performed in accordance with this section of the Standard are conduct-od with QA/QC involvement and are subject to QA audit. Procedures for those activities receive a cross-disciplinary review as well as review by the Onsite Review Committoo (QA is a permanent member of this l committee). For other activities, QA audits and surveillancos, and QC inspection activities assuro QA/QC involvement. With regard to Section 3.3 of ANSI N45.2.2 - 1972 titled Cleaning: (Third sentonco) UE interprets " documented cleaning methods" to allow generic cleaning procedures to be written which shall be implemented, as necessary, by trained personnel. Each particular cleaning opera-l tion shall be either governed by an individual cleaning procedure or by a generic procedure either of which shall specify method (s) of cleaning or type (s) of solvent (s) that may be used in a particular application. With regard to Section 3.4 of ANSI N45.2.2 - 1972 titled Methods of Proservation: (First sentence) UE shall comply with thesia require-ments subject to the clarifications of Section 3.2.1 (4) and (5) above, and the definition of the phrase "deletarious corrosion" to moan that corrosion which cannot be subsequently removed and which adversely affects form, fit, or function. With regard to Section 3.6 of ANSI N45.2.2 - 1972 titled Barrier and Wrap Material and Dossicants: This Section requires the use of nonhalogenated materials in contact with austenitic stainions stool. Rofer to Regulatory Guide 1.37 for the UE position. With regard to Section 3.7.1 of ANSI N45.2.2 - 1972 titled containers: Cloated, sheathod boxes may be used up to 1000 lbs. rather than 560 l lbs. as specified in 3.7.1(1) . This typo of box is safe for, and has I boon testod for, loads up to 1000 lbs. Other national standards allow l this (soo Fodoral Specification PPP-B-601). Special qualification l testing shall bo required for loads abovo 1000 lbs. 1 i With rogard to Soction 3.7.2 of ANSI 45.2.2 - 1972 titled Cratos and l Skids: Cratos shall be used for equipment in excess of 1000 lb. in woight. Skids or runners shall be used on boxes with a gross weight of approximately 100 lb. or more, allowing sufficient floor clearanco for forklift tinos (as nominally pr,ovided by 4 inch lumber). A-12 Rov. 10 6/87

OQAM APPENDIX A With regard to Section 4.2.2 of ANSI N45.2.2 - 1972 titled Closed carriers: The use of fully enclosed furniture vans, as recommended in (2) of this Section, is not considered a requirement. Stated for information only, UE shall assure adequate protection from weather or other environmental conditions by a combination of vehicle enclosure and item packaging. With regard to Sections. 4.3, 4.4 and 4.5 of ANSI N45.2.2 - 1972 titled, respectively, Procautions During Loading and Transit, Identi-fication and Marking, and Shipment from Countries outside the Unit-ed States UE shall comply with the requirements of these Sections subject to the clarifications taken to other Sections which are referenced therein. With regard to Section 5.2.1 of ANSI N45. 2.2 - 1972 titled Shipping Damage Inspection: Stores personnel shall normally visually scruti-nize incoming shipments for damage of the types listed in this Sec-tion; this activity is not necessarily performed prior to unloading. Since required items receive the Item Inspection of Section 5.2.2, separate documentation of the Shipping Damage Inspection is not necessary. Release of the transport agent after unloading and the signing for receipt of the shipment may be all of the only action taken to document completion of the Shipping Damage Inspection. Any nonconformanco noted shall be documented and dispositioned as required by 00AM Section 15. The person performing the visual scrutiny during unloading is not considered to be performing an inspection function as defined under Regulatory Guido 1.74; therefore, whilo ho shall be trained to perform this function, he may not necessarily be cortified to Regulatory Guido 1.58 (ANSI N45.2.6) an an Inspector. With regard to Section 5.2.2 of ANSI N45.2.2 - 1972 titled Item Inspection: The second division of this subsection requires six additional inspection activition if an item was not inspected or ' examined at the source. Engincoring shall determine and document the extent of receipt inopoction based on consideration of items in Section 5.2.2. Engineering actions performed in accordance with this section of the Standard are conducted with QA/QC involvemont and are subject to QA audit. proceduros for those activities rocoive a cross-disciplinary review as well as review by the Oncito Review Committoe (QA is a permanent member of this committoo). For other activition, QA audits and surveillancos, and QC inspection activitios assure QA/QC involvomont. With rogard to Section 6.1.2 of ANSI N45.2.2 - 1972 titled Lavoin of Storago: Subpart (2) is replaced with the following (2) Lovel D itomo shall bo stored within a fire resistant, weathertight, and well ventilated building or equivalent onclo-ouro in which measuros have boon taken against vandalism. This building shall bo situatod and constructed so that it is not normally be subject to flooding; tho floor shall be paved or equal, and wall drained. If any outside waters should como in contact with stored equipmont,such equipment shall be labolod or A-13 Hov. 10 6/07

OQAM APPENDIX A tagged nonconforming, and then the nonconformance document shall be processed and evaluated in accordance with OQAM Section 15. Items shall be placed on pallets or shoring or shelves to permit air circulation. The building shall be provided with heating and temperature control or its equivalent to reduce condensation and corrosion. Minimum temperature shall be 40' F and maximum temperature shall be 140' F or less if so stipulated by a manu-facturer. With regard to Section 6.2.1 of ANSI N45.2.2 - 1972 titled Access to Storage Areas Items which fall within the Level D classification of the standard shall be stored in an area which may be posted to limit access, but other positive controls such as fencing or guards shall not normally be provided, with engineering's concurrence. Engineering actions performed in accordance with this section of the Standard are conducted with QA/QC involvement and are subject to QA audit. Proce-dures for those activities receive a cross-disciplinary review as well as review by the Onsite Review Committoo (QA is a permanent member of this committee). For other activition, QA audits and surveillances, and QC inspection activities assure QA/QC involvement. With regard to Section 6.2.4 of ANSI N45.2.2 - 1972 titled Storage of Food and Associated Items: The sentence la replaced with the follow-ing: "The use or storage of food, drinks, and salt tablet dispensers in any storage area shall be controlled and shall be limited to designated areas where such use or storage is not deleterious to stored items, with engineering's concurrence." Engineering actions performed in accordance with this section of the Standard are conduct-ed with QA/QC involvement and are subject to QA audit. Procedures for those activition receive a cross-disciplinary review as well as review by the Onsite Review Committoo (QA is a permanent member of this committoo). For other activities, QA audits and surveillances, and QC inspection activition assure QA/QC involvement. With regard to Soction 6.2.5 of ANSI N45.2.2 - 1972 titled Measured go Provent Entrance of Animals: Tho sentonce is replaced with the following: "Extorminators or other appropriate measures shall be used to control animals to minimizo possibio contamination ond mechanical damage to stored material." With regard to Section 6.3.3 of ANSI N45.2.2 - 1972 titled Storage of Hazardoun Matorials: Tho santonce in replaced with the following:

 "llazardous chemicals, paints, solvonts, and other matorials of a like naturo shall bo stored in approved cabinots or containors which are not in closo proximity to installed safety-rolated systems."            The placoment of hazardous matorial storago lockors in the Plant is based upon installed safnty-related systoms, not particular components.

With rogard to Section 6.4.2 of ANSI N45.2.2 - 1972 titled Caro of Itnmni The following altornaton aro providad for tho indicated subparts: A-14 Rev. 10 6/07

OQAM APPENDIX A (5) " Space heaters in electrical equipment shall be energized unless a documented engineering evaluation determines that such space heaters are not required." (6) "Large (greater than or equal to 50 HP) rotating electrical equipment shall be given insulation resistance tests on a sched-uled basis unless a documented engineering evaluation determines that such tests are not required." (7) " Prior to being placed in storage, large (greater than or equal to 50 HP or when designed to be used with a prime mover of greater than or equal to 50 HP) horizontal rotating equipment shall be evaluated by engineering to determine if shaft rotation in storage is required: the results of the evaluation shall be documented. If rotation is required, it shall be performed at specified intervals, be documented, and be conducted so that parts receive a coating of lubrication where applicable and so that the shaft does not come to rest in the same position occu-pied prior to rotation. For long shafts or heavy equipment subject to undesirable bowing, shaf t orientation after rotation shall be specified and obtained." With regard to Section 6.5 of ANSI N45.2. 2 - 1972 titled Removal of Items from Storage UE does not consider ' the last sentence of this Section to be applicable to the Operating Phase due to the relatively short period of time Latween installation and use. The first sentence of the Section is replaced with: "UE shall develop, issue, and imple-ment a procedure (s) which cover (s) the removal of items from storage. The procedure (s) thall assure that the status of material issued is known, controlled, and appropriately dispositioned." With regard to Section 6.6 of ANSI N45.2.2 - 1972 titled Storage Records: UE shall comply with the requirements of this Section with the clarification that, for record purposes, only the access of non-UE employees or contractors into indoor storage areas shall be recorded. Unloading or pick-up of material shall not be considered " access," nor shall inspection by NRC or other regulatory agents, nor shall tours by non-UE employees who are accompanied by UE employees. With regard to Section 7.4.2, a subsection to Section 7.4 of ANSI N45.2.2-1972 titled Inspection of Equipment and Riqqing: Stated for information only, it is UE's position that this relates to the opera-bility of the hoisting equipment and does not preclude rarating as allowed by Section 7.3. REGULATORY CUIDE 1.39 REVISION 2 DATED 9/77 Housekeeping Requirements for Water-Cooled Nuclear Power Plants (Endorses ANSI N45.2.3-1975) A-15 Rev. 10 6/87

OQAM APPENDIX A DISCUSSION: UE complies with the recommendations of this Regulatory Guide with the following clarifications: - l For maintenance and modification activities UE shall comply with the Regulatory Position established in this Regulatory Guide in that QA programmatic / administrative requirements included therein (subject to the clarifications below) shall apply to these maintenance and modifi-cation activities even though such requirements may not have been in effect originally. Technical requirements associated with the mainte-nance or modification shall be equal to or better than the original requirements (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection requirements) , or as required to preclude repetition of defects. Specific clarifications for ANSI N45.2.3 - 1973 are indicated below by Sections. Section 1.4 - Definitions: Definitions in this Standard which are not included in Regulatory Guide 1.74 (ANSI N45.2.10) shall be used; definitions which are included in ANSI N45.2.10 shall be used as clarified in UE's commitment to Regulatory Guide 1.74. Section 2.1 - Planning: UE may choose not to utilize the five-level zone designation system, but shall utilize. standard janitorial and work practices to maintain a level of cleanliness commensurate with Program requirements in the areas of housekeeping, Plant and personnel safety, and fire protection. Cleanliness shall be maintained, consistent with the work being per-formed, so as to prevent the entry of foreign material into safe-ty-related systems. This shall include, as a minimum, documented cleanliness inspections which shall be performed prior to system closure. As necessary, (e.g. the opening is larger than the tools being used) control of personnel, tools, equipment, and suppliestshall be established when the reactor system is opened for inspection, maintenance, refueling, modification or repair. Additional housekeeping requirements shall be implemented as required for control of radioactive contamination. Section 2.2 - Procedures and Instructions: Appropriate procedures shall be written and implemented. Section 3.2 - Control of Facilities: UE may choose not to utilize the five-level zone designation system, but shall utilize standard janito-rial and work practices to maintain a level of cleanliness commensu-rate with Program requirements in the areas of housekeeping, Plant and personnel safety, and fire protection. Cleanliness shall be maintained, consistent with the work being per-formed, so as to prevent the entry of foreign material into safe-A-16 Rev. 10 6/87

f OQAM APPENDIX A ty-related systems. This shall include, as a minimum, documented cleanliness inspections which shall be performed prior to system closure. As necessary, (e.g. the opening is larger than the tools

 , being used) control of personnel, tools, equipment, and supplies shall be established when the reactor system is opened for inspection, maintenance, modification, refueling or repair.

Additional housekeeping requirements shall be implemented as required for control of radioactive contamination. Section 4 - Records: The requirements of OQAM Section 17 and Regula-tory Guide 1.88 (ANSI N45.2.9) as set forth in this Appendix shall be implemented in lieu of the requirements of the Section. In every case either identical or equivalent controls are provided in the sections of the referenced Standards or documents. REGULATORY GUIDE 1.58 REVISION 1 DATED 9/80 Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel (Endorses ANSI N45.2.6-1978) DISCUSSION: UE complies with the recommendations of this Regulatory Guide with the following clarifications: The qualification of UE QC or contracted QC personnel performing work at the Plant shall be in accordance with Regulatory Guide 1.58 (ANSI N4 5. 2. 6-197 8) . Other personnel performing inspection, examination, and testing activities shall have appropriate experience, training, and retraining to assure competence in accordance with Regulatory Guide 1.8 (ANSI /ANS 3.1-1978). This position is consistent with Regulatory Guide 1.33 (ANSI N18.7-1976/ANS-3.2, Section 3.4.2). In instances where the education and experience recommendations of ANSI N45.2.6-1978 are not met by QC personnel, UE shall demonstrate by documented results of written examinations and evaluations of actual work proficiency that these individuals possess comparable or equiva-lent competence. Persons performing Nondestructive Examinations (NDE) as may be required by Section III or XI of the ASME B&PV Code shall be qualified and certified as required by the Edition and Addenda of the Code to which UE is committed at the time the NDE is performed. Persons certified to perform NDE for Code work shall also be consid-ered as qualified to perform non-Code NDE (e.g. crane hook inspection) unless more rigorous qualification or certification requirements are imposed by UE's commitments or government regulations. With regard to Section 1.2 of ANSI N45.2.6 -1978 titled Applicability: The third paragraph requires that the Standard be used in conjunction with ANSI N45.2; UE no longer specifically commits to ANSI N45.2 in the Operating QA Manual. The fourth paragraph requires that the Standard be imposed on personnel other than UE employees; the applica-bility of.the Standard to suppliers shall be documented and applied, as appropriate, in the procurement documents for such suppliers. A-17 Rev. 10 6/87

OQAM APPENDIX A With regard to Section 1.4 of ANSI N45.2.6 - 1978 titled Definitions: Definitions in this Standard which are not included in Regulatory Guide 1.74 (ANSI. N45.2.10) shall be .used; definitions which are included in~ ANSI N45.2.10 shall be used as clarified in UE's commit-ment.to Regulatory Guide 1.74.

           .With-regard to Section 2.5 of ANSI N45.2.6 - 1978 titled Physical: UE shall implement the requirements of this Section with the stipulation that, where no special physical characteristics are required, none shall.be.specified. .The converse is also true:     if no special physi-cal requirements; are stipulated by UE, none        shall be considered
         ' necessary.

REGULATORY GUIDE 1.64 REVISION 2 DATED 6/76

           ~ Quality Assurance. Requirements for the Design of Nuclear Power Plants.

(Endorses ANSI N45.2.11-1974) DISCUSSION:

      . UE complies with the rec'ommendations of this Regulatory Guide with the P-      following clarifications:

When uniqueness or special design considerations warrant or are judged to be appropriate, an independent third-level review may be employed. N With regard to Paragraph C.2(1) of Regulatory Guide ~1.64: If the

         ' designer's immediate Supervisor is the only technically qualified
      <     iAdividual available, this-review may be conducted by-the Supervisor, provided that: _(a) the other provisions of the Regulatory Guide are satisfied' and (b)   the justification _ is ' individually documented and approved in advance by the Suparvisor's management, and -(c) quality
           . assurance audits cover frequency and effectiveness of use of the
           ' Supervisors as design verifiers to guard against abuse.

With regard to-Section 1.4 of ANSI N'45.2.11 - 1974 titled Definitions: Definitions in this Standard which are not included in Regulatory Guide 1.74 (ANSI N45.2.10) shall be used; definitions which are included in ANSI N45.2.10.shall be used as clarified in this Appendix. With regard to Section 112 (including subsections 11.1 through 11.7) of ANSI N45.2.11 - 1974, titled Audits: UE's audit program shall be L implemented in accordance with and to meet the requirements of Regula-

. tory Guide 1.144 (ANSI N45. 2.12) . as endorsed in this Appendix, OQAM Sections 16 and 18,-and the requirements of the Callaway Plant Techni-cal Specifications. In every case either identical or equivalent 1 controls are provided in the sections of the referenced Standards or l documents.

REGULATORY GUIDE 1.74 INITIAL ISSUE DATED 2/74 I . Quality Assurance Terms and Definitions (Endorses ANSI N45.2.10-1973) A-18 Rev. 10 6/87

7-

0QAM APPENDIX A-DISCUSSION:

 ;      UE complies with the recommendations.of.this Regulatory Guide with the following clarifications.

UE. reserves the right to define additional words or phrases which are-not' included in this Standard. Such additional definitions shall.be ll documented in appropriate procedures or in Sections of the Operating QA Manual. l In addition.to the.Stan'dard's defin'ition of " Inspection," UE.shall use the following: " Inspection (when used to refer to activities that.are NOT performed by QA or QC personnel) - Examining, viewing closely, scrutinizing, looking over or otherwise checking activities. Person- , nel performing these_ functions are_ not necessarily-- certified to Regulatory Guide 1.58 (ANSI N4 5. 2. 6) .~ " These activities are con-trolled-by the'Callaway Plant Operating Manual. When_UE intends for Inspertion-to be performed:in accordance with the Operating _ QA Program by personnel certified as required by that-Program'and for activities - defined by " Inspection" in ANSI N45.2.10, appropriate references .to QC group or the procedures to be used for

       -performing the activity shall be made.             If such references are NOT' made, inspections are to be considered under the additional definition given above.'

In addition to ~ the Standard's definition of " procurement documents,"

UE_shall utilize.the definition given in ANSI N45.2.13. The compound definition is given as follows: Procurement documents - Contractually

binding ' documents that identify and define the requirements which

items or services must meet in order to be considered acceptable by

the purchaser. They may include documents which authorize the seller to perform '. services or supply equipment, material or facilities on behalf of the ' purchaser (e.g. Engineering Service Agreement agree-

, .ments for engineering, construction, or consulting services), con-

tracts, letters of intent, purchase requisitions, purchase orders, or proposals and their acceptance, drawings, specifications, or instruc-l tion'which define. requirements for purchase.

" Program ' Deficiencies" (Not defined in ANSI N45.2.10, but used and defined differently in Regulatory Guide 1.144 (ANSI N45.2.12)) -

Failure to develop, document or implement effectively any applicable i element of the Operating QA Program.

        " Quality Assurance-Program Requirements" (Not defined in ANSI N45.2.10 i        but used and defined differently in ANSI N45.2.13) - Those individual requirements of the Operating QA Program which, when invoked in total-or . in part,    establish the requirements of the quality assurance program for the activity being controlled. Although not specifically used in the Operating QA Program, ANSI N45.2 may be imposed upon UE's suppliers.

l A-19 Rev. 10 6/87 L

OQAM APPENDIX A

          " Independent Verification" - Verification by an individual other than the person who performed the operation or activity being verified that required. actions have been completed.                              Such verification need not require confirmation of the identical action when other indications
         -provide assurance or indication that the prescribed activity is in fact complete.                         Examples include, but are not limited to: verification of a breaker opening by observed remote breaker indication lights; verification of a set point (made with a voltmeter or ammeter for example) by observing the actuation of status or indicating lights at the required Panel-meter indicated value; verification that a valve
         - has been positioned by observing the starting or stopping of flow on meter indications or by remote value positions indicating lights.
          " Audit" (This is a modification of the word's definition - to allow                            as the use of subjective evidence if no evidence is available                                   -

defined in Section 1.4 of ANSI N45.2.12 - 1977 (Regulatory Guide 1.144) and Section 1.4.3 of ANSI N45.2.23 - 1978 (Regulatory Guide 1.146) as opposed to the definition given in ANSI N45.2.10 - 1973) -A documented activity performed in accordance with written procedures or checklists to verify, by examination and evaluation of objective evidence where available, (subjective evidence may be used when objective evidence is not available) , that applicable elements of the Quality Assurance Program have been developed, documented and effec-tively = implemented in accordance with specified requirements. An audit should not be confused with surveillance or inspection for the sole purpose of' process control or product acceptance.

