ML16034A033
| ML16034A033 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 01/20/2016 |
| From: | Ice G Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NO-AA-10, Rev. 90 | |
| Download: ML16034A033 (151) | |
Text
ToFacilityAddress: : TMI Department:
DESKPASSPORT DOCUMENTTRANSMITTAL Page: 1111liiill I/l lNi1Ult I iFromAddressCityCountryEmailContactTMI-RM Attention:
Records ManagerRecords Management Exelon NuclearTMI StationMIDDLETOWN State: PA Postal Code: 17057UNITED STATESDate/Time
- 0/2TitleTotal Items: 00001/21 9:5Tasmital Group Id:Trans No. : 000678031 0000102839 Item Facility Type Sub Document Number Sheet Doc Status Revision Doc Date Copy # Media Cpys* 0001 TMI PROC NSP ACTIVE 090 DCl H3 01Marked (*) documents require your acknowledgement.
Acknowledgement Date SintueSignature:
If a document was not received or is no longer required check the response below and return to sender.I Documents noted above not received (identify those not received).
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GENERAL CONTROLLED COPY -VERIFY BEFORE USEExelon Generation
- Company, LLCQUALITY ASSURANCE TOPICAL REPORT(QATR)NO-AA-1 0Revision 90IExelon NuclearCorporate Headquarters 4300 Winfield RoadWarrenville, IL 60555 This Page Intentionally Left Blank Standard Quality Assurance Topical Report(NO-AA-I1O)
-Revision 90Transmittal and Summary of ChangesTo: All Site Document Control CentersThese changes are approved,
_December 18, 2015, with site and corporate implementation on January 25. 2016.The Quality Assurance Topical Report (QATR) has been revised to:* Clarify the reporting relationship for the Management Position responsible for Licensing and Regulatory Affairs.* Re-organized the corporate and site assessment functions from NuclearOversight to the Organizational Effectiveness and Integrated Performance Assessment group.*"Clarify that the audit function is credited with meeting the appendix Brequirements.
- Include Clinton Station ISFSl requirements.
These changes have been reviewed in accordance with 10QCFR50.54 (a) and didnot reduce Exelon's commitments previously approved by the NRC. (Ref. AT680087-56 and 57 for supporting 50.54(a) evaluations).
This revision to theQATR will be submitted to the NRC for post implementation review as tracked byAction Tracking Number 95188-09.
The specific changes are described as follows:Table of Contentso Updated to coincide with the current revision.
Chapter 1 (Organization) o Section 2.2.3 was revised to include a description for the management position responsible for Regulatory Affairs and General Counsel.o Section 2.2.3.1 was revised to clarify the reporting relationship for themanagement position responsible for Licensing and Regulatory Affairs.o Section 2.2.4.5 was revised to include a description for the management position responsible for Organizational Effectiveness and Integrated Performance Assessment and defines the responsibility for fleetassessments.
o Section 2.2.4.6 was revised to re-organize the corporate and siteassessment functions from Nuclear Oversight to the Organizational Effectiveness and Integrated Performance Assessment groupa Section 2.2.4.6.A was revised to re-organize the reporting relationship forQuality Verification and Employee Concerns from the site NOSorganization to the corporate NOS organization.
Page 1 of 3 Standard Quality Assurance Topical Report(NO-AA- 10) -Revision 90Transmittal and Summary of Changeso Section 2.3.6 was revised to define the site position responsible forassessment activities.
o Section 2.3.7 was revised to define the site position responsible forPerformance Improvement.
o Section 2.4 was revised to clarify that PORO is part of the three-tiered approach for accomplishing oversight of safety.Chapter 18 (AssessmentslAudits) o Entire chapter 18 was revised to clarify that Audits are credited withmeeting our Appendix B and NQA-1 Requirements o Section 1 was revised to clarify audits are performed in accordance withNQA-I.o Section 2.1.1 B was revised to clarify that audits of Emergency Preparedness and Security are not subject to an extension.
o Section 2.1.1 was revised to clarify scheduling for Fleet Assessments.
o Section 2.1 .5.B was revised to define the reporting and follow-up requirements for Fleet Assessments.
o Section 2.2 was revised to clarify that vendors are audited, not assessed.
o Section 2.3 was revised to clarify that the independent review of the statusand adequacy of the QAP is an audit.Appendix A (Augmented Quality)o Section 2.5 was revised to include Calvert Cliffs and Nine Mile Point 1 and2 within the Augmented Quality requirements for Station Blackout.
o Section 2.8.2 was revised to add the ISFSI requirements for ClintonStation.Appendix C (Codes, Standards, and Guides)o Grammatical corrections were made throughout the entire Appendix.
o Section 1.3.4.18 b was revised to define Ginna Stations commitment toNFPA 805.Page 2 of 3 Standard Quality Assurance Topical Report(NO-AA- 1O) -Revision 90Transmittal and Summary of ChangesThis summary is provided to familiarize the readers with the changes included inRevision 90 of the QATR. Personnel engaged in activities covered by the QualityAssurance Program (QAP) are required to review the revised chapters.
Affectedprocedures should be changed and training provided as needed to ensurecompliance with the updated requirements.
Prepared P"Nuclear Oversight Quality Assurance Specialist Approved BY: ________________
o'_S-Rob Radulovich
/ DateNuclear Oversight Audit and Programs DirectorPage 3 of 3 TABLE OF CONTENTSO CHAPTER 1, ORGANIZATION 1 .....SCOPE......................................................................................I 2 .....REQU IREM ENTS ........................................................................
I2.1. Organization
...........................................................................
I2.2. Corporate Organization...............................................................
22.2.1. President and Chief Executive Officer...............................................
22.2.2. Sr. Executive Vice President, Chief Commercial
- Officer, Exelon Corporation, and President and Chief Executive
- Officer, Exelon Generation Company.....
22.2.3. Sr. Vice President Regulatory Affairs and General Counsel.....................
22.2.4. Sr. Executive Vice President and President and Chief Nuclear Officer, ExelonNuclear.........................................................................
32.3. Site Organization......................................................................
102.4. Three-Tiered Approach
..............................................................
142.5. Decommissioning
.............................................................
142.6 Responsibility
.........................................................................
142.7 Authority
......................................................................
15CHAPTER 2, QUALITY ASSURANCE PROGRAM.1 .....SCOPE.....................................................................................
12 .....REQUIREMENTS..........................................................................I 2.1. General.................................................................................
12.2. Supplier's Quality Assurance Program ..............................................
12.3. Planning................................................................................
22.4. Program Description
..................................................................
22.5. Indoctrination
& Training..............................................................
22.6. Program Review.......................................................................
32.7. Quality Assurance Manual ...........................................................
3CHAPTER 3, DESIGN CONTROL1. SCOPE.....................................................................................
- 12. REQUIREMENTS..........................................................................I 2.1 General ................................................................................
12.2 Design Input ...........................................................................
12.3 Design Process........................................................................
22.4 Design Analyses.......................................................................
2.2.5 Design Verification
....................................................................
3O ~2.5.1 Extent of Design Verification
.........................................................
32.5.2 Design Reviews........................................................................
4Page 1 of 8 Revision 90 TABLE OF CONTENTS2.6 Change Control........................................................................
4* 2.7 Design Errors .........................................................................
52.8 Interface Control.......................................................................
52.9 Vendor Design Control ...............................................................
52.10 Modifications...........................................................................
62.11 Documentation and Records .........................................................
6CHAPTER 4, PROCUREMENT DOCUMENT CONTROL1 .....SCOPE.....................................................................................
12 .....REQUIREMENTS
.........................................................................
12.1. General.................................................................................
12.2. Content of Procurement Documents
................................................
12.2.1. Scope of Work .........................................................................
12.2.2. Technical Requirements...............................................................I 2.2.3. Quality Assurance Program Requirements..............1 2.2.4. Non-conformances....................................................................
22.2.5. Documentation Requirements........................................................
22.2.6. Spare and Replacement Parts.......................................................
22.3. Procurement Document Review .....................................................
2.2.4. Procurement Records 3CHAPTER 5, INSTRUCTIONS, PROCEDURES, AND DRAWINGS1 .....SCOPE.....................................................................................
12 .....REQUIREMENTS
.........................................................................
12.1. General ................................................................................
12.2. Preparation and Review...............................................................I 2.3. Procedures and Programs
...........................................................
22.3.1. Technical Review and Control........................................................
22.3.2. On-site Qualified Technical Review (Dresden Unit 1) .........................
....4CHAPTER 6, DOCUMENT CONTROL1 .....SCOPE.....................................................................................
12 .....REQUIREMENTS
.........................................................................
12.1. General.................................................................................
12.2. Reviews ................................................................................
12.3. Controlled Documents
................................................................
2.2.4. Control Measures
......................................................................
22.5. Document Changes...................................................................
3Page 2 of 8 Revision 90 TABLE OF CONTENTSO CHAPTER 7, CONTROL OF PURCHASED
- MATERIAL, EQUIPMENT, ANDSERVICES1.....SCOPE
.....................................................................................
12 .....REQUIREMENTS
.........................................................................
12.1. Supplier Selection......................................................................I 2.1.1. General..................................................................................I 2.1.2. Methods................................................................................
12.2. Bid Evaluations
.......................
................................................
22.3. Supplier In-Process Control..........................................................
22.3.1. General...........................
......................................................
22.3.2. In-Process Control and Verification Planning
.......................................
22.3.3. Programmatic Verification
............
...............................................
32.3.4. Supplier and Verification of Supplier Performance Records.......................
32.3.5. Control of Procurement Changes....................................................
32.4. Acceptance of Purchased Items and
....................................
42.4.1. General ................................................................................
42.4.2. Acceptance by Receiving Inspection
................................................
42.4.3. Acceptance by Source Verification
...................................................
4* ...
byCetfce of Cofrac..........................5...............
2.4.5. Acceptance by Post Installation Testing.............................................
52.4.6. Accep3tance of Services Only .........................................................
52.4.7. Commercial Grade Items.............................................................
62.4.8. Acceptance of Calibration Services............................................
62.5. Presence of Documentary Evidence
................................................
72.6. Spare or Replacement Items.........................................................
72.6.1. Procurement from Other Utilities.....................................................
82.6.2. Maintenance or Modification
.........................................................
8CHAPTER 8, IDENTIFICATION AND CONTROL OF MATERIALS, PARTS,AND COMPONENTS 1I.....SCOPE.......................................
2 .....REQUIREMENTS
.........................................................................
12.1!. General.................................................................................
12.2. Traceability
.............................................................................
I2.3. Identification Methods.
................................................................
I2.4. Transfer of Markings..................................................
................
2.2.5. Limited Life Items ......................................................................
22.6. Stored Items ...........................................................................
2Page 3 of 8 Revision 90 TABLE OF CONTENTS.CHAPTER 9, CONTROL OF SPECIAL PROCESSES 1 .....SCOPE.....................................................................................I 2 .....REQUIREMENTS
.........................................................................
12.1. General..................................................................................I 2.2. Process Control........................................................................
12.3. Special Processes
.....................................................................
I2.4. Personnel Qualification
...............................................................
22.5. Special Process Records.............................................................
3CHAPTER 10, INSPECTION 1 .....SCOPE.....................................................................................I 2 .....REQUIREMENTS
..........................................................................
I2.1. General..................................................................................I 2.2. Inspection Plans.......................................................................
12.3. Inspection Personnel and Qualification
.............................................
22.4. Inspection Process....................................................................
22.5. In-Service Inspections
................................................................
3* 2.6. Independent Verification..............................................................
3CHAPTER 11, TEST CONTROL1 .....SCOPE .....................................................................................
I2 .....REQUIREMENTS
..........................................................................
I2.1. General..................................................................................I 2.1.1. Testing Program.......................................................................
12.1.2. Test Procedures........................................................................I 2.2. Instrumentation and Control ..................................................
........42.3. Electrical Tests ........................................................................
52.4. Mechanical Tests .......................................................................
52.5. Physical and Chemical Tests ........................................................
52.6. Surveillance Tests.....................................................................
62.7. Maintenance or Major Procedure Change..........................................
6CHAPTER 12, CONTROL OF MEASURING AND TEST EQUIPMENT 1.....SCOPE
.....................................................................................
I2 .....REQUIREMENTS
.........................................................................
1O 2.1. General..........................1 2.2. Control ..................................................................................
12.3. Labeling
................................................................................
2Page 4 of 8 Revision 90 TABLE OF CONTENTS2.4. Accuracy...............................................................................
2* 2.5. Traceability and Interval
..............................................................
22.6. Certified M&TE ........................................................................
22.7. Corrective Actions.....................................................................
32.8. Vendor Control ........................................................................
32.9. Commercial Devices..................................................................
32.10. Calibration Records ...................................................................
3CHAPTER 13, HANDLING,
- STORAGE, AND SHIPPING1 .....SCOPE.....................................................................................
12 .....REQUIREMENTS
..........................................................................
I2.1. General .................................................................................
I2.2. Special Equipment and Environments...............................................
12.3. Classification of Items..................................................................I 2.4. Special Handling Tools and Equipment
.............................................
22.5. Marking and Labeling..................................................................
22.6. Storage.................................................................................
2CHAPTER 14, INSPECTION, TEST, AND OPERATING STATUS..CP.....................................................................................
2 .....REQUIREMENTS
.........................................................................
12.1. General.................................................................................
12.1.1. Procedures.............................................................................
22.2. Operating Status .........................................
.............................
22.2.1. Release for Maintenance.............................................................
22.2.2. Preparation for Work ...... ...........................................................
22.2.3. Temporary Modifications
.............................................................
32.2.4. Return to Service ......................................................................
3CHAPTER 15, NONCONFORMING MATERIALS, PARTS, ORCOMPONENTS 1 .....SCOPE..................................................................................
... 12 .....REQUIREMENTS
..........................................................................
I2.1. General..................................................................................I 2.1.1. Supplier Nonconforming Items .......................................................
12.2. Identification
...........................................................................
2.2.3. Segregation............................................................................
22.4. Disposition
...........................................................................
22.4.1. Control..................................................................................
2Page 5 of 8 Revision 90 TABLE OF CONTENTS2.4.2. Evaluation..............................................................................
2.2.4.3. Personnel
..............................................................................
32.4.4. Documentation
........................................................................
32.4.5. Repaired,
- Reworked, or Scrapped Items ...........................................
3CHAPTER 16, CORRECTIVE ACTION1 .....SCOPE......................................................................................I 2 .....REQUIREMENTS
.........................................................................
12.1. General..................................................................................I 2.2. Conditions Adverse to Quality ........................................................
I2.2.1. Significant Conditions Adverse to Quality ............................................
12.3. Verification and Follow-up
.... .......................................................
22.4. Evaluation and Qualification..........................................................
32.5. Documentation and Reporting........................................................
3CHAPTER 17, QUALITY ASSURANCE RECORDS1 .....SCOPE.....................................................................................
12 .....REQUIREMENTS
.........................................................................
1.2.1. Program.............................................................................1...
2.2. Administration..........................................................................I 2.3. Receipt and Transmittal
..............................................................
22.4. Storage and Preservation.............................................................
22.5. Safekeeping and Classification
......................................................
32.6. Retention and Disposition
............................................................
32.7. Plant Operating Records..............................................................
32.7.1. Records and!/ or Logs, 5-Year Retention
...........................................
32.7.2 Lifetime Records ......................................................................
5CHAPTER 18, ASSESSMENTS
/ Audits1 .....SCOPE......................................................................................I 2 .....REQUIREMENTS
......:...................................................................
12.1. Assessments
-General ...............................................................
12.1.1. Scheduling.................
.............................................................
I2.1.2. Preparation.............................................................................
22.1.3. Personnel
..............................................................................
2.2.1.4. Performance
...........................................................................
22.1.5. Reporting and Follow-up..............................................................
32.1.6. Records ................................................................................
4Page 6 of 8 Revision 90 TABLE OF CONTENTS2.2. Vendor Audits..........................................................................
42.3. Independent Management Assessment
........................................
,.... 4APPENDIX A, AUGMENTED QUALITY1 .....SCOPE.....................................................................................
12 .....REQUIREMENTS
.........................................................................
12.1. Health Physics and ALARA (As Low As Reasonably Achievable)................
12.2. Transport of Radioactive W aste ......................................
2.3. Services
................
...............................................................
22.4. Fire Protection
.........................................................................
22.5. Station Blackout (Reg. Guide 1.155) ........................................
........22.6. Augmented Quality Requirements for Dresden 1, and Peach Bottom 1I.........
22.7. Repairs and Alterations...............................................................
32.7.1. State of Illinois
.........................................................................
32.8. Dry Cask Storage System............................................................
42.8.1. Limerick, Peach Bottom, and Oyster Creek ........................................
42.8.2. Braidwood, Byron, Dresden, LaSalle and Quad Cities Station(s).................
42.9 Emergency Planning...........................................................
52.10 Security
...............
- .........................................................5 2.11 License Renewal...............................................................
5APPENDIX B, AUDIT FREQUENCY 1 .....TABLE......................................................................................
1APPENDIX C, CODES, STANDARDS, AND GUIDES1.1. Codes and Standards
.................................................................
11.2. Regulatory Guides ......................................................................
21.3. Site Specific Clarifications and Exceptions..........................................
31.3.1. Limerick (LGS) and Peach Bottom Atomic Power Station (PBAPS) ..............
31.3.2. Oyster Creek (OCNGS) and Three Mile Island (TMI) Stations....................
51.3.3. Clinton Power Station (CPS).........................................................
111.3.4. Calvert Cliffs, Ginna, and Nine Mile Point ......................................
11APPENDIX D, DEFINITIONS 1I.....SCOPE
......................................................................................
I2 .....GLOSSARY OF TERMS .................................................................
1Page 7 of 8 Revision 90 TABLE OF CONTENTS.APPENDIX E, CONTROL OF RADIOACTIVE WASTE OR MATERIALS (SITE SPECIFIC)
- 1. SCOPE ..........................................................................................
I2. REQUIREMENTS.............................................................................
12.1. Generai.................................................................................
12.2. Three Mile Island/Oyster Creek.......................................................I 2.3. Clinton Power Station .................................................................
32.3.1. Radioactive Waste/Augmented "D" Systems .......................................
32.3.2. Packaging and Transportation of Radioactive Waste ..............................
3APPENDIX F, GRADED APPROACH (SITE SPECIFIC) 1 .....SCOPE.....................................................................................
12 .....REQUIREMENTS
..........................................................................
I2.1. General.................................................................................
12.2. Quality Classification...................................................................I 2.2.1. Nuclear Safety Related or Augmented Quality Items ..............................
22.2.2. QATR Scope Activities................................................................
2O APPENDIX G, SUPPLEMENTAL APPLICATIONS(STSPCF) 1.....SCOPE
.....................................................................................
12 .....REQUIREMENTS..........................................................................I 2.1. Clinton Power Station (CPS)..........................................................I 2.1.1. Environmental
....................
....................................................
12.1.2. Fire Protection
...................................................................
22.1.3. Security........................................................................
32.2. Oyster Creek Nuclear Generating Station (OCNGS) ............................
32.2.1. Audits...........................................................................
3Page 8 of 8 Revision 90 EXELON NUCLEARPOLICY1. POLICY STATEMENT The Quality Assurance Topical Report (QATR), NO-AA-1 0, is the highest tiereddocument that assigns major functional responsibilities plants owned oroperated by Exelon Generation
- Company, LLC. Implementing documents assign more specific responsibilities and tasks and define the organizational interfaces involved in conducting activities and tasks within the scope of thisPlan. These requirements apply to those organizations and positions, whichmanage and perform activities within its scope.The Company organization is structured on the basis that the attainment of theobjectives of this Plan relies on those who manage, perform, and support theperformance of activities within the scope of this plan. Assurance of thisattainment relies on those who have no direct responsibility for managing orperforming the activity.
The Company will maintain and operate its nuclear plants in a manner that willensure the health and safety of the public and our workers.
All facilities shall beat a minimum compliance with the requirements on the Code of FederalRegulations, NRC Operating
- Licenses, and the applicable laws and regulations of the state and local governments.
- 2. APPLICABILITY All Company personnel who work directly, or indirectly, for the Company areresponsible for the achievement of quality in their work. Accordingly, allCompany personnel and its contractors engaged in supporting nucleargeneration activities shall comply with the requirements of our Quality Assurance Program (QAP).Page lofI Revision 90Page 1 of IRevision 90 ORGANIZATION CHAPTER 11. SCOPEThis chapter identifies those portions of the Company organization as it appliesto the Quality Assurance Program (QAP), and defines the responsibility andauthority for establishing, executing, and verifying its implementation.
Theresponsibility for the program is retained and executed by the Companyexclusively.
Organizational responsibilities are described for assuring that activities affecting quality are prescribed and implemented by documented instructions, procedures, and drawings.
The achievement of quality in the performance ofquality related activities are the responsibility of each individual in support ofnuclear operations.
The requirements and commitments contained in the QAP are mandatory andmust be implemented,
- enforced, and adhered to by all individuals andorganizations.
- 2. REQUIREMENTS Note: Minor variations may occur between the titles contained herein and those used in practice.
Specific positiondescriptions may be contained in approved Companydocuments.
2.1. Organization
The organizational structure of the Company consists of corporate functions, and the nuclear facilities.
Organizational titles for the quality assurance functions described are identified in Company policies and procedures.
Lines of authority and responsibility are established from the highestmanagement level through intermediate levels to the implementing personnel.
The responsibility, authority, and relationships of the various personnel andorganizations are documented and maintained current.The authority to accomplish the quality assurance functions described hereinmay be delegated to the incumbent's staff as necessary to fulfill the identified responsibilities.
Page 1 ofl6 Revision 90Page 1 of 16Revision 90 ORGANIZATION CHAPTER 12.2. Corporate Organization 2.2.1. President and Chief Executive OfficerThe President and Chief Executive Officer (CEO), Exelon Corporation, isresponsible for overall corporate policy and provides executive direction andguidance for the corporation as well as promulgates corporate policy through theCompany 's senior management staff. A management position responsible forNew Business Development reports to this position through the Sr. Executive Vice President and Chief Strategy
- Officer, Exelon Corporation.
2.2.2. Sr. Executive Vice President, Chief Commercial
- Officer, ExelonCorporation, and President and Chief Executive
- Officer, ExelonGeneration CompanyThe Sr. Executive Vice President, Chief Commercial Officer of ExelonCorporation, President and Chief Executive
- Officer, Exelon Generation, isresponsible for Exelon Generation policy and provides executive direction andguidance for Exelon Generation as well as promulgates corporate policy throughExelon Generation senior management staff. Overall responsibility for theimplementation of the QAP is delegated to the Sr. Executive Vice President, Exelon Generation and President and Chief Nuclear Officer, Exelon Nuclear.2.2.3. Sr. Vice President Regulatory Affairs and General CounselThe Senior Vice President and General Counsel serves as the primary legal andregulatory advisor to the company's senior management with respect to all legaland regulatory matters within his or her area of expertise, sets the companyvision and overall legal strategy for his or her area of expertise, is responsible forall legal and regulatory services relating to one or more practice areas andprovides leadership for and manages attorneys and other legal and regulatory professionals in those practice areas throughout the company.
This positionperforms legal and regulatory services involving high-level or complex legalmatters in his or her practice area. The following management position reports tothis position.
- 1. A management position responsible for licensing and regulatory affairsprovides organizational support and management oversight of the stationsto ensure prompt and proper disposition of regulatory issues, developsregulatory positions and advises senior management on priorities andactivities affecting regulatory issues at the nuclear sites. Otherresponsibilities include developing policies and standardized processes andprocedures for the maintenance of the licensing basis, the preparation ofsubmittals to the NRC and other regulatory organizations, the dissemination of regulatory experience information and the NSRB. Sr. Executive VicePresident, Exelon Generation and President and Chief Nuclear Officer,Exelon NuclearPage 2 of 16 Revision 90Page 2 of 16Revision 90 ORGANIZATION CHAPTER 12.2.4 The Sr. Executive Vice President, Exelon Generation and President and ChiefNuclear Officer (ONO), Exelon Nuclear, reports to the Sr. Executive VicePresident, Chief Commercial
- Officer, Exelon Corporation, and President andChief Executive
- Officer, Exelon Generation Company and has overallresponsibility for the safe and reliable operation of the Company's nuclearstations.
This is the senior executive responsible for setting and implementing
- policies, objectives, expectations, and priorities to ensure activities areperformed in accordance with QAP and other requirements.
The following management positions and committees report to and / or receive direction fromthe CNO with respect to their assigned roles and responsibilities associated withthe execution of the Exelon Nuclear Quality Assurance Program:1. The Chief Nuclear Officer (CNO), CENG Senior Vice President Operations is responsible to provide management and oversight and support of the day-to-day operations of the CENG stations for the safe and efficient operation of the CENG nuclear fleet in compliance with the CENG QAP. In addition, the CNO, CENG is the CENG role for all industry, legal and regulatory requirements for plants owned under the CENG joint venture; and fulfill theacting CEO role reporting to the CENG Board.2. The Chief Operating Officer (COO), Fleet Operations, Exelon Nuclear, isresponsible to provide management oversight and support of the day-to-day operations of the stations for the safe and efficient operation of the nuclearfleet in compliance with the QAP. The COO is responsible for planning, organizing, and directing and controlling the operations, maintenance andimprovement of the nuclear facilities.
This position participates in theformulation of nuclear group strategy and policy, and provides leadership and direction to implement industry best practices.
The following management positions report to the COO:A management position responsible for Mid-Atlantic operations provides management oversight and support of the day-to-day operations of the Mid-Atlantic stations.
This position implements
- policies, goals, and objectives, in accordance with the QAP and otherrequirements, to assure the safe and reliable operation of the Mid-Atlantic nuclear stations This position participates in the formulation ofnuclear group strategy and policy, and provides leadership anddirection to implement industry best practices.
- Management positions responsible for Midwest operations providemanagement oversight and support of the day-to-day operations ofthe Midwest stations.
These positions implement
- policies, goals, andobjectives, in accordance with the QAP and other requirements, toassure the safe and reliable operation of the Midwest nuclear stationsThese positions participate in the formulation of nuclear group strategyPage 3 of 16Revision 90 ORGANIZATION CHAPTER 1and policy, and provide leadership and direction to implement industrybest practices.
- A management position responsible for Nuclear Project Management who is responsible for the oversight and support of Projectmanagement activities for Exelon Nuclear.3. A management position for operations support who is accountable fordefining standard programs and processes, delivering effective servicesand support, providing technical oversight of program implementation, andsupporting the deployment and sharing of best practices throughout thenuclear organization in accordance with the QAP and other requirements, as applicable.
Other responsibilities include providing overall direction andmanagement oversight for environmental issues. Reporting to thisposition is a staff of management, administrative, and technical personnel.
Functional areas of responsibilities include:-security, chemistry, industrial safety, maintenance and workcontrol, outage planning and services, operations, radiation protection, radioactive waste, emergency
- planning, environmental.
-Laboratory services including calibration and maintenance ofmeasuring and test equipment, calibration of radiation protection equipment and test & analysis services.
- 4. The management position responsible for engineering
& technical servicesprovides oversight and support and is accountable for defining standardprograms, processes,
- policies, procedures, delivering effective servicesand support, providing technical oversight of program implementation, andsupporting the deployment and sharing of best practices throughout thenuclear organization in accordance with the QAP, regulatory requirements, and the ASME Code. Reporting to this position is a staff of management, administrative, and technical personnel.
Functional areas of responsibility include;-Engineering that provides support to the nuclear stations, designauthority under the ASME Code, configuration management
- programs, special processes, and generic programs for technical and regulatory issues. A support staff provides the necessary discipline and expert support for setting technical policy,developing design standards, performing engineering discipline
- reviews, and performing the document control and recordsmanagement programs.
This staff develops and supports commonapproaches for technical and regulatory engineering issues, aswell as develops and coaches engineers.
Corporate procurement engineering provides governance and oversight of the nuclearorganization's procurement engineering process and technical operations.
This includes parts evaluation, upgrading of stockmaterial, equivalent item evaluation, and examination and testingPage 4 of 16Revision 90 ORGANIZATION CHAPTER 1in accordance with the applicable ASME Code and FederalRegulations.
-nuclear fuels management providing BWR/PWR nuclear fuelprocurement and fabrication
- services, technical support to monitorfuel reliability and certain in-core components, design and licensing analyses for core reloads, safety analyses, wet and dry spent fuelstorage governance, oversight and technical
- support, long-term spent fuel management strategies, and decommissioning activities including cost estimating, governance, oversight and technical support..
This position is responsible for reactivity management oversight and corporate support of reactor operations to ensuresafe and reliable plant operations, as the manager of nuclearmaterials, and for controls and reports associated with specialnuclear material accountability.
-a management position responsible for license renewal-project management including power uprate and other projects-risk management
- 5. The Management position responsible for Organizational Effectiveness andIntegrated Performance Assessments (OR&IPA).
This position isresponsible for the independent assessment
- program, initiating,
- trending, and recommending solutions for deficiencies, initiating stop work, ordering aunit shutdown, or requesting any other actions deemed necessary to avoidunsafe plant conditions or a significant violation of the QAP, periodicassessments to determine that the Quality Assurance Policy is being carriedout, and maintaining a suitably trained and qualified staff as appropriate.
This position is independent of station responsibilities and is responsible toprioritize and communicate common quality issues to appropriate seniormanagement including the resolution of these issues. The following management positions report to the OR&IPA SVP:PageS of 16 Revision 90Page 5 of 16Revision 90 ORGANIZATION CHAPTER 1-A management position responsible for Organizational Performance, which includes functional results and organizational effectiveness performance.
This position is responsible for theindependent assessment program including regularly scheduled assessments and any assessment required based on analysis ofan emergent performance issues. In addition, this position is alsoresponsible for performance improvement which includes theadministration of the fleet Operational Experience and Corrective Action Programs.
This position maintains authority andresponsibility to escalate issues and stop work or request anyother actions to avoid unsafe plant conditions.
oReporting to the management position forOrganizational Performance is a management position responsible for Fleet Assessments oAlso reporting to the management position forOrganizational Performance is a management position for Performance Improvement.
-A management position responsible for Innovation.
-A management position responsible for Training.
-Maintaining a dotted line reporting relationship to themanagement position responsible for OR&IPA is a management position responsible for Talent Management
& Organization Development (TMOD).6. The management position responsible for Nuclear Oversight (NOS)activities is independent of production and assures that an appropriate QAPis established, maintained, and effectively executed throughout the nuclearorganization.
This position provides overall direction for the implementation of the QAP and for the effective implementation of quality assurance functions that verify activities affecting safety-related functions.
A staff ofsupervisory, administrative, and technical personnel supports assessment and quality verification.
Functional responsibilities include:-employee concern program activities.
-establishing quality assurance practices and policies.
-quality verification activities.
Page 6 of 16 Revision 90Page 6 of 16Revision 90 ORGANIZATION CHAPTER 1-initiating stop work, ordering unit shutdown, or request any otheractions deemed necessary to avoid unsafe plant conditions or asignificant violation of the QAP.-initiating,
- trending, and recommending solutions for deficiencies identified by NOS.-maintaining a trained and qualified staff of personnel within the NOSorganization.
-maintenance and approval of revisions to the Quality Assurance Topical Report (QATR) and the program for employee concerns.
-overseeing nuclear site NOS activities.
-participation in joint membership groups.-periodic audits to determine that the Quality Assurance Policy isbeing carried out.-periodic review of the independent assessment program.-periodically apprising the President and ONO and the Nuclear SafetyReview Board of the status of the quality assurance aspects atCompany facilities and immediately apprise them of significant problems affecting quality.-settling disputes between NOS and other organizations.
-the certifying authority for NOS audit personnel.
-the Independent audit oversight program.-verifying implementation of solutions for significant conditions adverseto quality identified by NOS.A. Reporting to the management position responsible for NOS is amanagement position responsible for auditing and programs.
Functional areas of responsibility include:-maintaining the regulatory required compliance auditingprogram.-maintaining the Quality Verification (QV) program-managing supplier assessments, audits, or surveys (including their sub-tier suppliers) as required.
Verifies that supplierquality assurance programs comply with Companyrequirements and has the authority and responsibility for QAPage 7 of 16Revision 90 ORGANIZATION CHAPTER 1activities applicable to supplier evaluation including, stop workas deemed necessary when a violation of the QAP is identified.
-establishing, maintaining, and interpreting Company qualityassurance policies and procedures
-providing training on quality assurance subjects.
-establishing the requirements for auditor and inspector certification.
-controlling and maintaining the QATR.-provides an offsite point of contact for station QualityVerification personnel if assistance is necessary for qualityverification activities.
-provide management with periodic reports on the adequacy ofthe QAP.-managing implementation of the program for employeeconcerns.
Personnel performing Quality Verification functions including:
- planning, inspecting, and reporting, shall be trained and qualified for their assignedfunctions.
With the exception of receipt inspection activities, inspection personnel shall:-report to the Management Position responsible for QV when performing Quality Verification functions, even though they may functionally report toanother organization for their other assigned activities
-have their qualifications approved by the Management Positionresponsible for QV prior to performing inspection activities.
-not perform independent inspections on any work that they haveperformed or directly supervised.
-be subject to audit by NOS.The receipt inspection activities are controlled by the Nuclear Supplyorganization.
This structure assures adequate independence between performance andverification of activities is maintained.
Page 8 of 16 Revision 90Page 8 of 16Revision 90 ORGANIZATION CHAPTER 17. The Nuclear Safety Review Board (NSRB) is an offsite committee thatreports to and advises the Sr. Executive Vice President, Exelon Generation and President and Chief Nuclear Officer of the results of their independent oversight of plant operations related to safe operation of the station and theCompany's nuclear program relative to nuclear safety. The NSRB isresponsible for the independent safety review function and functions inaccordance with written procedures and instructions which delineates committee composition, responsibility, authority, member qualifications, meeting frequency, subjects to be reviewed, reporting requirements, andadministrative controls under which the board operates.
The NSRB:-conducts independent reviews of station performance andoperations to determine if the facility is being operated andmaintained in a manner that promotes safety and providesfeedback to the organization on suggested improvements.
-focuses primarily in the areas of Operations, Maintenance, Engineering, Plant Support, Regulatory and Nuclear Oversight, orother matters relating to safety.-reviews station materials and activities and advises the CNO andmanagement responsible for NOS on the following activities:
-, any issue potentially affecting the safe operation of the facility.
-station nuclear safety performance determined by discussion andinterviews with station and Exelon Nuclear individuals, plant tours,oversight of meetings, and review of documents distributed forNSRB review.-effectiveness of the station program for oversight including audits,assessments, and self-assessments.
-corrective actions for degraded or non-conforming conditions involving violations of the NRC license requirements, planttransients or forced shutdowns, or the submission of a LicenseeEvent Report (LER).-oversight of activities of the on-site safety review function.
- 8. The management role of Integration, Business Development
- 9. The management role of Strategy and planning10. The management position of strategy with Exelon Nuclear Partners (ENP)Functional areas that also maintain a dotted line report to CNO supporting the ExelonNuclear organization are:* Legal* Human Resources
- Communication
- Information Technology Page 9 of 16Revision 90 ORGANIZATION CHAPTER1Information technology is no longer a functional area exclusively withinthe nuclear organizational structure but now supports the entireExelon Corporation.
The management position responsible foroperations support will supply oversight and governance for thefunctional area of information systems as it applies to Exelon Nuclear.The oversight and governance of this functional area is performed toensure that organizational and functional responsibilities and thereporting relationship to the management position responsible for allnuclear activities, the CNO, is maintained within the requirements stated within the QATR. This includes all regulatory requirements committed to by the QATR. Specifically, the management positionresponsible for operations support supplies oversight and governance for management and supervision of information systems relatedservices and activities including the software quality assurance program (DTSQA).
This includes the creation, acquisition, theenhancement of computer
- hardware, communication, and softwaresystems to support operational requirements.
-The management position responsible for business operations providesintegrated support to senior management and the nuclear sites for allbusiness functions.
This position dotted line reports to the CNO. Reporting to this position is a staff of supervisory, administrative, and technical personnel.
Functional areas of responsibility includes:
-business planning and process improvement.
-communications.
-decommissioning financial reporting and trust fundreimbursements.
Supply is no longer a functional area exclusively within the nuclearorganizational structure but now supports the entire Exelon Corporation andhas a dotted line to the CNO. This management position will supply oversight and governance for the functional area of supply as it applies to ExelonNuclear in the procurement and warehousing areas. The oversight andgovernance of this functional area is performed to ensure that organizational and functional responsibilities and the reporting relationship to themanagement position responsible for all nuclear activities, the CNO, ismaintained within the requirements stated within the QATR. This includes allregulatory requirements committed to by the QATR. The management position responsible for business operations supplies oversight andgovernance for:-the Exelon Nuclear supply function including the establishment ofpriorities and providing operational control of the purchase of non-fuelgoods and services required for nuclear operations.
This organization is also responsible for the areas of material procurement, servicesprocurement, supply programs, inventory management, andinvestment recovery.
Supply establishes
- policies, commonPage 10 of 16Revision 90 ORGANIZATION CHAPTER1administrative controls and processes to ensure compliance withapplicable requirements and effective use of resources.
2.3. Site Organization A management position for each nuclear site reports through the applicable management position responsible for each designated operating group including the MidAtlantic and the Midwest and is responsible for overall plant nuclearsafety and the implementation of the Company's QAP. This position is alsoresponsible for the station compliance with its NRC operating license,governmental regulations, and ASME Code requirements:
Day to-day direction and management oversight of activities associated with the safe and reliableoperation of a nuclear station is provided.
The following site management positions report to the respective Senior Vice President MW Operations orSenior Vice President MA Operations through the Site Plant Manager or SiteVice President.
The Site Vice President has overall responsibility and accountability for the safeand efficient operation of a nuclear power plant. The following positions reportto the Site Vice President 2.3.1. The Plant Manager has the day-to-day responsibility for managing the safe andefficient operation of a nuclear power plant. This management position assuresthe safe, reliable, and efficient operation of the plant within the constraints ofapplicable regulatory requirements, operating
- license, and the QAP.Supervisory direction is provided for the Technical Review Program, including approval of individuals as technical reviewers, and the Plant Operations ReviewCommittee (PORC). During periods that exceed three months, whenunavailable, responsibility is designated in writing to an established alternate who satisfies the experience requirements of this position.
The following positions report to the plant manager:-Operations and Support Including:
- a management position responsible for safe, reliable, and efficient plant operations within the constraints of the operating license andregulatory requirements.
This position is also responsible for thedevelopment and implementation of appropriate controls inaccordance with the QAP and other requirements.
- management position(s) responsible for operations shift crews andadministration, direction and supervision of operating staff. Thisposition is also responsible for routine plant operations activities andevolutions that are performed within the constraints of the operating
- license, the QAP, and other requirements.
Typically this position isthe senior individual on site who holds a Senior Reactor Operatorlicense.Page 11 of 16Revision 90 ORGANIZATION CHAPTER 1*management position(s) responsible for the day-to-day operation ofO the nuclear unit(s) ) including reactor engineering and overallcommand and control of shift activities including operations of theradioactive waste system.*management position(s) responsible for supervision for control of workand of the plant and field supervision that coordinates and/or assists inthe control of shift operations.
This position directs control roompersonnel, field operations, has the primary responsibility forauthorizing removal and restoration of systems to supportmaintenance activities and holds a Senior Reactor Operator License.*a management position responsible for advisory technical support toshift management in the areas of thermal hydraulics, reactorengineering and plant analysis with regards to the safe operations ofthe facility.
In addition, this position shall meet the qualifications asspecified by the NRC.-The management position(s) for maintenance are responsible for theperformance of corrective, predictive and preventive maintenance, cleanliness controls and modification installation of mechanical andelectrical equipment and instrumentation in accordance with the QAP andother requirements.
A staff of supervisory, technical, administrative, and* contract personnel supports day-to-day maintenance of equipment withintheir functional area.-The management position(s) responsible for control of work coordinate, administer,
- execute, and monitor daily and outage work schedules.
Thisposition is also responsible for material management and site supply,which coordinates parts requirements, specifies and evaluates parts,procures all materials for the site, ships and receives
- material, andcontrols the onsite inventory.
The site supply chain provides andcoordinates scope and priority for station procurement engineering efforts.-The management position(s) responsible for chemistry activities, laboratory and system processes, related procedures and programs.
- environmental services.
- radioactive waste.* radiological environmental monitoring
-The management position health physics/radiological protection.
-The management position responsible for performa~nce improvement.
-The management position responsible for safety.2.3.2. The management position for engineering and design has the responsibility andO authority for day-to-day engineering support activities, develops and maintains engineering
- programs, policies, procedures, and provides engineering servicesin accordance with the QAP. A staff of supervisory, technical, and administrative Page 12 of 16Revision 90 ORGANIZATION CHAPTER 1personnel supports maintenance activities.
Functional areas of responsibility include:-design engineering.
-engineering administration.
-modifications and their implementation.
-plant configuration control.-system engineering.
-system testing.technical support.-dotted line accountability for document control and quality assurance records management.
2.3.3. The management position responsible for regulatory assurance maintains aninterface and liaison between the station and federal and state regulators..
Functional responsibilities include:-emergency preparedness 2.3.4. The management position responsible for training provides direction, control,and overall supervision of personnel as required by regulations and training forall site personnel as required.
Functional areas of responsibility include:-learning services.
-maintenance technical training.
-operations training.
2.3.5. The Plant Operations Review Committee (PORC) is a multi-disciplined committee responsible for review of activities that affect nuclear safety, reportsto, and advises the management position responsible for plant operation onmatters related to nuclear safety. The PORC shall ensure that plant activities are conducted safely and do not require NRC review and approval prior toimplementation or changes to the Technical Specifications.
The POROfunctions in accordance with written instructions which delineate committee composition, responsibility, authority, member qualifications, meeting frequency, subjects to be reviewed, reporting requirements, and administrative controlsunder which the group operates.
In discharging its independent review responsibilities, PORC shall keep safetyconsiderations paramount when opposed to cost or schedule considerations.
Should a voting member have direct responsibility for preparation or technical review of the item requiring PORC independent review, where conflict of suchconsiderations is likely, that member shall be replaced (to fill the quorum) byanother voting member not having such potential conflict.
2.3.6. A position responsible for site assessment activities reports to the management position responsible for Fleet Assessments.
This position has the organizational freedom and authority to identify
- problems, has a reporting relationship with thePage 13 of 16Revision 90 ORGANIZATION CHAPTER 1senior management position responsible for overall plant nuclear safety, andensures compliance with QAP and nuclear safety requirements.
Significant safety or quality issues requiring escalated action will be directedthrough the management position responsible for Organizational Effectiveness and Integrated Performance Assessments (OR&IPA)to the President and CNO.This individual, supported by the fleet organization, is functionally responsible for:-authority and responsibility to escalate matters.-conducting independent assessments of line and support activities andsafety reviews.-initiate, trend and recommend solutions for deficiencies identified byOR&I PA.-monitoring day-to-day station activities.
-provide OR&IPA management periodic reports on the status andadequacy of the QAP.-promptly communicate significant issues to OR&IPA and appropriate sitemanagement.
-stop work or request any other actions to avoid unsafe plant conditions.
2.3.7. The Management Position responsible for Performance Improvement.
Functional responsibilities include:-Corrective Action Program-Self-Assessments/Benchmarking
-Operating Experience 2.3.8. The management position responsible for security.
2.3.9. The management position(s) responsible for project management.
2.3.10. The following management positions maintain a dotted line reporting relationship to the Site Vice President.
-The management position(s) responsible for Business Operations.
-The management position(s) responsible for Human Resources.
-The management position(s) responsible for Communications.
2.4 The Company uses a three-tiered approach to accomplish the oversight ofsafety which are:-A collection of program elements for implementing and/or reviewing areasof quality of plant operations and nuclear safety. These elements includesystem performance monitoring, review of operating experience information, operability evaluations, and reviews of changes to technical specifications and final safety analysis reports that affect design bases.Specific guidance is contained in applicable procedures and programs.
Page 14 of 16Revision 90 ORGANIZATION CHAPTER1-A NOS staff who assesses and performs quality verification inspection aspects of Company activities within the scope of the QATR relating tosafety. This provides for an overview of activities affecting or potentially affecting safety.-A PORC which is an on-site committee that reports to and advises thePlant Manager on all matters related to nuclear safety in plant operations.
A NSRB which is an off-site committee that reports to and advises the Sr.Executive Vice President, Exelon Generation and Chief Nuclear Officer,Exelon Nuclear, of the results of independent oversight of plant operation relative to nuclear safety.2.5 Decommissioning Site Organization Similar to the operating units, the management position responsible for plantoperations is also responsible for the management oversight, directing, andimplementing appropriate controls to maintain the site within the requirements and constraints applicable to a permanently shutdown station or unit (or thosestations or units not under the control of an NRC approved decommissioning plan), and to ensure the safe storage of spent nuclear fuel.2.6. Responsibility Each holder of position as identified in this Chapter, has the responsibility for thescope and effective implementation of the QAP and may delegate all or part ofthe activities of planning, establishing, and implementing the QAP to others, butretains the responsibility for the program's effectiveness.
The Company is responsible for ensuring that the applicable portion(s) of theQATR is properly documented,
- approved, and implemented before an activitywithin the scope of the QAP is undertaken by the Company or by others.Personnel performing oversight functions for the Company have theresponsibility, authority, organizational
- freedom, and sufficient independence from cost and schedule to:-assure that further processing,
- delivery, installation, or use is controlled until proper disposition of a nonconformance, deficiency, or unsatisfactory condition has occurred.
-identify quality problems.
-initiate, recommend, or provide solutions to quality problems throughdesignated channels.
-initiate stop work, order unit shutdown, or request any other actionsdeemed necessary to avoid unsafe plant conditions or a significant violation of the QAPPage 15 of 16Revision 90 ORGANIZATION CHAPTER1-verify implementation of solutions for significant conditions adverse toquality.The Company may delegate certain phases of the work to non-company laborand contracted
- services, which act as the Company's agents in assigned areas.They shall work to a Company accepted quality program (or in accordance withthe Company's program) under overall site direction and document theirorganization and any delegated responsibilities necessary to establish, execute,and verify their quality program.
The Company may also assign the authority forcertification and stamping in accordance with the ASME Code.2.7. Authority When the Company delegates responsibility for planning, establishing, orimplementing any part of the overall QAP, sufficient authority to accomplish theassigned responsibilities is delegated.
Regardless of delegation, the Companyretains responsibility.
Page 16 of 16 Revision 90Page 16 of 16Revision 90 QUALITY ASSURANCE PROGRAMCHAPTER21. SCOPEThe purpose of this chapter is to define how the Company's QAP applies tothose activities such as design, procurement, fabrication, installation, modification, maintenance, repair, refueling, operation, inspection, and testsrelated to systems, structures, and components.
The QAP also applies tocertain non-safety related structures,
- systems, components and activities to adegree consistent with their importance to safety. Policies, directives, procedures, guidelines,
- manuals, or instructions shall be reviewed,
- approved, distributed, and revised in accordance with administrative procedures.
- 2. REQUIREMENTS 2.1. GeneralThe QAP comprises all those planned and systematic actions necessary toprovide adequate confidence that structures,
- systems, and components willperform satisfactorily in service.
Quality assurance includes quality verification, which comprises the examination of those physical characteristics of material, structure, component, or system which provide a means to control the quality ofthe material, structure, component, or system to predetermined requirements.
All persons and organizations involved in activities in support of the nuclear sitesand governed by this program are responsible for implementing therequirements of this manual.The QAP is based upon 10OCFR50, Appendix B, "Quality Assurance Criteria forNuclear Power Plants and Fuel Reprocessing Plants."
The requirements of10CFR50.54, "Conditions of License,"
10CFR50.55a, "Codes and Standards,"
10OCFR50.59, "Changes, Test, and Experiments,"
10OCFR50 Appendix A,"General Design Criteria for Nuclear Power Plants,"
10OCFR50 Appendix R, "FireProtection Programs for Nuclear Power Plants,"
are included in the basis for theQAP.The requirements of 10CFR21, Reporting of Defects and Non-Compliance,"
- 10OCFR71, Subpart H, "Quality Assurance for Packaging and Transportation ofRadioactive Material,"
and 10CFR72, Subpart G, "Quality Assurance forLicensing Requirements for the Independent Storage of Spent Nuclear Fuel andHigh-Level Radioactive Waste," are also included.
The Company is committed to carrying out the provisions of various NRC regulatory guides and industrystandards which further define Quality Assurance Program requirements (seeattached Appendix C).2.2. Supplier's Quality Assurance ProgramThe Company's procurement documents require that each vendor, supplier, orcontractor maintain a quality assurance program that satisfies the applicable portions of:Page 1 of 3 Revision 90 QUALITY ASSURANCE PROGRAMCHAPTER 2-ASME NQA-1 and the ANSI N45.2 Standards not covered by NQA-1 orthe ANSI N45.2 series of standards for previously accepted non-ASMEquality assurance programs.
-ANSI N18.7 Standards
-ASME Section III, Appendix XXII for suppliers of ASME Code Designservices.
2.3. PlanningPlanning establishes the systematic, sequential progression of actions to meetthe defined requirements.
The Company documents these plans in appropriate communications, approvals, instructions, and procedures.
Activities described inthe QAP are accomplished under controlled conditions that include appropriate equipment, qualified personnel, suitable environment, and use of appropriate procedures.
2.4. Program Description The Company's total program for providing administrative controls and qualityassurance is incorporated in many diverse documents.
The Company's nucleardocument hierarchy describes the implementation of the QAP. Approvedimplementing procedures and instructions are written to the extent necessary toimplement the quality requirements of 10CFR50 Appendix B. Line, staff,administrative, and quality oversight organizations issue and control theseimplementing procedures.
All activities affecting quality are described insufficient detail to assure quality.2.5. Indoctrination
& TrainingFormal indoctrination and training programs for personnel performing or verifying activities within the scope of this Plan are established and maintained.
Atraining organizational element is established and staffed with qualified instructors and is responsible for planning, scheduling, developing and providing training to Company personnel.
The indoctrination and training programs areestablished by on-site and by off-site organizational units responsible for theperformance or verification of activities within the scope of the QAP.Indoctrination,
- training, and qualification programs are established such that:-personnel responsible for performing quality-affected activities areinstructed as to the purpose, scope, and implementation of the quality-related manuals, instructions, and procedures.
-personnel verifying activities affecting quality are trained and qualified inthe principles, techniques, and requirements of the activity beingperformed.
-formal training and qualification programs documentation includes theobjective, content of the program, attendees, and date of attendance.
Page 2 of 3Revision 90 I QUALITY ASSURANCE PROGRAMCHAPTER2-proficiency tests are given to those personnel performing and verifying activities affecting
- quality, and the acceptance criteria are developed todetermine if individuals are properly trained and qualified.
-certificate of qualification clearly delineates the specific functions personnel are qualified to perform and the criteria used to qualifypersonnel in each function.
-proficiency of personnel performing and verifying activities affecting quality is maintained by re-training, re-examining, re-qualifying, and/or re-certifying as determined by management or program commitment.
2.6. Program ReviewThe effectiveness of the QAP and its implementation is periodically reviewed byvarious organizations at various levels. The results of these reviews aredocumented in reports to senior management for evaluation and corrective action is initiated as required.
The effectiveness of the QAP is evaluated andreported by NOS through the monitoring, assessment, and inspection functions.
Other organizational elements provide additional information!/evaluations asrequested.
2.7. Quality Assurance ManualThis Quality Assurance Manual (QAM) contains the Company's QAP. The QAMis made available to NRC, Company personnel, the Authorized NuclearInspector, and other regulatory authorities.
The Company submits revisions tothe QAP document (as a topical report) to the NRC for acceptance.
Page 3 of 3 Revision 90Page 3 of 3Revision 90 J DESIGN CONTROLCHAPTER 31. SCOPEThe purpose of this chapter is to establish the requirements and controlmeasures for assuring design bases and regulatory requirements are correctly translated into design documents.
The scope of design control covers allphases of engineering design, including:
identification of design inputs (criteria and bases); identification and control of design interfaces; production of designdocuments, calculations and analyses; procurement related engineering anddesign verification.
- 2. REQUIREMENTS 2.1. GeneralThe Company has overall responsibility for design and design control activities including, preparing, reviewing, approving, and verifying design documents related to the plant's structures,
- systems, and components within the scope ofthe QAP. Additionally, the Company is responsible for reactor core designanalysis, core design specifications and design reviews, for nuclear fuel andin-core components.
Qualified personnel perform detailed design activities or review and controldesign work involving electrical, mechanical, structural, and instrumentation andcontrol designs.
Design activities are conducted to written procedures thatinclude consideration of quality standards, quality assurance requirements, suitability of material parts, equipment, and processes, control of designinterfaces, analytical or testing requirements, design basis, and configuration management.
2.2. Design InputThe Company has the responsibility to properly translate applicable safetyanalysis
- reports, regulatory requirements, ASME Code requirements, anddesign bases into specifications,
- drawings, procedures and instructions.
TheCompany is responsible for electrical, mechanical, structural, instrumentation and control; nuclear engineering activities involved in nuclear stationmodifications, and also maintains a configuration management program.Design inputs, such as design bases, performance requirements, regulatory requirements, codes, and standards shall be identified and documented.
Theirselection shall be reviewed and approved by the responsible designorganization.
The design input shall be specified and approved in a timelymanner and be to the level of detail necessary to provide a consistent basis formaking design decisions, accomplishing design verification, and evaluating design changes.
Changes from approved design inputs, including the reason forthe changes shall be identified,
- approved, documented, and controlled.
Page 1 of 6Revision 90 DESIGN CONTROLCHAPTER 32.3. Design ProcessThe Company is responsible for design changes, performs detailed designactivities, and issues design documents in accordance with approvedprocedures.
The responsible design organization shall prescribe and documentdesign activities in a timely manner and to the level of detail necessary to permitverification that the design meets requirements.
Included in this scope of activities are considerations for field designengineering, fire hazards, human factors,
- physics, seismic, stress, compatibility of materials, application of special process, associated computer
- programs, thermal, hydraulic, ALARA and radiation
- factors, the safety analysis accidentscenarios, and accessibility for in-service inspection, maintenance and repairs,and quality standards.
Design documents shall be adequate to support facilitydesign, construction, and operation.
Selection of the appropriate qualitystandards shall be documented, reviewed and approved.
Reasons for changes from specified quality standards, shall be identified, documented, approved and controlled.
Design methods, materials, parts,equipment, and processes that are essential to the function of the structure, system, or component shall be selected and reviewed for suitability ofapplication.
Applicable industry experience, as set forth in reports or otherdocumentation, shall be made available to cognizant design personnel.
The final design output documents and approved changes thereto shall berelatable to the design input by documentation in sufficient detail to permitdesign verification.
The final design shall identify assemblies and/orcomponents that are part of the item being designed.
If materials, parts,equipment, or processes are different from the published supplier information, these differences shall be documented.
Commercially standard (catalog items) materials, parts, or equipment, whichhave been previously approved for different applications, are reviewed forsuitability in the design process.2.4. Design AnalysesDesign analyses shall be performed in a planned, controlled, and documented manner. Design analysis documents shall be legible and suitable forreproduction, filing, and retrieval.
They shall be sufficiently detailed as topurpose, method, assumptions, design input, references, and units such that aperson technically qualified in the subject can review, understand the analysis, and verify the adequacy of the results without recourse to the originator.
Calculations shall be identified for retrievability by subject including structure, system, component, originator,
- reviewer, and date or by other unique identifiers.
Page 2 of 6 Revision 90Page 2 of 6Revision 90 DESIGN CONTROLCHAPTER 3Computer programs shall be controlled to assure that changes are documented and approved.
Verification shall be required for changes to previously verifiedcomputer programs including evaluation of the effects of these changes asspecified below.Computer programs may be utilized for design analysis without individual verification of the program for each application provided:
-the computer program has been verified to show that it produces correctsolutions for the encoded mathematical model within defined limits foreach parameter employed.
-the encoded mathematical model has been shown to produce a validsolution to the physical problem associated with the particular application.
2.5. Design Verification Design control measures shall be applied to verify the adequacy of design, suchas by one or more of the following:
-performance of design reviews.-use of alternate calculations.
-performance of qualification tests.The results of design verification shall be documented the identification of the verifier.
Design verification shall be performed by competent individual(s) other than those who performed the original design but may be from the sameorganization.
This verification may be performed by the originator's supervisor, provided the supervisor did not specify a singular design approach, rule outcertain design considerations, did not establish the design inputs used in thedesign, or the supervisor is the only individual in the organization competent toperform the verification.
Cursory supervisory reviews do not satisfy the intent ofdesign verification.
Verification shall be performed in a timely manner. Design verification, for thestage of design activity accomplished, shall be performed prior to release forprocurement, manufacture, construction, or release to another organization foruse in other design activities provided sufficient data exists. Any unverified portion of the design shall be identified and controlled.
In all cases the designverification shall be completed prior to relying upon the component, system,structure, or computer program to perform its function.
2.5.1. Extent of Design Verification The extent of the design verification required is a function of the importance tosafety, the complexity of the design, the degree of standardization, the state ofthe art, and the similarity with previously proven designs.Page 3 of 6 Revision 90Page 3 of 6Revision 90 DESIGN CONTROLCHAPTER 3Where the design has been subjected to a verification
- process, the processneed not be duplicated for identical designs.
For each application theapplicability of standardized or previously proven designs for design inputs shallbe verified.
Known problems affecting the standard or previously proven designs and theireffects on other features shall be considered.
The original design andassociated verification shall be adequately documented and referenced insubsequent applications.
Design verification shall be required for changes to previously verified designs.This includes evaluation of the effects of those changes on the overali designand on any affected design analyses.
2.5.2. Design ReviewsVerification consists of a check of design adequacy by such methods as designreviews, use of alternate calculations or methods, or performance of verification or qualification testing.
The method, or combination of methods, used to verify adesign will be selected on a case-by-case basisAcceptable verification methods include one or more of the following items:-alternate calculations using alternate methods that verify the correctness of original calculations or analyses.
-critical design reviews providing assurance that the final design is correctand satisfactory.
-where design adequacy is to be verified by qualification tests, the testsare iden'tified.
2.6. Change ControlChanges to final designs, field changes, modifications to operating facilities, andnonconforming items dispositioned use-as-is or repair shall be justified andsubject to design control measures commensurate with those applied to theoriginal design.These measures shall include assurance that the design analyses for thestructure, system, or components are still valid. A 10OCFR50.59/72.48 review isperformed for changes to the facility.
Changes shall be approved by the same affected groups or organizations, whichreviewed and approved the original design documents.
In the case where theoriginal organization is no longer responsible for design approval, then a newresponsible design organization shall be designated.
The designated organization shall have demonstrated competence in the specific design area ofinterest and have an adequate understanding of the requirements and intent ofthe original design.Page 4 of 6Revision 90 DESIGN CONTROLCHAPTER 3When a design change is approved, other than by revision to the affected designdocuments, measures shall be established to incorporate, where appropriate thechange into these documents.
Plant personnel will be made aware of designchanges/modifications, which may affect the performance of their duties. Wherea significant design change is necessary because of an incorrect design, thedesign process and verification procedure shall be reviewed and modified asnecessary.
2.7. Design ErrorsThe Company detects deficiencies or errors in design or in the design qualityassurance program by:-actual failure during operation.
-assessments.
-design verification measures.
-other means.-personnel using the design documents.
-tests conducted.
2.8. interface ControlDesign interfaces shall be identified and controlled.
The Company shallcoordinate design efforts among the participating organizations.
Interface controls shall include the assignment of responsibility and the establishment ofprocedures among participating design organizations.
Controls shall beestablished for the review, approval,
- release, distribution and revision ofdocuments involving design interfaces.
Design information transmitted acrossinterfaces shall be documented and controlled.
2.9. Vendor Design ControlThe Company reviews and accepts the specifications and drawings forelectrical, mechanical, instrumentation, nuclear and structural
- material, equipment, and erection work, prepared by the Architect Engineer and NSSSSupplier.
The purpose of these reviews is to verify inclusion of inspection, testing and acceptance criteria.
The Architect Engineer's evaluation of fabricator and erector's detailed designs,drawings, and work instructions are reviewed for reasonableness andcompleteness.
Audits are conducted by the company for design review systemsof architect engineers, nuclear fuel, and NSSS suppliers.
Page 5 of 6 Revision 90Page 5 of 6Revision 90 DESIGN CONTROLCHAPTER 3The Company assures that:-personnel certifying ASME Section III design activities are qualified Registered Professional Engineers in accordance with ASME Section III,Appendix XXIII.-architect engineers and NSSS suppliers maintain procedures to assurethat their personnel certifying ASME Section III design activities arequalified Registered Professional Engineers in accordance with ASMESection III, Appendix XXIII.The Company provides qualified personnel to review and approve the resolution of non-conformances relating to electrical, mechanical, instrumentation andstructural portions of the plant and to evaluate discrepant modification testresults for operating plants.2.10. Modifications The Company performs modifications that may affect the function ofsafety-related structures,
- systems, or components in a manner to assure qualityat least equivalent to that specified in original design bases and requirements, materials specifications, and inspection requirements.
2.11. Documentation and RecordsThe Company notifies jurisdictional authorities of the location of ASME Coderelated permanent records.
Design documentation and records which provideevidence that the design and design verification process were performed inaccordance with the requirements of this chapter, shall be stored andmaintained.
Documentation of design analyses shall include the following:
-statement of the objective of the analyses.
-list of design inputs and their sources.-results of literature searches or other applicable background data.-list of assumptions and indication of those that must be verified as thedesign proceeds.
-list of any computer calculation and the bases for its use.-review and approval.
Page 6 of 6 Revision 90Page 6 of 6Revision 90 PROCUREMENT DOCUMENT CONTROLCHPE4 CHAPTER41. SCOPEThis Chapter identifies the requirements for preparation, review, approval,
- release, and retention of procurement documents.
- 2. REQUIREMENTS 2.1. GeneralThe Company establishes measures for the preparation, review, and approval ofprocurement documents for those items and activities within the scope of theQATR. Procurement documents at all tiers include or reference the appropriate regulatory, technical, and quality requirements necessary to assure adequatequality.
These requirements include reference to 1OCFR21 when applicable.
2.2. Content of Procurement Documents Procurement documents at all tiers include the following items as deemednecessary by the Company.2.2.1. Scope of WorkProcurement documents describe the scope of the items or services to befurnished by a supplier.
For those items that are important to plant safety,applicable requirements should be specified in the procurement document.
2.2.2. Technical Requirements The Company establishes measures in controlled procedures to; specifytechnical requirements by reference to the appropriate specific
- drawings, specifications, codes, standards, regulations, procedures, or instructions, including revisions thereto that describe the items or services to be furnished.
The procurement documents identify test, inspection and acceptance requirements as appropriate.
These documents identify as appropriate specialinstructions and requirements for such activities as design, material andcomponent identification, fabrication, special process controls,
- cleaning, erecting, packaging,
- handling, shipping, and extended storage.2.2.3. Quality Assurance Program Requirements Measures are established, in controlled procedures, to ensure the appropriate technical and quality requirements are established, by qualified personnel, forthe material, equipment, and services purchased from vendors, suppliers, orcontractors.
