ML13252A037
| ML13252A037 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Watts Bar, Sequoyah, Bellefonte  |
| Issue date: | 09/03/2013 |
| From: | Shea J W Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TVA-NQA-PLN89-A | |
| Download: ML13252A037 (141) | |
Text
Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402September 3, 201310 CFR 50.410 CFR 50.54(a)(3) 10 CFR 50.55(f)(3) 10 CFR 50.71(e)ATTN: Document Control DeskU.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Bellefonte Nuclear Plant, Units 1 and 2Construction Permit Nos. CPPR-122 and CPPR-123NRC Docket Nos. 50-438 and 50-439Browns Ferry Nuclear Plant, Units 1, 2, and 3Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68NRC Docket Nos. 50-259, 50-260, and 50-296Sequoyah Nuclear Plant, Units 1 and 2Facility Operating License Nos. DPR-77 and DPR-79NRC Docket Nos. 50-327 and 50-328Watts Bar Nuclear Plant, Unit 1Facility Operating License No. NPF-90NRC Docket No. 50-390Watts Bar Nuclear Plant, Unit 2Construction Permit No. CPPR-92NRC Docket No. 50-391
Subject:
Nuclear Quality Assurance Plan, TVA-NQA-PLN89-A This letter transmits the Tennessee Valley Authority (TVA) Nuclear Quality Assurance Plan(NQAP), Revision
- 28. The enclosures to this letter fulfill the Title 10, Code of FederalRegulations (10 CFR) Part 50.71(e) licensee annual submittal requirement and the10 CFR 50.55(f)(3) requirement to provide changes to the NQAP within the following 90 days for revisions involving construction permit holders.The due date for this letter to satisfy the above 90 day criteria is November 29, 2013,based on an effective date of August 31, 2013, for the changes to the NQAP. This letter issubmitted with a due date of August 31, 2013, to meet the periodic update requirements for licensees required by 10 CFR 50.71(e).
Enclosure 1 to this letter provides a summary of the changes including a description of thechanges, the reason for the changes, and the basis for the conclusion that the changes arenot a reduction in commitment.
Enclosure 2 to this letter provides a copy of TVA NQAP,Revision 28.Printed o. recycled paper U.S. Nuclear Regulatory Commission Page 2September 3, 2013There are no new regulatory commitments included in this submittal.
Please address anyquestions regarding this submittal to Edward D. Schrull at (423) 751-3850.
I certify that I am duly authorized by TVA, and that, to the best of my knowledge and belief,the information contained herein accurately presents changes made since the previoussubmittal, necessary to reflect information and analyses submitted to the Commission orprepared pursuant to Commission requirements.
Respe ully,J. Sheace President, Nuclear Licensing
Enclosures:
- 1. Summary of Changes to the TVA Nuclear Quality Assurance Plan,TVA-NQA-PLN89-A, Revision 282. Nuclear Quality Assurance Plan, TVA-NQA-PLN89-A, Revision 28cc (Enclosures):
NRC Director, Office of Nuclear Reactor Regulation NRC Regional Administrator
-Region IINRC Senior Resident Inspector
-Bellefonte Nuclear PlantNRC Senior Resident Inspector
-Browns Ferry Nuclear PlantNRC Senior Resident Inspector
-Sequoyah Nuclear PlantNRC Senior Resident Inspector
-Watts Bar Nuclear Plant, Unit 1NRC Senior Resident Inspector
-Watts Bar Nuclear Plant, Unit 2 ENCLOSUREI Summary of Changes to the TVA Nuclear Quality Assurance PlanTVA-NQA-PLN89-A, Revision 28Description of Change [ Reason for Change Basis for Conclusion that the Change is Not aDescriptionofChange_
ReasonforChange
_ Reduction in Commitment Editorial changes(Pages 24, 68, and 77 of137)Editorial clarification 1Changes are editorial.
The change on Pages 68 and 77 of 137 delete "or" fromthe Quality Assurance (QA) Program for effluent andenvironmental monitoring discussion.
The previousexistence of "or" was identified by QA as an error in thatcompliance with both Regulatory Guides (RGs)connected by the "or" was required and were beingcomplied with. The removal of the word "or" did notchange compliance with both RGs as currently implemented.
+ +Incorporate organizational change to include the newlycreated position of ChiefGenerating Officer (CGO)and change the reporting relationship for the ChiefNuclear Officer (CNO).(Pages 125, 127, 129, 131,134, and 135 of 137)Changed to reflect the neworganizational position of CGOand the reporting relationship ofthe CNO to the CGO.2The change provides an additional position between theCNO and the Chief Executive Officer.
The changerepresents no change in QA reporting functions.
Personsand organizations performing QA functions continue tohave the requisite authority and organizational freedom,including sufficient independence from cost andschedule when opposed to safety considerations.
Thechanges continue to assure an adequate level ofmanagement reporting including independence betweenthe performing and verifying activities in the areas ofauditing, inspection, and procurement.
El-1 ENCLOSURE 2TVA Nuclear Quality Assurance PlanTVA-NQA-PLN89-A, Revision 28 q pNuclear Quality Assurance Plan(NQAP)(Quality Assurance ProgramDescription)
TVA-NQA-PLN89-A Rev. 0028Page 1 of 137Quality Related 0 Yes 03 NoTVA QualityAssurance ProgramEffective Date 08/31/2013 Responsible Peer Team/Working Group: Quality Assurance Approved by: Ronald E. DetwilerGeneral Manager, Quality Assurance Date TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 2 of 137Revision LogRevision or AffectedChange Effective PageNumber Date Numbers Description of Revision/Change 0 Refer to All Initial IssueAppendix A1 No later All First annual updatethan 2/25/912 No later All Second annual updatethan 4/17/923 No later All Third annual updatethan 4/19/934 No later All Fourth annual updatethan 4/19/945 No later All Fifth annual updatethan 6/15/95for BLN,BFN andSQN. Byfuel load forWBN.Note: Section 12.2.E.2 is effective after NRCapproval.
6 Upon 4,15,16,17, Revised to incorporate subject matter relocated issuance for 22, 23, 25, from WBN Unit 1 Technical Specifications, ChapterBLN, BFN, 65-71, 77, 78, 5.0, Administrative Controls.
and SQN. 79, 92,103,By fuel load 110,111for WBN.7 Subsequent 2, 6, 9,11-18, Revised to incorporate subject matter relocated to NRC's 20-26, 30, 31, from SQN and BFN Technical Specifications, acceptance 33, 34, 39, Chapter 6.0, Administrative Controls; and otherof 42, 45, 46, changes as indicated by revision bars.correspondi 49, 51, 52,ng 55, 59, 60,Technical 62, 64, 65,Specificatio 67, 69-79, 86,n changes.
87, 89, 92-94,Effective 97, 111, 115,7/27/98 119-121, 123,126, 133-136 TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 3 of 137Revision LogRevision or AffectedChange Effective PageNumber Date Numbers Description of Revision/Change 8 9/11/98 3-7, 8-29, Revised to update organization charts in Appendix32-35, 37-43, H, and position titles and functional responsibilities 45, 48, 50, throughout the Plan. Removed redundant 51, 53-59, 61, information from Section 4.1 that is addressed in63, 64, 66, the Responsibilities sections throughout the Plan.67, 87, 92, Revised Section 9.9 as a step in standardizing 94, 95, 100, Plant Reviews.102, 105,106,108,109 8-A1 5/25/99 2, 5, 7, 10, Addendum No. 1 adds responsibilities for the13, 14, 20, Procurement organization and the Nuclear Support26, 34, 35, organization, changes the reporting relationship of37, 38, 50, Corporate Licensing, and clarifies a function of55, 63, 108, Qualified Reviewers.
1099 1/31/2000 2, 3, 7,10, Incorporated changes made in Revision 8,RPL 12/3/99 13,14, 20, Addendum No. 1, and other changes as indicated 24, 26, 35, by revision bars. Revised to add responsibilities 38, 39, 51, associated with independent technical reviews in56, 65, 70, Sections 4.1.3.D and 4.1.4.A.
Added reference to84, 92, 96, 10 CFR 72 in Sections 5.1.A, 5.4.B, and 14.1, and109, 110 Appendix B. Changed effective date from 12/13/99to 1/31/2000 to accommodate impacted procedure revisions.
9-Al 1/31/2000 2, 5, 8,11, Addendum No. 1 clarifies that the ASME III QAM is18, 22, 23, 70 currently inactive.
10 9/8/00 2, 3, 55-59, Incorporated changes made in Revision 9,107, 109 Addendum No. 1, and other changes as indicated by revision bars. Standardized the requirements forplant reviews and the Plant Operations ReviewCommittees (PORCs) in Section 9.9. Revised titlein Appendix H.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 4 of 137Revision LogRevision or AffectedChange Effective PageNumber Date Numbers Description of Revision/Change 11 6/29/01 1-4, 10,13, Added reference to self-evaluation in Section 3.3.4.15-18, 55, 57, Updated to comply with 10 CFR 50.59 rule changes83, 84, 98, in Sections 4.1.3.B.5.b, 9.9.2.A.5, and 9.9.2.B.7.i.
106, 107 Changed reference to "the quarterly trend report" inSection 4.1.4.A.
to "a performance report at leastquarterly."
Updated the description of functions performed by the Nuclear Assurance organization in Section 4.1.6 to consolidate overlapping functions.
Added reference to ANSI/ASNT CP-189-1991 in Appendix B, Table 1, page 8 tocomply with 10 CFR 50.55a(b)(a).
Revised SiteQuality Managers qualification requirements inSection 4.1.6 and Appendix B, Table 2, page 9.Revised commitment to NRC Regulatory Guide1.146 concerning Lead Auditor qualification consistent with approved NRC safety evaluations (Appendix B, Table 2, page 23). Revised AppendixH org. chart to reflect title change. Deleted the BLNSite Nuclear Assurance and Licensing Managerfrom Sections 4.1.6.A, 4.1.6.C and the Appendix HOrganization Chart.11-Al 8/20/01 3, 6, 12 Deleted the reference to the Vice President, E&TS,as the Chairman of the Nuclear Safety ReviewBoard.11-A2 1/18/02 3, 6, 63 Revise the annual Fire Protection audit frequency to"a maximum interval of 24 months."12 08/19/02 1-4, 7, 21, 57, Incorporate Addendum Nos. 1 and 2 to Revision 11.59, 65, 69, Added reference to 10 CFR 72 in Sections 5.1.B,77, 93, 95-98, 9.9.2.A.5, 9.9.2.B.7, 12.2.E.4.d, and 14.1. Added103, 108 10 CFR 72, Subpart G references to Appendix Amatrix. Clarified that Regulatory Guide 1.88 withnoted alternatives apply to 10 CFR 72 records inAppendix B, Regulatory Guide Conformance Status. Included the requirement that 10 CFR 72records must be maintained in duplicate.
Updateretention times for 10 CFR 50.59 records to agreewith 10 CFR 50.59(d)
(3) in Appendix B for WBN,SQN, and BFN. Added records and retention timefor 10 CFR 72 records to Appendix B for SQN andBFN. Added reference to 10 CFR 72 in Appendix C,Section 4.4. Deleted note on Appendix H, Page 1.
TA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 5 of 137Revision LogRevision or AffectedChange Effective PageNumber Date Numbers Description of Revision/Change 12-Al 06/09/03 4, 7,17 Added clarification to Section 4.1.6.A12-A2 06/20/03 4, 7,17, 18, Added reference to BFN Unit 1 Restart organization 20, 108-110 in Section 4.1.6, new Section 4.1.8, and AppendixH. Added Appendix I, BFN Unit 1 RestartOrganizational Matrix.13 08/27/03 4, 7, 21, 58, Incorporated Addendum Nos. 1 and 2 to Revision109 12. Updated Appendix H Organization Chart.Corrected minor format errors.13-Al 03/12/04 4, 5, 7-9, 15, Clarify and enhance ISFSI requirements to23, 26, 56, implement 1OCFR72.
(SQN PERs 03-12911 and69, 70, 72, 12912)76, 84, 94,97, 98,102-106, 10913-A2 04/30/04 4, 7,16, 17, Moved the reporting relationship of the General110,111 Manager, NA (and organization) from a "direct"report of the CNO and Executive Vice President, WVAN, to a direct (hard-line) report to the VicePresident, Nuclear Support.
The General Manager,NA still retains access and a "dotted-line" reporting channel to the CNO and Executive Vice President, WVAN.13-A3 6/4/04 1-5, 8, 9, 45, Deleted requirement that the General Manager47, 110 concur with WVAN Inspector Certifications (Sections 9.1.3.D and 9.3.3.F).
Added Appendix F, DeferredPlant Equipment Policy.14 8/31/04 All Incorporated Addendum Nos. 1, 2 and 3 fromRevision 13.14-Al 12/17/04 5,8,73,74 Revised definition of "Independent Spent FuelStorage Installation (ISFSI)."
Added definition of"Greater than Class C Waste (GTCC Waste)."14-A2 5/17/05 5, 8, 84 Added reference to Reg. Guide 1.189 in AppendixB, Table 1.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 6 of 137Revision LogRevision or AffectedChange Effective PageNumber Date Numbers Description of Revision/Change 15 8/31/05 5, 6, 8, 9,12, Incorporated Addendum Nos. 1 & 2 from revision14,17,18,
- 14. Updated organization titles. Updated Appendix19, 21, 22, H organization charts.23, 28, 35,40, 43, 44,46, 48, 49,52, 53, 55,56, 63, 65,68, 69, 73,74, 84, 88,111,112,113 15-Al 7/14/06 5, 8,12,18, Clarified Section 3.3.3 concerning assessment of19, 20 NA performance.