          "Must"      -            (Not defined in any ANSI Standard) - An internally auditable requirement imposed'by UE management upon its employees, contractors, and agents - above.and in excess of the legally binding requirements of the appropriate regulatory body.                              Such items are internally re-quired but not externally enforcesble.                               (See additional discussion under Section 2.13 of the OQAM.)

l

          " Unit staff"                        -  (Not defined in any ANSI standard)        -

Means those personnel who report to the General Manager, Nuclear Operations. This term shall also be synonymous with the "onsite operating organization" described (but not defined) in ANSI N18.7-1976, Section 3.4.2; the l" unit staff" as used in the OQAM and in Callaway Plant Technical Specifications Section 6.3 and its subparts and Section 6.5.2.9.b; the l " unit organization" described in the Callaway Plant Technical Specifi-cations Section 6.2.2.

          "Like kind replacements"                         -   (Not defined in any ANSI standard) - Like kind replacements include both exact item replacements and other item

, replacements which are not " exact" but meet the original design

! requirements. REGULATORY GUIDE 1.88 REVISION 2 DATED 10/76 Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records (Endorses ANSI N45.2.9-1974) i l A-20 Rev. 10 6/87

OQAM-APPENDIX A DISCUSSION: UE complies with the recommendations of this Regulatory Guide with the following clarific'ations: With regard to Section 3.2.1 of ANSI N45.2.9 - 1974 titled Generation Lof Quality Assurance Records: The phrase " completely filled out" is clarified to mean that sufficient information is recorded to fulfill the intended purpose of the record. It is_the information, not the form, that is the' record. Thus the information, not the form, needs to be complete to furnish documented " evidence of activities affecting

   -quality".

With regard to Section 3.2.2 of ANSI N45.2.9 - 1974 titled Index: The phrase "an index" is-clarified to mean a collection of documents or indices which, when taken.together, supply the information attributed to "an index" in the Standard. The. specific location of a record "within a storage area" may not be delineated. (e.g. The specific location within a computer record file may not be constant. Further, UE may utilize a computer assisted random access. filing system where such location could not be readily

    " documented," or would such a location be " relevant.") The storage location shall be delineated, but where file locations change with time,  .

the specific location of a record within that file; may not always be documented. With regard to Section 4.2 of ANSI N45.2.9 - 1974 titled Timeliness: UE's contractual agreement with its contractors and suppliers shall constitute fulfillment of the requirements of this Section. The following clarification is substituted for the current subsection 5.4.3: " Provisions shall be made for special processed records (such as radiographs, photographs, negatives, microfilm and magnetic media) +

   -to prevent damage from excessive light, stacking, electromagnetic
   ' fields, temperature and humidity as appropriate to the rec'erds type."

Consideration shall be given to manufacturer's recommendation. With regard to Section 5.5 of ANSI N45.2.9 ,1974 titled Safekeeping: Routine General Offices and Plant site security systems and access controls shall be provided: no special security systems are required to be established for record storage areas. t With ~ regard to Section 5.6 of ANSI N45.2.9 - 1974 titled Facility: This'Section provides no distinction between temporary and permanent facilities. To cover temporary storage, the following clarification is added: " Active records (those completed but not yet duplicated or j placed on microform) may be temporarily stored in one-hour fire rated

    -file cabinets. In general, records shall not be maintained in such j    temporary storage for more than three months after completion without j    being duplicated (for dual storage) or being placed on microform.

i Open-ended documents --those revised or updated on a more-or-less l A-21 Rev. 10 6/87 i

OQAM APPENDIX A continuing basis . over an extended period of time (e.g. personnel. qualification and training documents, equipment history cards, master audit or master surveillance schedules) and those which are cumulative in nature (e.g. nonconforming item logs and control room log books)- ~~ are not considered as QA' records since they are not " complete." These types of documents shall become QA records when they are issued as a specific revision ( e . g. . the master audit schedule) ; when they are filled-up or discontinued (e.g. log books or equipment history cards) ; on a predefined ' periodic basis when the completed portion of the on-going document shall be transferred to document control as a

      " record" (e.g.-training and qualification records).

Paragraph 4, subsection 3 is clarified-to require a two-hour minimum

     . fire rating  to be consistent with the 1979 version of the Standard and NRC Criteria  for Records Storage Facilities     (Guidance-ANSI N45.2.9, Section 5.6)  issued 7/1/80.

Paragraph.4, subsection 9 is clarified to read: "No pipes or penetra-tions except those providing fire protection, lighting, temperature / humidity control, or communications are to be located within the facility and they shall comply with a minimum two-hour fire protection rating." Where duplicate storage is employed, no special precautions or provi-sions (including vault storage, special humidity and- temperature recorders and similar items) are required. Paragraph 5 is clarified to read the same as our commitment to subsec-tion 5.4.3. Both paragraphs address the same requirement and there-fore the commitment must be the same. REGULATORY GUIDE 1.94 REVISION 1 DATED 4/76 Quality- Assurance Requirements for Installation, Inspection and Testing of Structural Concrete and Structural Steel During the Con- ! struction' Phase of Nuclear Power Plants. (Endorses ANSI N45.2.5-1974) DISCUSSION: I l UE complies with the recommendations of this Regulatory Guide with the i following clarifications: l For modification activities UE shall comply with the Regulatory Position established in this Regulatory Guide in that QA programmatic / administrative requirements included therein (subject to the clarifications below) shall apply to these modification activities even though such requirements may not have been ja effect originally. Technical requirements associated with modifications shall be equal to or better than the original requirements (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection requirements), or as required to preclude repetition of defects. A-22 Rev. 10 6/87 t

c i OQAM APPENDIX A The recommendations for structural concrete, structural steel, and other Plant components shall be met as indicated by the applicable design documents with the following exceptions:

a. Bolts for friction type connections may be tightened using direct tension indicators in accordance with the AISC Specification for Structural Joints Using ASTM A 235 or A 490 bolts, approved May 8, 1974.

b. Section 5.4 (1) of ANSI N45.2.5 does not apply. The require-ment for the acceptance of tightened bolt assemblies is:

               "The length of the bolts shall be such that the point _of the bolt shall be flush with or outside of the face of the nut when completely installed."

REGULATORY GUIDE 1.116 REVISION 0-R DATED 5/77 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems (Endorses ANSI N45.2.8-1975) DISCUSSION: UE complies with the recommendations of this Regulatory Guide with the following clarifications: l For maintenance and modification activities UE shall comply with the Regulatory Position established in this Regulatory Guide in that QA programmatic / administrative requirements included therein shall apply to these maintenance and modification activities even though such requirements may not have been in effect originally. Technical requirements associated with maintenance and modifications shall be equal to or better than the original requirements (e.g., code require-ments, material properties, design margins, manufacturing processes, and inspection requirements) , or as required to preclude repetition of defects. REGULATORY GUIDE 1.123 REVISION 1 DATED 7/77 Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants (Endorses ANSI N45.2.13-1976) DISCUSSION: UE complies with the recommendations of this Regulatory Guide with the following clarifications: With regard to Section 1.3 of ANSI N45.2.13 - 1976 titled Definitions: With two exceptions (Procurement Document and Quality Assurance Program Requirements) definitions in this Standard which are not included in Regulatory Guide 1.74 (ANSI N45.2.10) shall be used; definitions which are included in ANSI N45.2.10 shall be used as A-23 Rev. 10 6/87

OQAM APPENDIX A clarified in UE's commitment to Regulatory Guide. 1.74. The two exceptions are defined in this Appendix under Regulatory Guide 1.74.

i. With regard to Section 1.2.2 of ANSI N45.2.13 -1976 titled Purchaser's Responsibilities:. Item C.is one of the options which may be used by UE to assure quality; however, any of the options given in 10 CFR 50, Appendix B, Criterion VII as implemented by OQAM Sections 4.and 7 may also be used.

With regard to.Section 3.1 of ANSI N45.2.13 - 1976 titled Procurement Document Preparation, Review and Change Control: The phrase "the same degree.of control" is stipulated to mean " equivalent level of review and approval." The changed document may not always be re-reviewed by

  ..the originator; however, at least an equivalent level of supervision shall review and approve any changes.

With regard to-Section 3.4 of ANSI N45.2.13 - 1976 titled Procurement Document Control: UE shall meet the requirements of OQAM Sections 4 and 7 in lieu of the requirements specified in this Section. In every. case either identical or equivalent controls are provided in the sections of the referenced documents. With regard to Section 5.3 of ANSI N45.2.13 - 1976 titled Preaward Evaluation: UE shall comply with'an alternate paragraph which reads:

   "Except in unusual circumstances (e.g. replacement parts are needed to preclude the development of some unsafe or undesirable condition at Callaway), an evaluation of the supplier's acceptability as a procure-ment source shall be performed as required by the-Operating QA Manu-al.-"  While it is not the intent to make " unusual circumstances" determinations without Engineering or QA involvement, Callaway Opera-tions Support is ultimately responsible for the decision. QA audit and surveillance activities assure against abuse.

With regard to Section 6.4 of ANSI N45.2.13 - 1976 titled Control of Changes in Items of Services: The phrase "the Operating QA Program" is inserted in lieu of " ANSI N45.2, Section 17.2.7." With regard to Section 8.2 of ANSI N45.2.13 - 1976 titled Disposition:

  -The third sentence of item b is revised to read:

Nonconformances to the contractual procurement requirements or Purchaser approved documents and which consist.of one or more of the following shall be submitted to the Purchaser for approval of A-24 Rev. 10 6/87

T~ ~ OQAM APPENDIX A the recommended dis' position. prior to shipment when the-nonconfor-mance:could adversely affect the end use of a module

• or shippa-ble component relative to safety, interchangeability, operabili-

ty, reliability,. integrity, or maintainability:

1) . Technical or material requirement is violated;-

2) Requirement in Supplier documents, which have been approved by the Purchaser, is. violated;

3) Nonconformance cannot . be corrected by continuation of the original manufacturing process or by rework; and/or

4) The item does. not conform to the original requirement even though the item can be restored to a condition such that the capability of the item to function is unimpaired.

               *A module is an assembled device, instrument, or piece of equip-ment identified by serial number or-other identification code, having been evaluated by inspection.and/or test for conformance to procurement requirements regarding' end use.         A shippable component _is a part of sub-assembly of a device,-instrument, or piece -of equipment which is shipped as an individual item and which has 'been evaluated by inspection and/or test for confor-mance to procurement requirements regarding end use.

With regard .to Section 12 of ANSI ' N4 5. 2.13 - 1976 titled Audit of Procurement-Program: The UE audit program shall be implemented in accordance with.and to meet the requirements-of Regulatory Guide 1.144 (ANSI N45.2.12) as endorsed in this Appendix, OQAM Sections 16 and 18, l and the requirements of the Callaway Plant Technical Specifications. REGULATORY GUIDE 1.144 REVISION 1 DATED 9/80 L ,. Auditing of Quality Assurance Programs for Nuclear Power Plants l (Endorses ANSI N45.2.12-1974) l DISCUSSION: UE complies with the recommendations of.this Regulatory Guide with the following clarifications: With-regard to Section 1.4 of ANSI N45.2.12 - 1977 titled Definitions: c With' one exception (Program Deficiencies) the definitions in this Standard which are not included in Regulatory Guide 1.74 (ANSI [ N45.2.10) shall be used; definitions which are included in ANSI !~ N45.2.10 shall be used as clarified in UE's commitment to Regulatory , Guide l.74. The one excepted definition and a clarified definition

(of audit) relevant to this Standard are defined in this Appendix l .under Regulatory Guide 1.74.

I l With regard to Section 2. 2 of ANSI N45. 2.12 - 1977 titled Personnel Qualification: The qualification of UE audit personnel shall be i I I' A-25 Rev. 10 l 6/87 l-

r- _ i OQAM' APPENDIX A accomplished as-described to meet the requirements of Regulatory Guide 1.146 (ANSI N45.2.23 - 1978) as endorsed in this Appendix and OQAM Section'18. With regard to Section 2.3 (and subsections 2.3.1.through 2.3.3) of

    -ANSI N45.2.12                 -  1977 titled Training:                           The training of UE audit personnel shall be accomplished as described to meet the requirements of Regulatory Guide 1.146 '(ANSI N45.2.23 - 1978) as endorsed in this Appendix and OQAM Section 18.
    'With regard to Section 2.4 of ANSI.N45.2.12 - 1977 titled Maintenance of Proficiency: The maintenance of proficiency of UE audit personnel shall be accomplished as described to meet the requirements of Regula-
     -tory Guide 1.14'6 (ANSI N45.2.23 - 1978) as endorsed in this Appendix and OQAM Section 18.

With regard to Section 3.'3 of ANSI N45.2.12 - 1977 titled Essential-Elements of-the Audit System: UE shall comply with subsection 3.3.5 as it was . originally written (subsection 3.2.5) in ANSI N45.2.12, Draft 3, . Revision ^ 4 : " Provisions for reporting on the effectiveness of the-Quality Assurance Program to the responsible management. " For the auditing organization (UE), effectiveness shall - be reported as-

  -l required. by the Callaway Plant Technical Specifications. Other than audit: reports, UE may not directly report on the effectiveness of the quality assurance programs to                    the audited organization when such organizations'are outside of UE.

Subsection 3.3.6 requirements are considered _to be fulfilled by compliance with _the organization and reporting measures outlined in this Operating QA Manual and the Callaway Plant Technical Specifi-cations. In every case either identical or equivalent controls are provided in the sections of the referenced documents. Subsection 3.3.7 requires verification of effective corrective action on a " timely _ basis. " Timely basis is interpreted to mean within the framework or period of_ time for completion of corrective action that is accepted by the Quality Assurance Division. Each finding requires a-response and a corrective action completion date; these dates are subject. to revision (with the approval of the Quality Assurance Division) and must be escalated' to higher authority when there is a disagreement- between the audited and the auditing organizations on what constitutes " timely corrective action." With regard to Section 3.5.of ANSI N45.2.12 - 1977 titled Scheduling: Subsection 3.5.3.1 is interpreted .to mean that UE may procedurally control qualification- of a contractor's or supplier's quality assur-ance program prior to awarding a contract or purchase order by means other than audit. With regard to Section 4.3.1 of ANSI N54.2.12 - 1977 titled Pre-Audit Conference: _UE shall comply with requirements of this Section by inserting the word "Normally" at the beginning of the first sentence. This clarification is required because, in the case of certain A-26 Rev. 10 6/87 -

OQAM APPENDIX A unannounced audits or audits of a particular operation or work activi-ty, a pre-audit conference might interfere with the spontaneity of the operation or activity being audited. In other cases, persens who should be present at a pre-audit conference may not always be avail-able: such lack of availability should not be an impediment to begin-ning an audit. Even in the above examples, which are not intended to be all inclusive, the material set forth in Section 4.3.1 shall normally be covered during the course of the audit. With regard to Section 4.3.2 of ANSI N45.2.12 - 1977 titled Audit Process: (a) Subsection 4.3.2.2 could be interpreted to limit auditors to the review of only objective evidence; sometimes and for some Program elements, no objective evidence may be available. UE shall comply with an alternate sentence which reads: "When available, objective evidence shall be examined for compliance with Quality Assurance Program requirements. If subjective evidence is used (e.g. personal interviews, direct observations by the auditor) , then the audit report must indicate how the evidence was ob-tained." (b) Subsection 4.3.2.4 is modified as follows to take into account the fact that some nonconformances are virtually " obvious" with respect to the needed corrective action: "When a nonconformance or Quality Assurance Program deficiency is identified as a result of an audit, unless the apparent cause, extent, and corrective action are readily evident, further investigation shall be conducted by the audited organization in an effort to identify the cause and effect and to determine the extent of the correc-tive action required." (c) Subsection 4.3.2.5 contains a recommendation which is clarified with the definition of " acknowledged by a member of the audited organization" to mean that "a member of the audited organization has been informed of the findings." Agreement or disagreement with n finding may be expressed in the response from the audited organization. (d) Subsection 4.3.2.6 is modified as follows to account for the fact l that immediate notification is not always possible: " Conditions i requiring immediate corrective action (i.e. those which are so severe that any delay would be undesirable) shall be reported immediately to the audited organization and as soon as practical to the management thereof." With regard to Section 4.3.3 of ANSI N45.2.12 - 1977 titled Post-Audit Conference: UE shall substitute and comply with the following paragraph: "For external audits, a post-audit conference shall be held with management of the audited organization to present audit findings and clarify misunderstandings; where no adverse findings exist, this conference may be waived by management of the audited organization: such waiver shall be documented in the audit report. A-27 Rev. 10 6/87

f OQAM APPENDIX A Unless unusual operating or maintenance conditions preclude attendance by appropriate managers / supervisors, a post-audit conference shall be held with managers / supervisors for internal audits for the same reasons as above. Again, if there are no adverse findings, management of the internal audited organization may waive the post-audit confer-ence: such waiver shall be documented in the audit report." With regard to Section 4.4 of ANSI N45.2.12 - 1977 titled Reporting: (a) This Section requires that the audit report shall be signed by the Audit Team Leader (ATL); this is not always the most expedi-tious route to take to assure that the audit report is issued as soon as practical. UE shall comply with Section 4.4 as clarified in the following opening: "An audit report, which shall be signed by the Audit Team Leader (ATL), or the ATL's supervisor in ' the ATL's absence, shall provide: . . ." In cases where the audit report is not signed by the ATL due to absence, one record copy of the report must be signed by the ATL upon return. The report shall not require the ATL's review / concurrence / signature if the ATL is no longer employed by UE at the time the audit report is issued.

 '(b)   UE shall comply with subsection 4.4.3 clarified to read:      " Super-visory level personnel with whom significant discussions were held during the course of pre-audit (where conducted) audit, and post-audit (where conducted) activities."

(c) Audit reports may not necessarily contain an evaluation statement regarding the effectiveness of the Quality Assurance Program elements which were audited, as required by subsection 4.4.4, but they shall provide a summary of the audited areas and the results which identify the importance of any adverse findings. With regard to Section 4.5.1 of ANSI N45.2.12 - 1977 titled By Audited Organization: UE shall comply with the following clarification of the Section: " Management of the audited organization or activity shall review and investigate adverse audit findings, as necessary, (e.g. where the cause is not already known, another organization has not already investigated and found the cause, etc.) to determine and schedule appropriate corrective action including action to prevent recurrence. They shall clearly state the corrective action taken or planned to prevent recurrence and the results of the investigation, if conducted. In the event that corrective action is not completed within thirty days, the audited organization's response shall include a scheduled date for completion of planned corrective action: a follow-up response shall be provided stating the corrective action taken and the date that the action was completed. If corrective actions are verified as satisfactorily completed by the auditing organization prior to the scheduled completion date, no follow-up response is required. The audited organization shall take appropriate action to assure that corrective action is accomplished as scheduled. Either the Manager, Quality Assurance or a Superintendent, Quality Assurance may waive the requirement for a supplementary response." A-28 Rev. 10 6/87

r: 1 OQAM APPENDIX A l REGULATORY GUIDE 1.146 INITIAL ISSUE DATED 8/80 Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants-(Endorses ANSI N45.2.23-1978) . DISCUSSION: UE complies with the recommendations of this Regulatory Guide with the following clarifications:

   .With respect to Section 1.4 of ANSI N45~.2.23-1978 titled Definitions:                  ;
  ' Definitions in this Standard which are not included in ANSI N45. 2.10 shall be used: " Audit" which is included in this Standard and ANSI
   .N45.2.10 shall be used as clarified in this Appendix under Regulatory ,

Guide 1.74. With respect.to Section 2.2 of ANSI N45.2.23 - 1978 titled Qualifica-tion of Auditors: Subsection 2.2.1 references an ANSI B54.2 (presumed to be standard N45.2) ; therefore, UE shall comply with an alternate subsection 2.2.1 which reads: Orientation to provide a working knowledge and understanding of the. Operating QA Manual, including the ANSI standards and Regula-tory Guides included in this Appendix and UE's procedures for implementing audits and reporting results. With respect to Section 4.1 of ANSI N45.2.23 - 1978 titled Organiza-tional Responsibility: UE shall comply - with this Section with the substitution of the following sentence in place of the last sentence in the Section. The Manager, Quality Assurance; a Superintendent, Quality Assur-ance; Supervising Engineer, QA; or Lead Auditor shall, prior to commencing the audit, assign personnel who collectively -have. r experience or training commensurate with the scope, complexity,- or special nature of the activities to be audited. With respect to SectionUE 3.2shall of ANSI N45.2.23 - 1978 titled Mainte- . nance of Proficiency: comply with the requirements of this Section by defining " annual assessment" as one which takes places every 12 + or - 3 months and which uses the initial date of certifica-tion (not the calendar year) as theThe starting date for combined determining time interval forwhen any such annual assessment is due. three consecutive assessment intervals shall not exceed 3.25 years. With respect to Section 5.3 UE of ANSI N45.2.23 the shall substitute - 1978 titled Updating following sentence of~ Lead Auditor's Records: for this Section Records for each Lead Auditor shall be maintained and updated during the period of the annual management assessment as defined in Section 3.2 (as clarified). A-29 Rev. 10 6/87

OQAM APPENDIX A With respect to - Section 5.4 of ANSI N45.2.23 - 1978 ~ titled Records Retention: UE shall substitute the following- sentence for this Section.