Page 1 of 3 Revision 90Page I of 3Revision 90 PROCUREMENT DOCUMENT CONTROLCHAPTER 4Any changes to these requirements require prior approval by the Company.Each vendor, supplier, or contractor has an acceptable quality assurance
- program, which is consistent with applicable regulatory requirements for the itemor service.The Nuclear Oversight Vendor Audit Group (NOVA) maintains a controlled list ofevaluated suppliers that are audited on a triennial basis. The evaluated list ofsuch vendors, suppliers, and contractors is described in controlling procedures for the appropriate safety classification except for procurement from otherlicensees that has a NRC approved quality program.Procurement documents require the vendors to incorporate quality assurance program requirements in sub-tier procurement documents and allow right ofaccess to the vendors, sub-tier
- vendors, and contractors facilities and recordsfor inspection or audit by the Company or designated representative.
2.2.4. Non-conformances
,The Company procurement documents specify the requirements for reporting and approving the disposition of supplier non-conformances.
"Use as is" or"Repair" requires approval of the supplier disposition by the appropriate Company representative.
2.2.5. Documentation Requirements The procurement documents shall identify, at all tiers, the documentation required to be submitted for information, review, and approval including the timerequirements for submittal.
The Company procurement documents require thesupplier to maintain specific quality assurance documents including retention times and disposition requirements.
2.2.6. Spare and Replacement PartsThe procurement documents require the identification of appropriate spare andreplacement parts or assemblies and the appropriate delineation of the technical and quality assurance related data required for ordering these parts orassemblies.
These spare parts and replacement items are at least equivalent tothe original design requirements or those specified by a properly reviewed andapproved revision.
2.3. Procurement Document ReviewMeasures are established in controlled procedures to ensure the appropriate technical and quality requirements are established for the material, equipment, and services purchased from vendors, suppliers, or contractors prior to releasefor bid and contract award.Page 2 of 3 Revision 90Page 2 of 3Revision 90 PROCUREMENT DOCUMENT CONTROLCHPE4 CHAPTER4These documented
- reviews, including changes to the specification or purchaseorder, ensure the technical and quality requirements are correctly stated,inspectable, and controllable and have adequate acceptance and rejection criteria and are prepared,
- reviewed, and approved in accordance with QAPrequirements.
Review of the exceptions or changes requested by the supplier shall beanalyzed to ensure they do not change or impact the technical or qualityrequirements and are incorporated in to the procurement documents, prior to thesupplier proceeding, using the same review and approval process asappropriate except for commercial terms and editorial changes.Personnel who have access to pertinent information and who have an adequateunderstanding of the requirements and intent of the procurement documents shall perform reviews required by this chapter.2.4. Procurement RecordsRecords as required by the procurement documents or the QATR are retained inthe Company's department files, vendor files, or both locations.
Page 3 of 3 Revision 90Page 3 of 3Revision 90 INSTRUCTIONS, PROCEDURES, AND CHAPTER 5DRAWINGS1. SCOPEActivities governed by the Company's QAP shall be performed as directed bydocumented instructions, procedures, and drawings appropriate for the activity.
The requirements for the use of these procedures shall also be prescribed inwriting.
These instructions, procedures, and drawings shall includeresponsibilities and acceptance criteria as applicable or appropriate for theactivity.
Those participating in any activity shall be aware of and use the proper andcurrent revision of instructions, procedures,
- drawings, and engineering requirements for performing the activity.
Procedures may include reference tovendor equipment
- manuals, design drawings and specifications, prerequisites, special precautions, and the delineation of work to be performed.
Equipment Manuals and manufacturers instructions shall be readily available for use.2. REQUIREMENTS 2.1. GeneralOperation, maintenance, or modification of equipment shall be preplanned andperformed in accordance with written procedures that are appropriate to thecircumstances and that conform to applicable codes, standards, specifications, and criteria.
Documents identify and specify the content of records to begenerated in conducting the activity.
The establishment and execution of qualityprocedures shall be used by the station staff or those under their direction, foroperating, maintenance, modifications, in-service inspection, refueling, andstores activities.
Temporary procedures may be issued to provide guidance in unusual situations that are not within the scope of the normal procedures.
Temporary procedures shall be subject to review and approval, and shall include designation of the timeperiod during which they may be used. In the event of an emergency notcovered by an approved procedure, authorized personnel shall provideappropriate direction to minimize personnel injury and damage to the facility andto protect the health and safety of plant personnel and the general public.2.2. Preparation and ReviewProcedures shall be prepared,
- reviewed, approved, and used as prescribed inwriting, and shall contain step by step instructions in the degree of detailnecessary for qualified individuals to perform the required function or task.Where appropriate, these procedures will include checklists containing thenecessary attributes to be observed or measured.
Page 1 of 4Revision 90 INSTRUCTIONS, PROCEDURES, AND CHAPTER 5DRAWINGSThese documents shall include or reference appropriate quantitative orqualitative acceptance criteria for determining that prescribed activities havebeen satisfactorily accomplished.
The procedures will be independently reviewed and evaluated by other involvedcompany organizations with interface responsibilities and the commentsforwarded to the issuing department.
2.3. Procedures and ProgramsReview and approval of site procedures are performed in accordance withtechnical specification requirements as delineated in the Technical Review orStation Qualified Review (SQR) programs.
2.3.1. Technical Review and Control1. Procedures required by a station's Technical Specifications and otherprocedures which affect nuclear safety, as determined by the managerresponsible for station operation, and changes thereto, other thaneditorial or typographical
- changes, shall be reviewed as follows prior toimplementation, except as noted in item 5 (below).-Each procedure or procedure change shall be independently reviewed by a qualified individual knowledgeable in the areaaffected other than the individual who prepared the procedure orprocedure change. This review shall include a determination ofwhether or not additional cross-disciplinary reviews are necessary.
If deemed necessary, the reviews shall be performed by thequalified review personnel of the appropriate discipline(s).
-Changes to the approved fire protection program may be madewithout prior Plant Operations Review Committee (PORC)approval provided that the changes would not adversely affect theability to achieve and maintain safe shutdown in the event of a fire,and specific features of the approved program may be alteredprovided such changes do not otherwise involve a change to theOperating License or technical specifications, or require anexemption.
-Reviews of procedures or changes to procedures, that describethe means for controlling or operating structure,
- systems, and/orcomponents as described in the UFSAR, will include a review todetermine if NRC review and approval is necessary prior to theimplementation of the procedure activity.
This review is based onthe review of a written 1OCFR50.59/72.48 review and evaluation prepared by qualified individual(s),
or documentation that a10CFR50.59/72.48 evaluation is not required.
The PORC shallreview and recommend approval of items requiring NRC reviewand approval prior to station approval for implementation.
NRCPage 2 of 4Revision 90 INSTRUCTIONS, PROCEDURES, AND CHAPTER 5DRAWINGSapproval shall also be obtained prior to station approval forimplementation.
-Department head approval authority shall be as specified in stationprocedures.
-Written records of reviews performed in accordance with thisspecification shall be prepared and maintained.
-Editorial and typographical changes shall be made in accordance with station procedures.
- 2. Technical reviewers shall advise their supervisors and/or PORO on allmatters related to nuclear safety that are identified during reviews.
Thereviewer shall be other than the originator.
The reviewer shall determine if additional cross-disciplinary reviews are required to ensure allapplicable technical disciplines are included.
This review shall ensuretechnical
- accuracy, compliance with regulatory requirements, and shallverify the originator's determination of whether items reviewed constitutes a change to the Technical Specifications, Operating
- License, or if NRCreview and approval is required prior to implementation.
- 3. Technical reviewers shall be qualified to perform technical reviews basedon the individual's
- training, experience, and knowledge level. Technical reviewers, assigned the responsibility for reviewing 10OCFR50.59/72.48 reviews and evaluations, shall receive training in this process.
Technical reviewers shall be qualified to perform this function and meet theexperience requirements per applicable standards.
Personnel shall haveexpertise in one or more of the following disciplines as appropriate, for thesubject or subjects being reviewed:
-chemistry
-instrumentation and controls-mechanical and electrical systems-nuclear power plant technology
-radiological controls-reactor engineering
-reactor operations
- 4. Technical reviews shall be documented and records maintained.
- 5. Temporary ChangesTemporary changes to procedures required by 2.3.1.1 (above) may bemade provided:
-the intent of the original procedure is not altered.-the change is approved by two members of the plant management Staff knowledgeable in the areas affected by the procedures, at leastPage 3 of 4Revision 90 INSTRUCTIONS, PROCEDURES, AND CHAPTER 5DRAWINGSone of whom holds a Senior Reactor Operator's License on the unitaffected.
-the change is documented,
- reviewed, and approved in accordance with 2.3.1 (above) within 14 days of implementation.
2.3.2. On-site Qualified Technical Review (Dresden Unit 1)A Qualified Technical Reviewer shall conduct thorough reviews of thedocuments specified below. Persons performing these reviews shall beknowledgeable in the subject area being reviewed.
Qualified technical reviewsmust be completed prior to implementation of proposed activities.
- 1. Qualified Technical Reviewers shall be individuals without directresponsibility for the document under review; these reviewers may befrom the same functionally cognizant organization as the individual orgroup performing the original work.2. Qualified Technical Reviewers shall have at least 5 years of professional experience and either a Bachelor's degree in Engineering or the PhysicalSciences or shall have equivalent qualifications evaluated on a case bycase basis and approved by the manager responsible fordecommissioning activities.
The appointment of Qualified Technical Reviewers shall be documented.
- 3. A Qualified Technical Reviewer shall independently review the following subjects:
-Proposed changes to the license, technical specifications, orbases.-Proposed changes to the programs required by the Technical Specifications to verify that such changes do not involve a changeto the Technical Specifications and will not require NRC reviewand approval as defined in 100FR50.59/72.48.
-10OCFR50.59 evaluations for changes in the facility as described inthe De-fueled Safety Analysis Report (DSAR), changes inprocedures as described in the DSAR, and tests or experiments not described in the DSAR to verify that such actions do notinvolve a change to the Technical Specifications or will not requireNRC review and approval as defined in 10OCFR50.59.
Page 4 of 4 Revision 90Page 4 of 4Revision 90 DOCUMENT CONTROLCHAPTER 61. SCOPEMeasures shall be established to control and coordinate the classification, review, approval,
- issuance, revision, and change of documents that prescribe methods or provide the technical and/or quality requirements for activities anditems within the scope of this program.
These measures shall ensure that suchdocuments are reviewed for adequacy, approved for release and use, anddistributed to the location where the activity is performed
- 2. REQUIREMENTS 2.1. GeneralThe Company document control process ensures that procedures are reviewedand approved before initial use. The Company has in place programmatic
- controls, which ensure that procedures are technically and administratively correct before use. These programmatic controls ensure that procedures arereviewed and revised as needed, when pertinent source material is changed,when the plant design is changed, or when deficiencies are identified andcorrected.
Provisions shall be established to ensure that infrequently usedprocedures are reviewed prior to use, unless they have been reviewed within theprevious two years. The periodic biennial review requirements are satisfied byimplementation of several processes and programs.
Except as noted inappendix C, due to their importance to safety, biennial review of abnormalprocedures (such as emergency operating procedures) shall continue.
Theseprocesses and programs provide the programmatic controls that ensure therequired reviews are accomplished and include the following:
-Commitment Management and Tracking Process.-Integrated Reporting/Corrective Action Program.-Operational Experience Feedback Program.-Plant Modification Program.-Procedure Feedback Process.-Technical Specification and Updated Final Safety Analysis ReportRevision Programs.
-Vendor Information Program.2.2. ReviewsThe company has also established provisions to ensure that the following reviews are conducted:
-inspection, identification of inspection personnel, and documentation ofinspection results.-maintenance, modification, and inspection procedures are reviewed byqualified personnel, knowledgeable in quality assurance disciplines.
Page 1 of 3Revision 90 DOCUMENT CONTROLCHAPTER 6-necessary inspection requirements,
- methods, and acceptance criteriahave been identified.
2.3. Controlled Documents Written document control procedures shall be established to provide for thecontrol of approved documents.
Documents that are controlled
- include, but arenot limited to, the following items:-administrative procedures
-as-built and design drawings.
-assessments
-calibration procedures.
-computer codes and software.
-corrective action reports.-design specifications.
-emergency operating procedures.
-engineering calculations.
-inspection and test reports.-maintenance procedures
-nonconformance reports.-NOS procedures.
-operating procedures.
-purchase orders and related documents.
-safety analysis reports.-supplier audit and surveillance procedures.
-technical specifications (station and Independent Spent Fuel StorageInstallation)
-temporary and emergency procedure changes.-topical reports.-work instructions and procedures.
2.4. Control MeasuresThe Company document control process includes the following documentcontrol measures:
-coordinating and controlling interface documents.
-distributing documents approved for issuance in accordance with updatedand current distribution lists.-establishing document control procedures to assure that properdocuments are accessible and are being used.-establishing lists of documents controlled by organizations involved withactivities affecting quality.Page 2 of 3Revision 90 DOCUMENT CONTROLCHAPTER 6-establishing procedural requirements for the protection of safeguards information
-identifying and assuring that proper documents are used in performing activities affecting quality.-identifying qualified individuals or organizations responsible for preparing, reviewing, approving and issuing documents, including revisions.
-recalling or identifying obsolete documents.
2.5. Document ChangesThe Company document control process ensures changes, to documents arereviewed and approved by the same organizations that performed the originalreview and approval, unless delegated to another responsible organization.
Thereviewing organization has access to pertinent background data or information upon which to base their approval.
To avoid a possible omission of a requiredreview, the Company document control process includes provisions to controlminor changes.Page 3 of 3 Revision 90Page 3 of 3Revision 90 CONTROL OF PURCHASED
- MATERIAL, CHAPTER 7EQUIPMENT, AND SERVICES1. SCOPEThe Company establishes measures to assure the quality of purchased
- material, equipment and services conform to procurement document requirements foritems contained within the QATR.2. REQUIREMENTS 2.1. Supplier Selection 2.1.1. GeneralThe Company establishes measures to assure that purchased
- material, equipment, and services conform to the procurement documents for safetyrelated and ASME code specifications as appropriate.
This assurance isaccomplished by controlling both the selection of procurement sources andacceptance of the product at the source and/or upon receipt at the appropriate location.
The company procedures, which address the procurement process and receiptand storage of material and equipment, clearly define the responsibilities andinterfaces between the line requisitioning organization, engineering, supply andquality assurance.
2.1.2. MethodsThe Company establishes and implements measures for the evaluation andselection of procurement sources.
These measures must be completed prior tothe award of contract.
These measures include one or more of the following:
-evaluation of the supplier's history of providing an identical or similarproduct that performs satisfactorily in actual use.-supplier's current quality records supported by documented qualitative and quantitative information that can be objectively evaluated.
-supplier's technical and quality capability of meeting the applicable qualityrequirements of 100FR50 Appendix B as determined by a directevaluation of its facilities and personnel and the implementation of itsquality assurance program.-review and evaluation of audits, surveys, and inspections conducted byother utilities, or American Society of Mechanical Engineers (ASME).-if there is insufficient evidence of implementation of a QA program, theinitial evaluation is of the existence of a QA program addressing thescope of the services to be provided.
The initial audit is performed afterthe supplier has completed sufficient work to demonstrate that itsorganization is implementing a QA program.Page 1 of 8Revision 90 CONTROL OF PURCHASED
- MATERIAL, CHAPTER 7EQUIPMENT, AND SERVICESThe Company documents and files the results of these measures and maintains an evaluated list of suppliers.
2.2. Bid Evaluations The Company reviews and evaluates bids and awards contracts using writtenprocedures and documents the results.
The Company designates individuals ororganizations to review bids to assure that they conform to the procurement document requirements and the supplier has the appropriate technical ability,Quality Program, production capability, personnel, and acceptable pastperformance to supply the product or service.
The Company obtainscommitments to resolve unacceptable quality conditions identified as part of thebid evaluation before award of the contract and ensure exceptions andalternatives do not impact the technical or quality requirements.
2.3. Supplier In-Process Control2.3.1. GeneralThe Company establishes measures to interface with and to verify supplierperformance.
These measures include the following items:-establishing an understanding between the Company and the supplier ofthe provisions and specifications contained in the procurement documents.
-establishing a method of document information exchange between theCompany and the supplier.
-establishing the extent of source surveillance and inspection activities.
-identifying and processing necessary change information.
-requiring the supplier to identify planning techniques, tests, inspections, and processes to be used in fulfilling procurement documentrequirements.
-reviewing supplier documents that are generated or processed duringactivities fulfilling procurement requirements.
2.3.2. In-Process Control and Verification PlanningThe Company and the supplier, establish as appropriate, notification points,including hold and witness points and incorporate into the appropriate documents based upon the complexity and scope of the item or service.
Whenrequired by the procurement document or specification, surveillances andevaluations at the supplier's facility are conducted to verify continued compliance with the quality assurance requirements of the procurement documents.
Qualified individuals or its agents accomplish source inspections at thesupplier's facility to verify that the procurement item or service is being suppliedin accordance with the requirements of the procurement documents.
Page 2 of 8Revision 90 CONTROL OF PURCHASED
- MATERIAL, CHAPTER 7EQUIPMENT, AND SERVICESSuch inspections, examinations or tests are accomplished in accordance withwritten procedures, plans, and/or checklists containing or referencing appropriate acceptance criteria.
Upon acceptance by source verification, theCompany furnishes documented evidence of acceptance to the receiving destination of the item, to the purchaser, and to the supplier.
2.3.3. Programmatic Verification The Company or its agents verify the effectiveness of the supplier's qualityprogram by survey, audit or surveillance.
Verification is performed at intervals consistent with the importance to safety, complexity and quality of the product orservices furnished.
Activities are witnessed or observed and the resultsdocumented when source verification is performed.
The Company conducts audits per the requirements established in Chapter 18or reviews audits performed by other license holders as defined in procedures.
The results of these audits are used to support the maintenance of the list ofevaluated suppliers.
Verification activities are conducted as early as practicable so that subsequent activities do not prevent disclosure of deficiencies.
TheCompany's verification activities do not relieve the supplier of its responsibility for quality verification.
2.3.4. Supplier and Verification of Supplier Performance RecordsThe Company establishes methods to control, handle and approve supplierdocuments.
Suppliers submit their documents per procurement requirements.
Acceptance criteria is used for the acquisition, processing, and record evaluation of technical inspection and test data.The Company records activities to verify supplier conformance with therequirements of procurement documents.
Source surveillances, procurement plans, inspections, audits, surveys, receiving inspections, non-conformance dispositions, waivers and corrective actions concerning supplier activities aredocumented.
This documentation is used to determine the supplier's qualityassurance program effectiveness.
2.3.5. Control of Procurement ChangesThe Company documents changes to procurement documents involving technical or quality assurance matters.
These changes are subjected to thesame review and approval process as the original procurement documentexcept for commercial terms and conditions and editorial changes.Page 3 of 8 Revision 90Page 3 of 8Revision 90 CONTROL OF PURCHASED
- MATERIAL, CHAPTER 7EQUIPMENT, AND SERVICES2.4. Acceptance of Purchased Items and Services2.4.1. GeneralUpon receipt the applicable materials, parts, and components are controlled.
Qualified inspection personnel are responsible for inspecting, releasing, andmaintaining the inspection status of purchased material and equipment.
Afterreceipt inspection, the purchased material is placed in a controlled storage areaor issued for installation or further work.2.4.2. Acceptance by Receiving Inspection The Company uses approved procedures to accept purchased items andservices.
Acceptance of an item or service from a supplier includes certificate ofconformance, source verification, receiving inspection or post installation testingat the plant location or a combination thereof.
Items are inspected during receiptusing approved procedures and checklists.
The Company does receiving inspections using procedures and inspection instructions to verify conformance to the specified requirements, using objective evidence to check such features as: complete documentation and visualinspection of: proper configuration; identification; dimensional, physical andother characteristics; freedom from shipping damage; and cleanliness.
Items,which can not meet the purchase order requirements, will be segregated andcontrolled as defined in the applicable procedures.
The Company coordinates the review of supplier documentation with thereceiving inspection when procurement documents require such documentation to be furnished prior to the receiving inspection.
Source verification and auditactivities are factored into the receipt inspection activities as appropriate.
2.4.3. Acceptance by Source Verification The Company considers acceptance by source verification when the item orservice is:-vital to plant safety; or-difficult to verify quality characteristics after delivery; or-complex in design, manufacture, and test.Source verification shall be implemented in accordance with plans to performinspections, examinations, or tests at pre-determined points. Upon acceptance by source verification, the Company furnishes documented evidence ofacceptance to the receiving destination of the item, to the purchaser, and to thesupplier.
Page 4 of 8 Revision 90Page 4 of 8Revision 90 CONTROL OF PURCHASED
- MATERIAL, CHAPTER 7EQUIPMENT, AND SERVICES2.4.4. Acceptance by Certificate of Conformance The supplier's certificate of conformance attests the product or service providedis in accordance with the procurement documents is reviewed during sourceand/or receipt inspections to verify compliance.
This document provides thepurchase order number; codes, standards or other specifications required to bemet in the purchase order. Requirements which cannot be met must beincluded with an explanation why and a means to resolve the non-conformances.
A person who is responsible for quality assurance functionattests to this certificate The validity of a supplier's certificate of conformance is ascertained through anyof the following methods source inspection, independent inspection agency,receipt inspections, surveillance, testing of hardware, quality assurance audits orsurveillances at intervals commensurate with the suppliers past performance.
Inspection and test activities verify that the hardware performs in accordance with applicable technical requirements and serve to demonstrate that thehardware meets the requirements stated in a certificate of conformance.
The results of the source and/or receipt inspections, the acceptability of supplierfurnished documentation, and the resulting determination of conformance ornonconformance is documented.
2.4.5. Acceptance by Post Installation TestingWhen post-installation testing is used, the Company establishes post-installation test requirements, giving due consideration to supplier recommendations.
Acceptance by this method is satisfactory when performed following theaccomplishment of at least one preceding method and when:-it is difficult to verify the quality characteristics of the item without it beinginstalled and in use; or-the item requires an integrated system checkout or test with other itemsto verify its quality characteristics; or-the item cannot prove its ability to perform its intended function exceptwhen in use.2.4.6. Acceptance of Services OnlyIn cases involving procurement of services only, the Company accepts theservice by any of the following methods:-technical verification of data produced.
-surveillance, audit, survey, or assessment of the activity.
-review of objective evidence for conformance to the procurement document requirements such as certifications, stress reports, etc.Page 5 of 8Revision 90 CONTROL OF PURCHASED
- MATERIAL, CHAPTER 7EQUIPMENT, AND SERVICESIn lieu of the above the Company performs a receiving inspection for itemsarriving back onsite that were sent offsite for repair, testing, or rework.2.4.7. Commercial Grade ItemsWhere the safety related design utilizes commercial grade items, the following requirements are a permissible alternative for acceptance, to other requirements of this Chapter:1. An approved design document identifies the commercial grade item. (Analternate commercial grade item may be applied, provided the cognizant design organization provided verification that the alternate commercial grade item will perform the intended function and will meet designrequirements applicable to both the replaced item and its application.)
- 2. The Company performs source evaluation and selection, wheredetermined necessary, based on complexity and importance to safety.-commercial grade dedication plans for use in a safety relatedapplications state responsibility for 10CFR21 requirements.
-the Company identifies commercial grade items in the purchaseorder by the supplier's published product description.
- 3. One or a combination of the following methods shall be utilized to providereasonable assurance that the item meets the acceptance criteria for thecharacteristics identified to be verified for acceptance:
-acceptable supplier/item performance records.-commercial grade survey of the supplier.
-source verification.
-special test(s) or inspection(s) or both.4. After receipt of a commercial grade item, the Company determines thefollowing:
-damage was not sustained during shipment.
-documentation, as applicable to the item, was received and isacceptable.
-inspection and/or testing are accomplished, as required by thepurchaser, to assure conformance with the manufacturer's published requirements.
-the item received was the item ordered.2.4.8 Acceptance of Calibration ServicesFor suppliers of commercial-grade calibration services with accreditation by anationally recognized accrediting body, a documented review of the supplier's accreditation by the purchaser may be used in lieu of inspections or tests following Page 6 of 8Revision 90 CONTROL OF PURCHASED
- MATERIAL, CHAPTER 7EQUIPMENT, AND SERVICESdelivery or in-process surveillances during performance of the service.
This reviewshall include, at a minimum, all of the following:
- 1. The accreditation is to ANSI/ISO/lEC 17025.2. The calibration laboratory holds a domestic accreditation by one of the following accrediting bodies, which are recognized by the International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement (MRA):-National Voluntary Laboratory Accreditation Program (NVLAP),
administered by NIST-American Association for Laboratory Accreditation (A2LA)-ACLASS Accreditation Services (ACLASS)-International Accreditation Service (lAS)-Laboratory Accreditation Bureau (L-A-B)3. The published scope of accreditation for the calibration laboratory covers theneeded measurement parameters, ranges, and uncertainties.
- 4. The purchase documents impose additional technical and administrative requirements, as necessary, to satisfy the Exelon QATR program and technical requirements.
The technical requirements will also include the following requirements:
-The calibration certificate/report shall include identification of the laboratory equipment/standards used.-The calibration certificate/report shall include as-found and as-left data.5. The purchase documents require reporting as-found calibration data whencalibrated items are found to be out-of-tolerance.
2.5. Presence of Documentary EvidenceDocumented evidence that material or equipment conforms to procurement requirements is present at the site before use or installation.
This documentary evidence is traceable to the item and shall be retained at the nuclear power plantsite and shall be sufficient to identify the specific requirements such as codes,standards, or specifications met by the purchased material and equipment.
2.6. Spare or Replacement ItemsProcedures control the procurement, storage and issuance of materials andcomponents including spare and replacement parts. Procurement documents Page 7 of 8Revision 90 CONTROL OF PURCHASED
- MATERIAL, CHAPTER 7EQUIPMENT, AND SERVICESfor these items identify the appropriate technical and quality relatedrequirements.
The Company purchases spare parts and replacement items,equipment and components to at least the original design requirements or thosespecified by a properly reviewed and approved revision.
Where the QA requirements of the original item cannot be determined, qualified individuals conduct an engineering evaluation to establish appropriate requirements and controls.
This evaluation insures that interfaces, interchangeability, safety, fit and function are not adversely affected or arecontrary to applicable regulatory or ASME Code requirements.
The evaluators document their results.Where the company procured the original item with no specifically identified quality assurance program requirements or from an Original Equipment Manufacturer/Supplier (QEM/QES) who no longer is on a list of evaluated suppliers, identical (like-for-like) items may be similarly procured from theOEM/QES through the use of procurement plans.In such cases, the Company conducts a joint technical engineering and qualityassurance documented evaluation to established requirements and controls toassure at least equivalent product performance.
The evaluation shall assurethat interfaces, interchangeability, safety, fit and function are not adversely affected or are not contrary to applicable regulatory or ASME Coderequirements.
2.6.1. Procurement from Other Utilities Purchases of safety related items can be made from other utilities who have hadan NRC approved QA Program in effect at the time of their procurement andreceipt and such utility has maintained a quality system program for storage,handling, and maintenance with documented traceability to the manufacturer ofthe items.Certificates-of-Conformance to the above requirements and associated requireddocumentation are provided.
2.6.2. Maintenance or Modification The Company performs maintenance or modifications that may affect thefunction of safety related structures,
- systems, or components in a manner toassure quality at least equivalent to that specified in original design bases andrequirements, materials specifications, and inspection requirements.
Page 8 of 8 Revision 90Page 8 of 8Revision 90 IDENTIFICATION AND CONTROL OF CHAPTER 8MATERIALS, PARTS, ANDCOMPONENTS
- 1. SCOPEControls are established to assure that only correct and accepted items are usedor installed.
Identification shall be maintained on the items or in documents traceable to the items, or in a manner, which assures that identification isestablished and maintained.
- 2. REQUIREMENTS 2.1. GeneralThe Company establishes measures for the identification and control ofmaterials, parts and components, including partially fabricated assemblies, andassures that only correct and accepted items are used or Identification is maintained on the items or in documents traceable to the items. Physicalidentification shall be used to the maximum extent possible.
Provisions are in place to maintain
- markings, which could be damaged duringshipping or handling or deterioration due to environmental exposure.
Provisions are also established to control nonconforming items and maintain parts,material, and equipment in storage traceable to quality assurance documents.
2.2. Traceability
Items within the scope of the QAP shall be identified, so that they can be tracedto the appropriate documentation, which provides objective evidence that thetechnical and quality requirements are met.Responsible organizations document and maintain identification and traceability of items from initial receipt, throughout fabrication, installation, and use of theitems such as: subassemblies, components, equipment
- numbers, part numbers,serial number, heat treatment number, batch or lot numbers.When installed material or equipment is removed for maintenance, repair, ormodification, control measures are implemented to ensure proper identification and traceability is maintained.
Before use or installation of an item, the installer verifies that identification has been maintained.
2.3. Identification MethodsIdentification is on the item where practicable.
Identification is clear,unambiguous and indelible.
Identification does not affect the fit, function, quality,and service life of the item. If the item cannot be practicably marked, theCompany uses records traceable to the item for identification.
Page 1 of 2Revision 90 IDENTIFICATION AND CONTROL OF CHAPTER 8MATERIALS, PARTS, ANDCOMPONENTS If physical identification is either impractical or insufficient for proper control, theCompany controls an item by physical separation, procedural control or otherappropriate means.2.4. Transfer of MarkingsPrior to cutting or dividing
- material, each new piece shall be marked with thesame traceability markings of the original piece to ensure that the traceability ofthe material is maintained.
These markings shall not be obliterated or hidden bysurface treatment or coatings unless other means of identification aresubstituted.
The Company independently verifies proper identification of eachpiece.2.5 Limited Life ItemsThe Company identifies and controls items having limited life to preclude use ofitems whose shelf life or operating life has expired.2.6 Stored ItemsThe Company uses procedures to assure proper control of identification foritems in storage.Page 2 of 2 Revision 90Page 2 of 2Revision 90 CONTROL OF SPECIAL PROCESSES CHAPTER 91. SCOPEProcesses affecting quality of items or services shall be controlled.
Specialprocesses that control or verify quality, shall be performed by qualified personnel, using qualified procedures, in accordance with specified requirements and are properly documented and evaluated.
These requirements are defined in codes, standards, specifications, or special instructions.
Thequality of such processes is assured through reliance on operator skill andin-process control.
Examples of special processes
- include, but are not limited towelding, heat treating, chemical
- cleaning, and non-destructive examination (NDE).2. REQUIREMENTS 2.1. GeneralThe Company organization directing work during repair, replacement, modification, or in-service inspection (ISI) activities is responsible for controlling special processes.
Special process controls are assured through independent assessment and inspection activities.
2.2. Process ControlInstructions, procedures,
- drawings, checklists, or other appropriate meanscontrol processes.
Process controls specify the prerequisite steps, processing
- details, conditions to be maintained during the process, equipment requirements, inspection and test requirements, acceptance
- criteria, and recordrequirements.
Controlling includes:
-maintenance and retention of records.-personnel qualification.
-procedure development and qualification.
-procedure implementation.
-qualification of equipment.
2.3. Special Processes Measures shall be established and documented to assure that specialprocesses are accomplished under controlled conditions in accordance withapplicable codes, standards, applications
- criteria, regulatory requirements andCommitments, and other special requirements including the use of qualified personnel and procedures.
Special processes are controlled by instructions, procedures,
- drawings, checklists, travelers, or other appropriate means.Page 1 of 3 Revision 90Page 1 of 3Revision 90 CONTROL OF SPECIAL PROCESSES CHAPTER 9Special process controls specify the preparatory steps, processing details,conditions to be maintained during the process, equipment requirements, inspection and test requirements, acceptance
- criteria, and record requirements.
Special process procedures are written and qualified in accordance withapplicable requirements.
Special process procedures are reviewed andapproved as follows:-Coating and ASME Code concrete placement procedures are reviewedand approved by the appropriate Company organizations.
-Company, contractor and subcontractor heat treating,
- welding, andbrazing procedures are reviewed in accordance with the companywelding program as approved by Engineering.
-Company NDE procedures are reviewed and approved by the appropriate Company Level Ill.-Contractor, subcontractor,Section III, XI, and other ISI-related NDEprocedures that will be utilized on site are reviewed and approved by aCompany NDE Level Ill.-The responsible Company engineering organization reviews contractor and subcontractor non-welding special process procedures.
When permitted by applicable requirements, the Company may directcontractors or subcontractors to use Company special process procedures.
When there is a specific reason to question whether special process procedure requirements are being met, the Company, or the Authorized Inspection Agency(AlA) may require re-evaluation of the procedure before work may proceed.For special processes not covered by the existing codes or standards, or whenthe quality requirements of an item exceed the requirements of established codes or standards, the necessary qualifications of personnel, procedures andequipment shall be defined in the procedure.
2.4. Personnel Qualification Company and contractor personnel performing special processes are trained,tested, qualified, or certified in accordance with a company procedure that meetsapplicable requirements.
For NDE personnel, the Company and contractor personnel performing NDE aretrained, tested, qualified, or certified in accordance with a company procedure that meets applicable requirements of 10CFR50.55a and ASME Section Xl withspecific exceptions and clarifications.
When permitted by applicable requirements, the Company may qualify and control contractor personnel certifications.
Page 2 of 3 Revision 90Page 2 of 3Revision 90 CONTROL OF SPECIAL PROCESSES CHAPTER 9The Company assures compliance with the ASME Code through an agreement with an AlA who verifies compliance in accordance with their procedure thatdescribes the ANI duties and responsibilities.
When there is a specific reason toquestion the ability of an individual performing special processes, the Company,or the AlA may require re-evaluation before that individual will be permitted toresume work. Individuals failing any retest will be removed from applicable operations pending re-qualification.
The Company designates a principal(s)
NDE Level Ill and they are responsible for personnel qualification and procedure development to ASME Coderequirements for nondestructive examination.
These NDE personnel are qualified and certified in accordance with the Company procedure and maydesignate other NDE Level Ill's for certification of personnel.
NDE Level Ill'shave authority for the interpretation of any NDE indication that has beenrecorded by a company or supplemental vendor Level IlIll1 Examiner.
Training and certification of NDE personnel associated with nondestructive examination are carried out in accordance with the requirements of10OCFR50.55a and ASME Section XI with specific exceptions and clarifications are met. The company develops and maintains a procedure detailing theprogram that will be used for qualification and certification and has ultimateresponsibility for determination of the qualification process.
Qualified personnel administer all ASME Code examination activities.
2.5. Special Process RecordsSpecial process records provide evidence that special processes wereperformed in accordance with approved procedures by qualified personnel.
These records are retained by the Company or by the contractor orsubcontractor as required by procurement documents.
Records are maintained for currently qualified personnel, processes, and equipment for each specialprocess.Page 3 of 3 Revision 90Page 3 of 3Revision 90 INSPECTION CHAPTER 101. SCOPEThe Company plans and executes an inspection program to verify that activities affecting the quality of safety-related structures,
- systems, and components conform to documented requirements.
For modification and non-routine maintenance activities, inspections are conducted in a manner similar (i.e.frequency, type and personnel performing such inspections) to those associated with construction phase activities.
The independent inspections described in thisChapter are not intended to dilute or replace the clear responsibility of the firstline supervisors for the quality of work performed under their supervision orpersonnel performing the activity.
- 2. REQUIREMENTS 2.1. GeneralThe Company establishes controls for coordination and execution of inspection plans. Company quality verification organizations or other qualified organizations are responsible for implementation of established inspection plans. If an inspection plan includes inspections by personnel other than thosein a quality verification organization, the inspection requirements, personnel qualification
- criteria, and inspector independence will be accepted by theresponsible quality organization prior to implementation.
2.2. Inspection PlansThe Company prepares documented inspection plans. These inspection plansare applied when the activity is started.
The inspection plans may be separatedocuments or an integral part of approved instructions, procedures or drawings.
Related codes, standards, specifications and design documents are used todevelop the inspection plans. Procedures used for documenting inspection plans are selectively
- reviewed, as appropriate, by NOS to assure that necessary verification points and inspection criteria are included.
The plans identify:
-acceptance criteria.
-activities to be inspected.
-inspection characteristics.
-inspection techniques/equipment (including accuracy requirements).
-provisions for inspection and test status.-provisions for the recording of inspection results.-qualification requirements.
-responsible organizations.
Page 1 of 3 Revision 90Page 1 of 3Revision 90 INSPECTION CHAPTER 102.3. Inspection Personnel and Qualification A qualification program is established and documented to conform to applicable codes, standards, or licensing requirements.
Qualifications and certifications arekept current.Qualified personnel perform inspections.
Inspectors with valid certifications perform inspections for acceptance.
Inspectors are independent of those whoperform or directly supervise the activity being inspected.
On-the-Job traininginspections shall be performed under the direct supervision of qualified personnel.
Second line supervisory personnel or other qualified personnel not assigned firstline supervisory responsibility for the conduct of the work may conductinspection of operating activities.
Operating activities are defined as workfunctions associated with normal operations of the plant, routine maintenance, and certain technical services routinely assigned to the onsite operating organization.
2.4. Inspection ProcessInspections are performed using approved instructions, procedures, processsheets, travelers, or checklists and applicable drawings.
-Inspections are performed for each work or operating activity wherenecessary to verify quality.
Where inspection sampling is used to verifythe acceptability of a group of items, the sampling procedure shall bebased on recognized standard practices.
-Process monitoring may be used when inspection of processed materialor products is impossible or impractical.
When necessary, to ensurequality throughout the duration of the process, both inspection andprocess monitoring will be systematically used to verify conformance torequirements.
-When inspections must be performed before work can continue, holdpoints are established in appropriate documents.
Consent to waive holdpoints are recorded prior to continuation of work. When inspection isdesired, but not mandatory before work can continue, witness points areestablished.
Completion of hold and witness points is documented.
-When acceptance criteria are not met, corrected areas are re-inspected.
Such inspections are documented in the Corrective Action Program.-Changes to, or rework of, an item after inspection requires re-inspection of the affected areas.-A final evaluation is performed.
Inspection results are reviewed toconfirm that required inspections and quality records have beencompleted, identified non-conformances have been resolved and the itemconforms to specified requirements.
Engineering, Maintenance, Operations or Quality Verification approves final acceptance of the item.Page 2 of 3Revision 90 INSPECTION CHAPTER 10-Inspection records are of sufficient detail to confirm completion and, as aminimum, identify:
-authorized individual approving results.-date of inspection.
-inspector/Data recorder.
-item inspected.
-M&TE used.-reference to action taken in connection with identified non-conformances.
-results or acceptability.
-type of observation.
-When the inspection activity is performed using a procedure notreferenced or included within the work package, the procedure and itsrevision should be recorded.
2.5. In-Service Inspections A program for the required ISI/IST inspection of completed
- systems, structures and components shall be planned and executed by or for the organization.
responsible for the operation of the plant to assure that plant components perform satisfactorily under all operating conditions.
Inspection methods shall be established and executed to applicable codes,standards and regulations, including baseline examinations and subsequent periodic examinations, which continue through the life of the plant in accordance applicable technical specifications.
2.6. Independent Verification Independent verifications are conducted by qualified personnel using approvedprocedures.
Characteristics to be verified and methods to be employed shall bespecified.
Verification results and unacceptable conditions identified shall bedocumented.
Verifications shall be performed by persons other than those whoperformed or directly supervised the work being verified.
Page 3 of 3 Revision 90Page 3 of 3Revision 90 TEST CONTROLCHAPTER 111. SCOPEA documented test program shall be established in accordance with applicable technical specifications, license conditions, and design documents to assure thatall testing required demonstrating that the structures,
- systems, or components within the scope of this QAP will perform satisfactorily in service.2. REQUIREMENTS 2.1. General2.1.1. Testing ProgramThe Company establishes and controls a test program to assure that design andperformance criteria have been satisfied and assures that testing does notadversely affect the safe operation of the plant. The test program includes, asappropriate, procedures to ensure those structures,
- systems, subsystems, andcomponents will perform in service.
Testing is conducted by appropriately trained and qualified personnel.
The extent of testing shall be based on thecomplexity of the modification, replacement, or repair. The test program coversall required tests including:
-operational tests.-production tests.-prototype qualification tests.-tests during design.-tests during fabrication.
-the demonstration of satisfactory performance following plantmaintenance and modifications or procedural changes.-those tests required by plant maintenance or modifications.
2.1.2. Test Procedures The program uses written test procedures which include the requirements andacceptance limits from applicable design documents.
The Company reviewsand approves test procedures and changes to test procedures, including changes that alter test sequence, in a similar manner to the original.
The organization responsible for the design of the item to be tested establishes the test requirements and acceptance criteria.
Test requirements andacceptance criteria are based upon specified requirements contained inapplicable design or other pertinent documents.
Test requirements includespecific characteristics to be tested.Page 1 of 6 Revision 90Page 1 of 6Revision 90 TEST CONTROLCHAPTER 11The Company specifies specific test methods when they must be employed, uses written procedures or checklists, and documents the status of equipment both before and after testing.The Company may use appropriate sections of related documents, such asASTM methods, supplier
- manuals, equipment maintenance instructions, orapproved drawings or travelers with acceptance criteria in lieu of specially prepared written test procedures.
Such documents must include adequateinstructions to assure the required quality of work. Test and inspection procedures contain:-a description of objectives.
-acceptance criteria or limits contained in applicable design or othersource documents, such as vendor's literature, engineering drawings or* plant specifications that will be used to evaluate results.-any special equipment or calibrations required to Conduct the test orinspection.
-responsibilities.
-instructions or checklists used to verify or document that affected plantsystems are arranged in their correct lineup and for restoring the systemto the condition consistent with the normal operating status.-limiting conditions.
-prerequisites for, or checks to be made prior to performing the tests orinspections including any special conditions to be used to simulate normalor abnormal operating conditions.
-data documentation is in compliance with test procedures.
-equipment to be tested is properly released for testing.-inspections and tests are done under suitable environmental conditions.
-proper calibrated inspection and test instruments are used.-retention control of test data documentation is adequate.
-test or inspection requirements contained in applicable designdocuments.
Where tests and inspections are to be witnessed, the procedure identifies holdpoints or witness points in the testing sequence to permit witnessing.
Theprocedure requires appropriate approval for the test to continue beyond thedesignated hold point.1. Prerequisites Prerequisites include the following, as applicable:
Page 2 of 6 Revision 90Page 2 of 6Revision 90 TEST CONTROLCHAPTER 11-appropriate test equipment.
-calibrated instrumentation in accordance with Chapter 12, "Controlof Measuring and Test Equipment."
-condition of test equipment and the item to be tested.-provisions for data acquisition.
-suitable environmental conditions.
-trained personnel.
Procedures ensure that prerequisite steps for equipment testing havebeen or will be performed.
Such steps include:-completion of necessary construction maintenance andmodification activities.
-formal release for testing.-measures to preserve equipment status.-prior testing.-safety precautions.
A detailed prescribed physical inspection of equipment components andfacilities is performed to ensure readiness for operation.
Typicalinspection items include:-calibration of instruments.
-cleanliness.
-lubrication.
-presence of safety devices.-setting of limit switches.
- 2. ScheduleSchedules are provided to assure that all necessary tests are performed and properly evaluated on a timely basis. Testing is scheduled so thatthe safety of the plant is never dependent on the performance of anuntested system.3. Test Results and RecordsAppropriate Company personnel evaluate test results to assureconformance with design and performance requirements.
Inspection andtest results are documented in a test report or data sheet. Each reportidentifies the following:
-acceptability of the test.-actions taken to correct the deviations noted.-any deviation of test results from acceptance criteria(nonconformance).
-as-found condition.
Page 3 of 6Revision 90 TEST CONTROLCHAPTER 11-as-left condition.
-completion date and other significant dates and times.-data sheets completed during the tests.-documents that provide acceptance criteria.
-identification of the conditions encountered which were notanticipated.
-identity of inspector or tester.-item to which it applies.-location where testing was performed or where test samples weretaken.-measuring and test equipment used.-person evaluating test results.-procedures or instructions followed in performing the task.-test procedures.
-test results.2.2. Instrumentation and ControlThe Company tests instrumentation and control channels to assure that they areproperly calibrated.
In addition, specific tests are performed at critical levelssuch as "set points" in a manner simulating the approach toward the set point.These calibrations are made with the devices in their normal positions if thecalibration is dependent upon location or attitude.
Testing determines that a proper response is obtained over the operating rangeof the device. It gives particular attention to verifying independence anddependence, as appropriate, of the elements of the systems.
Calibration documentation includes indicating the date and identity of the person thatperformed the calibration.
The Company prepares and documents installation, inspection and testprocedures and work instructions for instrumentation and electrical equipment.
These documents are kept current and revised as necessary to assure thatinstallation, inspections and tests are performed in accordance with latestinformation.
They include as appropriate:
-approvals.
-data report forms.-frequency of inspection or test.-identification of test equipment and date for required re-calibration whererequired for interpretation of test results.-inspection and test acceptance limits.-inspection and test equipment required.
-inspection and test objectives.
-installation specifications.
Page 4 of 6Revision 90 TEST CONTROLCHAPTER 11-precautions to avoid component or system damage during testing orinspection.
-prerequisites.
-sequence of tests (if applicable).
-sequential actions to be performed.
2.3. Electrical TestsElectrical tests include as appropriate:
-continuity tests, short circuit tests, polarity and rotational tests-control system tests including indicating meters, recorders, transducers, targets and lamps, annunciators and alarms, controls and interlocks
-insulation resistance measurements as specified
-over potential (HIPOT) tests as specified.
Overpotential tests conform tothe applicable codes and standards.
The manufacturer's recommendations are considered.
-voltage breakdown tests on liquid insulation 2.4. Mechanical TestsThe Company performs mechanical tests to ascertain that electric and/orinstrumentation components or systems can withstand system pressure ratings.As a minimum, the Company applies such tests to pressure sensing andtransmitting devices operating in steam, hydraulic, and vacuum systems andtheir hydraulic or pneumatic interconnecting piping or tubing and associated instruments.
- Pressurized equipment that is part of electrical apparatus such as heatexchangers, circulating
- systems, actuating
- systems, and electric andinstrumentation containment penetrations are likewise tested if site assembled or fabricated.
Tests are conducted after the assembly is complete even thoughthe components may have been tested previously.
These tests are performed inaccordance with the applicable codes and standards.
2.5. Physical and Chemical TestsPhysical and chemical tests, in accordance with the applicable codes, include,as appropriate:
-chemical analysis of fluids for oxygen or moisture content and purity.-radiation sensitivity testing to confirm that radiation sensor and controlling devices is properly functioning.
Page 5 of 6 Revision 90Page 5 of 6Revision 90 TEST CONTROLCHAPTER 112.6. Surveillance TestsThe Company's test program covers surveillance testing during the operational phase to provide assurances that failures or substandard performance do notremain undetected and that the required reliability of safety related systems ismaintained.
2.7. Maintenance or Major Procedure ChangeThe Company performs tests following plant modification or significant changesin operating procedures to confirm that the modification or changes produceexpected results.
These tests also demonstrate that the change does notproduce an unsafe operating condition.
Page 6 of 6 Revision 90Page 6 of 6Revision 90 CONTROL OF MEASURING AND TEST CHAPTER 12EQUIPMENT
- 1. SCOPEMeasures and responsibilities are established to assure tools, gauges,instruments, and other Measuring and Testing Equipment (M&TE) used inactivities affecting quality are properly controlled, calibrated, and adjusted atspecified periods to maintain accuracy within specified limits. Measures shallalso be established for the control of permanently installed instrument andcontrol devices.2. REQUIREMENTS 2.1. GeneralPower Labs is responsible for the governance of M&TE and oversight of the sitecalibration process for Exelon plants. This includes the establishment ofcalibration practices, intervals, accuracy requirements, certification/de-certification, and equivalency decisions (except where accuracy is impactive non-conservatively),
as well as the resolution of technical issues regarding M&TE calibration.
Corporate Maintenance is responsible for governance and oversight of siteM&TE Control.
This includes assessment of site compliance to the control ofM&TE as defined in corporate maintenance procedural guidance.
The engineering organizations are responsible for decisions regarding theacceptability of changes to M&TE specifications where accuracies are lessconservative than those currently established.
The engineering organization performs M&TE equivalency calculations for these items to assure associated specifications are consistent with plant design, test procedures, and accuracyrequirements (excluded are analytical chemistry and radiochemistry instruments).
The stations are responsible for the control and maintenance of calibrated M&TEfor the station.
The stations are also responsible for the control of stationanalytical chemistry instrumentation, radiochemistry instrumentation, andstandard solutions.
2.2. ControlA control program specifies how M&TE are stored, handled, and used. As aminimum the following items are addressed:
-administrative controls (including equipment marking and traceability tocalibration records).
-certification requirements.
-damaged or suspect M&TE.Page 1 of 3Revision 90 CONTROL OF MEASURING AND TEST CHAPTER 12EQUIPMENT
-environmental restrictions.
-items not requiring certification.
-M&TE selection.
-out of tolerance resolution.
-personnel qualifications.
-repairs and maintenance.
-status and usage history.2.3. LabelingEquipment shall be suitably marked to indicate calibration status. Where neither*labeling nor coding is practical, procedures shall provide for monitoring ofrecords to ensure control.2.4. AccuracyCalibration of M&TE should be against reference standards that have anaccuracy of at least four times the required accuracy of M&TE. Calibration ofreference standards will be against hierarchical standards more accurate thanthe reference standards calibrated.
When this is not possible, standards musthave an accuracy that assures the M&TE is within the required tolerance, andthat the basis for acceptance is documented and authorized by responsible management.
2.5. Traceability and IntervalM&TE is calibrated against and traceable to certified standards having validrelationships to nationally recognized standards.
Where national standards donot exist, provisions are established to document the basis for calibration.
Calibration intervals are established for all M&TE and the Company programspecifies how this interval is established.
2.6. Certified M&TECertified M&TE is required where measurements with specificaccuracy/tolerance requirements are delineated:
-calibration of other M&TE.-environmental monitoring.
-safety-related and applicable ASME applications.
-technical Specification related applications (including balance of plantsystems).
-verification of design parameters.
Certified M&TE is not required when measurements do not require specificaccuracy or when commercial devices (such as rulers, tape measures, levels)Page 2 of 3Revision 90 CONTROL OF MEASURING AND TEST CHAPTER 12EQUIPMENT provide adequate accuracy.
Electronic stopwatches are not required to becalibrated.
2.7. Corrective ActionsWhen M&TE is found to be out-of-tolerance, an evaluation is made of itsprevious uses to determine corrective action. Suspect equipment is identified and segregated to prevent inadvertent use. Devices that are consistently foundout of calibration are repaired or replaced.
2.8. Vendor ControlVendors supplying calibration services are on the Company's approvedsuppliers list.2.9. Commercial DevicesControl measures are not required for rulers, tape measures, levels, and othersuch commercial
- devices, if such equipment provides adequate accuracy.
2.10. Calibration RecordsM&TE calibration records contain, as a minimum:-as found/as left condition.
-calibration data.-calibration procedure used.-calibration results.-equipment location.
-established accuracy.
-individual performing calibration.
-last calibration date.-next calibration date.-out of tolerance notification.
-repairs (if any).-serial number.-standards used.Page 3 of 3 Revision 90Page 3 of 3Revision 90
- HANDLING, STORAGE, AND SHIPPINGCHAPTER 131. SCOPEThe Company establishes measures to control and specify special protective conditions in accordance with an item's design and procurement requirements, as necessary, to prevent damage or deterioration of materials, components, andsystems during handling, packaging, preservation,
- storage, and shipping.
- 2. REQUIREMENTS 2.1. GeneralThe Company uses written procedures or instructions for cleaning, packaging,
- shipping, storage, preservation, and to specify detailed requirements for accessto storage areas, housekeeping, and removal of items from storage.
Procedures include provisions for inspection, examination, testing and documentation.
These procedures specify special protective conditions necessary to preventdamage, deterioration or loss before and after receipt of materials, equipment, special nuclear material, and radioactive wastes.Procurement documents or the vendor's quality program specifies theestablishment of controls, to assure through the use of shipping procedures toprovide protection during loading and transit and inspections, that items aredelivered in acceptable condition.
2.2. Special Equipment and Environments When required, the Company:-provides special equipment and special protective environments
-specifies special equipment (such as containers, shock absorbers andaccelerometers)
-specifies special protective environments (such as inert gas atmosphere, specific moisture content levels and temperature levels)-verifies the maintenance of special equipment and special protective environments 2.3. Classification of ItemsLevels and methods of storage are classified to minimize the possibility ofdamage, deterioration, or contamination of items. This is based on the important physical characteristics and the importance to safety and reliability of the item.This classification considers the manufacturer's requirements.
The Company packages, ships, receives, stores, and handles items according toestablished manufacturers requirements or the Company' s' prescribed level.When a package or assembly contains items of different levels, the Companyclassifies it to the highest level designated for any of the items contained.
Page 1 of 2Revision 90
- HANDLING, STORAGE, AND SHIPPING CATR1CHAPTER 132.4. Special Handling Tools and Equipment The Company inspects and tests special handling tools and equipment usingprocedures at specified time intervals to verify adequate maintenance.
TheCompany provides special handling procedures and instructions for items thatare susceptible to handling damage. These procedures delineate acceptable techniques, necessary qualifications and precautions for maintenance and use.Operators of special handling and lifting equipment have experience or aretrained in their usage.2.5. Marking and LabelingThe Company establishes instructions for marking and labeling to identify,
- maintain, and preserve an item, including indication of the presence of specialenvironments or the need for special controls.
Consumable materials such as chemicals,
- reagents, and lubricants maintained in storerooms and warehouses are controlled procedurally by an inventory control system, which includes provisions for identifying storage requirements and shelf lives by commodity, when applicable.
Disposal of commodities whoseshelf life has expired is addressed and controlled by procedures.
2.6. StoragePeriodic monitoring is performed to assure that storage areas are beingmaintained in accordance with applicable requirements.
Access to storageareas shall be controlled and limited.
Cleanliness and good housekeeping practices shall be enforced at all times in the storage areas. Fire protection measures commensurate with the type of storage area shall be provided andmaintained.
Page 2 of 2 Revision 90Page 2 of 2Revision 90 INSPECTION, TEST, AND OPERATING CHAPTER 14STATUS1, SCOPEMeasures shall be established and documented to identify inspection, test, andoperating status of structures,
- systems, and components in the scope of thisQAP. Such measures shall provide means for assuring that requiredinspections and tests are performed and that the acceptability of items withregard to inspections and tests performed is known throughout procurement, installation, and operation in order to preclude inadvertent bypassing or alteringthe sequence of such inspections and tests.2. REQUIREMENTS 2.1. GeneralThe Company uses markings, tags, stamps, routing cards, labels, forms,inspection
- records, or other means to identify the operating status of plantequipment.
This identification helps avoid inadvertent bypassing of theinspections and tests required prior to its use.In cases where documentary evidence is not available to confirm that an itemhas passed required inspections and tests, that item shall be considered nonconforming.
An operability determination for the nonconforming item withtimeliness commensurate with the potential safety significance of the issue isperformed.
The operability determination is focused on whether the non-conforming item is capable of performing or supporting its specified functions ofprevention or mitigation as described in the current licensing basis and will resultin the determination of continued plant operation.
If operability is assured basedon this prompt determination, plant operation can continue while an appropriate corrective action program is implemented to restore qualification of the non-conforming item.Control procedures describe the use of such tags, stamps, routing cards, labels, forms,inspection
- records, and other methods.
The authority for application and removal of tags,markings, labels and stamps is specified.
- Tagging, labeling, color-coding, physicalseparation, or using an inventory system identifies acceptable or unacceptable items forinstallation.
The Company:-clearly identifies and documents all temporary connections, such asjumpers and bypass lines, and temporary set points of control equipment to allow restoration before placing the item in service.-conditionally releases items for installation pending subsequent correction of any non-conformances.
-indicates the date the item was placed in the acceptable or unacceptable installation status.Page I of 4Revision 90 INSPECTION, TEST, AND OPERATING CHAPTER 14STATUS-maintains
- records, marks equipment to indicate calibration status, andidentifies test equipment found out of calibration.
2.1.1. Procedures
The Company uses procedures for control of equipment to maintain personnel and reactor safety and to avoid unauthorized operation of equipment.
Theseprocedures require control measures such as locking or tagging to secure andidentify equipment in a controlled status. The procedures require independent verifications, where appropriate, to ensure that necessary
- measures, such asequipment
- tagging, have been done correctly.
2.2. Operating Status2.2.1. Release for Maintenance Operating personnel, including a senior reactor operator, as applicable, maygrant permission to release plant systems or equipment for maintenance orsurveillance testing.
Prior to granting permission, such operating personnel:
-verify that the equipment or system can be released.
-determine how long it may be out of service.-determine what functional testing or redundant systems are required priorto and during the out-of-service period.The Company documents such permission.
The Company uses independent verification to the extent necessary to ensure that the proper system wasremoved from service.
The Company considers the degraded protection available when one subsystem of a redundant safety system has been removedfor maintenance or surveillance testing.2.2.2. Preparation for WorkAfter permission has been granted to take the equipment out of service,measures provide for protection of equipment and workers.
The Companyclearly identifies the status of equipment and systems at any location where theequipment can be operated.
The Company enforces strict control measures forsuch equipment.
The operating staff can easily identify equipment, which is inother than normal conditions.
In addition to the requirements of the technical specifications, conditions to beconsidered in preparing equipment for maintenance or surveillance testinginclude, for example:-electrical hazards.-entry into closed vessels.-establishment of a path for decay heat removal.-handling hazardous materials.
-hazardous atmospheres and ALARA considerations.
Page 2 of 4Revision 90 INSPECTION, TEST, AND OPERATING CHAPTER 14STATUS-method of emergency core cooling.-shutdown margin.-temperature and pressure of the system.-valves between work and hazardous materials.
-venting,
- draining, and flushing.
When entering a closed system, the Company prevents the entry of extraneous material and removes foreign material before re-closing the system. Appropriate personnel inform control room supervision of changes in equipment status,including temporary modifications, and the effects of such changes.2.2.3. Temporary Modifications The Company controls temporary modifications, such as temporary bypasslines, electrical
- jumpers, lifted electrical leads, and temporary trip point settingswith approved procedures.
These procedures include requirements for theperiod of time when the temporary modification is in effect. They also include arequirement for:-a verification by a second person of the proper installation or removal ofthe temporary modification, or-a functional test which conclusively proves the proper installation orremoval of the temporary modification.
The Company maintains a log or other documented evidence for the currentstatus of such- temporary modifications.
The Company reviews temporary modifications periodically to assess their continued need and propriety.
2.2.4. Return to ServiceWhen equipment is ready to be returned to service, operating personnel placethe equipment in operation and verify and document its functional acceptability.
The Company assures return to normal conditions using approved procedures, including:
-removal of electrical jumpers.-removal of signals used during testing.-returning valves, breakers, or switches to proper start-up or operating positions.
-assuring that all alarms, which are indicative of inoperative status, arecleared.A second qualified person verifies proper alignment of equipment unless:-all equipment, valves and switches involved in the activity can be provento be in their correct alignment by functional testing without adversely affecting the safety of the plant, or-such verification would result in significant radiation exposure.
Page 3 of 4Revision 90 INSPECTION, TEST, AND OPERATING CHAPTER 14STATUSThe person who performs verifications (independent or concurrent) is qualified toperform such tasks. When placed into service, equipment receives additional surveillance during the run-in period. The on-duty supervisor responsible for theunit formally accepts equipment, which is returned to service.Page 4 of 4 Revision 90Page 4 of 4Revision 90 NONCONFORMING MATERIALS, PARTS, OR COMPONENTS
- 1. SCOPECHAPTER 15Controls shall provide for identification, evaluation, segregation when practical, disposition of nonconforming items, and for notification to affected organizations.
Items that do not conform to specified requirements shall be controlled toprevent inadvertent installation or use.2. REQUIREMENTS 2.1. GeneralNonconforming items are processed in accordance with the corrective actionprogram and / or documented procedures.
The Company uses writtenprocedures to identify and control items, services or activities that do notconform to requirements.
These procedures address the:-disposition of nonconforming items.-documentation of identified nonconformances.
-identification of nonconforming items.-notification of affected organizations.
-operability determination of the SSC with the identified nonconforming condition
-segregation of nonconforming items.Implementation of these procedures prevents the inadvertent use, operation, orunauthorized installation of nonconforming items.2.1.1. Supplier Nonconforming ItemsThe Company and its suppliers establish and document measures for theidentification, control and disposition of items and services that do not meetprocurement document requirements.
These measures provide for:-a review of nonconforming items.-supplier notification to the Company of a nonconformance.
Thesenotifications include a supplier recommended disposition (e.g. "use -as -is" or "repair")
and technical justification.
The supplier submitsnonconformances to the Company for approval if:-the supplier has violated a technical or material requirement, or-the supplier has violated a requirement in supplier documents, which have been approved by the Company, or-the supplier cannot correct the nonconformance by continuation ofthe original manufacturing process or by rework, orPage 1 of 4 Revision 90Page I of 4Revision 90 NONCONFORMING MATERIALS, CHAPTER 15PARTS, OR COMPONENTS
-the item does not conform to the original procurement requirement even though the item can be restored to a condition such that thecapability of the item to function is unimpaired.
-Company disposition of supplier recommendations.
-verification of disposition for nonconformances.
-maintenance of records for supplier nonconformances.
2.2. Identification
The Company identifies nonconforming items by marking,
- tagging, or othermethods, which do not adversely affect the end use of the item. Theidentification is legible and easily recognizable.
2.3. Segregation
When practical, the Company segregates nonconforming items by placing themin a clearly identified and designated hold area until properly dispositioned.
When segregation is impractical or impossible due to physical conditions suchas size, weight or access limitations, other precautions are employed to precludeinadvertent use of a nonconforming item.2.4. Disposition 2.4.1. ControlNonconforming characteristics shall be reviewed and recommended dispositions of nonconforming items shall be proposed and approved in accordance withdocumented procedures.
Further processing,
- delivery, installation, or use of anonconforming item shall be controlled pending an evaluation and an approveddisposition by authorized personnel.
2.4.2. Evaluation
The Company has responsibility for resolution of nonconformances inaccordance with written procedures.
Where ASME Code requirements areinvolved, the Authorized Inspection Agency reviews and accepts or rejects thedisposition and justification.
Engineering provides technical justification andindependent review of nonconformances dispositioned as repair or use-as-is.
For items under a contractor's direct control, the Company may delegate to thecontractor the authority to perform a technical evaluation of nonconformances, ifthe contractor has an acceptable procedure for handling nonconforming items.Where the Company delegates such authority, the contractor is responsible forestablishing that:-all actions fall within the requirements set by the Company.-an accepted nonconformance meets the design intent.-ASME Code items meet the requirements of the ASME Code.Page 2 of 4Revision 90 NONCONFORMING MATERIALS, CHAPTER 15PARTS, OR COMPONENTS
-personnel performing the evaluation meet the requirements of section2.4.3 below.When a technical evaluation has not been delegated to a supplier, the Companymakes a technical evaluation of all pertinent data relating to the nonconformity, including the cause, where known, and the corrective action either taken orplanned to prevent recurrence per the corrective action program.