Clarified Section 4.1.6.Aconcerning the NA Organizational Structure.
Clarified Section 4.1.6.E concerning reporting responsibility of the Evaluation and Analysis Group.Clarified Section 4.1.6.F.5 concerning evaluation ofQA Training.
16 8/31/06 5, 7, 8, 12, 14 Incorporated Addendum No. 15-Al. Updated-18, 20, 21, organization titles. Updated Appendix H34, 39, 42, organization charts. Corrected minor typographical 44, 45, 47, errors. Transferred responsibility for NSRB support52, 53, 55, from Nuclear Assurance to Corporate Nuclear63, 67, 85, Licensing and Industry Affairs.109,11016-Al 5/8/07 6, 9, 13, 18, Deleted reference to Bellefonte (BLN) in Sections19, 78, 96, 3.3.3; 4.1.6.F; Appendix C, Section 3.0; and102,108,112 Appendix F due to withdrawal of construction permit. Corrected references in Sections 4.1.7.D;Appendix A; Appendix B, Rag Guide 1.88, WBN QARecords List. Updated Title in Appendix I.17 08/31/07 6, 7, 9, 10-19, Incorporated Addendum No. 16-Al. Updated21-24, 28, 29, organization titles. Updated Appendix H31, 35, 40, organization charts. Deleted reference to Browns43-46, 48, 51, Ferry Unit 1 organization.
Deleted Appendix I.53-56, 60, 62, Added exceptions to Appendix B, Regulatory Guide64, 67, 68, Conformance Status, NRC Regulatory Guides 1.33,78, 79, 89, 1.123 and 1.146 concerning Commercial Grade93, 94, 96, Calibration Services.
Revised some responsibilities 101-106, 109, based on re-organization.
111,112 TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 7 of 137Revision LogRevision or AffectedChange Effective PageNumber Date Numbers Description of Revision/Change 1811/30/076,7,9-13, 16-19, 23,25-26, 36, 44,46, 49, 52,55, 57, 71,77, 110-113,115-117Pointer to a new organization is introduced as aresult of an internal re-organization.
The NuclearGeneration Development and Construction organization lead by a senior vice president reportsto the COO and is at the same management levelas the CNO. The WBN 2 specific position of ProjectNuclear Assurance Manager is introduced withresponsibilities and education and experience requirements specified.
This change is like the onedone for the recently completed BFN 1 restart.Addressed ASME III reactivation.
The ASME III QAmanual will be modified to allow the limited scopeactivities associated with completing the paperwork for work did started but did not complete under ourold N stamp. Bechtel will complete the ASME workunder their N Stamp. Clarified Inspection ServicesOrganization Manager to indicate they do not applyto WBN 2. The responsibilities for construction completion are contracted to the Engineering Procurement and Contractor (Bechtel).
Throughout body of the NQA Plan reassigned responsibility for construction and unlicensed unitactivities from the corporate VP Engineering to theVP WBN Unit 2 to be consistent with the internalorganizational recognizing NGDC as the groupcompleting construction.
Deleted text in AppendixF for deferred equipment policy since it is no longerapplicable.
Our 120 day letter to the NRC indicated needed equipment will be completely refurbished and no credit is taken for preservation activities.
The Appendix was renamed and text added todescribe the construction completion organization for TVA and Bechtel.
Appendix H organization charts were reworked to reflect the organization changes described in the text of the NQA Plan.18-Al 09/17/08 7,10,17, Changed the reporting relationship for the General113,115,
- Manager, Nuclear Assurance (NA), from a direct116, 117 report to the Chief Nuclear Officer to a direct reportto the General Manager, Nuclear Oversight andAssistance.
18-A2 09/17/08 7, 10, 60 Changed the review requirements for Administrative Procedures
-PORC Review is limited to procedures requiring an evaluation per 10 CFR 50.59.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 8 of 137Revision LogRevision or AffectedChange Effective PageNumber Date Numbers Description of Revision/Change 18-A3 09/30/08 7, 10, 20 In the second sentence of 4.1.7.C.3 add the words"or Alternate Chairman" so the sentence reads "TheChairman or Alternate
- Chairman, NSRB, is alsoresponsible for ensuring that the QA requirements established by this Plan related to NSRB functions are either included or referenced (as appropriate) inrelated procedures or instructions."
19 12/04/08 7, 10, 16, 17, Revised Sections 4.1.4 and 4.1.6, Appendix F, and20, 21, 23, Appendix H (Al), 9.9.2.B.7 (A2), and 4.1.7.C.3 (A3)38, 40, 41, to incorporate Addendum Al, A2, and A3. Updated42, 54, 60, organizational titles and charts based on63, 113, 115, organizational changes.
Revised Section 4.1.7.C.3 116,117 to change responsibilities from Alternate
- Chairman, NSRB, to General Manager, Licensing andPerformance Improvement.
19-Al 02/06/09 8, 11, 68, 91 Inserted Section 12.2.E.5 to clarify the use of graceperiods for internal audits. Revised exceptions toRegulatory Guide 1.33.20 03/16/09 8, 11, 15-19, Revised to reflect reinstatement of BLN21, 24, 26-27, Construction Permits.
Added new Appendix G for31, 37, 45, Bellefonte.
Revised various sections throughout 48, 54, 57, NQA Plan to recognize BLN CP reinstatement.
58, 69, 91, Incorporated revision 19 addendum Al.105, 115-12421 07/01/09 8,9, 12,13, Revised to reflect the changes of Nuclear15, 16,18, Assurance organization to address the construction 19, 24, 26, activities at WBN Unit 2 and BLN Units 1 and 2.30, 31, 47,48, 51, 57,59, 64, 66,70, 112-116,118-120, 123,125, 126 TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 9 of 137Revision LogRevision or AffectedChange Effective PageNumber Date Numbers Description of Revision/Change 22 10/30/09 8-9, 12, 15, Revised organization titles and responsibilities to17-21, 24, 25, reflect the reorganization of the NPG. Add the28-33, 37, 42, Radiological Emergency Plan and the Fire44-49, 51, 54, Protection Reports to Appendix H for PER 165761.56, 57, 62, Added a clarification to 5.5 Program Changes.66, 67, 70,71, 76, 81,90, 97, 99,104, 113-116,118-120,122-12623 12/14/09 8, 9, 13, 1) Revise section 9.1.2 to state that qualification of15-16, 18, personnel performing line verification shall be in21-24, 39, 42, accordance with Regulatory Guide 1.8 as endorsed43-44, 51, 54, in Appendix B of the Plan. 2) Add a definition for56-57, 61, 67, Quality Control Inspectors to section 15.0 stating69, 78, 82, that they are qualified to ANSI N45.2.6-1978.
3)107, 114-115, Mark Regulatory Guide 1.8 to be applicable to119-120, Inspection and Line Verification in Table 1 of123-126 Appendix B. 4) Update position titles. 5) ChangedPlan to Program as appropriate to be consistent.
(All pages affected.)
- 6) Removed dotted linerelationship between CNO and SENIOR VP NGDCto be consistent with Organizational Topical Report.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 10 of 137Revision LogRevision or AffectedChange Effective PageNumber Date Numbers Description of Revision/Change 24 08/31/10 All This document was converted from Word 95 toWord 2002 using Rev. 20. The document has beenupgraded to Word 2007 and Rev 21, 22, and 23changes have been incorporated.
The purpose of this revision is to reflectorganization as described by Organization Effectiveness Initiative as it relates to Bellefonte Units 1 & 2 and NGDC Organization.
Additionally NPG position titles below Executive Vice President, and CNO have been removed and the positions aredescribed as "management position responsible for." Removed the organizations charts for NPGorganization as described by NUREG 0800 Chapter17.3. Also modified the organization descriptions inthe NQAP to meet the organizational requirements of 10 CFR 50.54a and Standard Review Plan 800sections 17.1, 17.2 and 17.3.Changed title Plan and added Quality Assurance Program Description through the document.
Alsochanged Program to Plan or program description asappropriate to be consistent.
24-Al 09/30/10 5 -7,10,101 Corrected name conversion issue associated withNA to QA and Word 95 to 2007 conversion issueassociated with degrees Fahrenheit symbol onpage 101.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 11 of 137Revision LogRevision or AffectedChange Effective PageNumber .Date Numbers Description of Revision/Change 2509/30/2011 1,11,12 -21,24-26,28-32,35, 44,48,52-55,58,61, 64,66,67, 69,73,75, 78,125,126, 129-131,135, 136The purpose of this revision is to reflectorganization as described by Organization Effectiveness Initiative as it relates to Watts Bar 2,Bellefonte Units 1 & 2 and NGDC Organization.
NGDC position titles below Senior Vice President, NGDC have been removed and the positions aredescribed as "management position responsible for."Removed some organizations charts for NGDCorganization and modified charts to be genericorganizational charts to indicate functional relationships, as described in 10 CFR 50.54(a)
(3)(iv).Modified PORC Member: radiological andchemistry control representative(s) to Member:radiation protection representative(s) and Member:chemistry representative(s).
Eliminated the Evaluation and Analysis (E and A)Group while the activities previously performed bythe E and A Group are now assigned to the QualityAssurance organization.
Multiple minor changes throughout the document toreflect the separate NPG QA Organizations andNGDC QA Organizations and describe which groupis responsible for specific functions.
Changes implemented from QADP-4 requestsQAP-201 1-001, through QAP-2011-006.
Effective date 09/30/2011 to support ChangeManagement for QAP-20111-003, which updatedPORC Membership.
NPG-SPP-10.5 requiresrevision.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 12 of 137Revision LogRevision or AffectedChange Effective PageNumber Date Numbers Description of Revision/Change 2605/09/2012 12-14,20-28, 31, 32,35, 37-39,45, 49, 50,53, 54, 56,58 -62, 64,66,71, 73-75, 77, 79,89,101,124 127, 129-131,134-137Nuclear Quality Assurance Program PolicyStatement was revised to reflect elimination of theTVA Chief Operating Officer (COO) position andreassignment of the COO responsibilities regarding NQAP to the Executive Vice President and ChiefNuclear Officer (CNO). [PER 509082] References to the COO position throughout the NQAP wereremoved.Organization titles and reporting relationships wererevised to reflect the reorganization of the NuclearPower Group (NPG) and Nuclear Construction (NC), formerly Nuclear Generation Development
&Construction (NGDC). [PERs 494361, 506005 and509082] NGDC Project Management, NewGeneration Licensing (NGDC) and Training andPerformance Improvement (NGDC) positions wereeliminated.
Quality functions were transferred toappropriate WBN U2 and BLN personnel.
NuclearGeneration Development (NGDC) position waseliminated and small modular reactor technology was transferred to technology innovation.
Responsibility for Inspection Services Organization (ISO) was transferred from Operating Support andFleet Governance to Engineering, Environmental
&Support Services.
Responsibility for Supply Chain was transferred from Executive Vice President and Chief Financial Officer to Executive Vice President and ChiefAdministrative Officer.Added position description for the newly createdposition of Senior Vice President Nuclear SupportServices in section 4.1.1.Revised the section numbers related to1 OCFR73.55 Access Authorization reviews/audits inAppendix B. [QADP-4 Change Request QAP-201 1-008]Minor administrative errors were corrected.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 13 of 137Revision LogRevision or AffectedChange Effective PageNumber Date Numbers Description of Revision/Change 27 08/31/2012 23-24, 32-33, Annual update.37, 59, 74, Added reference to ASME OM Code in section98, 126 5.4.B and Appendix B Table 1 as the requirements for Inservice Testing (IST) of components to assesstheir operational readiness in light water reactorswere removed from ASME Section Xl and relocated to ASME OM Code.27 cont Incorporates recent Nuclear Construction (NC)organizational changes at WBN U2. Responsibility for pre-operational testing was transferred from theGeneral Manager WBN U2 Technical Services tothe General Manager WBN U2 Engineering andConstruction.
This organizational change alsoestablished responsibility for Corrective ActionProgram (CAP) management to the GeneralManager WBN U2 Engineering and Construction and reflects the current responsibility for CAP atBLN.Minor administrative errors were corrected.
28 08/31/2013 24 Removed "their"-
editorial change68, 77, Removed "or" -editorial change125, 127, Change reporting relationship for Chief Nuclear129, 131, Officer (CNO). The CNO now reports to the newly-134, 135 created position of Chief Generating Officer (CGO)rather than the Chief Executive Officer.Annual update.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 14 of 137NUCLEAR QUALITY ASSURANCE PROGRAM POLICY STATEMENT It is the policy of the Tennessee Valley Authority (TVA) that activities which affect quality beaccomplished in a planned and systematic manner to achieve compliance with pre-established qualityobjectives and acceptance criteria.
Accordingly, TVA has established and will maintain a qualityassurance program.
The quality assurance program includes this Nuclear Quality Assurance Plan(NQAP) and the approved documents, which are used to implement the program.
The qualityassurance program and requirements for specific items and activities are applied commensurate withtheir importance to safe, reliable nuclear operations, construction, and independent spent fuelstorage.Management policies and requirements for the TVA Quality Assurance Program are established bythe Executive Vice President and Chief Nuclear Officer (CNO) for operating units. The Executive VicePresident and CNO establishes the management policies and requirements for the TVA QualityAssurance
- Program, through the Senior Vice President, Nuclear Construction, for units withconstruction permits and other projects not related to the operating units. These management policies and requirements provide the controls that must be applied to the activities performed by andfor the agency to ensure implementation of TVA commitments.
Quality Assurance (QA) is responsible for maintaining the TVA Nuclear Quality Assurance Plan. QAis responsible for determining if the quality assurance program and quality requirements are beingimplemented by performing verification activities and informing management of quality problems.