    ' Qualification . records           shall    be   generated  and  maintained            as required by OQAM Section 17 and by commitment to Regulatory Guide 1.88 (ANSI N45.2.9) as clarified-in this Appendix .

In every case either identical or equivalent controls are provided in the sections of the referenced Standards and documents. A-30 Rev. 10 6/87

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ATTACHMENT 2 OQAM, REVISION 10 MARK-UP REPORT

OPERATING QUAL.TY ASSURANCE MANUAL (OQAM)

       -f Fermeriy-Ehapter-Hve-ef-the-6NUPPS-E-FSARt ( 2 )

1.0 ORGANIZATION 1.1 UE has established an organization for Quality Assurance activities. This Section identifies the organizational structure; management positions and responsibilities; and delegation of authority for the development, implementation and maintenance of the Operating Quality Assurance Program (OQAP). UE shall retain responsibility for the establishment and execution of the OQAP, although certain Program- activities may be delegated to others. The organization responsible for implementing appropriate portions of the OQAP isshowninBeetienf)FigureAofthe The Callaway G all aw ay-4echn-i ce-1-- 6 pecificetiens OQAN. Plant operating organization is aise shown in Geetie - Figure B of the Galiaway-Technical-Specificatiens OQAN. g-)5 (No changes to section 1.2) the Vice President, 1.3 Ugr the Executive Nuclear is responsible Vice President, for initiating the Quality

     /

Assurance Program, formulating the policy, and authorizing and assuring Program implementation. He is responsible for directing activities within the Nuclear Function which support the engineering, construction, testing, and operation of the Callaway Plant and coordinating support activities performed by others who are not under his direct administrative control. He has corporate responsibility for the operation and physical control of the Callaway Plant. 1.4 The Assistant to to the Vice President, / the Vicg President, [ Nuclear reports Nuclear and is responsible for-high level mpggement President, / Nuclear. activities as directed by the Vice Prier- to--the-opetetiene--phase, the-Assistant-te-the-Vice-President-Nuetear-was-respensihie fer--the-conduct--ef--the- Ceneteuction--Test- I'h;;; -ef--the Eatiaway- 9eet--Pregramr--@he---Genebreedien-Test-M.;;; -was geverned- by--the -adminiebredive-eentreis-ef--bhe--Beeign-and E e n s t r u c t ie n---Quel-i-ty-- Assurence---Pregr am ---end---in c lude d eenstructien-eempletsen-and-preeperatienal-testingr--Buring the-Genstructien-Test-Phase-the-Guperintendent7-Startup-re-perted--direetg-te--the--Assistant--te--the--Vice--Press-dent-Nuclearv 4rb) The Assipgnt to the Vice President, N} Nuclear is currently responsible for Nuclear Records and Information Services (NRIS). The Nuclear Records and Information Services organization includes the Superintendent, NRIS, the Superintendent, Administration-Services and the Superintendent, Rev. 10 6/87

OQAM-Administration-Records. The Superintendent, NRIS, the

         . Superintendent, Administration-Services, and the Superin-tendent, Administration-Records                  directly    to   the Assistant to the.Vice President,       / g ort Nuclear.

1.6bl'The._ Manager, Quality . Assurance reports to the General Manager, Quality Systems on ~ Quality Assurance Program

         . matters.   .The General Manager, Quality Systems reports to
         . the ' Executive Vice President for administrative matters.

QA Program matters are . reported .to t Executive. Vice

         . President,through the Vice President, /gpft Nuclear.

(1) 1.76 The Manager, Quality Assurance reports..to the General Manager, Quality Systems who is responsible for the administrative control (hire / fire and salary review) of the Manager, Quality Assurance. The Manager, Quality Assurance is responsible for directing the overall Quality Assurance Program for UE including Program development, maintenance, and . verification of implementation. The Manager, Quality. Assurance has sufficient authority, organizational freedom, and independence from undue influence from, or responsibility. for, cost and schedule that he can effectively assure compliance with OQAP.. requirements as they control Callaway Plant and offsite quality activities. He maintains a Quality Assurance staff and provides them technical direction and administrative guidance. He - is responsible for establishing -and implementing a comprehensive audit program. The qualifications of the Manager,. Quality Assurance are at least equivalent to those specified in ANSI /ANS-3.1-1978, " Selection and Training of Nuclear Power Plant Personnel," Section 4.2.4. (1) 1.67 The Manager, Quality Assuran;e is located ~at the Callaway Plant and provides technical direction and administrative guidance to the Superintendents, Quality Assurance.

     . (1)
 -1.98     The   Superintendent,     operations     Support,     QA   and    the Superintendent, Technical Support, QA are located at the Callaway    Plant. These     Superintendents      each     direct Supervising Engineers who have primary duties for assuring implementation of the OQAP at the Callaway Plant.                The activities of the groups reporting to the Superintendent, Operations Support, combined with the activities of the groups reporting to the Superintendent, Technical Support, assure implementation of the OQAP at the Callaway Plant.

Rev. 10 6/87

OOAM 9(1) 1.40 The qualifications of both the Superintendent, Operations Support and the Superintendent, Technical Support are at least equivalent to those specified in ANSI /ANS-3.1-1978,

         " Selection and Training of Nuclear Power Plant Personnel,"

Section 4.4.5. 10(1) 1.44 The Superintendent, Quality Engineering, QA, is located at the General Offices and directs Supervising Engineers. The Supervising Engineers have primary duties involving the audit and surveillance of supplier quality activities, engineering, procurement, and other support activities at the General Offices. 11(1) 1.42 General quality assurance indoctrination and training for the Nuclear ?/ unction is the responsibility of UE Nuclear Operations (UENO), Training. The Quality Assurance Divi-sion is responsible for specific QA training as requested by Nuclear Function organizations. 12(1) 1.43 The Manager, Quality Assurance, the Superintendents, Quality Assurance, and Supervising Engineers in the Quality A g rance Division are authorized by the Vice President, Nuclear to stop work on ongoing quality activities in

         /

accordance with approved procedures. During the operating phase they have the authority to stop unsatisfactory work during repair, maintenance, and refueling activities and the authority to recommend to the Manager, Callaway Plant stop work affecting the continuation of Plant operation. Other stop work authority shall be delineated in procedures. The continuance of an activity which would cover up a deficiency and preclude identification and correction, or increase the extent of the deficiency is subject to stop-work action by the Quality Assurance Division. The Manager, Quality Assurance, and the Superintendents, Quality Assurance have no duties or responsibilities unrelated to QA that would prevent their full attention to QA matters. 13(1) 1.44 The authorities and duties of persons and organizations performing quality assurance functions shall be clearly established. Such persons have sufficient authority and organizational freedom to identify quality problems; to initiate, recommend, or provide solutions; and to verify corrective action. Assurance of quality by checking, auditing, inspecting, or otherwise verifying Program activities shall be by personnel other than the individual or group performing the specific activity. 1d(1) 1.45 The General Manager, / Engineering (gelear)Il} reports directly to the Vice President, / Nuclear and is responsible for engineering, licensing, fuel, project j services, procurement other than that associated directly Rev. 10 6/87 L

n OQAM with operations, and an independent overview of Plant safety. :He provides administrative coordination between the various departments _under his direction to assure effective operation of the'various disciplines involved.in the offsite support and onsite overview of Callaway Plant. 15(1) 1.46 The Manager, Nuclear Safety and Emergency Preparedness (NSEP) . reports dir to the General Manager, / Engineering-(Nuclear) g lyand is responsible for providing a constant independent overview of nuclear Plant safety. He directs 1 the Supervising Engineer, Independent Safety Engineering Group (ISEG) and the Supervisor, Emergency Preparedness' (EP) . 16(1) l'.47 The Supervising Engineer, ISEG and staff evaluate Callaway Plant operations from a safety perspective and compare Callaway operating experience with that of. plants of-similar design. In addition, they. assess the conformance of Plant' . performance to safety requirements. The Supervisor, . EP and staff have overall responsibility for the development and maintenance of the Emergency Prepared-ness Program. This includes onsite and offsite emergency preparedness, coordination of the -Plant Radiological Emergency Response Plan with State and local emergency plans, and the planning and execution of_ emergency drills and emergency plan exercises.- A communication path exi g between the Manager,' NSEP and the Vice President, / ' Nuclear for matters having immediate or significant safety implications, thus providing a direct path to contact management personnel having corporate responsibility for Callaway Plant. . . 17(1) 1.48 reports The Manager, Nuclear Engineering(NucTear)(firectly to the General-Manager,./ Engineering and directs a staff of' engineers (as described in Callaway-SA FSAR Section 13.1) whose primary function is to provide offsite technical support to the operation of Callaway Plant. 18(1) 1.49 The Manager, Nuclear Fuel- reports dgetly to the General Manager, / Engineering (Nuclear) and has overall responsibility for UE nuclear fuel cycle activities including responsibility for procurement of fuel cycle goods and services, and for incore fuel management.

    -19 ( 1) 1.GG The Manager,. Nuclear Services                    reports dire           to the General       Manager,    /    Engineering         (Nuclear) ggy and      is responsible for providing administrative and management support;       for cost     forecasting,         status reporting,       and budgeting        matters;      and       for-     managing,      directing, coordinating,         and      administering           construction      and modification work as           assigned.         He   is   responsible   for direction of the Nuclear Function General Offices clerical activities.

Rev. 10 6/87

OQAM 20(1) 1.94 The Coordinator Nuclear Development reports di g tly to the General Manager, / Engineering (Nuclecr) and is responsible for generic nuclear matters. He maintains an awareness of advanced nuclear activities outside UE as well as being the administrative contact with the Institute of Nuclear Power Operations (INPO). 21(1) 1.EE The Principal Health Physicist reports to the General Manager, / Engineering (Nuclear)(firectly and provides a corporate level overview and guidance in the formulation and implementation of applied radiation protection programs. He reviews the radiological safety programs for compliance with Federal and State standards and regulations. 22(1) 1.EE The Superintendent, NRIS ggports directly to the Assistant to the Vice President, / Nuclear and is responsible for the direction of the Nuclear Records and Information Services (NRIS) organizttion at the Callaway Plant and for Document Control at the General Offices. 23(1) 1.24 The Superintendent, Administration-Records is a member of the NRIS and is responsible for the processing of documents and records related to safety, quality assurance, radiation exposure, and training activities of the Plant. 2d(1) 1.25 The Superintendent, Administration,-Services is a member of NRIS and is responsible for site clerical, stenographic and word processing activities to facilitate Plant operation. 4 rE 6--The-Menegen- Neeleer- Cenet euetion--eepoeted--d&reet-ly -be-the Vic e--hes ieent-Nee-leen--- He---wee---rc epc a s i-b le --fer--sit e f abrientien r---ins te-1-let-iem-- 5-eenebruebien--activities during-the-eenstructien-phase 25(1) 1.E7 The General M g ger, Nuclear Operations reports to for the Vice the President, / Nuclear and is responsible activities'of the Callaway Plant Operations Department and the Operations Support Department. This responsibility includes the safe, legal and efficient operation and maintenance of the Callaway Plant and protecting the health and safety of the public and Plant personnel. He assures a high level of quality is achieved in the Plant operations and support activities. 26(1) 1.E0 The Manager, Callaway Plant reports directly to the General Manager, Nuclear Operations and is responsible for the safe, legal, and efficient operation and maintenance of the Callaway Plant. He controls Plant functi the OQAP through Maintenance, the the Assistant Assistant Manager, Manager, /gg and imp Technical Services, and the Superintendent, Planning and Scheduling i Rev. 10 6/87

D. . OQAM

                 -(see    Seetion--4 -Fi          B    of- .the   Ee&&ewey--@eehndeed Speesisestiene OQAM.).. gurs He has the primary responsibility for reactor operation and safety. . A-persen-wie-ei+ eeme titier- but--wM-breeder-{;;waibiisit%-w-responsible fee--the- conduct--ef--gtiai--etePhep- t .;tiarf-decieg--the Ge&&ewey-9est-Programe
            .27.(1)
         'l.99    The Manager,     Operations Support reports to the General Manager,' Nuclear - Operations and is responsible for . Plant support _ - activities including training, materials manage-ment ,' outages,   security,, quality control, and compliance-activities required to- support. the .Callaway Operating License. He controls Plant support activities y d Support-  imple-mentstheOQAPthroughtheAssistany1yanager, /

Services, the Assistant Manager, / Materials, and the

                 -Superintendent,      Outages.      Within     the   .Callaway    Plant-organization, . the.. QC     Supervisor.     - reports   to    the Superintengt,SupportCompliance who reports to the Assistant Manager, /                 Services. The Quality control Group performs work activity inspections, receipt inspection as
                 ' described in Section'7, and nondestructive, examinations.and-is not involved in those activities ' performed by' others                ;

which are considered " inspections" unto themselves , e.g. , surveillance testing, initial startup -testing, and I&C, Radiation Protection, and Chemistry- group activities. Activities _ considered to be inspections unto themselves are covered by QA audits and QA surveillances as discussed under Section .18. The QC Supervisor has no duties or responsibilities unrelated to quality control that would prevent his full attention to quality control matters. 28(1) 1.99 The Superintendent, Personnel Development reports directly to the General Manager, Nuclear Operations and is responsi-ble for assisting in areas of labor relations, organiza-tional and personnel development, and other matters under the guidance of UE Company policies. . 29(1)

         ~1.94    The Purchasing Agent reports directly to the Vice President p                   (or Director) , Supply Service who in turn reports to the

[ Executive Vice President. The Purchasing Agent is respon-

sible for commercial aspects involved 'in procurement of materials, systems, components, and services (excluding l

engineering services and certaf , nuclear fuel cycle-related procurements) not delegated to others which are employed in t support of the operating Callaway Plant. l 30(1) i <l.99 The Manager, Mechanical Engineering reports to the Vice l

President (or Director) , Engineering and Construction who E in turn reports tow the Executive Vice President. The l- Manager, Mechanical Engineering provides technical support, i as necessary, to the Nuclear Engineering staff. The Chief Draftsman, who reports to the Manager, Mechanical !- Rev. 10 l-6/87 _ _ _ _, - . _ . _ . _ . _ ... _ . _ _ . _ _ _ ._ _ _ _ _ . _ _ _ .a

OQAM Engineering provides drawing preparation and revision support, as requested, for design performed by Nuclear Engineering or other UE organizations. 31(1) 1.03 The Manager, Electrical Engineering reports to the Vice President (or Director), Engineering and Construction. The Manager, Electrical Engineering provides technical support, as requested, to the Nuclear Engineering staff. 32(1) 1.04 Other UE functions may provide safety-related services which augment and support selected Program activities. These organizations shall be required to implement controls consistent with the OQAP requirements applicable to their scope of activities. The coordination of theqq) activities is the responsibility of the Vice President, / Nuclear. 33(1) 1.35 Safety review committees shall be established to provide an independent review of those items required by the Callaway Plant Technical Specifications. These committees, the Onsite Review Committee (ORC) and the Nuclear Safety Review Board (NSRB), are described h )the Administrative Controls Section of the Callaway Plant Technical Specifications. 2.0 QUALITY ASSURANCE PROGRAM 2.1 UE Company has established an OQAP which controls activi-ties affecting quality. The Program encompasses those quality activities necessary to support the operating phase of the Callaway Plant and shall comply with 10 CFR 50, Appendix B - " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" as described herein and with the Regulatory Position of Regulatory Guide 1.33. Commitments, clarifications, alternatives, and exceptions to the Regulatory Position of Guide 1.33 are In a th OQAP stategl in Appendix A of this OQAM. has sncorporated the commstments Regulatorfdstion, made sn responds,e ng to applicable NRC questions. The text of the NRC questions applicable to the OQAP, along with the responey are maintained as a qQ Record separate from the 0QAM. The Vice President, / Nuclear has initiated the Program and formulated the policy in addition to authorizing Program implementation. This responsibility has been established by the Executive Vice President who is responsible to the President of UE Company for establishing and implementing the Quality Assurance Program requirements. (No Changes to sections 2.2 through 2.4) 2.5 The-seAP-was- isnplemented-on- Genuery--l ,--M6+-whieh-was-ever 90-days-prier-te-fuel-leading-whieh-began-en-Gune-43 7-4984v The -tran;f cr -ef--eyetem -er--sobeyetem -eA--Progeom -applica-bility-- wee---identi-fi-ed --and-- contro-1-1ed .----Ici-t-ie1---f uel l e a d i n g 7 - preer-it i ee %--ieit-i e-1--eri deahby r -l e w- P e We r Rev. 10 6/87 L

OQAM testsy-- afte---powee---aseensken--teste-- weee---pePfe Pmed-g aceerdance-with-the-Operating-euality-Assurance-Programe ) The OQAP shall be implemented throughout the operating life of the Callaway Plant. Activities affecting quality shall be accomplished under suitably controlled conditions. Con-trolled conditions include the use of appropriate equip-ment; suitable environmental conditions for accomplishing the activity, such as adequate cleanness; and assurance that all prerequisites for the given activity have been satisfied. 2.6 Consistent with the schedule for accomplishing quality activities, the OQAP shall be established and documented by written policy, program manual, and procedure manuals. Persons conducting safety-related activities shall be responsible to implement approved procedures. The OQAP shall utilize the following document types to describe Program objectives:

1. Operating Quality Assurance Program Policy / Introduction Statement The Operating Quality Assurance Program Policy statement establishes governing principles in accordance with the requirements of 10 CFR 50, Appendix B.

The Operating Quality Assurance Program Policy state-mentandanyrevignstheretoshallbeapprovedbythe Vice President, / Nuclear.

2. Operating Quality Assurance Manual (OOAM)

The OQAM contains a delineation of the Policy state-ment, quality assurance requirements, assignment of responsibilities, and a definition of organizational interfaces. The OQAM is the written description of the' Approval of the OQAM is by the Vice President, Og. Nuclear

          /              and the Manager, Quality Assurance.

3. Callaway Plant Operating Manual The Callaway Plant Operating Manual consists of a multi-volume set of Plant operating procedures prepared or reviewed by the unit staff with the aid of other SNUPPS utilities, Nuclear Engineering, the Lead A/E, the NSSS Supplier, and Fuel Fabricator. These procedures are controlled, approved, and issued in accordance with Administrative Procedures contained within'the Manual. This Manual includes administrative controls consistent with those required by Regulatory Guide 1.33.

Rev. 10 6/87

T^ OQAM Administrative procedures which apply to the entire unit staff, and revisions thereto, shall be reviewed by the Callaway Plant Onsite Review Committee (ORC) and the Quality Assurance Division. The final approval of Administrative ProcE9ures and revisions thereto shall be by the Manager, Callaway Plant. The review and approval of other Plant operating procedures and revisions thereto shall be in accordance with approved Administrative Procedures which implement the require-ments of the Technical Specifications.

4. Union Electric Quality Assurance Procedures Manuals The Quality Assurance Procedures Manuals consist of a set of procedures prepared by various responsible UE Departments or Functions. These procedures are ap-proved by the various Department or Function Heads and serve to implement the requirements specified herein regarding the Quality Assurance Division and offsite quality activities necessary to support the operation of Callaway Plant.