The Companyretains the responsibility for the satisfactory resolution of suppliernonconformances.
2.4.3. Personnel
Personnel having expertise in the pertinent discipline determine whether anonconforming item may be accepted "as -is," may be repaired to anacceptable condition, or must be rejected.
These personnel have adequatecompetence and knowledge necessary to make this evaluation and have accessto pertinent background information.
2.4.4. Documentation
The Company identifies nonconforming items and documents their disposition as applicable (e.g. use -as -is, reject, repair, or rework).
Technical justification for the acceptability of a nonconforming item, dispositioned as repair, or use-as-is, is documented and traceable to each item. Appropriate documentation isretained.
Nonconformances to design requirements that are dispositioned as "use -as -is" or "repair" is subject to design control measures commensurate with thoseapplied to the original design. The Company technically justifies dispositions designated "use -as -is," and "repair" to assure that the final condition of anynonconforming item meets applicable code requirements and will not adversely affect the safety, operability, or maintainability of the item, or of the component or system in which it is installed.
The "as -built" records, if such records arerequired, reflect the accepted deviation.
If the nonconformance can be corrected after installation, the item may bereleased for installation on a conditional release basis. The Companydocuments the authority and technical justification for the conditional release ofthe item and makes it part of the documentation.
2.4.5. Repaired,
- Reworked, or Scrapped ItemsThe Company re-examines repaired or reworked items using procedures andthe original acceptance criteria unless the nonconforming item's disposition hasestablished alternate acceptance criteria.
Items that have been corrected arere-inspected or re-tested as required by the approved disposition.
Page 3 of 4 Revision 90Page 3 of 4Revision 90 NONCONFORMING MATERIALS, CHAPTER 15PARTS, OR COMPONENTS The area of inspection may be confined to the area of the nonconformance.
When it has been determined that the corrected item is satisfactory, the status ofthe item is changed to "acceptable" and an appropriate entry is made in thedocumentation after acceptance is determined.
The Company scraps, discards or transfers to training usage a nonconforming item that cannot be corrected or accepted "as -is." Nonconforming items thatare being used for training must be controlled (e.g. administratively controlled, permanently identified, marked, obliterate Material ID Tag or Q level indicators) to prevent inadvertent or inappropriate use of the item.Page 4 of 4 Revision 90Page 4 of 4Revision 90 CORRECTIVE ACTIONCHAPTER 161. SCOPEThis Chapter describes the Company program to identify and correct conditions adverse to quality.2. REQUIREMENTS 2.1. GeneralThe Company implements a Corrective Action Program to promptly identify andcorrect items or occurrences that are adverse to quality or might adversely affectthe safe operation of a nuclear generating station.
These items or occurrences are screened for reportability, operability, Part 21, etc. The Company makes athorough investigation of occurrences and identifies corrective action to preventrecurrence of an event, as appropriate.
Events may include reactor trips, failedequipment, personnel errors, and procedural infractions.
Measures are taken toassure that the cause of any significant condition adverse to quality isdetermined and takes corrective action to prevent recurrence.
2.2. Conditions Adverse to QualityMeasures are established to assure that conditions adverse to quality areidentified and corrected.
Examples of conditions adverse to quality are providedin procedures.
Examples include failures, malfunctions, adverse trends,deficiencies (including programmatic),
deviations, defective
- material, designerrors, equipment, and nonconformance to specified requirements.
An independent review body reviews violations, deviations and reportable events that require a report to the NRC in accordance with regulatory requirements and company procedures.
This includes the review of results ofany investigations made and the recommendations resulting from suchinvestigations.
These include items such as:-Licensee Event Reports (LER)-significant operating abnormalities or deviations from normal or expectedperformance of plant safety-related structures,
- systems, or components.
-violations of applicable codes, regulations, orders, technical specifications, license requirements or internal procedures or instructions having safety significance.
2.2.1. Significant Conditions Adverse to QualityIn cases of significant conditions adverse to quality the cause of the condition isdetermined and documented, resolution determined and documented, andcorrective action taken and documented to preclude recurrence.
Page 1 of 4 Revision 90Page 1 of 4Revision 90 CORRECTIVE ACTIONCHAPTER 161. Procurement The Company uses procedures that include methods for the identification of conditions adverse to quality and for timely corrective action. TheCompany requires individual vendors and their contractors to includecorrective action measures in their quality assurance programs.
In casesof significant conditions adverse to quality that arise during theprocurement
- process, the Company uses procedures to describe themethod used to:-identify and document deviations and non-conformances.
-review and evaluate the conditions to determine the cause, extentand measures needed to correct and prevent recurrence.
-report the conditions and corrective action to the appropriate levelsof management.
-implement and maintain required corrective action.2. Plant Hardware Malfunctions The causes of malfunctions are determined, evaluated, and recorded, asappropriate.
Experience with the malfunctioning equipment and similarcomponents are reviewed and evaluated to determine if a replacement component of the same type can be expected to perform the functionreliably.
If evidence indicates that common components in safety-related systems have performed unsatisfactorily, corrective measures areplanned prior to replacement or repair of all such components.
Appropriate procedures are revised in a timely manner to preventrecurrence of equipment malfunction or abnormal operation.
- 3. Incorrect DesignWhen a significant design change is necessary because of an incorrect design, the Company reviews and modifies the design process andverification procedures, as appropriate.
In cases of significant orrecurring deficiencies (or errors),
the Company follows written procedures to correct the deficiency (or error), determine the cause and makechanges in the design process and the QAP to prevent similar types ofdeficiencies (or errors) from recurring.
2.3. Verification and Follow-up The Company verifies completion of corrective actions for maintenance, repair,refueling, operation activities, completion of corrective action taken forassessment deficiencies (including programmatic),
and performs assessments of site corrective action. The Company tracks and verifies completion ofcorrective action taken for independent assessment findings and approves thecompletion of corrective actions.Page 2 of 4 Revision 90Page 2 of 4Revision 90 CORRECTIVE ACTIONCHAPTER 16Trending and assessment results are evaluated to assure that corrective measures are implemented effectively and that actions to prevent recurrence areeffective as appropriate.
The Company also requires contractors and vendors tofollow-up on corrective action commitments within their quality programs.
The Company regularly reviews and analyzes records to:-assure that the causes of a nonconformance and the corrective actionhave been clearly described.
-assure that authorized Company personnel have evaluated the overalleffect resulting from the use of nonconforming items.-determine whether corrective measures will preclude recurrence.
2.4. Evaluation and Qualification Personnel performing the evaluation function are responsible for considering thecause and the feasibility of corrective action to assure that the necessary qualityof an item is not deteriorated.
Where it is determined that the cause cannot becorrected immediately, the due date of corrective action will be determined during the review and evaluation.
Evaluation may indicate the need forinvestigations to assure that corrective measures are considered complete andmay also indicate that the nature of the deficient condition is minor and does notrequire corrective action.Qualified personnel are responsible for determining the root cause(s) of an eventand developing recommendations to preclude recurrence.
These personnel report the results of their determination to appropriate station personnel andCompany management.
2.5. Documentation and Reporting The Company documents the identification of significant conditions adverse toquality, the cause of the condition, the corrective action taken, and reports theseitems to the appropriate levels of management, NSRB, and as applicable, PORC, If the identified issue is not an indication of a significant failure in anyportion of the QAP, the Company does not require reporting to management.
Reports are made immediately if prompt corrective action is required.
Formalreports are filed with the appropriate regulatory agency, when required.
Reportsof investigations include a detailed description of the occurrence, the findings ofthe investigation, and the recommended corrective measures.
The Companynotifies the rest of the nuclear industry of significant events with genericimplications and its circumstances to help preclude a similar event occurring atanother plant.The Company keeps records to identify incidents (e.g., major damage, personalinjury, major schedule delays.),
non-conforming items, unfavorable conditions, programmatic deficiencies identified in assessment
- reports, significant equipment
- failures, and malfunctions that occur during station operation.
Page 3 of 4Revision 90 CORRECTIVE ACTIONCHAPTER 16The Company tracks the completion of corrective actions for conditions adverseto quality and maintains records of their resolution.
Parts or all of this systemmay be electronically monitored and electronic records may be used as the solerecord of such a system.Page 4 of 4 Revision 90Page 4 of 4Revision 90 QUALITY ASSURANCE RECORDSCHAPTER 171. SCOPEThe Company establishes and implements a program, which definesrequirements and responsibilities for identification, generation, collection, compilation,
- storage, maintenance, retention, and retrieval of records necessary to provide evidence of quality in assessment, corrective action,decommissioning, design, engineering, fabrication, installation, inspection, maintenance, modification, operations,
- testing, and associated reviews.2. REQUIREMENTS 2.1. ProgramThe records program provides for:-administration.
-generation
-receipt and transmittal.
-storage and preservation
( includes temporary and permanent records)-safekeeping and classification.
-retention and disposition.
2.2. Administration
Authority and responsibility for record control activities are delineated inprocedures.
Records are administered through a system, which includes anindex of record type, retention period, and storage location.
Distribution ofrecords shall be controlled in accordance with written procedures.
Measures areestablished for replacement, restoration, or substitution of lost or damagedrecords.Records are legible,
- accurate, complete, identifiable, and retrievable.
Recordsare considered valid and complete when dated and stamped, initialed, signed, orotherwise authenticated.
Corrections, revisions, or supplements to completed records are reviewed and approved by an authorized individual in the originating organization.
Such changes are dated and stamped, initialed, signed, orotherwise authenticated including the use of electronic approval andauthorization.
Records may be stored in electronic media provided that the process formanaging and storing data is documented in procedures that comply withapplicable regulations, including NRC guidance in RIS 2000-1 8. Media used forthe retention of records include (but are not limited to): microform, compact disk-recordable (CD-R), and magnetic media including videotape, computer tape,optical disks, and hard disk storage.
Electronic records retention must be anintegral component of the Corporate Records Management
- Program, approvedby the management position responsible for Nuclear Generation records.
ThePage 1 of 5Revision 90 QUALITY ASSURANCE RECORDSCHAPTER 17format used must be capable of producing
- legible, accurate, and completedocuments during the required retention period. Electronic approval andauthorization procedures are established to assure that only those personsauthorized grant the required approvals.
2.3. Receipt and Transmittal A system for receipt control of records is established.
Receipt control is requiredfor records transferred between Company locations, vendors and the Company,and from Company department files to final storage locations.
Systems areestablished to transfer records between Company locations and betweenvendors and the Company.
Records transferred from Company department filesto a final storage location are also under such systems.
The system of receiptcontrol of records for permanent or temporary storage includes inventory oftransmitted
- records, receipt acknowledgment, and control of records duringreceipt.2.4. Storage and Preservation Record storage facilities are established and maintained in a manner thatminimizes the risk of damage or destruction.
Records may be kept by suppliers and maintained on an available basis for a specified period of time. Storage andPreservation systems provide for:-assignment of responsibilities.
-attachment in binders,
- folders, or envelopes for storage in steel filecabinets or on shelving in containers.
-control and accountability of records removed.-damage from natural disasters such as winds, floods, and fires.-following manufacturer recommendations for special recording media.-protection from environmental conditions such as high and lowtemperatures and humidity.
-protection from infestation of insects, mold, or rodents etc.-special processed records such as radiographs, photographs, negatives, microfilm, and magnetic media to prevent damage from excessive light,stacking, electromagnetic fields, temperature and humidity.
Permanent storage alternative below applies to Calvert Cliffs Nuclear PowerPlant. In lieu of the reinforced
- concrete, concrete block, masonry, or equalconstruction requirements of Supplement 17S-1, Section 4.4.1(a),
the recordsvault is entirely enveloped by a structurally sound, fire-resistive building.
Thevault rests on a reinforced slab on grade and its walls extend fully to theunderside of the structural deck. The walls of the vault are constructed ofgypsum wallboard on metal studs per Underwriters Laboratory Test NumberU41 2, assuring the equivalent of 2-hour fire resistant construction.
This is equalconstruction to concrete block in terms of fire protection.
The walls carry nostructural load; hence, they provide equivalent structural integrity to that neededof concrete block. Supplement 17S-1 Section 4.4.1(b) requires floor and roofPage 2 of 5Revision 90 QUALITY ASSURANCE RECORDSCHAPTER 17drainage control.
If a floor drain is provided, a check valve (or equal) shall beincluded.
In lieu of this requirement, the vault is contained within anenvironmentally protected building.
As such, it has no roof, or need for floordrain.Interim storage provisions shall be established to properly maintain and protectrecords until they are permanently transferred to record storage facilities forretention and shall meet one of the following conditions:
- 1. Records shall be stored in steel cabinets located in a fire-resistant building or non-combustible building with a fire suppression system.A fire-resistant building must meet the following:
A facility constructed toresist the initiation or spreading of fire; fire-suppressive and/or non-combustible materials used; building certified as fire-resistant by a personwho specializes in the technical field of fire prevention and fireextinguishing.
- 2. Temporary storage per section 2.4.1.2.4.1. Temporary StorageMeasures are established for temporary storage of records when required by anorganization's procedures for activities such as; for processing, review, or use.These measures require that these records are stored in a 1-hour fire ratedcontainer and that a maximum allowable storage time limit is specified.
2.5. Safekeeping and Classification Measures are established to prevent access to records by unauthorized personnel.
These measures guard against theft and vandalism.
Records areclassified and retained in accordance with applicable regulations.
2.6. Retention and Disposition Record retention periods are established to meet regulatory, UFSAR, andLicense requirements.
The most stringent retention period is implemented whenmultiple requirements exist. Records are dispositioned at the end of theprescribed retention period.2.7. Plant Operating Records2.7.1. Records andlor Logs, 5-Year Retention (unless otherwise noted)Records and/or logs relative to the following items shall be kept in a mannerconvenient for review and shall be retained for at least 5 years unless otherwise noted. These items apply to Braidwood, Byron, Calvert Cliffs, Clinton, Dresden,Ginna, LaSalle,
- Limerick, Nine Mile Point, Peach Bottom (inclUding thePage 3 of 5Revision 90 QUALITY ASSURANCE RECORDSCHAPTER 17Independent Spent Fuel Storage Installation),
and Quad Cities Stations unlessotherwise noted:-records of normal plant operation, including power levels and periods ofoperation at each power level.-records and periodic checks, inspection and/or calibrations performed toverify that the surveillance requirements of the Technical Specifications (and Fire Protection Program at Clinton) are being met. All equipment failing to meet surveillance requirements and the corrective action takenshall be recorded.
-records of physics tests and other tests pertaining to nuclear safety.(Braidwood, Byron, Dresden,
- LaSalle, Peach Bottom, Quad Cities)-records of changes to procedures required by a station's Technical Specifications and other procedures, which affect nuclear safety, asdetermined by the management position holder responsible for plantoperation.
-shift manager/engineers' logs (Braidwood, Byron, Dresden, LaSalle,Quad Cities)-records of principal maintenance activities, including inspection andrepair, (and replacement for Braidwood, Byron, Limerick and PeachBottom) regarding principal items of equipment pertaining to nuclearsafety.-records of changes made to the equipment or reviews of tests andexperiments to comply with 10OCFR50.59 (Dresden and Quad Cities).-records of changes made to the procedures as required by Technical Specifications and the Operational Requirements Manual (Clinton).
-reportable events required by 10CFR50.73 and 10CFR72.216 asapplicable (Clinton 10CFR50.73 only, Calvert Cliffs, Ginna, Limerick, NineMile Point, and Peach Bottom).-records of radioactive shipments (Calvert Cliffs, Ginna, Limerick, andNine Mile Point)-records of secondary water sampling and water quality.
(Calvert Cliffs,Ginna, Nine Mile Point) (Lifetime)
-records of the service lives of all snubbers, including the date at which theservice life commences and associated installation and maintenance records.
(Calvert Cliffs, Ginna, Nine Mile Point Unit 2) (Lifetime)
-records of evaluations performed for changes made to procedures orequipment or evaluations of tests and experiments pursuant to 10 CFR50.59 or 10 CFR 72.48. (Calvert Cliffs, Ginna, Nine Mile Point) (Lifetime)
-records of QA activities required by this QATR and not otherwise listed.(Calvert Cliffs, Ginna, Nine Mile Point) (Lifetime)
Page 4 of 5 Revision 90Page 4 of 5Revision 90 QUALITY ASSURANCE RECORDSCHAPTER 172.7.2. Lifetime RecordsLifetime records are those that are specified by applicable regulations, standards, codes, and licensing basis documents.
Page 5 of 5 Revision 90Page 5 of 5Revision 90 ASSESSMENTS/AUDITS CHAPTER 181. SCOPEA documented, comprehensive system consisting of regulatory audits andperformance assessments of the Company and its vendors are conducted toverify QAP compliance,
- adequacy, and effectiveness.
Audits and assessments are conducted in accordance with written procedures or checklists.
Audits areperformed to the requirements of ASME NQA-1 to evaluate the auditedorganization and to assure completion of required corrective actions,commitments, or improvements and determine effectiveness in meeting programobjectives.
- 2. REQUIREMENTS 2.1. Assessments and Audits -General2.1.1. Scheduling The internal audit program is conducted on a performance driven frequency thatis commensurate with the status and importance of the activity to be completed but does not exceed 24-months.
Internal audit frequencies required byregulation that are different than the 24-month period are indicated withinAppendix B, "Audit Frequency."
Audit frequencies are determined based on aconsideration of the risk and consequences with respect to the activities beingaudited.Audits may be extended beyond their originally scheduled due date based onthe following criteria:
A. Audits shall be performed at the intervals designated in Appendix B, "AuditFrequency".
Schedules are based on the month in which the audit starts.B. A maximum extension not to exceed 25 percent of the audit interval isallowed.
That is to say that, for audits on a 24-month frequency, themaximum time between specific audits does not exceed 30 months.Likewise, audits on an annual (12-month) frequency do not extend beyond15 months. Audits of Emergency Preparedness and Security are notsubject to the extension and will be performed on a frequency not to exceed12 months (or not to exceed 24 months if performed on a 24-monthfrequency).
C. When an audit interval extension greater than one month is used, the nextaudit for that particular audit area is scheduled from the original anniversary month rather than from the month of the extended audit.The NSRB activities will be periodically reviewed for effectiveness at afrequency not to exceed 2 years by experienced Nuclear Oversight personnel and/or industry peers. This review will include an evaluation ofthe NSRB activities for compliance with the QATR requirements.
Page 1 of 4Revision 90 ASSESSMENTS/AUDITS CHAPTER 18ASSESSMENTSIAUDITS CHAPTER 18D. Item B applies to supplier audits and evaluations except that a totalcombined interval for any three consecutive inspection or audit intervals does not exceed 3.25 times the specified inspection or audit interval.
Fleet assessment activities are conducted to identify performance gaps andenable the site to drive towards sustainable performance excellence.
Theseplanned internal assessment activities are performed to a schedule that isapproved by the management position responsible for Fleet Assessments, ordesignated staff member(s).
2.1.2. Preparation
A documented plan or an agenda identifies an audit or assessment scope,requirements, audit or assessment personnel, activities to be evaluated, organizations to be notified, applicable documents, and schedule.
An approvedchecklist or procedure for each scheduled audit or assessment identifies therequirements of the area or items to be evaluated.
Audit plans, agendas,checklists, and procedures as applicable are prepared in advance under thedirection of an Audit Team Leader.2.1.3. Personnel Experienced and qualified personnel perform assessments and audits and arefamiliar with written procedures, standards, and processes applicable to the areabeing evaluated.
Assessment and audit personnel shall have sufficient authority and organizational freedom to make the assessment and audit processmeaningful and effective and shall not have direct responsibilities in the areas tobe assessed or audited.
They shall have access to the plant records necessary to fulfill their function.
The Audit Team Leader shall organize and direct audits and ensure the teamcollectively has the required experience or training for the activities to beevaluated.
Technical Specialists may supplement the team to provide additional experience and competence.
2.1.4. Performance
Performance assessments are conducted to assess specific activities, processes, and records on the basis of their impact and importance relative tosafety, reliability, and functionality with respect to risks and consequences.
Assessments can be focused on areas most in need of improvement.
Audits are initiated early to assure effective quality assurance during design,procurement, manufacturing, construction, installation, inspection,
- testing, andoperations.
Additional unscheduled audits/assessments may also be performed at various stages of activities, based on the nature and safety significance of thework being done; to verify continued adherence to and effectiveness of the 7/quality systems.
Objective evidence shall be examined to the extent necessary JPage 2 of 4 Revision 90Page 2 of 4Revision 90 ASSESSMENTSIAUDITS CHAPTER 18ASSESSMENTSIAUDITS CHAPTER 18to determine that a quality program is being effectively implemented.
2.1.5. Reporting and Follow-up A. AuditsAn audit report includes the description of the audit scope, identification of theteam and personnel contacted during audit activities, a summary of results(including a statement on effectiveness of the QAP elements),
and a description of each finding.
The ATL shall sign the audit report for which he or she isresponsible.
Audit results are documented and distributed to the management positionresponsible for NOS, and to the appropriate managerial level of the organization having responsibility for the area or activity audited.
Findings or deficiencies requiring prompt corrective action are reported immediately to the management of the audited organization.
- Findings, deficiencies and recommendations of each audit shall be reported toappropriate site management and the management position responsible forNOS. All findings of noncompliance with NRC requirements, and any significant nuclear safety or quality issues requiring escalated action, will be directedthrough the management position responsible for NOS to the President andONO in accordance with procedural requirements.
Responsible management shall take the necessary actions to correct findingsidentified in the audit. They will identify the corrective action to be taken, actionsthat will prevent recurrence, and a schedule for implementing these actions.Responses to audit findings are reviewed for adequacy.
Follow-up verification of the completion of scheduled corrective actioncommitments are performed by NOS to assure findings or adverse conditions are corrected in accordance with procedural requirements.
Follow-up action ofprevious deficient areas or adverse conditions (including re-audit) is taken toverify that corrective action has been completed, is effective, implementation continues, and is properly documented, when indicated.
B. Assessments Assessment reports will include a description of the assessment scope,identification of the team, a summary of results, and a description of eachassessment identified issue. Issues will be reported to the appropriate site!corporate management and to the management position responsible forOrganizational Effectiveness and Integrated Performance Assessments (OR&IPA).
All significant issues requiring escalated action will be directedthrough the management position responsible for OR&IPA to the President andCNO in accordance with procedural requirements.
Follow-up of previously identified assessment issues will be performed in accordance with procedural requirements.
Page 3 of 4 Revision 90 ASSESSMENTSIAUDITS CHAPTER 18ASSESSMENTSIAUDITS CHAPTER 182.1.6. RecordsAudit and Assessment results are documented and reports are generated andretained as applicable.
Associated documentation is on file at the appropriate location.
Personnel qualification records for assessment and audit teammembers are established, maintained, and reviewed as required.
2.2. Vendor AuditsAudits, or surveys of vendors and their sub-tier suppliers are performed to a pre-established schedule.
Audits are performed on a triennial basis. Documented supplier performance monitoring is performed in accordance with approvedprocedures as an acceptable alternate to the performance of the annualevaluation of suppliers.
The management position responsible for audits andprograms or designee, shall review and approve the audit/survey schedule andchecklists, and sign reports.
Schedules are reviewed semi-annually and revised'accordingly to assure that suppliers are audited, or surveyed as required.
Audit program requirements are imposed on suppliers by appropriate contract orprocurement documents.
The Company's active participation in nuclear industryaudits provides an alternative means to fulfilling its responsibility for examining supplier activities.
2.3. Independent Management AuditA periodic audit (not to exceed 24 months) of the status and adequacy of theQAP is performed by an independent organization to assure that audits arebeing accomplished to program requirements.
In addition, this will include anevaluation of the NSRB activities for compliance with the QATR requirements.
The management position responsible for NOS submits the results of this auditto the President and CNO.Page 4 of 4 Revision 90 AUGMENTED QUALITYAPPENDIX A1. SCOPEIt is the Company's policy to assure a high degree of availability and reliability forits nuclear plants while ensuring the health and safety of the public and itsworkers.
Therefore, the Quality Assurance Program is applied in a gradedmanner to certain areas and activities that are not clearly defined as safetyrelated.
The Company calls this application Augmented Quality.
Augmented Quality includes systems and components that are subject to the requirements of ASME Code Sections:
I "Power Boilers,"
IV "Hot Water Heaters,"
and VIII"Non-fired Pressure Vessels" (see sub-section 2.7. below). This appendixapplies to all sites unless otherwise noted below or in Appendices B through G.2. REQUIREMENTS The Company applies the following augmented quality requirements to certainsystems, structures, components (SSC), and activities that are not safety relatedto a degree consistent with their importance to safety. Unless otherwise noted:-routine audits are performed of the program's content andimplementation.
-deficiencies are addressed in accordance with the corrective actionprogram.-program records of audits and reviews are maintained as required.
2.1. Health Physics and ALARA (As Low As Reasonably Achievable)
The Company develops, documents, and implements a radiation protection program sufficient to ensure compliance with the provisions of 10OCFR20.
TheCompany uses, to the extent practical, procedures and engineering controlsbased on sound radiation protection principles to achieve occupational dosesand doses to the public that are as low as reasonably achievable.
2.2. Transport of Radioactive WasteWhen the Company contracts with vendors to transport radioactive waste inNRC approved shipping
- packages, it meets the requirements of IOCFR71,Subpart H. The Company assures that this service is procured from anorganization with a QA program and if applicable, includes a NRC licensedtransport system. Loading, surveying,
- closure, placarding, and inspections areconducted in accordance with written procedures and instructions.
Transport casks and trailers are inspected before release in accordance withDepartment of Transportation (DOT) 49CFR.Shipping manifests, including final radiation
- surveys, are completed andretained.
Radioactive waste shipments not meeting the requirements for NRCapproved packaging, shall meet the requirements of DOT 49CFR.Page 1 of 6 Revision 90 AUGMENTED QUALITYAPPENDIX A2.3. ServicesThe Company procures services from qualified suppliers.
It is not necessary thatthese suppliers have a quality assurance program approved by the licensee,
- however, suppliers should provide a quality assurance program that includes thequality assurance program elements presented in Reg. Guide 4.15, androutinely provide program data summaries sufficiently detailed to permitevaluation of the program for the following areas:-meteorology.
-Offsite Dose Calculation Manual.-radiological environmental monitoring.
2.4. Fire Protection 10OCFR50 Appendix A, General Design Criteria (GDC) 3 requires that theCompany's nuclear facilities have an established fire protection program thatprovides fire protection features such that the adverse effect of fires onstructures, systems and components important to safety is minimized.
Thequality assurance program established for these fire protection SSCs ensuresthat design, procurement, instruction, procedures,
- drawings, inspection, installation,
- testing, maintenance, operations, nonconforming Items, corrective Action, records, audits and administrative controls meet the applicable QualityAssurance guidelines as described in the applicable edition of Branch Technical Position (BTP) 9.5-1 for each Exelon site. Engineering determines what fireprotection SSCs protect Structures,
- Systems, and Components important tosafety. Engineering also establishes the requirements for the design,procurement, fabrication, installation and/or modification of these fire protection SSCs. Routine testing of fire protection systems assures reliability.
All other fireprotection equipment and supplies will be of commercial
- quality, in accordance with National Fire Protection Association (NFPA) guidelines.
2.5. Station Blackout (Regulatory Guide 1.155)Calvert Cliffs, Dresden,
- LaSalle, Limerick, Nine Mile Point Unit 1, Nine Mile PointUnit 2, Oyster Creek, Quad Cities and Three Mile Island stations rely on non-safety related equipment to achieve the redundancy required by 10CFR50.63.
Quality Assurance requirements for Calvert Cliffs, Dresden,
- LaSalle, Limerick, Nine Mile Point Units 1 and 2, Oyster Creek, Quad Cities and Three Mile Islandare implemented in accordance with Regulatory Guide 1.155 (Station Blackout),
Appendix A and B. Replacement and consumable parts and supplies areclassified non-safety related in accordance with original specifications and areprocured as commercial items. Routine testing of Station Blackout (SBO) SSCsassures the necessary redundancy is maintained.
SBO SSC reliability ismonitored in accordance with the Station's Maintenance Rule program.Page 2 of 6 Revision 90 AUGMENTED QUALITYAPPENDIX A2.6. Augmented Quality Requirements for Dresden 1, and Peach Bottom 1Dresden 1, and Peach Bottom 1, have ceased commercial operation and willultimately be decommissioned.
- Staffing, qualification of personnel, andorganization will be in accordance with the Dresden 1 De-fueled Technical Specifications (DTS) and De-fueled Safety Analysis Reports (DSAR), and thePeach Bottom 1 Updated Final Safety Analysis Report (UFSAR) and Technical Specifications.
Except for inspections or examinations required for ASME repairs andreplacements, station personnel may perform inspections provided they areexperienced, task-qualified personnel or supervisors who did not supervise theactivity being inspected.
Nuclear Oversight will monitor this activity throughperiodic overview.
Timeliness of corrective actions is prioritized commensurate with the safetysignificance.
Sufficient records of maintenance and modification activities will bemaintained to evaluate
- failures, perform root cause analysis, if applicable, anddetermine appropriate corrective actions and to meet the requirements of theapplicable DSAR or Peach Bottom Unit 1 UFSAR.2.7. Repairs and Alterations The requirements of ASME Code Sections II, V and IX shall be imposed asapplicable for the repair or alteration job specific work scope.2.7.1. State of IllinoisWelded repairs and all alterations to non-ISI boilers and pressure
- vessels, asdescribed in Section 505.2500 of the rules contained in the Illinois Emergency Management Agency (IEMA) Safe Operation of Nuclear Facility Boilers andPressure Vessels (Part 505), and the repair of pressure relief valves, asdescribed in Section 505.2500(b) are conducted in accordance withSection 505.2500(a)(1
)(A) of these rules.Section 505.2500(a)(1
)(A) requires that the Company apply an approved QualityAssurance (QA) Program to such repairs and alterations and describe how it isapplied.
The following describes the Company's application of these rules.-The Company has a QA Program that is reviewed and accepted by theNRC. In addition, the QA Program is reviewed and accepted by anaccredited Authorized Inspection Agency. Authorized Inspectors arepresent at each of the Company's plants while ASME Code work is inprogress.
-Chapter 1 of this QA Program describes the authority and responsibilities of the organization.
It also describes the retention of responsibility by theCompany when repair and modification activities are subcontracted.
-Chapter 3 requires that design and changes to designs be defined,documented, and controlled.
Page 3 of 6 Revision 90 AUGMENTED QUALITYAPPENDIX A-Chapter 5 requires that all work be accomplished in accordance withdocumented instructions and procedures and be subject to appropriate process controls.
Specifically, the Company uses the Nuclear WorkRequest (NWR) to authorize, track, and control work in the plant. TheNWR system includes provisions for specifying when work is ASME Coderelated and is not limited to any particular section of the ASME Code. Itfurther provides for detailed instructions to accomplish the work. Thisincludes the need for qualified inspectors, qualified
- welders, qualified procedures, special processes, required documentation, approveddrawings, and post-maintenance/post-modification testing.
NWRsmarked as ASME Code work is offered to the Authorized Inspector for theinsertion of hold and witness points.-Chapters 4, 7, 8, and 13 address the procurement, receiving,
- handling, storage, disbursement, and marking of materials.
Implementing procedures establish traceability of materials to the procurement andreceiving processes and provide assurance that only ASME Codeacceptable materials are utilized.
Any specific requirements for heattraceability will be in accordance with the applicable sections of the ASMECode being used.-Chapter 9 details the controls for special processes while Chapter 10details those for inspection.
This includes the requirement for the use ofindependent, qualified inspectors and examiners when required by theASME Code, and invokes the Company's Special Processes andProcedures Manual (SPPM). The SPPM is also reviewed and acceptedby the Authorized Inspection Agency.-Chapters 6 and 17 require that documents and records be generated andmaintained to satisfy the requirements of the ASME Code and theJurisdiction.
-Chapter 18 provides for overview and audit of ASME Code activities.
Repairs and alterations performed as described above meet the requirements ofthe approved QA Program and meet the requirements of the IEMA B&PV rules;regardless of the safety classification of the boiler or pressure vessel or pressurerelief valve being repaired.
2.8. Dry Cask Storage System2.8.1. Limerick, Peach Bottom, Oyster Creek, Calvert Cliffs, Ginna, and Nine MilePointISFSI quality assurance program requirements are performed in accordance with the applicable I0CFR72.212 report which invokes the portions of the NRCapproved 10OCFR50 Appendix B quality assurance program as described in thisQATR, commensurate with the safety classification of the component and qualityrequirements specified in the cask vendor Final Safety Analysis Report (ESAR)or site specific license.Page 4 of 6 Revision 90 AUGMENTED QUALITYAPPENDIX A2.8.2. Braidwood, Byron, Clinton,
- Dresden, LaSalle and Quad Cities Station(s)
The ISFSI SSCs that are important to safety are categorized as Category A, B,or C in accordance with NUREG/CR-6407, "Classification of Transportation Packaging and Dry Spent Fuel Storage System Components According toImportance to Safety."
Per 1OCFR72, Subpart G, the QATR applies to the ISFSISSCs and activities consistent with their importance to safety as identified in theclassification table on next page identifies the graded approach and applicability of the Exelon QA Program Chapters based on the safety categories that aredefined in NUREG/CR-6407.
2.9. Emergency PlanningRequirements with respect to audits and records for Emergency Preparedness are described in an Emergency Plan that meets the requirements of10CFR50.47.
2.10.Security2.11Requirements with respect to audits and records for Security are controlled foreach station by an NRC approved Station Security Plan that is prepared andimplemented in accordance with the requirements contained in 10CFR73.55.
License RenewalConsistent with the requirements of 10 CFR 54.21 (a)(3), the companyimplements the requirements of QATR Chapters 1 through 18 for agingmanagement activities related to safety related SSCs.Additionally, to manage the aging effects of non-safety related SSCs that weredetermined to be within the scope of License Renewal, the company implements the administrative
- controls, corrective actions and confirmation processes described in QATR Chapters 6, 16 and the applicable requirements of this appendix.
Page 5 of 6 Revision 90Page 5 of 6Revision 90 AUGMENTED QUALITYAPPENDIX AAUGMENTED QUALITY APPENDIX AISFSI REQUIREMENTS Important to Safety SSCs CategoryChapter Title_ _ _ _ _ _ _ _ A B COrganization 1M M R(Roles and Responsibilities)________
Quality Assurance Program2 M M NR(Paragraphs 2.1, 2.4, 2.5, and 2.6) ______3 Design Control M M R4 Procurement Document Control M R NR5 Instructions, Procedures, and Drawings M M R6 Document Control M M RControl of Purchase
- Material, Equipment, andMRRServicesMRR 8 Identification and Control of Materials, Parts, andMRRComponentsMRR 9 Control of Special Processes M M R10 Inspections M M RTest Control,11 (Design, Fabrication, Installation, and Maintenance)
M M R12 Control of Measuring, and Test Equipment M M R13 Handling,
- Storage, and Shipping M R NR14 Inspection, Test, and Operating Status M M NR15 Nonconforming Materials, Parts, or Components M M R16 Corrective Action M M R17 Quality Assurance Records M M R18 Audits M M R(M) Mandatory
= Indicates the Appendix B QA Program shall be used.(R) Recommended
= Indicates application of the applicable quality assurance criterion may benefit the user.The Engineering organization shall determine the extent of application required for the SSCs in question.
O (NR) Not Required
= Indicates that little benefit has been identified or no regulatory basis has been found torequire application of applicable QA criteria.
Imprudent use of this criterion may add unnecessary burden.Page 6 of 6 Revision 90Page 6 of 6Revision 90 AUDITFREQUENCY APPENDIX BInternal audits shall be conducted on a performance driven frequency, not toexceed 24 months or at the frequencies indicated below, in accordance with theCompany's QAP. Audits shall include the following safety-related functions asapplicable:
AUDIT FREQUENCY
- a. The conformance of unit operation to provisions contained within 24 Monthsthe technical specifications and applicable license conditions.
- b. The adherence to procedures,
- training, and qualification of the 24Mnhstation staff.c. The results of actions taken to correct deficiencies occurring in 24 Monthsfacility equipment, structures,
- systems, components, or methodof operation that affect nuclear safety (CAP).d. The performance of activities required by the Quality Assurance 24 MonthsProgram to meet the criteria of Appendix B of 10OCFR5O.
- Chemistry
- Engineering
-Design Control,* Engineering
-Programs* Procurement
/ Materials Management
- Maintenance
- Nuclear Fuels* Operations
- Quality Assurance Functions (internal and vendor audit\assessment activities are evaluated by NIEP.)e. The fire protection programmatic controls including the 24 Monthsimplementing procedures (by qualified Nuclear Oversight personnel).
- f. The fire protection equipment and program implementation, 24 Monthsincluding loss prevention, utilizing either a qualified offsitelicensee fire protection engineer or an outside, independent fireprotection consultant.
An outside, independent fire protection consultant shall be used at least every second year.g. The Radiological Environmental Monitoring Program (REMP) 24 Monthsand its results.h. The Offsite Dose Calculation Manual (ODCM) and implementing 24 Monthsprocedures.
Page 1 of 3Revision 90 AUDIT FREQUENCY APPENDIX BAUI RQECYAPNI AUDIT FREQUENCY
- i. The Process Control Program (PCP) and implementing 24 Monthsprocedures for the solidification of radioactive wastes.j. The non-radiological environmental monitoring activities required 24 Monthsby the Appendix B of the Facility Operating Licenses.
(Note:Dresden and TMI do not have an Environmental Appendix totheir Facility Operating Licenses.)
- k. Randomly selected procedures to ensure that the programmatic 24 Monthscontrol processes used to assure that procedures are technically and administratively correct prior to use are resulting in timelyand accurate procedure revisions.
I.The Security Plan and implementing procedures per 10CFR73.55 24 MonthsMinimally review each element of the physical protection programat least every 24 months. Including:
(i) Within 12 months following initial implementation of thephysical protection program or a change to personnel, procedures, equipment, or facilities that potentially couldadversely affect security.
(ii) As necessary based upon site-specific
- analyses, assessments, or other performance indicators.
(Reference 10OCFR73.55 and 10OCFR50.54(p)(3)(ii))
- m. The Emergency Plan and implementing procedures (Reference 12 Months10OCFR50.54(t)(1
)(ii) for lesser frequency requirements).
- n. Deletedo. The conformance of Spent Fuel Storage Installation operation to 24 Monthsprovisions contained within the technical specifications andapplicable license conditions and results of actions taken tocorrect deficiencies occurring in facility equipment, structures, syst'ems, components, or methods of operation affecting nuclearsafety (Reference NUREGICR-6407, and 10CFR72, Subpart G)(ISFSI sites only).p. Access Authorization Program (10OCFR73.56) 24 Months(Initial Audit frequency is 12 months and 24 months thereafter)
(Ref. RIS 2005-14)q. Personnel Access Data System (PADS) (10CFR73.56) 24 Months(Initial Audit frequency is 12 months and 24 months thereafter)
(Ref RIS 2005-14)
_______Page 2 of 3Revision 90 AUDITFREQUENCY APPENDIX BAUDIT FREQUENCY
- r. Deleteds. Fitness For Duty (FFD) Program (10CFR26.41) 24 Monthst. Station Black Out (Reg. Guide 1.155, Appendix A)24MnhAudits should be conducted and documented to verifycompliance with design and procurement documents, instructions, procedures,
- drawings, and inspection and testactivities developed to comply with 100FR50.63.
(Dresden,
- LaSalle, Limerick, Oyster Creek, Quad Cities, and Three MileIsland Only)u. Radiation Protection activities as defined in I0CFR20.24Mnh
- v. Plant Operations Review Committee (PORC) 24 Monthsw. Decommissioned Units 24 Monthsx. Cyber Security Program (10CFR 73.55(m)).
24 Months(Initial Audit frequency is 12 months and 24 months thereafter)
Page 3 of 3 Revision 90Page 3 of 3Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX C1.1. Codes and Standards The QAP takes into account the need for special controls, processes, testequipment, tools, and skills necessary to attain the required quality and the needfor the verification of quality by inspection and test. The Codes and Standards listed below represent a listing of quality assurance codes and standards used todefine the quality assurance program.
A general listing of quality assurance related codes and standards, such as: ASME B&PV, ANSI, AWS, and IEEE usedthroughout Exelon at each nuclear site can be found in the applicable site specificUpdated Final Safety Analysis Reports (UFSARs).
The UFSAR should bereferenced to identify site-specific commitments (including dates and/oraddendas) with respect to these codes and standards.
This Quality Assurance Program (QAP) complies with the quality requirements of the following codes andstandards as indicated in site specific UFSARs unless otherwise noted in sub-section 1.3 (the UFSAR may address position specific exceptions or clarifications on a site by site basis).-ANSI N18.1 -1971, "Selection and Training of Nuclear Power PlantPersonnel" (For Braidwood, Byron, Dresden,
- LaSalle, Peach Bottom,Quad Cities, Licensed Operators shall comply only with the requirements of 10 CFR 55) *Dresden,
- LaSalle,
- Oyster Creek (for RP personnel),
- Peach Bottom, *Quad Cities, and *TMI (RP and RP Supervisors only)(* per station Technical Specification, this does not include the LeadHP/RP person, who shall meet Reg. Guide 1.8)-ANSI /ANS 3.1 -1978, "American National Standard for Selection andTraining of Nuclear Power Plant Personnel" (Applicable to Clinton (for non-licensed personnel),
- Limerick, Oyster Creek, and TMI) (For Clinton,Limerick, Oyster Creek, and TMI , Licensed Operators shall comply onlywith the requirements of 10 CFR 55)-ANSI /ANS 3.1 -1981, "Selection, Qualification and Training of personnel for Nuclear Power Plants" Applies to Peach Bottom (for SQRs), LaSalle(for reactor engineers),
and Clinton (for chemistry supervisors).
-For Calvert Cliffs, Ginna, and Nine Mile Point, Licensed Operators shallcomply with the requirements of 10 CFR 55.-ANSI N18.7-1 976 /ANS 3.2, "Administrative Controls and QualityAssurance for the Operational Phase of Nuclear Power Plants."(Applicable to Limerick, Oyster Creek, TMI, and Clinton Only)-ANSI N18.7-1972 "Administrative Controls for Nuclear Power Plants"(Applicable to Peach Bottom Only)-ANSI / ANS 3.2 -1988, "Administrative Controls and Quality Assurance forthe Operational Phase of Nuclear Power Plants."
(Exception
-Exelon willimplement the requirements of 10OCFR26 for control of work hours in lieu ofthose specified in section 5.2.1.7 of this standard.)(Applicable toBraidwood, Byron, Dresden,
- LaSalle, and Quad Cities Only)-ASME NQA-1 (1994) (Revision and Consolidation of ASME NQA-1 -1 989and ASME NQA-2-1 989 Editions)
"Quality Assurance Requirements forNuclear Facility Applications" Part I, "Basic Requirements andPage 1 of 17Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX CSupplementary Requirements for Nuclear Facilities; Part II, "QualityAssurance Requirements for Nuclear Facility Applications;"
and Part Ill,"Nonmandatory Appendices,"
limited to Appendix 2A-1, "Nonmandatory Guidance on Qualifications of Inspection and Test Personnel,"
andAppendix 1 7A-1, Nonmandatory Guidance on Quality Assurance Records."
Exception:
Exelon qualifies personnel in accordance with the applicable editions of the codes and standards accepted by the NRC asidentified in Company NDE procedures and the Station ISIplans in lieu of SNT-TC-1A, June 1980, as specified in NQA-1,1994, Supplement 2S-2.As noted above, the plants in the Exelon Fleet comply with the ANSI standards associated with administrative controls and quality assurance for the operational phase of nuclear power plant operation.
Each plant complies with their specificstandards with the following exception:
The independent review of Technical Specification
- changes, licenseamendments, or Emergency Plan changes shall be performed by the PORC.NSRB review and approval of Technical Specification
- changes, licenseamendments, or Emergency Plan changes is not required.
1.2. Regulatory GuidesAlthough the QAP complies with the regulatory positions and programmatic quality requirements of the Regulatory Guides identified in this section, the sitespecific Clarifications and Exemptions identified in section 1.3 should always beverified by reviewing the applicable site specific Updated Final Safety AnalysisReport (UFSAR).-1 .8, "Personnel Qualification and Training."
-1.26, "Quality Group Classification and Standards for Nuclear PowerPlants."-1.28, "Quality Assurance Program Requirements for Design andConstruction."
-1.29, "Seismic Design Classification."
-1 .31 , "Control of Ferrite Content in Stainless Steel Weld Material"
-1.33, "Quality Assurance Program Requirements."
Exceptions:
Audits will be at the frequency defined in Appendix B of thisQATR and PORC review and approval of new or revised administrative procedures recommended by RG 1.33 is not required.
(Ref. SER fromUSNRC to C.G. Pardee, dated Sept. 29, 2008)-1.68, "Pre-Operational and Initial Start-Up Test Programs for Water CooledReactors."
-1.142, "Safety Related Concrete Structures for Nuclear Power Plants."-1.143, "Design Guidance for Radioactive Waste Management SSCsInstalled in Light Water-Cooled Nuclear Power Plants."-4.15 "quality Assurance for Radiological Monitoring Programs (NormalOperations)
-Effluent Streams and the Environment."
Page 2 of 17 Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX C1.3. Site Specific Clarifications and Exceptions 1.3.1. Limerick (LGS) and Peach Bottom Atomic Power Station (PBAPS)1. Regulatory Guide 1.33," Quality Assurance Program Requirements, (Operations),"
endorses ANSI N18.7.LGS shall comply with Regulatory Guide 1.33, Revision 2, February 1978,and ANSI N 18.7-1976/ANS-3.2, "Administrative Controls and QualityAssurance for the Operational Phase of Nuclear Power Plants"'
during theoperational phase except for the following clarifications or alternatives.
A. ANSI N18.7-1976/ANS-3.2, Section 5.2.2, Procedure Adherence
-The term "supervisor in charge of the shift" means either the ShiftManager or Shift Supervisor.
B. ANSI N18.7-1976/ANS-3.2, Section 5.2.7.1, Maintenance Programs:
- 1. Emergency maintenance to safety-related equipment (workwhich must proceed immediately to correct a degradedcondition) may be performed concurrent with procedure preparation and documentation of steps actually taken. Suchmaintenance may be performed with the authorization ofdesignated personnel and subsequent procedure review by thePORC and/or SQR, per Technical Specification requirements.
- 2. The cause of repetitive malfunctions should be determined;
- however, it is not practical, and may not be possible, todetermine the cause of every malfunction.
C. ANSI N18.7-1976/ANS-3.2, Section 5.2.10, "Housekeeping andCleanliness Control".
- 1. Control measures to prevent contamination with foreignmaterials will be specified in administrative procedures and willinclude, as appropriate, access control.2. Second paragraph, first and second sentences are taken tomean: "Where needed to prevent contamination
.... "D. ANSI N18.7-1976/ANS-3.2, Section 5.2.13, "Procurement andMaterials Control"
-Item (1) -Administrative procedures shall specifythe means for control of procurement of commercially "off-the-shelf' items. The administrative procedures shall describe the receiptinspection,
- storage, and handling prior to installation and operation.
Off-the-shelf (catalog) items are evaluated by qualified personnel fortheir intended use. The administrative procedures restrict the use ofcatalog items for only these evaluated applications.
The purchaseorder shall require the vendor to notify the requisitioning organization of a change in an item described in the catalog.E. ANSI N18.7-1976/ANS-3.2, Section 5.2.13.1, "Procurement DocumentControl,"
(second sentence)
-QA Program requirements or alternate approved methods will be used to ensure quality.
Examples ofalternates for suppliers without QA programs include material
- analysis, Page 3 of 17 Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX Csample testing, in-process inspection and monitoring, and designreview by LGS/PBAPS.
F. ANSI N18.7-1976/ANS-3.2, Section 5.2.15, "Review, Approval andControl of Procedures"
-The frequency of review of plant procedures is discussed in UFSAR Section 13.5, except for the following alternative.
- 1. Programmatic controls and processes described in UFSARSection 13.5 are used to assure that procedures are current.These controls take the place of scheduled periodic reviewsG. Emergency
/ Abnormal procedures do not require biennial reviewbased on the equivalent processes noted in NO-AA-10, Chapter 6,Section 2.1.2. Regulatory Guide 1.143, Revision 1, October 1979, "Design Guidance forRadioactive Waste Management
- Systems, Structures, and Components Installed in Light-Water-Cooled Nuclear Power Plants."LGS shall comply with Regulatory Guide 1.143, Revision 1, October 1979,for major modifications, subject to the exceptions and clarifications listed inLGS UFSAR Table 3.2-1, Note 18.3. ASTM D3843-93, "Standard Practice for Quality Assurance for Protective Coatings applied to Nuclear Facilities."
LGS/PBAPS shall comply with ASTM D3843-93 for safety-related protective coating work in service level 1 areas during operation with thefollowing additional clarification, exception, and requirement.
A. For coating formulations developed prior to issuance of ASTM 03843-93, service level 1 qualification based on ANSI N5.9 (Revised asANSI N512-1 974) and ANSI N101.2 remains valid.B. Section 10.1, last sentence
-instead of references to ANSI 45.2 andNQA-1, inspections will be documented for record purposes asrequired by 10OCFR50, Appendix B, and by this QA programdescription.
C. Limitations on use of coatings and cleaning materials which containelements which could contribute to corrosion, inter-granular
- cracking, or stress corrosion cracking of safety-related stainless steel will befollowed as described in Section C.4 of regulatory Guide 1.54, June1973.4. Branch Technical Position (BTP) CMEB 9.5-1:For modification work performed by Exelon Engineering during the operations phase, Exelon Engineering will maintain compliance with the requirements ofCMEB 9.5-1 in accordance with Section 9.5.1.Page 4 of 17 Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX C5. NQA-1, 1994 Supplement 2S-2PBAPS will comply with NQA-1, 1995 Supplement 2S-2 except for thefollowing clarification.
A. NQA-1, 1995 Supplement 2S-2 states that SNT-TC-IA, June 1980shall apply for personnel performing NDE. PBAPS personnel whoperform ISFSl cask leak testing or approve ISFSI leak testprocedures and test results and direct or supervise the conduct ofISFSI leak tests shall be qualified to either SNT-TC-IA or ANSIN18.1-1 971.1.3.2. Oyster Creek (OCNGS) and Three Mile Island (TMI) Stations1. RG 1.8, Revision 1-R (May 1977), Personnel Selection and Training TMI andOC3GS take the following Exceptions Clarifications.
A. Guidelines have long been established in the company with respect toawarding jobs to plant maintenance, operations, and other bargaining unit personnel who may be involved in testing, examination andinspection activities.
Personnel are qualified in accordance with thejob description manual. Exelon believes that the requirements specified in the job description manual meet the intent, and in manycases, exceed the requirements of ANSI N18.1. It is envisioned thatthere may be certain specific cases where an individual will beconsidered qualified because the individual has been evaluated asbeing capable of performing a job, even though the individual doesnot meet the detailed guidance contained in ANSI N 18.1 with respectto length of experience and formal training.
B. The unit staff and the corporate organizations have been upgraded tomeet ANS/ANSI 3.1-1 978 except as otherwise noted in the technical specifications.
C3. Licensed operators shall comply only with the requirements of 10CEFR 55.Page 5 of 17 Revision 90Page 5 of 17Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX C2. Regulatory Guide 1.26, Quality Group Classification and Standards ForNuclear Power Plants, Rev 3 February 1976. TMI and OCGS will complywith this guide with the following exceptions:
A. For modifications to existing plant systems, items will be classified by site engineering according to the original design basis, or thisguide. This classification will not degrade the safety of the systembeing modified.
B. Additions to existing plant systems will be designed and constructed to the same codes, standards, and technical requirements whichwere originally applied to the system to which the addition is to bemade, or more recent versions of these codes, standards, andtechnical requirements.
The addition will not degrade the safety ofthe system being added to.C. For new construction, the latest applicable codes will be utilized, unless such utilization would result in hardship or unusual difficulty without providing an equivalent level of safety.3. Regulatory Guide 1.33, Rev. 2, February 1978, "Quality Assurance Program Requirements (Operation)."
The stations comply with the Regulatory Position of this Guide with thefollowing clarifications:
A. Paragraph 5.2.2 of ANSI N 18.7-1 976, titled "Procedure Adherence."
In accordance with Section 6.8.3 of the OCNGS and TMI Technical Specifications, temporary changes shall be approved by twomembers of the Company's management staff qualified as a 50.59Evaluator/Reviewer who meets the qualification criteria of QATRAppendix G, Sections 2.2.1.14 and 2.3.1.14 and knowledgeable inthe area affected by the procedure.
For changes, which may affectthe operational status of facility systems or equipment, at least oneof these individuals shall be a member of facility management orsupervision holding a Senior Reactor Operator's License on thefacility.
B. Paragraph 5.2.15 of ANSI N18.7 -1976, titled "Review, Approvaland Control of Procedures."
The third sentence of the thirdparagraph is interpreted to mean that applicable procedures shallbe reviewed following a reportable incident such as an accident, anunexpected transient, significant operator error, or equipment malfunction.
In addition, the fourth paragraph is modified to statethat the periodic review of procedures shall include the following four elements; a) At least every two years, Nuclear Oversight will assess arepresentative sample of plant procedures that are usedmore frequently than every two years.Page 6 of 17 Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX Cb) All applicable plant procedures will be reviewed as described in paragraph no. 5.2.15 of ANSI N18.7-1976 as per the notedclarification described for the third sentence of the thirdparagraph.
c) Plant procedures that have been used at least biennially receive scrutiny by individuals knowledgeable in procedures and are updated as necessary to ensure adequacy duringsuitable controlled activities.
d) Plant procedures that have not been used for two years willbe reviewed before use or biennially to determine if changesare necessary or desirable.
- 4. Regulatory Guide 1.54, June 1973, "Quality Assurance Requirements for Protective Coatings Applied to Water Cooled Nuclear PowerPlants."The OCNGS and TMI QAP complies with this Guide with the following clarifications:
A. The Company will comply with the Regulatory Position established in this Regulatory Guide in that programmatic/administrative quality assurance requirements included therein shall apply tomaintenance and modification activities, even though suchrequirements were not in effect originally.
Technical requirements associated with maintenance and modifications (e.g., coderequirements, material properties, design margins, manufacturing processes, and inspection requirements) shall be the originalrequirements or better.B. The quality assurance program for protective coatings includes theplanned and systematic actions necessary to provide adequateconfidence that shop or field coating work for nuclear facilities willperform satisfactorily in service.C. All protective coatings applied to surfaces within containment, except those noted in 3 below, are tested to demonstrate that theycan withstand LOCA conditions.
These tests are performed inaccordance with Section 4 of ANSI N101.2, "Protective Coatings(Paints) for Light Water Nuclear Reactor Containment Facilities,"
under LOCA conditions, which equal or exceed those described inthe FSAR.D. The quality assurance program is applied to protective coatingsconsistent with the nature and scope of work specified in theTechnical Specifications.
The following elements are included:
- 1. Preparation of coatings specifications and procedures forgeneric coating materials/systems.
- 2. Review and evaluation of coating manufacturers' demonstration test data and quality assurance measures forcontrol of manufacture, identification, and performance verification of applied coating systems.Page 7 of 17 Revision 90 I CODES, STANDARDS, AND GUIDESAPPENDIX C3. Review and evaluation of supplier quality assurance measures to control storage and handling, surfacepreparation, application, touch-up, repair, curing andinspection of the coating systems.4. Training and qualification of inspection personnel in coatingsinspection requirements.
- 5. Supplier surveillance inspection.
E. The coatings qualification program and the associated qualityassurance requirements are necessary only for coatings whosefailure or failure mechanism would have a significant effect onsafety.F. Regulatory Guide 1.54 is not imposed for:1. Surfaces to be insulated.
- 2. Surfaces "contained" within a cabinet or enclosure (forexample, the interior surfaces of ducts).3. Field repair on any Q-class coated item of less than 30square inches surface area, such as; cut ends or otherwise damaged galvanizing; bolt heads, nuts, and miscellaneous fasteners; and damage resulting from spot, tack, or studwelding.4. Field touch-up and repair of larger areas shall be inaccordance with item A.5. Small "production line" items such as small motors, handwheels, electrical
- cabinets, control panels, loudspeakers, etc., where special painting requirements would beimpracticable.
- 6. Stainless steel or galvanized surfaces.
- 7. Coating used for the banding of piping.8. Strippable coatings used for cleanup.G. Quality assurance documentation may not be similar to recordsand documents listed in Sections 7.4 through 7.8 of ANSINI101.4, but will be evaluated to assure that they provide at leastthe same degree of documentation as required by this standard.
- 5. Regulatory Guide 1.58, Rev. 1, September 1980, "Qualifications ofNuclear Power Plant Inspection, Examination, and Testing Personnel."
The OCNGS and TMI QAP complies with this Guide with the following clarifications:
A. Plant operation personnel may be utilized to perform the visualleakage examinations required by the edition of ASME SectionXl and related codes currently committed to for the conduct ofin-service inspections.
Such personnel shall be qualified consistent with these ASME Code requirements.
The selection Page 8ofl17 Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX Cand qualification of such personnel shall be prescribed by aprocedure(s).
B. Not all personnel who review and approve inspection and testingprocedures, evaluate the adequacy of activities to accomplish the inspection and test objectives, evaluate the adequacy ofspecific programs used to train and test inspection and testpersonnel, or certify Level III individuals in specific categories orclasses, will be certified as meeting the Level III capability requirements of ANSI N45.2.6-1 978 (NQA-1).
Rather, thesepersonnel will be determined by management to be fullyqualified and competent to perform these functions through,evaluation of their education, experience and training.
Thebasis for the determination will be documented.
- 6. Regulatory Guide 1.123, Rev. 1, July 1977, "Quality Assurance Requirements for Control of Procurement of Items and Services forNuclear Power Plants."The OCNGS and TMI QAP complies with this Guide with the following clarifications:
A. Section 4.2.a of ANSI N45.2.13-1976.
When evaluation of asupplier is based solely on historical supplier data, these data willprimarily include records that have been accumulated inconnection with previous procurement actions.
Data that includesexperience of users of identical or similar products of theprospective supplier and product operating experience will beused if available.
B. Section 10.2.f, Verification of the Validity of Supplier Certificates and the Effectiveness of the Certification System, is as follows:The verification of the validity of supplier certificates and theeffectiveness of the certification system are accomplished as anintegral part of the total supplier control and product acceptance
- program, and no separate Company system exists that addresses itself solely to such verification.
The degree of verification required will depend upon the type of item or service and theirsafety importance.
The means of verification may include sourcewitness/hold points, source audits, and document reviews;independent inspections at the time of material receipt; user testson selected commodities, such as concrete components; and testson selected components and systems after installation.
All ofthese means verify whether or not a supplier has fulfilled procurement document requirements and whether or not acertification system is effective.
- 7. Regulatory Guide 1.142, October 1981, "Safety-Related ConcreteStructures for Nuclear Power Plants (Other Than Reactor Vessels andContainments)."
A. The Company shall comply with the Regulatory Positionestablished in this Regulatory Guide as augmented by ANSIPage 9 of 17 Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX CN45.2.5, ANSI/ANS 6.4-1977, and ANSI/ACI 318-77 for the designand construction of new Safety Related or Augmented Qualitystructures, and additions to existing Safety Related or Augmented Quality structures.
Inspectors will be qualified according to eitherANSI N45.2.6 or Appendix VII of Section III, Division 2, of theASME Boiler and Pressure Vessel Code.8. Regulatory Guide 1.143, October 1979, "Design Guidance for Radioactive Waste Management
- Systems, Structures and Components Installed inLight-Water-Cooled Nuclear Power Plants."Since OCNGS and TMI were originally designed and constructed todifferent classification criteria than those contained in this Guide; theCompany will comply with the Regulatory Position of this Guide with thefollowing clarifications:
A. For modifications to existing plant systems, items will beclassified by Site Engineering according to the original designbasis, or this Guide. This classification will not degrade thesafety of the system being modified.
B. Additions to existing plant systems will be designed andconstructed to the same codes, standards, and technical requirements which were originally applied to the system to whichthe addition is to be made, or more recent versions of thesecodes, standards, and technical requirements.
The addition willnot degrade the safety of the system being added to.C. For new construction, the latest applicable codes will be utilized, unless such utilization would result in hardship or unusualdifficulty without providing an equivalent level of safety.D. Hose may be used in lieu of pipe where the connections aretemporary.
The anticipated applications of hose would normallybe (1) connections to contractor owned skid mounted radioactive waste processing equipment, (2) connections to a non-mounted, frequently-changed component such as a burial liner/H IC, or (3)connections to non-mounted pieces of radioactive wasteprocessing or collection equipment which must be readilyremovable (e.g., items placed on equipment hatches).
Thepressure rating of such hoses and connections shall equal orexceed those of the systems or components to which they areconnected.
- 1. Prior to use, the hoses shall be hydro-tested to theappropriate pressure for the system or component towhich they will be connected.
After installation, they willreceive regular hydro-testing or in-service inspections.
- 2. A 50.59 review process is required to justify the use ofsuch hose connections.
Page 10 of 17 Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX C1.3.3 Clinton Power Station (CPS)1. The CPS QAPD also includes the following sections of the Operations Requirements Manual (ORM) and the Updated Safety Analysis Report(USAR). The specific sections are as follows:A. ORM Section 6.8.2, Procedures and Programs
-Review andApprovalB. ORM Section 6.8.3, Procedures and Programs
-Temporary ChangesC. USAR Section 13.4D. USAR Table 3.2-12. Site specific clarifications and exceptions applicable to Clinton PowerStation include:A. The CPS USAR Section 1.8, "Conformance to NRC Regulatory Guides",
which provides the CPS project position for implementation of regulatory guides, includes additional clarifications and exceptions to the regulatory guides.B. CPS complies with RG 1.8 (Proposed Rev 2), "Personnel Qualification and Training."
(Also reference USAR Section 1.8.)C. CPS complies with Regulatory Guide 1.33, Rev. 2 (February 1978);"Quality Assurance Program Requirements (Operation)."
CPScomplies with this guide and with the following additional exception:
- 1. ANSI N18.7-1976/ANS-3.2, Section 5.2.17 Inspections:
Duringplant operations emergencies, inspections may be performed under the direction of the duty shift manager.1.3.4 Calvert Cliffs, Ginna, and Nine Mile Point1. Regulatory Guide 1.16, (revision facility
-specific),
"Reporting of Operating Information"
-The commitment to this Regulatory Guide is facility-specific asdescribed in the approved Safety Analysis Report (SAR) or License for eachnuclear facility.
Where items do not conform to the requirements of theRegulatory Guide, they are addressed in the facility specific SAR.2. Regulatory Guide 1.26, Revision (facility
-specific),
"Quality Group Classifications and Standards for Water-, Steam-, and Radioactive Waste-Containing Components of Nuclear Power Plants" -Commitment to Safety/Regulatory Guide1.26 is facility-specific, as required by the approved SAR/License at each nuclearfacility.
Sites may use this guidance to assist in establishing the lists ofequipment to which this QA program applies, or for other purposes.