The QA program is founded on the principle that the line organization has the primary responsibility for quality and safety. Self-assessment practices are used to ensure the desired levels of quality andsafety are achieved and maintained.
Line management is responsible for establishing quality requirements in procedures and instructions and ensuring that the achievement of quality receives major emphasis in planning, implementing, verifying, and documenting work. Quality assurance objectives are not to be subordinated toachieving cost or schedule objectives.
Line management will be held accountable for compliance withthe quality assurance program and quality requirements.
Conflicts involving interpretation of quality assurance requirements of TVA's NQAP are resolved bythe Executive Vice President and CNO. Where TVA has delegated responsibility for implementation of parts of the NQAP to contractors, TVA line management retains responsibility for adequacy ofcontractor implementation of quality requirements.
Activities may be performed by a contractor using their quality assurance program provided that thecontractor's quality assurance program is approved by TVA and appropriate interfaces areestablished.
Each employee is encouraged and expected to do the job right the first time and is responsible forcomplying with the requirements contained in the Nuclear Quality Assurance Plan and itsimplementing documents.
Procedures and instructions must be followed or appropriately changedthrough a controlled change process before work proceeds.
Preston Swafford 5/8/12 M. Skaggs 5/3/12Executive Vice President Date Senior Vice President Dateand Chief Nuclear Officer Nuclear Construction TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 15 of 137Table of Contents1.0 PURPOSE .............................................................................................................................
212.0 APPLICABILITY
....................................................................................................................
213.0 GENERAL .............................................................................................................................
213.1 General Management Requirements
..................................................................................
21312 General Regulatory Requirements
....................................................................................
2233 NQAP Overview
.....................................................................................................................
223.3.1 Implementation
...................................................................................................
223.3.2 Authority and Organizational Freedom of Those Performing QAVerification
.............................................................................................................
223.3.3 Assessment of Effectiveness
..............................................................................
233.3.4 Achievement of Quality in Performance
............................................................
233.3.5 Interpretation of Quality Assurance Program Requirements
...............................
233.3.6 Units with Construction Permits ...........................................................................
234.0 ORGANIZATION
...................................................................................................................
234.1 Functions of Organizations
................................................................................................
244.1.1 Executive Nuclear Management
.........................................................................
244.1.2 TVA Organizations
.............................................................................................
244.1.3 Nuclear Business Operation
...............................................................................
254.1.4 Nuclear Operations Support ...............................................................................
254.1.5 Nuclear Operations (NO) ....................................................................................
264.1.6 Nuclear Engineering
...........................................................................................
274.1.7 Quality Assurance (QA) .....................................................................................
274.1.8 NPG Licensing
...................................................................................................
304.1.9 Procurement
......................................................................................................
324.1.10 NPG Nuclear Oversight
......................................................................................
324.1.11 W BN U2 Construction Completion Project ..........................................................
324.1.12 Bellefonte Units 1 & 2 .........................................................................................
324.1.13 Technology Innovation
........................................................................................
334.1.14 NC Quality Assurance
........................................................................................
334.1.15 Deleted ...................................................................................................................
334.1.16 Deleted ...................................................................................................................
334.1.17 Deleted ...................................................................................................................
334.1.18 Engineering, Environmental
& Support Services
.................................................
33 TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 16 of 137Table of Contents (continued) 5.0 NUCLEAR QA PROGRAM ...............................................................................................
335.1 Program Scope ......................................................................................................................
335.2 Graded Approach
...................................................................................................................
355.3 Program Elements
.................................................................................................................
365.4 Program Documents
..............................................................................................................
375.5 Program Changes ..................................................................................................................
376.0 CONTROL OF DOCUMENTS AND RECORDS ...............................................................
386.1 Procedures and Instructions
...............................................................................................
386.1.1 General ...................................................................................................................
386.1.2 Program Elements
............................................................................................
386.1.3 Responsibilities
....................................................................................................
396.1.4 Source Requirement Documents
........................................................................
406.2 Document Control ..................................................................................................................
406.2.1 General ...................................................................................................................
406.2.2 Program Elements
............................................................................................
406.2.3 Responsibilities
.....................................................
I ..............................................
416.2.4 Source Requirement Documents
........................................................................
416.3 QA Records ............................................................................................................................
416.3.1 General .................................................................................................................
416.3.2 Program Elements
............................................................................................
416.3.3 Responsibilities
...................................................................................................
426.3.4 Source Requirement Documents
........................................................................
427.0 DESIGN CONTROL ...............................................................................................................
427.1 General ..................................................................................................................................
427.2 Program Elements
.................................................................................................................
427.2.1 Basic .......................................................................................................................
427.2.2 Design Inputs ......................................................................................................
447.2.3 Design Analysis
.................................................................................................
447.2.4 Interface Control .................................................................................................
447.2.5 Design Output ....................................................................................................
447.2.6 Design Verification
............................................................................................
457.2.7 Design Changes .................................................................................................
457.3 Responsibilities
......................................................................................................................
46 TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 17 of 137Table of Contents (continued) 7.4 Source Requirement Documents
......................................................................................
468.0 PROCUREMENT AND MATERIAL CONTROL ...............................................................
468.1 Procurement Document Control ........................................................................................
468.1.1 General ...................................................................................................................
468.1.2 Program Elements
.............................................................................................
478.1.3 Responsibilities
.................................................................................................
488.1.4 Source Requirement Documents
........................................................................
498.2 Control of Purchased
- Material, Equipment, and Services
.................................................
498.2.1 General ...................................................................................................................
498.2.2 Program Elements
.............................................................................................
498.2.3 Responsibilities
....................................................................................................
518.2.4 Source Requirement Documents
........................................................................
518.3 Identification and Control of Materials, Parts, and Components
........................................
518.3.1 General ...................................................................................................................
518.3.2 Program Elements
.............................................................................................
518.3.3 Responsibilities
.....................................................................................................
528.3.4 Source Requirement Documents
........................................................................
529.0 CONTROL OF PLANT ACTIVITIES
.................................................................................
529.1 Inspection and Line Verification
.........................................................................................
529.1.1 General ...................................................................................................................
529.1.2 Program Elements
..............................................................................................
529.1.3 Responsibilities
...................................................................................................
549.1.4 Source Requirement Documents
........................................................................
559.2 Quality Assurance Assessments
.........................................................................................
559.2.1 General ...................................................................................................................
559.2.2 Program Elements
...............................................................................................
559.2.3 Responsibilities
....................................................................................................
559.2.4 Source Requirement Documents
........................................................................
559.2.5 Units with Construction Permits ...........................................................................
559.3 Control of Special Processes
.................................................................................................
569.3.1 General ...................................................................................................................
569.3.2 Program Elements
...............................................................................................
569.3.3 Responsibilities
....................................................................................................
57 TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 18 of 137Table of Contents (continued) 9.3.4 Source Requirem ent Docum ents ........................................................................
579.4 Test Control ....................................
.......................................................................................
579.4.1 General ...................................................................................................................
579.4.2 Program Elem ents ...............................................................................................
589.4.3 Responsibilities
....................................................................................................
599.4.4 Source Requirem ent Docum ents ........................................................................
609.5 Control of M &TE and Installed Safety-Related I&C Devices ...............................................
609.5.1 G eneral ...................................................................................................................
609.5.2 Program Elem ents ...............................................................................................
609.5.3 Responsibilities
....................................................................................................
629.5.4 Source Requirem ent Docum ents ........................................................................
639.6 Handling,
- Storage, and Shipping
........................................................................................
639.6.1 General ...................................................................................................................
639.6.2 Program Elem ents ............................................................................................
639.6.3 Responsibilities
...................................................................................................
649.6.4 Source Requirem ent Docum ents ........................................................................
649.7 Inspection, Test, and O perating Status ............................................................................
649.7.1 G eneral ...................................................................................................................
649.7.2 Program Elem ents .............................................................................................
659.7.3 Responsibilities
...................................................................................................
659.7.4 Source Requirem ent Docum ents ........................................................................
669.8 Control of M aintenance
......................................................................................................
669.8.1 General ..................................................................................................................
669.8.2 Program Elem ents .............................................................................................
669.8.3 Responsibilities
................................................................................................
679.8.4 Source Requirem ent Docum ents ........................................................................
679.9 Plant Reviews ........................................................................................................................
679.9.1 General ...................................................................................................................
679.9.2 Plant Reviews ......................................................................................................
689.9.3 Records ..................................................................................................................
7110.0 ADVERSE CO NDITIO NS .................................................................................................
7110.1 G eneral ..................................................................................................................................
7110.2 Program Elem ents .................................................................................................................
72 TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 19 of 137Table of Contents (continued) 10.2.1 Control of Nonconform ing Item s ........................................................................
7210.2.2 Corrective Action For Adverse Conditions
...........................................................
7210.2.3 Escalation of Adverse Conditions
........................................................................
7210.2.4 Tracking
..................................................................................................................
7310.2.5 QA Trending
........................................................................................................
7310.2.6 Stop W ork ...............................................................................................................
7310.3 Responsibilities
......................................................................................................................
7410.4 Source Requirem ent Docum ents .....................................................................................
7411.0 INDOCTRINATION,
- TRAINING, QUALIFICATION, AND CERTIFICATION
......................
7411.1 General ..................................................................................................................................
7411.2 Program Elem ents .................................................................................................................
7511.2.1 Indoctrination and Training
.................................................................................
7511.2.2 Q ualification and Certification
.............................................................................
7511.3 Responsibilities
......................................................................................................................
7511.4 Source Requirem ent Docum ents ......................................................................................
7612.0 AUDITING
.............................................................................................................................
7612.1 General ..................................................................................................................................
7612.2 Program Elem ents .................................................................................................................
7612.3 Responsibilities
......................................................................................................................
7812.4 Source Requirem ent Docum ents .....................................................................................
7913.0 CO M PUTER SO FTW ARE AND DATA ............................................................................
7913.1 General ..................................................................................................................................
7913.2 Program Elem ents .................................................................................................................
7913.3 Responsibilities
......................................................................................................................
8013.4 Source Requirem ent Docum ents ......................................................................................
80
14.0 REFERENCES
......................................................................................................................
8014.1 Regulations
...........................................................................................................................
8014.2 Regulatory G uidance ......................................................................................................
8114.3 TVA Licensing Subm ittal Docum ents .................................................................................
8114.4 QA M anuals ...........................................................................................................................
8114.5 Other ......................................................................................................................................
8115.0 DEFINITIO NS ........................................................................................................................
82 TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 20 of 137Appendix A:Appendix B:Appendix C:Appendix D:Appendix E:Appendix F:Appendix G:Appendix H:Appendix 1:Appendix J:Table of Contents (continued)
Comparison Matrix of Quality Assurance ProgramRequirements with those of 10 CFR 50, Appendix B, 10 CFR72, Subpart G, and Selected ANSI Standards
...............................................
88Regulatory Guide Conformance Status ........................................................
89Guidelines for Determination of TVA Identified Quality-Related C lassifications
..................................................................................................
117Scope of Nuclear Quality Assurance Program ...............................................
121Computer Software
...........................................................................................
122Watts Bar Unit 2 Construction Completion Project ........................................
123Quality Assurance Programs for Bellefonte Units I and 2 ............................
128Types of Controlled Documents and Manuals ................................................
133TVA NQAP Organization Charts ......................................................................
134List Of Abbreviations
........................................................................................
136 TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 21 of 1371.0 PURPOSEThis document defines and describes the nuclear quality assurance (QA) requirements forTennessee Valley Authority and establishes responsibilities for their implementation.
Theprincipal objective of the Nuclear Quality Assurance Plan (NQAP) is to provide confidence that activities affecting quality during design, construction, operation, and maintenance areaccomplished in a manner to achieve compliance with preestablished quality objectives andacceptance criteria.
2.0 APPLICABILITY
The NQAP applies to (1) Tennessee Valley Authority Nuclear Power Group (NPG) andNuclear Construction (NC) personnel and organizations performing activities that couldaffect quality-related structures,
- systems, and components at TVA's nuclear plants andISFSI; (2) TVA non-nuclear organizations working either directly under the TVA NQAP orunder their program as required by Intergroup Agreement; and (3) contractor activities thatcould affect quality-related structures,
- systems, and components, unless NPG or NC hasapproved alternate administrative controls for those activities.
3.0 GENERALThis Nuclear Quality Assurance Plan is formatted in such a manner as to provide users witha functionally usable document from which Nuclear Procedure System (NPS) documents are developed to implement the requirements stated herein.The source requirement documents for QA activities are listed in Appendix B. Not only arethe source requirement documents listed (e.g., ANSI Standards and Regulatory Guides) butthey also specify the particular sections of these source documents that must be addressed (e.g., ANSI N18.7, Section 5.2.12).
Providing specific sections of the source requirement documents facilitates use by individuals responsible for the development of applicable procedures and instructions.
- However, it must be stressed that the entire set of source requirement documents referenced in each section must be reviewed and understood to capture the programrequirements of each source requirement document in QA Program procedures andinstructions.
The following subsections identify the management and regulatory requirements applicable to the NQAP. An overview of the program and a description of the functions of the variousorganizations performing activities within the scope of the program are provided.
3.1 General Management Requirements The management policies and requirements for the QA Program are established by theExecutive Vice President and Chief Nuclear Officer (CNO), and the Senior VP, NC. Thesemanagement policies and requirements provide the administrative controls that shall beapplied to activities performed by and for TVA to ensure activities are performed in amanner consistent with QA objectives and to provide adequate record of accomplishment ofcommitments.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 22 of 1373.2 General Regulatory Requirements The NQAP shall address the conditions of licenses and permits and encompass theapplicable regulatory requirements contained in Appendix B of this program description.