Procedures within the Union Electric Quality Assurance Procedures Manuals and revisions thereto shall be reviewed by the Quality Assurance Division. Final approval of procedures and revisions to these Manuals is by the responsible Departmen g or Function Head, and the Manager Quality Assurance. E r 7---The-Ee-1leway--Plent- deeign f- scr.:;treetion-and preeperatiena1 t e s ti n g - eoti vi ties--weee--geve rned - by--t he--eeaMby - As s ur a n c e Pregram -described- in- bhe--6NUPP6--Geag-Assuranee-Pregrams der-Bestgn-and-Eenstreetten-Manualv 2.67 IlbE Company may employ the safety-related services of architect engineers, NSSS suppliers, fuel fabricators, constructors, and others which provide or augment UE efforts during the operating phase. These organizations shall be required to work under a quality assurance program whose controls are consistent with the scope of their effort. This does not preclude any organization from working under the UE OQAP. The quality assurance program of outside organizations shall be subject to review, evaluation and acceptance by the UE Company Quality Assur-ance Division prior to the initiation of safety-related work. Vendor programs and procedures shall also meet UE's commitment to USNRC Generic Letter 83-28. 2.9h" Disputes which may arise between QA or QC personnel and personnel in other UE organizations which cannot be re-solved shall be referred to the next higher level of management for resolution. Disputes which cannot be Rev. 10 6/87

OQAM resolved through these levels shall be resolved ultimately by the Executive Vice President. 9(1) 2.40 Preservice (PSI) and inservice (ISI) inspection, testing, and examination activities may be performed by outside organizations. These inspections and other operating phase

        " code" activities shall comply with the requirements of the applicable Code Edition and Addenda of the ASME Boiler and Pressure    Vessel    Code. This   compliance     includes    the independent third-party inspection coverage of " code" items by an Authorized Nuclear Inspector.

10(1) 2.44 General indoctrination and training programs shall be developed for personnel performing safety-related activi-ties to assure that responsible functions, departments, and individuals are knowledgeable regarding quality policy and requirements of applicable manuals and procedures. The requirements for training of Callaway Plant personnel are described in Section 13.2 of the Callaway-SA FSAR. The training of permanent Plant personnel is the responsibility of the Superintendent, Training. UE personnel performing complex, unusual, or hazardous work shall be instructed in special indoctrination or briefing sessions. Emphasis shall be on special requirements for safety of personnel, radiation control and protection, unique features of equipment and systems, operating constraints, and control requirements in effect during performance of work. Train-ing shall be conducted as required to, as a minimum, meet the requirements of UE's commitment to Regulatory Guide 1.8 (ANSI /ANS 3.1), Regulatory Guide 1.33 (ANSI N18.7), other Regulatory Guides as endorsed in OQAM Appendix A, and other regulatory requirements. Records of training shall be maintained as described in Section 17. Where required by code or standard, personnel are trained or qualified according to written procedures in the principles and techniques of performing specific activities. Special equipment, environmental conditions, skills, or processes shall be provided as necessary for the effective implementation of the OQAP. 11(1) 2.49 An audit system shall be established to assure management is advised of Program effectiveness. The implementation and effectiveness of the OQAP shall be assessed through an audit program of quality activities which includes design, procurement, modification, and operation. The Manager, Quality Assurance is responsible for a system of planned audits to assure OQAP compliance, with a frequency commen-surate with the Program aspect's safety significance and in accordance with the requirements of Section 18. He is responsible for conducting audits of offsite and onsite activities. Deficiencies identified during the audit process are reported to responsible management of the Rev. 10 6/87 L

OQAM i I organization involved in the resolution and follow-up to assure corrective action. 12(1). gg 2.43 The Vice -President, / Nuclear provides for an independent assessment of the . scope, implementation, . - and

. . effectiveness of the OQAP to assure compliance with policy,.

commitments, and the requirements of 10 CFR 50,. Appendix B l as set forth in this OQAM. This assessment shall be i conducted biennially and may be by representatives of other utilities, co outside adds.ns,ultants ,, or. UE management In tson, varsous reports are sesued i to t entativehr.esident, repr*Se Tsce Nuclear on a periodic basia to assist his independent assessment of the _0QAP

semiannual QA report, and periodic QA audit reports). Qg.,

13(1) , 2.44 Implementation of OQAP controls over . activities affecting. quality assures achieving the ~ objective of 'the UE- Company ' $ OQAP to provide management with adequate confidence that

activities affecting quality regarding the design,

! installation, modification,.and operation of the Callaway. Plant are performed consistent with policy. . Documentation ' i of the accomplishment of OQAP objectives is maintained in 1 the form of records of data and other. information as . necessary to support operetion, maintenance, repair, t i modification, refueling, and inservice inspection. 14(1) 2.45- UE Management has established standards of performance which exceed those set forth by the Regulatory Agencies.

~As a management initiative in this area, UE has defined the-word "must" to impose management directed performance standards in excess of and in addition to established

<. Regulatory directed performance. From the viewpoint of UE employees and UE contractors', there is no difference in the degree of compliance mandated by use of the words "shall" ' e or "must. " Compliance with . actions initiated by use of either "shall" or "must" is-' audited and surveilled by the

QA Division. Failure to implement a "must" mandated activity requires corrective action in the same way as i' failure to implement a "shall" mandated activity. However, from an external viewpoint, internally imposed "must" requirements (i.e., those in excess of Regulatory require-ments) are not intended to be subject to enforcement "Must" is defined in Appendix A of this OQAM under i action.

Regulatory Guide 1.74. j- 3.0 DESIGN CONTROL (No changes to sections 3.1 through 3.6) 3.7 Design requirements and changes thereto shall be identi-l fied, documented, reviewed and approved to assure incorpo-4 ration of appropriate quality standards in design documents ! and to control departures from these standards. 5 i Rev. 10 i 6/87 L. . - , ,._ _,.____._ _.- _ -._ - --_ _ _ , . _ . _ . _ , _ , _ , _ _ _ _ _ _ . , . _ - .

k l ON

     -         Modifications to structures, systems, and components shall consider, as a minimum, the design bases described in the Callaway-SP and the Callaway-SA FSAR and the Technical Specifications.              Design' criteria documents which are newly issued or modified in the course of design or design changes         shall be          reviewed by the--4)ee-1-ity---Aeeueenee Bkvksien a y perintendent in the Nuclear Engineering Department                for seismic and quality group classifica-tion and selection of quality standards.                        Design. criteria
   .          . documents consist of original Plant design criteria, system descriptions           and other documents           defining design               input which change the Plant as described in the FSAR.

(No changes to section 3.8) 3.9 Procedures shall specify requirements for the review and approval of_ design changes by the organizations or individ-uals that performed the original design or Nuclear Engi-neering. Design control activities, including design changes, may be delegated to others provided they have access to background and technical information. Design

 ,             control measures for design revisions shall be commensurate with those applied to the original design.                        Specificatiens and- eevisiene--thecete ,--genereded-er- revised--in--bhe-design prece s s y--ehe-1-1 -%g-a --quel-ity--review--by--the--euality Assurance-Bevtstent (No changes to sections 3.10 through 3.15)

Ov46--Besign-changes-er-eenstructien-eempletien-implemented-after equipment-ee--cyctas -were- re-leesed- to--Nueleer-sperationey but-prier-te-90-days-befere-fuel-leady-were-perfermed-under the--OOAP--er--the--Besign--and--Genstructien--GA--Pregram, Evaluatien-ef-design-changes-persuant-te-40-EFR-50159-began

      ,        en- Genuecy--l r-4904- whig-wes -ever--90 -days-prier-e-fuel lead-en-June-43 7 -4904v 16(1) 3.47   Requests          for    design       changes     affecting       safety-related structures, systems, and components may be originated by the unit staff, Nuclear Fuel or Nuclear Engineering. Design changes shall be processed by Nuclear Engineering. Design changes engineered by the site Nuclear Engineering group shall be the responsibility of the Assistant Manager, Nuclear Engineering.                Design change efforts assumed by the General Offices Nuclear Engineering group shall be the responsibility of the Manager, Nuclear Engineering.

17(1) 3.40 Independent of the responsibilities of the design organiza-tion, the requirements of the Onsite Review Committee (ORC) and the Nuclear Safety Review Board (NSRB) as defined in the Technical Specifications shall be satisfied. Design changes require a safety evaluation which shall be reviewed by the ORC and approved by the Manager, Callaway Plant. In Rev. 10 6/87

  -                   .      -.-      -       -...-.- -                                                               ~.     .-     . .               -          -

l OQAM addition, changes in-the facility as describeq fn the FSAR which involve a change in the CaIIaway Plant Technical j Specifications incorporated.in the license or an unreviewed i safety. question require review and approval by the NSRB and

the. Nuclear Regulatory Commission prior to implementation.

. -When 1 design is performed by _ an outside organization, UE i shall perform . or coordinate a. review of the design ' for operability, maintainability, inspectability, FSAR commit-ment: compatibility, test and-inspection. acceptance criteria

                   - acceptability,     and -design requirements imposed by Plant generating equipment.

28(1) 3.49 Safety evaluations which consider the effect'of the design as described-in the design documents, shall be performed by the responsible UE engineering organization or - outside organization (s). These evaluations shall include the basis for-'the 2 determination that- the design change does not involve: an unreviewed safety question. As deemed necessary by the evaluating organization,-detailed analyses shall be performed to support the bases Hof safety evaluations.

Safety' evaluations. approved by the Manager o r - A s's i s t a n t .

Manager, Nuclear . Engineering - or outside organization are submitted to the ORC. Changes involving the substitution

                   = of equivalent hardware require-safety evaluations to assure that the design requirement' changes are consistent with and-do not alter _the design criteria specified in existing-design documents..        The engineering approval of design documents 'and       safety           evaluations                                                   prepared- by       outside 7                    organizations shall-be by the outside organization.                                                                                             1

_ 29(1)- . - 3.GG The ORC shall review . design ~ change safety evaluations to recommend final approval of design changes. Design changes which involve ~an unreviewed safety question or a change in - the Technical Specifications shall be forwarded to the NSRB . for review. An application for amendment of the license shall be submitted to the Nuclear Regulatory Commission for ! spproval pursuant to-10.CFR 50.90. 120(1) c3.24 - The NSRB shall review safety evaluations to . verify that - , . . changes did not involve unreviewed safety questions.  ; 22(1)

         -3.Ga ' Procedures and instructions related to equipment or systems that are: modified shall be reviewed and updated to reflect the modification prior to' placing the equipment or systems
                   - in operation. to perform safety-related functions.                                                                         Plant 4

Lpersonnel shall be made aware of changes affecting the performance of their duties through procedure revisions, or specific training in the operation of modified equipment or systems, or other appropriate means. 22(1) 3.23 Records shall be maintained which reflect current design including safety analyses, safety evaluations, design Rev. 10 6/87 y - g- o w e-,-e.wr,.-. , - , , , , - - , , , - - , - - - , , - , , . -y->. y - s my

 ,                                                                                        OQAM change      installation- procedures, . material                                                                                       identification documents,_ . procurement documents,                                                                             special process docu-ments, - equipment                          and                 installation specifications,                                                                 and
                       - as-built drawings.                                                                                          -

23(1) 3.44 Drawings 'shall be prepared under a drawing control system which provides for checking methods and review and approval requirements. Drawings shall be subject to reviews by the responsible design organization for correctness, confor-mance to design criteria, and compliance with applicable codes and standards. 4.0 PROCUREMENT DOCUMENT CONTROL (No changes to section 4) 5.0 INSTRUCTIONS, PROCEDURES AND DRAWINGS

         . (No changes to section 5) 6.0              DOCUMENT CONTROL (No changes to section 6.1) 6.2              Functions, departments, and organizations responsible for OQAP implementing documents shall be. required = to provide the   necessary review and                                                        approval                                        for      instructions, procedures, specifications,                                                       and drawings.                                               Reviews and, approvals-shall assure that' issued documents.are adequate, authorized,                    . include                        proper                 quality                                        and-        technical requirements, and are correct for intended use.                                                                                                   Individu-

!-- - als o,r groups responsible for preparing, reviewing, and approving documents and revisions thereto shall be identi-fled in written procedures. Specifically, the QA Division shall review Administrative Procedures as described in i Section 2.6; the QC Grpup shall review maintenance and modification procedures; and the QC Group is responsible Work Requests (WRs) and - YNwN*Y

         . preventive                 maintenance                                   requestsRepeating--Mocie   (PMRs)                                           g 5 D*m*a*z y             *,*y ~~c~onta instructions to workers.                                                 However, WRs and RWRs PMRs                                                                 are not

, ' considered " maintenance procedures" which require QC review. l When required, the assignment of inspection points for work authori::ing documents is performed by Planning Department personnel based on established criteria. - Rev. 10 6/87

     *w=     evw-* -we-,w-        www   ,e,ey-w------e-         - - - - - , , - - -          ..-w-n.+w---w       %*------.----e-w--.---e-m-.---sew---,----c-                                    n-.* ee- -[

OQAM for the preparation of inspection procedures and/or checklists to . support maintenance and modification activities. Collectively, these reviews by the QA Division and the QC Group determine:

1. The need for inspection, identification of inspection personnel, and documentation of inspection results; and

2. That the necessary inspection requirements, methods, and acceptance criteria have been identified.

(No changes to sections 6.3 through 6.9) 7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES (No changes to sections 7.1 through 7.5) 7.6 Procurement source evaluation and selection involves the Quality Assurance Division and the originating organiza-tion. The evaluation and selection process shall be specified in Quality Assurance Division procedures and may vary depending on the complexity g relative importance to safety of the item or service. Nuclear Engineering, Nuclear Fuel, Nuclear Services, the unit staff or other organizations participate-4n-+he--que1i-Eieetien -evaluations - ef- supp1-iees in-eeeeracnc+-wi+h -*Pkbben -precedures may be requested to provide input to the qualification evaluations of suppliers. Suppliers of hardware and services which are manufactured prior to avard, considered a commercial grade item, or implemented under the OQAP do not require pre-avard source evaluation audits which to a suppliers capability as a procurement source. y test 7.7 Measures--foc--the-eva-leetion--eed -se-leetien--of--precurement seurees--ehekk--be - speebfied--in--proccduree- en&-may--vary depending--en-+he--eemp-lexity--and- sci;ti-ve---importenee--te safety-ef--the--hbem-er-service,-- Gupp-1-iece--of -hardware-and services-which-ere- menufectuced--peioe -to -awardr-eensidered a-temmercie-1--geede -i-beer-er-implemented- under--the -9s-seAP

        - de--not--require--prc cuerd -eeuree--evakeabien- eudite--which a--eupp1-iece---eapabi1-sty--es---e --precurement attest-g-seuree.       Procurement source evaluations shall consider one or more of the following:

1. Experience of users of identical or similar products of the prospective supplier. NRC Licensee Contractor and Vendor Inspection Program (LCVIP) reports, ASME Certif-icates of Authorization, Coordinating Agency for Supplier Evaluation (CASE) register listings, UE records accumulated in previous procurement actions, and UE product-operating experience may be used in this evaluation. Supplier history shall reflect recent capability. Previous favorable quality experience with Rev. 10 6/87

OQAMl

             'supp1'1ers may be an- adequate- basis for judgements
             -attesting to their. capability. When an LCVIP letter of' confirmation or the _ CASE register listing is used to establish a ' supplier's acceptability as asprocurement-source, 'the documentation - shall identify the " letter" or " audit" used.

2. An evaluation of the supplier's current'qualityJrecords supported by ' documented qualitative and quantitative.

information which can be - objectively evaluated. This

             . may include review and evaluation of the supplier's - QA Program, Manual, and Procedures, as appropriate, and' responses to. questionnaires.

3. A source evaluation ~ of the supplier's technical and quality capability as determined by-a direct evaluation (audit or surveillance) of facilities, personnel and Quality Assurance Program implementation.

(No changes to sections 7.8 through 7.26) 8.0 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS AND COMPO-NENTS (No changes to section 8) 9.0 CONTROL OF SPECIAL PROCESSES (No changes to sections 9.1 through 9.3) 9.4 Qualified outside organizagns may be employed to perform shall be required to special processes onsite and conform to the requirements-submitted described herein. by en--eutende Specg the,e-process _ procedures organization (s) in accordance with procurement document requirements shall receive a technical review by the responsible engineering organization and a quality review by the Quality Assurance Division. 10.0 INSPECTION

   .(No changes to sections 10.1 through 10.13) 10.14 Nuclear Engineering shall be responsible for assuring the development of the inservice testing program plan for pumps and' valves, the test procedures required by this plan, and the securing of consulting services         in this    area. In addition Nuclear Engineering        shall  be   responsible    for administering and performing        the   PSI /ISI  program    and implementing the examination and testing plans developed within the Nuclear Function. They are also responsible for updating the reference plans and NDE procedures subsequent to the    issuance of the     inservice   inspection plans     and Rev. 10 6/87

OQAM procedures. The services of an outside organization may be .

               . secured to        conduct the PSI /ISI examinations.                         PSI /ESE

, inspectien-paans-and-medifi g ens-sha&&-be-reviewed-by-the Gueisty-Assuranee-94vissent , 11.0- TEST CONTROL I .No ( changesi to section 11.'1) t 11.2 Testing programs shall. be established to demonstrate -item , or system performance. Testing shall be performed in accordance with written procedures which incorporate or . reference the requirements and acceptance limits contained in - applicable - Callaway Plant (1) Technical Specifications, drawings, instructions, procurement documents, specifications, codes, standards, and regulatory

requirements.

(No changes to sections 11.3 through 11.7) 11.8 Test results.shall be documented, reviewed, and approved-by ^ i qualified individuals or groups. Equipment found .to be deficient shall be identified in accordance with Section

14. Surveillance test procedure results which fail to meet the re and acceptance criteria of Cattaway i

Plant (1guirements Technical Specifications shall be documented and reviewed in accordance with Section 15. Deficiencies identified as nonconforming shall be processed in accordance with Section 15. ' i 11.9 Review and approval of tests and experiments not described - in the Plant (l{SARshallbeconductedasspecifiedintheCaZZauay Technical Specifications and'10 CFR 50.59.

!'     44v40-5nitial-- etectup---teeting--wes- -esnduc-te- ;;h;c.qucat --te preeperational--testing--by--qualified--persennel--tet---4F                                              :

provide--edditione4 -assurance--thet -+he--feekkkty,--hed -been i adequately--designedt--GF--te--verify--the--eerrectness--ef i assumptiens-- ueed --fer--5:ad-i-ctiag---Plant-- r;;;;>sn;;; --te antiespated-trenaients-end- poetti .ted--eeei-dent; r-and-3)--te i previde--eeeeeeeee-that--eenstructien--and - isote-1-Latien--ef facility-equipment-had-been-aeeemplished-in-aceerdenee-with design r-- 9he - Oupc rintendent r--Baghneering- wee--responsible

;.               fer- the      ' ' ' " - i-an--and-cenduet-ef--the -inkt sel -s tartup testingr---Enitsak- st;; tup --beet--preg-rea -precedures--were reviewed- by--the--ORG-and-eppreved- by--the -MenagePr-Ea44away Plant,(2) 44,44-Enitial-startup-testing-evaluatiens-were-the-respensibility                                                 l ef- the--4RGr --Test--eeeu4te--were-eve 1-na t+4 -by-the--ORG--and                                      j j'                 they--were -eeeisted--by- peceonne4--frem--the--Plent--Startup                                          '

erganimatieny---the---Plent----Engieeecing---staff y---Nuclear Engineeringy--Leed--h/-Br-N666--eupplic r ,--Site- k/ Fn--ee -ether I

 -                                                                                Rev. 10                            l 6/87 i                                                                                                            - , . -

OQAM erganisatsens--es---necc;;;;=f---to --veci-fy --eempkianee--with acceptance-eriteria r--@est- peoceducee,--beet -dete r-and-test data-eveleetiene -shell -be-retained-es--pect--&f -bhe-Plantas reeerds,---Endividuals--that--directed--er--supervised--the eenduet--e6---iedividue1---startup- -tc; t+--end --individuals assigned--: ;;;;nsibi1-i-ty--6oc--the--review--and--epprove-1--ef startup--test--precedures--er--results--were--qualified--in aseerdance7p-Regulatery--Gu4de--iv6 --bue 7 -they--weee--net eentifsed 14rH-At--bhe- ;cica;c -ef--systems--er-mb;ys t;me - to--the--Plant ergenisatieny---ther-- a;;ur.cd --responsibility---fee---their operatien-te-suppert-Plant-evelutiensv--The-seAP-became-the g e v e r ning- see-14.ty--preeeeence--Peogeem ,--on -a - s y s tem-by- s y s t em er-;ubsystem-p,--ee -symbems-were--re1;;;;d -bo -bhe-Plant ergenisatsene 10(1) 11.40 Provisions shall be established for the performance of surveillance testing to assure that the necessary quality of systems and components is maintained, that facility operations are within the safety limits, and that limiting conditions for operation can be met. The test g frequency shall be as prescribed in the CaIIauay Plant Technical Specifications. The provisions for surveillance testing shall include the preparation of a surveillance testing schedule (s) which reflects the status of in-plant surveillance tests. Qualified personnel shall perform surveillance tests. 11(1) 11.14 Appropriate tests shall also be performed subsequent to Plant modifications, maintenance or significant operating procedure changes to confirm expected results. Tests provide a level of confidence in structure,. system or component operation or functional acceptability. 12(1) 11.45 When required by procurement documents, testing shall be employed as a means of purchased material and equipment acceptance. Acceptance testing of this nature shall be performed during receiving inspection or subsequent to installation in accordance with Section 7. 13(1)

11.46 Equipment failure or malfunction analysis testing may also be performed. The causes of malfunctions shall be investigated, evaluated, and recorded. Experience with malfunctioning equipment and similar components shall be reviewed and evaluated to determine whether a like kind replacement component can be expected to perform its function reliably.