- 3. Regulatory Guide 1.28, Revision 3, August 1985, "Quality Assurance ProgramRequirements (Design and Construction)"
(ASME NQA-1, 1 983a) -Calvert Cliffs,Nine Mile Point and Ginna will implement the requirements and guidance of thePage 11 of 17Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX Cstandard and Regulatory Guide during the design and construction phases of thefacilities subject to the following:
- a. Regulatory Position C endorses the basic and supplementary requirements of ANSI/ASME NQA-1-1983 and the ANSI/ASME NQA-1a-1983 Addenda.
In place of the specific edition and addenda of NQA-1addressed in the Regulatory Guide, Calvert Cliffs, Nine Mile Point andGinna commit to implement the requirements of NQA-1 -1 994 Part I.Calvert Cliffs, Ginna, and Nine Mile Point are not committed to Part II ofNQA-1 unless otherwise noted. The commitment to these requirements and any exceptions/alternatives to these requirements are addressed inthis QATR.4. In establishing qualification and training
- programs, Calvert Cliffs, Ginna, and NineMile commits to compliance with NQA-1-1994 Basic Requirement 2 andSupplements 2S-1, 2S-2, 2S-3 and 2S-4, with the following alternatives andexceptions:
- a. For Supplement 2S-1: Inspections, examinations or tests may beperformed by individuals in the same organization as that which performed the work, provided that (a) the qualifications of the inspector for an activityare the same as the minimum qualifications for persons performing theactivity, (b) the work is within the skills of personnel and/or is addressed byprocedures, and (c) if work involves breaching a pressure-retaining item,the quality of the work can be demonstrated through a functional test.When a, b and c are not met, inspections, examinations or tests arecarried out by individuals certified in accordance with Supplement 2S-1.Individuals performing visual inspections required by the ASME Boiler andPressure Vessel Code are qualified and certified according to Coderequirements.
- b. In lieu of being certified as Level I, II or Ill in accordance with Non-Mandatory Appendix 2A-1 of NQA-1 -1 994, personnel performing operations phase independent quality verification inspections, examinations, measurements, or tests on material, products or activities, that are in the same organization as that which performed the work, will berequired to possess the same minimum level of qualification as thatrequired for performing the task being verified.
The verification shall bewithin the skills of these personnel and/or is addressed by procedures.
These individuals will also be trained and certified to perform inspections ina manner consistent with a Level I quality inspector.
The inspectors will beauthorized to accept or reject the work being inspected.
The results ofinspections by these individuals will be reviewed by a certified Level II orhigher quality inspector.
These individuals will not be responsible for theplanning of quality verification inspections and tests (i.e. establishing holdpoints and acceptance criteria in procedures, or determining who will beresponsible for performing the inspections),
evaluating inspection trainingprograms, or certifying inspection personnel.
- 5. Regulatory Guide 1.29, Revision (facility-specific)
"Seismic Design Classification"
-Calvert Cliffs, Nine Mile Point and Ginna may have been designed, constructed and licensed based on criteria available prior to this Regulatory Guide beingPage12 of 17 Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX Cissued. The specific design criteria and seismic designations are reflected ineach plant's SAR, and in other docketed analysis.
Thus, the commitment toSafety/Regulatory Guide 1.29 is facility-specific, as required by the approvedSAR/License at each facility.
Sites may use this guidance in establishing the listsof equipment to which this QA program applies, or for other purposes.
- 6. Regulatory Guide 1.30, August 1972, "Quality Assurance Requirements for theInstallation, Inspection and Testing of Instrumentation and Electric Equipment,"
(ANSI N45.2.4-1 972/IEEE 336-1971
):a. Calvert Cliffs, Nine Mile Point, and Ginna commits to ANSI N45.2.4-1972/IEEE 336-1971 in its commitment to Position C of Regulatory Guide1.30.b. As noted in Regulatory Position 0.1, ANSI N45.2.4-1972 is being used inconjunction with NQA-1 -1 994, Part I, which replaced ANSI N45.2.c. As noted in Regulatory Position 0.2, other industry standards may bereferenced.
The commitment in this QATR to ANSI N45.2.4-1 972 includescommitment to those standards to the extent necessary to implement ANSIN45.2.4-1 972 requirements.
If NRC guidance applies to those referenced standards, it is followed.
- d. Consistent with Regulatory Position C.3, the requirements of the endorsedstandard are also considered applicable during the operation phase of thenuclear power plant.e. In lieu of the requirements of the last paragraph of ANSI N45.2.4-1 972Section 6.2.1, the calibration program at Calvert Cliffs, Nine Mile Point andGinna does not use calibration stickers on installed plant instrumentation that contain the date of calibration and identity of person that performed the calibration.
Calibrations of instruments are scheduled and tracked by acomputer database.
- 7. Regulatory Guide 1.33, Revision 2, February 1978, "Quality Assurance ProgramRequirements (Operation)"
(ANSI N 18.7-1 976/ANS-3.2):
- a. NQA-1-1994 Part I contains quality assurance requirements equivalent tothose of ANSI N18.7-1976/ANS-3.2.
Although this QATR complies withthe requirements of NQA-1 -1 994 and ANSI N18.7-1976/ANS-3.2, CalvertCliffs, Ginna and Nine Mile Point does not commit to compliance with therequirements of ANSI N-I18.7-1 976/ANS-3.2 as defined in their SafetyEvaluation Report dated December 21, 2006.b. As recommended by Regulatory Position C.1, Calvert Cliffs, Nine MilePoint and Ginna uses Appendix A of Regulatory Guide 1.33, Revision 2, asguidance in establishing the types of procedures required for plantoperation and support.c. Calvert Cliffs, Nine Mile Point and Ginna's commitment to the applicable Regulatory Guides and associated standards listed in Regulatory Position0.2 is addressed within this QATR. A number of these Regulatory Guidesand standards have been incorporated into NQA-1-1 994 Part I.Page 13 of 17 Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX C8. Regulatory Guide 1.37, Revision (facility-specific),
"Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components ofWater-Cooled Nuclear Power Plants,"
(ANSI N45.2.1-1 973) -The commitment tothis Regulatory Guide is facility-specific as described in the approved SAR orLicense for each nuclear facility.
Where items do not conform to therequirements of the Regulatory Guide, they are addressed in the applicable facility's SAR.9. Regulatory Guide 1.38, Revision (facility-specific),
"Quality Assurance Requirements for Packaging,
- Shipping, Receiving,
- Storage, and Handling ofItems for Water-Cooled Nuclear Power Plants,"
(ANSI N45.2.2-1 972) -Thecommitment to this Regulatory Guide is facility-specific as described in theapproved SAR or License for each nuclear facility.
Where items do not conformto the requirements of the Regulatory Guide, they are addressed in the applicable facility's SAR.a. This alternative applies to Nine Mile Point Nuclear Station (NMPNS).NMPNS commits to ANSI/ASME NQA-2-1 983 Part 2.2, "Quality Assurance Requirements for Packaging,
- Shipping, Receiving,
- Storage, and Handlingof Items for Nuclear Power Plants,"
for nuclear safety-related activities pertaining directly to permanent plant modifications only. NQA-2-1 983Section 7.1 refers to NQA-2-1 983 Part 2.15 for requirements related tohandling of items. The scope of Part 2.15 includes
- hoisting, rigging andtransporting of items for nuclear power plants. This scope exceeds thescope of the NRC's original endorsement of ANSI N45.2.2 in Regulatory Guide 1.38, and establishes requirements for which there is no NRCregulatory position.
In lieu of compliance with Part 2.15, NMPNS iscommitted to the requirements of applicable heavy load reports for NineMile Point Units 1 and 2 that have been approved by the NRC. Unit 2'sreport is a part of the SAR (Appendix 9C). Unit l's is a separate report.10. Regulatory Guide 1.39, Revision 2, September 1977, "Housekeeping Requirements for Water-Cooled Nuclear Power Plants,"
(ANSI N45.2.3-1 973) -Calvert Cliffs, Nine Mile Point and Ginna substitutes NQA-1 -1 994, Subpart 2.3 forN45.2.3 in its commitment to Regulatory Guide 1.39. As noted in Regulatory Position C.1, other industry standards may be referenced; the commitment in thisQATR to NQA-1, Subpart 2.3 includes commitment to those standards to theextent necessary to implement Subpart 2.3 requirements.
If NRC guidanceapplies to those referenced standards, it is followed.
Regulatory Position C.2indicates that the provisions of section 3.2.3 of N45.2.3 are not part of theregulatory endorsement.
As NQA-1, Subpart 2.3, section 3.2.3 has the samewording as N45.2.3; the Regulatory Position is applicable and will be followed inCalvert Cliffs, Nine Mile Point and Ginna's implementation of Subpart 2.3.Regulatory Position C.3 indicates that the endorsed standard is "applicable forhousekeeping activities during the operations phase that are comparable to thoseoccurring during construction."
This is addressed in appendix C of this QATR,which also establishes any necessary exceptions or alternatives to the provisions of Subpart 2.3.a. In lieu of the five-level zone designation in Subpart 2.3, Calvert Cliffs,Ginna, and Nine Mile may base its control over housekeeping activities onPage14 ofl17 Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX Ca consideration of what is necessary and appropriate for the activityinvolved.
The controls are effected through procedures or instructions.
Factors considered in developing the procedures and instructions includecleanliness
- control, personnel safety, fire prevention and protection, radiation control and security.
The procedures and instructions make useof standard janitorial and work practices to the extent possible.
- 11. Regulatory Guide 1.54, Revision (facility-specific),
"Quality Assurance forProtective Coatings Applied to Nuclear Power Plants" (N101 .4-1 972) -Thecommitment to this Regulatory Guide is facility-specific as described in theapproved SAR or License for each nuclear facility.
Where items do not conformto the requirements of the Regulatory Guide, they are addressed in the applicable facility's SAR.12. Regulatory Guide 1.68, Revision (facility-specific),
"Preoperational and InitialStartup Test Programs for Water-Cooled Power Reactors,"
-The commitment tothis Regulatory Guide is facility-specific as described in the approved SAR orLicense for each nuclear facility.
Where items do not conform to therequirements of the Regulatory Guide, they are addressed in the applicable facility's SAR.13. Regulatory Guide 1.94, Revision (facility-specific),
"Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete andStructural Steel During the Construction Phase of Nuclear Power Plants,"
(ANSIN45.2.5-1 974) -Calvert Cliffs, Nine Mile Point and Ginna may have beendesigned, constructed and licensed based on criteria available prior to thisRegulatory Guide being issued. The specific installation, inspection, and testingcriteria are reflected in each plant's SAR, and in other docketed analysis.
Thus,the commitment to Regulatory Guide 1.94 is facility-specific, as required by theapproved SAR/License at each facility.
Facilities may use this guidance to assistin establishing the equipment to which this QA program applies, or for otherpurposes.
- 14. Regulatory Guide 1.116, Revision O-R, May 1977, "Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems,"
(ANSI N45.2.8-1 975) -Calvert Cliffs, Nine Mile Point and Ginnasubstitutes NQA-1-1 994, Subpart 2.8 for N45.2.8 in its commitment to Regulatory Guide 1.116. As noted in Regulatory Position C.1, other industry standards maybe referenced; the commitment in this QATR to NQA-1, Subpart 2.8 includescommitment to those standards to the extent necessary to implement Subpart 2.8requirements.
If NRC guidance applies to those referenced standards, it isfollowed.
Regulatory Position C.2 indicates that the endorsed standard should be"followed for those applicable operations phase activities that are comparable toactivities occurring during the construction phase." This is addressed in AppendixC of this QATR, which also establishes any necessary exceptions or alternatives to the provisions of Subpart 2.8.15. Regulatory Guide 1.143, Revision (facility-specific),
"Design Guidance forRadioactive Waste Management
- Systems, Structures and Components Installed in Light-water-Cooled Nuclear Power Plants" Commitment to Regulatory Guide1.143 is facility-specific, as required by the approved SAR at each facility.
Page 15 of 17Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX CFacilities may use this guidance to assist in establishing the lists of equipment towhich this QA program applies, or for other purposes.
- 16. Regulatory Guide 1.152, Revision 0, November 1985, "Criteria for Programmable Digital Computer System Software in Safety-Related Systems of Nuclear PowerPlants" -Calvert Cliffs, Nine Mile Point and Ginna does not make a commitment to Regulatory Guide 1.152. Calvert Cliffs, Nine Mile Point and Ginna commit toGeneric Letter 95-02, and its endorsement of NUMARC/EPRI Report TR-1 02348,"Guidelines on Licensing Digital Upgrades."
- 17. Generic Letter 89-02/EPRI-NP-5652 (June 1988)- Calvert Cliffs, Nine Mile Pointand Ginna commits to compliance with the endorsed industry guidance regarding selection and qualification of commercial grade suppliers and dedication ofcommercial grade items for use in safety related applications.
- 18. Branch Technical Position CMEB 9.5-1, Revision 2, July 1981 (Positions C.2 andC.4) of the current plants are committed to CMEB 9.5-1. Calvert Cliffs,Nine Mile Point and Ginna plants are committed to the guidance in Appendix A toBranch Technical Position APCSB 9.5-1, "Guidelines for Fire Protection forNuclear Power Plants Docketed Prior to July 1, 1976." However, application ofthe requirements is facility-specific as described in the applicable facility SAR,Fire Protection
- Program, and License documents.
- a. Nine Mile Point Unit 1 is committed tol0 CFR 50.48(c),National FireProtection Association Standard NEPA 805, "Performance Based Standardfor Fire Protection for Light Water Reactor Electric Generating Plants"2001 Edition per NRC License Amendment number 215 to DPR-63(ADAMS Accession number ML14126A003) dated 6/30/2014.
- b. Ginna is committed to10 CFR 50.48(c),National Fire Protection Association Standard NFPA 805, "Performance Based Standard for Fire Protection forLight Water Reactor Electric Generating Plants" 2001 Edition per NRCLicense Amendment number 119 to DPR-1 8 (ADAMS Accession numberML 15271A101 dated 11/23/2015
- 19. Regulatory Guide 4.15, Revision 1, February 1979, "Quality Assurance forRadiological Monitoring Programs (Normal Operations)
-Effluent Streams andthe Environment"
-Calvert Cliffs, Nine Mile Point and Ginna commits tocompliance with the Regulatory Positions of Section C with the following alternatives/exceptions:
- a. In lieu of plotting background parameters and setting predetermined control values for gamma spectroscopy instrumentation as described inRegulatory Position C.6.2, background results may be logged andevaluated to ensure the background does not bias reported results.b. The NRC's independent sampling and analysis program described inRegulatory Position C.6.3.2 may not be performed.
- c. In lieu of performing source check calibrations at least once per 18 monthsas described in Regulatory Position C.7, Calvedt Cliffs, Nine Mile Point andGinna may perform these calibrations at least once per refueling interval.
Page 16 of 17Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX C20. Regulatory Guide 7.10, Revision 1, June 1986, "Establishing Quality Assurance Programs for Packaging Used in the Transport of Radioactive Material"
-CalvertCliffs, Nine Mile Point and Ginna commits to implement the quality assurance guidance for activities related to the packaging and transport of radioactive material that are under its control.
Quality Assurance for the design, fabrication and licensing of shipping containers is the responsibility of the container certificate holders.21. Regulatory Issue Summary 2000-18, October 2000, "Guidance on ManagingQuality Assurance Records in Electronic Media" -Should Calvert Cliffs, Nine MilePoint or Ginna choose electronic media storage as a means of maintaining required
- records, they will comply with the guidance of this Regulatory IssueSummary.22. Calvert Cliffs, Nine Mile Point and Ginna will use the guidance contained inGeneric Letters 91-05 and 89-02/EPRI NP-5652 to procure commercial gradeitems in lieu of these requirements NQA-1 -1994 Supplement 4S-1 andSupplement 7S-1.23. INDEPENDENT SAFETY ENGINEERING GROUP ('ISEG)Independent safety review is performed to meet the individual unit's commitment to NUREG-0737,Section I.B.1.2, "Independent Safety Engineering Group," asdescribed in the unit's safety analysis report, if applicable.
Page 17 of 17 Revision 90IPage 17 of 17Revision 90 I DEFINITIONS APPENDIX D1. SCOPEThis Appendix consists of definitions for words or phrases found in the QAP andprovides a common basis for understanding those words or phrases that mayhave a different meaning when used elsewhere.
All words and phrases aresubject to review and revision, as circumstances require.
Site specific items arenoted.2. GLOSSARY OF TERMS2.1. ApprovalApproval as used herein means by signature or initialing and date by anauthorized individual.
2.2. ASME Boiler and Pressure Vessel Code, Section IRefers to ASME Section I, Power Boilers2.3. ASME Boiler and Pressure Vessel Code,Section III, Division I and Division2 for Concrete Containment Refers to ASME Section III, Division 1 and Division 2 for Concrete Containment; ASME Section III; ASME Code; ASME; or Code.2.4. ASME Boiler and Pressure Vessel Code, Section IVRefers to ASME Section IV, Heating Boilers2.5. ASME Boiler and Pressure Vessel Code, Section VIIIRefers to ASME Section VIII, Pressure Vessels2.6. ASME Boiler and Pressure Vessel Code, Section XlRefers to ASME Section Xl, Rules for In-Service Inspection of Nuclear PowerPlant Components.
2.7. AuditA planned and documented activity performed to determine by investigation, examination, or evaluation of objective evidence the adequacy of andcompliance with established procedures, instructions,
- drawings, and otherapplicable documents, and the effectiveness of implementation.
An audit shouldnot be confused with surveillance or inspection activities performed for the solepurpose of process control or product acceptance.
2.8. Audit Team LeaderAn individual appointed to lead an Audit Team. The Audit Team Leadercoordinates the preparation of the audit report.2.9. AuditorOne qualified and authorized to examine quality assurance practices and verifywhether requirements are being met.Page I of 17Revision 90 DEFINITIONS APPENDIX D2.10. Augmented D (CPS Only)A term applied to those components within the Augmented D boundaries asdefined in the engineering specifications.
See K-2882, USAR Table 3.2.1, andAppendix C of this manual for scope of requirements and boundaries pertaining to Augmented D.2.11. Authorized Inspector or Al or ANIAs used herein is meant to mean Authorized Nuclear Inspector.
An Authorized Nuclear Inspector is an employee of an Authorized Inspection Agency who hasqualifications for and has been properly accredited for Division 1 or Division 2.2.12. Authorized Nuclear In-service Inspector or ANIIAs used herein is meant to mean the Authorized Nuclear In-service Inspector.
An ANII is an employee of an Authorized Inspection Agency who hasqualifications for and has been properly accredited for ASME Section XI.2.13. Balance of PlantGenerating station items and equipment not designed, furnished or installed as apart of the Nuclear Steam Supply System. Balance of Plant items includesafety-related and ASME Code items, such as the containment as well as nonsafety-related and non-ASME Code items.2.14. Basic Component "Basic component",
when applied to nuclear power reactors means a plantstructure, system, component or part thereof necessary to assure (1) theintegrity of the reactor coolant pressure
- boundary, (2) the capability to shut downthe reactor and maintain it in a safe shutdown condition, or (3) the capability toprevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to those referred to in 10CFR1 00.11 Chapter 1(1-1-87),
Part 21.2.15. Bid PackageThe total of drawings, specifications, codes, standards, quality and otherrequirements that describes the task on which a prospective contractor/supplier will bid.2.16. Calibration A method of assuring accuracy of gauges and instruments used for measuring and testing by comparing with recognized standards.
2.17. Certificate of Compliance A written statement signed by a qualified person, attesting that the materials oritems are in compliance with the purchasing documents.
2.18. Certified Personnel Personnel who have passed a formal training program and a formal proficiency test for special processes such as welding, plating and nondestructive testing.Page 2 of 17Revision 90 DEFINITIONS APPENDIX D2.19. Certified Standards Standards of measurement whose accuracy can be traced to standards at theNational Institute of Standards and Technology or established standards.
2.20. Certified Material Test ReportA document attesting that material is in accordance with specified requirements including the actual results of all required chemical
- analyses, tests andexaminations.
2.21. Change OrderA formal award to a vendor or contractor covering revision(s) to the originalPurchase Order or Change Order, involving but not limited to quantity, technical requirements, quality assurance requirements or scope of work.2.22. Change Order Requisition A document describing revisions to be made to the original Purchase Order orsubsequent Change Order and which is converted into a Change Order.2.23. Characteristic Any property or attribute of an item, process or service that is distinct, describable and measurable, as conforming or nonconforming to specified quality requirements.
Quality characteristics are generally identified inspecifications and drawings, which describe the item, process or service.2.24. CodeSee ASME Boiler and Pressure Vessel Code,Section III or Section XI,whichever is applicable.
2.25. codeA recognized standard for using or processing materials, or for the skill involvedin use or processing.
2.26. Cognizant EngineerThe engineer assigned a specific task or area of responsibility in the design ortesting of a component or system.2.27. CornEdCommonwealth Edison Company (an Exelon Company).
2.28. Company Level IllChief Level Ill (NDE) for the Company2.29. Component An item designed and manufactured to perform a specific function within asystem. It consists of a combination of parts and will be combined with othercomponents to form an assembly.
And for ASMEPage 3 of 17Revision 90 DEFINITIONS APPENDIX DASME Code items such as vessels, concrete containments, piping systems,pumps, valves, core support structures and storage tanks which will becombined with other items to form an assembly or installation of a nuclear powerplant.2.30. Component Identification NumberAn identification number assigned (where appropriate) to an item for usethroughout its lifetime.
2.31. Construction Activities at the building site necessary to erect, inspect and accept a powergenerating station and its associated installation.
This definition applies unlessotherwise indicated.
-Construction (ASME Section III Div.1) comprises all activities relating tomaterials, design fabrication, examination,
- testing, inspection andcertification required in the manufacture and installation of items.-Construction (ASME Section III Div. 2) includes all those operations required to build the component and its parts in accordance with theDesign Drawings and Construction Specification which have beenprepared by the Designer (AE).2.32. Construction TestsThose tests necessary to verify that the installation of each component of asystem is complete and complies with the applicable specifications, standards, codes, drawings and engineering information.
2.33. Contract (including purchase order)A binding agreement between two or more persons or companies.
2.34. Contractor Any organization under contract for furnishing items or services.
It includes theterms vendor, supplier, subcontractor, fabricator and sub-tier levels of thesewhere appropriate.
A "Code" contractor is a contractor holding a valid ASMESection III Certificate of Authorization.
2.35. Control PointIn a sequential operation, a checkpoint at which certain data are taken,inspections are made or approval is required.
2.36. Control StampA stamp used to mark a unique identification of inspection or test status uponitems, tags, labels, routing cards or records traceable to an item. Control stampimpressions clearly identify the person who applied it such that traceability totheir authorization is provided.
2.37. Corrective ActionMeasures taken to rectify conditions adverse to quality, and, where necessary, to preclude repetition.
Page 4 of 17Revision 90 DEFINITIONS APPENDIX D2.38. Department When a responsibility is given to a department in this Manual it is meant that thedepartment head has the responsibility.
2.39. Design ChangeAny change in design that may affect functional requirements, operating conditions, safety-,
regulatory-,
reliability-,
and ASME Code-related requirements, performance objectives, plant reliability or design life and wouldrequire that affected documentation be changed.2.40. Design ControlsMethods for assuring that basic design requirements are formalized andtranslated into design documents with proper review to assure the scheduled release of a valid design.2.41. Design CriteriaStatements of the form, function and interface requirements within well definedlimitations.
"2.42. Designer (Division 2)As used in ASME Code Division 2 construction, the Designer (AE) is theorganization responsible for the preparation and completion of the DesignReport, design drawings, and construction specifications for applicable items.2.43. Design Requirements Documents that set the functional requirements, operating conditions, safetyrequirements, performance objectives, design margins and design life. Includedare any special requirements for size, weight, ruggedness, materials, fabrications or constructions,
- testing, maintenance, operating environments, safety margins and derating factors.2.44. Design ReviewAn analysis of design with respect to technical
- adequacy, interface control,inspectability, maintainability and conformance to applicable codes, standards, regulations and design criteria.
2.45. Design Specification A document that sets the functional requirements; design requirements; environmental conditions, including radiation; ASME Code classification; definition of the boundaries; and material requirements.
Sufficient detail shall becontained within the document to provide a complete basis for design.For Section III ASME Code, Division I: A document prepared by the owner orowner's designee which provides a complete basis for construction inaccordance with the ASME Code, Section II1.2.46. Desk SurveyAn evaluation of a supplier's quality control capability made from documented procedures and records of past performance.
Page 5 of 17Revision 90 DEFINITIONS APPENDIX D2.47. Destructive TestA test to determine the properties of a material or the behavior of an item whichresults in the destruction of the sample or item.2.48. Deviation A non-conformance.
Departure of a characteristic from specified requirements.
2.49. Discrepancy A non-conformance.
2.50. Documentation Any written or pictorial information describing,
- defining, specifying, reporting orcertifying activities, requirements, procedures or results.2.51. Drawing ManifestA document for transmitting drawings released for construction to anengineering, construction and/or production organization."
2.52. ErectorAn organization involved in assembling and building equipment or structures atthe site.2.53. Examination Specific actions by qualified personnel using qualified procedures to verify thatitems and fabrication processes are in conformance with specified requirements.
This term, when used in conjunction with qualification of personnel to performquality-related activities shall mean a written examination.
2.54. Extended Quality Assurance Program (CPS Only)The selected use of technical and management controls to improve theoperational performance of equipment important to reliable station operation butnot included in compliance based quality assurance programs.
2.55. Fabricator An organization involved in the manufacture of equipment.
2.56. Fabricator (ASME Section III Div. 2)The NPT Certificate holder2.57. Final Safety Analysis Report (FSAR)A finalization of the preliminary safety analysis report prepared for the NuclearRegulatory Commission prior to issuance of an operating license.2.58. First Level Design ReviewA review conducted by the responsible project engineer within the designagency for a specific design discipline.
Page 6 of 17 Revision 90Page 6 of 17Revision 90 DEFINITIONS APPENDIX D2.59. Flow ChartA representation of the sequence of activities such as procurement, fabrication, processing,
- assembly, inspection and test, or the sequence of individual operations within one or more of those functions.
2.60. Hold PointA designated stopping place during or following a specific activity at whichinspection or examination is required before further work can be performed.
2.61. IncidentOccurrence of major damage, serious personal injury or significant scheduledelay.2.62. Independent ReviewReview completed by personnel not having direct responsibility for the workfunctions under review regardless of whether they operate as a part of anorganizational unit or as individual staff members.2.63. In-service Inspection A mandatory program of examinations,
- testing, inspections and control of repairsand replacements to ensure adequate safety in maintaining the nuclear powerplant and to return the plant to service in a safe and expeditious manner.2.64. Inspection A phase of quality verification that, by means of examination, observation ormeasurement, determines the conformance of materials,
- supplies, components, parts, appurtenances,
- systems, processes or structures to predetermined qualityrequirements.
2.65. Inspection and Test PlanA listing, with optimum sequencing, of all the inspections and tests required tobe performed for a specific item, component, structure or service.2.66. Interface When two or more organizations have responsibilities for accomplishing anactivity, the functional relationship that one organization has to the others incompleting the activity is called an "interface" relation.
One example of interface is when one organization must perform a step, which is a prerequisite to anotherorganization accomplishing its function.
Interface can also mean that severalorganizations accomplishing similar activities are under the coordination controlof one organization.
2.67. Interface controlConsideration that components and structures are geometrically and functionally compatible and those materials are compatible with both process andenvironment.
Page 7 of 17 Revision 90Page 7 of 17Revision 90 DEFINITIONS APPENDIX D2.68. ItemAny level of unit assembly, including structure, system, subsystem, subassembly, component, part or material.
When ASME Code items arereferenced, this means products constructed under a certificate of authorization and material.
2.69. Jurisdictional Boundaries The physical limits of an ASME Code item, which are identified to determine theapplicability of ASME Code rules for that item.2.70. Lifetime RecordA record that meets one or more of the following criteria:
-those that would be of significant value in demonstrating capability forsafe operation;
-those that would be of significant value in maintaining, reworking, repairing, replacing, or modifying an item;-those that would be of significant value in understanding the cause of anaccident or malfunction of an item;-those that provide required baseline data for in-service inspections.
2.71. Like -for -Like Replacement The replacement of an item with an item that is identical in all physical andperformance characteristics.
2.72. Local Purchase OrderA purchase order initiated through the computer by a station for the purchase ofonly Company Stores Coded items.2.73. Maintenance Repair, rework, or replacement of a structure, system or component withequipment of the same design, i.e., meeting the same engineering requirements.
2.74. Maintenance/Modification Work PackageThe complete set of documentation that enables the station to fabricate,
- examine, test and install ASME and safety related items. The work packageconsists of the work request, provisions for station traveler, document checklist and maintenance/modification procedures and supporting information such as,but not limited to, approved
- drawings, design specifications, and special processprocedures.
2.75. MaterialA substance or combination of substances forming components, parts, piecesand equipment.
(Intended to include such things as machinery,
- castings, liquids,formed steel shapes, aggregates and cement.)When ASME Code material is referenced (this refers to metallic materials) whichare manufactured to a SA, SB, or SEA Specification or any other materialspecification permitted by Section III of the ASME Code. For Division 2, refersto metallic materials, as well as to nonmetallic materials, conforming to thespecifications permitted in Section III of the ASME Code.Page 8 of 17Revision 90 DEFINITIONS APPENDIX D2.76. Material SupplierAn organization which supplies material produced and certified by MaterialManufacturers, but does not perform any operations that affect the materialexcept when agreed upon by the Certificate Holder who uses the material inASME Code construction or when so authorized by a Quality System Certificate (Materials).
The Material Supplier may perform and certify the results of tests,examinations,
- repairs, or treatments required by the material specification thatwere not performed by the Material Manufacturer.
2.77. Measuring and Test Equipment (M&TE)Equipment used to quantitatively generate or measure physical or electrical parameters with a known degree of accuracy for the purpose of calibration, inspection, test, or repair of plant mechanical, electrical, or instrument controlequipment.
2.78. Modification A change to an item made necessary by, or resulting in, a change in designrequirements (ASME -NCA 9000). A planned change in plant design oroperation and accomplished in accordance with the requirements and limitation of applicable codes, standards, specifications, licenses and predetermined safety restrictions.
2.79. National Standards Standards maintained at or issued by the National Institute of Standards andTechnology (NIST) or other designated institutions, and the values for naturalphysical constants and conversion factors recommended by NIST.2.80. Non-compliance A failure to comply with a regulatory requirement 2.81. Nonconformance A nonconformance is a deficiency in characteristic, documentation, or procedure that renders the quality of a structure, system, or component (SSC) or activityunacceptable or indeterminate.
Some examples of nonconforming conditions include the following:
-There is failure to conform to one or more applicable codes or standards specified in the UFSAR or procurement documents.
-As-built equipment, or as modified equipment, does not meet UFSARdescriptions or design bases.-Requirements can not be substantiated with proper documentation.
-Physical defects.-Test failures.
-Deviation from prescribed processing, inspection, or test procedures.
2.82. Nonpermanent RecordA record that is required to show evidence that an activity was performed inaccordance with the applicable requirements but do not meet the criteria for alifetime record.Page 9 of 17Revision 90 DEFINITIONS APPENDIX D2.83. NQA -1 (ASME NQA -1)Quality Assurance Program Requirements for Nuclear Facilities.
For ASMESection III activities, NQA -1 is as modified by the ASME Code.2.84. Nuclear Steam Supply System (NSSS)That portion of the nuclear generating plant that provides steam from nuclearheat. It includes the reactor, its control systems, main coolant and steamgeneration
- systems, fuel handling equipment, emergency core cooling systemand other safeguards, associated electrical equipment, instrumentation, spentfuel handling and radioactive waste disposal system.2.85. Objective EvidenceAny statement of fact, information or record, either quantitative or qualitative, pertaining to the quality of an item or service based on observations, measurements or tests that can be verified.
2.86. Operable/Operability A system, subsystem, train, component or device shall be operable or haveoperability when it is capable of performing its specified function(s) and when allnecessary attendant instrumentation,
- controls, electrical power, cooling or sealwater, lubrication or other auxiliary equipment that are required for the system,subsystem, train, component or device to perform its function(s) are alsocapable of performing their related support function(s).
NOTE: Safe operation of the plant is determined by licensed operators.
2.87. Operational TestsTests that are performed during the operations of the plant to verify continued satisfactory performance of safety-related structures, systems and components.
2.88. Personnel Access Data System (PADS)A computerized and restricted access data system used by the domesticcommercial nuclear power industry to share information necessary to processthe applications of workers for unescorted access to nuclear power plants. Thissystem is intended to meet regulatory requirements mandating that certaininformation be available to any power reactor licensee by retaining certainaccess information in a central computer database.
2.89. Permanently Installed Instrument and Control DevicesThe installed plant equipment including computer points used in determining acceptance criteria of Technical Specification surveillances (Category A andSurveillance Instruments for CPS).2.90. Phased Replacement Where several identical items are to be replaced with a new model, they arereplaced a few at a time to allow monitoring of the new items.Page 10 of 17 Revision 90Page 10 of 17Revision 90 DEFINITIONS APPENDIX D2.91. Preliminary Safety Analysis Report (PSAR)The initial detailed safety evaluation prepared for the U.S. Nuclear Regulatory Commission prior to issuance of the site construction permit. The PSARdelineates design, normal and emergency operation, potential accidents andpredicted consequences of such accidents and the means proposed to preventsuch accidents and/or reduce their consequences to acceptable levels.2.92. Pre-Operational TestingPreliminary testing prior to fuel loading and plant operation to assure thatconstruction and installation are complete and to verify design and systemfunctions.
2.93. Procedure A controlled document that specifies or describes how an activity is to beperformed.
It may include methods to be employed, equipment or materials tobe used, accept/reject criteria and sequence of operations.
2.94. Proprietary DesignsDesigns engineered, produced and sold by manufacturers in accordance withtheir criteria and warranty.
2.95. Purchase Requisition The basic document describing a material, component or service that isconverted into a purchase order for procurements.
2.96. Quality Assurance All those planned and systematic actions necessary to provide adequateconfidence that an item or a facility will perform satisfactorily in service.
For theASME Code, Quality Assurance comprises all those planned and systematic actions necessary to provide adequate confidence that all items designed andconstructed are in accordance with the applicable ASME Code.2.97. Quality Assurance Program (QAP)The Quality Assurance Program is the method for complying with the provisions of 10OCFR5O Appendix B for nuclear power plant systems, structures, andcomponents that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. The QualityAssurance Program is defined in the Quality Assurance Topical Report andimplementing procedures.
2.98. Quality Assurance Topical Report (QATR)A NRC approved regulatory document that describes quality assurance programelements for the operational phase of nuclear power plants. This term issynonymous with Quality Assurance Program Description (QAPD), Operation Quality Assurance Program (OQAP), and Quality Assurance Manual (QAM).2.99. Quality ControlSee Quality verification Page 11 of 17Revision 90 DEFINITIONS APPENDIX D2.100. Quality Receipt Inspection ReportA form utilized by station Quality Control to document technical receiptinspection of ASME Code and safety-related items received by the station.2.101. Quality RelatedActivities which influence quality of safety-related items or work related to thosesystems, structures and components as identified in the USAR, Table 3.2-1,including design, purchasing, fabricating,
- handling, shipping,
- storing, cleaning, preserving,
- erecting, installing, inspecting,
- testing, operating, maintaining, repairing, refueling or modifying.
2.102. Quality Verification Those quality assurance examinations and actions that provide a means tocontrol and measure the characteristics of an item, process or facility todetermine or establish conformance to acceptance standards and specified requirements.
2.103. Receipt Inspection An inspection which verifies that items are in satisfactory condition, that theymatch the purchase order requirements and that required documentation accurately reflects the item(s) received.
Visual and physical inspection will beperformed as necessary to determine the acceptability of the item(s).2.104. Receiving Inspection Notice (RIN)A form initiated by the station upon receipt of ASME Code or safety-related items to record inspection for damage, to record receipt of documentation and tonotify station Quality Control that item(s) are available for technical receiptinspection.
2.105. RecordA completed document that:-furnishes evidence of the quality of items or activities.
-furnishes evidence of compliance with regulations or requirements.
-is required by Technical Specifications.
Included are such related documents as drawings, specifications, procurement documents, procedures, operating logs, and reportable occurrences.
Suchdocuments may be originals or reproduced copies.2.106. Registered Professional Engineer (RPE)A person competent in the applicable field of design and qualified in accordance with the requirements of ASME Section III, Appendix XXIII.2.107. RepairThe process of restoring a nonconforming characteristic to a condition such thatthe capability of an item to function reliably and safely is unimpaired, eventhough that item still may not conform to the original requirements.
For ASMESection III items, repair is the process of physically restoring a nonconformance to a condition such that an item complies with ASME Code requirements.
Page 12 of 17Revision 90 DEFINITIONS APPENDIX D2.108. Request for BidInvitation made to suppliers or contractors to bid on a specific task for materials, goods and services.
2.109. Request for PurchaseA generating station's document originated by supervisors or department headsthat designates the required items and services and delineates the designspecifications, applicable codes and standards, as well as, any specialrequirements.
This document is the basis of initiating a Purchase Requisition.
2.110. Resolution (CPS Only)2.111. The process by which a nonconforming item is corrected or determined toadequately perform its design function without adversely affecting safety. Theresolution may contain controls or limitations that are to apply until thenonconformance is fully corrected.
2.112. ReworkThe process by which a nonconforming item is made to conform to a priorspecified requirement by completion, re-machining, and re-assembling usingpreviously approved procedural requirements.
(For ASME Section III, rework issame as repair.)2.113. Safety-Related
- Systems, structures and components, which are considered important to safetybecause they perform safety actions, required to avoid or mitigate theconsequences of abnormal operation transients or accidents.
In addition, designrequirements are placed upon such equipment to assure the properperformance of safety actions, when required (Safety-related items are thosedesignated Seismic Category 1, Safety Class 1, 2, 3, "Other" and Electrical Class 1 E as identified in the CPS USAR, Section 3.2).2.114. Second Level Design ReviewIndependent objective assessment of a design by qualified personnel who haveno direct project responsibility for the design.2.115. Seismic Classification Plant structures, systems and components important to safety which aredesigned to withstand the effects of a safe shutdown earthquake and remainfunctional if they are necessary to assure:-The integrity of the reactor coolant pressure
- boundary, or-The capability to shutdown the reactor and maintain it in a safe condition, or-The capability to prevent or mitigate the consequences of accidents whichcould result in potential offsite exposures comparable to the guideline exposures of 10CFR1 00.(Plant structures, systems and components, including their foundations andsupports, which are designed to remain functional in the event of an SSE aredesignated as Seismic Category 1 as indicated in Table 3.2-1 of the CPSUSAR.)Page 13 of 17Revision 90 DEFINITIONS APPENDIX D2.116. Significant Conditions (adverse to quality)A condition, which if left uncorrected, could have a serious effect on safety oroperability.
2.117. Source Acceptance Acceptance made at a vendor's plant prior to shipment of purchased items.2.118. Source Inspection Inspection carried out at a vendor's plant prior to shipment of purchased items.2.119. Special ProcessA process, the results of which are highly dependent on the control of theprocess or skill of the operator, or both.2.120. Special Process Procedures ManualA compilation of Company procedures governing nondestructive examination and special processes such as welding and heat-treating.
2.121. Specification A concise set of requirements to be satisfied by a product, material or process.The set of requirements may, also, indicate the procedure by which one maydetermine if the given requirements are satisfied.
2.122. Start Up TestsTests that are performed after initial fuel loading and proceed through severalpower level plateaus to 100% power.2.123. Stock MaterialMaterial which is or may be used for conversion to an ASME SA, SB, or SFASpecification or allowable ASTM Specification.
As used in this Program, StockMaterial is that material that has not been produced in accordance with an NCA3800 QA Program.2.124. Stop WorkCollective term used to describe the following three levels of stopping workactivities:
-The stopping of a single or specific work activity by NOS or Linepersonnel.
-A hold imposed by a Department Head on a department or general workactivity.
-A Stop Work Action initiated by the NOS Manager.2.125. Surveillance Examination of supplier's manufacturing, inspection and test operations and ofrecords of work in progress.
This activity is documented.
2.126. SurveyA documented evaluation of an organization's ability to perform activities asverified by a determination of the adequacy of the organization's quality programand by a review of the implementation of that program at the location of work.Page 14 of 17Revision 90 DEFINITIONS APPENDIX D2.127. System Safety Classifications (CPS Only)Structures, systems and components are classified as Safety Class 1, SafetyClass 2, Safety Class 3, Safety Class Other or Class 1 E in accordance with theimportance to Nuclear Safety. Equipment is assigned a specific safety class,recognizing that components within a system may be a differing safetyimportance.
Definitions of various Safety Classes are:2.127.1.
Safety Class 1 (CPS Only)Components of the reactor coolant pressure boundary or core support structure whose failure could cause a loss of reactor coolant at a rate in excess of thenormal make-up system.2.127.2.
Safety Class 2 (CPS Only)Structures, systems and components, other than service water systems, that arenot Safety Class 1, but are necessary to accomplish the safety functions of:1. Inserting negative reactivity to shut down the reactor,2. Preventing rapid insertion of positive reactivity,
- 3. Maintaining core geometry appropriate to all plant process conditions,
- 4. Providing emergency core cooling,5. Providing and maintaining containment,
- 6. Removing residual heat from the reactor and reactor core, or7. Storing spent fuel.2.127.3.
Safety Class 3 (CPS Only)Structures, systems and components that are not Safety Class 1 or Safety Class2, but whose function is to process radioactive fluids and whose postulated failure would result in conservatively calculated offsite doses that exceed 0.5remn to the whole body or its equivalent to any part of the body in accordance with Regulatory Guide 1.26.2.127.4.
Safety Class "Other" (CPS Only)Structures, systems and components used in the power conversion or otherportions of the facility which have no direct safety function, but which may beconnected to or influenced by the equipment within the Safety Classes 1, 2 or 3.2.127.5.
Class 1E (CPS Only)The safety classification of the electric equipment and systems that are essential to emergency reactor shutdown, containment isolation, reactor core cooling andcontainment and reactor heat removal or otherwise are essential in preventing significant release of radioactive material to the environment.
(Structures, systems and component safety classifications and related Quality Assurance Program requirements classifications are summarized in Table 3.2-1 of the CPSUSAR.)2.128. Technical Review (nonconforming item)A determination as to whether a nonconforming item will be accepted "as is",reworked, repaired to an acceptable condition or rejected.
Page 15 of 17Revision 90 DEFINITIONS APPENDIX D2.129. Technical Specification The design and performance criteria and operating limits and principles of anoperating license to be observed during initial fuel loading, critical testing,start-up, power operations, refueling and maintenance operations.
2.130. TestDetermination of the physical and functional properties of an item by subjecting the item to a set of physical,
- chemical, environmental or operating conditions.
2.131. Test PlanAn outline, narrative description or flow diagram indicating the tests to beperformed, the methods to be used and the points in the process where they areto be executed.
It may be in the form of a test procedure.
2.132. Traceability The ability to verify the history,
- location, or application of an item by means ofrecorded identification.
2.133. USARAbbreviation for the Updated Safety Analysis Report, which is the documentsubmitted by the Company to the Nuclear Regulatory Commission inaccordance with 10OCFR50.71.
2.134. Use -As -IsA disposition which may be imposed for a nonconformance when it can beestablished that the discrepancy will result in no adverse conditions to safetyand that the item under consideration will continue to meet all engineering functional requirements including performance, maintainability, fit and safety.2.135. Variation A nonconformance.
Departure of a characteristic from specified requirements.
2.136. Verification The act of confirming, substantiating,
- assuring, and documenting that a task,element, or condition is implemented in conformance with the specified requirements.
Two commonly used type of verification as are described asfollows:-Concurrent Verification is also known as "apart-in-action" because theverification is being done concurrently as the action is implemented.
Concurrent Verification is accomplished when two individuals verify theactions concurrently and apart from each other as they perform the task.Concurrent verification should be used for any action that if performed incorrectly, could result in an immediate threat to personnel safety,nuclear safety, reliable plant operation, or for an activity that can't beverified after it's completed.
-Independent Verification is also known as "apart-in-time" because theverification occurs at some time after the action has been performed.
Anindependent verification is performed at a later time by a second qualified individual who is not part of the initial job performance checking thePage 16 of 17Revision 90 DEFINITIONS APPENDIX Dactions previously performed by others. Independent verification may beused in cases were actions if done incorrectly, could significantly affectnuclear and personnel safety, regulatory or other issues important to safeand reliable plant operations, but would not result in immediate consequences.
2.137. Witness PointsIn a sequential operation, a notification to the Company, or its authorized agent,that a phase of work is about to be reached, so that it may be witnessed at aspecific time, or in process, to verify acceptable performance of the phase.Witness points may be established in the traveler, procedure or in the course ofmonitoring the work activity.
2.138. Work Instructions Actions to be completed by personnel while they are performing specific tasks inareas such as material controls and identification and fabrication or installation of equipment.
2.139. Workmanship That quality of an item expressing its skillful and artful manufacture, withoutapparent blemishes.
Page 17 of 17 Revision 90Page 17 of 17Revision 90 CONTROL OF RADIOACTIVE WASTE APPENDIX EOR MATERIALS (SITE SPECIFIC) 1, SCOPEMeasures shall be established and documented to assure that the requirements of the Code of Federal Regulations, Title 10, Part 71, Title 10, Part 20, and Title49, Parts 100 through 199, applicable to the packaging and transporting ofradioactive wastes or materials are satisfied
- 2. REQUIREMENTS 2.1. GeneralIt is the Company's goal to minimize the generation of radioactive waste,consistent with the ALARA concept to minimize personnel exposures andenvironmental contamination.
The elements contained within this appendixapply to Three Mile Island, Oyster Creek, and Clinton Power StationPart 20, requires that a quality control program be implemented to verifycompliance with Title 10, Part 61.55 (Waste Classification) and Title 10, and Part61.56 (Waste Characteristics).
This Plan shall be implemented to the extentnecessary to assure compliance with those Parts of Title 10, using a gradedapproach.
Subpart H to 10CFR71 identifies the quality assurance criteria applicable to thecontrol of packaging to be utilized to ship radioactive wastes or materials.
Theportions of this Plan that relate to the criteria in Subpart H to 10CFR71 describe, to a large extent, the administrative controls and quality requirements to beapplied in the control, packaging, and transportation of radioactive waste ormaterial.
2.2. Three Mile IslandlOyster Creek2.2.1. Procedures and administrative controls shall be developed and implemented tocover the following:
- 1. Processing of radioactive wastes, including the collection, handling andpreparation for shipment of radioactive liquids and solids. Theseprocedures shall be consistent with the ALARA program and shall clearlyidentify the administrative controls and organizational responsibilities.
- 2. Training and qualification of personnel operating radioactive wasteprocessing equipment, health physics monitoring, packaging and shipping(which includes Waste Classification and establishment of WasteCharacteristics) and other operations deemed appropriate bymanagement.
Page 1 of 4Revision 90 CONTROL OF RADIOACTIVE WASTE APPENDIX EOR MATERIALS (SITE SPECIFIC)
- 3. The activities associated with the packaging of radioactive wastes ormaterials shall include the proper selection of the receptacles to be usedfor containing the waste materials, the selection of the shippingcontainers (structures used to contain and support the receptacle and itscontents),
establishment of Waste Characteristics, radiological controlinspections of the packaging prior to release, proper markings on theoUtside of the package, and the preparation of shipping papers andcertificates.
The activities shall be in accordance with 10CFR20,10CFR61,
- 100FR71, and 49CFR.4. Movement of radioactive wastes or materials within and outside theprotected area to assure personnel protection at all times.5. The shipment of radioactive wastes or materials from the Station shall bein accordance with the regulations of the U.S. Department ofTransportation for the transportation of hazardous materials (49CFR) andof the NRC (10CFR71 and 10CFR20).
- 6. Design, fabrication,
- assembly, testing, and modification of packaging used for transportation of radioactive waste or material which exceed thelimits specified by 10OCFR71
.10 shall not be performed by the Company.Such packaging shall be purchased from an outside supplier and shallcomply with 10CFR71 and 49CFR. The Company shall review andaccept designs of packaging purchased from an outside supplier.
- 7. The packaging used for transporting of radioactive waste or material, which does not exceed the limits specified in 10CFR71.10, whetherpurchased from an outside supplier or designed by the Company, shallmeet 49CFR.8. Minimization of the generation of radioactive wastes through trainingprograms, prudent scheduling and use of equipment and personnel, andgood housekeeping practices.
2.2.2. The carriers to be used for transporting of radioactive waste or material shall beselected on the basis of their experience, knowledge of DOT regulations, controland maintenance of their equipment and the selection and control of theirdrivers.
The carrier is required to have or shall be supplied documented procedures Covering acceptance of radioactive waste or material from a shipper,certification requirements, placarding, storage control, reporting of incidents andsecurity.
The Company shall review and accept carrier procedures specified byprocurement documents covering the acceptance of radioactive waste ormaterial for shipment.
2.2.3. Operations involving radioactive waste processing or radioactive material shallbe controlled to minimize personnel exposures or environmental contamination, consistent with ALARA.Page 2 of 4Revision 90 CONTROL OF RADIOACTIVE WASTE APPENDIX EOR MATERIALS (SITE SPECIFIC) 2.2.4. Operations procedures relating to radioactive waste or material shipping andpackaging shall be reviewed by Quality Verification to establish any necessary inspection points.2.3. Clinton Power Station2.3.1. Radioactive Waste/Augmented "D" Systems.QATR Chapters that are applicable to Radioactive Waste/Augmented "D"Systems are I through 7, 9 through 11, and 13 through 18. Chapters 8 and 12do not apply.1. Chapter 4 -Specification of quality assurance program requirements forsuppliers of radioactive waste/augmented 0 materials, equipment andservices shall be on a case-by-case basis. Commercial grade or off-the-shelf items may provide an acceptable level of quality based on thenature of the item. This determination shall be made by Engineering personnel prior to issuance of procurement documents.
- 2. Chapter 7 -Suppliers providing
- material, equipment and services forRadioactive Waste/Augmented D shall be subject to source evaluation and surveillance.
The extent of imposition of these requirements shall bedetermined on a case-by-case basis by the design organization responsible for review and approval of the procurement specifications.
Measures shall be established, and appropriate, for examination ofproducts upon delivery.
- 3. Chapter 9 -Applicable to the qualification of welders and weldingprocedures (ASME Section IX) for Radioactive Waste systems.(Pressure boundaries only.)4. Chapter 10 -Applicable only to inspection of those items and activities affecting Radioactive Waste/Augmented D systems within the qualityassurance boundaries as specified in the USAR, Table 3.2-1, and furtheramplified by the appropriate design drawings.
2.3.2. Packaging and Transportation of Radioactive MaterialQATR Chapters 1 through 18 are applicable to the packaging and transportation of radioactive material.
- 1. Chapter 3 -Applicable, design activities are not normally performed byCPS for radioactive material packaging,
- however, audits of suppliers establish that the design was accomplished under control of an NRCapproved QA program.Page 3 of 4 Revision 90Page 3 of 4Revision 90 CONTROL OF RADIOACTIVE WASTE APPENDIX EOR MATERIALS (SITE SPECIFIC)
- 2. Chapter 7 -Applicable, measures such as source surveillance and auditsof records should be taken as appropriate to ensure that the design andfabrication of packaging were performed under the control of an NRC-approved QA program.3. Chapter 9 -Applicable, special processes such as welding ornondestructive testing are not normally performed by OPS. However, ifpackaging requires major repairs necessitating use of special processes, e.g., welding or heat treating, measures shall be established to ensurethat the special processes are controlled.
- 4. Chapter 10 -Applicable, visual inspections shall be performed uponreceipt of packaging to ensure compliance with certificates of compliance.
- 5. Chapter 13 -Applicable, all conditions identified in a certificate ofcompliance when using packages shall be adhered to.6. Chapter 16 -Applicable, measures are established for obtaining corrective actions from suppliers and for ensuring that follow-up isdocumented to verify that corrective actions were implemented andeffective.
- 7. Chapter 17 -Applicable, records showing evidence of delivery ofpackages to a carrier and proof that all NRC and Department ofTransportation (DOT) requirements have been satisfied shall also beretained.
- 8. Chapter 18 -Applicable, audits are performed on the supplier ofpackaging to ensure compliance with the certificate of compliance.
Page 4 of 4 Revision 90Page 4 of 4Revision 90 GRADED APPROACH (SITE SPECIFIC)
APNIAPPENDIX F1. SCOPEThe Company establishes measures that provide a graded approach to qualityat Oyster Creek and Three Mile Island Stations.
The extent to which therequirements of this appendix and its associated implementing documents areapplied to an item will be based upon the effect of a malfunction or failure of theitem on nuclear safety or safe plant operations.
- 2. REQUIREMENTS 2.1. GeneralThe quality requirements for items within the scope of this appendix shall beestablished using approved procedures.
Quality requirements will beestablished by the responsible organizational element and subject toassessment by Nuclear Oversight.
The need for special controls, and surveillance or maintaining of processes, equipment and of operational activities will be applied consistent with:-The design and fabrication complexity or uniqueness of the item.-The degree to which functionality can be demonstrated by inspection ortest.-The quality history and degree of standardization of the item.The extent to which the requirements of the QATR apply to activities will bebased, as a minimum, on Operating License conditions and other planspreviously submitted to the NRC for approval, other regulatory commitments asmay have been made associated with activities, the text of this Plan, the unit'sTechnical Specifications, and Appendix C of the QATR.Such other plans or regulatory commitments
- include, but are not limited to, thoseassociated with emergency
- planning, physical plant security, safeguard contingency
- planning, radiological
- controls, radiological environmental
- controls, fire protection, in-service inspection, in-service
- testing, licensed operatorqualification and re-qualification, process control, off-site dose calculation, ShiftTechnical Advisor training, environmental qualification of electrical equipment, security guard training and qualification, etc.2.2. Quality Classification The scope of the Company's QATR includes but is not limited to items andactivities related to safe nuclear plant operation, protection of personnel, andprotection of the public. To ensure consistency in identifying those items andactivities within the scope of the QATR, a classification process has beendeveloped and documented.
This process relies on the use of the terms "SafetyRelated,"
"Augmented Quality,"
and "QATR Scope."Page 1 of 3Revision 90 GRADED APPROACH (SITE SPECIFIC)
APNIAPPENDIX F2.2.1. Nuclear Safety Related or Augmented Quality Items1. Items within the scope of the QATR are designated as "Nuclear SafetyRelated" or "Augmented Quality."
A quality classification process forItems has been developed.
This classification process produces aComponent Record List, which identifies the permanent plant structures,
- systems, and components that are within the scope of the QATR andtheir specific classification.
New Items to which the QATR applies shallbe added to the Component Record List subsequent to their installation.
The classification of structures,
- systems, and components shall besubject to independent design review as part of the classification process.2. Spare or replacement parts and materials are not necessarily classified the same as the component of which they are a part. Such parts andmaterials that perform or contribute to the performance of a SafetyRelated or Augmented Quality function are within the scope of the QATRand classified similar to the component of which it is a part. Forprocurement of spare or replacement parts which are of a different classification, the classification will be determined by Procurement Engineering.
The determinations will be documented,
- retained, andsubject to review and assessment.
- 3. The classification of items and consumable items (such as chemicals, radwaste liners, diesel fuel, etc.) and the technical and qualityrequirements will be specified, documented and approved as part of theprocurement process.4. The QATR may be applied to items, other than those designated as"Safety Related" or "Augmented Quality" as specified by Companymanagement.
2.2.2. QATR Scope Activities
- 1. Activities within the scope of the QATR are designated as within "QATRScope." Activities that are within the scope are those directly related tonuclear and radiological safety and protection of the public and aredelineated below.2. Support activities within the scope of the QATR are quality classification, operating experience assessment, design, maintenance of environmental and fire protection qualification, nuclear fuel management, procurement, fabrication,
- handling, shipping,
- storage, cleaning,
- erecting, installing,
- testing, repairing,
- training, welding, in-service inspection, heat treatment, document
- control, records management, access authorization andfitness-for-duty.
- 3. Operational activities within the scope of the QATR are normal, abnormaland emergency operation, chemistry
- control, core performance monitoring, shift technical advice, equipment
- control, surveillance testing,in-service
- testing, maintenance, housekeeping, fire protection,
- security, Page 2 of 3Revision 90 GRADED APPROACH (SITE SPECIFIC)
APNIAPPENDIX Fradiological
- controls, radiological environmental monitoring, radwastepreparation for shipment, radwaste
- shipment, fuel handling/refueling, technical specification compliance, and emergency preparedness.
- 4. Assurance activities within the scope of the QATR are assessment (audit,document review, monitoring, survey, and surveillance),
inspection, non-destructive examination, and safety review. Individuals who are notdirectly responsible for managing or performing the work or activityperform assurance activities.
Nuclear Oversight personnel performperiodic assessments of the "assurance" activities performed by otherorganizational elements (e.g. NDEIISI) to assure effectiveness andadequacy.
- 5. The above stated activities are controlled through the use of approveddocuments which are, as a minimum, consistent with the requirements ofthe QATR, the unit Operating
- License, specific Regulatory Guides to theextent listed and committed to in Appendix C of the QATR, the FinalSafety Analysis Report, and other regulatory requirements andcommitments.
- 6. A specific task associated with the above activities will be classified aswithin scope of the QATR depending upon:-Statements within the text and the Regulatory Guides identified inAppendix C of the QATR.-The relationship of the task to the safe operation of the nuclearplant.-The relationship of the task to the protection of personnel from theeffects of radiation.
-The relationship of the task to protection of the health and safety ofthe public.-The relationship of the task to regulatory requirements andcommitments.
-Other factors specified by Company management.
Page 3 of 3 Revision 90Page 3 of 3Revision 90 SUPPLEMENTAL APPLICATIONS APNIAPPENDIX G(SITE SPECIFIC)
- 1. SCOPE10OCFR50 Appendix B requires a quality assurance program be established inwriting and executed for activities affecting the safety-related function ofdesignated structures, systems and components to an extent consistent withtheir importance to safety.2. REQUIREMENTS 2.1. Clinton Power Station (CPS)The areas of Environmental, Fire Protection, and Security are specifically identified in Table 3.2-1 of the CPS USAR and/or highlighted in severalRegulatory Guides that define and clarify its importance to the plant.2.1.1. Environmental QATR Chapters 1, 2, 15, 16, and 18 apply to the Environmental area. QATRChapters 3, 10, 11, and 12 do not apply to the Environmental area. QATRChapters 4, 5, 6, 7, 8, 9, 14, and 17 apply to the Environmental area in thelimited manner discussed below.1. Chapter 4 -Applicable to procurement of monitoring services to beperformed by contractors providing services dealing with radiological dataand to radionuclide reference standards used for calibration of radiation measurement systems.2. Chapter 5 -Applicable to all activities related to carrying out theradiological monitoring program including:
sample collection; packaging, shipment and receipt of samples for off-site analysis; procurement, maintenance, storage and use of radioactivity reference standards; calibration and checks of radiation and radioactivity measurement systems; and reduction, evaluation and reporting of data.3. Chapter 6 -Applicable to procedures and instructions required by Chapter5.4. Chapter 7 -Applicable to radionuclide reference standards used forcalibration of radiation measurement systems and to radiological monitoring activities (services) provided by contractors.
- 5. Chapter 8 -Applicable only to radiological sample collection, identification, packaging,
- shipping, receiving, storage and analysis.
- 6. Chapter 9 -Applicable to radioactivity measurements of samples,instrument backgrounds, replicate samples and analytical blanks; dataPage 1 of 3Revision 90 SUPPLEMENTAL APPLICATIONS APNIAPPENDIX G(SITE SPECIFIC) reduction and verification; computer program documentation andverification.
- 7. Chapter 9 -Applicable to laboratory instruments for radiation andradioactivity measurement, continuous radiological effluent monitoring systems and flow-rate measuring devices associated with radiological effluent monitoring systems.8. Chapter 13 -Applicable to radiolog'ical samples only.9. Chapter 14 -Applicable to continuous radiological effluent monitoring systems equipment only.10. Chapter 17 -Applicable to personnel training and qualification; field andin-plant collection of samples; continuous effluent monitoring; samplereceipt and laboratory identification; sample preparation andradiochemical processing; radioactivity measurements of samples,instrument backgrounds and analytical blanks; data reduction andverification; instrument calibration and calibration standards; computerprogram documentation; audits; and corrective action.2.1.2. Fire Protection QATR Chapters that are applicable to the Fire Protection area are 1 through 7,10, 11, and 14 through 18. Chapters 8, 9, 12 and 13 do not apply.1. Chapter 4 -Applicable.
Specification of quality assurance programrequirements for suppliers of fire protection materials, equipment andservices shall be on a case-by-case basis. Commercial grade or off-the-shelf items may provide an acceptable level of quality based on thenature of the item. This determination shall be made by Engineering personnel prior to issuance of procurement documents
- 2. Chapter 7 -Applicable.
Suppliers providing
- material, equipment andservices for fire protection shall be subject to source evaluation andsurveillance.
The extent of imposition of these requirements shall bedetermined on a case-by-case basis by the design organization responsible for review and approval of the procurement specifications.
Measures shall be established, as appropriate, for examination ofproducts upon delivery.
- 3. Chapter 10 -Applicable only to inspection of those items and activities affecting the fire protection system within the quality assurance boundaries as specified in the USAR, Table 3.2-1 and further amplified bythe appropriate design drawings.
- 4. Chapter 17 -Applicable to documents designated as Quality Assurance Records generated in the implementation of the Fire Protection Programand consistent with the requirements identified in Chapter 10 above.Page 2 of 3Revision 90 SUPPLEMENTAL APPLICATIONS APNIAPPENDIX G(SITE SPECIFIC)
- Records are prepared and maintained to furnish evidence that theW applicable criteria discussed herein are being met for activities affecting the Fire Protection Program.5. Chapter 18 -Applicable.
Audits shall be performed and documented toverify compliance with the Fire Protection
- Program, including design andprocurement documents, instructions, procedures and drawings andinspection and test activities.
2.1.3. SecurityQATR Chapters that are applicable to the Security area are 16 through 18.Chapters 1 through 15 do not apply.1. Chapter 17 -Applicable to those records required by the CPS PhysicalSecurity Plan.2. Chapter 18 -Applicable to the physical security of CPS and designated records.2.2 Oyster Creek Nuclear Generating Station (OCNGS)2.2.1 AuditsS1. Independent audits and reviews of Oyster Creek Environmental Technical Specifications (OCETS) will encompass:
A. Coordination of the OCETS with the safety technical specifications toavoid conflicts and maintain consistency.
B. Compliance of station activities and operations with the OCETS.C. Adequacy of the programs and station procedures which are involvedin ensuring the plant is operated in accordance with the OCETS.D. The proper functioning in accordance with the responsibilities listed inSection 3.1 of the OCETS.E. Proposed changes to the OCETS and the evaluation of the impactsresulting from the changes.F. Proposed written procedures, as described in Section 3.4.1 [of theOCETS] and proposed changes thereto which affect theenvironmental impact of the plant.G. Proposed changes or modifications to plant systems or equipment anda determination of the environmental impact resulting from thechanges.H. Adequacy of investigations of violations of the OCETS and adequacyof and implementation of the recommendations to prevent recurrence of the violations.