3.3 NQAP OverviewThe quality assurance program includes the Nuclear Quality Assurance Program PolicyStatement, this Nuclear Quality Assurance Plan (NQAP), the ASME Section III QualityAssurance Manual (ASME III QAM), and other quality-related NPS documents.
The NQAPprovides direction and implements requirements derived from regulatory requirements, national codes and standards, and other TVA commitments.
General regulatory guidanceand national standards that TVA is obligated to implement in the NQAP are listed inAppendix B, "Regulatory Guide Conformance Status."3.3.1 Implementation A. The requirements established by this program description and the ASME III QAM areimplemented by NPG and NC documents sponsored by various organizations.
Toensure the NQAP is fully integrated and implemented, procedures and instructions address additional implementing level details contained in requirement documents onwhich the NQAP is based.B. The terms "procedure" and/or "instruction,"
when used within this program description, also includes written standards and documents of a similar nature.3.3.2 Authority and Organizational Freedom of Those Performing QAVerification Personnel with responsibility for performing QA verification functions shall have sufficient authority and organizational freedom to:A. Identify quality problems.
B. Initiate, recommend, and provide corrective actions through a comprehensive corrective action program.C. Verify the implementation of corrective actions.D. Initiate stop work, if required, to restrict further processing,
- delivery, or installation of anonconforming item or unsatisfactory condition until completion of corrective action orsatisfactory dispositioning.
The individuals and organizations responsible for performing QA verifications andassessments of the NQAP shall be formally designated and sufficiently independent fromconsiderations of cost or scheduling to ensure objectivity in performing assessments.
Theyshall be afforded direct access to appropriate management levels.QA verification of conformance to established quality assurance program requirements isaccomplished by those who have neither the direct responsibility nor the authority forperforming the quality-related work activities being verified.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 23 of 1373.3.3 Assessment of Effectiveness The General Manager, NPG QA, shall assess the overall effectiveness of the NQAP forCorporate and nuclear plant operating sites (BFN, SQN, and WBN). Results shall bereported to the Executive Vice President and CNO, and affected vice presidents.
Theseassessments include NPG and non-NPG organizations and contractors.
QA verifies theeffectiveness of NSSS suppliers through audits and annual review of their performance.
The General Manager, NPG QA, shall arrange for a biennial assessment of NPG's QualityAssurance Program by an organization external to the QA organization.
The Senior Manager BLN QA (SM BLN QA) and Senior Manager WBN Unit 2 QA (SM WBNU2 QA) shall assess the effectiveness of the NQAP for NC. Results shall be reported to theSenior Vice President, NC, affected vice presidents and general managers.
The SM BLN QA and SM WBN U2 QA shall arrange for the assessment of the performance of NC QA organization(s) by an independent organization at a frequency that meetsregulatory requirements.
3.3.4 Achievement of Quality in Performance Management personnel shall ensure, through organizational structure, self-evaluation, andassigned functional responsibilities, that the attainment of program objectives isaccomplished by those who have been assigned the work. Achievement of quality in theperformance of quality-related activities is the responsibility of each individual involved inTVA's nuclear power program.3.3.5 Interpretation of Quality Assurance Program Requirements The General Manager, NPG QA shall provide interpretation of Nuclear Quality Assurance Plan requirements for TVA organizations.
Differences involving interpretation orimplementation of the Nuclear Quality Assurance Plan shall be immediately identified andreported to QA for resolution.
If satisfactory resolution is not readily attainable, then thedifference shall be escalated to the appropriate Executive Nuclear Manager and ultimately the Executive Vice President and CNO, if necessary.
3.3.6 Units with Construction PermitsRefer to Appendices F and G for units with construction permits.4.0 ORGANIZATION The organizational structure, functional responsibilities, levels of authority, and lines ofinternal and external communication for the management, direction, and execution of theNQAP shall be clearly established for all organizational levels. This Nuclear QualityAssurance Plan describes the general organizational structure and primary responsibilities of NPG and NC organizations and responsibilities of non-NPG organizations involved in theNQAP. The Human Resources organization shall prepare organization charts that showoverall NPG and NC organizational structure.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 24 of 137%cr%4.0 ORGANIZATION (continued)
The overall organizational structure is shown in Appendix I. The QA organizations areresponsible for establishing upper-tier QA Program requirements and implementation ofQuality Assurance functions at corporate and nuclear plant sites. The size of the QAorganizations, including the size of respective Site QA staffs, is determined by assessing theresources required to adequately perform functions and workloads assigned to each QAorganizational unit.Each plant's Final Safety Analysis Report (FSAR) references the Tennessee ValleyAuthority Organization Topical Report (TVA-NPOD89A) or provides a description of otherkey organizational positions, including the Executive Vice President, and CNO'sorganization and plant operating staffs, responsible for administering and implementing theNQAP.4.1 Functions of Organizations TVA management, while carrying out their functions, are required to fully comply with allaspects of the NQAP applicable to their organization and ensure proper implementation.
This subsection identifies (1) functional responsibilities that are generally implemented through procedures and instructions by all TVA organizations involved in the program and(2) specific NQAP responsibilities for sponsors of upper-tier corporate program documents.
4.1.1 Executive Nuclear Management A. The Executive Vice President and Chief Nuclear Officer (CNO) has the overallresponsibility for the establishment, implementation, and administration of TVA's NQAPand the evaluation of its effectiveness for operating units. This responsibility isadministered through management staff.B. The Senior Vice President, NC has responsibility for establishment, implementation, and administration of TVA's NQAP and the evaluation of its effectiveness for units withconstruction permits and other projects that are subject to NQAP requirements.
Thisresponsibility is administered through management staff as shown in Appendices F, Gand I.C. The Senior Vice President, Nuclear Support Services reports directly to the Executive Vice President and CNO and has responsibility for the support organizations thatcoordinate and integrate efforts and initiatives into day-to-day NPG business.
Organizations reporting to this position include nuclear engineering, nuclear businessoperations, regulatory recovery
- projects, BLN interface and nuclear operations support.4.1.2 TVA Organizations All TVA organizations that work directly under the TVA NQAP have the following generalfunctions:
A. Invoke appropriate NQAP requirements on other organizations that provide services forquality-related programs and features.
B. Regularly review the status and adequacy of those parts of the NQAP, which they areexecuting.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 25 of 137%cr%/64.1.2 TVA Organizations (continued)
C. Develop,
- control, and maintain procedures and instructions as appropriate toimplement quality-related activities and processes.
D. Ensure appropriate controls for documents and records generated within theorganization or received from external sources.E. Ensure appropriate controls are developed and implemented to maintain housekeeping and cleanness requirements of facilities,
- systems, and components during theperformance of work activities.
F. Identify and resolve adverse conditions and perform related corrective action activities including assessing trends for internally and externally identified problems.
G. Make personnel and resources available during audit performance and ensure thataudit responses and corrective actions are completed within established timeframes.
H. Develop certification programs as appropriate and ensure that trained, qualified, and,where required, certified employees are used in the performance of quality-related activities.
I. Initiate stop work within their area of responsibilities when warranted.
J. Ensure personnel performing quality-related activities receive indoctrination andtraining as necessary to ensure that adequate proficiency is achieved and maintained.
K. Ensure procedures adequately address interfaces of affected organizations.
L. Ensure during preparation and review of procedures and procurement documents thatappropriate technical and QA requirements are included.
4.1.3 Nuclear Business Operation In addition to the responsibilities described in subsection 4.1.2, the management positionresponsible for nuclear business operation, who reports to the management positionresponsible for nuclear support services, is responsible for ensuring that the QArequirements established by this program description are either included or referenced (asappropriate) in related program areas sponsored by nuclear business operations.
Theserequirements are identified in the body of this program description.
4.1.4 Nuclear Operations SupportThe management position responsible for nuclear operations support reports to themanagement position responsible for nuclear support services and is responsible forNuclear Security, which includes protection of safeguard information, reporting of safeguard events, and development and maintenance of the Site Physical Security/Contingency Plans.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 26 of 1374.1.5 Nuclear Operations (NO)A. In addition to the responsibilities described in subsection 4.1.2, the management position responsible for NO reports to the Executive Vice President, and CNO and isresponsible for ensuring that the QA requirements established by this programdescription are either included or referenced (as appropriate) in related NO-sponsored program areas identified in the body of this program description.
B. A management position for each operating nuclear site reports to the management position responsible for NO. The nuclear site management position is responsible foroverall plant nuclear safety and the implementation of TVA's quality program.
Day to-day direction and management oversight of activities associated with the safe andreliable operation of a nuclear station is provided.
This position is also responsible for:1. The site compliance with the operating unit license, governmental regulations, and ASME Code requirements.
- 2. Supplementing programs at licensed units ensuring that the QA requirements ofthis program description are appropriately established in licensed unit's siteprocedures.
- 3. The plant technical review process and PORC.4. Fire Protection Program.C. Site Organizations The following site management positions report to the management position for eachnuclear site:1. The management position responsible for plant operations.
- 2. The management position responsible for engineering.
- 3. The management position responsible for safety and licensing.
- 4. The management position responsible for training.
- 5. The management position(s) responsible for project management.
- 6. The management positions responsible for business operations and planning, andresponsible for document control and quality assurance records management arematrix to this position.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 27 of 1374.1.6 Nuclear Engineering A. In addition to the responsibilities described in subsection 4.1.2, the management position responsible for nuclear engineering reports to the management positionresponsible for nuclear support services.
For issues involving nuclear safety or quality,the management position responsible for nuclear engineering has the requisite authority and organizational freedom to report directly to the Executive Vice President and CNO. This management position is responsible for ensuring that the QArequirements established in this program description are either included or referenced (as appropriate
) in related engineering-sponsored program areas identified in the bodyof this program description.
B. Developing and maintaining the ASME III QAM for WBN Unit 2 are the responsibilities of the General Manager WBN U2 Engineering
& Construction C. Developing and maintaining the ASME III QAM for Bellefonte are the responsibilities ofthe manager responsible for BLN Project.D. The engineering organizations are responsible for independent technical reviews.These reviews primarily include:1. System performance monitoring as required by the Maintenance Rule, 10 CFR50.65.2. Technical operability evaluations.
- 3. Review of technical specification changes that affect the design basis.4. Review of Final Safety Analysis Report changes that affect the design basis.5. Self assessments to ensure maintenance of design basis and adequacy oftechnical programs.
E. The management position responsible for nuclear engineering is also responsible forthe computer process systems support.
Computer process systems supportcoordinates the implementation of the software quality assurance program.4.1.7 Quality Assurance (QA)A. The General Manager, NPG QA, reports to the management position responsible fornuclear oversight.
The General Manager, NPG QA has an independent reporting relationship to the Executive Vice President, and CNO on quality issues.The quality organization has direct access to appropriate levels of management andsufficient independence and organizational freedom to be able to effectively assureconformance to quality assurance program requirements.
The General Manager, NPG QA, administers quality assurance responsibilities throughthe Corporate Quality Assurance Manager and Site Quality Assurance Managers.
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Page 28 of 137.%cr0/%4.1.7 Quality Assurance (QA) (continued)
The General Manager, NPG QA, is required to have a bachelor's degree in anengineering or related science, or equivalent related experience.
The GeneralManager, NPG QA, shall have at least 10 years experience in a senior managerial capacity with five years' experience in nuclear quality assurance related activities.
The General Manager, NPG QA, is responsible for overseeing the transition of TVANuclear Construction Units from NC to NPG. The General Manager, NPG QA, workswith the SM BLN QA and SM WBN U2 QA in developing the QA transition planincluding required audits or assessments of the transition of jurisdiction fromconstruction to operation organizations.
This plan will form part of the Operation Readiness Review process acceptance by NPG.The General Manager, NPG QA, has responsibility for the administration of TVA'sNQAP requirements for projects being implemented on operating units by NC or otherorganizations.
B. The Corporate Quality Assurance Manager reports directly to the General Manager,NPG QA, and manages the development and maintenance of NPG quality assurance programs to ensure compliance with regulations, commitments, and policies, including those Quality Assurance programs that govern activities performed by Site QualityAssurance organization personnel.
The Corporate Quality Assurance Manager manages TVA's review and qualification ofsuppliers to ensure final acceptance of all "safety-related material" for all nuclear plantsto comply with applicable specifications and requirements.
The Corporate QualityAssurance Manager manages the training programs for NPG QA personnel, andmanages the quality audit and vendor audit programs.
C. The Site Quality Assurance Managers report directly to the General Manager, NPGQA, and are responsible for the performance of the quality control and qualityassurance functions at the site. The Site Quality Assurance Managers provideoversight of day-to-day plant activities important to safety (i.e., the QA organization routinely attends and participates in daily plant work schedule and status meetings toassure they are kept abreast of day-to-day work assignments throughout the plant and*that there is adequate QA coverage).
The Site Quality Assurance Managers are required to have a bachelor's degree in anengineering or scientific discipline, or equivalent related experience.
They shall haveat least nine years experience in plant design, construction, power plant operation, ormaintenance, including five years experience in QA-related activities.
D. NPG and NC Quality Assurance is responsible for:1. Developing and administering the Nuclear Quality Assurance Plan and the QAorganization procedures required to ensure that TVA activities provide therequired degree of safety and reliability.
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Page 29 of 137%cr%/64.1.7 Quality Assurance (QA) (continued)
- 2. Providing oversight of TVA activities by auditing, inspecting, assessing andobserving the conduct of activities at Corporate and nuclear plant sites to ensurethat they provide the required high degree of safety and reliability and are carriedout consistent with applicable laws, regulations, regulatory commitments,
- licenses, and other requirements.