12.0 CONTROL OF MEASURING AND TEST EQUIPMENT (No changes to sections 12.1 through 12.3) Rev. 10 6/87

OQAM 2 12.4 The calibration and control program established at' . the . Callaway-Plant shall assure that METE, reference standards, and ' PI ma accuracy. - The Assistant - Manager, / gain their required Operations and Maintenance is responsible for-assuring the program establishment. ' Program implementation

             -is the responsibility of the appropriate Department Heads.

(No changes to. sections 12.5 through 12.8) 13.O~ HANDLING, STORAGE,~AND SHIPPING

      -(No~ changes.to section 13) 14.0   INSPECTION, TEST, AND OPERATING STATUS (No changes to section 14) 15.0   NONCONFORMING MATERIAL, PARTS OR COMPONENTS (No changessto' sections 15.1 through 15.7) 15.8   The . Manager,   . Operations    Support    shall(fave      material-nonconformance     summaries    prepared semi /       annually -and
    ,         analyzed for potential adverse quality trends.                 These summaries shall.be - sent to the Quality Assurance Division for an independent review.          The results of this review shall be reported to management.

(No changes to sections 15.9 and 15.10) 16.0 CORRECTIVE ACTION

       -(No changes to section 16.1) 16.2   Conditions , adverse to quality - which impede the implemeng7 j              tion or reduce the effectiveness of the operating QA

! Program shall be controlled by the measures described herein. Adverse conditions may include. noncompliance with procedural requirements; reportable occurrences required by regulations; adverse nonconformance trends; or deficiencies identified in the OQAP. Procedures shall provide , instructions for identifying, reporting, 'and initiating corrective action to preclude recurrence of adverse condi- . tions. Within the UE corrective action program, a Request

for Corrective Action (RCA) may be employed to document I adverse conditions (such as those described above) within or between Nuclear Function Departments. while--e A t Corrective Action Report (CAR) shall be employed to l- document more significant adverse conditions, 4such as a recurring condition for which past corrective action has i been ineffectivek or a significant breakdoun in j administrative and managerial control systems which could i result in a system designed to prevent or mitigate serious 1

! Rev.-10 6/87

OQAM events not being able to perform its intended function. While-eny-@E-+rgesint-len -mey initiate-en- REA-er- CAR, they are--nermally--employed --by the--eA--Bi-vi eien te--deeument adverse--gitiene--end---to --iei-tiete--eerreehive--action requests. Each of the Nuclear Function Managers is responsible for developing and implementing a program for identifying and controlling adverse conditions. Per i nt r a- d e pa r tme nt--eeeeeebive- eetiens,-- t hi s --may --be-- a c e em-pli s h e d - by- edeptien- of--the--RGM C-AR-ment-ef--an--ekternadive-pregramish ppappeeme As a-ee-by-develep-minimum each program shall pro @e for developing and analyzing trends on a semi / annual basis. An RCA may not need to be issued when corrective action is being monitored by an alternate, documented program. 16.3 Corrective action documents shall be transmitted to the responsible organization. The responsible organization shall investigayeg the findings and identify the cause (s) of the deficiency, and specify and initiate the action (s) necessary to correct the conditions and prevent recurrence. (No changes to section 16.4) 16.5 The corrective action documents shall be closed out by verifying the implementation and adequacy of corrective action. Summaries of corrective action documents shall be revieued ffgethe effectiveness of the mrrective actions taken and analyzed for potential adverse quality trends. These summaries and analyses shall be sent to the Quality Assurance Division for an independent review. The results of this review shall be reported to management. The Quality Assurance Division shall periodically prepare summaries of CARS and submit them to the NSRB and appropriate levels of management. 16.6 The Quality Assurance Division shall--eeview -requeste- for EARS--prier--te--issuance--and shall close out CARS by verifying the implementation and adequacy of corrective action. Copies of completed CARS shall be transmitted to management to keep conditions adverse to quality. (tg apprised of significant 16.7 The close-out of corrective action documents shall be accomplished as promptly as practicable but shall occur only after the-effectiveness-ef the corrective action taken has been verified. Verification may be accomplished through direct observations, written communications, re-audit, surveillances, or other appropriate means. It is understood that the term " corrective action" includes remedial action necessary to correct the deficiency, as well as corrective action necessary to preclude recurrence. The nature of the deficiency may be such that remedial actions need to be taken immediately whereas development 7 Rev. 10 6/87

OQAM-

 '~

and -implen g tion 7----and----determinatien----ed----the addeetsveness of corrective action to preclude

             ' recurrence may take substantially longer.

(No changes to section 16.8) 17.0 QUALITY ASSURANCE RECORDS

          ~

(No changes to section 17) 18.0 ! AUDITS (No changes to sections 18.1 through 18.4) 18.5 .The Manager, Quality Assurance shall be responsible ' for assuring the implementation of a comprehensive system of planned audits to verify compliance with the OQAP.- The Manager, Quality. Assurance has sufficient- authority and - organizational freedom to schedule and perform both inter-nal and' external audits. He has the organizational respon-sibility to measure and assure the overall effectiveness of the'OQAP'and'is independent of the economic pressures of-production when opposed to safety or quality. The Manager, QgityAssurancehasdirectaccesstotheVicePresident,

              /     Nuclear and the General Manager, Quality Systems.. The General Manager, Quality Systems has direct access to-the Executive Vice President.

(No changes to sections 18.6 through 18.13) 18.14 Audits ~ shall also be conducted when: 1) significant changes are made in functional' areas of the Quality Assur-ance Program such as significant reorganization or proce-dure revisions; or 2). when it is suspected that the quality of the _ item is in jeopardy due to deficiencies in the Quality. Assurance Program; or 3) when a systematic, inde-pendent assessment of Program effectiveness is considered necessary; or 4) when it'is necessary to verify implementa-

              ' tion of required corrective action. The NSRB shall selec-tively review audit reports of onsite audits.            The ~ NSRB shall also periodically review the onsite' audit program as developed by the Quality Assurance Division, to assure that audity1yare   being performed in accordance with Callaway Technical Specification requirements and the OQAP.

Plant Appropriate levels of' management shall be provided copies of internal and external augi)t reports. The audits described in the Cattaway Plant Technical Specifications which are performed under the cognizance of the NSRB shall be conducted by the Quality Assurance Division. 18.15 Audits shall be conducted using written plans in accordance with Quality Assurance Division procedures. The procedures require evaluation of work areas, activities, processes, Rev. 10 6/87

j OQAM I goods, services, and the review of documents and records for quality-related practices, procedures, and instructions to determine the effectiveness'of the implementation of the

    .                   OQAP. and compHtnce with 10 CFR 50, Appendix                                                            B and the The audit plan 7

CaZZaway~PZant Technical Specifications. shall identify the audit scope, the requirements, the

                      - activities to be audited, organizations to be notified, the
                      - applicable documents, the schedule, and the written proca-dures or checklists.as appropriate.                                               The audit plan and any-necessary reference documents shall be available to the audit team members.

(No changes to sections 18.16 ' and 18.17) 9 k i i Rev. 10 6/87 J

  & * -e e er=+- .+,. .-w+-,r-,---,w-r-   ..,--r-,,,-we-.
                                                        -   -,,---r.ww.--w...--,-..,-*-.      me.e-,m.,w,      w------r,s-,       .wr..m-,ww.~w--,,--
                                                                                                                                                        .....ve-

OQAM I*I if able-4-7 v a-4-dele tedy--See-S ectien-G v6 v t Rev. 10 6/87

OQAM 4 Tab 4e-47,G-G-deletedv--See-Sectien-Ev6vt- ( 2 ) Rev. 10 6/87

OQAM ifable-47,G-3-deletedv--See-Sectien-519xt (2) Rev. 10 6/87

OPERATING QUALITY ASSURANCE MANUAL (OQAM) APPENDIX A OQAM CONFORMANCE TO APPLICABLE NRC REGULATORY GUIDES (No changes to the introduction) i i 4 A-1 Rev. 10 i 6/87 l 1

OQAM APPENDIX A REGULATORY GUIDE 1.8

• PROPOSED REVISION 2
• DATED 2/79 (No changes to Regulatory Guide 1.8)

REGULATORY GUIDE 1.28 REVISION 2 DATED 2/79 (No changes to Regulatory Guide 1.28) REGULATORY GUIDE 1.30 INITIAL ISSUE DATED 8/72 Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electronic Equipment (Safety Guide 30) (Endorses ANSI N45.2.4-1974/IEEE 336-1971) DISCUSSION: UE complies with the recommendations of this Regulatory Guide with the following clarifications: For eperating-phase maintenance and modification activities whieh-are comparable-in-nature-and-extent-te-similar-activities-eenducted-during the-eenstructien-phaser-UE-shait-either-eentrel-these-activities-under the-Operating-QA-Program-er-under-a-UE-accepted-yggstructien-eA Pregramv--When-the-Operating-GA-Pregram-is-usedy UE shall comply with the Regulatory Position established in this Regulatory Guide in that QA programmatic / administrative requirements included therein (subject to the clarifications below) shall apply to these maintenance and modification activities even though such requirements may not have been in effect originally. Technical requirements associated with the maintenance and modifications shall be equal to or better than the original requirements (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection requirements) , or as required to preclude repetition of defects. Specific clarifications for ANSI N45.2.4 - 1972 are indicated below by sections. Section 1.4 - Definitions in this Standard which are not included in ANSI N45.2.10 shall be used; definitions which are included in ANSI N45.2.10 shall be used as clarified in UE's commitment to Regulatory Guide 1.74. Section 2.1 - Planning requirements, as determined by engineering, shall be incorporated into modification procedures. Engineering actione performed in accordance uith thia section of the Standard are conducted with QA/QC involvement and are subject to QA audit. Proce-dures for these activities receive a cross-diaciplinary revieu as vett ao revieu by the Onsite Revieu committee (QA is a permanent member of this committee). For other activities, QA audits and and QC inspection activities accure QA/QC involvement.qygveillances, Section 2.3 - Procedures and Instructions shall be implemented as set forth in OQAM Sections 2, 3, 5, 10 and 11 and by compliance with the A-2 Rev. 10 6/87

OQAM APPENDIX A Callaway Plant Technical Specifications and Regulatory Guide 1.33 (ANSI N18.7) as set forth in this Appendix in lieu of the requirements set forth here. When compliance with an NRC accepted program (e.g., Callauay Plant Technical Specificatione) is referenced, UE has substi-tuted the NRC accepted program for applicable regulatory requirements in lieu of })g general requirementa of the Quality Assurance program standarde. Section 2.4 - Results shall be implemented as set forth in OQAM Sections 10, 11 and 17 and by compliance with ANSI N18.7 as set forth in this Appendix in lieu of the requirements set forth here. In every caseeitheridenticalorequivalentcontroleareprgyjdedin the sections of the referenced Standards or documente Section 2.5.2 - Calibration and Control covers three classes of instrumentation used by UE: (1) M&TE (portable measuring instruments, test equipment, tools, gages, and non-destructive test equipment used in measuring and inspecting safety-related structures, systems, and I components) ; (2) reference standards (primary, secondary, transfer, and working); and (3) permanently installed process instrumentation (PI). l With respect to the first sentence, M&TE and reference standards shall ) be included in a calibration program and shall either be calibrated at prescribed intervals or shall be calibrated prior to use. With I respect to the last sentence, personnel shall be trained and proce-dures shall require that the calibration label or tag shall be re-viewed to determine calibration status prior to use: This label or tag shall be considered to clearly identify equipment which is out of calibration. Lack of a label or tag shall require the organization responsible for calibrating the M&TE to review records and affix a new label or tag based on calibration data. M&TE and reference standards shall comply with sentences 2, 3 and 4. With respect to the 3rd sentence, UE uniquely identifies each safety-related item of permanently installed process instrumentation. This identification provides traceability to calibration data. These actions are UE's alternative to the tagging or labeling of items to indicate the calibration date and the identity of the person who performed the calibration. Permanently installed process instrumenta-tion shall comply with sentences 1, 2, and 5. Section 3 - Preconstruction verification shall be implemented as follows: (1) shall be required only for modifications (2) shall be implemented with the clarification that " approved instruction manuals" shall be interpreted to mean the manuals provided by the supplier as required by the procurement order - these manuals are not necessarily reviewed and approved, per se, by UE: (3) no special checks shall be required to be made by the person withdrawing a replacement part from the warehouse - equivalent controls are assured by compliance with Regulatory Guide 1.38 (ANSI N45.2.2) as set forth in this Appendix; and, (4) shall be complied with as determined by engineering or by individual technicians as part of the modification process. A-3 Rev. 10 6/87

OQAM APPENDIX A Engineering actions performed in accordance uith this Section of the Standard are conducted uith QA/QC involvement and are subject to QA audit. Procedures for these activities receive a cross-disciplinary revieu as well as revieu by the Oneite Revieu Committee (QA is a permanent member of this committee). For other activities, QA audits and aurveittar(3gs, and QC inspection activities assure QA/QC snvolvement Section 4 - Installation shall be implemented as stated and as fol-tous: Engineering actions performed in accordance uith this Section of the Standard are conducted with QA/QC involvement and are subject to QA audit. Procedures for these activities receive a crosa-disciplinary revieu as well as revieu by the Oneite Revieu Committee (QA is a permanent member of this committee). For other activities, QA audits and gg$veillances, and QC inspection activities assure QA/QC involvement. Section 5.1 - Inspections, including subsections 5.1.1, 5.1.2, and the first sentence in 5.1.3, shall be implemented as set forth in OQAM Section 10. The inspection program shall incorporate, as determined by engineering and QC, those items listed in these subsections. The remaining sentence in 5.1.3 is covered in equivalent detail in UE's commitment to Regulatory Guide 1.33 (ANSI N18.7), Section 5.2.6; the requirements as set forth in that commitment shall be implemented in lieu of the requirements stated here. In every case either identical or equivalent controls aqqyprovided in the Sections of the referenced Standards or documente. Section 5.2 - Tests, including subsections 5.2.1 through 5.2.3, shall be implemented as set forth in OQAM Sections 3 and 11. In some cases Surveillance testing may be used to meet the appropriate requirements of this Section. Section 6 - Post-Construction Verification is not generally considered applicable at operating facilities because of the scope of the work and the relatively short interval between installation and operation. Where considered necessary by engineering or QC, the elements de-scribed in this Section shall be used in the development and implemen-tation of inspection and testing programs as described in 00AM Sec-tions 3, 10 and 11. Section 7 - Data Analysis and Evaluation shall be implemented as stated herein after adding the clarifying phrase "Where used" at the beginning of the paragraph. This clarification accoyggs for the fact that come testing uitt not generate " Data" as such. Section 8 - Records shall be implemented by conformance with 00AM Section 17 and Regulatory Guide 1.88 (ANSI N45.2.9) as set forth in this Appendix. A-4 Rev. 10 6/87

e OQAM APPENDIX A REGULATORY GUIDE 1.33 REVISION 2 DATED 2/78 Quality Assurance Program Requirements (Operation) (Endorses ANSI N18.7-1976/ANS 3.2) DISCUSSION: UE complies with the recommendations of this Regulatory Guide with the following clarifications: Paragraph C.3 of Regulatory Guide 1.33 (and Section 4.3.4 of ANSI N18.7whichitreferences{19allbeimplementedasrequiredbythe h applicable Callauay Plant Technical Specifications which define

 " Subjects Requiring Independent Review."

Paragraph C.4.a of Regulatory Guide 1.33 (and Section 4.5 of ANSI N18.7whichitreferences}19hallbeimplementedasrequiredbythe applicable Callaway Plant Technical Specifications which define the

 " audit program" to be conducted. The audit program is further defined and shall be implemented as required by the commitment to Regulatory Guide 1.144 (ANSI N45.2.12) as stated in this Appendix.

Paragraph C.S.d of Regulatory Guide 1.33 (and Section 5.2.7.1 of ANSI N18.7 which it references) shall be implemented by adding the clarify-ing phrase "When determined by engineering" in front of the fourth sentence of the fifth paragraph. It is not always practicable to test parts prior to use. For modifications where these requirements are not considered practicable, a review in accordance with the provisions of 10 CFR 50.59 shall be conducted and documented. Engineering actions performed in accordance uith this Section of the Regulatory Guide ara conductad Uith QA/QC involvement and are subject to QA audit. Procedures for these activities receive a cross-disciplinary review as well as revieu by the Oneite Revieu Committee (QA is a permanent member of ORC). For other activities, QA audita and sur-veillances, and QC inspection activities assure QA/QC involvement.(') Paragraph C.S.e of Regulatory Guide 1.33 and Section 5.2.13.4 of ANSI N18.7 which it references shall be implemented subject to the same clarifications made for Regulatcry Guide 1.38 ( ANSI N45. 2. 2) . Paragraph C.5.f of Regulatory Gui.e 1.33 (and Section 5. 2.19 (2) of ANSI N18.7 which it references) shall be implemented with the substi-tution of the word " practicable" for the word "possible" in the last sentence. The action referenced in this Section is the responsibility of the Callauay Plant Operating Organization, and includes QA/QC involvement. QA is involved through audit and curveillance qqtivi-ties. QC is involved in maintenance inspection activities. Paragraph C.S.g of Regulatory Guide 1.33 (and Section 5.2.19.1 on ANSI N18.7 which it references) shall be implemented with the addition of the modifier "normally" after each of the verbs (should) which the Regulatory Guide converts to "shall." It is UE's intent to fully comply with the requirements of this paragraph, and any conditions A-5 Rev. 10 6/87

OQAM APPENDIX A which do not fully comply shall be documented and approved by manage-ment personnet. Management personnel includes QA through cross-disciplinary revieue and through QA permanent membership on the Cattavay Oneite Review Committee. QA hag 39nd ahatt conduct audits or surveillances of preoperationa In these cases uhere conditionsdonotfullycomply[3festing., the reason for the exception shall also be documented. The documentation shall be retained as lifetime records. With regard to Section 3.4.2 of ANSI N18.7 - 1976 titled Requirements for the Onsite Operating Organization: Training standards referenced in this Section are implemented as described in this Appendix's commitments to Regulatory Guide 1.8 (ANSI /ANS 3.1) and Regulatory Guide 1.58 (ANSI N45.2.6-1978) or as otherwise included as part of the Callaway operating license. UE's methods of documenting and otherwise meeting the remainder of the requirements of tp{9 Section are set forth in OQAM Section 2, in the Cattauay Plant Technical Specifica-tions, and in other licensing commitments. Some of UE's technical support organizations are physically located at the Callaway site. Therefore the second sentence of this Section shall be implemented as follows: " Initial incumbents or replacements for members of the onsite or offsite technical support organizations shall have appropriate experience, training and retraining to assure that necessary competence is maintained in accordance with the provi-sions of ANSI /ANS 3.1 - 1978 as committed to in the OQAM." - With regard to Section 4.1 of ANSI N18.7 - 1976 titled General: The UE audit program shall be implemented in accordance with and to meet the requirements of Regulatory Guide 1.144 (ANSI N45.2.12 in this Appendix, OQAM Section 18, and the Callauay Plant { 9s Technical endorsed Specifications. With regard to Section 4.2 of ANSI N18.7 - 1976 titled Program De-scription: Two aspects are addressed in this Section: audits and independent reviews. The independent review program shall be imple-mented as required by the Technical Specifications. The UE audit program shall be described in accordance with and to meet the require-ments of Regulatory Guide 1.((j (ANSI N45.2.12) as endorsed in this Appendix, the Callauay Plant Technical Specifications, and OQAM Section 18. With regard to Section 4.3 of ANSI N18.7 - 1976 titled Independent Review Process: The requirements of this Section, including of its subparts, shall be met by compliance with the Technical Specification requirements and the OQAM. With regard to Section 4.5 of ANSI N18.7 - 1976 titled Audit Program: The UE audit program shall be implemented in accordance with and to meet the requirements of Regulatory Guide 1.144 (ANSIN45.2{}) as endorsed in this Appendix, the OQAM, and the Callauay Plant 7 Techni-cal Specifications. l A-6 Rev. 10 6/87