Page 3 of 3 Revision 90Page 3 of 3Revision 90 ToFacilityAddress: : TMI Department:
DESKPASSPORT DOCUMENTTRANSMITTAL Page: 1111liiill I/l lNi1Ult I iFromAddressCityCountryEmailContactTMI-RM Attention:
Records ManagerRecords Management Exelon NuclearTMI StationMIDDLETOWN State: PA Postal Code: 17057UNITED STATESDate/Time
- 0/2TitleTotal Items: 00001/21 9:5Tasmital Group Id:Trans No. : 000678031 0000102839 Item Facility Type Sub Document Number Sheet Doc Status Revision Doc Date Copy # Media Cpys* 0001 TMI PROC NSP ACTIVE 090 DCl H3 01Marked (*) documents require your acknowledgement.
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If a document was not received or is no longer required check the response below and return to sender.I Documents noted above not received (identify those not received).
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Date: ____________
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GENERAL CONTROLLED COPY -VERIFY BEFORE USEExelon Generation
- Company, LLCQUALITY ASSURANCE TOPICAL REPORT(QATR)NO-AA-1 0Revision 90IExelon NuclearCorporate Headquarters 4300 Winfield RoadWarrenville, IL 60555 This Page Intentionally Left Blank Standard Quality Assurance Topical Report(NO-AA-I1O)
-Revision 90Transmittal and Summary of ChangesTo: All Site Document Control CentersThese changes are approved,
_December 18, 2015, with site and corporate implementation on January 25. 2016.The Quality Assurance Topical Report (QATR) has been revised to:* Clarify the reporting relationship for the Management Position responsible for Licensing and Regulatory Affairs.* Re-organized the corporate and site assessment functions from NuclearOversight to the Organizational Effectiveness and Integrated Performance Assessment group.*"Clarify that the audit function is credited with meeting the appendix Brequirements.
- Include Clinton Station ISFSl requirements.
These changes have been reviewed in accordance with 10QCFR50.54 (a) and didnot reduce Exelon's commitments previously approved by the NRC. (Ref. AT680087-56 and 57 for supporting 50.54(a) evaluations).
This revision to theQATR will be submitted to the NRC for post implementation review as tracked byAction Tracking Number 95188-09.
The specific changes are described as follows:Table of Contentso Updated to coincide with the current revision.
Chapter 1 (Organization) o Section 2.2.3 was revised to include a description for the management position responsible for Regulatory Affairs and General Counsel.o Section 2.2.3.1 was revised to clarify the reporting relationship for themanagement position responsible for Licensing and Regulatory Affairs.o Section 2.2.4.5 was revised to include a description for the management position responsible for Organizational Effectiveness and Integrated Performance Assessment and defines the responsibility for fleetassessments.
o Section 2.2.4.6 was revised to re-organize the corporate and siteassessment functions from Nuclear Oversight to the Organizational Effectiveness and Integrated Performance Assessment groupa Section 2.2.4.6.A was revised to re-organize the reporting relationship forQuality Verification and Employee Concerns from the site NOSorganization to the corporate NOS organization.
Page 1 of 3 Standard Quality Assurance Topical Report(NO-AA- 10) -Revision 90Transmittal and Summary of Changeso Section 2.3.6 was revised to define the site position responsible forassessment activities.
o Section 2.3.7 was revised to define the site position responsible forPerformance Improvement.
o Section 2.4 was revised to clarify that PORO is part of the three-tiered approach for accomplishing oversight of safety.Chapter 18 (AssessmentslAudits) o Entire chapter 18 was revised to clarify that Audits are credited withmeeting our Appendix B and NQA-1 Requirements o Section 1 was revised to clarify audits are performed in accordance withNQA-I.o Section 2.1.1 B was revised to clarify that audits of Emergency Preparedness and Security are not subject to an extension.
o Section 2.1.1 was revised to clarify scheduling for Fleet Assessments.
o Section 2.1 .5.B was revised to define the reporting and follow-up requirements for Fleet Assessments.
o Section 2.2 was revised to clarify that vendors are audited, not assessed.
o Section 2.3 was revised to clarify that the independent review of the statusand adequacy of the QAP is an audit.Appendix A (Augmented Quality)o Section 2.5 was revised to include Calvert Cliffs and Nine Mile Point 1 and2 within the Augmented Quality requirements for Station Blackout.
o Section 2.8.2 was revised to add the ISFSI requirements for ClintonStation.Appendix C (Codes, Standards, and Guides)o Grammatical corrections were made throughout the entire Appendix.
o Section 1.3.4.18 b was revised to define Ginna Stations commitment toNFPA 805.Page 2 of 3 Standard Quality Assurance Topical Report(NO-AA- 1O) -Revision 90Transmittal and Summary of ChangesThis summary is provided to familiarize the readers with the changes included inRevision 90 of the QATR. Personnel engaged in activities covered by the QualityAssurance Program (QAP) are required to review the revised chapters.
Affectedprocedures should be changed and training provided as needed to ensurecompliance with the updated requirements.
Prepared P"Nuclear Oversight Quality Assurance Specialist Approved BY: ________________
o'_S-Rob Radulovich
/ DateNuclear Oversight Audit and Programs DirectorPage 3 of 3 TABLE OF CONTENTSO CHAPTER 1, ORGANIZATION 1 .....SCOPE......................................................................................I 2 .....REQU IREM ENTS ........................................................................
I2.1. Organization
...........................................................................
I2.2. Corporate Organization...............................................................
22.2.1. President and Chief Executive Officer...............................................
22.2.2. Sr. Executive Vice President, Chief Commercial
- Officer, Exelon Corporation, and President and Chief Executive
- Officer, Exelon Generation Company.....
22.2.3. Sr. Vice President Regulatory Affairs and General Counsel.....................
22.2.4. Sr. Executive Vice President and President and Chief Nuclear Officer, ExelonNuclear.........................................................................
32.3. Site Organization......................................................................
102.4. Three-Tiered Approach
..............................................................
142.5. Decommissioning
.............................................................
142.6 Responsibility
.........................................................................
142.7 Authority
......................................................................
15CHAPTER 2, QUALITY ASSURANCE PROGRAM.1 .....SCOPE.....................................................................................
12 .....REQUIREMENTS..........................................................................I 2.1. General.................................................................................
12.2. Supplier's Quality Assurance Program ..............................................
12.3. Planning................................................................................
22.4. Program Description
..................................................................
22.5. Indoctrination
& Training..............................................................
22.6. Program Review.......................................................................
32.7. Quality Assurance Manual ...........................................................
3CHAPTER 3, DESIGN CONTROL1. SCOPE.....................................................................................
- 12. REQUIREMENTS..........................................................................I 2.1 General ................................................................................
12.2 Design Input ...........................................................................
12.3 Design Process........................................................................
22.4 Design Analyses.......................................................................
2.2.5 Design Verification
....................................................................
3O ~2.5.1 Extent of Design Verification
.........................................................
32.5.2 Design Reviews........................................................................
4Page 1 of 8 Revision 90 TABLE OF CONTENTS2.6 Change Control........................................................................
4* 2.7 Design Errors .........................................................................
52.8 Interface Control.......................................................................
52.9 Vendor Design Control ...............................................................
52.10 Modifications...........................................................................
62.11 Documentation and Records .........................................................
6CHAPTER 4, PROCUREMENT DOCUMENT CONTROL1 .....SCOPE.....................................................................................
12 .....REQUIREMENTS
.........................................................................
12.1. General.................................................................................
12.2. Content of Procurement Documents
................................................
12.2.1. Scope of Work .........................................................................
12.2.2. Technical Requirements...............................................................I 2.2.3. Quality Assurance Program Requirements..............1 2.2.4. Non-conformances....................................................................
22.2.5. Documentation Requirements........................................................
22.2.6. Spare and Replacement Parts.......................................................
22.3. Procurement Document Review .....................................................
2.2.4. Procurement Records 3CHAPTER 5, INSTRUCTIONS, PROCEDURES, AND DRAWINGS1 .....SCOPE.....................................................................................
12 .....REQUIREMENTS
.........................................................................
12.1. General ................................................................................
12.2. Preparation and Review...............................................................I 2.3. Procedures and Programs
...........................................................
22.3.1. Technical Review and Control........................................................
22.3.2. On-site Qualified Technical Review (Dresden Unit 1) .........................
....4CHAPTER 6, DOCUMENT CONTROL1 .....SCOPE.....................................................................................
12 .....REQUIREMENTS
.........................................................................
12.1. General.................................................................................
12.2. Reviews ................................................................................
12.3. Controlled Documents
................................................................
2.2.4. Control Measures
......................................................................
22.5. Document Changes...................................................................
3Page 2 of 8 Revision 90 TABLE OF CONTENTSO CHAPTER 7, CONTROL OF PURCHASED
- MATERIAL, EQUIPMENT, ANDSERVICES1.....SCOPE
.....................................................................................
12 .....REQUIREMENTS
.........................................................................
12.1. Supplier Selection......................................................................I 2.1.1. General..................................................................................I 2.1.2. Methods................................................................................
12.2. Bid Evaluations
.......................
................................................
22.3. Supplier In-Process Control..........................................................
22.3.1. General...........................
......................................................
22.3.2. In-Process Control and Verification Planning
.......................................
22.3.3. Programmatic Verification
............
...............................................
32.3.4. Supplier and Verification of Supplier Performance Records.......................
32.3.5. Control of Procurement Changes....................................................
32.4. Acceptance of Purchased Items and
....................................
42.4.1. General ................................................................................
42.4.2. Acceptance by Receiving Inspection
................................................
42.4.3. Acceptance by Source Verification
...................................................
4* ...
byCetfce of Cofrac..........................5...............
2.4.5. Acceptance by Post Installation Testing.............................................
52.4.6. Accep3tance of Services Only .........................................................
52.4.7. Commercial Grade Items.............................................................
62.4.8. Acceptance of Calibration Services............................................
62.5. Presence of Documentary Evidence
................................................
72.6. Spare or Replacement Items.........................................................
72.6.1. Procurement from Other Utilities.....................................................
82.6.2. Maintenance or Modification
.........................................................
8CHAPTER 8, IDENTIFICATION AND CONTROL OF MATERIALS, PARTS,AND COMPONENTS 1I.....SCOPE.......................................
2 .....REQUIREMENTS
.........................................................................
12.1!. General.................................................................................
12.2. Traceability
.............................................................................
I2.3. Identification Methods.
................................................................
I2.4. Transfer of Markings..................................................
................
2.2.5. Limited Life Items ......................................................................
22.6. Stored Items ...........................................................................
2Page 3 of 8 Revision 90 TABLE OF CONTENTS.CHAPTER 9, CONTROL OF SPECIAL PROCESSES 1 .....SCOPE.....................................................................................I 2 .....REQUIREMENTS
.........................................................................
12.1. General..................................................................................I 2.2. Process Control........................................................................
12.3. Special Processes
.....................................................................
I2.4. Personnel Qualification
...............................................................
22.5. Special Process Records.............................................................
3CHAPTER 10, INSPECTION 1 .....SCOPE.....................................................................................I 2 .....REQUIREMENTS
..........................................................................
I2.1. General..................................................................................I 2.2. Inspection Plans.......................................................................
12.3. Inspection Personnel and Qualification
.............................................
22.4. Inspection Process....................................................................
22.5. In-Service Inspections
................................................................
3* 2.6. Independent Verification..............................................................
3CHAPTER 11, TEST CONTROL1 .....SCOPE .....................................................................................
I2 .....REQUIREMENTS
..........................................................................
I2.1. General..................................................................................I 2.1.1. Testing Program.......................................................................
12.1.2. Test Procedures........................................................................I 2.2. Instrumentation and Control ..................................................
........42.3. Electrical Tests ........................................................................
52.4. Mechanical Tests .......................................................................
52.5. Physical and Chemical Tests ........................................................
52.6. Surveillance Tests.....................................................................
62.7. Maintenance or Major Procedure Change..........................................
6CHAPTER 12, CONTROL OF MEASURING AND TEST EQUIPMENT 1.....SCOPE
.....................................................................................
I2 .....REQUIREMENTS
.........................................................................
1O 2.1. General..........................1 2.2. Control ..................................................................................
12.3. Labeling
................................................................................
2Page 4 of 8 Revision 90 TABLE OF CONTENTS2.4. Accuracy...............................................................................
2* 2.5. Traceability and Interval
..............................................................
22.6. Certified M&TE ........................................................................
22.7. Corrective Actions.....................................................................
32.8. Vendor Control ........................................................................
32.9. Commercial Devices..................................................................
32.10. Calibration Records ...................................................................
3CHAPTER 13, HANDLING,
- STORAGE, AND SHIPPING1 .....SCOPE.....................................................................................
12 .....REQUIREMENTS
..........................................................................
I2.1. General .................................................................................
I2.2. Special Equipment and Environments...............................................
12.3. Classification of Items..................................................................I 2.4. Special Handling Tools and Equipment
.............................................
22.5. Marking and Labeling..................................................................
22.6. Storage.................................................................................
2CHAPTER 14, INSPECTION, TEST, AND OPERATING STATUS..CP.....................................................................................
2 .....REQUIREMENTS
.........................................................................
12.1. General.................................................................................
12.1.1. Procedures.............................................................................
22.2. Operating Status .........................................
.............................
22.2.1. Release for Maintenance.............................................................
22.2.2. Preparation for Work ...... ...........................................................
22.2.3. Temporary Modifications
.............................................................
32.2.4. Return to Service ......................................................................
3CHAPTER 15, NONCONFORMING MATERIALS, PARTS, ORCOMPONENTS 1 .....SCOPE..................................................................................
... 12 .....REQUIREMENTS
..........................................................................
I2.1. General..................................................................................I 2.1.1. Supplier Nonconforming Items .......................................................
12.2. Identification
...........................................................................
2.2.3. Segregation............................................................................
22.4. Disposition
...........................................................................
22.4.1. Control..................................................................................
2Page 5 of 8 Revision 90 TABLE OF CONTENTS2.4.2. Evaluation..............................................................................
2.2.4.3. Personnel
..............................................................................
32.4.4. Documentation
........................................................................
32.4.5. Repaired,
- Reworked, or Scrapped Items ...........................................
3CHAPTER 16, CORRECTIVE ACTION1 .....SCOPE......................................................................................I 2 .....REQUIREMENTS
.........................................................................
12.1. General..................................................................................I 2.2. Conditions Adverse to Quality ........................................................
I2.2.1. Significant Conditions Adverse to Quality ............................................
12.3. Verification and Follow-up
.... .......................................................
22.4. Evaluation and Qualification..........................................................
32.5. Documentation and Reporting........................................................
3CHAPTER 17, QUALITY ASSURANCE RECORDS1 .....SCOPE.....................................................................................
12 .....REQUIREMENTS
.........................................................................
1.2.1. Program.............................................................................1...
2.2. Administration..........................................................................I 2.3. Receipt and Transmittal
..............................................................
22.4. Storage and Preservation.............................................................
22.5. Safekeeping and Classification
......................................................
32.6. Retention and Disposition
............................................................
32.7. Plant Operating Records..............................................................
32.7.1. Records and!/ or Logs, 5-Year Retention
...........................................
32.7.2 Lifetime Records ......................................................................
5CHAPTER 18, ASSESSMENTS
/ Audits1 .....SCOPE......................................................................................I 2 .....REQUIREMENTS
......:...................................................................
12.1. Assessments
-General ...............................................................
12.1.1. Scheduling.................
.............................................................
I2.1.2. Preparation.............................................................................
22.1.3. Personnel
..............................................................................
2.2.1.4. Performance
...........................................................................
22.1.5. Reporting and Follow-up..............................................................
32.1.6. Records ................................................................................
4Page 6 of 8 Revision 90 TABLE OF CONTENTS2.2. Vendor Audits..........................................................................
42.3. Independent Management Assessment
........................................
,.... 4APPENDIX A, AUGMENTED QUALITY1 .....SCOPE.....................................................................................
12 .....REQUIREMENTS
.........................................................................
12.1. Health Physics and ALARA (As Low As Reasonably Achievable)................
12.2. Transport of Radioactive W aste ......................................
2.3. Services
................
...............................................................
22.4. Fire Protection
.........................................................................
22.5. Station Blackout (Reg. Guide 1.155) ........................................
........22.6. Augmented Quality Requirements for Dresden 1, and Peach Bottom 1I.........
22.7. Repairs and Alterations...............................................................
32.7.1. State of Illinois
.........................................................................
32.8. Dry Cask Storage System............................................................
42.8.1. Limerick, Peach Bottom, and Oyster Creek ........................................
42.8.2. Braidwood, Byron, Dresden, LaSalle and Quad Cities Station(s).................
42.9 Emergency Planning...........................................................
52.10 Security
...............
- .........................................................5 2.11 License Renewal...............................................................
5APPENDIX B, AUDIT FREQUENCY 1 .....TABLE......................................................................................
1APPENDIX C, CODES, STANDARDS, AND GUIDES1.1. Codes and Standards
.................................................................
11.2. Regulatory Guides ......................................................................
21.3. Site Specific Clarifications and Exceptions..........................................
31.3.1. Limerick (LGS) and Peach Bottom Atomic Power Station (PBAPS) ..............
31.3.2. Oyster Creek (OCNGS) and Three Mile Island (TMI) Stations....................
51.3.3. Clinton Power Station (CPS).........................................................
111.3.4. Calvert Cliffs, Ginna, and Nine Mile Point ......................................
11APPENDIX D, DEFINITIONS 1I.....SCOPE
......................................................................................
I2 .....GLOSSARY OF TERMS .................................................................
1Page 7 of 8 Revision 90 TABLE OF CONTENTS.APPENDIX E, CONTROL OF RADIOACTIVE WASTE OR MATERIALS (SITE SPECIFIC)
- 1. SCOPE ..........................................................................................
I2. REQUIREMENTS.............................................................................
12.1. Generai.................................................................................
12.2. Three Mile Island/Oyster Creek.......................................................I 2.3. Clinton Power Station .................................................................
32.3.1. Radioactive Waste/Augmented "D" Systems .......................................
32.3.2. Packaging and Transportation of Radioactive Waste ..............................
3APPENDIX F, GRADED APPROACH (SITE SPECIFIC) 1 .....SCOPE.....................................................................................
12 .....REQUIREMENTS
..........................................................................
I2.1. General.................................................................................
12.2. Quality Classification...................................................................I 2.2.1. Nuclear Safety Related or Augmented Quality Items ..............................
22.2.2. QATR Scope Activities................................................................
2O APPENDIX G, SUPPLEMENTAL APPLICATIONS(STSPCF) 1.....SCOPE
.....................................................................................
12 .....REQUIREMENTS..........................................................................I 2.1. Clinton Power Station (CPS)..........................................................I 2.1.1. Environmental
....................
....................................................
12.1.2. Fire Protection
...................................................................
22.1.3. Security........................................................................
32.2. Oyster Creek Nuclear Generating Station (OCNGS) ............................
32.2.1. Audits...........................................................................
3Page 8 of 8 Revision 90 EXELON NUCLEARPOLICY1. POLICY STATEMENT The Quality Assurance Topical Report (QATR), NO-AA-1 0, is the highest tiereddocument that assigns major functional responsibilities plants owned oroperated by Exelon Generation
- Company, LLC. Implementing documents assign more specific responsibilities and tasks and define the organizational interfaces involved in conducting activities and tasks within the scope of thisPlan. These requirements apply to those organizations and positions, whichmanage and perform activities within its scope.The Company organization is structured on the basis that the attainment of theobjectives of this Plan relies on those who manage, perform, and support theperformance of activities within the scope of this plan. Assurance of thisattainment relies on those who have no direct responsibility for managing orperforming the activity.
The Company will maintain and operate its nuclear plants in a manner that willensure the health and safety of the public and our workers.
All facilities shall beat a minimum compliance with the requirements on the Code of FederalRegulations, NRC Operating
- Licenses, and the applicable laws and regulations of the state and local governments.
- 2. APPLICABILITY All Company personnel who work directly, or indirectly, for the Company areresponsible for the achievement of quality in their work. Accordingly, allCompany personnel and its contractors engaged in supporting nucleargeneration activities shall comply with the requirements of our Quality Assurance Program (QAP).Page lofI Revision 90Page 1 of IRevision 90 ORGANIZATION CHAPTER 11. SCOPEThis chapter identifies those portions of the Company organization as it appliesto the Quality Assurance Program (QAP), and defines the responsibility andauthority for establishing, executing, and verifying its implementation.
Theresponsibility for the program is retained and executed by the Companyexclusively.
Organizational responsibilities are described for assuring that activities affecting quality are prescribed and implemented by documented instructions, procedures, and drawings.
The achievement of quality in the performance ofquality related activities are the responsibility of each individual in support ofnuclear operations.
The requirements and commitments contained in the QAP are mandatory andmust be implemented,
- enforced, and adhered to by all individuals andorganizations.
- 2. REQUIREMENTS Note: Minor variations may occur between the titles contained herein and those used in practice.
Specific positiondescriptions may be contained in approved Companydocuments.
2.1. Organization
The organizational structure of the Company consists of corporate functions, and the nuclear facilities.
Organizational titles for the quality assurance functions described are identified in Company policies and procedures.
Lines of authority and responsibility are established from the highestmanagement level through intermediate levels to the implementing personnel.
The responsibility, authority, and relationships of the various personnel andorganizations are documented and maintained current.The authority to accomplish the quality assurance functions described hereinmay be delegated to the incumbent's staff as necessary to fulfill the identified responsibilities.
Page 1 ofl6 Revision 90Page 1 of 16Revision 90 ORGANIZATION CHAPTER 12.2. Corporate Organization 2.2.1. President and Chief Executive OfficerThe President and Chief Executive Officer (CEO), Exelon Corporation, isresponsible for overall corporate policy and provides executive direction andguidance for the corporation as well as promulgates corporate policy through theCompany 's senior management staff. A management position responsible forNew Business Development reports to this position through the Sr. Executive Vice President and Chief Strategy
- Officer, Exelon Corporation.
2.2.2. Sr. Executive Vice President, Chief Commercial
- Officer, ExelonCorporation, and President and Chief Executive
- Officer, ExelonGeneration CompanyThe Sr. Executive Vice President, Chief Commercial Officer of ExelonCorporation, President and Chief Executive
- Officer, Exelon Generation, isresponsible for Exelon Generation policy and provides executive direction andguidance for Exelon Generation as well as promulgates corporate policy throughExelon Generation senior management staff. Overall responsibility for theimplementation of the QAP is delegated to the Sr. Executive Vice President, Exelon Generation and President and Chief Nuclear Officer, Exelon Nuclear.2.2.3. Sr. Vice President Regulatory Affairs and General CounselThe Senior Vice President and General Counsel serves as the primary legal andregulatory advisor to the company's senior management with respect to all legaland regulatory matters within his or her area of expertise, sets the companyvision and overall legal strategy for his or her area of expertise, is responsible forall legal and regulatory services relating to one or more practice areas andprovides leadership for and manages attorneys and other legal and regulatory professionals in those practice areas throughout the company.
This positionperforms legal and regulatory services involving high-level or complex legalmatters in his or her practice area. The following management position reports tothis position.
- 1. A management position responsible for licensing and regulatory affairsprovides organizational support and management oversight of the stationsto ensure prompt and proper disposition of regulatory issues, developsregulatory positions and advises senior management on priorities andactivities affecting regulatory issues at the nuclear sites. Otherresponsibilities include developing policies and standardized processes andprocedures for the maintenance of the licensing basis, the preparation ofsubmittals to the NRC and other regulatory organizations, the dissemination of regulatory experience information and the NSRB. Sr. Executive VicePresident, Exelon Generation and President and Chief Nuclear Officer,Exelon NuclearPage 2 of 16 Revision 90Page 2 of 16Revision 90 ORGANIZATION CHAPTER 12.2.4 The Sr. Executive Vice President, Exelon Generation and President and ChiefNuclear Officer (ONO), Exelon Nuclear, reports to the Sr. Executive VicePresident, Chief Commercial
- Officer, Exelon Corporation, and President andChief Executive
- Officer, Exelon Generation Company and has overallresponsibility for the safe and reliable operation of the Company's nuclearstations.
This is the senior executive responsible for setting and implementing
- policies, objectives, expectations, and priorities to ensure activities areperformed in accordance with QAP and other requirements.
The following management positions and committees report to and / or receive direction fromthe CNO with respect to their assigned roles and responsibilities associated withthe execution of the Exelon Nuclear Quality Assurance Program:1. The Chief Nuclear Officer (CNO), CENG Senior Vice President Operations is responsible to provide management and oversight and support of the day-to-day operations of the CENG stations for the safe and efficient operation of the CENG nuclear fleet in compliance with the CENG QAP. In addition, the CNO, CENG is the CENG role for all industry, legal and regulatory requirements for plants owned under the CENG joint venture; and fulfill theacting CEO role reporting to the CENG Board.2. The Chief Operating Officer (COO), Fleet Operations, Exelon Nuclear, isresponsible to provide management oversight and support of the day-to-day operations of the stations for the safe and efficient operation of the nuclearfleet in compliance with the QAP. The COO is responsible for planning, organizing, and directing and controlling the operations, maintenance andimprovement of the nuclear facilities.
This position participates in theformulation of nuclear group strategy and policy, and provides leadership and direction to implement industry best practices.
The following management positions report to the COO:A management position responsible for Mid-Atlantic operations provides management oversight and support of the day-to-day operations of the Mid-Atlantic stations.
This position implements
- policies, goals, and objectives, in accordance with the QAP and otherrequirements, to assure the safe and reliable operation of the Mid-Atlantic nuclear stations This position participates in the formulation ofnuclear group strategy and policy, and provides leadership anddirection to implement industry best practices.
- Management positions responsible for Midwest operations providemanagement oversight and support of the day-to-day operations ofthe Midwest stations.
These positions implement
- policies, goals, andobjectives, in accordance with the QAP and other requirements, toassure the safe and reliable operation of the Midwest nuclear stationsThese positions participate in the formulation of nuclear group strategyPage 3 of 16Revision 90 ORGANIZATION CHAPTER 1and policy, and provide leadership and direction to implement industrybest practices.
- A management position responsible for Nuclear Project Management who is responsible for the oversight and support of Projectmanagement activities for Exelon Nuclear.3. A management position for operations support who is accountable fordefining standard programs and processes, delivering effective servicesand support, providing technical oversight of program implementation, andsupporting the deployment and sharing of best practices throughout thenuclear organization in accordance with the QAP and other requirements, as applicable.
Other responsibilities include providing overall direction andmanagement oversight for environmental issues. Reporting to thisposition is a staff of management, administrative, and technical personnel.
Functional areas of responsibilities include:-security, chemistry, industrial safety, maintenance and workcontrol, outage planning and services, operations, radiation protection, radioactive waste, emergency
- planning, environmental.
-Laboratory services including calibration and maintenance ofmeasuring and test equipment, calibration of radiation protection equipment and test & analysis services.
- 4. The management position responsible for engineering
& technical servicesprovides oversight and support and is accountable for defining standardprograms, processes,
- policies, procedures, delivering effective servicesand support, providing technical oversight of program implementation, andsupporting the deployment and sharing of best practices throughout thenuclear organization in accordance with the QAP, regulatory requirements, and the ASME Code. Reporting to this position is a staff of management, administrative, and technical personnel.
Functional areas of responsibility include;-Engineering that provides support to the nuclear stations, designauthority under the ASME Code, configuration management
- programs, special processes, and generic programs for technical and regulatory issues. A support staff provides the necessary discipline and expert support for setting technical policy,developing design standards, performing engineering discipline
- reviews, and performing the document control and recordsmanagement programs.
This staff develops and supports commonapproaches for technical and regulatory engineering issues, aswell as develops and coaches engineers.
Corporate procurement engineering provides governance and oversight of the nuclearorganization's procurement engineering process and technical operations.
This includes parts evaluation, upgrading of stockmaterial, equivalent item evaluation, and examination and testingPage 4 of 16Revision 90 ORGANIZATION CHAPTER 1in accordance with the applicable ASME Code and FederalRegulations.
-nuclear fuels management providing BWR/PWR nuclear fuelprocurement and fabrication
- services, technical support to monitorfuel reliability and certain in-core components, design and licensing analyses for core reloads, safety analyses, wet and dry spent fuelstorage governance, oversight and technical
- support, long-term spent fuel management strategies, and decommissioning activities including cost estimating, governance, oversight and technical support..
This position is responsible for reactivity management oversight and corporate support of reactor operations to ensuresafe and reliable plant operations, as the manager of nuclearmaterials, and for controls and reports associated with specialnuclear material accountability.
-a management position responsible for license renewal-project management including power uprate and other projects-risk management
- 5. The Management position responsible for Organizational Effectiveness andIntegrated Performance Assessments (OR&IPA).
This position isresponsible for the independent assessment
- program, initiating,
- trending, and recommending solutions for deficiencies, initiating stop work, ordering aunit shutdown, or requesting any other actions deemed necessary to avoidunsafe plant conditions or a significant violation of the QAP, periodicassessments to determine that the Quality Assurance Policy is being carriedout, and maintaining a suitably trained and qualified staff as appropriate.
This position is independent of station responsibilities and is responsible toprioritize and communicate common quality issues to appropriate seniormanagement including the resolution of these issues. The following management positions report to the OR&IPA SVP:PageS of 16 Revision 90Page 5 of 16Revision 90 ORGANIZATION CHAPTER 1-A management position responsible for Organizational Performance, which includes functional results and organizational effectiveness performance.
This position is responsible for theindependent assessment program including regularly scheduled assessments and any assessment required based on analysis ofan emergent performance issues. In addition, this position is alsoresponsible for performance improvement which includes theadministration of the fleet Operational Experience and Corrective Action Programs.
This position maintains authority andresponsibility to escalate issues and stop work or request anyother actions to avoid unsafe plant conditions.
oReporting to the management position forOrganizational Performance is a management position responsible for Fleet Assessments oAlso reporting to the management position forOrganizational Performance is a management position for Performance Improvement.
-A management position responsible for Innovation.
-A management position responsible for Training.
-Maintaining a dotted line reporting relationship to themanagement position responsible for OR&IPA is a management position responsible for Talent Management
& Organization Development (TMOD).6. The management position responsible for Nuclear Oversight (NOS)activities is independent of production and assures that an appropriate QAPis established, maintained, and effectively executed throughout the nuclearorganization.
This position provides overall direction for the implementation of the QAP and for the effective implementation of quality assurance functions that verify activities affecting safety-related functions.
A staff ofsupervisory, administrative, and technical personnel supports assessment and quality verification.
Functional responsibilities include:-employee concern program activities.
-establishing quality assurance practices and policies.
-quality verification activities.
Page 6 of 16 Revision 90Page 6 of 16Revision 90 ORGANIZATION CHAPTER 1-initiating stop work, ordering unit shutdown, or request any otheractions deemed necessary to avoid unsafe plant conditions or asignificant violation of the QAP.-initiating,
- trending, and recommending solutions for deficiencies identified by NOS.-maintaining a trained and qualified staff of personnel within the NOSorganization.
-maintenance and approval of revisions to the Quality Assurance Topical Report (QATR) and the program for employee concerns.
-overseeing nuclear site NOS activities.
-participation in joint membership groups.-periodic audits to determine that the Quality Assurance Policy isbeing carried out.-periodic review of the independent assessment program.-periodically apprising the President and ONO and the Nuclear SafetyReview Board of the status of the quality assurance aspects atCompany facilities and immediately apprise them of significant problems affecting quality.-settling disputes between NOS and other organizations.
-the certifying authority for NOS audit personnel.
-the Independent audit oversight program.-verifying implementation of solutions for significant conditions adverseto quality identified by NOS.A. Reporting to the management position responsible for NOS is amanagement position responsible for auditing and programs.
Functional areas of responsibility include:-maintaining the regulatory required compliance auditingprogram.-maintaining the Quality Verification (QV) program-managing supplier assessments, audits, or surveys (including their sub-tier suppliers) as required.
Verifies that supplierquality assurance programs comply with Companyrequirements and has the authority and responsibility for QAPage 7 of 16Revision 90 ORGANIZATION CHAPTER 1activities applicable to supplier evaluation including, stop workas deemed necessary when a violation of the QAP is identified.
-establishing, maintaining, and interpreting Company qualityassurance policies and procedures
-providing training on quality assurance subjects.
-establishing the requirements for auditor and inspector certification.
-controlling and maintaining the QATR.-provides an offsite point of contact for station QualityVerification personnel if assistance is necessary for qualityverification activities.
-provide management with periodic reports on the adequacy ofthe QAP.-managing implementation of the program for employeeconcerns.
Personnel performing Quality Verification functions including:
- planning, inspecting, and reporting, shall be trained and qualified for their assignedfunctions.
With the exception of receipt inspection activities, inspection personnel shall:-report to the Management Position responsible for QV when performing Quality Verification functions, even though they may functionally report toanother organization for their other assigned activities
-have their qualifications approved by the Management Positionresponsible for QV prior to performing inspection activities.
-not perform independent inspections on any work that they haveperformed or directly supervised.
-be subject to audit by NOS.The receipt inspection activities are controlled by the Nuclear Supplyorganization.
This structure assures adequate independence between performance andverification of activities is maintained.
Page 8 of 16 Revision 90Page 8 of 16Revision 90 ORGANIZATION CHAPTER 17. The Nuclear Safety Review Board (NSRB) is an offsite committee thatreports to and advises the Sr. Executive Vice President, Exelon Generation and President and Chief Nuclear Officer of the results of their independent oversight of plant operations related to safe operation of the station and theCompany's nuclear program relative to nuclear safety. The NSRB isresponsible for the independent safety review function and functions inaccordance with written procedures and instructions which delineates committee composition, responsibility, authority, member qualifications, meeting frequency, subjects to be reviewed, reporting requirements, andadministrative controls under which the board operates.
The NSRB:-conducts independent reviews of station performance andoperations to determine if the facility is being operated andmaintained in a manner that promotes safety and providesfeedback to the organization on suggested improvements.
-focuses primarily in the areas of Operations, Maintenance, Engineering, Plant Support, Regulatory and Nuclear Oversight, orother matters relating to safety.-reviews station materials and activities and advises the CNO andmanagement responsible for NOS on the following activities:
-, any issue potentially affecting the safe operation of the facility.
-station nuclear safety performance determined by discussion andinterviews with station and Exelon Nuclear individuals, plant tours,oversight of meetings, and review of documents distributed forNSRB review.-effectiveness of the station program for oversight including audits,assessments, and self-assessments.
-corrective actions for degraded or non-conforming conditions involving violations of the NRC license requirements, planttransients or forced shutdowns, or the submission of a LicenseeEvent Report (LER).-oversight of activities of the on-site safety review function.
- 8. The management role of Integration, Business Development
- 9. The management role of Strategy and planning10. The management position of strategy with Exelon Nuclear Partners (ENP)Functional areas that also maintain a dotted line report to CNO supporting the ExelonNuclear organization are:* Legal* Human Resources
- Communication
- Information Technology Page 9 of 16Revision 90 ORGANIZATION CHAPTER1Information technology is no longer a functional area exclusively withinthe nuclear organizational structure but now supports the entireExelon Corporation.
The management position responsible foroperations support will supply oversight and governance for thefunctional area of information systems as it applies to Exelon Nuclear.The oversight and governance of this functional area is performed toensure that organizational and functional responsibilities and thereporting relationship to the management position responsible for allnuclear activities, the CNO, is maintained within the requirements stated within the QATR. This includes all regulatory requirements committed to by the QATR. Specifically, the management positionresponsible for operations support supplies oversight and governance for management and supervision of information systems relatedservices and activities including the software quality assurance program (DTSQA).
This includes the creation, acquisition, theenhancement of computer
- hardware, communication, and softwaresystems to support operational requirements.
-The management position responsible for business operations providesintegrated support to senior management and the nuclear sites for allbusiness functions.
This position dotted line reports to the CNO. Reporting to this position is a staff of supervisory, administrative, and technical personnel.
Functional areas of responsibility includes:
-business planning and process improvement.
-communications.
-decommissioning financial reporting and trust fundreimbursements.
Supply is no longer a functional area exclusively within the nuclearorganizational structure but now supports the entire Exelon Corporation andhas a dotted line to the CNO. This management position will supply oversight and governance for the functional area of supply as it applies to ExelonNuclear in the procurement and warehousing areas. The oversight andgovernance of this functional area is performed to ensure that organizational and functional responsibilities and the reporting relationship to themanagement position responsible for all nuclear activities, the CNO, ismaintained within the requirements stated within the QATR. This includes allregulatory requirements committed to by the QATR. The management position responsible for business operations supplies oversight andgovernance for:-the Exelon Nuclear supply function including the establishment ofpriorities and providing operational control of the purchase of non-fuelgoods and services required for nuclear operations.
This organization is also responsible for the areas of material procurement, servicesprocurement, supply programs, inventory management, andinvestment recovery.
Supply establishes
- policies, commonPage 10 of 16Revision 90 ORGANIZATION CHAPTER1administrative controls and processes to ensure compliance withapplicable requirements and effective use of resources.
2.3. Site Organization A management position for each nuclear site reports through the applicable management position responsible for each designated operating group including the MidAtlantic and the Midwest and is responsible for overall plant nuclearsafety and the implementation of the Company's QAP. This position is alsoresponsible for the station compliance with its NRC operating license,governmental regulations, and ASME Code requirements:
Day to-day direction and management oversight of activities associated with the safe and reliableoperation of a nuclear station is provided.
The following site management positions report to the respective Senior Vice President MW Operations orSenior Vice President MA Operations through the Site Plant Manager or SiteVice President.
The Site Vice President has overall responsibility and accountability for the safeand efficient operation of a nuclear power plant. The following positions reportto the Site Vice President 2.3.1. The Plant Manager has the day-to-day responsibility for managing the safe andefficient operation of a nuclear power plant. This management position assuresthe safe, reliable, and efficient operation of the plant within the constraints ofapplicable regulatory requirements, operating
- license, and the QAP.Supervisory direction is provided for the Technical Review Program, including approval of individuals as technical reviewers, and the Plant Operations ReviewCommittee (PORC). During periods that exceed three months, whenunavailable, responsibility is designated in writing to an established alternate who satisfies the experience requirements of this position.
The following positions report to the plant manager:-Operations and Support Including:
- a management position responsible for safe, reliable, and efficient plant operations within the constraints of the operating license andregulatory requirements.
This position is also responsible for thedevelopment and implementation of appropriate controls inaccordance with the QAP and other requirements.
- management position(s) responsible for operations shift crews andadministration, direction and supervision of operating staff. Thisposition is also responsible for routine plant operations activities andevolutions that are performed within the constraints of the operating
- license, the QAP, and other requirements.
Typically this position isthe senior individual on site who holds a Senior Reactor Operatorlicense.Page 11 of 16Revision 90 ORGANIZATION CHAPTER 1*management position(s) responsible for the day-to-day operation ofO the nuclear unit(s) ) including reactor engineering and overallcommand and control of shift activities including operations of theradioactive waste system.*management position(s) responsible for supervision for control of workand of the plant and field supervision that coordinates and/or assists inthe control of shift operations.
This position directs control roompersonnel, field operations, has the primary responsibility forauthorizing removal and restoration of systems to supportmaintenance activities and holds a Senior Reactor Operator License.*a management position responsible for advisory technical support toshift management in the areas of thermal hydraulics, reactorengineering and plant analysis with regards to the safe operations ofthe facility.
In addition, this position shall meet the qualifications asspecified by the NRC.-The management position(s) for maintenance are responsible for theperformance of corrective, predictive and preventive maintenance, cleanliness controls and modification installation of mechanical andelectrical equipment and instrumentation in accordance with the QAP andother requirements.
A staff of supervisory, technical, administrative, and* contract personnel supports day-to-day maintenance of equipment withintheir functional area.-The management position(s) responsible for control of work coordinate, administer,
- execute, and monitor daily and outage work schedules.
Thisposition is also responsible for material management and site supply,which coordinates parts requirements, specifies and evaluates parts,procures all materials for the site, ships and receives
- material, andcontrols the onsite inventory.
The site supply chain provides andcoordinates scope and priority for station procurement engineering efforts.-The management position(s) responsible for chemistry activities, laboratory and system processes, related procedures and programs.
- environmental services.
- radioactive waste.* radiological environmental monitoring
-The management position health physics/radiological protection.
-The management position responsible for performa~nce improvement.
-The management position responsible for safety.2.3.2. The management position for engineering and design has the responsibility andO authority for day-to-day engineering support activities, develops and maintains engineering
- programs, policies, procedures, and provides engineering servicesin accordance with the QAP. A staff of supervisory, technical, and administrative Page 12 of 16Revision 90 ORGANIZATION CHAPTER 1personnel supports maintenance activities.
Functional areas of responsibility include:-design engineering.
-engineering administration.
-modifications and their implementation.
-plant configuration control.-system engineering.
-system testing.technical support.-dotted line accountability for document control and quality assurance records management.
2.3.3. The management position responsible for regulatory assurance maintains aninterface and liaison between the station and federal and state regulators..
Functional responsibilities include:-emergency preparedness 2.3.4. The management position responsible for training provides direction, control,and overall supervision of personnel as required by regulations and training forall site personnel as required.
Functional areas of responsibility include:-learning services.
-maintenance technical training.
-operations training.
2.3.5. The Plant Operations Review Committee (PORC) is a multi-disciplined committee responsible for review of activities that affect nuclear safety, reportsto, and advises the management position responsible for plant operation onmatters related to nuclear safety. The PORC shall ensure that plant activities are conducted safely and do not require NRC review and approval prior toimplementation or changes to the Technical Specifications.
The POROfunctions in accordance with written instructions which delineate committee composition, responsibility, authority, member qualifications, meeting frequency, subjects to be reviewed, reporting requirements, and administrative controlsunder which the group operates.
In discharging its independent review responsibilities, PORC shall keep safetyconsiderations paramount when opposed to cost or schedule considerations.
Should a voting member have direct responsibility for preparation or technical review of the item requiring PORC independent review, where conflict of suchconsiderations is likely, that member shall be replaced (to fill the quorum) byanother voting member not having such potential conflict.
2.3.6. A position responsible for site assessment activities reports to the management position responsible for Fleet Assessments.
This position has the organizational freedom and authority to identify
- problems, has a reporting relationship with thePage 13 of 16Revision 90 ORGANIZATION CHAPTER 1senior management position responsible for overall plant nuclear safety, andensures compliance with QAP and nuclear safety requirements.
Significant safety or quality issues requiring escalated action will be directedthrough the management position responsible for Organizational Effectiveness and Integrated Performance Assessments (OR&IPA)to the President and CNO.This individual, supported by the fleet organization, is functionally responsible for:-authority and responsibility to escalate matters.-conducting independent assessments of line and support activities andsafety reviews.-initiate, trend and recommend solutions for deficiencies identified byOR&I PA.-monitoring day-to-day station activities.
-provide OR&IPA management periodic reports on the status andadequacy of the QAP.-promptly communicate significant issues to OR&IPA and appropriate sitemanagement.
-stop work or request any other actions to avoid unsafe plant conditions.
2.3.7. The Management Position responsible for Performance Improvement.
Functional responsibilities include:-Corrective Action Program-Self-Assessments/Benchmarking
-Operating Experience 2.3.8. The management position responsible for security.
2.3.9. The management position(s) responsible for project management.
2.3.10. The following management positions maintain a dotted line reporting relationship to the Site Vice President.
-The management position(s) responsible for Business Operations.
-The management position(s) responsible for Human Resources.
-The management position(s) responsible for Communications.
2.4 The Company uses a three-tiered approach to accomplish the oversight ofsafety which are:-A collection of program elements for implementing and/or reviewing areasof quality of plant operations and nuclear safety. These elements includesystem performance monitoring, review of operating experience information, operability evaluations, and reviews of changes to technical specifications and final safety analysis reports that affect design bases.Specific guidance is contained in applicable procedures and programs.
Page 14 of 16Revision 90 ORGANIZATION CHAPTER1-A NOS staff who assesses and performs quality verification inspection aspects of Company activities within the scope of the QATR relating tosafety. This provides for an overview of activities affecting or potentially affecting safety.-A PORC which is an on-site committee that reports to and advises thePlant Manager on all matters related to nuclear safety in plant operations.
A NSRB which is an off-site committee that reports to and advises the Sr.Executive Vice President, Exelon Generation and Chief Nuclear Officer,Exelon Nuclear, of the results of independent oversight of plant operation relative to nuclear safety.2.5 Decommissioning Site Organization Similar to the operating units, the management position responsible for plantoperations is also responsible for the management oversight, directing, andimplementing appropriate controls to maintain the site within the requirements and constraints applicable to a permanently shutdown station or unit (or thosestations or units not under the control of an NRC approved decommissioning plan), and to ensure the safe storage of spent nuclear fuel.2.6. Responsibility Each holder of position as identified in this Chapter, has the responsibility for thescope and effective implementation of the QAP and may delegate all or part ofthe activities of planning, establishing, and implementing the QAP to others, butretains the responsibility for the program's effectiveness.
The Company is responsible for ensuring that the applicable portion(s) of theQATR is properly documented,
- approved, and implemented before an activitywithin the scope of the QAP is undertaken by the Company or by others.Personnel performing oversight functions for the Company have theresponsibility, authority, organizational
- freedom, and sufficient independence from cost and schedule to:-assure that further processing,
- delivery, installation, or use is controlled until proper disposition of a nonconformance, deficiency, or unsatisfactory condition has occurred.
-identify quality problems.
-initiate, recommend, or provide solutions to quality problems throughdesignated channels.
-initiate stop work, order unit shutdown, or request any other actionsdeemed necessary to avoid unsafe plant conditions or a significant violation of the QAPPage 15 of 16Revision 90 ORGANIZATION CHAPTER1-verify implementation of solutions for significant conditions adverse toquality.The Company may delegate certain phases of the work to non-company laborand contracted
- services, which act as the Company's agents in assigned areas.They shall work to a Company accepted quality program (or in accordance withthe Company's program) under overall site direction and document theirorganization and any delegated responsibilities necessary to establish, execute,and verify their quality program.
The Company may also assign the authority forcertification and stamping in accordance with the ASME Code.2.7. Authority When the Company delegates responsibility for planning, establishing, orimplementing any part of the overall QAP, sufficient authority to accomplish theassigned responsibilities is delegated.
Regardless of delegation, the Companyretains responsibility.
Page 16 of 16 Revision 90Page 16 of 16Revision 90 QUALITY ASSURANCE PROGRAMCHAPTER21. SCOPEThe purpose of this chapter is to define how the Company's QAP applies tothose activities such as design, procurement, fabrication, installation, modification, maintenance, repair, refueling, operation, inspection, and testsrelated to systems, structures, and components.
The QAP also applies tocertain non-safety related structures,
- systems, components and activities to adegree consistent with their importance to safety. Policies, directives, procedures, guidelines,
- manuals, or instructions shall be reviewed,
- approved, distributed, and revised in accordance with administrative procedures.
- 2. REQUIREMENTS 2.1. GeneralThe QAP comprises all those planned and systematic actions necessary toprovide adequate confidence that structures,
- systems, and components willperform satisfactorily in service.
Quality assurance includes quality verification, which comprises the examination of those physical characteristics of material, structure, component, or system which provide a means to control the quality ofthe material, structure, component, or system to predetermined requirements.
All persons and organizations involved in activities in support of the nuclear sitesand governed by this program are responsible for implementing therequirements of this manual.The QAP is based upon 10OCFR50, Appendix B, "Quality Assurance Criteria forNuclear Power Plants and Fuel Reprocessing Plants."
The requirements of10CFR50.54, "Conditions of License,"
10CFR50.55a, "Codes and Standards,"
10OCFR50.59, "Changes, Test, and Experiments,"
10OCFR50 Appendix A,"General Design Criteria for Nuclear Power Plants,"
10OCFR50 Appendix R, "FireProtection Programs for Nuclear Power Plants,"
are included in the basis for theQAP.The requirements of 10CFR21, Reporting of Defects and Non-Compliance,"
- 10OCFR71, Subpart H, "Quality Assurance for Packaging and Transportation ofRadioactive Material,"
and 10CFR72, Subpart G, "Quality Assurance forLicensing Requirements for the Independent Storage of Spent Nuclear Fuel andHigh-Level Radioactive Waste," are also included.
The Company is committed to carrying out the provisions of various NRC regulatory guides and industrystandards which further define Quality Assurance Program requirements (seeattached Appendix C).2.2. Supplier's Quality Assurance ProgramThe Company's procurement documents require that each vendor, supplier, orcontractor maintain a quality assurance program that satisfies the applicable portions of:Page 1 of 3 Revision 90 QUALITY ASSURANCE PROGRAMCHAPTER 2-ASME NQA-1 and the ANSI N45.2 Standards not covered by NQA-1 orthe ANSI N45.2 series of standards for previously accepted non-ASMEquality assurance programs.
-ANSI N18.7 Standards
-ASME Section III, Appendix XXII for suppliers of ASME Code Designservices.
2.3. PlanningPlanning establishes the systematic, sequential progression of actions to meetthe defined requirements.
The Company documents these plans in appropriate communications, approvals, instructions, and procedures.
Activities described inthe QAP are accomplished under controlled conditions that include appropriate equipment, qualified personnel, suitable environment, and use of appropriate procedures.
2.4. Program Description The Company's total program for providing administrative controls and qualityassurance is incorporated in many diverse documents.
The Company's nucleardocument hierarchy describes the implementation of the QAP. Approvedimplementing procedures and instructions are written to the extent necessary toimplement the quality requirements of 10CFR50 Appendix B. Line, staff,administrative, and quality oversight organizations issue and control theseimplementing procedures.
All activities affecting quality are described insufficient detail to assure quality.2.5. Indoctrination
& TrainingFormal indoctrination and training programs for personnel performing or verifying activities within the scope of this Plan are established and maintained.
Atraining organizational element is established and staffed with qualified instructors and is responsible for planning, scheduling, developing and providing training to Company personnel.
The indoctrination and training programs areestablished by on-site and by off-site organizational units responsible for theperformance or verification of activities within the scope of the QAP.Indoctrination,
- training, and qualification programs are established such that:-personnel responsible for performing quality-affected activities areinstructed as to the purpose, scope, and implementation of the quality-related manuals, instructions, and procedures.
-personnel verifying activities affecting quality are trained and qualified inthe principles, techniques, and requirements of the activity beingperformed.
-formal training and qualification programs documentation includes theobjective, content of the program, attendees, and date of attendance.
Page 2 of 3Revision 90 I QUALITY ASSURANCE PROGRAMCHAPTER2-proficiency tests are given to those personnel performing and verifying activities affecting
- quality, and the acceptance criteria are developed todetermine if individuals are properly trained and qualified.
-certificate of qualification clearly delineates the specific functions personnel are qualified to perform and the criteria used to qualifypersonnel in each function.
-proficiency of personnel performing and verifying activities affecting quality is maintained by re-training, re-examining, re-qualifying, and/or re-certifying as determined by management or program commitment.
2.6. Program ReviewThe effectiveness of the QAP and its implementation is periodically reviewed byvarious organizations at various levels. The results of these reviews aredocumented in reports to senior management for evaluation and corrective action is initiated as required.
The effectiveness of the QAP is evaluated andreported by NOS through the monitoring, assessment, and inspection functions.
Other organizational elements provide additional information!/evaluations asrequested.
2.7. Quality Assurance ManualThis Quality Assurance Manual (QAM) contains the Company's QAP. The QAMis made available to NRC, Company personnel, the Authorized NuclearInspector, and other regulatory authorities.
The Company submits revisions tothe QAP document (as a topical report) to the NRC for acceptance.
Page 3 of 3 Revision 90Page 3 of 3Revision 90 J DESIGN CONTROLCHAPTER 31. SCOPEThe purpose of this chapter is to establish the requirements and controlmeasures for assuring design bases and regulatory requirements are correctly translated into design documents.
The scope of design control covers allphases of engineering design, including:
identification of design inputs (criteria and bases); identification and control of design interfaces; production of designdocuments, calculations and analyses; procurement related engineering anddesign verification.
- 2. REQUIREMENTS 2.1. GeneralThe Company has overall responsibility for design and design control activities including, preparing, reviewing, approving, and verifying design documents related to the plant's structures,
- systems, and components within the scope ofthe QAP. Additionally, the Company is responsible for reactor core designanalysis, core design specifications and design reviews, for nuclear fuel andin-core components.
Qualified personnel perform detailed design activities or review and controldesign work involving electrical, mechanical, structural, and instrumentation andcontrol designs.
Design activities are conducted to written procedures thatinclude consideration of quality standards, quality assurance requirements, suitability of material parts, equipment, and processes, control of designinterfaces, analytical or testing requirements, design basis, and configuration management.
2.2. Design InputThe Company has the responsibility to properly translate applicable safetyanalysis
- reports, regulatory requirements, ASME Code requirements, anddesign bases into specifications,
- drawings, procedures and instructions.
TheCompany is responsible for electrical, mechanical, structural, instrumentation and control; nuclear engineering activities involved in nuclear stationmodifications, and also maintains a configuration management program.Design inputs, such as design bases, performance requirements, regulatory requirements, codes, and standards shall be identified and documented.
Theirselection shall be reviewed and approved by the responsible designorganization.
The design input shall be specified and approved in a timelymanner and be to the level of detail necessary to provide a consistent basis formaking design decisions, accomplishing design verification, and evaluating design changes.
Changes from approved design inputs, including the reason forthe changes shall be identified,
- approved, documented, and controlled.
Page 1 of 6Revision 90 DESIGN CONTROLCHAPTER 32.3. Design ProcessThe Company is responsible for design changes, performs detailed designactivities, and issues design documents in accordance with approvedprocedures.
The responsible design organization shall prescribe and documentdesign activities in a timely manner and to the level of detail necessary to permitverification that the design meets requirements.
Included in this scope of activities are considerations for field designengineering, fire hazards, human factors,
- physics, seismic, stress, compatibility of materials, application of special process, associated computer
- programs, thermal, hydraulic, ALARA and radiation
- factors, the safety analysis accidentscenarios, and accessibility for in-service inspection, maintenance and repairs,and quality standards.
Design documents shall be adequate to support facilitydesign, construction, and operation.
Selection of the appropriate qualitystandards shall be documented, reviewed and approved.
Reasons for changes from specified quality standards, shall be identified, documented, approved and controlled.
Design methods, materials, parts,equipment, and processes that are essential to the function of the structure, system, or component shall be selected and reviewed for suitability ofapplication.
Applicable industry experience, as set forth in reports or otherdocumentation, shall be made available to cognizant design personnel.
The final design output documents and approved changes thereto shall berelatable to the design input by documentation in sufficient detail to permitdesign verification.
The final design shall identify assemblies and/orcomponents that are part of the item being designed.
If materials, parts,equipment, or processes are different from the published supplier information, these differences shall be documented.
Commercially standard (catalog items) materials, parts, or equipment, whichhave been previously approved for different applications, are reviewed forsuitability in the design process.2.4. Design AnalysesDesign analyses shall be performed in a planned, controlled, and documented manner. Design analysis documents shall be legible and suitable forreproduction, filing, and retrieval.
They shall be sufficiently detailed as topurpose, method, assumptions, design input, references, and units such that aperson technically qualified in the subject can review, understand the analysis, and verify the adequacy of the results without recourse to the originator.
Calculations shall be identified for retrievability by subject including structure, system, component, originator,
- reviewer, and date or by other unique identifiers.
Page 2 of 6 Revision 90Page 2 of 6Revision 90 DESIGN CONTROLCHAPTER 3Computer programs shall be controlled to assure that changes are documented and approved.
Verification shall be required for changes to previously verifiedcomputer programs including evaluation of the effects of these changes asspecified below.Computer programs may be utilized for design analysis without individual verification of the program for each application provided:
-the computer program has been verified to show that it produces correctsolutions for the encoded mathematical model within defined limits foreach parameter employed.
-the encoded mathematical model has been shown to produce a validsolution to the physical problem associated with the particular application.
2.5. Design Verification Design control measures shall be applied to verify the adequacy of design, suchas by one or more of the following:
-performance of design reviews.-use of alternate calculations.
-performance of qualification tests.The results of design verification shall be documented the identification of the verifier.
Design verification shall be performed by competent individual(s) other than those who performed the original design but may be from the sameorganization.
This verification may be performed by the originator's supervisor, provided the supervisor did not specify a singular design approach, rule outcertain design considerations, did not establish the design inputs used in thedesign, or the supervisor is the only individual in the organization competent toperform the verification.
Cursory supervisory reviews do not satisfy the intent ofdesign verification.
Verification shall be performed in a timely manner. Design verification, for thestage of design activity accomplished, shall be performed prior to release forprocurement, manufacture, construction, or release to another organization foruse in other design activities provided sufficient data exists. Any unverified portion of the design shall be identified and controlled.
In all cases the designverification shall be completed prior to relying upon the component, system,structure, or computer program to perform its function.
2.5.1. Extent of Design Verification The extent of the design verification required is a function of the importance tosafety, the complexity of the design, the degree of standardization, the state ofthe art, and the similarity with previously proven designs.Page 3 of 6 Revision 90Page 3 of 6Revision 90 DESIGN CONTROLCHAPTER 3Where the design has been subjected to a verification
- process, the processneed not be duplicated for identical designs.
For each application theapplicability of standardized or previously proven designs for design inputs shallbe verified.
Known problems affecting the standard or previously proven designs and theireffects on other features shall be considered.
The original design andassociated verification shall be adequately documented and referenced insubsequent applications.
Design verification shall be required for changes to previously verified designs.This includes evaluation of the effects of those changes on the overali designand on any affected design analyses.
2.5.2. Design ReviewsVerification consists of a check of design adequacy by such methods as designreviews, use of alternate calculations or methods, or performance of verification or qualification testing.
The method, or combination of methods, used to verify adesign will be selected on a case-by-case basisAcceptable verification methods include one or more of the following items:-alternate calculations using alternate methods that verify the correctness of original calculations or analyses.
-critical design reviews providing assurance that the final design is correctand satisfactory.
-where design adequacy is to be verified by qualification tests, the testsare iden'tified.
2.6. Change ControlChanges to final designs, field changes, modifications to operating facilities, andnonconforming items dispositioned use-as-is or repair shall be justified andsubject to design control measures commensurate with those applied to theoriginal design.These measures shall include assurance that the design analyses for thestructure, system, or components are still valid. A 10OCFR50.59/72.48 review isperformed for changes to the facility.
Changes shall be approved by the same affected groups or organizations, whichreviewed and approved the original design documents.
In the case where theoriginal organization is no longer responsible for design approval, then a newresponsible design organization shall be designated.
The designated organization shall have demonstrated competence in the specific design area ofinterest and have an adequate understanding of the requirements and intent ofthe original design.Page 4 of 6Revision 90 DESIGN CONTROLCHAPTER 3When a design change is approved, other than by revision to the affected designdocuments, measures shall be established to incorporate, where appropriate thechange into these documents.
Plant personnel will be made aware of designchanges/modifications, which may affect the performance of their duties. Wherea significant design change is necessary because of an incorrect design, thedesign process and verification procedure shall be reviewed and modified asnecessary.
2.7. Design ErrorsThe Company detects deficiencies or errors in design or in the design qualityassurance program by:-actual failure during operation.
-assessments.
-design verification measures.
-other means.-personnel using the design documents.
-tests conducted.
2.8. interface ControlDesign interfaces shall be identified and controlled.
The Company shallcoordinate design efforts among the participating organizations.
Interface controls shall include the assignment of responsibility and the establishment ofprocedures among participating design organizations.
Controls shall beestablished for the review, approval,
- release, distribution and revision ofdocuments involving design interfaces.
Design information transmitted acrossinterfaces shall be documented and controlled.
2.9. Vendor Design ControlThe Company reviews and accepts the specifications and drawings forelectrical, mechanical, instrumentation, nuclear and structural
- material, equipment, and erection work, prepared by the Architect Engineer and NSSSSupplier.
The purpose of these reviews is to verify inclusion of inspection, testing and acceptance criteria.
The Architect Engineer's evaluation of fabricator and erector's detailed designs,drawings, and work instructions are reviewed for reasonableness andcompleteness.
Audits are conducted by the company for design review systemsof architect engineers, nuclear fuel, and NSSS suppliers.
Page 5 of 6 Revision 90Page 5 of 6Revision 90 DESIGN CONTROLCHAPTER 3The Company assures that:-personnel certifying ASME Section III design activities are qualified Registered Professional Engineers in accordance with ASME Section III,Appendix XXIII.-architect engineers and NSSS suppliers maintain procedures to assurethat their personnel certifying ASME Section III design activities arequalified Registered Professional Engineers in accordance with ASMESection III, Appendix XXIII.The Company provides qualified personnel to review and approve the resolution of non-conformances relating to electrical, mechanical, instrumentation andstructural portions of the plant and to evaluate discrepant modification testresults for operating plants.2.10. Modifications The Company performs modifications that may affect the function ofsafety-related structures,
- systems, or components in a manner to assure qualityat least equivalent to that specified in original design bases and requirements, materials specifications, and inspection requirements.
2.11. Documentation and RecordsThe Company notifies jurisdictional authorities of the location of ASME Coderelated permanent records.
Design documentation and records which provideevidence that the design and design verification process were performed inaccordance with the requirements of this chapter, shall be stored andmaintained.
Documentation of design analyses shall include the following:
-statement of the objective of the analyses.
-list of design inputs and their sources.-results of literature searches or other applicable background data.-list of assumptions and indication of those that must be verified as thedesign proceeds.
-list of any computer calculation and the bases for its use.-review and approval.
Page 6 of 6 Revision 90Page 6 of 6Revision 90 PROCUREMENT DOCUMENT CONTROLCHPE4 CHAPTER41. SCOPEThis Chapter identifies the requirements for preparation, review, approval,
- release, and retention of procurement documents.
- 2. REQUIREMENTS 2.1. GeneralThe Company establishes measures for the preparation, review, and approval ofprocurement documents for those items and activities within the scope of theQATR. Procurement documents at all tiers include or reference the appropriate regulatory, technical, and quality requirements necessary to assure adequatequality.
These requirements include reference to 1OCFR21 when applicable.
2.2. Content of Procurement Documents Procurement documents at all tiers include the following items as deemednecessary by the Company.2.2.1. Scope of WorkProcurement documents describe the scope of the items or services to befurnished by a supplier.
For those items that are important to plant safety,applicable requirements should be specified in the procurement document.
2.2.2. Technical Requirements The Company establishes measures in controlled procedures to; specifytechnical requirements by reference to the appropriate specific
- drawings, specifications, codes, standards, regulations, procedures, or instructions, including revisions thereto that describe the items or services to be furnished.
The procurement documents identify test, inspection and acceptance requirements as appropriate.
These documents identify as appropriate specialinstructions and requirements for such activities as design, material andcomponent identification, fabrication, special process controls,
- cleaning, erecting, packaging,
- handling, shipping, and extended storage.2.2.3. Quality Assurance Program Requirements Measures are established, in controlled procedures, to ensure the appropriate technical and quality requirements are established, by qualified personnel, forthe material, equipment, and services purchased from vendors, suppliers, orcontractors.