The depth and scope of oversight is dependent on the item's or subject's importance to safety and performance history.3. Stopping work or further processing,
- delivery, or installation or taking othercomparable actions when warranted to control and/or prevent the use ofnonconforming materials or continuance of activities adverse to quality atCorporate and nuclear plant sites.4. Establishing upper-tier QA requirements for QA training and for evaluating theimplementation and effectiveness of that training.
- 5. Developing and implementing the vendor audit and services QA Program whichincludes
- auditing, source inspection and surveillance of supplier activities.
Developing and maintaining the Acceptable Suppliers List (ASL) of approvedvendors.6. Conducting overview of procured engineering services (offsite) including thereview of procurement documents for QA requirements utilizing graded approachcriteria, in-depth technical and/or performance based auditing, performing pre-award surveys, and reviewing contractor QA programs.
- 7. Planning, conducting, and reporting the results of Corporate and site audits andfollowing-up identified adverse conditions to ensure appropriate corrective actionhas been taken.8. Reviewing and/or auditing QA programs of TVA non-nuclear organizations whichsupport nuclear quality-related activities.
- 9. Developing, reviewing, and maintaining the Nuclear Quality Assurance Plan.10. Verifying through assessing or other means that QA requirements are contained in applicable Site QA program procedures, and quality-related activities complywith QA program requirements.
- 11. Approving the site quality control inspection program.12. Moved to section 4.1.18.13. Reviewing the ASME III QAM -WBN U2 and BLN 1 & 2 (when active).14. Managing development, maintenance, and improvements of site/corporate qualitymethodologies to evaluate quality programs and technical programs based onobservations and trending.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 30 of 137%cr%4.1.7 Quality Assurance (QA) (continued)
- 15. Analyzing technical and quality programs from many sources to developrecommendations for senior management action. This includes oversight andindependent analysis of trending results.
Results are provided to seniormanagement.
Advising senior management relative to alternative solutions totechnical and quality problems to improve the effectiveness and efficiency ofimplementation techniques.
- 16. Advising and interfacing with senior site and corporate management on matterspertaining to the assessment program to aid in the identification and resolution ofitems that could result in enforcement
- actions, reduction in power generation, orendangering the health and safety of the general public.4.1.8 NPG Licensing The management position responsible for nuclear licensing reports to the Executive VicePresident, and CNO and is responsible to:A. Maintain an interface between TVA and NRC for licensing activities.
B. Direct and manage Nuclear Safety Review Board (NSRB) activities.
C. Nuclear Safety Review Board1. The NSRB is an offsite committee, which provides senior level oversight of TVA'snuclear program with respect to nuclear safety. The NSRB reviews include theactivities of the line organizations, as well as other review, audit, and verification organizations.
The NSRB also provides senior level management with anassessment of facility operations and recommendations to improve nuclear safetyand plant reliability.
- 2. The Chairperson, NSRB, has an independent reporting relationship to theExecutive Vice President, and CNO, and other NPG management on nuclearsafety matters.
The Chairperson, NSRB, is responsible for advising the Executive Vice President, and CNO on the adequacy and implementation of TVA's nuclearsafety policies and programs and for evaluating these policies and programs forcompliance with regulatory requirements governing nuclear safety.3. The Chairperson NSRB, is responsible for complying with the requirements ofANSI N18.7-1976/ANS 3.2. The management position responsible for nuclearlicensing is responsible for ensuring that the QA requirements established by theQA program related to NSRB functions are either included or referenced (asappropriate) in related procedures or instructions.
- 4. The NSRB shall function to provide for independent review as specified in Section4.1.8C.5.b and oversight of operational phase audits and technical reviews asspecified in Sections 12.2E and 4.1.6D.
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- 5. The Chairperson,
- members, and alternate members of the NSRB shall beappointed in writing by the Executive Vice President, and CNO; and shall have anacademic degree in engineering or a physical science field, or the equivalent; andshall have a minimum of five years technical experience in one or more of theareas specified in ANSI N18.7-1976/ANS 3.2. The NSRB shall be composed ofat least five members, including the Chairperson.
Members of the NSRB may befrom NPG, or other TVA organizations or external to TVA. No more than twoalternates shall participate as voting members in NSRB activities at any one time.a. Functions The NSRB shall, as a minimum, incorporate the following functions:
(1) Advise the Executive Vice President, and CNO on all matters related tonuclear safety;(2) Recommend to the Executive Vice President, and CNO any corrective action to improve nuclear safety and plant operations; and(3) Notify the Executive Vice President and CNO of any safety significant disagreement between the NSRB and the organization or function*being reviewed.
- b. NSRB Review Responsibilities The NSRB shall be responsible for the review of:(1) The 10 CFR 50.59 Program.
10 CFR 50.59 evaluations will bescreened.
Review of representative 10 CFR 50.59 evaluations will beperformed, selected based on safety significance, for 1) changes toprocedures, equipment or systems and 2) tests or experiments completed under the provision of 10 CFR 50.59, to verify that suchactions did not require a license amendment; (2) Proposed changes to procedures, equipment, or systems that require alicense amendment as defined in 10 CFR 50.59;(3) Proposed tests or experiments that require a license amendment asdefined in 10 CFR 50.59;(4) Proposed changes to Technical Specifications or the Operating Licenserelating to nuclear safety prior to implementation, except in those caseswhere the change is identical to a previously reviewed proposedchange;(5) Violations of codes, regulations, orders, license requirements, andinternal procedures or instructions having nuclear safety significance; (6) Reportable events (10 CFR 50.73);(7) Plant staff performance; TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 32 of 137%cr%1o4.1.8 NPG Licensing (continued)
(8) Recognized indications of unanticipated deficiencies in any aspect ofdesign or operation of structures, system, or components that couldaffect nuclear safety;(9) Significant accidental, unplanned, or uncontrolled radioactive
- releases, including corrective action to prevent recurrence; (10) Significant operating abnormalities or deviations from normal andexpected performance of equipment that affect nuclear safety; and(11) Implementation of the corrective action program.(12) The 10 CFR 72.48 Program.
10 CFR 72.48 evaluations will bescreened.
Review of representative 10 CFR 72.48 evaluations will beperformed, selected based on safety significance, for 1) changes toprocedures,
- facility, or spent fuel storage cask design, and 2) tests orexperiments completed under the provision of 10 CFR 72.48, to verifythat such actions did not require a license amendment; (13) Proposed changes to procedures,
- facility, or spent fuel storage caskdesign that require a license amendment as defined in 10 CFR 72.48.c. Minutes of each NSRB meeting and reports of other reviews shall beforwarded to the Executive Vice President and CNO within 30 days following completion of the meeting or review.4.1.9 Procurement The management position responsible for procurement reports through the Executive VicePresident and Chief Administrative Officer to the President and Chief Executive Officer.
Inaddition to the responsibilities described in subsection 4.1.2, the management positionresponsible for procurement, is responsible for ensuring that the QA requirements established by this program description are either included or referenced (as appropriate) inrelated Procurement sponsored program areas identified in the body of this Program.4.1.10 NPG Nuclear Oversight The management position responsible for nuclear oversight, reports to the Executive VicePresident, and CNO and manages the NPG Quality Assurance organization.
In addition, the management position responsible for nuclear oversight, maintains a positionqualification documentation and validation program through human resources.
Themanagement position responsible for nuclear oversight, also manages the NuclearOperating Experience Review Program.4.1.11 WBN U2 Construction Completion ProjectSee Appendix F.4.1.12 Bellefonte Units 1 & 2See Appendix G.
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Page 33 of 1374.1.13 Technology Innovation The management position responsible for technology innovation reports through the SeniorVice President Policy & Oversight to the President and Chief Executive Officer and isresponsible to apply the appropriate NQAP requirements to the development of new nucleargeneration projects.
4.1.14 NC Quality Assurance The SM WBN U2 QA and SM WBN U2 QA report directly to the Senior Vice President, NCand administer quality assurance responsibilities through their staff. See Appendix F and G.4.1.15 Deleted4.1.16 Deleted4.1.17 Deleted4.1.18 Engineering, Environmental
& Support ServicesThe management position responsible for engineering, environmental
& support servicesreports to the Executive Vice President and Chief Generation Officer.
This position isresponsible for Inspection Services Organization (ISO). ISO implements the quality controlinspection program and assists the responsible organization at the sites in the performance of ASME, Section Xl, NDE. This organization has a quality responsibility to themanagement position responsible for nuclear engineering.
5.0 NUCLEAR QA PROGRAMThe General Manager, NPG QA, develops this program description to establish therequirements of the NQAP that encompass the general management and general regulatory requirements in sections 3.1 and 3.2 of this program description.
The program requirements apply to design, construction,
- testing, operation, maintenance, repair, replacement, andmodification of TVA nuclear facilities.
NPG, NC, and TVA non-nuclear organizations performing activities within the scope of theNQAP shall implement the program through written procedures and instructions.
TVA non-nuclear organizations providing services within the scope of the NQAP through anIntergroup Agreement shall develop QA programs that comply with nuclear requirements.
These QA programs shall be assessed and/or audited by QA.5.1 Program ScopeA. The requirements of the NQAP shall apply to activities associated with structures,
- systems, and components which are safety-related or controlled by 10 CFR 72, andshall take into account special equipment, environmental conditions, skills, orprocesses.
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Page 34 of 137%cr%5.1 Program Scope (continued)
B. The requirements shall also apply to TVA identified quality-related programs andfeatures which are important to the continued reliable operation of TVA's nuclearfacilities.
Organizations responsible for these programs and features shall determine the extent to which these requirements apply and develop and document applicable NQAP elements and the levels of verification required.
- 1. Technical requirements related to engineering design are specified by themanager responsible for nuclear engineering.
QA shall review or assess theseprograms and features.
The program procedures shall be included in NPSdocuments.
- 2. Programs and features for which the NQAP applies are listed below. Appendix C,"Guidelines for Determination of WVA-Identified Quality-Related Classifications,"
was used to develop the list.a. Radiological Control.b. Emergency Preparedness.
- c. Nuclear Plant Security.
- d. Radioactive Material Shipment.
- e. Special Nuclear Material Management.
- f. Fire Protection.
- g. Radwaste Management
- Systems, Structures, and Components.
- h. Seismic Category I (L) Items.i. Non safety-related Anticipated Transient Without Scram (ATWS) Equipment.
- j. Chemistry.
- k. Safety Parameter Display SystemI. 10 CFR 72 -NUREG/CR
-6407 Important To Safety Category CComponents When using services outside NPG, responsible organizations for the aboveprograms and features shall specify the extent of applicable QArequirements.
C. To facilitate proper application and implementation of the NQAP, the managerresponsible for a nuclear site (delegated to the manager responsible for engineering atthe nuclear site) shall develop a Q-List for each nuclear unit. The Q-List shalldocument and classify structures,
- systems, and components consistent with theirimportance to safety.D. Selected requirements of the NQAP shall apply to safety-related activities associated with the license application for new nuclear generation.
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Page 35 of 137%cr%5.1 Program Scope (continued) 5.2 Graded ApproachThe NQAP shall provide for the graded application and verification of QA requirements toquality-related items and activities.
A. The following criteria are to be considered when applying NQAP requirements:
- 1. The impact on safety of an item malfunction or failure.2. The specification, design, fabrication complexity, or uniqueness of the item, andthe environment under which the item must function.
- 3. The need for special controls and assessments of equipment, processes, andoperational activities.
- 4. The degree to which functional compliance can be demonstrated by an inspection or test.5. The quality history of the item or activity and its degree of standardization.
- 6. The intended life span during which the item must perform a quality-related function.
- 7. Requirements of applicable codes and standards.
B. The following factors are to be considered in the degree of QA verification required toensure implementation of NQAP requirements:
- 1. New activities not previously performed or implemented.
- 2. Trend or previous histories of quality problems.
- 3. Activities critical to safety or having the most potential to impact safety.4. Revisions of the procedures which have recently been implemented.
- 5. Activities that have not been assessed in the recent past or are performed infrequently.
- 6. Activities that are performed by new personnel, contractors, or technicians.
- 7. The requirements of applicable codes and standards that are mandated for theitem or activity.
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Page 36 of 1375.3 Program Elements kThis section identifies or references the NQAP elements delineated through the ASME IIIQAM for WBN U2 and BLN 1 & 2 (when active) during construction completion andimplemented through NPG and/or NC procedures and instructions.
The documents identified in Appendix B contain QA requirements applicable to the NQAP elements.
TheNQAP shall encompass the following elements:
A. Establishment and use of a comprehensive list of safety-related structures, systems,and components for each TVA nuclear plant unit and ISFSI identifying the critical plantfeatures that will receive the highest level of QA program application.
B. Use of a graded approach in the application and verification of NQAP requirements.
Quality-related items and activities shall be subjected to a level of QA controls andverification commensurate with their importance to nuclear safety.C. Assignment of responsibilities to appropriate organizations and positions forimplementation of the NQAP.D. Preparation of NPS documents which provide specific guidance in planning, performing, assessing, and controlling activities affecting quality to ensure that quality-related activities are performed in accordance with applicable national codes andstandards, regulatory requirements, licensing commitments, and management requirements.
E. Verification of the adequacy of quality-related structures,
- systems, and components byappropriate inspections, tests, and assessments; and of quality-affecting activities byperiodic
- reviews, audits, and assessments to ensure the adequacy and effectiveness of the NQAP and its implementation.
F. Provisions for adequate indoctrination and training of personnel, and qualification orcertification when required, prior to their performing activities which affect quality.G. Provisions for special controls, processes, test equipment, tools, and skills necessary to attain the required quality.H. Measures to control cleanness of facilities,
- material, and equipment; fire prevention; plant access; and equipment protection.