OQAM APPENDIX A With regard to Section 5.1 of ANSI N18.7 - 1976 titled Program De-scription: The fourth sentence in this Section requires a " summary document." UE's OQAM is organized in accordance with the 18 criteria of 10 CFR 50, Appendix B. UE interprets this OQAM and applicable Regulatory Guides as endorsed in this Appendix to fulfill the require-ments for a " summary document." With regard to Section 5.2.2 of ANSI N18.7 - 1976 titled Procedure Adherence: The temporary change requirements of this Section are delineated in the Technical Specifications for activities occurring aftertheOper9}{ngLicense (OL) is issued; the requirements of the Callaway Plant Technical Specifications shall be used to control temporary changes. With respect to Section 5.2.6 of ANSI N18.7 - 1976 titled Equipment Control: UE shall comply with the " independent verification" require-ments based on the definition of this phrase as given under our commitment to Regulatory Guide 1.74 in this Appendix. Since UE sometimes uses descriptive names to designate equipment, the sixth paragraph, second sentence is replaced with: " Suitable means include identification numbers or other descriptions which are trace-able to records of the status of inspections and tests." The first sentence in the seventh paragraph shall be met after clari-fying " operating personnel" to mean trained employees assigned to, or under the control of, Plant management at Callaway. With regard to Section 5.2.7 of ANSI N18.7 - 1976 titled Maintenance and Modification: UE shall interpret the word " original" in the first sentence of this Section to modify ONLY the words " design bases." This interpretation is to assure that original inspection requirements are only required for modifications and maintenance that are similar in nature and extent to original construction activities. This makes this Section consistent with Section 5.2.17 of the Standard. Opera-tional inspection requirements shall be in accordance with UE's commitment to Section 5.2.17 of the Standard and, in conjunction with the use of qualified maintenance personnel and approved procedures, shall assure quality at least as good as the original quality. Since some emergency situations could arise which might preclude preplanning of all activities, UE shall comply with an alternate to the first sentence in the second paragraph which reads: "Except in emergency or abnormal operating conditions where immediate actions are required to protect the health and safety of the public, to protect equipment or personnel, or to prevent the deterioration of Plant conditions to a possibly unsafe or unstable level, maintenance or modification of equipment shall be preplanned and performed in accor-dance with written procedures. Where written procedures would be required and are not used, the activities that were accomplished shall be documented after-the-fact and receive the same degree of review as if they had been preplanned." A-7 Rev. 10 6/87

  ~

OQAM APPENDIX A With regard to Section 5.2.7.1 of ANSI N18.7 - 1976 titled Mainte-nance Programs: UE shall comply with the requirements of the first sentence of the fifth paragraph, where practical. This clarification t is needed since it is not always possible to promptly determ'lne the cause of the malfunction. UE shall initiate proceedings to determine the cause, and shall make such determinations promptly, where practi-cal. QA is involved via both audits and surveillances, and i involved in inspection of maintenance inspection activities.'qqy a With regard to Section 5.2.8 of ANSI N18.7 - 1976 titled Surveillance Testing and Inspection Schedule: In lieu of a " master surveillance schedule,".the following requirement shall be met: " Schedules shall~be established reflecting the status of in-plant surveillance tests and scheduled inspections." i With regard to Section 5.2.9 of ANSI N18.7 - 1976 titled Plant Securi-ty and Visitor Control: The requirements of the Security Plan shall be implemented in lieu of these general requirements. When compliance i vith an NRC accepted program (e.g., Callauay Security Plan) is refer-enced, UE has substituted the NRC accepted program for applicable  ! + regulatory requirements in lieu of t}$y eneral g requirements.of the Quality Assurance program standards With regard to Section 5.2.10 of ANSI b'18.7 - 1976 titled Housekeep-inq and Cleanliness Control: The requirements of this Section, beginning with the last sentence of the first paragraph and continuing , through the end of the Section, shall be implemented as described in UE's commitments to Regulatory Guide 1.39 (ANSI N45.2.3) and Regulato-ry Guide 1.37 (ANSI N45.2.1) as set forth in this Appendix. In every e case either identical or equivalent controle are Sections of the reference standards or documents.g59vided in the With regard-to Section 5.2.13.1 of ANSI N18.7 - 1976 titled Procure-1 ment Document control: UE shall comply with the fot lieu of the last sentence of the referenced Section.}gying sentence in Where changes are made to the technical or quality specifications on procurement documents, they shall be subject to engineering and QA i review. With regard to Section 5.2.17 of ANSI N18.7 - 1976 titled Inspection: Inspections may not require generation of a separate inspection report. Inspection requirements may be integrated into appropriate procedures or other documents with the procedure or document. serving as the record. However, records of inspections shall be identifiable and retrievable. 4 With regard to Section 5.2.18 of ANSI N18.7 - 1976 titled Control of Special Processes: UE shall comply with the following sentence in lieu of the last sentence of the referenced Section.

!                                                                                                                                                                                      f 1
;                                                                                        A-8                                                               Rev. 10 6/87

OQAM APPENDIX A For special processes not covered by existing codes or standards, or where item quality requirements exceed the requirements of established codes or standards, personnel, equipment and procedure qualification shall be defined by engineering. With regard to Section 5.3.5 (4) of ANSI N18.7 - 1976 titled Support-ing Maintenance Documents: UE may choose to include material from vendor manuals in any of three ways. (1) The applicable section of a manual may be duplicated, referenced in, and attached to the proce-dure. (2) The procedure may reference the technical manual or a specific section; the manual may then be used in conjunction with the procedure for performing the activity. (3) The material, either as originally written or as modified by the procedure's author, may be reproduced within the body of the procedure. In options (1) and (2) above, the material shall be considered as having received "the same level of review and approval as operating procedures" by virtue of the review and approval of the maintenance procedure. In option (2), the manual shall be available when the procedure is being considered for . approval. In option (3), this material receives the same review and approval as the procedure since it is part of the procedure. In any of the options, Union Electric is NOT reviewing and accepting the entire manual. UE reviews and accepts that portion of each vendor manual that is used by UE. With regard to Section 5.3.9 of ANSI N18.7 - 1976 titled Emergency Procedures: UE's Emergency Procedures are in the format specified by the NRC in the Callaway Safety Evaluation Report, as required for issuance of the Operating License, in lieu of the requirements given here. With regard to Section 5.3.9.2 of ANSI N18.7 - 1976 titled Events of Potential Emergency: The licensing FSAR identified natural occurrenc-es which affect the Callaway Plant. Therefore, UE shall interpret item (11) to mean the natural occurrences which were evaluated in the licensing FSAR. With regard to Section 5.3.9.3 of ANSI N18.7 - 1976 titled Procedures for Implementing Emergency Plan: UE's NRC accepted Emergency Plan shall be implemented in lieu of the requirements in this Section. When compliance uith an NRC accepted program (e.g., Callauay Plant Radiation Emergency Response Plan) is referenced, UE has substituted the NRC accepted program for applicable regulatory requiremente in lieu of thq,qeneral requirementa of the Quality Assurance Program standards REGULATORY GUIDE 1.37 INITIAL ISSUE DATED 3/73 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants (Endorses ANSI N45.2.1-1973) A-9 Rev. 10 6/87

f OQAM APPENDIX A DISCUSSION: UE complies with the recommendations of this Regulatory Guide with the following clarifications: For operating-phase maintenance and modification activities whieh-are eemperable-in-nature-and-extent-te-similar-activities-eenducted-during the-eenstructien-phasey-UE-shall-either-eentrel-these-activities-under the-Operating-eA-Pregram-er-under-a-UE-accepted-yg9structien-eA Programv--When-the-Operating-eA-Program-is-used7 UE shall comply with the Regulatory Position established in this Regulatory Guide in that QA programmatic / administrative requirements included therein (subject to the clarifications below) shall apply to these maintenance and modification activities even though such requirements may not have been in effect originally. Technical requirements associated with maintenance and modifications shall be equal to or better than the original requirements (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection requirements), or as required to preclude repetition of defects. Specific clarifications for this Regulatory Guide and ANSI N45.2.1 - 1973 are indicated below by Sections. With regard to Paragraph C.3 of Regulatory Guide 1.37: The water quality for final flushing of fluid systems and associated components shall be at least equivalent to the quality of the operating system water except for the oxygen and nitrogen content; but this does not infer that chromates or other additives, normally in the system water, are added to the flush water. With regard to Paragraph C.4 of Regulatory Guide 1.37: Expendable materials, such as inks and related products; temperature indicating sticks; tapes; gummed labels; wrapping materials (other than polyeth-ylene); water soluble dam materials; lubricants; NDT penetrant materi-als and couplants, dessicants, which contact stainless steel or nickel alloy surfaces shall not contain lead, zinc, copper, mercury, cadmium and other low melting points metals, their alloys or compounds as basic and essential chemical constituents. No more than 0.1 percent (1,000 ppm) halogens shall be allowed where such elements are leachable or where they could be released by breakdown of the com-pounds under expected environmental conditions. With regard to Section 5 of ANSI N45.2.1 - 1973 titled Installation Cleaning: The recommendation that local rusting on corrosion resis-tant alloys be removed by mechanical methods is interpreted to mean that local rusting may be removed mechanically, but the use of other removal means is not precluded, as determined by engineering or Chemistry. Engineering actions performed in accordance uith this Section of the Standard are conducted with QA/QC involvement and are subject to QA audit. Procedures for these activities receive a cross-disciplinary reviou as uell as revieu by the Onsite Reviou Committee (QA is a permanent member of this committee). For other

activities, QA audits and accure QA/QC involvement.(surveillances,

3) and QC inapection activities A-10 Rev. 10 6/87 t

OQAM APPENDIX A REGULATORY GUIDE 1.38 REVISION 2 DATED 5/77 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items' for Water-Cooled Nuclear Power Plants (Endorses ANSI N45.2.2-1972) DISCUSSION: UE complies with the recommendations of this Regulatory Guide with the following clarifications: With regard to Section 1.4 of ANSI N45.2.2 - 1972 titled Definitions: Definitions in this Standard which are not included in ANSI N45.2.10 shall be used; definitions which are included in ANSI N45.2.10 shall be used as clarified in UE's commitment to Regulatory Guide 1.74. With regard to Section 2.1 of ANSI N45.2.2 - 1972 titled Planning: (First sentence) The specific items to be governed by the Standard shall be identified in Callaway-SP FSAR Table 3.2-1, which lists those structures, systems and components to which the UE QA Program is applied. With regard to Section 2.3 of ANSI N45.2.2 - 1972 titled Results: The specific methods for performing and documenting tests and inspections are given in OQAM Sections 10 and 11. The requirements in these Sections shall be implemented in lieu of the general requirements here. In every case either identical or equivalent controle are provided in the cactions of the referenced Standards or documento. g 3y With regard to Section 2.4 of ANSI N45.2.2 - 1972 titled Personnel Qualifications: Specific requirements for personnel qualifications are set forth in the OQAM description and in the commitments in this Appendix. These requirements shall be implemented in lieu of the general requirements stated in this Section. In every case either sdentical or equivalent controla referenced Standarda or document.959 provided in the sectione of the With regard to Section 2.7 of ANSI N45.5.2.2 - 1972 titled Classifica-tion of Items: UE may choose not to explicitly use the four level classification system. However, the specific requirements of the Standard that are appropriate to each class are generally applied to the items suggested in each classification and to similar items, as determined by engineering. Engineering actions performed in accor-dance with this section of the Standard are conducted uith QA/QC involvement and are subject to QA audit. Procedures for these activi-ties receive a croaa-disciplinary reviou as veil as revieu by the Oneite Reviou Committee (QA ia a permanent member of thic committee). For other activities, QA audits and and QC inspection activities accure QA/QC involvement.gygopittances, With regard to Section 3.2.1 of ANSI N45.2.2 - 1972 titled Level A Items: As an alternate to the requirements for packaging and contain-erizing items in storage to control contaminants (Items (4) and (5)), A-11 Rev. 10 6/87

OQAM APPENDIX A UE may choose a storage atmosphere which is free of harmful contami-nants in concentrations that could produce damage to stored items, as determined by engineering. Similarly (for Item (7)) UE may obviate the need for caps and plugs, as determined by engineering, with an appropriate storage atmosphere, and may choose to protect weld-end preparations and threads by controlling the manner in which the items are stored. These clarifications apply whenever items (4), (5) or (7) are subsequently referenced and to Section 3.5.1 titled Caps and Plugs and Section 3.4 titled Methods of Prevention. Engineering actions performed in accordance uith this section of the Standard are conduct-ed uith QA/QC involvement and are subject to QA audit. Procedures for these activities receive a cross-disciplinary reviou as uell as review by the Onaite Reviou Committee (QA is a permanent member of this committee). For other activities, QA audits an and QC inapactionactivitiesassureQA/QCinvolvement.f3gurveillances, With regard to Section 3.3 of ANSI N45.2.2 - 1972 titled Cleaning: (Third sentence) UE interprets " documented cleaning methods" to allow generic cleaning procedures to be written which shall be implemented, as necessary, by trained personnel. Each particular cleaning opera-tion shall be either governed by an individual cleaning procedure or by a generic procedure either of which shall specify method (s) of cleaning or type (s) of solvent (s) that may be used in a particular application. With regard to Section 3.4 of ANSI N45.2.2 - 1972 titled Methods of Preservation: (First sentence) UE shall comply with these require-ments subject to the clarifications of Section 3.2.1 (4) and (5) above, and the definition of the phrase " deleterious corrosion" to mean that corrosion which cannot be subsequently removed and which adversely affects form, fit, or function. With regard to Section 3.6 of ANSI N45.2.2 - 1972 titled Barrier and Wrap Material and Dessicants: This Section requires the use of nor.halogenated materials in contact with austenitic stainless steel. Refer to Regulatory Guide 1.37 for the UE position. With regard to Section 3.7.1 of ANSI N45.2.2 - 1972 titled Containers: Cleated, sheathed boxes may be used up to 1000 lbs. rather than 500 lbs. as specified in 3.7. l(1) . This type of box is safe for, and has been tested for, loads up to 1000 lbs. Other national standards allow this (see Federal Specification PPP-B-601) . Special qualification testing shall be required for loads above 1000 lbs. With regard to Section 3.7.2 of ANSI 45.2.2 - 1972 titled Crates and Skids: Crates shall be used for equipment in excess of 1000 lb. in weight. Skids or runners shall be used on boxes with a gross weight of approximately 100 lb. or more, allowing sufficient floor clearance for forklift tines (as nominally provided by 4 inch lumber). With regard to Section 4.2.2 of ANSI N45.2.2 - 1972 titled Closed Carriers: The use of fully enclosed furniture vans, as recommended in (2) of this Section, is not considered a requirement. Stated for A-12 Rev. 10 6/87

OQAM APPENDIX A information only,I3' UE shall assure adequate protection from weather or other environmental conditions by a combination of vehicle enclo-sure and item packaging. With regard to Sections. 4.3, 4.4 and 4.5 of ANSI N45.2.2 - 1972 titled, respectively, Precautions During Loading and Transit, Identi-fication and Marking, and Shipment from Countries Outside the Unit-ed States: UE shall comply with the requirements of these Sections subject to the clarifications taken to other Sections which are referenced therein. With regard to Section 5.2.1 of ANSI N45.2.2 - 1972 titled Shipping Damage Inspection: Stores personnel shall normally visually scruti-nize incoming shipments for damage of the types listed in this Sec-tion; this activity is not necessarily performed prior to unloading. Since required items receive the Item Inspection of Section 5.2.2, separate documentation of the Shipping Damage Inspection is not necessary. Release of the transport agent after unloading and the signing for receipt of the shipment may be all of the only action taken to document completion of the Shipping Damage Inspection. Any nonconformance noted shall be documented and dispositioned as required by OQAM Section 15. The person performing the visual scrutiny during unloading is not considered to be performing an inspection function as defined under Regulatory Guide 1.74; therefore, while he shall be trained to perform this function, he may not necessarily be certified to Regulatory Guide 1.58 (ANSI N45.2.6) as an Inspector. With regard to Section 5.2.2 of ANSI N45.2.2 - 1972 titled Item Inspection: The second division of this subsection requires six additional inspection activities if an item was not inspected or examined at the source. Engineering shall determine and document the extent of receipt inspection based on consideration of items in Section 5.2.2. Engineering actions performed in accordance with this section of the Standard are conducted uith QA/QC involvement and are subject to QA audit. Procedures for these activities receive a crose-dieciplinary reviou as velt as review by the Onsite Revieu Committee (QA is a permanent member of this committee). For other activities, QA audita and assure QA/QC involvement.ggyrveillances, and QC inspection activities With regard to Section 6.1.2 of ANSI N45.2.2 - 1972 titled Levels of Storage: Subpart (2) is replaced with the following: (2) Level B items shall be stored within a fire resistant, weathertight, and well ventilated building or equivalent enclo-sure in which measures have been taken against vandalism. This building shall be situated and constructed so that it is not normally be subject to flooding; the floor shall be paved or equal, and well drained. If any outside waters should come in contact with stored equipment,such equipment shall be labeled or tagged nonconforming, and then the nonconformance document shall be processed and evaluated in accordance with OQAM Section 15. Items shall be placed on pallets or shoring or shelves to permit A-13 Rev. 10 6/87

OQAM APPENDIX A air circulation. The building shall be provided with heating and temperature control or its equivalent to reduce condensation and corrosion. Minimum temperature shall be 40' F and maximum temperature shall be 140' F or less if so stipulated by a manu-facturer. With regard to Section 6.2.1 of ANSI N45.2.2 - 1972 titled Access to Storage Areas: Items which fall within the Level D classification of, the standard shall be stored in an area which may be posted to limit. access, but other positive controls such as fencing or guards shall not normally be provided, with engineering's concurrence. Engineering actions performed in accordance usth this section of the Standard are conducted with QA/QC involvement and are subject to QA audit. Proce-durea for these activities receive a cross-disciplinary review as veil as revieu by the Onsite Revieu Committee (QA is a permanent member of , this committee). For other activities, QA audits and and QC inspection activities assure QA/QC involvement.qugveillances, With regard to Section 6.2.4 of ANSI N45.2.2 - 1972 titled Storage of Food and Associated Items: The sentence is replaced with the follow-ing: "The use or storage of food, drinks, and salt tablet dispensers in any storage area shall be controlled and shall be limited to designated areas where such use or storage is not deleterious to

• stored items, with engineerin 's concurrence." Engineering actions performedinaccordancewith$hissectionoftheStandardareconduct-ed with QA/QC involvement and are subject to QA audit. Procedures for these activities receive a cross-disciplinary revieu as uelt as reviou by the Oneite Revieu Committee (QA is a permanent member of this committee). For other activities, QAauditsanf,gurveillances, and QC inspection activities assure QA/QC involvement With regard to Section 6.2.5 of ANSI N45.2.2 - 1972 titled Measured to Prevent Entrance of Animals: The sentence is replaced with the following: " Exterminators or other appropriate measures shall be used to control animals to minimize possible contamination and mechanical damage to stored material."

With regard to Section 6.3.3 of ANSI N45.2.2 - 1972 titled Storage of Hazardous Materials: The sentence is replaced with the following: " Hazardous chemicals, paints, solvents, and other materials of a like nature shall be stored in approved cabinets or containers which are not in close proximity to installed safety-related systems." The placement of hazardous material storage lockers in the Plant ia bqagd upon inatatted safety-related systems, not particular componente With regard to Section 6.4.2 of ANSI N45.2.2 - 1972 titled Care of Items: The following alternates are provided for the indicated subparts: (5) " Space heaters in electrical equipment shall be energized unless a documented engineering evaluation determines that such space heaters are not required." A-14 Rev. 10 6/87

                                                                                 ~ _ - . .         - - - -

APPENDIX A ff e u a m t , . [ f(6) "Large -(greater .than or equal to 50 HP) rotating electrical ja equipment shall be given insulation resistance tests on a sched-i, uled: basis unless a: documented engineering evaluation determines-p ,

                          ~that such tests are not required."                  -

l 4- (7) " Prior tolbeing placed in storage, large (greater than or equal to.50 HP.or-when. designed to be used with a prime mover of greaterf than or equal to 50 HP) horizontal rotating equipment , shall be evaluated by engineering to determine if shaft rotation i s in: storage is required: the results of the evaluation shall be 3 documented. If rotation is required, it shall be performed at specified" intervals, be documented, and be conducted so that parts' receive a coating of lubrication where applicable and so

                        , that the shaft does not come to rest in the same position occu-iL

{ k* p'iedsprior to' rotation. For long shafts or heavy equipment subject to undesirable bowing, shaft orientation after rotation p shall be specified and-obtained." With regard to Sec61on 6.5 of ANSI N45.2.2 - 1972 titled Removal of , Items from Storage:'"UE does not consider the last sentence of this-i Section to be. applicable to the' Operating Phase due to the relatively short period of' time between installation and use. The first sentence

of the section is replaced withs'"UE'shall develop, issue, and imple-ment 'a procedure (s) which cover (s) the-removal of items from storage.