Page 1 of 3 Revision 90Page I of 3Revision 90 PROCUREMENT DOCUMENT CONTROLCHAPTER 4Any changes to these requirements require prior approval by the Company.Each vendor, supplier, or contractor has an acceptable quality assurance
- program, which is consistent with applicable regulatory requirements for the itemor service.The Nuclear Oversight Vendor Audit Group (NOVA) maintains a controlled list ofevaluated suppliers that are audited on a triennial basis. The evaluated list ofsuch vendors, suppliers, and contractors is described in controlling procedures for the appropriate safety classification except for procurement from otherlicensees that has a NRC approved quality program.Procurement documents require the vendors to incorporate quality assurance program requirements in sub-tier procurement documents and allow right ofaccess to the vendors, sub-tier
- vendors, and contractors facilities and recordsfor inspection or audit by the Company or designated representative.
2.2.4. Non-conformances
,The Company procurement documents specify the requirements for reporting and approving the disposition of supplier non-conformances.
"Use as is" or"Repair" requires approval of the supplier disposition by the appropriate Company representative.
2.2.5. Documentation Requirements The procurement documents shall identify, at all tiers, the documentation required to be submitted for information, review, and approval including the timerequirements for submittal.
The Company procurement documents require thesupplier to maintain specific quality assurance documents including retention times and disposition requirements.
2.2.6. Spare and Replacement PartsThe procurement documents require the identification of appropriate spare andreplacement parts or assemblies and the appropriate delineation of the technical and quality assurance related data required for ordering these parts orassemblies.
These spare parts and replacement items are at least equivalent tothe original design requirements or those specified by a properly reviewed andapproved revision.
2.3. Procurement Document ReviewMeasures are established in controlled procedures to ensure the appropriate technical and quality requirements are established for the material, equipment, and services purchased from vendors, suppliers, or contractors prior to releasefor bid and contract award.Page 2 of 3 Revision 90Page 2 of 3Revision 90 PROCUREMENT DOCUMENT CONTROLCHPE4 CHAPTER4These documented
- reviews, including changes to the specification or purchaseorder, ensure the technical and quality requirements are correctly stated,inspectable, and controllable and have adequate acceptance and rejection criteria and are prepared,
- reviewed, and approved in accordance with QAPrequirements.
Review of the exceptions or changes requested by the supplier shall beanalyzed to ensure they do not change or impact the technical or qualityrequirements and are incorporated in to the procurement documents, prior to thesupplier proceeding, using the same review and approval process asappropriate except for commercial terms and editorial changes.Personnel who have access to pertinent information and who have an adequateunderstanding of the requirements and intent of the procurement documents shall perform reviews required by this chapter.2.4. Procurement RecordsRecords as required by the procurement documents or the QATR are retained inthe Company's department files, vendor files, or both locations.
Page 3 of 3 Revision 90Page 3 of 3Revision 90 INSTRUCTIONS, PROCEDURES, AND CHAPTER 5DRAWINGS1. SCOPEActivities governed by the Company's QAP shall be performed as directed bydocumented instructions, procedures, and drawings appropriate for the activity.
The requirements for the use of these procedures shall also be prescribed inwriting.
These instructions, procedures, and drawings shall includeresponsibilities and acceptance criteria as applicable or appropriate for theactivity.
Those participating in any activity shall be aware of and use the proper andcurrent revision of instructions, procedures,
- drawings, and engineering requirements for performing the activity.
Procedures may include reference tovendor equipment
- manuals, design drawings and specifications, prerequisites, special precautions, and the delineation of work to be performed.
Equipment Manuals and manufacturers instructions shall be readily available for use.2. REQUIREMENTS 2.1. GeneralOperation, maintenance, or modification of equipment shall be preplanned andperformed in accordance with written procedures that are appropriate to thecircumstances and that conform to applicable codes, standards, specifications, and criteria.
Documents identify and specify the content of records to begenerated in conducting the activity.
The establishment and execution of qualityprocedures shall be used by the station staff or those under their direction, foroperating, maintenance, modifications, in-service inspection, refueling, andstores activities.
Temporary procedures may be issued to provide guidance in unusual situations that are not within the scope of the normal procedures.
Temporary procedures shall be subject to review and approval, and shall include designation of the timeperiod during which they may be used. In the event of an emergency notcovered by an approved procedure, authorized personnel shall provideappropriate direction to minimize personnel injury and damage to the facility andto protect the health and safety of plant personnel and the general public.2.2. Preparation and ReviewProcedures shall be prepared,
- reviewed, approved, and used as prescribed inwriting, and shall contain step by step instructions in the degree of detailnecessary for qualified individuals to perform the required function or task.Where appropriate, these procedures will include checklists containing thenecessary attributes to be observed or measured.
Page 1 of 4Revision 90 INSTRUCTIONS, PROCEDURES, AND CHAPTER 5DRAWINGSThese documents shall include or reference appropriate quantitative orqualitative acceptance criteria for determining that prescribed activities havebeen satisfactorily accomplished.
The procedures will be independently reviewed and evaluated by other involvedcompany organizations with interface responsibilities and the commentsforwarded to the issuing department.
2.3. Procedures and ProgramsReview and approval of site procedures are performed in accordance withtechnical specification requirements as delineated in the Technical Review orStation Qualified Review (SQR) programs.
2.3.1. Technical Review and Control1. Procedures required by a station's Technical Specifications and otherprocedures which affect nuclear safety, as determined by the managerresponsible for station operation, and changes thereto, other thaneditorial or typographical
- changes, shall be reviewed as follows prior toimplementation, except as noted in item 5 (below).-Each procedure or procedure change shall be independently reviewed by a qualified individual knowledgeable in the areaaffected other than the individual who prepared the procedure orprocedure change. This review shall include a determination ofwhether or not additional cross-disciplinary reviews are necessary.
If deemed necessary, the reviews shall be performed by thequalified review personnel of the appropriate discipline(s).
-Changes to the approved fire protection program may be madewithout prior Plant Operations Review Committee (PORC)approval provided that the changes would not adversely affect theability to achieve and maintain safe shutdown in the event of a fire,and specific features of the approved program may be alteredprovided such changes do not otherwise involve a change to theOperating License or technical specifications, or require anexemption.
-Reviews of procedures or changes to procedures, that describethe means for controlling or operating structure,
- systems, and/orcomponents as described in the UFSAR, will include a review todetermine if NRC review and approval is necessary prior to theimplementation of the procedure activity.
This review is based onthe review of a written 1OCFR50.59/72.48 review and evaluation prepared by qualified individual(s),
or documentation that a10CFR50.59/72.48 evaluation is not required.
The PORC shallreview and recommend approval of items requiring NRC reviewand approval prior to station approval for implementation.
NRCPage 2 of 4Revision 90 INSTRUCTIONS, PROCEDURES, AND CHAPTER 5DRAWINGSapproval shall also be obtained prior to station approval forimplementation.
-Department head approval authority shall be as specified in stationprocedures.
-Written records of reviews performed in accordance with thisspecification shall be prepared and maintained.
-Editorial and typographical changes shall be made in accordance with station procedures.
- 2. Technical reviewers shall advise their supervisors and/or PORO on allmatters related to nuclear safety that are identified during reviews.
Thereviewer shall be other than the originator.
The reviewer shall determine if additional cross-disciplinary reviews are required to ensure allapplicable technical disciplines are included.
This review shall ensuretechnical
- accuracy, compliance with regulatory requirements, and shallverify the originator's determination of whether items reviewed constitutes a change to the Technical Specifications, Operating
- License, or if NRCreview and approval is required prior to implementation.
- 3. Technical reviewers shall be qualified to perform technical reviews basedon the individual's
- training, experience, and knowledge level. Technical reviewers, assigned the responsibility for reviewing 10OCFR50.59/72.48 reviews and evaluations, shall receive training in this process.
Technical reviewers shall be qualified to perform this function and meet theexperience requirements per applicable standards.
Personnel shall haveexpertise in one or more of the following disciplines as appropriate, for thesubject or subjects being reviewed:
-chemistry
-instrumentation and controls-mechanical and electrical systems-nuclear power plant technology
-radiological controls-reactor engineering
-reactor operations
- 4. Technical reviews shall be documented and records maintained.
- 5. Temporary ChangesTemporary changes to procedures required by 2.3.1.1 (above) may bemade provided:
-the intent of the original procedure is not altered.-the change is approved by two members of the plant management Staff knowledgeable in the areas affected by the procedures, at leastPage 3 of 4Revision 90 INSTRUCTIONS, PROCEDURES, AND CHAPTER 5DRAWINGSone of whom holds a Senior Reactor Operator's License on the unitaffected.
-the change is documented,
- reviewed, and approved in accordance with 2.3.1 (above) within 14 days of implementation.
2.3.2. On-site Qualified Technical Review (Dresden Unit 1)A Qualified Technical Reviewer shall conduct thorough reviews of thedocuments specified below. Persons performing these reviews shall beknowledgeable in the subject area being reviewed.
Qualified technical reviewsmust be completed prior to implementation of proposed activities.
- 1. Qualified Technical Reviewers shall be individuals without directresponsibility for the document under review; these reviewers may befrom the same functionally cognizant organization as the individual orgroup performing the original work.2. Qualified Technical Reviewers shall have at least 5 years of professional experience and either a Bachelor's degree in Engineering or the PhysicalSciences or shall have equivalent qualifications evaluated on a case bycase basis and approved by the manager responsible fordecommissioning activities.
The appointment of Qualified Technical Reviewers shall be documented.
- 3. A Qualified Technical Reviewer shall independently review the following subjects:
-Proposed changes to the license, technical specifications, orbases.-Proposed changes to the programs required by the Technical Specifications to verify that such changes do not involve a changeto the Technical Specifications and will not require NRC reviewand approval as defined in 100FR50.59/72.48.
-10OCFR50.59 evaluations for changes in the facility as described inthe De-fueled Safety Analysis Report (DSAR), changes inprocedures as described in the DSAR, and tests or experiments not described in the DSAR to verify that such actions do notinvolve a change to the Technical Specifications or will not requireNRC review and approval as defined in 10OCFR50.59.
Page 4 of 4 Revision 90Page 4 of 4Revision 90 DOCUMENT CONTROLCHAPTER 61. SCOPEMeasures shall be established to control and coordinate the classification, review, approval,
- issuance, revision, and change of documents that prescribe methods or provide the technical and/or quality requirements for activities anditems within the scope of this program.
These measures shall ensure that suchdocuments are reviewed for adequacy, approved for release and use, anddistributed to the location where the activity is performed
- 2. REQUIREMENTS 2.1. GeneralThe Company document control process ensures that procedures are reviewedand approved before initial use. The Company has in place programmatic
- controls, which ensure that procedures are technically and administratively correct before use. These programmatic controls ensure that procedures arereviewed and revised as needed, when pertinent source material is changed,when the plant design is changed, or when deficiencies are identified andcorrected.
Provisions shall be established to ensure that infrequently usedprocedures are reviewed prior to use, unless they have been reviewed within theprevious two years. The periodic biennial review requirements are satisfied byimplementation of several processes and programs.
Except as noted inappendix C, due to their importance to safety, biennial review of abnormalprocedures (such as emergency operating procedures) shall continue.
Theseprocesses and programs provide the programmatic controls that ensure therequired reviews are accomplished and include the following:
-Commitment Management and Tracking Process.-Integrated Reporting/Corrective Action Program.-Operational Experience Feedback Program.-Plant Modification Program.-Procedure Feedback Process.-Technical Specification and Updated Final Safety Analysis ReportRevision Programs.
-Vendor Information Program.2.2. ReviewsThe company has also established provisions to ensure that the following reviews are conducted:
-inspection, identification of inspection personnel, and documentation ofinspection results.-maintenance, modification, and inspection procedures are reviewed byqualified personnel, knowledgeable in quality assurance disciplines.
Page 1 of 3Revision 90 DOCUMENT CONTROLCHAPTER 6-necessary inspection requirements,
- methods, and acceptance criteriahave been identified.
2.3. Controlled Documents Written document control procedures shall be established to provide for thecontrol of approved documents.
Documents that are controlled
- include, but arenot limited to, the following items:-administrative procedures
-as-built and design drawings.
-assessments
-calibration procedures.
-computer codes and software.
-corrective action reports.-design specifications.
-emergency operating procedures.
-engineering calculations.
-inspection and test reports.-maintenance procedures
-nonconformance reports.-NOS procedures.
-operating procedures.
-purchase orders and related documents.
-safety analysis reports.-supplier audit and surveillance procedures.
-technical specifications (station and Independent Spent Fuel StorageInstallation)
-temporary and emergency procedure changes.-topical reports.-work instructions and procedures.
2.4. Control MeasuresThe Company document control process includes the following documentcontrol measures:
-coordinating and controlling interface documents.
-distributing documents approved for issuance in accordance with updatedand current distribution lists.-establishing document control procedures to assure that properdocuments are accessible and are being used.-establishing lists of documents controlled by organizations involved withactivities affecting quality.Page 2 of 3Revision 90 DOCUMENT CONTROLCHAPTER 6-establishing procedural requirements for the protection of safeguards information
-identifying and assuring that proper documents are used in performing activities affecting quality.-identifying qualified individuals or organizations responsible for preparing, reviewing, approving and issuing documents, including revisions.
-recalling or identifying obsolete documents.
2.5. Document ChangesThe Company document control process ensures changes, to documents arereviewed and approved by the same organizations that performed the originalreview and approval, unless delegated to another responsible organization.
Thereviewing organization has access to pertinent background data or information upon which to base their approval.
To avoid a possible omission of a requiredreview, the Company document control process includes provisions to controlminor changes.Page 3 of 3 Revision 90Page 3 of 3Revision 90 CONTROL OF PURCHASED
- MATERIAL, CHAPTER 7EQUIPMENT, AND SERVICES1. SCOPEThe Company establishes measures to assure the quality of purchased
- material, equipment and services conform to procurement document requirements foritems contained within the QATR.2. REQUIREMENTS 2.1. Supplier Selection 2.1.1. GeneralThe Company establishes measures to assure that purchased
- material, equipment, and services conform to the procurement documents for safetyrelated and ASME code specifications as appropriate.
This assurance isaccomplished by controlling both the selection of procurement sources andacceptance of the product at the source and/or upon receipt at the appropriate location.
The company procedures, which address the procurement process and receiptand storage of material and equipment, clearly define the responsibilities andinterfaces between the line requisitioning organization, engineering, supply andquality assurance.
2.1.2. MethodsThe Company establishes and implements measures for the evaluation andselection of procurement sources.
These measures must be completed prior tothe award of contract.
These measures include one or more of the following:
-evaluation of the supplier's history of providing an identical or similarproduct that performs satisfactorily in actual use.-supplier's current quality records supported by documented qualitative and quantitative information that can be objectively evaluated.
-supplier's technical and quality capability of meeting the applicable qualityrequirements of 100FR50 Appendix B as determined by a directevaluation of its facilities and personnel and the implementation of itsquality assurance program.-review and evaluation of audits, surveys, and inspections conducted byother utilities, or American Society of Mechanical Engineers (ASME).-if there is insufficient evidence of implementation of a QA program, theinitial evaluation is of the existence of a QA program addressing thescope of the services to be provided.
The initial audit is performed afterthe supplier has completed sufficient work to demonstrate that itsorganization is implementing a QA program.Page 1 of 8Revision 90 CONTROL OF PURCHASED
- MATERIAL, CHAPTER 7EQUIPMENT, AND SERVICESThe Company documents and files the results of these measures and maintains an evaluated list of suppliers.
2.2. Bid Evaluations The Company reviews and evaluates bids and awards contracts using writtenprocedures and documents the results.
The Company designates individuals ororganizations to review bids to assure that they conform to the procurement document requirements and the supplier has the appropriate technical ability,Quality Program, production capability, personnel, and acceptable pastperformance to supply the product or service.
The Company obtainscommitments to resolve unacceptable quality conditions identified as part of thebid evaluation before award of the contract and ensure exceptions andalternatives do not impact the technical or quality requirements.
2.3. Supplier In-Process Control2.3.1. GeneralThe Company establishes measures to interface with and to verify supplierperformance.
These measures include the following items:-establishing an understanding between the Company and the supplier ofthe provisions and specifications contained in the procurement documents.
-establishing a method of document information exchange between theCompany and the supplier.
-establishing the extent of source surveillance and inspection activities.
-identifying and processing necessary change information.
-requiring the supplier to identify planning techniques, tests, inspections, and processes to be used in fulfilling procurement documentrequirements.
-reviewing supplier documents that are generated or processed duringactivities fulfilling procurement requirements.
2.3.2. In-Process Control and Verification PlanningThe Company and the supplier, establish as appropriate, notification points,including hold and witness points and incorporate into the appropriate documents based upon the complexity and scope of the item or service.
Whenrequired by the procurement document or specification, surveillances andevaluations at the supplier's facility are conducted to verify continued compliance with the quality assurance requirements of the procurement documents.
Qualified individuals or its agents accomplish source inspections at thesupplier's facility to verify that the procurement item or service is being suppliedin accordance with the requirements of the procurement documents.
Page 2 of 8Revision 90 CONTROL OF PURCHASED
- MATERIAL, CHAPTER 7EQUIPMENT, AND SERVICESSuch inspections, examinations or tests are accomplished in accordance withwritten procedures, plans, and/or checklists containing or referencing appropriate acceptance criteria.
Upon acceptance by source verification, theCompany furnishes documented evidence of acceptance to the receiving destination of the item, to the purchaser, and to the supplier.
2.3.3. Programmatic Verification The Company or its agents verify the effectiveness of the supplier's qualityprogram by survey, audit or surveillance.
Verification is performed at intervals consistent with the importance to safety, complexity and quality of the product orservices furnished.
Activities are witnessed or observed and the resultsdocumented when source verification is performed.
The Company conducts audits per the requirements established in Chapter 18or reviews audits performed by other license holders as defined in procedures.
The results of these audits are used to support the maintenance of the list ofevaluated suppliers.
Verification activities are conducted as early as practicable so that subsequent activities do not prevent disclosure of deficiencies.
TheCompany's verification activities do not relieve the supplier of its responsibility for quality verification.
2.3.4. Supplier and Verification of Supplier Performance RecordsThe Company establishes methods to control, handle and approve supplierdocuments.
Suppliers submit their documents per procurement requirements.
Acceptance criteria is used for the acquisition, processing, and record evaluation of technical inspection and test data.The Company records activities to verify supplier conformance with therequirements of procurement documents.
Source surveillances, procurement plans, inspections, audits, surveys, receiving inspections, non-conformance dispositions, waivers and corrective actions concerning supplier activities aredocumented.
This documentation is used to determine the supplier's qualityassurance program effectiveness.
2.3.5. Control of Procurement ChangesThe Company documents changes to procurement documents involving technical or quality assurance matters.
These changes are subjected to thesame review and approval process as the original procurement documentexcept for commercial terms and conditions and editorial changes.Page 3 of 8 Revision 90Page 3 of 8Revision 90 CONTROL OF PURCHASED
- MATERIAL, CHAPTER 7EQUIPMENT, AND SERVICES2.4. Acceptance of Purchased Items and Services2.4.1. GeneralUpon receipt the applicable materials, parts, and components are controlled.
Qualified inspection personnel are responsible for inspecting, releasing, andmaintaining the inspection status of purchased material and equipment.
Afterreceipt inspection, the purchased material is placed in a controlled storage areaor issued for installation or further work.2.4.2. Acceptance by Receiving Inspection The Company uses approved procedures to accept purchased items andservices.
Acceptance of an item or service from a supplier includes certificate ofconformance, source verification, receiving inspection or post installation testingat the plant location or a combination thereof.
Items are inspected during receiptusing approved procedures and checklists.
The Company does receiving inspections using procedures and inspection instructions to verify conformance to the specified requirements, using objective evidence to check such features as: complete documentation and visualinspection of: proper configuration; identification; dimensional, physical andother characteristics; freedom from shipping damage; and cleanliness.
Items,which can not meet the purchase order requirements, will be segregated andcontrolled as defined in the applicable procedures.
The Company coordinates the review of supplier documentation with thereceiving inspection when procurement documents require such documentation to be furnished prior to the receiving inspection.
Source verification and auditactivities are factored into the receipt inspection activities as appropriate.
2.4.3. Acceptance by Source Verification The Company considers acceptance by source verification when the item orservice is:-vital to plant safety; or-difficult to verify quality characteristics after delivery; or-complex in design, manufacture, and test.Source verification shall be implemented in accordance with plans to performinspections, examinations, or tests at pre-determined points. Upon acceptance by source verification, the Company furnishes documented evidence ofacceptance to the receiving destination of the item, to the purchaser, and to thesupplier.
Page 4 of 8 Revision 90Page 4 of 8Revision 90 CONTROL OF PURCHASED
- MATERIAL, CHAPTER 7EQUIPMENT, AND SERVICES2.4.4. Acceptance by Certificate of Conformance The supplier's certificate of conformance attests the product or service providedis in accordance with the procurement documents is reviewed during sourceand/or receipt inspections to verify compliance.
This document provides thepurchase order number; codes, standards or other specifications required to bemet in the purchase order. Requirements which cannot be met must beincluded with an explanation why and a means to resolve the non-conformances.
A person who is responsible for quality assurance functionattests to this certificate The validity of a supplier's certificate of conformance is ascertained through anyof the following methods source inspection, independent inspection agency,receipt inspections, surveillance, testing of hardware, quality assurance audits orsurveillances at intervals commensurate with the suppliers past performance.
Inspection and test activities verify that the hardware performs in accordance with applicable technical requirements and serve to demonstrate that thehardware meets the requirements stated in a certificate of conformance.
The results of the source and/or receipt inspections, the acceptability of supplierfurnished documentation, and the resulting determination of conformance ornonconformance is documented.
2.4.5. Acceptance by Post Installation TestingWhen post-installation testing is used, the Company establishes post-installation test requirements, giving due consideration to supplier recommendations.
Acceptance by this method is satisfactory when performed following theaccomplishment of at least one preceding method and when:-it is difficult to verify the quality characteristics of the item without it beinginstalled and in use; or-the item requires an integrated system checkout or test with other itemsto verify its quality characteristics; or-the item cannot prove its ability to perform its intended function exceptwhen in use.2.4.6. Acceptance of Services OnlyIn cases involving procurement of services only, the Company accepts theservice by any of the following methods:-technical verification of data produced.
-surveillance, audit, survey, or assessment of the activity.
-review of objective evidence for conformance to the procurement document requirements such as certifications, stress reports, etc.Page 5 of 8Revision 90 CONTROL OF PURCHASED
- MATERIAL, CHAPTER 7EQUIPMENT, AND SERVICESIn lieu of the above the Company performs a receiving inspection for itemsarriving back onsite that were sent offsite for repair, testing, or rework.2.4.7. Commercial Grade ItemsWhere the safety related design utilizes commercial grade items, the following requirements are a permissible alternative for acceptance, to other requirements of this Chapter:1. An approved design document identifies the commercial grade item. (Analternate commercial grade item may be applied, provided the cognizant design organization provided verification that the alternate commercial grade item will perform the intended function and will meet designrequirements applicable to both the replaced item and its application.)
- 2. The Company performs source evaluation and selection, wheredetermined necessary, based on complexity and importance to safety.-commercial grade dedication plans for use in a safety relatedapplications state responsibility for 10CFR21 requirements.
-the Company identifies commercial grade items in the purchaseorder by the supplier's published product description.
- 3. One or a combination of the following methods shall be utilized to providereasonable assurance that the item meets the acceptance criteria for thecharacteristics identified to be verified for acceptance:
-acceptable supplier/item performance records.-commercial grade survey of the supplier.
-source verification.
-special test(s) or inspection(s) or both.4. After receipt of a commercial grade item, the Company determines thefollowing:
-damage was not sustained during shipment.
-documentation, as applicable to the item, was received and isacceptable.
-inspection and/or testing are accomplished, as required by thepurchaser, to assure conformance with the manufacturer's published requirements.
-the item received was the item ordered.2.4.8 Acceptance of Calibration ServicesFor suppliers of commercial-grade calibration services with accreditation by anationally recognized accrediting body, a documented review of the supplier's accreditation by the purchaser may be used in lieu of inspections or tests following Page 6 of 8Revision 90 CONTROL OF PURCHASED
- MATERIAL, CHAPTER 7EQUIPMENT, AND SERVICESdelivery or in-process surveillances during performance of the service.
This reviewshall include, at a minimum, all of the following:
- 1. The accreditation is to ANSI/ISO/lEC 17025.2. The calibration laboratory holds a domestic accreditation by one of the following accrediting bodies, which are recognized by the International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement (MRA):-National Voluntary Laboratory Accreditation Program (NVLAP),
administered by NIST-American Association for Laboratory Accreditation (A2LA)-ACLASS Accreditation Services (ACLASS)-International Accreditation Service (lAS)-Laboratory Accreditation Bureau (L-A-B)3. The published scope of accreditation for the calibration laboratory covers theneeded measurement parameters, ranges, and uncertainties.
- 4. The purchase documents impose additional technical and administrative requirements, as necessary, to satisfy the Exelon QATR program and technical requirements.
The technical requirements will also include the following requirements:
-The calibration certificate/report shall include identification of the laboratory equipment/standards used.-The calibration certificate/report shall include as-found and as-left data.5. The purchase documents require reporting as-found calibration data whencalibrated items are found to be out-of-tolerance.
2.5. Presence of Documentary EvidenceDocumented evidence that material or equipment conforms to procurement requirements is present at the site before use or installation.
This documentary evidence is traceable to the item and shall be retained at the nuclear power plantsite and shall be sufficient to identify the specific requirements such as codes,standards, or specifications met by the purchased material and equipment.
2.6. Spare or Replacement ItemsProcedures control the procurement, storage and issuance of materials andcomponents including spare and replacement parts. Procurement documents Page 7 of 8Revision 90 CONTROL OF PURCHASED
- MATERIAL, CHAPTER 7EQUIPMENT, AND SERVICESfor these items identify the appropriate technical and quality relatedrequirements.
The Company purchases spare parts and replacement items,equipment and components to at least the original design requirements or thosespecified by a properly reviewed and approved revision.
Where the QA requirements of the original item cannot be determined, qualified individuals conduct an engineering evaluation to establish appropriate requirements and controls.
This evaluation insures that interfaces, interchangeability, safety, fit and function are not adversely affected or arecontrary to applicable regulatory or ASME Code requirements.
The evaluators document their results.Where the company procured the original item with no specifically identified quality assurance program requirements or from an Original Equipment Manufacturer/Supplier (QEM/QES) who no longer is on a list of evaluated suppliers, identical (like-for-like) items may be similarly procured from theOEM/QES through the use of procurement plans.In such cases, the Company conducts a joint technical engineering and qualityassurance documented evaluation to established requirements and controls toassure at least equivalent product performance.
The evaluation shall assurethat interfaces, interchangeability, safety, fit and function are not adversely affected or are not contrary to applicable regulatory or ASME Coderequirements.
2.6.1. Procurement from Other Utilities Purchases of safety related items can be made from other utilities who have hadan NRC approved QA Program in effect at the time of their procurement andreceipt and such utility has maintained a quality system program for storage,handling, and maintenance with documented traceability to the manufacturer ofthe items.Certificates-of-Conformance to the above requirements and associated requireddocumentation are provided.
2.6.2. Maintenance or Modification The Company performs maintenance or modifications that may affect thefunction of safety related structures,
- systems, or components in a manner toassure quality at least equivalent to that specified in original design bases andrequirements, materials specifications, and inspection requirements.
Page 8 of 8 Revision 90Page 8 of 8Revision 90 IDENTIFICATION AND CONTROL OF CHAPTER 8MATERIALS, PARTS, ANDCOMPONENTS
- 1. SCOPEControls are established to assure that only correct and accepted items are usedor installed.
Identification shall be maintained on the items or in documents traceable to the items, or in a manner, which assures that identification isestablished and maintained.
- 2. REQUIREMENTS 2.1. GeneralThe Company establishes measures for the identification and control ofmaterials, parts and components, including partially fabricated assemblies, andassures that only correct and accepted items are used or Identification is maintained on the items or in documents traceable to the items. Physicalidentification shall be used to the maximum extent possible.
Provisions are in place to maintain
- markings, which could be damaged duringshipping or handling or deterioration due to environmental exposure.
Provisions are also established to control nonconforming items and maintain parts,material, and equipment in storage traceable to quality assurance documents.
2.2. Traceability
Items within the scope of the QAP shall be identified, so that they can be tracedto the appropriate documentation, which provides objective evidence that thetechnical and quality requirements are met.Responsible organizations document and maintain identification and traceability of items from initial receipt, throughout fabrication, installation, and use of theitems such as: subassemblies, components, equipment
- numbers, part numbers,serial number, heat treatment number, batch or lot numbers.When installed material or equipment is removed for maintenance, repair, ormodification, control measures are implemented to ensure proper identification and traceability is maintained.
Before use or installation of an item, the installer verifies that identification has been maintained.
2.3. Identification MethodsIdentification is on the item where practicable.
Identification is clear,unambiguous and indelible.
Identification does not affect the fit, function, quality,and service life of the item. If the item cannot be practicably marked, theCompany uses records traceable to the item for identification.
Page 1 of 2Revision 90 IDENTIFICATION AND CONTROL OF CHAPTER 8MATERIALS, PARTS, ANDCOMPONENTS If physical identification is either impractical or insufficient for proper control, theCompany controls an item by physical separation, procedural control or otherappropriate means.2.4. Transfer of MarkingsPrior to cutting or dividing
- material, each new piece shall be marked with thesame traceability markings of the original piece to ensure that the traceability ofthe material is maintained.
These markings shall not be obliterated or hidden bysurface treatment or coatings unless other means of identification aresubstituted.
The Company independently verifies proper identification of eachpiece.2.5 Limited Life ItemsThe Company identifies and controls items having limited life to preclude use ofitems whose shelf life or operating life has expired.2.6 Stored ItemsThe Company uses procedures to assure proper control of identification foritems in storage.Page 2 of 2 Revision 90Page 2 of 2Revision 90 CONTROL OF SPECIAL PROCESSES CHAPTER 91. SCOPEProcesses affecting quality of items or services shall be controlled.
Specialprocesses that control or verify quality, shall be performed by qualified personnel, using qualified procedures, in accordance with specified requirements and are properly documented and evaluated.
These requirements are defined in codes, standards, specifications, or special instructions.
Thequality of such processes is assured through reliance on operator skill andin-process control.
Examples of special processes
- include, but are not limited towelding, heat treating, chemical
- cleaning, and non-destructive examination (NDE).2. REQUIREMENTS 2.1. GeneralThe Company organization directing work during repair, replacement, modification, or in-service inspection (ISI) activities is responsible for controlling special processes.
Special process controls are assured through independent assessment and inspection activities.
2.2. Process ControlInstructions, procedures,
- drawings, checklists, or other appropriate meanscontrol processes.
Process controls specify the prerequisite steps, processing
- details, conditions to be maintained during the process, equipment requirements, inspection and test requirements, acceptance
- criteria, and recordrequirements.
Controlling includes:
-maintenance and retention of records.-personnel qualification.
-procedure development and qualification.
-procedure implementation.
-qualification of equipment.
2.3. Special Processes Measures shall be established and documented to assure that specialprocesses are accomplished under controlled conditions in accordance withapplicable codes, standards, applications
- criteria, regulatory requirements andCommitments, and other special requirements including the use of qualified personnel and procedures.
Special processes are controlled by instructions, procedures,
- drawings, checklists, travelers, or other appropriate means.Page 1 of 3 Revision 90Page 1 of 3Revision 90 CONTROL OF SPECIAL PROCESSES CHAPTER 9Special process controls specify the preparatory steps, processing details,conditions to be maintained during the process, equipment requirements, inspection and test requirements, acceptance
- criteria, and record requirements.
Special process procedures are written and qualified in accordance withapplicable requirements.
Special process procedures are reviewed andapproved as follows:-Coating and ASME Code concrete placement procedures are reviewedand approved by the appropriate Company organizations.
-Company, contractor and subcontractor heat treating,
- welding, andbrazing procedures are reviewed in accordance with the companywelding program as approved by Engineering.
-Company NDE procedures are reviewed and approved by the appropriate Company Level Ill.-Contractor, subcontractor,Section III, XI, and other ISI-related NDEprocedures that will be utilized on site are reviewed and approved by aCompany NDE Level Ill.-The responsible Company engineering organization reviews contractor and subcontractor non-welding special process procedures.
When permitted by applicable requirements, the Company may directcontractors or subcontractors to use Company special process procedures.
When there is a specific reason to question whether special process procedure requirements are being met, the Company, or the Authorized Inspection Agency(AlA) may require re-evaluation of the procedure before work may proceed.For special processes not covered by the existing codes or standards, or whenthe quality requirements of an item exceed the requirements of established codes or standards, the necessary qualifications of personnel, procedures andequipment shall be defined in the procedure.
2.4. Personnel Qualification Company and contractor personnel performing special processes are trained,tested, qualified, or certified in accordance with a company procedure that meetsapplicable requirements.
For NDE personnel, the Company and contractor personnel performing NDE aretrained, tested, qualified, or certified in accordance with a company procedure that meets applicable requirements of 10CFR50.55a and ASME Section Xl withspecific exceptions and clarifications.
When permitted by applicable requirements, the Company may qualify and control contractor personnel certifications.
Page 2 of 3 Revision 90Page 2 of 3Revision 90 CONTROL OF SPECIAL PROCESSES CHAPTER 9The Company assures compliance with the ASME Code through an agreement with an AlA who verifies compliance in accordance with their procedure thatdescribes the ANI duties and responsibilities.
When there is a specific reason toquestion the ability of an individual performing special processes, the Company,or the AlA may require re-evaluation before that individual will be permitted toresume work. Individuals failing any retest will be removed from applicable operations pending re-qualification.
The Company designates a principal(s)
NDE Level Ill and they are responsible for personnel qualification and procedure development to ASME Coderequirements for nondestructive examination.
These NDE personnel are qualified and certified in accordance with the Company procedure and maydesignate other NDE Level Ill's for certification of personnel.
NDE Level Ill'shave authority for the interpretation of any NDE indication that has beenrecorded by a company or supplemental vendor Level IlIll1 Examiner.
Training and certification of NDE personnel associated with nondestructive examination are carried out in accordance with the requirements of10OCFR50.55a and ASME Section XI with specific exceptions and clarifications are met. The company develops and maintains a procedure detailing theprogram that will be used for qualification and certification and has ultimateresponsibility for determination of the qualification process.
Qualified personnel administer all ASME Code examination activities.
2.5. Special Process RecordsSpecial process records provide evidence that special processes wereperformed in accordance with approved procedures by qualified personnel.
These records are retained by the Company or by the contractor orsubcontractor as required by procurement documents.
Records are maintained for currently qualified personnel, processes, and equipment for each specialprocess.Page 3 of 3 Revision 90Page 3 of 3Revision 90 INSPECTION CHAPTER 101. SCOPEThe Company plans and executes an inspection program to verify that activities affecting the quality of safety-related structures,
- systems, and components conform to documented requirements.
For modification and non-routine maintenance activities, inspections are conducted in a manner similar (i.e.frequency, type and personnel performing such inspections) to those associated with construction phase activities.
The independent inspections described in thisChapter are not intended to dilute or replace the clear responsibility of the firstline supervisors for the quality of work performed under their supervision orpersonnel performing the activity.
- 2. REQUIREMENTS 2.1. GeneralThe Company establishes controls for coordination and execution of inspection plans. Company quality verification organizations or other qualified organizations are responsible for implementation of established inspection plans. If an inspection plan includes inspections by personnel other than thosein a quality verification organization, the inspection requirements, personnel qualification
- criteria, and inspector independence will be accepted by theresponsible quality organization prior to implementation.
2.2. Inspection PlansThe Company prepares documented inspection plans. These inspection plansare applied when the activity is started.
The inspection plans may be separatedocuments or an integral part of approved instructions, procedures or drawings.
Related codes, standards, specifications and design documents are used todevelop the inspection plans. Procedures used for documenting inspection plans are selectively
- reviewed, as appropriate, by NOS to assure that necessary verification points and inspection criteria are included.
The plans identify:
-acceptance criteria.
-activities to be inspected.
-inspection characteristics.
-inspection techniques/equipment (including accuracy requirements).
-provisions for inspection and test status.-provisions for the recording of inspection results.-qualification requirements.
-responsible organizations.
Page 1 of 3 Revision 90Page 1 of 3Revision 90 INSPECTION CHAPTER 102.3. Inspection Personnel and Qualification A qualification program is established and documented to conform to applicable codes, standards, or licensing requirements.
Qualifications and certifications arekept current.Qualified personnel perform inspections.
Inspectors with valid certifications perform inspections for acceptance.
Inspectors are independent of those whoperform or directly supervise the activity being inspected.
On-the-Job traininginspections shall be performed under the direct supervision of qualified personnel.
Second line supervisory personnel or other qualified personnel not assigned firstline supervisory responsibility for the conduct of the work may conductinspection of operating activities.
Operating activities are defined as workfunctions associated with normal operations of the plant, routine maintenance, and certain technical services routinely assigned to the onsite operating organization.
2.4. Inspection ProcessInspections are performed using approved instructions, procedures, processsheets, travelers, or checklists and applicable drawings.
-Inspections are performed for each work or operating activity wherenecessary to verify quality.
Where inspection sampling is used to verifythe acceptability of a group of items, the sampling procedure shall bebased on recognized standard practices.
-Process monitoring may be used when inspection of processed materialor products is impossible or impractical.
When necessary, to ensurequality throughout the duration of the process, both inspection andprocess monitoring will be systematically used to verify conformance torequirements.
-When inspections must be performed before work can continue, holdpoints are established in appropriate documents.
Consent to waive holdpoints are recorded prior to continuation of work. When inspection isdesired, but not mandatory before work can continue, witness points areestablished.
Completion of hold and witness points is documented.
-When acceptance criteria are not met, corrected areas are re-inspected.
Such inspections are documented in the Corrective Action Program.-Changes to, or rework of, an item after inspection requires re-inspection of the affected areas.-A final evaluation is performed.
Inspection results are reviewed toconfirm that required inspections and quality records have beencompleted, identified non-conformances have been resolved and the itemconforms to specified requirements.
Engineering, Maintenance, Operations or Quality Verification approves final acceptance of the item.Page 2 of 3Revision 90 INSPECTION CHAPTER 10-Inspection records are of sufficient detail to confirm completion and, as aminimum, identify:
-authorized individual approving results.-date of inspection.
-inspector/Data recorder.
-item inspected.
-M&TE used.-reference to action taken in connection with identified non-conformances.
-results or acceptability.
-type of observation.
-When the inspection activity is performed using a procedure notreferenced or included within the work package, the procedure and itsrevision should be recorded.
2.5. In-Service Inspections A program for the required ISI/IST inspection of completed
- systems, structures and components shall be planned and executed by or for the organization.
responsible for the operation of the plant to assure that plant components perform satisfactorily under all operating conditions.
Inspection methods shall be established and executed to applicable codes,standards and regulations, including baseline examinations and subsequent periodic examinations, which continue through the life of the plant in accordance applicable technical specifications.
2.6. Independent Verification Independent verifications are conducted by qualified personnel using approvedprocedures.
Characteristics to be verified and methods to be employed shall bespecified.
Verification results and unacceptable conditions identified shall bedocumented.
Verifications shall be performed by persons other than those whoperformed or directly supervised the work being verified.
Page 3 of 3 Revision 90Page 3 of 3Revision 90 TEST CONTROLCHAPTER 111. SCOPEA documented test program shall be established in accordance with applicable technical specifications, license conditions, and design documents to assure thatall testing required demonstrating that the structures,
- systems, or components within the scope of this QAP will perform satisfactorily in service.2. REQUIREMENTS 2.1. General2.1.1. Testing ProgramThe Company establishes and controls a test program to assure that design andperformance criteria have been satisfied and assures that testing does notadversely affect the safe operation of the plant. The test program includes, asappropriate, procedures to ensure those structures,
- systems, subsystems, andcomponents will perform in service.
Testing is conducted by appropriately trained and qualified personnel.
The extent of testing shall be based on thecomplexity of the modification, replacement, or repair. The test program coversall required tests including:
-operational tests.-production tests.-prototype qualification tests.-tests during design.-tests during fabrication.
-the demonstration of satisfactory performance following plantmaintenance and modifications or procedural changes.-those tests required by plant maintenance or modifications.
2.1.2. Test Procedures The program uses written test procedures which include the requirements andacceptance limits from applicable design documents.
The Company reviewsand approves test procedures and changes to test procedures, including changes that alter test sequence, in a similar manner to the original.
The organization responsible for the design of the item to be tested establishes the test requirements and acceptance criteria.
Test requirements andacceptance criteria are based upon specified requirements contained inapplicable design or other pertinent documents.
Test requirements includespecific characteristics to be tested.Page 1 of 6 Revision 90Page 1 of 6Revision 90 TEST CONTROLCHAPTER 11The Company specifies specific test methods when they must be employed, uses written procedures or checklists, and documents the status of equipment both before and after testing.The Company may use appropriate sections of related documents, such asASTM methods, supplier
- manuals, equipment maintenance instructions, orapproved drawings or travelers with acceptance criteria in lieu of specially prepared written test procedures.
Such documents must include adequateinstructions to assure the required quality of work. Test and inspection procedures contain:-a description of objectives.
-acceptance criteria or limits contained in applicable design or othersource documents, such as vendor's literature, engineering drawings or* plant specifications that will be used to evaluate results.-any special equipment or calibrations required to Conduct the test orinspection.
-responsibilities.
-instructions or checklists used to verify or document that affected plantsystems are arranged in their correct lineup and for restoring the systemto the condition consistent with the normal operating status.-limiting conditions.
-prerequisites for, or checks to be made prior to performing the tests orinspections including any special conditions to be used to simulate normalor abnormal operating conditions.
-data documentation is in compliance with test procedures.
-equipment to be tested is properly released for testing.-inspections and tests are done under suitable environmental conditions.
-proper calibrated inspection and test instruments are used.-retention control of test data documentation is adequate.
-test or inspection requirements contained in applicable designdocuments.
Where tests and inspections are to be witnessed, the procedure identifies holdpoints or witness points in the testing sequence to permit witnessing.
Theprocedure requires appropriate approval for the test to continue beyond thedesignated hold point.1. Prerequisites Prerequisites include the following, as applicable:
Page 2 of 6 Revision 90Page 2 of 6Revision 90 TEST CONTROLCHAPTER 11-appropriate test equipment.
-calibrated instrumentation in accordance with Chapter 12, "Controlof Measuring and Test Equipment."
-condition of test equipment and the item to be tested.-provisions for data acquisition.
-suitable environmental conditions.
-trained personnel.
Procedures ensure that prerequisite steps for equipment testing havebeen or will be performed.
Such steps include:-completion of necessary construction maintenance andmodification activities.
-formal release for testing.-measures to preserve equipment status.-prior testing.-safety precautions.
A detailed prescribed physical inspection of equipment components andfacilities is performed to ensure readiness for operation.
Typicalinspection items include:-calibration of instruments.
-cleanliness.
-lubrication.
-presence of safety devices.-setting of limit switches.
- 2. ScheduleSchedules are provided to assure that all necessary tests are performed and properly evaluated on a timely basis. Testing is scheduled so thatthe safety of the plant is never dependent on the performance of anuntested system.3. Test Results and RecordsAppropriate Company personnel evaluate test results to assureconformance with design and performance requirements.
Inspection andtest results are documented in a test report or data sheet. Each reportidentifies the following:
-acceptability of the test.-actions taken to correct the deviations noted.-any deviation of test results from acceptance criteria(nonconformance).
-as-found condition.
Page 3 of 6Revision 90 TEST CONTROLCHAPTER 11-as-left condition.
-completion date and other significant dates and times.-data sheets completed during the tests.-documents that provide acceptance criteria.
-identification of the conditions encountered which were notanticipated.
-identity of inspector or tester.-item to which it applies.-location where testing was performed or where test samples weretaken.-measuring and test equipment used.-person evaluating test results.-procedures or instructions followed in performing the task.-test procedures.
-test results.2.2. Instrumentation and ControlThe Company tests instrumentation and control channels to assure that they areproperly calibrated.
In addition, specific tests are performed at critical levelssuch as "set points" in a manner simulating the approach toward the set point.These calibrations are made with the devices in their normal positions if thecalibration is dependent upon location or attitude.
Testing determines that a proper response is obtained over the operating rangeof the device. It gives particular attention to verifying independence anddependence, as appropriate, of the elements of the systems.
Calibration documentation includes indicating the date and identity of the person thatperformed the calibration.
The Company prepares and documents installation, inspection and testprocedures and work instructions for instrumentation and electrical equipment.
These documents are kept current and revised as necessary to assure thatinstallation, inspections and tests are performed in accordance with latestinformation.
They include as appropriate:
-approvals.
-data report forms.-frequency of inspection or test.-identification of test equipment and date for required re-calibration whererequired for interpretation of test results.-inspection and test acceptance limits.-inspection and test equipment required.
-inspection and test objectives.
-installation specifications.
Page 4 of 6Revision 90 TEST CONTROLCHAPTER 11-precautions to avoid component or system damage during testing orinspection.
-prerequisites.
-sequence of tests (if applicable).
-sequential actions to be performed.
2.3. Electrical TestsElectrical tests include as appropriate:
-continuity tests, short circuit tests, polarity and rotational tests-control system tests including indicating meters, recorders, transducers, targets and lamps, annunciators and alarms, controls and interlocks
-insulation resistance measurements as specified
-over potential (HIPOT) tests as specified.
Overpotential tests conform tothe applicable codes and standards.
The manufacturer's recommendations are considered.
-voltage breakdown tests on liquid insulation 2.4. Mechanical TestsThe Company performs mechanical tests to ascertain that electric and/orinstrumentation components or systems can withstand system pressure ratings.As a minimum, the Company applies such tests to pressure sensing andtransmitting devices operating in steam, hydraulic, and vacuum systems andtheir hydraulic or pneumatic interconnecting piping or tubing and associated instruments.
- Pressurized equipment that is part of electrical apparatus such as heatexchangers, circulating
- systems, actuating
- systems, and electric andinstrumentation containment penetrations are likewise tested if site assembled or fabricated.
Tests are conducted after the assembly is complete even thoughthe components may have been tested previously.
These tests are performed inaccordance with the applicable codes and standards.
2.5. Physical and Chemical TestsPhysical and chemical tests, in accordance with the applicable codes, include,as appropriate:
-chemical analysis of fluids for oxygen or moisture content and purity.-radiation sensitivity testing to confirm that radiation sensor and controlling devices is properly functioning.
Page 5 of 6 Revision 90Page 5 of 6Revision 90 TEST CONTROLCHAPTER 112.6. Surveillance TestsThe Company's test program covers surveillance testing during the operational phase to provide assurances that failures or substandard performance do notremain undetected and that the required reliability of safety related systems ismaintained.
2.7. Maintenance or Major Procedure ChangeThe Company performs tests following plant modification or significant changesin operating procedures to confirm that the modification or changes produceexpected results.
These tests also demonstrate that the change does notproduce an unsafe operating condition.
Page 6 of 6 Revision 90Page 6 of 6Revision 90 CONTROL OF MEASURING AND TEST CHAPTER 12EQUIPMENT
- 1. SCOPEMeasures and responsibilities are established to assure tools, gauges,instruments, and other Measuring and Testing Equipment (M&TE) used inactivities affecting quality are properly controlled, calibrated, and adjusted atspecified periods to maintain accuracy within specified limits. Measures shallalso be established for the control of permanently installed instrument andcontrol devices.2. REQUIREMENTS 2.1. GeneralPower Labs is responsible for the governance of M&TE and oversight of the sitecalibration process for Exelon plants. This includes the establishment ofcalibration practices, intervals, accuracy requirements, certification/de-certification, and equivalency decisions (except where accuracy is impactive non-conservatively),
as well as the resolution of technical issues regarding M&TE calibration.
Corporate Maintenance is responsible for governance and oversight of siteM&TE Control.
This includes assessment of site compliance to the control ofM&TE as defined in corporate maintenance procedural guidance.
The engineering organizations are responsible for decisions regarding theacceptability of changes to M&TE specifications where accuracies are lessconservative than those currently established.
The engineering organization performs M&TE equivalency calculations for these items to assure associated specifications are consistent with plant design, test procedures, and accuracyrequirements (excluded are analytical chemistry and radiochemistry instruments).
The stations are responsible for the control and maintenance of calibrated M&TEfor the station.
The stations are also responsible for the control of stationanalytical chemistry instrumentation, radiochemistry instrumentation, andstandard solutions.
2.2. ControlA control program specifies how M&TE are stored, handled, and used. As aminimum the following items are addressed:
-administrative controls (including equipment marking and traceability tocalibration records).
-certification requirements.
-damaged or suspect M&TE.Page 1 of 3Revision 90 CONTROL OF MEASURING AND TEST CHAPTER 12EQUIPMENT
-environmental restrictions.
-items not requiring certification.
-M&TE selection.
-out of tolerance resolution.
-personnel qualifications.
-repairs and maintenance.
-status and usage history.2.3. LabelingEquipment shall be suitably marked to indicate calibration status. Where neither*labeling nor coding is practical, procedures shall provide for monitoring ofrecords to ensure control.2.4. AccuracyCalibration of M&TE should be against reference standards that have anaccuracy of at least four times the required accuracy of M&TE. Calibration ofreference standards will be against hierarchical standards more accurate thanthe reference standards calibrated.
When this is not possible, standards musthave an accuracy that assures the M&TE is within the required tolerance, andthat the basis for acceptance is documented and authorized by responsible management.
2.5. Traceability and IntervalM&TE is calibrated against and traceable to certified standards having validrelationships to nationally recognized standards.
Where national standards donot exist, provisions are established to document the basis for calibration.
Calibration intervals are established for all M&TE and the Company programspecifies how this interval is established.
2.6. Certified M&TECertified M&TE is required where measurements with specificaccuracy/tolerance requirements are delineated:
-calibration of other M&TE.-environmental monitoring.
-safety-related and applicable ASME applications.
-technical Specification related applications (including balance of plantsystems).
-verification of design parameters.
Certified M&TE is not required when measurements do not require specificaccuracy or when commercial devices (such as rulers, tape measures, levels)Page 2 of 3Revision 90 CONTROL OF MEASURING AND TEST CHAPTER 12EQUIPMENT provide adequate accuracy.
Electronic stopwatches are not required to becalibrated.
2.7. Corrective ActionsWhen M&TE is found to be out-of-tolerance, an evaluation is made of itsprevious uses to determine corrective action. Suspect equipment is identified and segregated to prevent inadvertent use. Devices that are consistently foundout of calibration are repaired or replaced.
2.8. Vendor ControlVendors supplying calibration services are on the Company's approvedsuppliers list.2.9. Commercial DevicesControl measures are not required for rulers, tape measures, levels, and othersuch commercial
- devices, if such equipment provides adequate accuracy.
2.10. Calibration RecordsM&TE calibration records contain, as a minimum:-as found/as left condition.
-calibration data.-calibration procedure used.-calibration results.-equipment location.
-established accuracy.
-individual performing calibration.
-last calibration date.-next calibration date.-out of tolerance notification.
-repairs (if any).-serial number.-standards used.Page 3 of 3 Revision 90Page 3 of 3Revision 90
- HANDLING, STORAGE, AND SHIPPINGCHAPTER 131. SCOPEThe Company establishes measures to control and specify special protective conditions in accordance with an item's design and procurement requirements, as necessary, to prevent damage or deterioration of materials, components, andsystems during handling, packaging, preservation,
- storage, and shipping.
- 2. REQUIREMENTS 2.1. GeneralThe Company uses written procedures or instructions for cleaning, packaging,
- shipping, storage, preservation, and to specify detailed requirements for accessto storage areas, housekeeping, and removal of items from storage.
Procedures include provisions for inspection, examination, testing and documentation.
These procedures specify special protective conditions necessary to preventdamage, deterioration or loss before and after receipt of materials, equipment, special nuclear material, and radioactive wastes.Procurement documents or the vendor's quality program specifies theestablishment of controls, to assure through the use of shipping procedures toprovide protection during loading and transit and inspections, that items aredelivered in acceptable condition.
2.2. Special Equipment and Environments When required, the Company:-provides special equipment and special protective environments
-specifies special equipment (such as containers, shock absorbers andaccelerometers)
-specifies special protective environments (such as inert gas atmosphere, specific moisture content levels and temperature levels)-verifies the maintenance of special equipment and special protective environments 2.3. Classification of ItemsLevels and methods of storage are classified to minimize the possibility ofdamage, deterioration, or contamination of items. This is based on the important physical characteristics and the importance to safety and reliability of the item.This classification considers the manufacturer's requirements.
The Company packages, ships, receives, stores, and handles items according toestablished manufacturers requirements or the Company' s' prescribed level.When a package or assembly contains items of different levels, the Companyclassifies it to the highest level designated for any of the items contained.
Page 1 of 2Revision 90
- HANDLING, STORAGE, AND SHIPPING CATR1CHAPTER 132.4. Special Handling Tools and Equipment The Company inspects and tests special handling tools and equipment usingprocedures at specified time intervals to verify adequate maintenance.
TheCompany provides special handling procedures and instructions for items thatare susceptible to handling damage. These procedures delineate acceptable techniques, necessary qualifications and precautions for maintenance and use.Operators of special handling and lifting equipment have experience or aretrained in their usage.2.5. Marking and LabelingThe Company establishes instructions for marking and labeling to identify,
- maintain, and preserve an item, including indication of the presence of specialenvironments or the need for special controls.
Consumable materials such as chemicals,
- reagents, and lubricants maintained in storerooms and warehouses are controlled procedurally by an inventory control system, which includes provisions for identifying storage requirements and shelf lives by commodity, when applicable.
Disposal of commodities whoseshelf life has expired is addressed and controlled by procedures.
2.6. StoragePeriodic monitoring is performed to assure that storage areas are beingmaintained in accordance with applicable requirements.
Access to storageareas shall be controlled and limited.
Cleanliness and good housekeeping practices shall be enforced at all times in the storage areas. Fire protection measures commensurate with the type of storage area shall be provided andmaintained.
Page 2 of 2 Revision 90Page 2 of 2Revision 90 INSPECTION, TEST, AND OPERATING CHAPTER 14STATUS1, SCOPEMeasures shall be established and documented to identify inspection, test, andoperating status of structures,
- systems, and components in the scope of thisQAP. Such measures shall provide means for assuring that requiredinspections and tests are performed and that the acceptability of items withregard to inspections and tests performed is known throughout procurement, installation, and operation in order to preclude inadvertent bypassing or alteringthe sequence of such inspections and tests.2. REQUIREMENTS 2.1. GeneralThe Company uses markings, tags, stamps, routing cards, labels, forms,inspection
- records, or other means to identify the operating status of plantequipment.
This identification helps avoid inadvertent bypassing of theinspections and tests required prior to its use.In cases where documentary evidence is not available to confirm that an itemhas passed required inspections and tests, that item shall be considered nonconforming.
An operability determination for the nonconforming item withtimeliness commensurate with the potential safety significance of the issue isperformed.
The operability determination is focused on whether the non-conforming item is capable of performing or supporting its specified functions ofprevention or mitigation as described in the current licensing basis and will resultin the determination of continued plant operation.
If operability is assured basedon this prompt determination, plant operation can continue while an appropriate corrective action program is implemented to restore qualification of the non-conforming item.Control procedures describe the use of such tags, stamps, routing cards, labels, forms,inspection
- records, and other methods.
The authority for application and removal of tags,markings, labels and stamps is specified.
- Tagging, labeling, color-coding, physicalseparation, or using an inventory system identifies acceptable or unacceptable items forinstallation.
The Company:-clearly identifies and documents all temporary connections, such asjumpers and bypass lines, and temporary set points of control equipment to allow restoration before placing the item in service.-conditionally releases items for installation pending subsequent correction of any non-conformances.
-indicates the date the item was placed in the acceptable or unacceptable installation status.Page I of 4Revision 90 INSPECTION, TEST, AND OPERATING CHAPTER 14STATUS-maintains
- records, marks equipment to indicate calibration status, andidentifies test equipment found out of calibration.
2.1.1. Procedures
The Company uses procedures for control of equipment to maintain personnel and reactor safety and to avoid unauthorized operation of equipment.
Theseprocedures require control measures such as locking or tagging to secure andidentify equipment in a controlled status. The procedures require independent verifications, where appropriate, to ensure that necessary
- measures, such asequipment
- tagging, have been done correctly.
2.2. Operating Status2.2.1. Release for Maintenance Operating personnel, including a senior reactor operator, as applicable, maygrant permission to release plant systems or equipment for maintenance orsurveillance testing.
Prior to granting permission, such operating personnel:
-verify that the equipment or system can be released.
-determine how long it may be out of service.-determine what functional testing or redundant systems are required priorto and during the out-of-service period.The Company documents such permission.
The Company uses independent verification to the extent necessary to ensure that the proper system wasremoved from service.
The Company considers the degraded protection available when one subsystem of a redundant safety system has been removedfor maintenance or surveillance testing.2.2.2. Preparation for WorkAfter permission has been granted to take the equipment out of service,measures provide for protection of equipment and workers.
The Companyclearly identifies the status of equipment and systems at any location where theequipment can be operated.
The Company enforces strict control measures forsuch equipment.
The operating staff can easily identify equipment, which is inother than normal conditions.
In addition to the requirements of the technical specifications, conditions to beconsidered in preparing equipment for maintenance or surveillance testinginclude, for example:-electrical hazards.-entry into closed vessels.-establishment of a path for decay heat removal.-handling hazardous materials.
-hazardous atmospheres and ALARA considerations.
Page 2 of 4Revision 90 INSPECTION, TEST, AND OPERATING CHAPTER 14STATUS-method of emergency core cooling.-shutdown margin.-temperature and pressure of the system.-valves between work and hazardous materials.
-venting,
- draining, and flushing.
When entering a closed system, the Company prevents the entry of extraneous material and removes foreign material before re-closing the system. Appropriate personnel inform control room supervision of changes in equipment status,including temporary modifications, and the effects of such changes.2.2.3. Temporary Modifications The Company controls temporary modifications, such as temporary bypasslines, electrical
- jumpers, lifted electrical leads, and temporary trip point settingswith approved procedures.
These procedures include requirements for theperiod of time when the temporary modification is in effect. They also include arequirement for:-a verification by a second person of the proper installation or removal ofthe temporary modification, or-a functional test which conclusively proves the proper installation orremoval of the temporary modification.
The Company maintains a log or other documented evidence for the currentstatus of such- temporary modifications.
The Company reviews temporary modifications periodically to assess their continued need and propriety.
2.2.4. Return to ServiceWhen equipment is ready to be returned to service, operating personnel placethe equipment in operation and verify and document its functional acceptability.
The Company assures return to normal conditions using approved procedures, including:
-removal of electrical jumpers.-removal of signals used during testing.-returning valves, breakers, or switches to proper start-up or operating positions.
-assuring that all alarms, which are indicative of inoperative status, arecleared.A second qualified person verifies proper alignment of equipment unless:-all equipment, valves and switches involved in the activity can be provento be in their correct alignment by functional testing without adversely affecting the safety of the plant, or-such verification would result in significant radiation exposure.
Page 3 of 4Revision 90 INSPECTION, TEST, AND OPERATING CHAPTER 14STATUSThe person who performs verifications (independent or concurrent) is qualified toperform such tasks. When placed into service, equipment receives additional surveillance during the run-in period. The on-duty supervisor responsible for theunit formally accepts equipment, which is returned to service.Page 4 of 4 Revision 90Page 4 of 4Revision 90 NONCONFORMING MATERIALS, PARTS, OR COMPONENTS
- 1. SCOPECHAPTER 15Controls shall provide for identification, evaluation, segregation when practical, disposition of nonconforming items, and for notification to affected organizations.
Items that do not conform to specified requirements shall be controlled toprevent inadvertent installation or use.2. REQUIREMENTS 2.1. GeneralNonconforming items are processed in accordance with the corrective actionprogram and / or documented procedures.
The Company uses writtenprocedures to identify and control items, services or activities that do notconform to requirements.
These procedures address the:-disposition of nonconforming items.-documentation of identified nonconformances.
-identification of nonconforming items.-notification of affected organizations.
-operability determination of the SSC with the identified nonconforming condition
-segregation of nonconforming items.Implementation of these procedures prevents the inadvertent use, operation, orunauthorized installation of nonconforming items.2.1.1. Supplier Nonconforming ItemsThe Company and its suppliers establish and document measures for theidentification, control and disposition of items and services that do not meetprocurement document requirements.
These measures provide for:-a review of nonconforming items.-supplier notification to the Company of a nonconformance.
Thesenotifications include a supplier recommended disposition (e.g. "use -as -is" or "repair")
and technical justification.
The supplier submitsnonconformances to the Company for approval if:-the supplier has violated a technical or material requirement, or-the supplier has violated a requirement in supplier documents, which have been approved by the Company, or-the supplier cannot correct the nonconformance by continuation ofthe original manufacturing process or by rework, orPage 1 of 4 Revision 90Page I of 4Revision 90 NONCONFORMING MATERIALS, CHAPTER 15PARTS, OR COMPONENTS
-the item does not conform to the original procurement requirement even though the item can be restored to a condition such that thecapability of the item to function is unimpaired.
-Company disposition of supplier recommendations.
-verification of disposition for nonconformances.
-maintenance of records for supplier nonconformances.
2.2. Identification
The Company identifies nonconforming items by marking,
- tagging, or othermethods, which do not adversely affect the end use of the item. Theidentification is legible and easily recognizable.
2.3. Segregation
When practical, the Company segregates nonconforming items by placing themin a clearly identified and designated hold area until properly dispositioned.
When segregation is impractical or impossible due to physical conditions suchas size, weight or access limitations, other precautions are employed to precludeinadvertent use of a nonconforming item.2.4. Disposition 2.4.1. ControlNonconforming characteristics shall be reviewed and recommended dispositions of nonconforming items shall be proposed and approved in accordance withdocumented procedures.
Further processing,
- delivery, installation, or use of anonconforming item shall be controlled pending an evaluation and an approveddisposition by authorized personnel.
2.4.2. Evaluation
The Company has responsibility for resolution of nonconformances inaccordance with written procedures.
Where ASME Code requirements areinvolved, the Authorized Inspection Agency reviews and accepts or rejects thedisposition and justification.
Engineering provides technical justification andindependent review of nonconformances dispositioned as repair or use-as-is.
For items under a contractor's direct control, the Company may delegate to thecontractor the authority to perform a technical evaluation of nonconformances, ifthe contractor has an acceptable procedure for handling nonconforming items.Where the Company delegates such authority, the contractor is responsible forestablishing that:-all actions fall within the requirements set by the Company.-an accepted nonconformance meets the design intent.-ASME Code items meet the requirements of the ASME Code.Page 2 of 4Revision 90 NONCONFORMING MATERIALS, CHAPTER 15PARTS, OR COMPONENTS
-personnel performing the evaluation meet the requirements of section2.4.3 below.When a technical evaluation has not been delegated to a supplier, the Companymakes a technical evaluation of all pertinent data relating to the nonconformity, including the cause, where known, and the corrective action either taken orplanned to prevent recurrence per the corrective action program.
The Companyretains the responsibility for the satisfactory resolution of suppliernonconformances.