Controls shall be applied to the extentnecessary to ensure that only proper materials, equipment, processes, and procedures are utilized, and that the quality of items is not degraded through improper practices and techniques.
I. Prompt identification, documentation, evaluation, and correction of adverse conditions.
J. Generation and retention of adequate records to demonstrate compliance with NQAPrequirements, applicable national codes and standards, and regulatory requirements.
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Page 37 of 1375.4 Program Documents The quality assurance program shall be documented by written procedures and instructions.
The quality assurance program documents, required by this program description and theASME III QAM are contained in the NPS. Requirements for preparation, review,concurrence, and approval of NQAP documents are contained in NPS documents.
A. ASME III QAM for WBN 2 and BLN 1 & 2 (when active) during Construction Completion Associated with this program description is the ASME III QAM. The ASME III QAM is aself-contained manual that prescribes specific QA requirements for the control of itemsand activities subject to the ASME Code Section III, Division
- 1. The ASME III QAMsatisfies the ASME Section III Code requirement to fully describe both the qualityassurance program and the specific responsibilities applied to TVA's activities as an"N" certificate holder. The ASME III QAM is filed with the Authorized Inspection Agency in accordance with the requirements of ASME Code, Section II1. Changes tothe ASME Ill QAM shall be coordinated with the Authorized Inspection Agency forreview and acceptance prior to implementation.
B. Nuclear Quality Assurance PlanThis Nuclear Quality Assurance Plan (Quality Assurance Program Description) contains regulatory and management QA requirements and responsibilities that otherNPS documents must address.
This program description and implementing documents meet the requirements of 10 CFR 50, Appendix A; 10 CFR 50, Appendix B;10 CFR 72, Subpart G; applicable ASME Section Xl and ASME OM Coderequirements for a nuclear QA program.
To ensure the nuclear program is fullyintegrated, additional implementing level details contained in requirements documents shall be included in procedures and instructions sponsored by implementing organizations.
C. Implementing Procedures The NQAP establishes the quality assurance program requirements.
The NQAPplaces responsibilities on identified sponsors to develop specific elements of the qualityassurance programs addressing specific requirements of source requirement documents.
Sponsors of NPS documents are required to identify the document as"quality related" if it contains quality assurance program requirements.
Corporate NPSdocuments identified as quality related receive review and concurrence by QApersonnel or others knowledgeable of QA requirements.
5.5 Program ChangesChanges to the NQAP shall be submitted to the NRC in compliance with 10 CFR 50.54 and10 CFR 50.55. Changes to the NQAP will be distributed to senior managers anddepartment heads for incorporation into their quality procedures.
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Page 38 of 1376.0 CONTROL OF DOCUMENTS AND RECORDS6.1 Procedures and Instructions 6.1.1 GeneralA. The QA program requires that quality-related activities shall be prescribed bydocumented procedures and instructions appropriate to the circumstances.
Activities shall be accomplished in accordance with these procedures and instructions.
B. The requirements of this section are applicable to the preparation, review, andapproval of procedures and instructions (for example, this program description, NPSdocuments, ASME III QAM, etc.). Requirements for the preparation, review, andapproval of drawings are in Section 7.0 of this program description.
Requirements forplant reviews are in Section 9.9 of this program description.
6.1.2 Program ElementsA. ContentProcedures and instructions shall:1. Describe quality-related activities in adequate detail for the intended user, andinclude quantitative or qualitative acceptance criteria sufficient for determining thatthe activities have been satisfactorily accomplished.
- 2. Describe significant interfaces between personnel and organizations that affect, orare affected by, quality-related activities.
- 3. Include or reference appropriate technical, QA, regulatory, and licensing requirements, including those in design output documents.
B. ReviewProcedures and instructions shall:1. Receive a documented review for adequacy by a qualified reviewer other than thepreparer.
- 2. Receive the review and concurrence of affected organizations outside the issuingorganization prior to approval, unless concurrence has been established in ahigher-level document.
- 3. Receive a review to ensure proper incorporation of QA requirements.
Thesereviews are by QA personnel or others knowledgeable of QA requirements.
C. ApprovalProcedures and instructions shall be approved for release by the sponsoring organization prior to use.
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Page 39 of 137%cr%/66.1.2 Program Elements (continued)
D. Procedural ControlProcedures shall be issued for the identification and control of quality-related procedures, instructions, and their changes.
The organizations responsible forpreparing, reviewing, approving, and issuing procedures, instructions, and changesshall be specified.
E. Review of Operational Phase Procedures Operational phase site procedures and instructions shall be reviewed to ensure thatspecific known changes in source documents or changes identified through usage areincluded as necessary and in a timely manner. The following mechanisms ensure thatappropriate procedure reviews are conducted:
- 1. Plant modification program2. Resolution of issues identified by QA, NRC, Licensing, and corrective actionprogram3. Technical specification and FSAR update reviews (including the contractor's drycask storage system Certificate of Compliance licensing basis documents).
- 4. Source document program and process for administering Site procedures
- 5. Testing programF. Change Control1. Changes to procedures and instructions shall be reviewed and approved prior totheir implementation by the same organizations that performed the original reviewand approval, or by another organization assigned by appropriate management ordesignated in a controlling procedure or instruction.
- 2. Changes shall be reviewed by organizations having access to pertinent background information upon which to base their approval and having adequateunderstanding of the requirements and intent of the original document.
- 3. Minor changes, such as inconsequential editorial corrections that do not affect theoutcome,
- results, functions, processes, responsibilities, and requirements of theperformance of procedures or instructions, do not require the same review as theoriginal, but shall be reviewed and approved as defined in controlling documents.
6.1.3 Responsibilities
A. The management position responsible for nuclear support services is responsible forthe development of programs to control procedures and instructions.
The programelements in Section 6.1.2 and the related source requirements contained within thedocuments listed in Section 6.1.4 shall be addressed.
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Page 40 of 137%cr%6.1.3 Responsibilities (continued)
B. The General Manager, NPG QA, shall:1. Perform reviews or assessments of NPG NPS documents that implement theNQAP and,2. Verify through assessing or other means that reviews are conducted by personnel knowledgeable in QA requirements.
C. The SM WBN U2 QA and SM BLN QA perform reviews, assessments, and/or audits ofNPS documents that implement the requirements of the NQAP for units withconstruction permits.D. TVA organizations that work directly under the TVA NQAP are responsible for:1. Implementing the requirements of the QA program through written procedures and instructions.
- 2. Ensuring reviews of NPS documents that implement the NQAP are conducted bypersonnel knowledgeable of QA requirements.
6.1.4 Source Requirement Documents The applicable source requirement documents and their exceptions are noted in Appendix Bof this program description.
These establish mandatory
- controls, which must be addressed in the development of programs for procedures and instructions.
6.2 Document Control6.2.1 GeneralA. The QA program requires that for activities affecting
- quality, measures shall beestablished to ensure that documents prescribing the activity, including
- changes, areapproved for release by authorized personnel, reviewed for adequacy, and madeavailable to personnel performing the prescribed activity prior to commencing work.B. The requirements of this section are applicable to the distribution and control ofdocuments after they have been approved for use.6.2.2 Program ElementsA. Identification and Distribution
- 1. The types of documents to be controlled shall be identified.
Appendix H liststypes of controlled documents and manuals.2. Master document indexes shall be established and maintained for identifying allcontrolled documents and their revision status.3. The distribution of documents shall be controlled and maintained to assist inpreventing the use of obsolete or superseded documents.
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Page 41 of 137%cr0/%6.2.2 Program Elements (continued)
B. Contiolled Use1. Quality related activities shall be performed in accordance with approved andcontrolled instructions, procedures, and drawings.
- 2. Organizations shall ensure through procedures or instructions that thoseparticipating in an activity are made aware of and use proper and currentdocuments.
C. Control of Equipment Technical Information Administrative controls shall provide for control and distribution of equipment technical information (ETI) supplied to TVA.6.2.3 Responsibilities The management position responsible for nuclear support services is responsible for thedevelopment of programs to control documents.
The program elements in Section 6.2.2 ofthis section and the related source requirements contained within the documents listed inSection 6.2.4 shall be addressed.
6.2.4 Source Requirement Documents The applicable source requirement documents and their exceptions are noted in Appendix Bof this program description.
These establish mandatory
- controls, which must be addressed in the development of programs and procedures for the control of documents.
6.3 QA Records6.3.1 GeneralThe QA program established for the generation, collection,
- storage, maintenance, andretrieval of QA records requires that records be correctly identified,
- reviewed, stamped, orotherwise authenticated,
- retained, and retrievable without undue delay.6.3.2 Program ElementsA. Sufficient records and documentation shall be prepared and maintained to provideevidence of the quality of items or activities affecting quality.
QA records shall belegible,
- complete, and identifiable to the item involved.
B. Design specifications, procurement documents, procedures, and instructions shallspecify the QA records to be generated,
- supplied, and maintained by or for TVA.Retention times shall be designated.
Indexes shall be established to designate thosetypes of QA records to be maintained.
C. Measures shall be established to maintain control of in process QA documents prior totheir completion.
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Page 42 of 137%cr%/66.3.2 Program Elements (continued)
D. Requirements and responsibilities shall be established consistent with applicable codes, standards, and procurement documents for record transmittal, receipt,retention, updating and supplementing of information, and maintenance of the recordssubsequent to the completion of work and record retrieval.
E. Permanent and temporary QA record storage facilities shall be established to store QArecords to prevent infestation, deterioration, or destruction.
F. Measures shall be taken to preclude the entry of unauthorized personnel into QArecord storage areas to ensure the integrity of the stored QA records.G. Records shall be maintained in a manner that will allow access by the Authorized Inspection Agency representative.
6.3.3 Responsibilities
The management position responsible for nuclear support services is responsible for thedevelopment of a QA records program.
The program elements in Section 6.3.2 and therelated source requirements contained within the documents listed in Section 6.3.4 shall beaddressed.
6.3.4 Source Requirement Documents The applicable source requirement documents and their exceptions are noted in Appendix Bof this program description.
These establish mandatory
- controls, which must be addressed in the development of programs and procedures for the control of records.7.0 DESIGN CONTROL7.1 GeneralThe QA program requires that measures shall be established and documented to ensurethat applicable specified design requirements, such as design bases, regulatory requirements, and codes and standards, are correctly translated into specifications,
- drawings, procedures, or instructions.
7.2 Program Elements7.2.1 BasicA. Specific items, services, and activities subject to design control shall be identified (e.g.,reactor physics analysis,
.stress and thermal analyses, computer code development and use, computer
- software, compatibility of materials,
- drawings, specifications, engineering procedures, and instructions).
B. Design activities shall be documented in sufficient detail to permit verifications andaudits.
C. Measures shall be established and implemented to ensure that design outputdocuments appropriately identify engineering requirements that apply to plant activities, and to ensure that plant personnel are made aware of engineering requirements thatcould affect the performance and scope of their responsibilities before thoseengineering requirements are implemented.
D. Measures shall be established and implemented to provide test requirements in designoutput documents for the following tests as appropriate:
- 1. Design qualification.
- 2. Product acceptance (proof).3. Preoperational.
- 4. Construction.
- 5. Start-up.
- 6. Surveillance.
- 7. Functional.
- 8. Post-maintenance.
- 9. Post-modification.
E. Measures shall be established and implemented to provide documented input to otherorganizations which may request input for their special tests.F. Acceptance criteria shall be defined for verifications, inspections, and tests inappropriate design output documents.
G. Design output documents shall be utilized, as appropriate, for procurement activities.
H. The Q-List identified in Section 5.1C of this program description shall be developed using appropriate regulations, regulatory guides, and national codes and standards (such as 10 CFR 50, Appendix R; Regulatory Guides 1.26 and 1.29; and ASME Boilerand Pressure Vessel Code).I. Measures shall be established to ensure the environmental qualification (EQ) of safety-related electrical and mechanical equipment is included, as appropriate, within thedesign basis.J. Errors and deficiencies in approved design documents, including design methods(such as described in calculations) that could affect quality-related activities aredocumented and corrected.
(Reference Section 10.0 of this program description)
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Page 44 of 1377.2.2 Design InputsA. Design assumptions, design inputs, and deviations from approved design inputs shallbe identified,
- reviewed, approved, and documented prior to declaring the structure, system, or component affected by the design operable.
B. Design inputs shall be correctly translated into design outputs.C. Provisions shall be made to relate the final design to the source of design input.7.2.3 Design AnalysisA. The performance of design analysis shall be planned and controlled.
B. The suitability of application of materials, parts, equipment, and processes essential tothe function of a structure, system, or component shall be reviewed to ensure thatfunctional requirements are met.7.2.4 Interface ControlInternal and external design responsibilities and interface controls shall be established anddefined to facilitate the preparation, review, approval,
- release, distribution, and revision ofdocuments involving design interfaces.
This process ensures that quality-related structures,
- systems, and components are compatible geometrically, functionally, and with plantprocesses and environments.
7.2.5 Design OutputA. Engineering requirements on plant activities (e.g., operation, maintenance, installation, modification, surveillance) shall be identified in design output documents.
B. Measures shall be established and documented to control the preparation, review,approval,
- issuance, and revision of design output documents.
These measures shallinclude criteria and responsibilities to ensure that adequate technical and qualityrequirements are incorporated prior to issuance.
C. Drawings and specifications shall include, as appropriate, quantitative and qualitative acceptance criteria.
These acceptance criteria shall be sufficient for determining thatquality-related activities have been satisfactorily accomplished.
D. Drawings and specifications shall receive documented reviews and approvals (andconcurrences as required) by responsible organizations prior to use.E. After approval, drawings shall be controlled in accordance with the requirements ofSections 6.2 and 6.3 of this program description.