The procedure (s) shall assure that the status of material issued is i- * [ known, controlled,fand appropriately dispositioned." With regard to Section 6.6 of ANSI N45.2.2 - 1972 titled Storage

                   ' Records :' UE shallLcomply with the requirements of this Section with

' the clarification that, for record purposes,.only the~ access of non-UE l employees ~or' contractors into indoor storage areas shall be recorded. , ). Unloading xn: ' pick-up of ' material shall not be considered " access," nor  ; shall inspection by NRC or-other regulatory agents, nor shall tours by non-UE employees who-are accompanied by tHE employees. l With regar'd'to Section 7.4.2, a subsection to Section 7.4 of ANSI l-N45.2.2-1972 titled Inspection of Equipment and Riqqing: Stated for

information'only Eft is UE's position that this relates to the j operability of tbe hoisting equipment and does not preclude rarating

[ as allowed by Section 7.3. i REGULATORY GUIDE 1.39 REVISION 2 DATED 9/77 , i < l Hou'sekeeping Requirements for Water-Cooled Nuclear Power Plants i (Endorses-ANSI M45.2.3-1975) DISCUSSION: I UE complies with-the recommendations of this Regulatory Guide with the ! 'following clarifications: For operating-phase m'aintenance and modification activities whfeh-are eemperabte-en-nature-and-extent-te-sim64er-eettvities-eenducted-during  ! A-15 Rev. 10 6/87 i k' . _ _ _ _ _

OQAM APPENDIX A the-eenstructien-phasey-UE-shall-either-eenteel-these-activities-under the-Operating-eA-Program-er-under-a-UE-accepted-ye9structien-eA Programe--When-the-Operating-eA-Program-is-usedy UE shall comply with the Regulatory Position established in this Regulatory Guide in that QA programmatic / administrative requirements included therein (subject to the clarifications below) shall apply to these maintenance and modification activities even though such requirements may not have been in effect originally. Technical requirements associated with the maintenance or modification shall be equal to or better than the original requirements (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection requirements), or as required to preclude repetition of defects. Specific clarifications for ANSI N45.2.3 - 1973 are indicated below by Sections. Section 1.4 - Definitions: Definitions in this Standard which are not included in Regulatory Guide 1.74 (ANSI N45.2.10) shall be used; definitions which are included in ANSI N45.2.10 shall be used as clarified in UE's commitment to Regulatory Guide 1.74. Section 2.1 - Planning: UE may choose not to utilize the five-level , zone designation system, but shall utilize standard janitorial and work practices to maintain a level of cleanliness commensurate with Program requirements in the areas of housekeeping, Plant and personnel safety, and fire protection. Cleanliness shall be maintained, consistent with the work being per-formed, so as to prevent the entry of foreign material into safe-ty-related systems. This shall include, as a minimum, documented cleanliness inspections which shall be performed prior to system closure. As necessary, (e.g. the opening is larger than the tools being used) control of personnel, tools, equipment, and supplies shall be established when the reactor system is opened for inspection, maintenance, refueling, modification or repair. Additional housekeeping requirements shall be implemented as required for control of radioactive contamination. Section 2.2 - Procedures and Instructions: Appropriate procedures shall be written and implemented. Section 3.2 - Control of Facilities: UE may choose not to utilize the five-level zone designation system, but shall utilize standard janito-rial and work practices to maintain a level of cleanliness commensu-rate with Program requirements in the areas of housekeeping, Plant and personnel safety, and fire protection. Cleanliness shall be maintained, consistent with the work being per-formed, so as to prevent the entry of foreign material into safe-ty-related systems. This shall include, as a minimum, documented cleanliness inspections which shall be performed prior to system closure. As necessary, (e.g. the opening is larger than the tools A-16 Rev. 10 6/87

OQAM APPENDIX A being used) control of personnel, tools, equipment, and supplies shall be established when the reactor system is opened for inspection, maintenance,. modification, refueling or repair. . Additional housekeeping requirements shall be implemented as required -for-control of radioactive contamination. Section 4 - Records: The requirements of OQAM Section 17 and Regula-tory Guide 1.88 (ANSI N45.2.9) as set forth in this Appendix shall be implemented in lieu of the requirements of the Section. In every case either identical or equivalent controis aggyprovided in the sections of the referenced Standards or documents REGULATORY GUIDE 1.58 REVISION 1 DATED 9/80 (No changes to Regulatory Guide 1.58) REGULATORY GUIDE 1.64, REVISION 2 DATED 6/76 ' Quality Assurance Requirements for the Design of Nuclear Power Plants -(Endorses ANSI N45.2.11-1974) DISCUSSION: UE complies with the recommendations of this Regulatory Guide.with the following clarifications: When uniqueness or special design considerations warrant or are judged to be aqqgopriate, an independent third-levet revieu may be em-played With regard to Paragraph C.2 (1) of Regulatory Guide 1.64: If the designer's immediate Supervisor is the only technically qualified individual available, this review may be conducted by the Supervisor, provided that: (a) the other provisions of the Regulatory Guide are satisfied and (b) the justification is individually documented and approved in advance by the Supervisor's management, and (c) quality assurance audits cover frequency and effectiveness of use of the Supervisors as design verifiers to guard against abuse. With regard to Section 1.4 of ANSI N45.2.11 - 1974 titled Definitions: Definitions in this Standard which are not included in Regulatory Guide 1.74 (ANSI N45.2.10) shall be used; definitions which are included in ANSI N45.2.10 shall be used as clarified in this Appendix. With regard to Section 11 (including subsections 11.1 through 11.7) of ANSI N45.2.11 - 1974, titled Audits: UE's audit program shall be implemented in accordance with and to meet the requirements of Regula-tory Guide 1.144 (ANSI N45.2.12) as endorsed in this Appendix,gggAM Sections 16 and 18, and.the requirements of the Cattauay Plant Technical Specifications. In every case either identical or equiva-tent controls q$e provided in the sections of the referenced Standards or documents A-17 Rev. 10 6/87

n OQAM. APPENDIX A

 . REGULATORY GUIDE ~1.74            ' INITIAL-ISSUE               DATED 2/74 Quality Assurance Terms and Definitions (Endorses ANSI N45.2.10-1973)                     -j DISCUSSION:

UE' complies with the recommendations of this Regulatory Guide with the

  .following clarifications.
 'UE reserves'the right to define additional words or phrases which are not included in this Standard. Such additional definitions shall-be documentedinappropriateproceduresandjgy-in-attaehments/ appendices te-quality-Assuranee-Precedures-Manuaisy            or in Sections of the Operating QA Manual.

In addition.to the' Standard's definitio'n of " Inspection," UE shall use' theJfollowing:. " Inspection (when used to refer to activities that are NOT performed by QA or QC personnel) - Examining, viewing closely, scrutinizing, looking over or otherwise checking activities.. Person-nel performing these functions are not necessarily certified to Regulatory. Guide 1.~5 8 (ANSI N45.~ 2. 6) . " Theseaggjustiesare-con-

trolled by the Callauay Plant Operating Manual When.UE intendsffor Inspection to be performed in accordance with the Operating QA~_ Program-by personnel certified as. required by that Program.and for activities defined by " Inspection" in ANSI N45.2.10, appropriate references to QC group or the procedures to be used for performing the' activity shall be made. If such references are'NOT made, inspections are to be considered under the additional definition given above.

  .Irr addition to the Standard's definition of " procurement documents,"

UE shall utilize the definition given in ANSI N45.2.13. The compound defin'ition is given as'follows: Procurement documents - Contractually binding documents that identify and_ define the requirements which items or services must meet.in order to be considered acceptable by

  -the purchaser.- They may include documents which authorize the' seller to perform services or supply equipment, material or~ facilities on behalf of the purchaser (e.g.       Engineering Service Agreement agree-ments for engineering, construction, or consulting services) , con-tracts,-letters of intent, purchase requisitions, purchase orders, or proposals and their acceptance, drawings, specifications; er instruc-tion which define requirements for purchase.
    " Program. Deficiencies" (Not defined in ANSI N45.2.10, but used and defined differently in Regulatory Guide 1.144 (ANSI N45.2.12))          -

Failure to develop, document or implement effectively any applicable element of the Operating QA Program.

    " Quality Assurance Program Requirements" (Not defined in ANSI N45.2.10 but.used and defined differently in ANSI N45.2.13) - Those individual requirements of the Operating QA Program which, when invoked in total or i~n part, establish the requirements of the quality assurance A-18                           Rev. 10 6/87

.                                           OQAM APPENDIX A i

program for the activity being controlled. Although not specifically used in the Operating QA Program, ANSI N45.2 may be imposed upon UE's suppliers.

      " Independent Verification" - Verification by an individual other than the person.who performed the operation or activity being verified that required actions have been completed.       Such verification need not require confirmation of the identical action when other indications provide assurance or indication that the prescribed activity is in                 1 fact complete. Examples. include, but are not limited to: verification of a breaker opening by observed remote breaker indication lights; verification of a set point (made with a voltmeter or ammeter for example) by observing the actuation of status or indicating lights at the required Panel-meter indicated value'; verification that a valve has been positioned by observing the starting or stopping of flow on meter indications or by remote value positions indicating lights.
      " Audit" (This is'a modification of the word's definition - to allow               -

the usenof subjective evidence if no evidence is available - as defined in Section 1.4 of ANSI N45.2.12 - 1977 (Regulatory Guide 1.144) and Section 1.4.3 of ANSI N45.2.23 - 1978 (Regulatory Guide

-1.146) as opposed to the definition given in ANSI N45.2.10 - 1973) -A documented activity performed in accordance with written procedures or checklists to verify, by examination and evaluation of objective

     -evidence where available, (subjective evidence may be used when objective evidence is not available), that applicable elements of the Quality Assurance Program have been developed, documented and effec-tively implemented in accordance with specified requirements.         An audit should not-be confused with surveillance or inspection for the

, sole purpose of process control or product acceptance.

      "Must" - (Not defined in any ANSI Standard) - An internally auditable requirement imposed by UE management upon its employees, contractors, and agents - above and in excess of the legally binding requirements of the appropriate regulatory body. Such items are internally re-quired but not externally enforceable.        (See additional discussion under Section 2.15 of the OQAM.)

1 j nw; gin---4 Net-defined-in-any-ANSE-Standardt---Means-the-same-as r Ashalin-exceps-when-used-te-denete-simple-futurityv--yg9n-used-te denote-futurity 7 8wi448-is-nermally-fellowed-by 8be,n

      " Unit staff" - (Not defined in any ANSI standard) - Means those personnel who report to the General Manager, Nuclear Operations. This l

l_ term shall also be synonymous with the "onsite operating organization" described (but not defined) in ANSI N18.7-1976, Sectiop1}.4.2; the

       " unit staff" as used in the OQAM and in CaIIauay Plant         Technical Specifications Section 6.3 and its subparts and Secp{9n 6.5.2.9.b; the
       " unit organization" described in the Callauay Plant        Technical Specifications Section 6.2.2.
       "Like kind replacements" - (Not defined in any ANSI standard) - Like kind replacements include both exact item replacements and other item A-19                           Rev. 10     ,

6/87

                                             'OQAM
    -                                     APPENDIX A replacements which aresnot " exact" but meet the original design
      ~

requirements. REGULATORY GUIDE 1.88 REVISION 2 DATED 10/76 Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records (Endorses ANSI N45.2.9-1974) DISCUSSION: UE complies _with~the recommendations of this Regulatory Guide with the following clarifications:

        .With regard'to Section 3.2.1 of ANSI N45.2.9 - 1974 titled Generation of. Quality Assurance Records:     The phrase " completely filled out" is clarified to mean that sufficient information is recorded to fulfill the intended purpose of the record. It is the information, not the form, that is'the record. Thus the information, not the form, needs to be'com quality" qigte to furnish documented " evidence of activities affecting With regard to Section 3.2.2 of ANSI N45.2.9        1974 titled Index: The phrase "an index" is clarified to mean a collection.of documents or indices which, when taken together, supply the information attributed to "an index"'in the Standard.

The specific location of a record "within a storage area" may not be delineated. (e.g..The specific location within a computer _ record file may not be constant. Further, UE may utilize a computer assisted

random access-filing system where such location could not be readily

         " documented," or would such a location be " relevant. ")   The storage location shall be delineated, but where file locations change with time,.the_ specific location of a record within that file may not always be documented.

With regard to Section 4.2 of ANSI N45.2.9 - 1974 titled Timeliness: UE's contractual agreement with its contractors and suppliers shall constitute fulfillment of the requirements of this Section. TheLfollowing clarification is substituted for the current subsection .. 5.4.3: " Provisions shall be made for special processed records (such ! as ' radiographs, photographs, negatives, microfilm and magnetic media) to prevent damage from excessive light, stacking, electromagnetic fields, temperature and humidity as appropriate to.the records type." Consideration shall be given to manufacturer's recommendation. With regard to Section 5.5 of ANSI N45.2.9 - 1974 titled Safekeeping: Routine General Offices and Plant site security systems and access 4 controls shall be provided: no special security systems are' required i to be established for record storage areas. A-20 Rev. 10 6/87

OQAM APPENDIX A With regard to Section 5.6 of ANSI.N45.2.9 9 1974 titled Facility: This Section provides no distinction betweep temporary and permanent facilities. To cover temporary storage, the following clarification is added: " Active records (those completed.but not yet duplicated or placed on microform) may be temporarily stcred in one-hour fire rated file. cabinets. In general, records shall not be maintained in such temporary storage for more than three months after completion without being. duplicated (for dual storage) or being placed on microform. Open-ended documents --those revised or updated on a more-or-less continuing basis over an extended period of time (e.g. personnel qualification and training. documents, equisment history cards, master audit or master surveillance schedules) an1 those which are cumulative

        - in nature (e.g. nonconforming item logs ani control room log books)--

are not considered as QA records since they are not " complete." These types of documents shall become QA records. when they are issued as a specific revision (e.g. the master audit schedule); when they are filled-up or discontinued (e.g. log books .cnr equipment history cards) ; on a predefined periodic basis when the ccmpleted portion of the on-going document shall be transferred to: document control as a

          " record" (e.g. training and qualification records).

Paragraph 4,- subsection 3 is clarified to require a two-hour minimum fire rating to be consistent with the 1979 version of the Standard, and NRC Criteria for Records Storage Facilities (Guidance-ANSI

        ' N45.2.9, Section 5.6) issued                          7/1/80.

Paragraph 4, subsection 9 is clarified to read: "No pipes or penetra-tions except those providing fire protection, lighting, temperature / >

humidity control, or communications are to be located within the l facility and they shall comply with a minimum two-hour fire protection f

rating." Where duplicate storage is employed, no special precautions or provi-l sions (including vault storage, special humidity and temperature L recorders and similar items) are required. I ! Paragraph 5 is clarified to read the same as our commitment to subsec-l tion 5.4.3. Both paragraphs address the same requirement and there-fore the commitment must be the same. REGULATORY GUIDE 1.94 REVISION 1 DATED 4/76 Quality Assurance Requirements for Installation, Inspection and Testing of Structural Concrete and Struct ural Steel During the Con-struction Phase of Nuclear Power Plants. (Endorses ANSI N45.2.5-1974) l DISCUSSION: UE complies with the recommendations of this Regulatory Guide with the following clarifications: For eperating-phase modification activities whieh-are-eemperabie-in nature-and-extent-te-simitar-activities-eendueted-during-the A-21 Rev. 10 6/87 P vv -r-- --,--,,,.r-, , , - - - , -,,.,----a,, emr -,--,,,-,-----e---~~--,n--m --w, -e. , - , , , - - - , - , - , , , , - , , w a ~,-, -

                                                                                                                                                            -------er -

l OQAM APPENDIX A constructien-phase 7-UE-shall-either-eentrel-these-activities-under-the Operating-eA-Pregram-er-under-a-UE-acee When-the-Operating-9A-Program-is-used7 (gted-Eenstructien-eA-Pregramr

                                                                ) UE shall comply with the Regulatory Position established in this Regulatory Guide in that QA programmatic / administrative requirements included therein (subject to the clarifications below) shall apply to these modification activities even though such requirements may not have been in effect originally.

Technical requirements associated with modifications shall be equal to or better than the original requirements (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection requirements), or as required to preclude repetition of defects. The recommendations for structural concrete, structural steel, and other Plant components shall be met as indicated by the applicable design documents with the following exceptions:

a. Bolts for friction type connections may be tightened using direct tension indicators in accordance with the AISC Specification for Structural Joints Using ASTM A 235 or A 490 bolts, approved May 8, 1974.

b. Section 5.4 (1) of ANSI N45.2.5 does not apply. The require-ment for the acceptance of tightened bolt assemblies is:

            "The length of the bolts shall be such that the point of the bolt shall be flush with or outside of the face of the nut when completely installed."

REGULATORY GUIDE 1.116 REVISION 0-R DATED 5/77 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems (Endorses ANSI N45.2.8-1975) DISCUSSION: UE complies with the recommendations of this Regulatory Guide with the following clarifications: For eperating-phase maintenance and modification activities whieh-are eemperable-in-nature-and-extent-te-similar-activities-eenducted-dering the-eenstructien-phase 7-UE-shall-either-centrel-these-activities-under the-Operating-eA-Pregram-er-under-an-NRE-eeeepted-Genstruetien-eA Pregram---When-the-Operating-eA-Pregram-is-used 7 (2) UE shall comply with the Regulatory Position established in this Regulatory Guide in that QA programmatic / administrative requirements included therein shall apply to these maintenance and modification activities even though such requirements may not have been in effect originally. Technical requirements associated with maintenance and modifications shall be equal to or better than the original requirements (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection requirements), or as required to preclude repetition of defects. A-22 Rev. 10 6/87

                  - - - - - - - - - - _                                                          \

OQAM

                                   -APPENDIX A REGULATORY GUIDE 1.123            REVISION 1                DATED 7/77 Quality Assurance Requirements for Control of Procurement of Items and S,ervices for Nuclear Power Plants (Endorses ANSI N45.2.13-1976)

DISCUSSION: UE complies with the recommendations of this Regulatory Guide with the following clarifications: With regard to Section 1.3'of ANSI N45.2.13 - 1976 titled Definitions: With two exceptions (Procurement Document and Quality Assurance Program Requirements) definitions in this Standard which are not included in Regulatory Guide.l.74 (ANSI N45.2.10) shall be used; definitions which are included in ANSI N45.2.10 shall be used as clarified in UE's commitment to' Regulatory Guide 1.74. The two-exceptions are defined in this Appendix under Regulatory-Guide 1.74.

 ;With regard to Section 1.2.2 of ANSI N45.2.13 -1976 titled Purchaser's Responsibilities:     Item C is one of the options which may be used by UE to assure quality; however, any of the options given in 10 CFR 50, Appendix B, Criterion VII as implemented by OQAM Sections 4 and 7.may also be used.                                                    .