2.4.3. Personnel
Personnel having expertise in the pertinent discipline determine whether anonconforming item may be accepted "as -is," may be repaired to anacceptable condition, or must be rejected.
These personnel have adequatecompetence and knowledge necessary to make this evaluation and have accessto pertinent background information.
2.4.4. Documentation
The Company identifies nonconforming items and documents their disposition as applicable (e.g. use -as -is, reject, repair, or rework).
Technical justification for the acceptability of a nonconforming item, dispositioned as repair, or use-as-is, is documented and traceable to each item. Appropriate documentation isretained.
Nonconformances to design requirements that are dispositioned as "use -as -is" or "repair" is subject to design control measures commensurate with thoseapplied to the original design. The Company technically justifies dispositions designated "use -as -is," and "repair" to assure that the final condition of anynonconforming item meets applicable code requirements and will not adversely affect the safety, operability, or maintainability of the item, or of the component or system in which it is installed.
The "as -built" records, if such records arerequired, reflect the accepted deviation.
If the nonconformance can be corrected after installation, the item may bereleased for installation on a conditional release basis. The Companydocuments the authority and technical justification for the conditional release ofthe item and makes it part of the documentation.
2.4.5. Repaired,
- Reworked, or Scrapped ItemsThe Company re-examines repaired or reworked items using procedures andthe original acceptance criteria unless the nonconforming item's disposition hasestablished alternate acceptance criteria.
Items that have been corrected arere-inspected or re-tested as required by the approved disposition.
Page 3 of 4 Revision 90Page 3 of 4Revision 90 NONCONFORMING MATERIALS, CHAPTER 15PARTS, OR COMPONENTS The area of inspection may be confined to the area of the nonconformance.
When it has been determined that the corrected item is satisfactory, the status ofthe item is changed to "acceptable" and an appropriate entry is made in thedocumentation after acceptance is determined.
The Company scraps, discards or transfers to training usage a nonconforming item that cannot be corrected or accepted "as -is." Nonconforming items thatare being used for training must be controlled (e.g. administratively controlled, permanently identified, marked, obliterate Material ID Tag or Q level indicators) to prevent inadvertent or inappropriate use of the item.Page 4 of 4 Revision 90Page 4 of 4Revision 90 CORRECTIVE ACTIONCHAPTER 161. SCOPEThis Chapter describes the Company program to identify and correct conditions adverse to quality.2. REQUIREMENTS 2.1. GeneralThe Company implements a Corrective Action Program to promptly identify andcorrect items or occurrences that are adverse to quality or might adversely affectthe safe operation of a nuclear generating station.
These items or occurrences are screened for reportability, operability, Part 21, etc. The Company makes athorough investigation of occurrences and identifies corrective action to preventrecurrence of an event, as appropriate.
Events may include reactor trips, failedequipment, personnel errors, and procedural infractions.
Measures are taken toassure that the cause of any significant condition adverse to quality isdetermined and takes corrective action to prevent recurrence.
2.2. Conditions Adverse to QualityMeasures are established to assure that conditions adverse to quality areidentified and corrected.
Examples of conditions adverse to quality are providedin procedures.
Examples include failures, malfunctions, adverse trends,deficiencies (including programmatic),
deviations, defective
- material, designerrors, equipment, and nonconformance to specified requirements.
An independent review body reviews violations, deviations and reportable events that require a report to the NRC in accordance with regulatory requirements and company procedures.
This includes the review of results ofany investigations made and the recommendations resulting from suchinvestigations.
These include items such as:-Licensee Event Reports (LER)-significant operating abnormalities or deviations from normal or expectedperformance of plant safety-related structures,
- systems, or components.
-violations of applicable codes, regulations, orders, technical specifications, license requirements or internal procedures or instructions having safety significance.
2.2.1. Significant Conditions Adverse to QualityIn cases of significant conditions adverse to quality the cause of the condition isdetermined and documented, resolution determined and documented, andcorrective action taken and documented to preclude recurrence.
Page 1 of 4 Revision 90Page 1 of 4Revision 90 CORRECTIVE ACTIONCHAPTER 161. Procurement The Company uses procedures that include methods for the identification of conditions adverse to quality and for timely corrective action. TheCompany requires individual vendors and their contractors to includecorrective action measures in their quality assurance programs.
In casesof significant conditions adverse to quality that arise during theprocurement
- process, the Company uses procedures to describe themethod used to:-identify and document deviations and non-conformances.
-review and evaluate the conditions to determine the cause, extentand measures needed to correct and prevent recurrence.
-report the conditions and corrective action to the appropriate levelsof management.
-implement and maintain required corrective action.2. Plant Hardware Malfunctions The causes of malfunctions are determined, evaluated, and recorded, asappropriate.
Experience with the malfunctioning equipment and similarcomponents are reviewed and evaluated to determine if a replacement component of the same type can be expected to perform the functionreliably.
If evidence indicates that common components in safety-related systems have performed unsatisfactorily, corrective measures areplanned prior to replacement or repair of all such components.
Appropriate procedures are revised in a timely manner to preventrecurrence of equipment malfunction or abnormal operation.
- 3. Incorrect DesignWhen a significant design change is necessary because of an incorrect design, the Company reviews and modifies the design process andverification procedures, as appropriate.
In cases of significant orrecurring deficiencies (or errors),
the Company follows written procedures to correct the deficiency (or error), determine the cause and makechanges in the design process and the QAP to prevent similar types ofdeficiencies (or errors) from recurring.
2.3. Verification and Follow-up The Company verifies completion of corrective actions for maintenance, repair,refueling, operation activities, completion of corrective action taken forassessment deficiencies (including programmatic),
and performs assessments of site corrective action. The Company tracks and verifies completion ofcorrective action taken for independent assessment findings and approves thecompletion of corrective actions.Page 2 of 4 Revision 90Page 2 of 4Revision 90 CORRECTIVE ACTIONCHAPTER 16Trending and assessment results are evaluated to assure that corrective measures are implemented effectively and that actions to prevent recurrence areeffective as appropriate.
The Company also requires contractors and vendors tofollow-up on corrective action commitments within their quality programs.
The Company regularly reviews and analyzes records to:-assure that the causes of a nonconformance and the corrective actionhave been clearly described.
-assure that authorized Company personnel have evaluated the overalleffect resulting from the use of nonconforming items.-determine whether corrective measures will preclude recurrence.
2.4. Evaluation and Qualification Personnel performing the evaluation function are responsible for considering thecause and the feasibility of corrective action to assure that the necessary qualityof an item is not deteriorated.
Where it is determined that the cause cannot becorrected immediately, the due date of corrective action will be determined during the review and evaluation.
Evaluation may indicate the need forinvestigations to assure that corrective measures are considered complete andmay also indicate that the nature of the deficient condition is minor and does notrequire corrective action.Qualified personnel are responsible for determining the root cause(s) of an eventand developing recommendations to preclude recurrence.
These personnel report the results of their determination to appropriate station personnel andCompany management.
2.5. Documentation and Reporting The Company documents the identification of significant conditions adverse toquality, the cause of the condition, the corrective action taken, and reports theseitems to the appropriate levels of management, NSRB, and as applicable, PORC, If the identified issue is not an indication of a significant failure in anyportion of the QAP, the Company does not require reporting to management.
Reports are made immediately if prompt corrective action is required.
Formalreports are filed with the appropriate regulatory agency, when required.
Reportsof investigations include a detailed description of the occurrence, the findings ofthe investigation, and the recommended corrective measures.
The Companynotifies the rest of the nuclear industry of significant events with genericimplications and its circumstances to help preclude a similar event occurring atanother plant.The Company keeps records to identify incidents (e.g., major damage, personalinjury, major schedule delays.),
non-conforming items, unfavorable conditions, programmatic deficiencies identified in assessment
- reports, significant equipment
- failures, and malfunctions that occur during station operation.
Page 3 of 4Revision 90 CORRECTIVE ACTIONCHAPTER 16The Company tracks the completion of corrective actions for conditions adverseto quality and maintains records of their resolution.
Parts or all of this systemmay be electronically monitored and electronic records may be used as the solerecord of such a system.Page 4 of 4 Revision 90Page 4 of 4Revision 90 QUALITY ASSURANCE RECORDSCHAPTER 171. SCOPEThe Company establishes and implements a program, which definesrequirements and responsibilities for identification, generation, collection, compilation,
- storage, maintenance, retention, and retrieval of records necessary to provide evidence of quality in assessment, corrective action,decommissioning, design, engineering, fabrication, installation, inspection, maintenance, modification, operations,
- testing, and associated reviews.2. REQUIREMENTS 2.1. ProgramThe records program provides for:-administration.
-generation
-receipt and transmittal.
-storage and preservation
( includes temporary and permanent records)-safekeeping and classification.
-retention and disposition.
2.2. Administration
Authority and responsibility for record control activities are delineated inprocedures.
Records are administered through a system, which includes anindex of record type, retention period, and storage location.
Distribution ofrecords shall be controlled in accordance with written procedures.
Measures areestablished for replacement, restoration, or substitution of lost or damagedrecords.Records are legible,
- accurate, complete, identifiable, and retrievable.
Recordsare considered valid and complete when dated and stamped, initialed, signed, orotherwise authenticated.
Corrections, revisions, or supplements to completed records are reviewed and approved by an authorized individual in the originating organization.
Such changes are dated and stamped, initialed, signed, orotherwise authenticated including the use of electronic approval andauthorization.
Records may be stored in electronic media provided that the process formanaging and storing data is documented in procedures that comply withapplicable regulations, including NRC guidance in RIS 2000-1 8. Media used forthe retention of records include (but are not limited to): microform, compact disk-recordable (CD-R), and magnetic media including videotape, computer tape,optical disks, and hard disk storage.
Electronic records retention must be anintegral component of the Corporate Records Management
- Program, approvedby the management position responsible for Nuclear Generation records.
ThePage 1 of 5Revision 90 QUALITY ASSURANCE RECORDSCHAPTER 17format used must be capable of producing
- legible, accurate, and completedocuments during the required retention period. Electronic approval andauthorization procedures are established to assure that only those personsauthorized grant the required approvals.
2.3. Receipt and Transmittal A system for receipt control of records is established.
Receipt control is requiredfor records transferred between Company locations, vendors and the Company,and from Company department files to final storage locations.
Systems areestablished to transfer records between Company locations and betweenvendors and the Company.
Records transferred from Company department filesto a final storage location are also under such systems.
The system of receiptcontrol of records for permanent or temporary storage includes inventory oftransmitted
- records, receipt acknowledgment, and control of records duringreceipt.2.4. Storage and Preservation Record storage facilities are established and maintained in a manner thatminimizes the risk of damage or destruction.
Records may be kept by suppliers and maintained on an available basis for a specified period of time. Storage andPreservation systems provide for:-assignment of responsibilities.
-attachment in binders,
- folders, or envelopes for storage in steel filecabinets or on shelving in containers.
-control and accountability of records removed.-damage from natural disasters such as winds, floods, and fires.-following manufacturer recommendations for special recording media.-protection from environmental conditions such as high and lowtemperatures and humidity.
-protection from infestation of insects, mold, or rodents etc.-special processed records such as radiographs, photographs, negatives, microfilm, and magnetic media to prevent damage from excessive light,stacking, electromagnetic fields, temperature and humidity.
Permanent storage alternative below applies to Calvert Cliffs Nuclear PowerPlant. In lieu of the reinforced
- concrete, concrete block, masonry, or equalconstruction requirements of Supplement 17S-1, Section 4.4.1(a),
the recordsvault is entirely enveloped by a structurally sound, fire-resistive building.
Thevault rests on a reinforced slab on grade and its walls extend fully to theunderside of the structural deck. The walls of the vault are constructed ofgypsum wallboard on metal studs per Underwriters Laboratory Test NumberU41 2, assuring the equivalent of 2-hour fire resistant construction.
This is equalconstruction to concrete block in terms of fire protection.
The walls carry nostructural load; hence, they provide equivalent structural integrity to that neededof concrete block. Supplement 17S-1 Section 4.4.1(b) requires floor and roofPage 2 of 5Revision 90 QUALITY ASSURANCE RECORDSCHAPTER 17drainage control.
If a floor drain is provided, a check valve (or equal) shall beincluded.
In lieu of this requirement, the vault is contained within anenvironmentally protected building.
As such, it has no roof, or need for floordrain.Interim storage provisions shall be established to properly maintain and protectrecords until they are permanently transferred to record storage facilities forretention and shall meet one of the following conditions:
- 1. Records shall be stored in steel cabinets located in a fire-resistant building or non-combustible building with a fire suppression system.A fire-resistant building must meet the following:
A facility constructed toresist the initiation or spreading of fire; fire-suppressive and/or non-combustible materials used; building certified as fire-resistant by a personwho specializes in the technical field of fire prevention and fireextinguishing.
- 2. Temporary storage per section 2.4.1.2.4.1. Temporary StorageMeasures are established for temporary storage of records when required by anorganization's procedures for activities such as; for processing, review, or use.These measures require that these records are stored in a 1-hour fire ratedcontainer and that a maximum allowable storage time limit is specified.
2.5. Safekeeping and Classification Measures are established to prevent access to records by unauthorized personnel.
These measures guard against theft and vandalism.
Records areclassified and retained in accordance with applicable regulations.
2.6. Retention and Disposition Record retention periods are established to meet regulatory, UFSAR, andLicense requirements.
The most stringent retention period is implemented whenmultiple requirements exist. Records are dispositioned at the end of theprescribed retention period.2.7. Plant Operating Records2.7.1. Records andlor Logs, 5-Year Retention (unless otherwise noted)Records and/or logs relative to the following items shall be kept in a mannerconvenient for review and shall be retained for at least 5 years unless otherwise noted. These items apply to Braidwood, Byron, Calvert Cliffs, Clinton, Dresden,Ginna, LaSalle,
- Limerick, Nine Mile Point, Peach Bottom (inclUding thePage 3 of 5Revision 90 QUALITY ASSURANCE RECORDSCHAPTER 17Independent Spent Fuel Storage Installation),
and Quad Cities Stations unlessotherwise noted:-records of normal plant operation, including power levels and periods ofoperation at each power level.-records and periodic checks, inspection and/or calibrations performed toverify that the surveillance requirements of the Technical Specifications (and Fire Protection Program at Clinton) are being met. All equipment failing to meet surveillance requirements and the corrective action takenshall be recorded.
-records of physics tests and other tests pertaining to nuclear safety.(Braidwood, Byron, Dresden,
- LaSalle, Peach Bottom, Quad Cities)-records of changes to procedures required by a station's Technical Specifications and other procedures, which affect nuclear safety, asdetermined by the management position holder responsible for plantoperation.
-shift manager/engineers' logs (Braidwood, Byron, Dresden, LaSalle,Quad Cities)-records of principal maintenance activities, including inspection andrepair, (and replacement for Braidwood, Byron, Limerick and PeachBottom) regarding principal items of equipment pertaining to nuclearsafety.-records of changes made to the equipment or reviews of tests andexperiments to comply with 10OCFR50.59 (Dresden and Quad Cities).-records of changes made to the procedures as required by Technical Specifications and the Operational Requirements Manual (Clinton).
-reportable events required by 10CFR50.73 and 10CFR72.216 asapplicable (Clinton 10CFR50.73 only, Calvert Cliffs, Ginna, Limerick, NineMile Point, and Peach Bottom).-records of radioactive shipments (Calvert Cliffs, Ginna, Limerick, andNine Mile Point)-records of secondary water sampling and water quality.
(Calvert Cliffs,Ginna, Nine Mile Point) (Lifetime)
-records of the service lives of all snubbers, including the date at which theservice life commences and associated installation and maintenance records.
(Calvert Cliffs, Ginna, Nine Mile Point Unit 2) (Lifetime)
-records of evaluations performed for changes made to procedures orequipment or evaluations of tests and experiments pursuant to 10 CFR50.59 or 10 CFR 72.48. (Calvert Cliffs, Ginna, Nine Mile Point) (Lifetime)
-records of QA activities required by this QATR and not otherwise listed.(Calvert Cliffs, Ginna, Nine Mile Point) (Lifetime)
Page 4 of 5 Revision 90Page 4 of 5Revision 90 QUALITY ASSURANCE RECORDSCHAPTER 172.7.2. Lifetime RecordsLifetime records are those that are specified by applicable regulations, standards, codes, and licensing basis documents.
Page 5 of 5 Revision 90Page 5 of 5Revision 90 ASSESSMENTS/AUDITS CHAPTER 181. SCOPEA documented, comprehensive system consisting of regulatory audits andperformance assessments of the Company and its vendors are conducted toverify QAP compliance,
- adequacy, and effectiveness.
Audits and assessments are conducted in accordance with written procedures or checklists.
Audits areperformed to the requirements of ASME NQA-1 to evaluate the auditedorganization and to assure completion of required corrective actions,commitments, or improvements and determine effectiveness in meeting programobjectives.
- 2. REQUIREMENTS 2.1. Assessments and Audits -General2.1.1. Scheduling The internal audit program is conducted on a performance driven frequency thatis commensurate with the status and importance of the activity to be completed but does not exceed 24-months.
Internal audit frequencies required byregulation that are different than the 24-month period are indicated withinAppendix B, "Audit Frequency."
Audit frequencies are determined based on aconsideration of the risk and consequences with respect to the activities beingaudited.Audits may be extended beyond their originally scheduled due date based onthe following criteria:
A. Audits shall be performed at the intervals designated in Appendix B, "AuditFrequency".
Schedules are based on the month in which the audit starts.B. A maximum extension not to exceed 25 percent of the audit interval isallowed.
That is to say that, for audits on a 24-month frequency, themaximum time between specific audits does not exceed 30 months.Likewise, audits on an annual (12-month) frequency do not extend beyond15 months. Audits of Emergency Preparedness and Security are notsubject to the extension and will be performed on a frequency not to exceed12 months (or not to exceed 24 months if performed on a 24-monthfrequency).
C. When an audit interval extension greater than one month is used, the nextaudit for that particular audit area is scheduled from the original anniversary month rather than from the month of the extended audit.The NSRB activities will be periodically reviewed for effectiveness at afrequency not to exceed 2 years by experienced Nuclear Oversight personnel and/or industry peers. This review will include an evaluation ofthe NSRB activities for compliance with the QATR requirements.
Page 1 of 4Revision 90 ASSESSMENTS/AUDITS CHAPTER 18ASSESSMENTSIAUDITS CHAPTER 18D. Item B applies to supplier audits and evaluations except that a totalcombined interval for any three consecutive inspection or audit intervals does not exceed 3.25 times the specified inspection or audit interval.
Fleet assessment activities are conducted to identify performance gaps andenable the site to drive towards sustainable performance excellence.
Theseplanned internal assessment activities are performed to a schedule that isapproved by the management position responsible for Fleet Assessments, ordesignated staff member(s).
2.1.2. Preparation
A documented plan or an agenda identifies an audit or assessment scope,requirements, audit or assessment personnel, activities to be evaluated, organizations to be notified, applicable documents, and schedule.
An approvedchecklist or procedure for each scheduled audit or assessment identifies therequirements of the area or items to be evaluated.
Audit plans, agendas,checklists, and procedures as applicable are prepared in advance under thedirection of an Audit Team Leader.2.1.3. Personnel Experienced and qualified personnel perform assessments and audits and arefamiliar with written procedures, standards, and processes applicable to the areabeing evaluated.
Assessment and audit personnel shall have sufficient authority and organizational freedom to make the assessment and audit processmeaningful and effective and shall not have direct responsibilities in the areas tobe assessed or audited.
They shall have access to the plant records necessary to fulfill their function.
The Audit Team Leader shall organize and direct audits and ensure the teamcollectively has the required experience or training for the activities to beevaluated.
Technical Specialists may supplement the team to provide additional experience and competence.
2.1.4. Performance
Performance assessments are conducted to assess specific activities, processes, and records on the basis of their impact and importance relative tosafety, reliability, and functionality with respect to risks and consequences.
Assessments can be focused on areas most in need of improvement.
Audits are initiated early to assure effective quality assurance during design,procurement, manufacturing, construction, installation, inspection,
- testing, andoperations.
Additional unscheduled audits/assessments may also be performed at various stages of activities, based on the nature and safety significance of thework being done; to verify continued adherence to and effectiveness of the 7/quality systems.
Objective evidence shall be examined to the extent necessary JPage 2 of 4 Revision 90Page 2 of 4Revision 90 ASSESSMENTSIAUDITS CHAPTER 18ASSESSMENTSIAUDITS CHAPTER 18to determine that a quality program is being effectively implemented.
2.1.5. Reporting and Follow-up A. AuditsAn audit report includes the description of the audit scope, identification of theteam and personnel contacted during audit activities, a summary of results(including a statement on effectiveness of the QAP elements),
and a description of each finding.
The ATL shall sign the audit report for which he or she isresponsible.
Audit results are documented and distributed to the management positionresponsible for NOS, and to the appropriate managerial level of the organization having responsibility for the area or activity audited.
Findings or deficiencies requiring prompt corrective action are reported immediately to the management of the audited organization.
- Findings, deficiencies and recommendations of each audit shall be reported toappropriate site management and the management position responsible forNOS. All findings of noncompliance with NRC requirements, and any significant nuclear safety or quality issues requiring escalated action, will be directedthrough the management position responsible for NOS to the President andONO in accordance with procedural requirements.
Responsible management shall take the necessary actions to correct findingsidentified in the audit. They will identify the corrective action to be taken, actionsthat will prevent recurrence, and a schedule for implementing these actions.Responses to audit findings are reviewed for adequacy.
Follow-up verification of the completion of scheduled corrective actioncommitments are performed by NOS to assure findings or adverse conditions are corrected in accordance with procedural requirements.
Follow-up action ofprevious deficient areas or adverse conditions (including re-audit) is taken toverify that corrective action has been completed, is effective, implementation continues, and is properly documented, when indicated.
B. Assessments Assessment reports will include a description of the assessment scope,identification of the team, a summary of results, and a description of eachassessment identified issue. Issues will be reported to the appropriate site!corporate management and to the management position responsible forOrganizational Effectiveness and Integrated Performance Assessments (OR&IPA).
All significant issues requiring escalated action will be directedthrough the management position responsible for OR&IPA to the President andCNO in accordance with procedural requirements.
Follow-up of previously identified assessment issues will be performed in accordance with procedural requirements.
Page 3 of 4 Revision 90 ASSESSMENTSIAUDITS CHAPTER 18ASSESSMENTSIAUDITS CHAPTER 182.1.6. RecordsAudit and Assessment results are documented and reports are generated andretained as applicable.
Associated documentation is on file at the appropriate location.
Personnel qualification records for assessment and audit teammembers are established, maintained, and reviewed as required.
2.2. Vendor AuditsAudits, or surveys of vendors and their sub-tier suppliers are performed to a pre-established schedule.
Audits are performed on a triennial basis. Documented supplier performance monitoring is performed in accordance with approvedprocedures as an acceptable alternate to the performance of the annualevaluation of suppliers.
The management position responsible for audits andprograms or designee, shall review and approve the audit/survey schedule andchecklists, and sign reports.
Schedules are reviewed semi-annually and revised'accordingly to assure that suppliers are audited, or surveyed as required.
Audit program requirements are imposed on suppliers by appropriate contract orprocurement documents.
The Company's active participation in nuclear industryaudits provides an alternative means to fulfilling its responsibility for examining supplier activities.
2.3. Independent Management AuditA periodic audit (not to exceed 24 months) of the status and adequacy of theQAP is performed by an independent organization to assure that audits arebeing accomplished to program requirements.
In addition, this will include anevaluation of the NSRB activities for compliance with the QATR requirements.
The management position responsible for NOS submits the results of this auditto the President and CNO.Page 4 of 4 Revision 90 AUGMENTED QUALITYAPPENDIX A1. SCOPEIt is the Company's policy to assure a high degree of availability and reliability forits nuclear plants while ensuring the health and safety of the public and itsworkers.
Therefore, the Quality Assurance Program is applied in a gradedmanner to certain areas and activities that are not clearly defined as safetyrelated.
The Company calls this application Augmented Quality.
Augmented Quality includes systems and components that are subject to the requirements of ASME Code Sections:
I "Power Boilers,"
IV "Hot Water Heaters,"
and VIII"Non-fired Pressure Vessels" (see sub-section 2.7. below). This appendixapplies to all sites unless otherwise noted below or in Appendices B through G.2. REQUIREMENTS The Company applies the following augmented quality requirements to certainsystems, structures, components (SSC), and activities that are not safety relatedto a degree consistent with their importance to safety. Unless otherwise noted:-routine audits are performed of the program's content andimplementation.
-deficiencies are addressed in accordance with the corrective actionprogram.-program records of audits and reviews are maintained as required.
2.1. Health Physics and ALARA (As Low As Reasonably Achievable)
The Company develops, documents, and implements a radiation protection program sufficient to ensure compliance with the provisions of 10OCFR20.
TheCompany uses, to the extent practical, procedures and engineering controlsbased on sound radiation protection principles to achieve occupational dosesand doses to the public that are as low as reasonably achievable.
2.2. Transport of Radioactive WasteWhen the Company contracts with vendors to transport radioactive waste inNRC approved shipping
- packages, it meets the requirements of IOCFR71,Subpart H. The Company assures that this service is procured from anorganization with a QA program and if applicable, includes a NRC licensedtransport system. Loading, surveying,
- closure, placarding, and inspections areconducted in accordance with written procedures and instructions.
Transport casks and trailers are inspected before release in accordance withDepartment of Transportation (DOT) 49CFR.Shipping manifests, including final radiation
- surveys, are completed andretained.
Radioactive waste shipments not meeting the requirements for NRCapproved packaging, shall meet the requirements of DOT 49CFR.Page 1 of 6 Revision 90 AUGMENTED QUALITYAPPENDIX A2.3. ServicesThe Company procures services from qualified suppliers.
It is not necessary thatthese suppliers have a quality assurance program approved by the licensee,
- however, suppliers should provide a quality assurance program that includes thequality assurance program elements presented in Reg. Guide 4.15, androutinely provide program data summaries sufficiently detailed to permitevaluation of the program for the following areas:-meteorology.
-Offsite Dose Calculation Manual.-radiological environmental monitoring.
2.4. Fire Protection 10OCFR50 Appendix A, General Design Criteria (GDC) 3 requires that theCompany's nuclear facilities have an established fire protection program thatprovides fire protection features such that the adverse effect of fires onstructures, systems and components important to safety is minimized.
Thequality assurance program established for these fire protection SSCs ensuresthat design, procurement, instruction, procedures,
- drawings, inspection, installation,
- testing, maintenance, operations, nonconforming Items, corrective Action, records, audits and administrative controls meet the applicable QualityAssurance guidelines as described in the applicable edition of Branch Technical Position (BTP) 9.5-1 for each Exelon site. Engineering determines what fireprotection SSCs protect Structures,
- Systems, and Components important tosafety. Engineering also establishes the requirements for the design,procurement, fabrication, installation and/or modification of these fire protection SSCs. Routine testing of fire protection systems assures reliability.
All other fireprotection equipment and supplies will be of commercial
- quality, in accordance with National Fire Protection Association (NFPA) guidelines.
2.5. Station Blackout (Regulatory Guide 1.155)Calvert Cliffs, Dresden,
- LaSalle, Limerick, Nine Mile Point Unit 1, Nine Mile PointUnit 2, Oyster Creek, Quad Cities and Three Mile Island stations rely on non-safety related equipment to achieve the redundancy required by 10CFR50.63.
Quality Assurance requirements for Calvert Cliffs, Dresden,
- LaSalle, Limerick, Nine Mile Point Units 1 and 2, Oyster Creek, Quad Cities and Three Mile Islandare implemented in accordance with Regulatory Guide 1.155 (Station Blackout),
Appendix A and B. Replacement and consumable parts and supplies areclassified non-safety related in accordance with original specifications and areprocured as commercial items. Routine testing of Station Blackout (SBO) SSCsassures the necessary redundancy is maintained.
SBO SSC reliability ismonitored in accordance with the Station's Maintenance Rule program.Page 2 of 6 Revision 90 AUGMENTED QUALITYAPPENDIX A2.6. Augmented Quality Requirements for Dresden 1, and Peach Bottom 1Dresden 1, and Peach Bottom 1, have ceased commercial operation and willultimately be decommissioned.
- Staffing, qualification of personnel, andorganization will be in accordance with the Dresden 1 De-fueled Technical Specifications (DTS) and De-fueled Safety Analysis Reports (DSAR), and thePeach Bottom 1 Updated Final Safety Analysis Report (UFSAR) and Technical Specifications.
Except for inspections or examinations required for ASME repairs andreplacements, station personnel may perform inspections provided they areexperienced, task-qualified personnel or supervisors who did not supervise theactivity being inspected.
Nuclear Oversight will monitor this activity throughperiodic overview.
Timeliness of corrective actions is prioritized commensurate with the safetysignificance.
Sufficient records of maintenance and modification activities will bemaintained to evaluate
- failures, perform root cause analysis, if applicable, anddetermine appropriate corrective actions and to meet the requirements of theapplicable DSAR or Peach Bottom Unit 1 UFSAR.2.7. Repairs and Alterations The requirements of ASME Code Sections II, V and IX shall be imposed asapplicable for the repair or alteration job specific work scope.2.7.1. State of IllinoisWelded repairs and all alterations to non-ISI boilers and pressure
- vessels, asdescribed in Section 505.2500 of the rules contained in the Illinois Emergency Management Agency (IEMA) Safe Operation of Nuclear Facility Boilers andPressure Vessels (Part 505), and the repair of pressure relief valves, asdescribed in Section 505.2500(b) are conducted in accordance withSection 505.2500(a)(1
)(A) of these rules.Section 505.2500(a)(1
)(A) requires that the Company apply an approved QualityAssurance (QA) Program to such repairs and alterations and describe how it isapplied.
The following describes the Company's application of these rules.-The Company has a QA Program that is reviewed and accepted by theNRC. In addition, the QA Program is reviewed and accepted by anaccredited Authorized Inspection Agency. Authorized Inspectors arepresent at each of the Company's plants while ASME Code work is inprogress.
-Chapter 1 of this QA Program describes the authority and responsibilities of the organization.
It also describes the retention of responsibility by theCompany when repair and modification activities are subcontracted.
-Chapter 3 requires that design and changes to designs be defined,documented, and controlled.
Page 3 of 6 Revision 90 AUGMENTED QUALITYAPPENDIX A-Chapter 5 requires that all work be accomplished in accordance withdocumented instructions and procedures and be subject to appropriate process controls.
Specifically, the Company uses the Nuclear WorkRequest (NWR) to authorize, track, and control work in the plant. TheNWR system includes provisions for specifying when work is ASME Coderelated and is not limited to any particular section of the ASME Code. Itfurther provides for detailed instructions to accomplish the work. Thisincludes the need for qualified inspectors, qualified
- welders, qualified procedures, special processes, required documentation, approveddrawings, and post-maintenance/post-modification testing.
NWRsmarked as ASME Code work is offered to the Authorized Inspector for theinsertion of hold and witness points.-Chapters 4, 7, 8, and 13 address the procurement, receiving,
- handling, storage, disbursement, and marking of materials.
Implementing procedures establish traceability of materials to the procurement andreceiving processes and provide assurance that only ASME Codeacceptable materials are utilized.
Any specific requirements for heattraceability will be in accordance with the applicable sections of the ASMECode being used.-Chapter 9 details the controls for special processes while Chapter 10details those for inspection.
This includes the requirement for the use ofindependent, qualified inspectors and examiners when required by theASME Code, and invokes the Company's Special Processes andProcedures Manual (SPPM). The SPPM is also reviewed and acceptedby the Authorized Inspection Agency.-Chapters 6 and 17 require that documents and records be generated andmaintained to satisfy the requirements of the ASME Code and theJurisdiction.
-Chapter 18 provides for overview and audit of ASME Code activities.
Repairs and alterations performed as described above meet the requirements ofthe approved QA Program and meet the requirements of the IEMA B&PV rules;regardless of the safety classification of the boiler or pressure vessel or pressurerelief valve being repaired.
2.8. Dry Cask Storage System2.8.1. Limerick, Peach Bottom, Oyster Creek, Calvert Cliffs, Ginna, and Nine MilePointISFSI quality assurance program requirements are performed in accordance with the applicable I0CFR72.212 report which invokes the portions of the NRCapproved 10OCFR50 Appendix B quality assurance program as described in thisQATR, commensurate with the safety classification of the component and qualityrequirements specified in the cask vendor Final Safety Analysis Report (ESAR)or site specific license.Page 4 of 6 Revision 90 AUGMENTED QUALITYAPPENDIX A2.8.2. Braidwood, Byron, Clinton,
- Dresden, LaSalle and Quad Cities Station(s)
The ISFSI SSCs that are important to safety are categorized as Category A, B,or C in accordance with NUREG/CR-6407, "Classification of Transportation Packaging and Dry Spent Fuel Storage System Components According toImportance to Safety."
Per 1OCFR72, Subpart G, the QATR applies to the ISFSISSCs and activities consistent with their importance to safety as identified in theclassification table on next page identifies the graded approach and applicability of the Exelon QA Program Chapters based on the safety categories that aredefined in NUREG/CR-6407.
2.9. Emergency PlanningRequirements with respect to audits and records for Emergency Preparedness are described in an Emergency Plan that meets the requirements of10CFR50.47.
2.10.Security2.11Requirements with respect to audits and records for Security are controlled foreach station by an NRC approved Station Security Plan that is prepared andimplemented in accordance with the requirements contained in 10CFR73.55.
License RenewalConsistent with the requirements of 10 CFR 54.21 (a)(3), the companyimplements the requirements of QATR Chapters 1 through 18 for agingmanagement activities related to safety related SSCs.Additionally, to manage the aging effects of non-safety related SSCs that weredetermined to be within the scope of License Renewal, the company implements the administrative
- controls, corrective actions and confirmation processes described in QATR Chapters 6, 16 and the applicable requirements of this appendix.
Page 5 of 6 Revision 90Page 5 of 6Revision 90 AUGMENTED QUALITYAPPENDIX AAUGMENTED QUALITY APPENDIX AISFSI REQUIREMENTS Important to Safety SSCs CategoryChapter Title_ _ _ _ _ _ _ _ A B COrganization 1M M R(Roles and Responsibilities)________
Quality Assurance Program2 M M NR(Paragraphs 2.1, 2.4, 2.5, and 2.6) ______3 Design Control M M R4 Procurement Document Control M R NR5 Instructions, Procedures, and Drawings M M R6 Document Control M M RControl of Purchase
- Material, Equipment, andMRRServicesMRR 8 Identification and Control of Materials, Parts, andMRRComponentsMRR 9 Control of Special Processes M M R10 Inspections M M RTest Control,11 (Design, Fabrication, Installation, and Maintenance)
M M R12 Control of Measuring, and Test Equipment M M R13 Handling,
- Storage, and Shipping M R NR14 Inspection, Test, and Operating Status M M NR15 Nonconforming Materials, Parts, or Components M M R16 Corrective Action M M R17 Quality Assurance Records M M R18 Audits M M R(M) Mandatory
= Indicates the Appendix B QA Program shall be used.(R) Recommended
= Indicates application of the applicable quality assurance criterion may benefit the user.The Engineering organization shall determine the extent of application required for the SSCs in question.
O (NR) Not Required
= Indicates that little benefit has been identified or no regulatory basis has been found torequire application of applicable QA criteria.
Imprudent use of this criterion may add unnecessary burden.Page 6 of 6 Revision 90Page 6 of 6Revision 90 AUDITFREQUENCY APPENDIX BInternal audits shall be conducted on a performance driven frequency, not toexceed 24 months or at the frequencies indicated below, in accordance with theCompany's QAP. Audits shall include the following safety-related functions asapplicable:
AUDIT FREQUENCY
- a. The conformance of unit operation to provisions contained within 24 Monthsthe technical specifications and applicable license conditions.
- b. The adherence to procedures,
- training, and qualification of the 24Mnhstation staff.c. The results of actions taken to correct deficiencies occurring in 24 Monthsfacility equipment, structures,
- systems, components, or methodof operation that affect nuclear safety (CAP).d. The performance of activities required by the Quality Assurance 24 MonthsProgram to meet the criteria of Appendix B of 10OCFR5O.
- Chemistry
- Engineering
-Design Control,* Engineering
-Programs* Procurement
/ Materials Management
- Maintenance
- Nuclear Fuels* Operations
- Quality Assurance Functions (internal and vendor audit\assessment activities are evaluated by NIEP.)e. The fire protection programmatic controls including the 24 Monthsimplementing procedures (by qualified Nuclear Oversight personnel).
- f. The fire protection equipment and program implementation, 24 Monthsincluding loss prevention, utilizing either a qualified offsitelicensee fire protection engineer or an outside, independent fireprotection consultant.
An outside, independent fire protection consultant shall be used at least every second year.g. The Radiological Environmental Monitoring Program (REMP) 24 Monthsand its results.h. The Offsite Dose Calculation Manual (ODCM) and implementing 24 Monthsprocedures.
Page 1 of 3Revision 90 AUDIT FREQUENCY APPENDIX BAUI RQECYAPNI AUDIT FREQUENCY
- i. The Process Control Program (PCP) and implementing 24 Monthsprocedures for the solidification of radioactive wastes.j. The non-radiological environmental monitoring activities required 24 Monthsby the Appendix B of the Facility Operating Licenses.
(Note:Dresden and TMI do not have an Environmental Appendix totheir Facility Operating Licenses.)
- k. Randomly selected procedures to ensure that the programmatic 24 Monthscontrol processes used to assure that procedures are technically and administratively correct prior to use are resulting in timelyand accurate procedure revisions.
I.The Security Plan and implementing procedures per 10CFR73.55 24 MonthsMinimally review each element of the physical protection programat least every 24 months. Including:
(i) Within 12 months following initial implementation of thephysical protection program or a change to personnel, procedures, equipment, or facilities that potentially couldadversely affect security.
(ii) As necessary based upon site-specific
- analyses, assessments, or other performance indicators.
(Reference 10OCFR73.55 and 10OCFR50.54(p)(3)(ii))
- m. The Emergency Plan and implementing procedures (Reference 12 Months10OCFR50.54(t)(1
)(ii) for lesser frequency requirements).
- n. Deletedo. The conformance of Spent Fuel Storage Installation operation to 24 Monthsprovisions contained within the technical specifications andapplicable license conditions and results of actions taken tocorrect deficiencies occurring in facility equipment, structures, syst'ems, components, or methods of operation affecting nuclearsafety (Reference NUREGICR-6407, and 10CFR72, Subpart G)(ISFSI sites only).p. Access Authorization Program (10OCFR73.56) 24 Months(Initial Audit frequency is 12 months and 24 months thereafter)
(Ref. RIS 2005-14)q. Personnel Access Data System (PADS) (10CFR73.56) 24 Months(Initial Audit frequency is 12 months and 24 months thereafter)
(Ref RIS 2005-14)
_______Page 2 of 3Revision 90 AUDITFREQUENCY APPENDIX BAUDIT FREQUENCY
- r. Deleteds. Fitness For Duty (FFD) Program (10CFR26.41) 24 Monthst. Station Black Out (Reg. Guide 1.155, Appendix A)24MnhAudits should be conducted and documented to verifycompliance with design and procurement documents, instructions, procedures,
- drawings, and inspection and testactivities developed to comply with 100FR50.63.
(Dresden,
- LaSalle, Limerick, Oyster Creek, Quad Cities, and Three MileIsland Only)u. Radiation Protection activities as defined in I0CFR20.24Mnh
- v. Plant Operations Review Committee (PORC) 24 Monthsw. Decommissioned Units 24 Monthsx. Cyber Security Program (10CFR 73.55(m)).
24 Months(Initial Audit frequency is 12 months and 24 months thereafter)
Page 3 of 3 Revision 90Page 3 of 3Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX C1.1. Codes and Standards The QAP takes into account the need for special controls, processes, testequipment, tools, and skills necessary to attain the required quality and the needfor the verification of quality by inspection and test. The Codes and Standards listed below represent a listing of quality assurance codes and standards used todefine the quality assurance program.
A general listing of quality assurance related codes and standards, such as: ASME B&PV, ANSI, AWS, and IEEE usedthroughout Exelon at each nuclear site can be found in the applicable site specificUpdated Final Safety Analysis Reports (UFSARs).
The UFSAR should bereferenced to identify site-specific commitments (including dates and/oraddendas) with respect to these codes and standards.
This Quality Assurance Program (QAP) complies with the quality requirements of the following codes andstandards as indicated in site specific UFSARs unless otherwise noted in sub-section 1.3 (the UFSAR may address position specific exceptions or clarifications on a site by site basis).-ANSI N18.1 -1971, "Selection and Training of Nuclear Power PlantPersonnel" (For Braidwood, Byron, Dresden,
- LaSalle, Peach Bottom,Quad Cities, Licensed Operators shall comply only with the requirements of 10 CFR 55) *Dresden,
- LaSalle,
- Oyster Creek (for RP personnel),
- Peach Bottom, *Quad Cities, and *TMI (RP and RP Supervisors only)(* per station Technical Specification, this does not include the LeadHP/RP person, who shall meet Reg. Guide 1.8)-ANSI /ANS 3.1 -1978, "American National Standard for Selection andTraining of Nuclear Power Plant Personnel" (Applicable to Clinton (for non-licensed personnel),
- Limerick, Oyster Creek, and TMI) (For Clinton,Limerick, Oyster Creek, and TMI , Licensed Operators shall comply onlywith the requirements of 10 CFR 55)-ANSI /ANS 3.1 -1981, "Selection, Qualification and Training of personnel for Nuclear Power Plants" Applies to Peach Bottom (for SQRs), LaSalle(for reactor engineers),
and Clinton (for chemistry supervisors).
-For Calvert Cliffs, Ginna, and Nine Mile Point, Licensed Operators shallcomply with the requirements of 10 CFR 55.-ANSI N18.7-1 976 /ANS 3.2, "Administrative Controls and QualityAssurance for the Operational Phase of Nuclear Power Plants."(Applicable to Limerick, Oyster Creek, TMI, and Clinton Only)-ANSI N18.7-1972 "Administrative Controls for Nuclear Power Plants"(Applicable to Peach Bottom Only)-ANSI / ANS 3.2 -1988, "Administrative Controls and Quality Assurance forthe Operational Phase of Nuclear Power Plants."
(Exception
-Exelon willimplement the requirements of 10OCFR26 for control of work hours in lieu ofthose specified in section 5.2.1.7 of this standard.)(Applicable toBraidwood, Byron, Dresden,
- LaSalle, and Quad Cities Only)-ASME NQA-1 (1994) (Revision and Consolidation of ASME NQA-1 -1 989and ASME NQA-2-1 989 Editions)
"Quality Assurance Requirements forNuclear Facility Applications" Part I, "Basic Requirements andPage 1 of 17Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX CSupplementary Requirements for Nuclear Facilities; Part II, "QualityAssurance Requirements for Nuclear Facility Applications;"
and Part Ill,"Nonmandatory Appendices,"
limited to Appendix 2A-1, "Nonmandatory Guidance on Qualifications of Inspection and Test Personnel,"
andAppendix 1 7A-1, Nonmandatory Guidance on Quality Assurance Records."
Exception:
Exelon qualifies personnel in accordance with the applicable editions of the codes and standards accepted by the NRC asidentified in Company NDE procedures and the Station ISIplans in lieu of SNT-TC-1A, June 1980, as specified in NQA-1,1994, Supplement 2S-2.As noted above, the plants in the Exelon Fleet comply with the ANSI standards associated with administrative controls and quality assurance for the operational phase of nuclear power plant operation.
Each plant complies with their specificstandards with the following exception:
The independent review of Technical Specification
- changes, licenseamendments, or Emergency Plan changes shall be performed by the PORC.NSRB review and approval of Technical Specification
- changes, licenseamendments, or Emergency Plan changes is not required.
1.2. Regulatory GuidesAlthough the QAP complies with the regulatory positions and programmatic quality requirements of the Regulatory Guides identified in this section, the sitespecific Clarifications and Exemptions identified in section 1.3 should always beverified by reviewing the applicable site specific Updated Final Safety AnalysisReport (UFSAR).-1 .8, "Personnel Qualification and Training."
-1.26, "Quality Group Classification and Standards for Nuclear PowerPlants."-1.28, "Quality Assurance Program Requirements for Design andConstruction."
-1.29, "Seismic Design Classification."
-1 .31 , "Control of Ferrite Content in Stainless Steel Weld Material"
-1.33, "Quality Assurance Program Requirements."
Exceptions:
Audits will be at the frequency defined in Appendix B of thisQATR and PORC review and approval of new or revised administrative procedures recommended by RG 1.33 is not required.
(Ref. SER fromUSNRC to C.G. Pardee, dated Sept. 29, 2008)-1.68, "Pre-Operational and Initial Start-Up Test Programs for Water CooledReactors."
-1.142, "Safety Related Concrete Structures for Nuclear Power Plants."-1.143, "Design Guidance for Radioactive Waste Management SSCsInstalled in Light Water-Cooled Nuclear Power Plants."-4.15 "quality Assurance for Radiological Monitoring Programs (NormalOperations)
-Effluent Streams and the Environment."
Page 2 of 17 Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX C1.3. Site Specific Clarifications and Exceptions 1.3.1. Limerick (LGS) and Peach Bottom Atomic Power Station (PBAPS)1. Regulatory Guide 1.33," Quality Assurance Program Requirements, (Operations),"
endorses ANSI N18.7.LGS shall comply with Regulatory Guide 1.33, Revision 2, February 1978,and ANSI N 18.7-1976/ANS-3.2, "Administrative Controls and QualityAssurance for the Operational Phase of Nuclear Power Plants"'
during theoperational phase except for the following clarifications or alternatives.
A. ANSI N18.7-1976/ANS-3.2, Section 5.2.2, Procedure Adherence
-The term "supervisor in charge of the shift" means either the ShiftManager or Shift Supervisor.
B. ANSI N18.7-1976/ANS-3.2, Section 5.2.7.1, Maintenance Programs:
- 1. Emergency maintenance to safety-related equipment (workwhich must proceed immediately to correct a degradedcondition) may be performed concurrent with procedure preparation and documentation of steps actually taken. Suchmaintenance may be performed with the authorization ofdesignated personnel and subsequent procedure review by thePORC and/or SQR, per Technical Specification requirements.
- 2. The cause of repetitive malfunctions should be determined;
- however, it is not practical, and may not be possible, todetermine the cause of every malfunction.
C. ANSI N18.7-1976/ANS-3.2, Section 5.2.10, "Housekeeping andCleanliness Control".
- 1. Control measures to prevent contamination with foreignmaterials will be specified in administrative procedures and willinclude, as appropriate, access control.2. Second paragraph, first and second sentences are taken tomean: "Where needed to prevent contamination
.... "D. ANSI N18.7-1976/ANS-3.2, Section 5.2.13, "Procurement andMaterials Control"
-Item (1) -Administrative procedures shall specifythe means for control of procurement of commercially "off-the-shelf' items. The administrative procedures shall describe the receiptinspection,
- storage, and handling prior to installation and operation.
Off-the-shelf (catalog) items are evaluated by qualified personnel fortheir intended use. The administrative procedures restrict the use ofcatalog items for only these evaluated applications.
The purchaseorder shall require the vendor to notify the requisitioning organization of a change in an item described in the catalog.E. ANSI N18.7-1976/ANS-3.2, Section 5.2.13.1, "Procurement DocumentControl,"
(second sentence)
-QA Program requirements or alternate approved methods will be used to ensure quality.
Examples ofalternates for suppliers without QA programs include material
- analysis, Page 3 of 17 Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX Csample testing, in-process inspection and monitoring, and designreview by LGS/PBAPS.
F. ANSI N18.7-1976/ANS-3.2, Section 5.2.15, "Review, Approval andControl of Procedures"
-The frequency of review of plant procedures is discussed in UFSAR Section 13.5, except for the following alternative.
- 1. Programmatic controls and processes described in UFSARSection 13.5 are used to assure that procedures are current.These controls take the place of scheduled periodic reviewsG. Emergency
/ Abnormal procedures do not require biennial reviewbased on the equivalent processes noted in NO-AA-10, Chapter 6,Section 2.1.2. Regulatory Guide 1.143, Revision 1, October 1979, "Design Guidance forRadioactive Waste Management
- Systems, Structures, and Components Installed in Light-Water-Cooled Nuclear Power Plants."LGS shall comply with Regulatory Guide 1.143, Revision 1, October 1979,for major modifications, subject to the exceptions and clarifications listed inLGS UFSAR Table 3.2-1, Note 18.3. ASTM D3843-93, "Standard Practice for Quality Assurance for Protective Coatings applied to Nuclear Facilities."
LGS/PBAPS shall comply with ASTM D3843-93 for safety-related protective coating work in service level 1 areas during operation with thefollowing additional clarification, exception, and requirement.
A. For coating formulations developed prior to issuance of ASTM 03843-93, service level 1 qualification based on ANSI N5.9 (Revised asANSI N512-1 974) and ANSI N101.2 remains valid.B. Section 10.1, last sentence
-instead of references to ANSI 45.2 andNQA-1, inspections will be documented for record purposes asrequired by 10OCFR50, Appendix B, and by this QA programdescription.
C. Limitations on use of coatings and cleaning materials which containelements which could contribute to corrosion, inter-granular
- cracking, or stress corrosion cracking of safety-related stainless steel will befollowed as described in Section C.4 of regulatory Guide 1.54, June1973.4. Branch Technical Position (BTP) CMEB 9.5-1:For modification work performed by Exelon Engineering during the operations phase, Exelon Engineering will maintain compliance with the requirements ofCMEB 9.5-1 in accordance with Section 9.5.1.Page 4 of 17 Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX C5. NQA-1, 1994 Supplement 2S-2PBAPS will comply with NQA-1, 1995 Supplement 2S-2 except for thefollowing clarification.
A. NQA-1, 1995 Supplement 2S-2 states that SNT-TC-IA, June 1980shall apply for personnel performing NDE. PBAPS personnel whoperform ISFSl cask leak testing or approve ISFSI leak testprocedures and test results and direct or supervise the conduct ofISFSI leak tests shall be qualified to either SNT-TC-IA or ANSIN18.1-1 971.1.3.2. Oyster Creek (OCNGS) and Three Mile Island (TMI) Stations1. RG 1.8, Revision 1-R (May 1977), Personnel Selection and Training TMI andOC3GS take the following Exceptions Clarifications.
A. Guidelines have long been established in the company with respect toawarding jobs to plant maintenance, operations, and other bargaining unit personnel who may be involved in testing, examination andinspection activities.
Personnel are qualified in accordance with thejob description manual. Exelon believes that the requirements specified in the job description manual meet the intent, and in manycases, exceed the requirements of ANSI N18.1. It is envisioned thatthere may be certain specific cases where an individual will beconsidered qualified because the individual has been evaluated asbeing capable of performing a job, even though the individual doesnot meet the detailed guidance contained in ANSI N 18.1 with respectto length of experience and formal training.
B. The unit staff and the corporate organizations have been upgraded tomeet ANS/ANSI 3.1-1 978 except as otherwise noted in the technical specifications.
C3. Licensed operators shall comply only with the requirements of 10CEFR 55.Page 5 of 17 Revision 90Page 5 of 17Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX C2. Regulatory Guide 1.26, Quality Group Classification and Standards ForNuclear Power Plants, Rev 3 February 1976. TMI and OCGS will complywith this guide with the following exceptions:
A. For modifications to existing plant systems, items will be classified by site engineering according to the original design basis, or thisguide. This classification will not degrade the safety of the systembeing modified.
B. Additions to existing plant systems will be designed and constructed to the same codes, standards, and technical requirements whichwere originally applied to the system to which the addition is to bemade, or more recent versions of these codes, standards, andtechnical requirements.
The addition will not degrade the safety ofthe system being added to.C. For new construction, the latest applicable codes will be utilized, unless such utilization would result in hardship or unusual difficulty without providing an equivalent level of safety.3. Regulatory Guide 1.33, Rev. 2, February 1978, "Quality Assurance Program Requirements (Operation)."
The stations comply with the Regulatory Position of this Guide with thefollowing clarifications:
A. Paragraph 5.2.2 of ANSI N 18.7-1 976, titled "Procedure Adherence."
In accordance with Section 6.8.3 of the OCNGS and TMI Technical Specifications, temporary changes shall be approved by twomembers of the Company's management staff qualified as a 50.59Evaluator/Reviewer who meets the qualification criteria of QATRAppendix G, Sections 2.2.1.14 and 2.3.1.14 and knowledgeable inthe area affected by the procedure.
For changes, which may affectthe operational status of facility systems or equipment, at least oneof these individuals shall be a member of facility management orsupervision holding a Senior Reactor Operator's License on thefacility.
B. Paragraph 5.2.15 of ANSI N18.7 -1976, titled "Review, Approvaland Control of Procedures."
The third sentence of the thirdparagraph is interpreted to mean that applicable procedures shallbe reviewed following a reportable incident such as an accident, anunexpected transient, significant operator error, or equipment malfunction.
In addition, the fourth paragraph is modified to statethat the periodic review of procedures shall include the following four elements; a) At least every two years, Nuclear Oversight will assess arepresentative sample of plant procedures that are usedmore frequently than every two years.Page 6 of 17 Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX Cb) All applicable plant procedures will be reviewed as described in paragraph no. 5.2.15 of ANSI N18.7-1976 as per the notedclarification described for the third sentence of the thirdparagraph.
c) Plant procedures that have been used at least biennially receive scrutiny by individuals knowledgeable in procedures and are updated as necessary to ensure adequacy duringsuitable controlled activities.
d) Plant procedures that have not been used for two years willbe reviewed before use or biennially to determine if changesare necessary or desirable.
- 4. Regulatory Guide 1.54, June 1973, "Quality Assurance Requirements for Protective Coatings Applied to Water Cooled Nuclear PowerPlants."The OCNGS and TMI QAP complies with this Guide with the following clarifications:
A. The Company will comply with the Regulatory Position established in this Regulatory Guide in that programmatic/administrative quality assurance requirements included therein shall apply tomaintenance and modification activities, even though suchrequirements were not in effect originally.
Technical requirements associated with maintenance and modifications (e.g., coderequirements, material properties, design margins, manufacturing processes, and inspection requirements) shall be the originalrequirements or better.B. The quality assurance program for protective coatings includes theplanned and systematic actions necessary to provide adequateconfidence that shop or field coating work for nuclear facilities willperform satisfactorily in service.C. All protective coatings applied to surfaces within containment, except those noted in 3 below, are tested to demonstrate that theycan withstand LOCA conditions.
These tests are performed inaccordance with Section 4 of ANSI N101.2, "Protective Coatings(Paints) for Light Water Nuclear Reactor Containment Facilities,"
under LOCA conditions, which equal or exceed those described inthe FSAR.D. The quality assurance program is applied to protective coatingsconsistent with the nature and scope of work specified in theTechnical Specifications.
The following elements are included:
- 1. Preparation of coatings specifications and procedures forgeneric coating materials/systems.
- 2. Review and evaluation of coating manufacturers' demonstration test data and quality assurance measures forcontrol of manufacture, identification, and performance verification of applied coating systems.Page 7 of 17 Revision 90 I CODES, STANDARDS, AND GUIDESAPPENDIX C3. Review and evaluation of supplier quality assurance measures to control storage and handling, surfacepreparation, application, touch-up, repair, curing andinspection of the coating systems.4. Training and qualification of inspection personnel in coatingsinspection requirements.
- 5. Supplier surveillance inspection.
E. The coatings qualification program and the associated qualityassurance requirements are necessary only for coatings whosefailure or failure mechanism would have a significant effect onsafety.F. Regulatory Guide 1.54 is not imposed for:1. Surfaces to be insulated.
- 2. Surfaces "contained" within a cabinet or enclosure (forexample, the interior surfaces of ducts).3. Field repair on any Q-class coated item of less than 30square inches surface area, such as; cut ends or otherwise damaged galvanizing; bolt heads, nuts, and miscellaneous fasteners; and damage resulting from spot, tack, or studwelding.4. Field touch-up and repair of larger areas shall be inaccordance with item A.5. Small "production line" items such as small motors, handwheels, electrical
- cabinets, control panels, loudspeakers, etc., where special painting requirements would beimpracticable.
- 6. Stainless steel or galvanized surfaces.
- 7. Coating used for the banding of piping.8. Strippable coatings used for cleanup.G. Quality assurance documentation may not be similar to recordsand documents listed in Sections 7.4 through 7.8 of ANSINI101.4, but will be evaluated to assure that they provide at leastthe same degree of documentation as required by this standard.
- 5. Regulatory Guide 1.58, Rev. 1, September 1980, "Qualifications ofNuclear Power Plant Inspection, Examination, and Testing Personnel."
The OCNGS and TMI QAP complies with this Guide with the following clarifications:
A. Plant operation personnel may be utilized to perform the visualleakage examinations required by the edition of ASME SectionXl and related codes currently committed to for the conduct ofin-service inspections.
Such personnel shall be qualified consistent with these ASME Code requirements.
The selection Page 8ofl17 Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX Cand qualification of such personnel shall be prescribed by aprocedure(s).
B. Not all personnel who review and approve inspection and testingprocedures, evaluate the adequacy of activities to accomplish the inspection and test objectives, evaluate the adequacy ofspecific programs used to train and test inspection and testpersonnel, or certify Level III individuals in specific categories orclasses, will be certified as meeting the Level III capability requirements of ANSI N45.2.6-1 978 (NQA-1).
Rather, thesepersonnel will be determined by management to be fullyqualified and competent to perform these functions through,evaluation of their education, experience and training.
Thebasis for the determination will be documented.
- 6. Regulatory Guide 1.123, Rev. 1, July 1977, "Quality Assurance Requirements for Control of Procurement of Items and Services forNuclear Power Plants."The OCNGS and TMI QAP complies with this Guide with the following clarifications:
A. Section 4.2.a of ANSI N45.2.13-1976.
When evaluation of asupplier is based solely on historical supplier data, these data willprimarily include records that have been accumulated inconnection with previous procurement actions.
Data that includesexperience of users of identical or similar products of theprospective supplier and product operating experience will beused if available.
B. Section 10.2.f, Verification of the Validity of Supplier Certificates and the Effectiveness of the Certification System, is as follows:The verification of the validity of supplier certificates and theeffectiveness of the certification system are accomplished as anintegral part of the total supplier control and product acceptance
- program, and no separate Company system exists that addresses itself solely to such verification.
The degree of verification required will depend upon the type of item or service and theirsafety importance.
The means of verification may include sourcewitness/hold points, source audits, and document reviews;independent inspections at the time of material receipt; user testson selected commodities, such as concrete components; and testson selected components and systems after installation.
All ofthese means verify whether or not a supplier has fulfilled procurement document requirements and whether or not acertification system is effective.
- 7. Regulatory Guide 1.142, October 1981, "Safety-Related ConcreteStructures for Nuclear Power Plants (Other Than Reactor Vessels andContainments)."
A. The Company shall comply with the Regulatory Positionestablished in this Regulatory Guide as augmented by ANSIPage 9 of 17 Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX CN45.2.5, ANSI/ANS 6.4-1977, and ANSI/ACI 318-77 for the designand construction of new Safety Related or Augmented Qualitystructures, and additions to existing Safety Related or Augmented Quality structures.
Inspectors will be qualified according to eitherANSI N45.2.6 or Appendix VII of Section III, Division 2, of theASME Boiler and Pressure Vessel Code.8. Regulatory Guide 1.143, October 1979, "Design Guidance for Radioactive Waste Management
- Systems, Structures and Components Installed inLight-Water-Cooled Nuclear Power Plants."Since OCNGS and TMI were originally designed and constructed todifferent classification criteria than those contained in this Guide; theCompany will comply with the Regulatory Position of this Guide with thefollowing clarifications:
A. For modifications to existing plant systems, items will beclassified by Site Engineering according to the original designbasis, or this Guide. This classification will not degrade thesafety of the system being modified.
B. Additions to existing plant systems will be designed andconstructed to the same codes, standards, and technical requirements which were originally applied to the system to whichthe addition is to be made, or more recent versions of thesecodes, standards, and technical requirements.
The addition willnot degrade the safety of the system being added to.C. For new construction, the latest applicable codes will be utilized, unless such utilization would result in hardship or unusualdifficulty without providing an equivalent level of safety.D. Hose may be used in lieu of pipe where the connections aretemporary.
The anticipated applications of hose would normallybe (1) connections to contractor owned skid mounted radioactive waste processing equipment, (2) connections to a non-mounted, frequently-changed component such as a burial liner/H IC, or (3)connections to non-mounted pieces of radioactive wasteprocessing or collection equipment which must be readilyremovable (e.g., items placed on equipment hatches).
Thepressure rating of such hoses and connections shall equal orexceed those of the systems or components to which they areconnected.
- 1. Prior to use, the hoses shall be hydro-tested to theappropriate pressure for the system or component towhich they will be connected.
After installation, they willreceive regular hydro-testing or in-service inspections.
- 2. A 50.59 review process is required to justify the use ofsuch hose connections.
Page 10 of 17 Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX C1.3.3 Clinton Power Station (CPS)1. The CPS QAPD also includes the following sections of the Operations Requirements Manual (ORM) and the Updated Safety Analysis Report(USAR). The specific sections are as follows:A. ORM Section 6.8.2, Procedures and Programs
-Review andApprovalB. ORM Section 6.8.3, Procedures and Programs
-Temporary ChangesC. USAR Section 13.4D. USAR Table 3.2-12. Site specific clarifications and exceptions applicable to Clinton PowerStation include:A. The CPS USAR Section 1.8, "Conformance to NRC Regulatory Guides",
which provides the CPS project position for implementation of regulatory guides, includes additional clarifications and exceptions to the regulatory guides.B. CPS complies with RG 1.8 (Proposed Rev 2), "Personnel Qualification and Training."
(Also reference USAR Section 1.8.)C. CPS complies with Regulatory Guide 1.33, Rev. 2 (February 1978);"Quality Assurance Program Requirements (Operation)."
CPScomplies with this guide and with the following additional exception:
- 1. ANSI N18.7-1976/ANS-3.2, Section 5.2.17 Inspections:
Duringplant operations emergencies, inspections may be performed under the direction of the duty shift manager.1.3.4 Calvert Cliffs, Ginna, and Nine Mile Point1. Regulatory Guide 1.16, (revision facility
-specific),
"Reporting of Operating Information"
-The commitment to this Regulatory Guide is facility-specific asdescribed in the approved Safety Analysis Report (SAR) or License for eachnuclear facility.
Where items do not conform to the requirements of theRegulatory Guide, they are addressed in the facility specific SAR.2. Regulatory Guide 1.26, Revision (facility
-specific),
"Quality Group Classifications and Standards for Water-, Steam-, and Radioactive Waste-Containing Components of Nuclear Power Plants" -Commitment to Safety/Regulatory Guide1.26 is facility-specific, as required by the approved SAR/License at each nuclearfacility.
Sites may use this guidance to assist in establishing the lists ofequipment to which this QA program applies, or for other purposes.
- 3. Regulatory Guide 1.28, Revision 3, August 1985, "Quality Assurance ProgramRequirements (Design and Construction)"
(ASME NQA-1, 1 983a) -Calvert Cliffs,Nine Mile Point and Ginna will implement the requirements and guidance of thePage 11 of 17Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX Cstandard and Regulatory Guide during the design and construction phases of thefacilities subject to the following:
- a. Regulatory Position C endorses the basic and supplementary requirements of ANSI/ASME NQA-1-1983 and the ANSI/ASME NQA-1a-1983 Addenda.