F. Revisions shall be reviewed and approved by the same organizations that performed the original review unless another appropriate organization that has access to pertinent background information is designated in the appropriate NPS document orprocurement documents.
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Page 45 of 1377.2.6 Design Verification A. The translation of design inputs into design documents shall be verified and theverification documented.
B. Criteria for determining design verification methods shall be established, identified, implemented, and procedurally controlled.
The responsibilities of the verifier, the areasand features to be verified, and documentation requirements shall be included.
C. Design verification shall be performed by individuals or groups other than those whoperformed the original design.D. For nuclear units under a construction permit, design verification shall be completeprior to initial fuel loading.E. For operating nuclear units, design verification shall be complete prior to reliance uponthe component, system, or structure to perform its function.
Design outputs which arereleased prior to verification being completed shall be identified and tracked to ensurethe component, system, or structure is not relied upon to perform its function until theverification is complete.
F. When a verification test is used to verify the adequacy of a specific design feature inlieu of other verifying processes, the test shall include suitable qualification testing of aprototype unit under conditions that simulate, to the extent practical, the most adversedesign condition.
The prototype, component, and feature tests are performed as earlyas possible and prior to plant installation of the equipment or at least prior to the pointwhere installation of the item would be relied upon to perform its function.
In thosecases where the most adverse design conditions cannot be achieved in tests, suitableanalysis shall be performed to extrapolate test results to design conditions.
7.2.7 Design ChangesA. Design changes, including field changes and modifications, shall be identified.
Theyare subject to design'control measures commensurate with or better than those appliedto the original design.B. Design changes shall be reviewed and approved by the organization responsible forthe original design unless another appropriate organization that has access to pertinent background information is designated in the appropriate NPS document orprocurement documents.
C. Design changes that affect the supply of a quality-related item or service controlled byprocurement documents shall not be returned to operation until: (1) the change isreflected in the appropriate change document such as a contract or purchase orderchange notice, (2) the change document has received the requisite reviews andapprovals, and (3) the change document has been submitted to and accepted by therespective supplier.
D. Proposed modifications to quality-related structures,
- systems, and components shallbe reviewed,
- approved, and controlled in accordance with applicable requirements ofthe appropriate license and Section 9.9 of this Program.Design modifications shall beat least equivalent to the quality specified in the latest approved design basis.
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Page 46 of 137%cr%/67.2.7 Design Changes (continued)
E. Measures to control plant configuration and ensure that the actual plant configuration isaccurately depicted on drawings and other appropriate design output documents andreconciled with the applicable design basis shall be established, documented, andimplemented.
F. The design integrity shall be maintained during plant maintenance and modification processes, including temporary
- changes, and throughout the life of the plant.7.3 Responsibilities A. The management position responsible for nuclear engineering is responsible for thedevelopment of a design control program.
The program elements in Section 7.2 andthe related source requirements contained within the documents listed in Section 7.4shall be addressed.
This management position is also responsible for implementation of programs for maintaining design control at licensed units and corporate.
B. The General Manager WBN U2 Engineering
& Construction is responsible forimplementation of programs for maintaining design control at WBN Unit 2.C. The management position responsible for BLN Project is responsible forimplementation of programs for maintaining design control at BLN 1 & 2.7.4 Source Requirement Documents The applicable source requirement documents and their exceptions are noted in Appendix Bof this program description.
These establish mandatory controls which must be addressed in the development of programs and procedures for control of the design process.8.0 PROCUREMENT AND MATERIAL CONTROL8.1 Procurement Document Control8.1.1 GeneralThe QA program requires that measures shall be established to ensure that control isapplied to documents used to obtain materials, parts, components, spare and replacement parts, and services required to construct, test, modify, maintain, repair, or operate nuclearfacilities, commensurate with their importance to safety.8.1.2 Program ElementsA. Procurement Document PlanningThe procurement
- process, as documented in NPG procedures, shall identify eachactivity in the process, who accomplishes the activity, how, and when the activity isperformed.
The process shall be planned to integrate the following activities as aminimum:1. Document preparation, review, and change control.2. Selection of procurement sources.
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Page 47 of 1373. Bid evaluations and award.4. Purchaser control of supplier performance.
- 5. Verification activities of purchaser.
- 6. Control of nonconformances.
- 7. Corrective actions.8. Acceptance of item or service.9. QA records.10. Audit of procurement program.B. Procurement Document ContentIn the preparation of procurement documents, responsible organizations shall asapplicable:
- 1. Specify or reference applicable design basis technical requirements as defined byEngineering, such as regulatory requirements (including 10 CFR 50.49 and 10CFR Part 21 as applicable);
QA requirements; material and component identification requirements; drawings; specifications; inspection and testrequirements (including acceptance criteria);
calibration,
- handling, storage,packaging, and shipping requirements; and special process instructions.
Alltechnical requirements shall be prepared,
- reviewed, and released under therequirements established by Section 7.0 of this program description.
- 2. For commercial-grade replacement items intended for safety-related use,Engineering shall determine critical characteristics and specify inspection andacceptance criteria to ensure that items dedicated after receipt are acceptable foruse as replacement parts.3. As appropriate, require that suppliers have a documented QA program that isapproved by TVA and appropriate interfaces established.
- 4. As appropriate, require that NQAP requirements be imposed on sub-vendors andsubcontractors in sub-tier procurement documents.
- 5. Identify the documentation to be prepared and/or maintained by the supplier andsubmitted to WVA for review and approval.
- 6. Identify records to be retained, maintained, and controlled by the vendor orcontractor, and those documents and records that the vendors or contractors shalltransfer to TVA prior to installation or use of an item or service as applicable.
- 7. Include provisions for right of access to the facilities and records of vendors,contractors, and sub-tier vendors and contractors for source surveillances andaudits.
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Page 48 of 137%cr%8.1.2 Program Elements (continued)
- 8. Include requirements as defined by Engineering to ensure that suitable spare andreplacement materials and components are purchased to the applicable requirements of the NQAP and: (1) specifications and codes equivalent to thosespecified for the original equipment, or those specifications and codes specified by approved design output; or (2) in cases where the original item or part is foundto be commercially "off the shelf" or without specifically identified qualityassurance requirements, spare and replacement parts may be similarly procuredbut, at the very least, equivalent performance is ensured; or (3) in those where theQA requirements of the original item cannot be determined, a documented evaluation establishing the requirements and controls is conducted.
- 9. Include requirements for reporting nonconformances and for approving corrective actions and nonconformance dispositions.
C. Procurement Document Review and ApprovalThe review and approval of procurement documents shall include a documented review to ensure that technical, quality assurance, and administrative requirements areincluded in procurement documents prior to their use.D. Procurement Document Change ControlChanges in procurement documents shall be subject to the same degree of control aswas utilized in the original documents.
Changes such as typographical corrections,
- quantity, or monetary changes do not require a review.8.1.3 Responsibilities A. The management position responsible for procurement is responsible for thedevelopment of a procurement document control program.
The program elements inSection 8.1.2 and the related source requirements contained within the documents listed in Section 8.1.4 shall be addressed.
B. The management position responsible for procurement is responsible forimplementation of programs for maintaining procurement document control.8.1.4 Source Requirement Documents The applicable source requirement documents and their exceptions are noted in Appendix Bof this program description.
These establish mandatory
- controls, which must be addressed in the development of programs and procedures for control of procurement documents.
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Page 49 of 1378.2 Control of Purchased
- Material, Equipment, and Services8.2.1 GeneralThe QA program requires that measures shall be established to assure that purchased
- material, equipment, and services, whether purchased directly or through contractors, conform to the procurement documents.
8.2.2 Program ElementsA. Evaluation and Selection of Suppliers
- 1. Evaluations of prospective suppliers shall be conducted and documented todemonstrate that their qualifications and capabilities are adequate to meetprocurement document requirements.
Supplier evaluations shall include supplierperformance assessments as appropriate.
- 2. Evaluations and selection of procurement sources shall include, as appropriate, the use of historical quality performance data, source surveys or audits, or sourcequalification programs.
- 3. A list of approved suppliers shall be maintained.
B. Bid Evaluation and AwardA documented system for reviewing and evaluating bids and correcting biddiscrepancies shall be established to ensure suppliers' conformance to procurement document requirements.
C. Effectiveness Assessments
- 1. The effectiveness of the suppliers' control of quality shall be assessed throughperiodic audits and/or surveillances utilizing a graded approach consistent withthe importance, complexity, and quantity of the items and services procured.
- 2. The assessments shall consist of, as appropriate, checks, reviews, verifications, examinations, and witnessing of activities related to the fabrication, testing,inspection, and shipment of material, including periodic assessments of suppliers' certificates of conformance.
- 3. Records, qualifications, and process specifications or procedures shall bedocumented and verified to be in accordance with contract requirements.
D. Acceptance of Procured ServicesProcured services shall be accepted, as appropriate, by:1. Technical verification of product/data produced.
- 2. Assessments and/or audit of the activity.
- 3. Review of objective evidence such as certifications.
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E. Acceptance of Procured ItemsProcured items shall be accepted by receipt inspection and any combination of thefollowing, as appropriate, based on the item's degree of complexity, uniqueness, andsafety classification.
- 1. Source verification.
- 2. Preinstallation testing inspection.
- 3. Supplier certificate of conformance.
- 4. Post installation testing.F. Receipt Inspection
- 1. Receipt inspection shall be performed utilizing graded approach criteria to ensurethat material and equipment is properly identified to the purchase document andreceiving documentation and meets requirements of procurement documents.
When graded approach criteria are applied to receipt inspection activities, lineverification will be required.
The applicable QA organization shall independently verify line organization performance to ensure adequacy of line verifications.
- 2. Deficiencies, such as damage, shall be documented and resolution of thedeficiency shall be in accordance with approved documents.
- 3. Records, such as inspection and test records, shall be available at the Site priorto installation or use of the material or equipment.
G. Maintaining Disposition of Received Items1. A quality control method for identifying the status of items (e.g., an inventory system, tagging,
- labeling, and color code) shall be employed that indicates whether items received are acceptable or unacceptable for installation.
- 2. Items may be installed prior to final disposition of a deficiency.
Nonconforming items shall be controlled in accordance with Section 10.2.1.8.2.3 Responsibilities A. The management position responsible for procurement is responsible for thedevelopment of programs to control purchased
- material, equipment, and services.
Theprogram elements in Section 8.2.2 and the related source requirements contained within the documents listed in Section 8.2.4 shall be addressed.
B. The management position responsible for procurement is responsible forimplementation of programs for maintaining control of purchased
- material, equipment, and services.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 51 of 137C. The General Manager, NPG QA, is responsible for evaluation and selection ofsuppliers, acceptance of procured items (as described in Section 9.1.2C),
periodicassessments of suppliers utilizing graded approach
- criteria, and maintenance of anapproved suppliers' list.8.2.4 Source Requirement Documents The applicable source requirement documents and their exceptions are noted in Appendix Bof this program description.
These establish mandatory
- controls, which must be addressed in the development of programs and procedures for the control of purchased
- material, equipment, and services.
8.3 Identification and Control of Materials, Parts, and Components 8.3.1 GeneralThe QA program shall ensure that only correct and accepted items are installed and used,and that an item can be related to applicable
- drawings, specifications, or technical documents at any stage of construction, maintenance, or modification as required.
8.3.2 Program ElementsA. Identification Identification of quality-related items shall be verified and documented prior to releasefor fabrication,
- assembly, shipping, and installation.
Identification requirements shallbe specified in applicable design and procurement documents.
Determination ofidentification requirements shall be based on the item importance to safety, quality, orpotential hazards.B. Traceability Traceability of materials, parts, or components to specific manufacturing, installation, maintenance, and/or test records shall be provided as required by codes, standards, orspecifications; and shall be accomplished through the recording of heat, batch, lot,part, or serial numbers, or other appropriate identification, either on the item or onrecords traceable to the item.8.3.3 Responsibilities A. The management position responsible for procurement is responsible for thedevelopment of the material management program for identification and control ofmaterials, parts, and components.
The program elements in Section 8.3.2 and therelated source requirements contained within the documents listed in Section 8.3.4shall be addressed.
B. The management position responsible for procurement is responsible forimplementation of programs for maintaining identification and control of materials, parts, and components.
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Page 52 of 1378.3.4 Source Requirement Documents The applicable source requirement documents and their exceptions are noted in Appendix Bof this program description.
These establish mandatory
- controls, which must be addressed in the development of programs and procedures for the identification and control of items.9.0 CONTROL OF PLANT ACTIVITIES 9.1 Inspection and Line Verification 9.1.1 GeneralThe QA program requires that inspection and line verification procedures and instructions.
include provisions for inspections and line verifications to ensure quality.9.1.2 Program ElementsA. Line Verification
- 1. Line verifications shall be performed and documented to substantiate and ensurethat an activity or condition has been implemented and accomplished inconformance with specific requirements.
- 2. Requirements for line verification identified by design output documents shall beincluded in implementing documents.
- 3. Qualification of personnel performing line verifications shall be contained inprocedures and instructions developed by the organization performing the lineverification and shall be in accordance with Regulatory Guide 1.8 as endorsed inAppendix B of this program description.
B. Inspection Plans and Instructions Inspections shall be controlled by plans or instructions, which implement requirements, assign responsibilities, and identify acceptance criteria derived from design outputdocuments as appropriate.
- 1. Inspections to verify conformance to codes, standards, and design output shall berequired for each operation.
Factors used to determine the extent of inspections to be performed are listed in Section 5.2 of this NQAP.2. Inspection hold points, witness points, and notification points shall be used asrequired or needed to verify in-process or final achievement of quality.
Whengraded approach criteria are applied to design/regulatory required inspection activities, line verification will be required.