With regard to Section 3.1 of ANSI N45.2.13 - 1976 titled Procurement Document Preparation, Review and Change Control: The phrase "the same tdegree of control" is stipulated to mean " equivalent level of review and approval." The changed document may not always be re-reviewed by the originator; however, at least an equivalent level of supervision shall' review and approve any changes. With regard to Section 3.4 of ANSI N45.2.13 - 1976 titled Procurement Document Control: UE shall meet the requirements of OQAM Sections 4 and 7 in lieu of the requirements specified in this Section. In every case either identicat-or equivalent eqqyrots are provided in the sections of the referenced documents With regard to Section 5.3 of ANSI N45.2.13 - 1976 titled Preaward Evaluation: UE shall comply with an alternate paragraph which reads:

   "Except in unusual circumstances (e.g.- replacement parts- are needed to preclude the development of some unsafe or undesirable condition at Callaway), an evaluation of the supplier's acceptability as a procure-ment-source shall be performed as required by the Operating QA Manu-a1."    White it is not the intent to make " unusual circumstances" determinations uithout Engineering or QA involvement, Callauay Opera-tionsSupportisultimatelyresponsibleforthedqqfeion.            QA audit and surveittance activities assure against abuse With regard to Section 6.4 of ANSI N45.2.13 - 1976 titled Control of l  Changes in Items of Services: The phrase "the Operating     QA Program" i   is inserted in lieu of " ANSI N45.2, Section 17.2.7."

A-23 Rev. 10 6/87

                                                                                                   \

OQAM APPENDIX A

  .With regard-to section 8.2 of ANSI N45.2.13 - 1976 titled Disposition:

The third sentence of item b is revised to read: Nonconformances to the contractual procurement requirements or. Purchaser approved documents and which consist of one or more of the following shall be submitted to the Purchaser for. approval of the recommended disposition. prior to shipment when the.nonconfor-mance could adversely affect the end use of a module

• or shippa-ble component. relative to safety, interchangeability, operabili-ty, reliability, integrity, or maintainability: ,

1) Technical or material requirement is violated;

2) Requirement in Supplier documents, which have been approved by the Purchaser, is violated;

3) Nonconformance cannot be corrected by continuation of.the original manufacturing process or by rework; and/or

4) The item does not conform to the originalLrequirement even-though the item can be restored to a condition such that the capability of the item to function is unimpaired.

        *A module is an assembled device, instrument, or piece of equip-ment identified by serial number or other identification code, having been evaluated by inspection and/or test for conformance to. procurement requirements regarding end use. A shippable component is a part of sub-assembly of a device, instrument, or piece of equipment-which is shipped as an individual item and which has been evaluated by inspection and/or test for confor-mance to procurement requirements regarding end use.

With regard to Section 12 of ANSI N45.2.13 - 1976 titled Audit of

  . Procurement Program:  The-UE audit program shall be implemented in accordance with and to meet the requirements of. Regulatory Guide 1.144 (ANSI N45.2.12) as endorsed in this Append

> and the~ requirements of the Cattaway Plant {y, Technical OQAM Sections 16 and 18, Specifica- i tions. I REGULATORY GUIDE 1.144 REVISION 1 DATED 9/80 Auditing of Quality Assurance Programs for Nuclear Power Plants , (Endorses ANSI N45.2.12-1974) DISCUSSION:

j. UE complies with the recommendations of this Regulatory Guide with the L

following clarifications: With regard to Section 1.4 of ANSI N45.2.12 - 1977 titled Definitions: With one exception (Program Deficiencies) the definitions in this Standard which are not included in Regulatory Guide 1.74 (ANSI N45.2.10) shall be used; definitions which are included in ANSI A-24 Rev. 10 6/87 l _ _ _ , _ _ _ _ _ . _ _ _ _ _ . _ _.

OQAM APPENDIX A

  'N45.2.10 shall be.used as' clarified in UE's commitment to Regulatory-Guide 1.74. 'The-one excepted definition and a clarified definition
   -(of audit) relevant to_this Standard are defined in this Appendix under Regulatory Guide 1.74.

With regard to Section 2.2 of ANSI N45.2.12 - 1977 titled Personnel Qualification:.'The qualification of UE audit personnel shall be accomplished as described-to meet the requirements of Regulatory Guide 1.146 (ANSI N45.2.23 - 1978) as endorsed in this Appendix and OQAM Section 18. With regard to Section 2.3- (and subsections 2.3.1 through 2.3.3) of ANSI N45.2.12 - 1977 titled Traininc : The training of UE audit

         ~

personnel shall be accomplished as c.escribed to meet the requirements of Regulatory Guide 1.146 (ANSI N45.2.23 - 1978) as endorsed in this Appendix and OQAM Section 18.

  'With regard to Section 2.4 of ANSI N45.2.12 - 1977 titled Maintenance of Proficiency:    The maintenance of proficiency of UE audit personnel shall be accomplished as described to meet the requirements of Regula-tory Guide 1.146 (ANSI N45.2.23 - 1978) as endorsed in this Appendix and OQAM Section 18.

With regard to Section 3.3 of ANSI N45.2.12 - 1977 titled Essential Elements of'the Audit System: UE shall comply with subsection 3.3.5

  -as it was originally written (subsection 3.2.5) in ANSI N45.2.12, Draft 3, Revision 4:    " Provisions for reporting on the effectiveness of the Quality Assurance Program to the responsible management." For

the auditing organization (UE) g 19 f fectiveness shall be reported as required by the Cattaway Plant Technical Specifications. Other than audit reports, UE may not directly report on the effectiveness of the quality assurance programs to the audited organization when such organizations are outside of UE.

Subsection 3.3.6 requirements are considered to be fulfilled by compliance with the organization and reporting gg9sures outlined in this Operating QA Manual and the Cattaway Plant -Technical Specifi-

   . cations. In every case either identical or equivalen provided in the sections of the referenced documents.f39ontrols are Subsection 3.3.7 requires verification of effective corrective action on a " timely basis." Timely basis is interpreted to mean within the framework or period of time for completion of corrective action that

. is-accepted by the Quality Assurance Division. Each finding requires j a response and a corrective action completion date; these dates are !_ subject to revision (with the approval of the Quality Assurance 1 Division) and must be escalated to higher authority when there is a disagreement between the audited and the auditing organizations on what constitutes " timely corrective action." With regard to Section 3.5 of ANSI N45.2.12 - 1977 titled Scheduling:

Subsection 3.5.3.1 is interpreted to mean that UE may procedurally

!   control qualification of a contractor's or supplier's quality l.

l A-25 Rev. 10 6/87 L .-- . ._

OQAM APPENDIX A assurance program prior to awarding a contract or purchase order by means-other than audit. With regard to Section 4.3.1'of. ANSI N54.2.12 - 1977 titled Pre-Audit. LConference: UE shall comply with requirements of this Section by

                              ~
      . inserting the word "Normally" at the beginning of the.first sentence.

This clarification is required because, in the case of certain unan-nounced audits _or audits of a particular operation or work activity, a pre-audit conference might interfere with the spontaneity of the operation or_ activity being audited. In.other cases, persons who should be present at a pre-audit conference may not always be avail-able: such lack of availability should not be an impediment to begin-

      .ning an. audit.             Even in the above examples, which are not intended to be all inclusive, the material set forth.in Section 4.3.1 shall
      -normally be covered during the course of-the audit.

With regard to Section-4.3.2 of ANSI N45.2.12 - 1977 titled Audit Process: (a) Subsection 4.3.2.2 could be interpreted to limit auditors to the review of only objective evidence; sometimes and for some Program elements, no objective evidence may be available. UE shall comply with an alternate sentence.which reads: "When_available, objective evidence shall be examined'for compliance with Quality Assurance Program requirements. If subjective evidence is used (e.g. personal interviews, direct observations by the auditor) , then the audit report must indicate how the evidence was ob-tained." (b) Subsection 4.3.2.4 is modified as follows to take into account the fact that some nonconformances are virtually " obvious" with respect to the needed corrective action: "When a nonconformance or Quality Assurance Program deficiency is identified as a result , of an audit, unless the apparent cause, extent, and corrective action are readily evident, further investigation shall be conducted by the audited organization in an effort to identify the cause and effect and to determine the extent of the correc-tive action required." (c) Subsection 4.3.2.5 contains a recommendation which is clarified with the definition of " acknowledged by a member of the audited

organization" to mean that "a member of the audited organization has been informed of the findings." Agreement or disagreement

, with a finding may be expressed in the response from the audited organization. _(d) Subsection 4.3.2.6 is modified as follows to account for the fact that_immediate notification is not always possible: " Conditions requiring immediate corrective action (i.e. those which are so I. severe that any delay would be undesirable) shall be reported

immediately to the audited organization and as soon as practical j to the~ management thereof."

l f_ A-26 Rev. 10 l 6/87

  - .         ___ _    _ _ . . _ .        . . . - ~ . _ - _ - _ - . _ _            .-   - _ - _ _ - .        ___         -

                                                                                                                                                                                    .)

OQAM '

  ,                                                                            APPENDIX A With regard to.Section 4.3.3 of ANSI N45.2.12 - 1977 titled Post-Audit Conference: UE shall substitute and comply with the.following paragraph:                         "For external audits, a post-audit conference shall be H-          held with management of the audited organization to present audit
,             findings and clarify-misunderstandings; where no adverse findings

exist, this conference may be waived by management of the audited

,            ; organization: .such waiver shall be documented in the audit report.
,            .Unless unusual operating or maintenance conditions preclude attendance by appropriate managers / supervisors, a post-audit conference ~shall be held with managers / supervisors for internal audits for the same reasons as above. ~Again, if there are no adverse findings, management of the internal audited organization may waive the post-audit confer-ence: such waiver shall be documented in the audit. report."

[ With regard to Section 4.4 of ANSI N45.2.12 - 1977 titled Reporting:

 .            (a)     This Section requires that the audit report shall be signed by
 !                    the Audit Team Leader (ATL); this is not always the most expedi-tious route to take to assure that the audit report is issued as soon as practical. UE shall comply with Section 4.4 as clarified 4

in the following opening: "An audit report, which shall be signed by the Audit Team Leader (ATL), or the ATL's supervisor in the ATL's absence, shall provide: . . ." In cases where the audit report is not signed by the ATL due to absence, one record copy of the report must be signed by the ATL upon return. The report

,                     shall not require the ATL's review / concurrence / signature if the ATL is no longer employed by UE at the time the audit report is issued.

1 } ~ (b) UE shall comply with subsection 4.4.3 clarified to read: " Super- !' visory level personnel with whom significant discussions were held during the course of pre-audit (where conducted) audit, and post-audit.(where conducted) activities." i

(c) Audit reports may not necessarily contain an evaluation statement

~

regarding the effectiveness of the Quality Assurance Program elements which were audited, as required by subsection 4.4.4, but

they shall provide a summary of the audited areas and the results

! which identify the importance of any adverse findings. i

!             With regard to Section 4.5.1 of ANSI N45.2.12 - 1977 titled By Audited j             ' Organization:                                    UE shall comply.with the following clarification of the l              Section:                  " Management of the audited organization or activity shall review and investigate adverse audit findings, as necessary, (e.g.

I where the cause is not already known, another organization has not

already. investigated and.found the cause, etc.) to determine and l schedule appropriate corrective action including action to prevent l recurrence. They shall clearly state the corrective action taken or planned to prevent recurrence and the results of the investigation, if I

conducted. In the event that corrective action is not completed ! within thirty days, the audited organization's response shall include 4 a scheduled date for completion of planned corrective action: a follow-up response shall be provided stating the corrective action i b A-27 Rev. 10 l 6/87 L

    . - - . , ._;,-_...,             _ _ _. __,._.__- ..~.__.-- -..-                   ___,..._ .... . _ - .-. .__,--                         _ _ - . - - . - , _ . - - -

OQAM APPENDIX A taken and the date that the action was completed. If corrective actions are verified as satisfactorily completed by the auditing organization prior to the scheduled completion date, no follow-up response is required. The audited organization shall take appropriate action to assure that corrective action is accomplished as scheduled. Either the Manager, Quality Assurance or a Superintendent, Quality

           - Assurance may waive the requirement for a supplementary response."

REGULATORY GUIDE 1.146 INITIAL ISSUE DATED 8/80 Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants (Endorses ANSI N45.2.23-1978) DISCUSSION: UE complies with the recommendations of this Regulatory Guide with the following clarifications: l With respect to Section 1.4 of ANSI N45.2.23-1978 titled Definitions: Definitions in this Standard which are not included in ANSI N45.2.10

           - shall be used: " Audit" which is included in this Standard and                          ANSI N45.2.10 shall be used as clarified in this Appendix under Regulatory Guide 1.74.

With respect to Section 2.2 of ANSI N45.2.23 - 1978 titled Qualifica-- tion of Auditors: Subsection 2.2.1 references an ANSI B54.2 (presumed to be standard N45.2) ; therefore, UE shall comply with an-alternate subsection 2.2.1 which' reads: Orientation to provide a working knowledge and understanding of the. Operating QA Manual, including the ANSI standards and Regula-tory Guides included in this Appendix and UE's procedures for implementing audits and reporting results. With respect to Section 4.1 of ANSI N45.2.23 - 1978 titled Organiza-tional Responsibility: UE shall comply with this Section with the substitution of the following sentence in place of the last sentence

                          ~

in the Section. The Manager, Quality Assurance; a Superintendent, Quality Assur-ance; Supervising Engineer, QA; or Lead Auditor shall, prior to commencing the audit, assign personnel who collectively have experience or training commensurate with the scope, complexity, or special nature of the activities to be audited. With respect to Section 3.2 of ANSI N45.2.23 - 1978 titled Mainte-nance of Proficiency: UE shall comply with the requirements of this Section by defining " annual assessment" as one which takes places every 12 + or - 3 months and which uses the initial date of certifica-tion (not the calendar year) as the starting date for determining when such annual assessment is due. The combined time interval for any three consecutive assessment intervals shall not exceed 3.25 years. 1 A-28 Rev. 10 6/87

OQAM APPENDIX A l l With respect to Section 5.3 of ANSI N45.2.23 - 1978 titled Updating j of Lead Auditor's Records: UE shall substitute the following sentence  ; for this Section Records for each Lead Auditor shall be maintained and updated during the period of the annual management assessment as defined in Section 3.2 (as clarified). With respect to Section 5.4 of ANSI N45.2.23 - 1978 titled Records Retention: UE shall substitute the following sentence for this Section.. Qualification records shall be generated and maintained as required by OOAM Section 17 and by commitment to Regulatory Guide 1.88 (ANSI N45.2.9) as clarified in this Appendix . In every case either identical or equivalent controts aggyprovided in the sections of the referenced Standards and documents i A-29 Rev. 10 6/87

ATTACHMENT 3 EXPLANATIONS AND JUSTIFICATIONS FOR CHANGES TO THE OQAM

J i , EXPLANATION OF AND JUSTIFICATION FOR PROPOSED CHANGES TO THE , - OPERATING QUALITY ASSURANCE MANUAL (OQAM) The parenthetical numbers in this document refer to similar numbers which appear near.the proposed changes in Attachment

1.- Each number / letter designation is unique,-but the statement.may apply to many changes within the documents.

The affected OQAM sections are~ referenced following each justification. The statements are designed to provide a-brief description of:the proposed change and the justifica-tion for making the change. Based:on Union Electric's evaluation only two of the proposed changes represent a reduction in the Operating Quality Assurance. Program (OQAP) as_it has.been previously accepted by the NRC (refer to items 11 and 12). 1 (1) Editorial changes (e.g., Renumbering-of sections; clarifying reference to Technical Specifications as Callaway Plant Technical Specifications). None of these changes is considered a reduction in the OQAP.

(Table of Contents; Sections 1.3 - 1.35,12.6 - 2.15, 3.161- 3.24,.11.2, 11.8 - 11.16, 12.4, 15.8, 16. 2, .

16.3, 18.5, 18.14, and 18.15) _, (2) Deletion of OQAM text which is historical'in nature and is no longer applicable. These types of sections had been addressed in OQAM (Rev. 9) in order to provide a-single OQAM revision which documents the transition from the Design.and Construction QA program to the

                                                 -Operating QA program._ None of these changes is

considered a reduction in the OQAP. (Table of _ Con-tents; Page 1 (Title); Sections 1.4, 1.26, 1.28, 2.5,

                                                 '2,7, 3.16, 11.10, 11.11, 11.12; pp. 64-66; App. A, Reg.

f Guides 1.30, 1.37, 1.39, 1.94, and 1.116) (3) Incorporation of additional wording to more clearly address responses to NRC Questions previously accepted by the NRC. ~None of these changes is considered a reduction in the OQAP. (Section 2.1; App. A, Reg. Guides 1.30, 1.33, 1.37, 1.38, 1.39, 1.64, 1.74, 1.88,

  ;                                                 1.123, 1.144, and 1.146)

(4) Deletion of the definition of the term "will" from the OQAM. Since in OQAM (Rev. 9) the term "shall" was j substituted for "will" for clarification reasons, "will" no longer serves any purpose in the OQAM. This

change is not considered a reduction in the OQAP.

                                                   . ( App . A , Reg. Guide 1.74) m.w   y wg - --9 -W         a*wm-      --a yy-   e---e      ,w,.-se      ium=rgm-'  en kW-yam-      q v'* *g-    T  r7 m'-7Fe-~p-p   -vgF-          g 7FwM--PT-9-D wyF   g- -F'-r-*-Q-t hr-7t- F-t W S T

Pcga 2 of 3 (5)- ~ Revision of the term " Repeating Work Request" to _

                         " preventive maintenance requests".                      This change was made to coincide with a change ~made to a Nuclear

Operations program title.- Based on UE's evaluation, this change is not considered a reduction in the OQAP since the PMR program is equivalent to the superseded RWR program. (Section:6.2,. Footnote)

(6) Addition of. organization charts into the OQAM. This is being done per the request of the,NRC per NRC letter to D. F.'Schnell dated-February 13, 1987. (Table of Contents, Section 1.1, added Figures A and.B). (7) Identification of reports issued to-the Vice President, Nuclear for the purpose of independently assessing the Operating QA' Program. . This information is being added per the request of the NRC per NRC letter to D. F..Schnell dated February 13, 1987. (Section 2.13) (8) Clarification of which outside organizations performing special processes for Callaway Plant are required to work to UE's OQAP ,(vs. their own UE approved.QA pro-- gram). In addition, clarification of which special process procedures used by outside organizations at Callaway Plant are required to-be reviewed by UE. Based on UE's evaluation, this change is not considered a reduction in the OQAP. (Section 9.4)

             -(9)       Clarification of who performs procurement source evaluations and the role other organizations have in procurement-source evaluations. Based on UE's evalua-tion, this change is not considered to be a reduction in the OQAP effectiveness.                        (Sections 7.6 and 7.7)

(10)-Clarification of_the corrective action program.- Also, the corrective action program has been changed to clarify that corrective action documents _are to be closed upon verification of the implementation of + corrective action. The effectiveness of corrective actions taken are to be verified either prior to close-out of the corrective action document or on a

                      . periodic basis.            Based on UE's evaluation this change is not considered a reduction in the OQAP because the

, change only clarifies when the effectiveness of correc-  ; tive action is accomplished. (Sections 16.2, 16.5, 16.6, and 16.7)

-(11) Deletion of the requirement for QA to review new and revised design criteria documents and design specifica-l tions. This change is considered by UE to be a reduc-tion in OQAP commitments to the NRC; however, the OQAP l does continue to meet the requirements of 10CFR50, App.

L B with this change. The QA review of these documents l was a UE self-imposed requirement which exceeded E

Pcga 3 of 3 i l regulatory requirements to which UE is committed. ,

                         . Appropriate controls continue to exist within                                i OQAP-related procedures to assure that knowledgeable individuals reviewidesign criteria documents             and design specifications (i.e., APA-ZZ-00111, Engineering Specifications"; APA-ZZ-00600, " Design Change Control";

APA-ZZ-00601, " Category.I Modifications (CMPs) ") . QA i will continue to provide a review of design criteria documents and specifications (and any modifications) as part of the Onsite Review Committee through its member-ship in ORC. In addition, QA will continue to verify the implementation of the referenced procedures through audits and surveillances. (Sections 3.7 and 3.9) (12) Deletion of the requirement for.QA to review PSI /ISI inspection plans and modifications. The change is considered by UE to be a reduction in OQAP commitments to the NRC; however, the OQAP continues to meet the requirements of 10CFR50, App. B. The review of PSI /ISI inspection plans and modifications was a UE self-imposed requirement which exceeded the regulatory requirements which UE is committed. Appropriate controls continue to exist within OQAP-related proce-dures.to assure knowledgeable individuals review the-subject documents (i.e., APA-ZZ-00353, " Administration of the NDE and Qisual Inservice-Inspection Program"). QA will continue to verify the implementation of this program through audits and surveillances. (Section 10.14) l l m > 3 w, . wy.+-- 7 - www-- 9 w.- -w wg,,w--=w- --,w wyrm - , - - - ,wrv-}}