In place of the specific edition and addenda of NQA-1addressed in the Regulatory Guide, Calvert Cliffs, Nine Mile Point andGinna commit to implement the requirements of NQA-1 -1 994 Part I.Calvert Cliffs, Ginna, and Nine Mile Point are not committed to Part II ofNQA-1 unless otherwise noted. The commitment to these requirements and any exceptions/alternatives to these requirements are addressed inthis QATR.4. In establishing qualification and training
- programs, Calvert Cliffs, Ginna, and NineMile commits to compliance with NQA-1-1994 Basic Requirement 2 andSupplements 2S-1, 2S-2, 2S-3 and 2S-4, with the following alternatives andexceptions:
- a. For Supplement 2S-1: Inspections, examinations or tests may beperformed by individuals in the same organization as that which performed the work, provided that (a) the qualifications of the inspector for an activityare the same as the minimum qualifications for persons performing theactivity, (b) the work is within the skills of personnel and/or is addressed byprocedures, and (c) if work involves breaching a pressure-retaining item,the quality of the work can be demonstrated through a functional test.When a, b and c are not met, inspections, examinations or tests arecarried out by individuals certified in accordance with Supplement 2S-1.Individuals performing visual inspections required by the ASME Boiler andPressure Vessel Code are qualified and certified according to Coderequirements.
- b. In lieu of being certified as Level I, II or Ill in accordance with Non-Mandatory Appendix 2A-1 of NQA-1 -1 994, personnel performing operations phase independent quality verification inspections, examinations, measurements, or tests on material, products or activities, that are in the same organization as that which performed the work, will berequired to possess the same minimum level of qualification as thatrequired for performing the task being verified.
The verification shall bewithin the skills of these personnel and/or is addressed by procedures.
These individuals will also be trained and certified to perform inspections ina manner consistent with a Level I quality inspector.
The inspectors will beauthorized to accept or reject the work being inspected.
The results ofinspections by these individuals will be reviewed by a certified Level II orhigher quality inspector.
These individuals will not be responsible for theplanning of quality verification inspections and tests (i.e. establishing holdpoints and acceptance criteria in procedures, or determining who will beresponsible for performing the inspections),
evaluating inspection trainingprograms, or certifying inspection personnel.
- 5. Regulatory Guide 1.29, Revision (facility-specific)
"Seismic Design Classification"
-Calvert Cliffs, Nine Mile Point and Ginna may have been designed, constructed and licensed based on criteria available prior to this Regulatory Guide beingPage12 of 17 Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX Cissued. The specific design criteria and seismic designations are reflected ineach plant's SAR, and in other docketed analysis.
Thus, the commitment toSafety/Regulatory Guide 1.29 is facility-specific, as required by the approvedSAR/License at each facility.
Sites may use this guidance in establishing the listsof equipment to which this QA program applies, or for other purposes.
- 6. Regulatory Guide 1.30, August 1972, "Quality Assurance Requirements for theInstallation, Inspection and Testing of Instrumentation and Electric Equipment,"
(ANSI N45.2.4-1 972/IEEE 336-1971
):a. Calvert Cliffs, Nine Mile Point, and Ginna commits to ANSI N45.2.4-1972/IEEE 336-1971 in its commitment to Position C of Regulatory Guide1.30.b. As noted in Regulatory Position 0.1, ANSI N45.2.4-1972 is being used inconjunction with NQA-1 -1 994, Part I, which replaced ANSI N45.2.c. As noted in Regulatory Position 0.2, other industry standards may bereferenced.
The commitment in this QATR to ANSI N45.2.4-1 972 includescommitment to those standards to the extent necessary to implement ANSIN45.2.4-1 972 requirements.
If NRC guidance applies to those referenced standards, it is followed.
- d. Consistent with Regulatory Position C.3, the requirements of the endorsedstandard are also considered applicable during the operation phase of thenuclear power plant.e. In lieu of the requirements of the last paragraph of ANSI N45.2.4-1 972Section 6.2.1, the calibration program at Calvert Cliffs, Nine Mile Point andGinna does not use calibration stickers on installed plant instrumentation that contain the date of calibration and identity of person that performed the calibration.
Calibrations of instruments are scheduled and tracked by acomputer database.
- 7. Regulatory Guide 1.33, Revision 2, February 1978, "Quality Assurance ProgramRequirements (Operation)"
(ANSI N 18.7-1 976/ANS-3.2):
- a. NQA-1-1994 Part I contains quality assurance requirements equivalent tothose of ANSI N18.7-1976/ANS-3.2.
Although this QATR complies withthe requirements of NQA-1 -1 994 and ANSI N18.7-1976/ANS-3.2, CalvertCliffs, Ginna and Nine Mile Point does not commit to compliance with therequirements of ANSI N-I18.7-1 976/ANS-3.2 as defined in their SafetyEvaluation Report dated December 21, 2006.b. As recommended by Regulatory Position C.1, Calvert Cliffs, Nine MilePoint and Ginna uses Appendix A of Regulatory Guide 1.33, Revision 2, asguidance in establishing the types of procedures required for plantoperation and support.c. Calvert Cliffs, Nine Mile Point and Ginna's commitment to the applicable Regulatory Guides and associated standards listed in Regulatory Position0.2 is addressed within this QATR. A number of these Regulatory Guidesand standards have been incorporated into NQA-1-1 994 Part I.Page 13 of 17 Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX C8. Regulatory Guide 1.37, Revision (facility-specific),
"Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components ofWater-Cooled Nuclear Power Plants,"
(ANSI N45.2.1-1 973) -The commitment tothis Regulatory Guide is facility-specific as described in the approved SAR orLicense for each nuclear facility.
Where items do not conform to therequirements of the Regulatory Guide, they are addressed in the applicable facility's SAR.9. Regulatory Guide 1.38, Revision (facility-specific),
"Quality Assurance Requirements for Packaging,
- Shipping, Receiving,
- Storage, and Handling ofItems for Water-Cooled Nuclear Power Plants,"
(ANSI N45.2.2-1 972) -Thecommitment to this Regulatory Guide is facility-specific as described in theapproved SAR or License for each nuclear facility.
Where items do not conformto the requirements of the Regulatory Guide, they are addressed in the applicable facility's SAR.a. This alternative applies to Nine Mile Point Nuclear Station (NMPNS).NMPNS commits to ANSI/ASME NQA-2-1 983 Part 2.2, "Quality Assurance Requirements for Packaging,
- Shipping, Receiving,
- Storage, and Handlingof Items for Nuclear Power Plants,"
for nuclear safety-related activities pertaining directly to permanent plant modifications only. NQA-2-1 983Section 7.1 refers to NQA-2-1 983 Part 2.15 for requirements related tohandling of items. The scope of Part 2.15 includes
- hoisting, rigging andtransporting of items for nuclear power plants. This scope exceeds thescope of the NRC's original endorsement of ANSI N45.2.2 in Regulatory Guide 1.38, and establishes requirements for which there is no NRCregulatory position.
In lieu of compliance with Part 2.15, NMPNS iscommitted to the requirements of applicable heavy load reports for NineMile Point Units 1 and 2 that have been approved by the NRC. Unit 2'sreport is a part of the SAR (Appendix 9C). Unit l's is a separate report.10. Regulatory Guide 1.39, Revision 2, September 1977, "Housekeeping Requirements for Water-Cooled Nuclear Power Plants,"
(ANSI N45.2.3-1 973) -Calvert Cliffs, Nine Mile Point and Ginna substitutes NQA-1 -1 994, Subpart 2.3 forN45.2.3 in its commitment to Regulatory Guide 1.39. As noted in Regulatory Position C.1, other industry standards may be referenced; the commitment in thisQATR to NQA-1, Subpart 2.3 includes commitment to those standards to theextent necessary to implement Subpart 2.3 requirements.
If NRC guidanceapplies to those referenced standards, it is followed.
Regulatory Position C.2indicates that the provisions of section 3.2.3 of N45.2.3 are not part of theregulatory endorsement.
As NQA-1, Subpart 2.3, section 3.2.3 has the samewording as N45.2.3; the Regulatory Position is applicable and will be followed inCalvert Cliffs, Nine Mile Point and Ginna's implementation of Subpart 2.3.Regulatory Position C.3 indicates that the endorsed standard is "applicable forhousekeeping activities during the operations phase that are comparable to thoseoccurring during construction."
This is addressed in appendix C of this QATR,which also establishes any necessary exceptions or alternatives to the provisions of Subpart 2.3.a. In lieu of the five-level zone designation in Subpart 2.3, Calvert Cliffs,Ginna, and Nine Mile may base its control over housekeeping activities onPage14 ofl17 Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX Ca consideration of what is necessary and appropriate for the activityinvolved.
The controls are effected through procedures or instructions.
Factors considered in developing the procedures and instructions includecleanliness
- control, personnel safety, fire prevention and protection, radiation control and security.
The procedures and instructions make useof standard janitorial and work practices to the extent possible.
- 11. Regulatory Guide 1.54, Revision (facility-specific),
"Quality Assurance forProtective Coatings Applied to Nuclear Power Plants" (N101 .4-1 972) -Thecommitment to this Regulatory Guide is facility-specific as described in theapproved SAR or License for each nuclear facility.
Where items do not conformto the requirements of the Regulatory Guide, they are addressed in the applicable facility's SAR.12. Regulatory Guide 1.68, Revision (facility-specific),
"Preoperational and InitialStartup Test Programs for Water-Cooled Power Reactors,"
-The commitment tothis Regulatory Guide is facility-specific as described in the approved SAR orLicense for each nuclear facility.
Where items do not conform to therequirements of the Regulatory Guide, they are addressed in the applicable facility's SAR.13. Regulatory Guide 1.94, Revision (facility-specific),
"Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete andStructural Steel During the Construction Phase of Nuclear Power Plants,"
(ANSIN45.2.5-1 974) -Calvert Cliffs, Nine Mile Point and Ginna may have beendesigned, constructed and licensed based on criteria available prior to thisRegulatory Guide being issued. The specific installation, inspection, and testingcriteria are reflected in each plant's SAR, and in other docketed analysis.
Thus,the commitment to Regulatory Guide 1.94 is facility-specific, as required by theapproved SAR/License at each facility.
Facilities may use this guidance to assistin establishing the equipment to which this QA program applies, or for otherpurposes.
- 14. Regulatory Guide 1.116, Revision O-R, May 1977, "Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems,"
(ANSI N45.2.8-1 975) -Calvert Cliffs, Nine Mile Point and Ginnasubstitutes NQA-1-1 994, Subpart 2.8 for N45.2.8 in its commitment to Regulatory Guide 1.116. As noted in Regulatory Position C.1, other industry standards maybe referenced; the commitment in this QATR to NQA-1, Subpart 2.8 includescommitment to those standards to the extent necessary to implement Subpart 2.8requirements.
If NRC guidance applies to those referenced standards, it isfollowed.
Regulatory Position C.2 indicates that the endorsed standard should be"followed for those applicable operations phase activities that are comparable toactivities occurring during the construction phase." This is addressed in AppendixC of this QATR, which also establishes any necessary exceptions or alternatives to the provisions of Subpart 2.8.15. Regulatory Guide 1.143, Revision (facility-specific),
"Design Guidance forRadioactive Waste Management
- Systems, Structures and Components Installed in Light-water-Cooled Nuclear Power Plants" Commitment to Regulatory Guide1.143 is facility-specific, as required by the approved SAR at each facility.
Page 15 of 17Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX CFacilities may use this guidance to assist in establishing the lists of equipment towhich this QA program applies, or for other purposes.
- 16. Regulatory Guide 1.152, Revision 0, November 1985, "Criteria for Programmable Digital Computer System Software in Safety-Related Systems of Nuclear PowerPlants" -Calvert Cliffs, Nine Mile Point and Ginna does not make a commitment to Regulatory Guide 1.152. Calvert Cliffs, Nine Mile Point and Ginna commit toGeneric Letter 95-02, and its endorsement of NUMARC/EPRI Report TR-1 02348,"Guidelines on Licensing Digital Upgrades."
- 17. Generic Letter 89-02/EPRI-NP-5652 (June 1988)- Calvert Cliffs, Nine Mile Pointand Ginna commits to compliance with the endorsed industry guidance regarding selection and qualification of commercial grade suppliers and dedication ofcommercial grade items for use in safety related applications.
- 18. Branch Technical Position CMEB 9.5-1, Revision 2, July 1981 (Positions C.2 andC.4) of the current plants are committed to CMEB 9.5-1. Calvert Cliffs,Nine Mile Point and Ginna plants are committed to the guidance in Appendix A toBranch Technical Position APCSB 9.5-1, "Guidelines for Fire Protection forNuclear Power Plants Docketed Prior to July 1, 1976." However, application ofthe requirements is facility-specific as described in the applicable facility SAR,Fire Protection
- Program, and License documents.
- a. Nine Mile Point Unit 1 is committed tol0 CFR 50.48(c),National FireProtection Association Standard NEPA 805, "Performance Based Standardfor Fire Protection for Light Water Reactor Electric Generating Plants"2001 Edition per NRC License Amendment number 215 to DPR-63(ADAMS Accession number ML14126A003) dated 6/30/2014.
- b. Ginna is committed to10 CFR 50.48(c),National Fire Protection Association Standard NFPA 805, "Performance Based Standard for Fire Protection forLight Water Reactor Electric Generating Plants" 2001 Edition per NRCLicense Amendment number 119 to DPR-1 8 (ADAMS Accession numberML 15271A101 dated 11/23/2015
- 19. Regulatory Guide 4.15, Revision 1, February 1979, "Quality Assurance forRadiological Monitoring Programs (Normal Operations)
-Effluent Streams andthe Environment"
-Calvert Cliffs, Nine Mile Point and Ginna commits tocompliance with the Regulatory Positions of Section C with the following alternatives/exceptions:
- a. In lieu of plotting background parameters and setting predetermined control values for gamma spectroscopy instrumentation as described inRegulatory Position C.6.2, background results may be logged andevaluated to ensure the background does not bias reported results.b. The NRC's independent sampling and analysis program described inRegulatory Position C.6.3.2 may not be performed.
- c. In lieu of performing source check calibrations at least once per 18 monthsas described in Regulatory Position C.7, Calvedt Cliffs, Nine Mile Point andGinna may perform these calibrations at least once per refueling interval.
Page 16 of 17Revision 90 CODES, STANDARDS, AND GUIDESAPPENDIX C20. Regulatory Guide 7.10, Revision 1, June 1986, "Establishing Quality Assurance Programs for Packaging Used in the Transport of Radioactive Material"
-CalvertCliffs, Nine Mile Point and Ginna commits to implement the quality assurance guidance for activities related to the packaging and transport of radioactive material that are under its control.
Quality Assurance for the design, fabrication and licensing of shipping containers is the responsibility of the container certificate holders.21. Regulatory Issue Summary 2000-18, October 2000, "Guidance on ManagingQuality Assurance Records in Electronic Media" -Should Calvert Cliffs, Nine MilePoint or Ginna choose electronic media storage as a means of maintaining required
- records, they will comply with the guidance of this Regulatory IssueSummary.22. Calvert Cliffs, Nine Mile Point and Ginna will use the guidance contained inGeneric Letters 91-05 and 89-02/EPRI NP-5652 to procure commercial gradeitems in lieu of these requirements NQA-1 -1994 Supplement 4S-1 andSupplement 7S-1.23. INDEPENDENT SAFETY ENGINEERING GROUP ('ISEG)Independent safety review is performed to meet the individual unit's commitment to NUREG-0737,Section I.B.1.2, "Independent Safety Engineering Group," asdescribed in the unit's safety analysis report, if applicable.
Page 17 of 17 Revision 90IPage 17 of 17Revision 90 I DEFINITIONS APPENDIX D1. SCOPEThis Appendix consists of definitions for words or phrases found in the QAP andprovides a common basis for understanding those words or phrases that mayhave a different meaning when used elsewhere.
All words and phrases aresubject to review and revision, as circumstances require.
Site specific items arenoted.2. GLOSSARY OF TERMS2.1. ApprovalApproval as used herein means by signature or initialing and date by anauthorized individual.
2.2. ASME Boiler and Pressure Vessel Code, Section IRefers to ASME Section I, Power Boilers2.3. ASME Boiler and Pressure Vessel Code,Section III, Division I and Division2 for Concrete Containment Refers to ASME Section III, Division 1 and Division 2 for Concrete Containment; ASME Section III; ASME Code; ASME; or Code.2.4. ASME Boiler and Pressure Vessel Code, Section IVRefers to ASME Section IV, Heating Boilers2.5. ASME Boiler and Pressure Vessel Code, Section VIIIRefers to ASME Section VIII, Pressure Vessels2.6. ASME Boiler and Pressure Vessel Code, Section XlRefers to ASME Section Xl, Rules for In-Service Inspection of Nuclear PowerPlant Components.
2.7. AuditA planned and documented activity performed to determine by investigation, examination, or evaluation of objective evidence the adequacy of andcompliance with established procedures, instructions,
- drawings, and otherapplicable documents, and the effectiveness of implementation.
An audit shouldnot be confused with surveillance or inspection activities performed for the solepurpose of process control or product acceptance.
2.8. Audit Team LeaderAn individual appointed to lead an Audit Team. The Audit Team Leadercoordinates the preparation of the audit report.2.9. AuditorOne qualified and authorized to examine quality assurance practices and verifywhether requirements are being met.Page I of 17Revision 90 DEFINITIONS APPENDIX D2.10. Augmented D (CPS Only)A term applied to those components within the Augmented D boundaries asdefined in the engineering specifications.
See K-2882, USAR Table 3.2.1, andAppendix C of this manual for scope of requirements and boundaries pertaining to Augmented D.2.11. Authorized Inspector or Al or ANIAs used herein is meant to mean Authorized Nuclear Inspector.
An Authorized Nuclear Inspector is an employee of an Authorized Inspection Agency who hasqualifications for and has been properly accredited for Division 1 or Division 2.2.12. Authorized Nuclear In-service Inspector or ANIIAs used herein is meant to mean the Authorized Nuclear In-service Inspector.
An ANII is an employee of an Authorized Inspection Agency who hasqualifications for and has been properly accredited for ASME Section XI.2.13. Balance of PlantGenerating station items and equipment not designed, furnished or installed as apart of the Nuclear Steam Supply System. Balance of Plant items includesafety-related and ASME Code items, such as the containment as well as nonsafety-related and non-ASME Code items.2.14. Basic Component "Basic component",
when applied to nuclear power reactors means a plantstructure, system, component or part thereof necessary to assure (1) theintegrity of the reactor coolant pressure
- boundary, (2) the capability to shut downthe reactor and maintain it in a safe shutdown condition, or (3) the capability toprevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to those referred to in 10CFR1 00.11 Chapter 1(1-1-87),
Part 21.2.15. Bid PackageThe total of drawings, specifications, codes, standards, quality and otherrequirements that describes the task on which a prospective contractor/supplier will bid.2.16. Calibration A method of assuring accuracy of gauges and instruments used for measuring and testing by comparing with recognized standards.
2.17. Certificate of Compliance A written statement signed by a qualified person, attesting that the materials oritems are in compliance with the purchasing documents.
2.18. Certified Personnel Personnel who have passed a formal training program and a formal proficiency test for special processes such as welding, plating and nondestructive testing.Page 2 of 17Revision 90 DEFINITIONS APPENDIX D2.19. Certified Standards Standards of measurement whose accuracy can be traced to standards at theNational Institute of Standards and Technology or established standards.
2.20. Certified Material Test ReportA document attesting that material is in accordance with specified requirements including the actual results of all required chemical
- analyses, tests andexaminations.
2.21. Change OrderA formal award to a vendor or contractor covering revision(s) to the originalPurchase Order or Change Order, involving but not limited to quantity, technical requirements, quality assurance requirements or scope of work.2.22. Change Order Requisition A document describing revisions to be made to the original Purchase Order orsubsequent Change Order and which is converted into a Change Order.2.23. Characteristic Any property or attribute of an item, process or service that is distinct, describable and measurable, as conforming or nonconforming to specified quality requirements.
Quality characteristics are generally identified inspecifications and drawings, which describe the item, process or service.2.24. CodeSee ASME Boiler and Pressure Vessel Code,Section III or Section XI,whichever is applicable.
2.25. codeA recognized standard for using or processing materials, or for the skill involvedin use or processing.
2.26. Cognizant EngineerThe engineer assigned a specific task or area of responsibility in the design ortesting of a component or system.2.27. CornEdCommonwealth Edison Company (an Exelon Company).
2.28. Company Level IllChief Level Ill (NDE) for the Company2.29. Component An item designed and manufactured to perform a specific function within asystem. It consists of a combination of parts and will be combined with othercomponents to form an assembly.
And for ASMEPage 3 of 17Revision 90 DEFINITIONS APPENDIX DASME Code items such as vessels, concrete containments, piping systems,pumps, valves, core support structures and storage tanks which will becombined with other items to form an assembly or installation of a nuclear powerplant.2.30. Component Identification NumberAn identification number assigned (where appropriate) to an item for usethroughout its lifetime.
2.31. Construction Activities at the building site necessary to erect, inspect and accept a powergenerating station and its associated installation.
This definition applies unlessotherwise indicated.
-Construction (ASME Section III Div.1) comprises all activities relating tomaterials, design fabrication, examination,
- testing, inspection andcertification required in the manufacture and installation of items.-Construction (ASME Section III Div. 2) includes all those operations required to build the component and its parts in accordance with theDesign Drawings and Construction Specification which have beenprepared by the Designer (AE).2.32. Construction TestsThose tests necessary to verify that the installation of each component of asystem is complete and complies with the applicable specifications, standards, codes, drawings and engineering information.
2.33. Contract (including purchase order)A binding agreement between two or more persons or companies.
2.34. Contractor Any organization under contract for furnishing items or services.
It includes theterms vendor, supplier, subcontractor, fabricator and sub-tier levels of thesewhere appropriate.
A "Code" contractor is a contractor holding a valid ASMESection III Certificate of Authorization.
2.35. Control PointIn a sequential operation, a checkpoint at which certain data are taken,inspections are made or approval is required.
2.36. Control StampA stamp used to mark a unique identification of inspection or test status uponitems, tags, labels, routing cards or records traceable to an item. Control stampimpressions clearly identify the person who applied it such that traceability totheir authorization is provided.
2.37. Corrective ActionMeasures taken to rectify conditions adverse to quality, and, where necessary, to preclude repetition.
Page 4 of 17Revision 90 DEFINITIONS APPENDIX D2.38. Department When a responsibility is given to a department in this Manual it is meant that thedepartment head has the responsibility.
2.39. Design ChangeAny change in design that may affect functional requirements, operating conditions, safety-,
regulatory-,
reliability-,
and ASME Code-related requirements, performance objectives, plant reliability or design life and wouldrequire that affected documentation be changed.2.40. Design ControlsMethods for assuring that basic design requirements are formalized andtranslated into design documents with proper review to assure the scheduled release of a valid design.2.41. Design CriteriaStatements of the form, function and interface requirements within well definedlimitations.
"2.42. Designer (Division 2)As used in ASME Code Division 2 construction, the Designer (AE) is theorganization responsible for the preparation and completion of the DesignReport, design drawings, and construction specifications for applicable items.2.43. Design Requirements Documents that set the functional requirements, operating conditions, safetyrequirements, performance objectives, design margins and design life. Includedare any special requirements for size, weight, ruggedness, materials, fabrications or constructions,
- testing, maintenance, operating environments, safety margins and derating factors.2.44. Design ReviewAn analysis of design with respect to technical
- adequacy, interface control,inspectability, maintainability and conformance to applicable codes, standards, regulations and design criteria.
2.45. Design Specification A document that sets the functional requirements; design requirements; environmental conditions, including radiation; ASME Code classification; definition of the boundaries; and material requirements.
Sufficient detail shall becontained within the document to provide a complete basis for design.For Section III ASME Code, Division I: A document prepared by the owner orowner's designee which provides a complete basis for construction inaccordance with the ASME Code, Section II1.2.46. Desk SurveyAn evaluation of a supplier's quality control capability made from documented procedures and records of past performance.
Page 5 of 17Revision 90 DEFINITIONS APPENDIX D2.47. Destructive TestA test to determine the properties of a material or the behavior of an item whichresults in the destruction of the sample or item.2.48. Deviation A non-conformance.
Departure of a characteristic from specified requirements.
2.49. Discrepancy A non-conformance.
2.50. Documentation Any written or pictorial information describing,
- defining, specifying, reporting orcertifying activities, requirements, procedures or results.2.51. Drawing ManifestA document for transmitting drawings released for construction to anengineering, construction and/or production organization."
2.52. ErectorAn organization involved in assembling and building equipment or structures atthe site.2.53. Examination Specific actions by qualified personnel using qualified procedures to verify thatitems and fabrication processes are in conformance with specified requirements.
This term, when used in conjunction with qualification of personnel to performquality-related activities shall mean a written examination.
2.54. Extended Quality Assurance Program (CPS Only)The selected use of technical and management controls to improve theoperational performance of equipment important to reliable station operation butnot included in compliance based quality assurance programs.
2.55. Fabricator An organization involved in the manufacture of equipment.
2.56. Fabricator (ASME Section III Div. 2)The NPT Certificate holder2.57. Final Safety Analysis Report (FSAR)A finalization of the preliminary safety analysis report prepared for the NuclearRegulatory Commission prior to issuance of an operating license.2.58. First Level Design ReviewA review conducted by the responsible project engineer within the designagency for a specific design discipline.
Page 6 of 17 Revision 90Page 6 of 17Revision 90 DEFINITIONS APPENDIX D2.59. Flow ChartA representation of the sequence of activities such as procurement, fabrication, processing,
- assembly, inspection and test, or the sequence of individual operations within one or more of those functions.
2.60. Hold PointA designated stopping place during or following a specific activity at whichinspection or examination is required before further work can be performed.
2.61. IncidentOccurrence of major damage, serious personal injury or significant scheduledelay.2.62. Independent ReviewReview completed by personnel not having direct responsibility for the workfunctions under review regardless of whether they operate as a part of anorganizational unit or as individual staff members.2.63. In-service Inspection A mandatory program of examinations,
- testing, inspections and control of repairsand replacements to ensure adequate safety in maintaining the nuclear powerplant and to return the plant to service in a safe and expeditious manner.2.64. Inspection A phase of quality verification that, by means of examination, observation ormeasurement, determines the conformance of materials,
- supplies, components, parts, appurtenances,
- systems, processes or structures to predetermined qualityrequirements.
2.65. Inspection and Test PlanA listing, with optimum sequencing, of all the inspections and tests required tobe performed for a specific item, component, structure or service.2.66. Interface When two or more organizations have responsibilities for accomplishing anactivity, the functional relationship that one organization has to the others incompleting the activity is called an "interface" relation.
One example of interface is when one organization must perform a step, which is a prerequisite to anotherorganization accomplishing its function.
Interface can also mean that severalorganizations accomplishing similar activities are under the coordination controlof one organization.
2.67. Interface controlConsideration that components and structures are geometrically and functionally compatible and those materials are compatible with both process andenvironment.
Page 7 of 17 Revision 90Page 7 of 17Revision 90 DEFINITIONS APPENDIX D2.68. ItemAny level of unit assembly, including structure, system, subsystem, subassembly, component, part or material.
When ASME Code items arereferenced, this means products constructed under a certificate of authorization and material.
2.69. Jurisdictional Boundaries The physical limits of an ASME Code item, which are identified to determine theapplicability of ASME Code rules for that item.2.70. Lifetime RecordA record that meets one or more of the following criteria:
-those that would be of significant value in demonstrating capability forsafe operation;
-those that would be of significant value in maintaining, reworking, repairing, replacing, or modifying an item;-those that would be of significant value in understanding the cause of anaccident or malfunction of an item;-those that provide required baseline data for in-service inspections.
2.71. Like -for -Like Replacement The replacement of an item with an item that is identical in all physical andperformance characteristics.
2.72. Local Purchase OrderA purchase order initiated through the computer by a station for the purchase ofonly Company Stores Coded items.2.73. Maintenance Repair, rework, or replacement of a structure, system or component withequipment of the same design, i.e., meeting the same engineering requirements.
2.74. Maintenance/Modification Work PackageThe complete set of documentation that enables the station to fabricate,
- examine, test and install ASME and safety related items. The work packageconsists of the work request, provisions for station traveler, document checklist and maintenance/modification procedures and supporting information such as,but not limited to, approved
- drawings, design specifications, and special processprocedures.
2.75. MaterialA substance or combination of substances forming components, parts, piecesand equipment.
(Intended to include such things as machinery,
- castings, liquids,formed steel shapes, aggregates and cement.)When ASME Code material is referenced (this refers to metallic materials) whichare manufactured to a SA, SB, or SEA Specification or any other materialspecification permitted by Section III of the ASME Code. For Division 2, refersto metallic materials, as well as to nonmetallic materials, conforming to thespecifications permitted in Section III of the ASME Code.Page 8 of 17Revision 90 DEFINITIONS APPENDIX D2.76. Material SupplierAn organization which supplies material produced and certified by MaterialManufacturers, but does not perform any operations that affect the materialexcept when agreed upon by the Certificate Holder who uses the material inASME Code construction or when so authorized by a Quality System Certificate (Materials).
The Material Supplier may perform and certify the results of tests,examinations,
- repairs, or treatments required by the material specification thatwere not performed by the Material Manufacturer.
2.77. Measuring and Test Equipment (M&TE)Equipment used to quantitatively generate or measure physical or electrical parameters with a known degree of accuracy for the purpose of calibration, inspection, test, or repair of plant mechanical, electrical, or instrument controlequipment.
2.78. Modification A change to an item made necessary by, or resulting in, a change in designrequirements (ASME -NCA 9000). A planned change in plant design oroperation and accomplished in accordance with the requirements and limitation of applicable codes, standards, specifications, licenses and predetermined safety restrictions.
2.79. National Standards Standards maintained at or issued by the National Institute of Standards andTechnology (NIST) or other designated institutions, and the values for naturalphysical constants and conversion factors recommended by NIST.2.80. Non-compliance A failure to comply with a regulatory requirement 2.81. Nonconformance A nonconformance is a deficiency in characteristic, documentation, or procedure that renders the quality of a structure, system, or component (SSC) or activityunacceptable or indeterminate.
Some examples of nonconforming conditions include the following:
-There is failure to conform to one or more applicable codes or standards specified in the UFSAR or procurement documents.
-As-built equipment, or as modified equipment, does not meet UFSARdescriptions or design bases.-Requirements can not be substantiated with proper documentation.
-Physical defects.-Test failures.
-Deviation from prescribed processing, inspection, or test procedures.
2.82. Nonpermanent RecordA record that is required to show evidence that an activity was performed inaccordance with the applicable requirements but do not meet the criteria for alifetime record.Page 9 of 17Revision 90 DEFINITIONS APPENDIX D2.83. NQA -1 (ASME NQA -1)Quality Assurance Program Requirements for Nuclear Facilities.
For ASMESection III activities, NQA -1 is as modified by the ASME Code.2.84. Nuclear Steam Supply System (NSSS)That portion of the nuclear generating plant that provides steam from nuclearheat. It includes the reactor, its control systems, main coolant and steamgeneration
- systems, fuel handling equipment, emergency core cooling systemand other safeguards, associated electrical equipment, instrumentation, spentfuel handling and radioactive waste disposal system.2.85. Objective EvidenceAny statement of fact, information or record, either quantitative or qualitative, pertaining to the quality of an item or service based on observations, measurements or tests that can be verified.
2.86. Operable/Operability A system, subsystem, train, component or device shall be operable or haveoperability when it is capable of performing its specified function(s) and when allnecessary attendant instrumentation,
- controls, electrical power, cooling or sealwater, lubrication or other auxiliary equipment that are required for the system,subsystem, train, component or device to perform its function(s) are alsocapable of performing their related support function(s).
NOTE: Safe operation of the plant is determined by licensed operators.
2.87. Operational TestsTests that are performed during the operations of the plant to verify continued satisfactory performance of safety-related structures, systems and components.
2.88. Personnel Access Data System (PADS)A computerized and restricted access data system used by the domesticcommercial nuclear power industry to share information necessary to processthe applications of workers for unescorted access to nuclear power plants. Thissystem is intended to meet regulatory requirements mandating that certaininformation be available to any power reactor licensee by retaining certainaccess information in a central computer database.
2.89. Permanently Installed Instrument and Control DevicesThe installed plant equipment including computer points used in determining acceptance criteria of Technical Specification surveillances (Category A andSurveillance Instruments for CPS).2.90. Phased Replacement Where several identical items are to be replaced with a new model, they arereplaced a few at a time to allow monitoring of the new items.Page 10 of 17 Revision 90Page 10 of 17Revision 90 DEFINITIONS APPENDIX D2.91. Preliminary Safety Analysis Report (PSAR)The initial detailed safety evaluation prepared for the U.S. Nuclear Regulatory Commission prior to issuance of the site construction permit. The PSARdelineates design, normal and emergency operation, potential accidents andpredicted consequences of such accidents and the means proposed to preventsuch accidents and/or reduce their consequences to acceptable levels.2.92. Pre-Operational TestingPreliminary testing prior to fuel loading and plant operation to assure thatconstruction and installation are complete and to verify design and systemfunctions.
2.93. Procedure A controlled document that specifies or describes how an activity is to beperformed.
It may include methods to be employed, equipment or materials tobe used, accept/reject criteria and sequence of operations.
2.94. Proprietary DesignsDesigns engineered, produced and sold by manufacturers in accordance withtheir criteria and warranty.
2.95. Purchase Requisition The basic document describing a material, component or service that isconverted into a purchase order for procurements.
2.96. Quality Assurance All those planned and systematic actions necessary to provide adequateconfidence that an item or a facility will perform satisfactorily in service.
For theASME Code, Quality Assurance comprises all those planned and systematic actions necessary to provide adequate confidence that all items designed andconstructed are in accordance with the applicable ASME Code.2.97. Quality Assurance Program (QAP)The Quality Assurance Program is the method for complying with the provisions of 10OCFR5O Appendix B for nuclear power plant systems, structures, andcomponents that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. The QualityAssurance Program is defined in the Quality Assurance Topical Report andimplementing procedures.
2.98. Quality Assurance Topical Report (QATR)A NRC approved regulatory document that describes quality assurance programelements for the operational phase of nuclear power plants. This term issynonymous with Quality Assurance Program Description (QAPD), Operation Quality Assurance Program (OQAP), and Quality Assurance Manual (QAM).2.99. Quality ControlSee Quality verification Page 11 of 17Revision 90 DEFINITIONS APPENDIX D2.100. Quality Receipt Inspection ReportA form utilized by station Quality Control to document technical receiptinspection of ASME Code and safety-related items received by the station.2.101. Quality RelatedActivities which influence quality of safety-related items or work related to thosesystems, structures and components as identified in the USAR, Table 3.2-1,including design, purchasing, fabricating,
- handling, shipping,
- storing, cleaning, preserving,
- erecting, installing, inspecting,
- testing, operating, maintaining, repairing, refueling or modifying.
2.102. Quality Verification Those quality assurance examinations and actions that provide a means tocontrol and measure the characteristics of an item, process or facility todetermine or establish conformance to acceptance standards and specified requirements.
2.103. Receipt Inspection An inspection which verifies that items are in satisfactory condition, that theymatch the purchase order requirements and that required documentation accurately reflects the item(s) received.
Visual and physical inspection will beperformed as necessary to determine the acceptability of the item(s).2.104. Receiving Inspection Notice (RIN)A form initiated by the station upon receipt of ASME Code or safety-related items to record inspection for damage, to record receipt of documentation and tonotify station Quality Control that item(s) are available for technical receiptinspection.
2.105. RecordA completed document that:-furnishes evidence of the quality of items or activities.
-furnishes evidence of compliance with regulations or requirements.
-is required by Technical Specifications.
Included are such related documents as drawings, specifications, procurement documents, procedures, operating logs, and reportable occurrences.
Suchdocuments may be originals or reproduced copies.2.106. Registered Professional Engineer (RPE)A person competent in the applicable field of design and qualified in accordance with the requirements of ASME Section III, Appendix XXIII.2.107. RepairThe process of restoring a nonconforming characteristic to a condition such thatthe capability of an item to function reliably and safely is unimpaired, eventhough that item still may not conform to the original requirements.
For ASMESection III items, repair is the process of physically restoring a nonconformance to a condition such that an item complies with ASME Code requirements.
Page 12 of 17Revision 90 DEFINITIONS APPENDIX D2.108. Request for BidInvitation made to suppliers or contractors to bid on a specific task for materials, goods and services.
2.109. Request for PurchaseA generating station's document originated by supervisors or department headsthat designates the required items and services and delineates the designspecifications, applicable codes and standards, as well as, any specialrequirements.
This document is the basis of initiating a Purchase Requisition.
2.110. Resolution (CPS Only)2.111. The process by which a nonconforming item is corrected or determined toadequately perform its design function without adversely affecting safety. Theresolution may contain controls or limitations that are to apply until thenonconformance is fully corrected.
2.112. ReworkThe process by which a nonconforming item is made to conform to a priorspecified requirement by completion, re-machining, and re-assembling usingpreviously approved procedural requirements.
(For ASME Section III, rework issame as repair.)2.113. Safety-Related
- Systems, structures and components, which are considered important to safetybecause they perform safety actions, required to avoid or mitigate theconsequences of abnormal operation transients or accidents.
In addition, designrequirements are placed upon such equipment to assure the properperformance of safety actions, when required (Safety-related items are thosedesignated Seismic Category 1, Safety Class 1, 2, 3, "Other" and Electrical Class 1 E as identified in the CPS USAR, Section 3.2).2.114. Second Level Design ReviewIndependent objective assessment of a design by qualified personnel who haveno direct project responsibility for the design.2.115. Seismic Classification Plant structures, systems and components important to safety which aredesigned to withstand the effects of a safe shutdown earthquake and remainfunctional if they are necessary to assure:-The integrity of the reactor coolant pressure
- boundary, or-The capability to shutdown the reactor and maintain it in a safe condition, or-The capability to prevent or mitigate the consequences of accidents whichcould result in potential offsite exposures comparable to the guideline exposures of 10CFR1 00.(Plant structures, systems and components, including their foundations andsupports, which are designed to remain functional in the event of an SSE aredesignated as Seismic Category 1 as indicated in Table 3.2-1 of the CPSUSAR.)Page 13 of 17Revision 90 DEFINITIONS APPENDIX D2.116. Significant Conditions (adverse to quality)A condition, which if left uncorrected, could have a serious effect on safety oroperability.
2.117. Source Acceptance Acceptance made at a vendor's plant prior to shipment of purchased items.2.118. Source Inspection Inspection carried out at a vendor's plant prior to shipment of purchased items.2.119. Special ProcessA process, the results of which are highly dependent on the control of theprocess or skill of the operator, or both.2.120. Special Process Procedures ManualA compilation of Company procedures governing nondestructive examination and special processes such as welding and heat-treating.
2.121. Specification A concise set of requirements to be satisfied by a product, material or process.The set of requirements may, also, indicate the procedure by which one maydetermine if the given requirements are satisfied.
2.122. Start Up TestsTests that are performed after initial fuel loading and proceed through severalpower level plateaus to 100% power.2.123. Stock MaterialMaterial which is or may be used for conversion to an ASME SA, SB, or SFASpecification or allowable ASTM Specification.
As used in this Program, StockMaterial is that material that has not been produced in accordance with an NCA3800 QA Program.2.124. Stop WorkCollective term used to describe the following three levels of stopping workactivities:
-The stopping of a single or specific work activity by NOS or Linepersonnel.
-A hold imposed by a Department Head on a department or general workactivity.
-A Stop Work Action initiated by the NOS Manager.2.125. Surveillance Examination of supplier's manufacturing, inspection and test operations and ofrecords of work in progress.
This activity is documented.
2.126. SurveyA documented evaluation of an organization's ability to perform activities asverified by a determination of the adequacy of the organization's quality programand by a review of the implementation of that program at the location of work.Page 14 of 17Revision 90 DEFINITIONS APPENDIX D2.127. System Safety Classifications (CPS Only)Structures, systems and components are classified as Safety Class 1, SafetyClass 2, Safety Class 3, Safety Class Other or Class 1 E in accordance with theimportance to Nuclear Safety. Equipment is assigned a specific safety class,recognizing that components within a system may be a differing safetyimportance.
Definitions of various Safety Classes are:2.127.1.
Safety Class 1 (CPS Only)Components of the reactor coolant pressure boundary or core support structure whose failure could cause a loss of reactor coolant at a rate in excess of thenormal make-up system.2.127.2.
Safety Class 2 (CPS Only)Structures, systems and components, other than service water systems, that arenot Safety Class 1, but are necessary to accomplish the safety functions of:1. Inserting negative reactivity to shut down the reactor,2. Preventing rapid insertion of positive reactivity,
- 3. Maintaining core geometry appropriate to all plant process conditions,
- 4. Providing emergency core cooling,5. Providing and maintaining containment,
- 6. Removing residual heat from the reactor and reactor core, or7. Storing spent fuel.2.127.3.
Safety Class 3 (CPS Only)Structures, systems and components that are not Safety Class 1 or Safety Class2, but whose function is to process radioactive fluids and whose postulated failure would result in conservatively calculated offsite doses that exceed 0.5remn to the whole body or its equivalent to any part of the body in accordance with Regulatory Guide 1.26.2.127.4.
Safety Class "Other" (CPS Only)Structures, systems and components used in the power conversion or otherportions of the facility which have no direct safety function, but which may beconnected to or influenced by the equipment within the Safety Classes 1, 2 or 3.2.127.5.
Class 1E (CPS Only)The safety classification of the electric equipment and systems that are essential to emergency reactor shutdown, containment isolation, reactor core cooling andcontainment and reactor heat removal or otherwise are essential in preventing significant release of radioactive material to the environment.
(Structures, systems and component safety classifications and related Quality Assurance Program requirements classifications are summarized in Table 3.2-1 of the CPSUSAR.)2.128. Technical Review (nonconforming item)A determination as to whether a nonconforming item will be accepted "as is",reworked, repaired to an acceptable condition or rejected.
Page 15 of 17Revision 90 DEFINITIONS APPENDIX D2.129. Technical Specification The design and performance criteria and operating limits and principles of anoperating license to be observed during initial fuel loading, critical testing,start-up, power operations, refueling and maintenance operations.
2.130. TestDetermination of the physical and functional properties of an item by subjecting the item to a set of physical,
- chemical, environmental or operating conditions.
2.131. Test PlanAn outline, narrative description or flow diagram indicating the tests to beperformed, the methods to be used and the points in the process where they areto be executed.
It may be in the form of a test procedure.
2.132. Traceability The ability to verify the history,
- location, or application of an item by means ofrecorded identification.
2.133. USARAbbreviation for the Updated Safety Analysis Report, which is the documentsubmitted by the Company to the Nuclear Regulatory Commission inaccordance with 10OCFR50.71.
2.134. Use -As -IsA disposition which may be imposed for a nonconformance when it can beestablished that the discrepancy will result in no adverse conditions to safetyand that the item under consideration will continue to meet all engineering functional requirements including performance, maintainability, fit and safety.2.135. Variation A nonconformance.
Departure of a characteristic from specified requirements.
2.136. Verification The act of confirming, substantiating,
- assuring, and documenting that a task,element, or condition is implemented in conformance with the specified requirements.
Two commonly used type of verification as are described asfollows:-Concurrent Verification is also known as "apart-in-action" because theverification is being done concurrently as the action is implemented.
Concurrent Verification is accomplished when two individuals verify theactions concurrently and apart from each other as they perform the task.Concurrent verification should be used for any action that if performed incorrectly, could result in an immediate threat to personnel safety,nuclear safety, reliable plant operation, or for an activity that can't beverified after it's completed.
-Independent Verification is also known as "apart-in-time" because theverification occurs at some time after the action has been performed.
Anindependent verification is performed at a later time by a second qualified individual who is not part of the initial job performance checking thePage 16 of 17Revision 90 DEFINITIONS APPENDIX Dactions previously performed by others. Independent verification may beused in cases were actions if done incorrectly, could significantly affectnuclear and personnel safety, regulatory or other issues important to safeand reliable plant operations, but would not result in immediate consequences.
2.137. Witness PointsIn a sequential operation, a notification to the Company, or its authorized agent,that a phase of work is about to be reached, so that it may be witnessed at aspecific time, or in process, to verify acceptable performance of the phase.Witness points may be established in the traveler, procedure or in the course ofmonitoring the work activity.
2.138. Work Instructions Actions to be completed by personnel while they are performing specific tasks inareas such as material controls and identification and fabrication or installation of equipment.
2.139. Workmanship That quality of an item expressing its skillful and artful manufacture, withoutapparent blemishes.
Page 17 of 17 Revision 90Page 17 of 17Revision 90 CONTROL OF RADIOACTIVE WASTE APPENDIX EOR MATERIALS (SITE SPECIFIC) 1, SCOPEMeasures shall be established and documented to assure that the requirements of the Code of Federal Regulations, Title 10, Part 71, Title 10, Part 20, and Title49, Parts 100 through 199, applicable to the packaging and transporting ofradioactive wastes or materials are satisfied
- 2. REQUIREMENTS 2.1. GeneralIt is the Company's goal to minimize the generation of radioactive waste,consistent with the ALARA concept to minimize personnel exposures andenvironmental contamination.
The elements contained within this appendixapply to Three Mile Island, Oyster Creek, and Clinton Power StationPart 20, requires that a quality control program be implemented to verifycompliance with Title 10, Part 61.55 (Waste Classification) and Title 10, and Part61.56 (Waste Characteristics).
This Plan shall be implemented to the extentnecessary to assure compliance with those Parts of Title 10, using a gradedapproach.
Subpart H to 10CFR71 identifies the quality assurance criteria applicable to thecontrol of packaging to be utilized to ship radioactive wastes or materials.
Theportions of this Plan that relate to the criteria in Subpart H to 10CFR71 describe, to a large extent, the administrative controls and quality requirements to beapplied in the control, packaging, and transportation of radioactive waste ormaterial.
2.2. Three Mile IslandlOyster Creek2.2.1. Procedures and administrative controls shall be developed and implemented tocover the following:
- 1. Processing of radioactive wastes, including the collection, handling andpreparation for shipment of radioactive liquids and solids. Theseprocedures shall be consistent with the ALARA program and shall clearlyidentify the administrative controls and organizational responsibilities.
- 2. Training and qualification of personnel operating radioactive wasteprocessing equipment, health physics monitoring, packaging and shipping(which includes Waste Classification and establishment of WasteCharacteristics) and other operations deemed appropriate bymanagement.
Page 1 of 4Revision 90 CONTROL OF RADIOACTIVE WASTE APPENDIX EOR MATERIALS (SITE SPECIFIC)
- 3. The activities associated with the packaging of radioactive wastes ormaterials shall include the proper selection of the receptacles to be usedfor containing the waste materials, the selection of the shippingcontainers (structures used to contain and support the receptacle and itscontents),
establishment of Waste Characteristics, radiological controlinspections of the packaging prior to release, proper markings on theoUtside of the package, and the preparation of shipping papers andcertificates.
The activities shall be in accordance with 10CFR20,10CFR61,
- 100FR71, and 49CFR.4. Movement of radioactive wastes or materials within and outside theprotected area to assure personnel protection at all times.5. The shipment of radioactive wastes or materials from the Station shall bein accordance with the regulations of the U.S. Department ofTransportation for the transportation of hazardous materials (49CFR) andof the NRC (10CFR71 and 10CFR20).
- 6. Design, fabrication,
- assembly, testing, and modification of packaging used for transportation of radioactive waste or material which exceed thelimits specified by 10OCFR71
.10 shall not be performed by the Company.Such packaging shall be purchased from an outside supplier and shallcomply with 10CFR71 and 49CFR. The Company shall review andaccept designs of packaging purchased from an outside supplier.
- 7. The packaging used for transporting of radioactive waste or material, which does not exceed the limits specified in 10CFR71.10, whetherpurchased from an outside supplier or designed by the Company, shallmeet 49CFR.8. Minimization of the generation of radioactive wastes through trainingprograms, prudent scheduling and use of equipment and personnel, andgood housekeeping practices.
2.2.2. The carriers to be used for transporting of radioactive waste or material shall beselected on the basis of their experience, knowledge of DOT regulations, controland maintenance of their equipment and the selection and control of theirdrivers.
The carrier is required to have or shall be supplied documented procedures Covering acceptance of radioactive waste or material from a shipper,certification requirements, placarding, storage control, reporting of incidents andsecurity.
The Company shall review and accept carrier procedures specified byprocurement documents covering the acceptance of radioactive waste ormaterial for shipment.
2.2.3. Operations involving radioactive waste processing or radioactive material shallbe controlled to minimize personnel exposures or environmental contamination, consistent with ALARA.Page 2 of 4Revision 90 CONTROL OF RADIOACTIVE WASTE APPENDIX EOR MATERIALS (SITE SPECIFIC) 2.2.4. Operations procedures relating to radioactive waste or material shipping andpackaging shall be reviewed by Quality Verification to establish any necessary inspection points.2.3. Clinton Power Station2.3.1. Radioactive Waste/Augmented "D" Systems.QATR Chapters that are applicable to Radioactive Waste/Augmented "D"Systems are I through 7, 9 through 11, and 13 through 18. Chapters 8 and 12do not apply.1. Chapter 4 -Specification of quality assurance program requirements forsuppliers of radioactive waste/augmented 0 materials, equipment andservices shall be on a case-by-case basis. Commercial grade or off-the-shelf items may provide an acceptable level of quality based on thenature of the item. This determination shall be made by Engineering personnel prior to issuance of procurement documents.
- 2. Chapter 7 -Suppliers providing
- material, equipment and services forRadioactive Waste/Augmented D shall be subject to source evaluation and surveillance.
The extent of imposition of these requirements shall bedetermined on a case-by-case basis by the design organization responsible for review and approval of the procurement specifications.
Measures shall be established, and appropriate, for examination ofproducts upon delivery.
- 3. Chapter 9 -Applicable to the qualification of welders and weldingprocedures (ASME Section IX) for Radioactive Waste systems.(Pressure boundaries only.)4. Chapter 10 -Applicable only to inspection of those items and activities affecting Radioactive Waste/Augmented D systems within the qualityassurance boundaries as specified in the USAR, Table 3.2-1, and furtheramplified by the appropriate design drawings.
2.3.2. Packaging and Transportation of Radioactive MaterialQATR Chapters 1 through 18 are applicable to the packaging and transportation of radioactive material.
- 1. Chapter 3 -Applicable, design activities are not normally performed byCPS for radioactive material packaging,
- however, audits of suppliers establish that the design was accomplished under control of an NRCapproved QA program.Page 3 of 4 Revision 90Page 3 of 4Revision 90 CONTROL OF RADIOACTIVE WASTE APPENDIX EOR MATERIALS (SITE SPECIFIC)
- 2. Chapter 7 -Applicable, measures such as source surveillance and auditsof records should be taken as appropriate to ensure that the design andfabrication of packaging were performed under the control of an NRC-approved QA program.3. Chapter 9 -Applicable, special processes such as welding ornondestructive testing are not normally performed by OPS. However, ifpackaging requires major repairs necessitating use of special processes, e.g., welding or heat treating, measures shall be established to ensurethat the special processes are controlled.
- 4. Chapter 10 -Applicable, visual inspections shall be performed uponreceipt of packaging to ensure compliance with certificates of compliance.
- 5. Chapter 13 -Applicable, all conditions identified in a certificate ofcompliance when using packages shall be adhered to.6. Chapter 16 -Applicable, measures are established for obtaining corrective actions from suppliers and for ensuring that follow-up isdocumented to verify that corrective actions were implemented andeffective.
- 7. Chapter 17 -Applicable, records showing evidence of delivery ofpackages to a carrier and proof that all NRC and Department ofTransportation (DOT) requirements have been satisfied shall also beretained.
- 8. Chapter 18 -Applicable, audits are performed on the supplier ofpackaging to ensure compliance with the certificate of compliance.
Page 4 of 4 Revision 90Page 4 of 4Revision 90 GRADED APPROACH (SITE SPECIFIC)
APNIAPPENDIX F1. SCOPEThe Company establishes measures that provide a graded approach to qualityat Oyster Creek and Three Mile Island Stations.
The extent to which therequirements of this appendix and its associated implementing documents areapplied to an item will be based upon the effect of a malfunction or failure of theitem on nuclear safety or safe plant operations.
- 2. REQUIREMENTS 2.1. GeneralThe quality requirements for items within the scope of this appendix shall beestablished using approved procedures.
Quality requirements will beestablished by the responsible organizational element and subject toassessment by Nuclear Oversight.
The need for special controls, and surveillance or maintaining of processes, equipment and of operational activities will be applied consistent with:-The design and fabrication complexity or uniqueness of the item.-The degree to which functionality can be demonstrated by inspection ortest.-The quality history and degree of standardization of the item.The extent to which the requirements of the QATR apply to activities will bebased, as a minimum, on Operating License conditions and other planspreviously submitted to the NRC for approval, other regulatory commitments asmay have been made associated with activities, the text of this Plan, the unit'sTechnical Specifications, and Appendix C of the QATR.Such other plans or regulatory commitments
- include, but are not limited to, thoseassociated with emergency
- planning, physical plant security, safeguard contingency
- planning, radiological
- controls, radiological environmental
- controls, fire protection, in-service inspection, in-service
- testing, licensed operatorqualification and re-qualification, process control, off-site dose calculation, ShiftTechnical Advisor training, environmental qualification of electrical equipment, security guard training and qualification, etc.2.2. Quality Classification The scope of the Company's QATR includes but is not limited to items andactivities related to safe nuclear plant operation, protection of personnel, andprotection of the public. To ensure consistency in identifying those items andactivities within the scope of the QATR, a classification process has beendeveloped and documented.
This process relies on the use of the terms "SafetyRelated,"
"Augmented Quality,"
and "QATR Scope."Page 1 of 3Revision 90 GRADED APPROACH (SITE SPECIFIC)
APNIAPPENDIX F2.2.1. Nuclear Safety Related or Augmented Quality Items1. Items within the scope of the QATR are designated as "Nuclear SafetyRelated" or "Augmented Quality."
A quality classification process forItems has been developed.
This classification process produces aComponent Record List, which identifies the permanent plant structures,
- systems, and components that are within the scope of the QATR andtheir specific classification.
New Items to which the QATR applies shallbe added to the Component Record List subsequent to their installation.
The classification of structures,
- systems, and components shall besubject to independent design review as part of the classification process.2. Spare or replacement parts and materials are not necessarily classified the same as the component of which they are a part. Such parts andmaterials that perform or contribute to the performance of a SafetyRelated or Augmented Quality function are within the scope of the QATRand classified similar to the component of which it is a part. Forprocurement of spare or replacement parts which are of a different classification, the classification will be determined by Procurement Engineering.
The determinations will be documented,
- retained, andsubject to review and assessment.
- 3. The classification of items and consumable items (such as chemicals, radwaste liners, diesel fuel, etc.) and the technical and qualityrequirements will be specified, documented and approved as part of theprocurement process.4. The QATR may be applied to items, other than those designated as"Safety Related" or "Augmented Quality" as specified by Companymanagement.
2.2.2. QATR Scope Activities
- 1. Activities within the scope of the QATR are designated as within "QATRScope." Activities that are within the scope are those directly related tonuclear and radiological safety and protection of the public and aredelineated below.2. Support activities within the scope of the QATR are quality classification, operating experience assessment, design, maintenance of environmental and fire protection qualification, nuclear fuel management, procurement, fabrication,
- handling, shipping,
- storage, cleaning,
- erecting, installing,
- testing, repairing,
- training, welding, in-service inspection, heat treatment, document
- control, records management, access authorization andfitness-for-duty.
- 3. Operational activities within the scope of the QATR are normal, abnormaland emergency operation, chemistry
- control, core performance monitoring, shift technical advice, equipment
- control, surveillance testing,in-service
- testing, maintenance, housekeeping, fire protection,
- security, Page 2 of 3Revision 90 GRADED APPROACH (SITE SPECIFIC)
APNIAPPENDIX Fradiological
- controls, radiological environmental monitoring, radwastepreparation for shipment, radwaste
- shipment, fuel handling/refueling, technical specification compliance, and emergency preparedness.
- 4. Assurance activities within the scope of the QATR are assessment (audit,document review, monitoring, survey, and surveillance),
inspection, non-destructive examination, and safety review. Individuals who are notdirectly responsible for managing or performing the work or activityperform assurance activities.
Nuclear Oversight personnel performperiodic assessments of the "assurance" activities performed by otherorganizational elements (e.g. NDEIISI) to assure effectiveness andadequacy.
- 5. The above stated activities are controlled through the use of approveddocuments which are, as a minimum, consistent with the requirements ofthe QATR, the unit Operating
- License, specific Regulatory Guides to theextent listed and committed to in Appendix C of the QATR, the FinalSafety Analysis Report, and other regulatory requirements andcommitments.
- 6. A specific task associated with the above activities will be classified aswithin scope of the QATR depending upon:-Statements within the text and the Regulatory Guides identified inAppendix C of the QATR.-The relationship of the task to the safe operation of the nuclearplant.-The relationship of the task to the protection of personnel from theeffects of radiation.
-The relationship of the task to protection of the health and safety ofthe public.-The relationship of the task to regulatory requirements andcommitments.
-Other factors specified by Company management.
Page 3 of 3 Revision 90Page 3 of 3Revision 90 SUPPLEMENTAL APPLICATIONS APNIAPPENDIX G(SITE SPECIFIC)
- 1. SCOPE10OCFR50 Appendix B requires a quality assurance program be established inwriting and executed for activities affecting the safety-related function ofdesignated structures, systems and components to an extent consistent withtheir importance to safety.2. REQUIREMENTS 2.1. Clinton Power Station (CPS)The areas of Environmental, Fire Protection, and Security are specifically identified in Table 3.2-1 of the CPS USAR and/or highlighted in severalRegulatory Guides that define and clarify its importance to the plant.2.1.1. Environmental QATR Chapters 1, 2, 15, 16, and 18 apply to the Environmental area. QATRChapters 3, 10, 11, and 12 do not apply to the Environmental area. QATRChapters 4, 5, 6, 7, 8, 9, 14, and 17 apply to the Environmental area in thelimited manner discussed below.1. Chapter 4 -Applicable to procurement of monitoring services to beperformed by contractors providing services dealing with radiological dataand to radionuclide reference standards used for calibration of radiation measurement systems.2. Chapter 5 -Applicable to all activities related to carrying out theradiological monitoring program including:
sample collection; packaging, shipment and receipt of samples for off-site analysis; procurement, maintenance, storage and use of radioactivity reference standards; calibration and checks of radiation and radioactivity measurement systems; and reduction, evaluation and reporting of data.3. Chapter 6 -Applicable to procedures and instructions required by Chapter5.4. Chapter 7 -Applicable to radionuclide reference standards used forcalibration of radiation measurement systems and to radiological monitoring activities (services) provided by contractors.
- 5. Chapter 8 -Applicable only to radiological sample collection, identification, packaging,
- shipping, receiving, storage and analysis.
- 6. Chapter 9 -Applicable to radioactivity measurements of samples,instrument backgrounds, replicate samples and analytical blanks; dataPage 1 of 3Revision 90 SUPPLEMENTAL APPLICATIONS APNIAPPENDIX G(SITE SPECIFIC) reduction and verification; computer program documentation andverification.
- 7. Chapter 9 -Applicable to laboratory instruments for radiation andradioactivity measurement, continuous radiological effluent monitoring systems and flow-rate measuring devices associated with radiological effluent monitoring systems.8. Chapter 13 -Applicable to radiolog'ical samples only.9. Chapter 14 -Applicable to continuous radiological effluent monitoring systems equipment only.10. Chapter 17 -Applicable to personnel training and qualification; field andin-plant collection of samples; continuous effluent monitoring; samplereceipt and laboratory identification; sample preparation andradiochemical processing; radioactivity measurements of samples,instrument backgrounds and analytical blanks; data reduction andverification; instrument calibration and calibration standards; computerprogram documentation; audits; and corrective action.2.1.2. Fire Protection QATR Chapters that are applicable to the Fire Protection area are 1 through 7,10, 11, and 14 through 18. Chapters 8, 9, 12 and 13 do not apply.1. Chapter 4 -Applicable.
Specification of quality assurance programrequirements for suppliers of fire protection materials, equipment andservices shall be on a case-by-case basis. Commercial grade or off-the-shelf items may provide an acceptable level of quality based on thenature of the item. This determination shall be made by Engineering personnel prior to issuance of procurement documents
- 2. Chapter 7 -Applicable.
Suppliers providing
- material, equipment andservices for fire protection shall be subject to source evaluation andsurveillance.
The extent of imposition of these requirements shall bedetermined on a case-by-case basis by the design organization responsible for review and approval of the procurement specifications.
Measures shall be established, as appropriate, for examination ofproducts upon delivery.
- 3. Chapter 10 -Applicable only to inspection of those items and activities affecting the fire protection system within the quality assurance boundaries as specified in the USAR, Table 3.2-1 and further amplified bythe appropriate design drawings.
- 4. Chapter 17 -Applicable to documents designated as Quality Assurance Records generated in the implementation of the Fire Protection Programand consistent with the requirements identified in Chapter 10 above.Page 2 of 3Revision 90 SUPPLEMENTAL APPLICATIONS APNIAPPENDIX G(SITE SPECIFIC)
- Records are prepared and maintained to furnish evidence that theW applicable criteria discussed herein are being met for activities affecting the Fire Protection Program.5. Chapter 18 -Applicable.
Audits shall be performed and documented toverify compliance with the Fire Protection
- Program, including design andprocurement documents, instructions, procedures and drawings andinspection and test activities.
2.1.3. SecurityQATR Chapters that are applicable to the Security area are 16 through 18.Chapters 1 through 15 do not apply.1. Chapter 17 -Applicable to those records required by the CPS PhysicalSecurity Plan.2. Chapter 18 -Applicable to the physical security of CPS and designated records.2.2 Oyster Creek Nuclear Generating Station (OCNGS)2.2.1 AuditsS1. Independent audits and reviews of Oyster Creek Environmental Technical Specifications (OCETS) will encompass:
A. Coordination of the OCETS with the safety technical specifications toavoid conflicts and maintain consistency.
B. Compliance of station activities and operations with the OCETS.C. Adequacy of the programs and station procedures which are involvedin ensuring the plant is operated in accordance with the OCETS.D. The proper functioning in accordance with the responsibilities listed inSection 3.1 of the OCETS.E. Proposed changes to the OCETS and the evaluation of the impactsresulting from the changes.F. Proposed written procedures, as described in Section 3.4.1 [of theOCETS] and proposed changes thereto which affect theenvironmental impact of the plant.G. Proposed changes or modifications to plant systems or equipment anda determination of the environmental impact resulting from thechanges.H. Adequacy of investigations of violations of the OCETS and adequacyof and implementation of the recommendations to prevent recurrence of the violations.
Page 3 of 3 Revision 90Page 3 of 3Revision 90