The QA organization shallindependently verify line organization performance to ensure adequacy of lineverifications.
- 3. Indirect control by assessment of processing
- methods, equipment, and personnel shall be specified when direct inspection is impossible or disadvantageous.
- 4. Instructions for activities such as sampling, assessments, and independent inspections shall be included.
- 5. Persons responsible for performing
- sampling, assessments, and independent inspections shall be specified.
C. Inspection Performance Inspections shall be performed by QA or other qualified individuals approved by QAutilizing graded approach criteria in accordance with controlled plans or instructions which specify attributes to be verified in accordance with requirements and acceptance criteria.
- 1. Inspections shall be performed by individuals delineated above other than thosewho performed or directly supervised the activity being inspected.
- 2. Personnel performing inspections shall be trained, qualified, and certified, asrequired, within their discipline in accordance with established requirements.
Therequirements criteria shall be approved by QA.3. Measuring and test equipment (M&TE) used to perform inspections shall becontrolled, calibrated, and maintained as required in Section 9.5 of this programdescription.
The identification of M&TE shall be documented.
- 4. Work shall not proceed beyond designated hold points prior to release byauthorized personnel.
D. ResultsRecords of inspection results and personnel performing the inspection shall be retainedas required in Section 6.3 of this program description.
- 1. Inspection records shall be identified as such and shall be retrievable.
- 2. Inspection records shall contain a description of the type of inspection, the dateperformed, inspection or verification of corrective action results, and identification of the inspector and data recorder as well as the person approving the inspection results including the date of approval.
- 3. Inspection records and/or data sheets shall include a statement attesting to theacceptability of results and provide for identifying the individual who performed theevaluation.
- 4. Periodic trending of inspection results shall be performed and reported toappropriate management.
- 5. Records shall be kept in sufficient detail to permit adequate evaluation ofinspection activities.
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9.1.3 Responsibilities
A. The management position responsible for engineering, environmental
& supportservices, and the General Manager, NPG QA or the SM WBN U2 QA or the SM BLNQA, as appropriate, are responsible for including the applicable QA program elementsin Section 9.1.2 and the related source requirements found in the documents listed inSection 9.1.4, within the inspection program.
The General Manager, NPG QA or theSM WBN U2 QA or the SM BLN QA, reviews and approves the inspection program toensure inclusion of QA requirements for their respective site.B. The management position responsible for engineering, environmental
& supportservices and the management position responsible for nuclear support services areresponsible for including the program elements in Section 9.1.2 and the related sourcerequirements contained within the documents listed in Section 9.1.4, as applicable, within the line verification program.C. The management position responsible for nuclear engineering is responsible forproviding qualitative
/ quantitative criteria in design output documents, which areincorporated in implementing procedures.
D. For WBN 2 construction completion, the General Manager WBN U2 Engineering
&Construction is responsible for providing qualitative
/ quantitative criteria in designoutput documents, which are incorporated in implementing procedures.
E. For BLN 1 & 2 the management position responsible for BLN Project, is responsible forproviding qualitative
/ quantitative criteria in design output documents, which areincorporated in implementing procedures.
F. The management position responsible for engineering, environmental
& supportservices and the General Manager, NPG QA are responsible for establishing andimplementing programs for training and certification of personnel performing QCactivities at licensed plants.G. For WBN 2 construction completion, the SM WBN U2 QA is responsible forestablishing and implementing programs for training and certification of personnel performing QC activities.
H. For BLN 1 & 2 the SM BLN QA is responsible for establishing and implementing programs for training and certification of personnel performing QC activities.
9.1.4 Source Requirement Documents The applicable source requirement documents and their exceptions are noted in Appendix Bof this program description.
These establish mandatory
- controls, which must be addressed in the development of programs and procedures for inspection.
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Page 55 of 1379.2 Quality Assurance Assessments 9.2.1 GeneralAssessments by QA are performed as a type of verification to ensure that observed quality-related activities are performed in accordance with requirements and desired results areachieved.
9.2.2 Program ElementsA. Assessment procedures and instructions shall address assessment techniques.
B. Assessment frequencies shall be based on such factors as the status and safetysignificance of the activity or process, frequency of occurrence, degree andacceptability of previous experience, adverse trends, and testing or operation sequences.
C. The results of assessments shall be documented and reported to appropriate levels ofmanagement.
D. Records shall be maintained in sufficient detail to provide adequate documentation ofassessed activities.
E. Follow up verifications or additional assessments shall be conducted as necessary toensure that required corrective action has been taken.F. Assessments shall be performed in accordance with written procedures andinstructions by qualified and appropriately trained personnel not having directresponsibility in the areas being assessed.
9.2.3 Responsibilities
The General Manager, NPG QA, is responsible for the development and implementation ofthe QA assessment program at operating units.The SM WBN U2 QA and SM BLN QA are responsible for the development andimplementation of the QA assessment program for their respective construction sites.9.2.4 Source Requirement Documents None applicable.
9.2.5 Units with Construction PermitsFor units with construction
- permits, refer to Appendix F and G.9.3 Control of Special Processes 9.3.1 GeneralThose processes, as determined by the Engineering organization, which by their naturemake a direct inspection either impossible or disadvantageous, are controlled as specialprocesses.
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Page 56 of 137Special processes shall be controlled and accomplished in accordance with approvedprocess control documents by qualified personnel using qualified written procedures.
9.3.2 Program ElementsA. Processes, which are to be controlled, as special processes, shall be documented indesign output documents and maintained current.
These processes shall include, butnot be limited to welding, forming and bending, heat treating, chemical
- cleaning, protective
- coatings, and NDE.B. Measures shall be established, documented, and implemented, as appropriate, usingspecifications, procedures, and instructions to ensure that special processes areaccomplished under controlled conditions and in accordance with applicable codes,standards, specifications, manufacturer instructions, or other special requirements.
These measures shall include requirements for procedures, equipment, personnel, specifications, and control of consumable materials.
C. When a special process is not covered by existing codes or standards, or when anitem's quality requirements exceed the requirements of existing codes or standards, any special requirements necessary for controlling, implementing, and documenting the special process shall be defined as appropriate.
D. Procedure, Equipment, and Personnel Qualification and Certification
- 1. Personnel performing special processes shall be qualified and, when required, certified in accordance with the applicable codes, standards, and any specialrequirements.
- 2. Qualification or certification of procedures, equipment, and personnel required bycodes, standards, or any special requirements shall be performed.
- 3. Documentation shall be maintained for these qualifications and certifications.
M&TE used in special processes shall be controlled in accordance with Section9.5 of this program description.
E. ResultsResults of examinations associated with special processes shall be documented andevaluated for acceptability.
Documentation shall provide for identifying the individual who performed the evaluation.
9.3.3 Responsibilities
A. The management position responsible for nuclear engineering is responsible fordevelopment of programs for control of special processes.
The program elements inSection 9.3.2 and the related source requirements contained within the documents listed in Section 9.3.4 shall be addressed.
B. The management position responsible for Inspection Services Organization isresponsible for interpretation of NDE results when not achievable at the site level, anddevelopment and implementation of NDE methods and procedures.
He is alsoresponsible for the qualification or certification of procedures, equipment, andpersonnel.
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Page 57 of 137C. For WBN 2 construction completion, the General Manager, WBN U2 Engineering
&Construction has delegated to the construction completion contractor the work ofdeveloping and implementing the NDE Program for ASME Section III work. (See alsoAppendix F.)D. The management position responsible for BLN Project has the responsibility fordeveloping and implementing the NDE Program for ASME Section III work (whenactive) at BLN 1 & 2. (See also Appendix G.)E. The General Manager, NPG QA, reviews and approves the inspection program forcontrol of special processes to ensure inclusion of QA requirements.
He is alsoresponsible for the development of upper tier QA requirements for the NDE program(refer to Section 9.3.2). For construction NDE activities, refer to Appendices F and G.F. The management position responsible for nuclear engineering is responsible forcoordinating with appropriate organizations and determining which processes are to becontrolled as special processes and for developing engineering requirements for NDE.G. The management position responsible for nuclear support services is responsible forthe qualification or certification of NPG special process procedures, equipment, andpersonnel for all areas other than NDE.9.3.4 Source Requirement Documents The applicable source requirement documents and their exceptions are noted in Appendix Bof this program description.
These establish mandatory
- controls, which must be addressed in the development of programs and procedures for the control of special processes.
9.4 Test Control9.4.1 GeneralThe QA program requires that controls shall be established to ensure that required testing isidentified and performed in accordance with procedures, which incorporate engineering requirements.
9.4.2 Program ElementsA. The following types of tests, as a minimum, shall be included:
- 1. Design qualification tests.2. Product acceptance (proof) tests prior to installation.
- 3. Preoperational tests.4. Construction tests.5. Start-up tests.6. Surveillance tests.7. Functional tests.
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Page 58 of 1378. Post maintenance tests.9. Post modification tests.10. Special tests.B. Test Performance
- 1. Tests shall be accomplished in accordance with written and approved testprocedures which include the requirements and acceptance criteria of technical specifications,
- drawings, specifications, codes, standards, regulatory requirements, and scoping documents as applicable.
- 2. Tests performed following plant repairs, replacements, maintenance, ormodifications shall be conducted in accordance with the original design andtesting requirements or approved documented alternatives.
Tests shall besufficient to confirm that the changes produce expected results and do not reducesafety of operations.
- 3. Test procedures or instructions include the following, as applicable:
- a. Description of test objective.
- b. Instructions for performing the test.c. Test prerequisites such as calibrated instrumentation, adequate testequipment and instrumentation including their accuracy requirements, completeness of the item to be tested, suitable and controlled environmental conditions, provisions for data collection and storage, and qualified personnel.
- d. Provisions to assure test prerequisites have been met.e. Mandatory inspection hold points.f. Acceptance or rejection criteria.
- g. Methods of recording, documenting, and reviewing test data and results.h. Provisions for assuring that adverse conditions are corrected, or areevaluated and determined not to adversely impact testing, prior to theinitiation of preoperational testing of the affected item.C. Test ResultsTest results shall be documented in a suitable test results package that contains:
- 1. The identification of the item to which it applies.2. The identification of instructions followed in performing the test.3. Pertinent inspection and test data.
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Page 59 of 137%cr%9.4.2 Program Elements (continued)
- 4. Significant dates and times.5. Signature of inspector or tester.6. Conditions encountered which were not anticipated, including identification ofdeviations or adverse conditions, and actions taken to resolve the condition.
D. Results Evaluation The technical acceptability of the results shall be evaluated by an appropriate authority to ensure that the test requirements have been satisfied.
E. Records of test results shall be retained in accordance with Section 6.3 of this programdescription.
9.4.3 Responsibilities
A. The management position responsible for nuclear engineering is responsible for thedevelopment of test control programs.
The program elements in Section 9.4.2 and therelated source requirements contained within the documents listed in Section 9.4.4shall be addressed.
B. The management position responsible for a nuclear site, (delegated to themanagement position responsible for site engineering) is responsible for reviewing testresults and specifying through design output documents the acceptance criteria fortests necessary to demonstrate an item's compliance with design parameters for initialacceptance and major modifications for licensed units.C. The General Manager, WBN U2 Engineering and Construction is responsible for thedevelopment and conduct of construction, component, and preoperational tests, whichincorporate engineering requirements.
For lower tier responsibilities related to WattsBar Unit 2 testing program see UFSAR Section 14.D. The management position responsible for a nuclear site, (delegated to themanagement position responsible for site engineering) is responsible for thedevelopment of tests (startup and operations phase) which incorporate engineering requirements and for the conduct of tests, including leak tests (operations phase). Heis also responsible for documenting, evaluating, and determining acceptability of testresults.E. The General Manager, NPG QA, is responsible for oversight of the test controlprogram (i.e., test performance, test results and acceptability of tests).F. The SM WBN U2 QA and SM BLN QA are responsible for oversight of the test controlprogram for construction and preoperational testing activities (i.e., test procedures, testperformance, test results, and acceptability test).9.4.4 Source Requirement Documents The applicable source requirement documents and their exceptions are noted in Appendix Bof this Program.
These establish mandatory
- controls, which must be addressed in thedevelopment of programs and procedures for the control of tests.
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Page 60 of 137%cr%9.4.3 Responsibilities (continued) 9.5 Control of M&TE and Installed Safety-Related I&C Devices9.5.1 GeneralMeasures shall be established to control equipment, which is used to conductmeasurements or tests related to determining the functionality or quality of structures,
- systems, and components within the scope of the QA program.9.5.2 Program ElementsA. Requirements Common to M&TE and Installed Safety-Related I&C Devices1. Procedures or instructions for administrative controls shall establish:
- a. Controls for calibration, selection, identification, and utilization of M&TE andinstalled safety-related I&C devices.b. The scope of the various safety-related calibration and control programs.
- c. The types of equipment to be controlled.
- 2. Calibration procedures and instructions, as a minimum, shall include:a. The identity of the item to be calibrated.
- b. Calibration equipment and reference standards to be used.c. Checks, tests, measurements, and acceptance tolerances.
- d. Sequence of operations.
- e. Special instructions when necessary.
- f. Recording of performer and applicable procedure or instruction.
- g. Recording of as found and as left data.3. Intervals shall be established for calibration and adjustments of M&TE andinstalled safety related I&C devices.
These intervals shall be based on requiredaccuracy,
- purpose, degree of usage, stability characteristics, and other conditions which may affect the measurement or output data.4. An index, listing, or log shall be procedurally maintained; and shall identify eachpiece of M&TE and installed safety-related I&C device within the calibration program.5. Reference standards shall be traceable to nationally recognized standards orphysical constants.
When national standards do not exist, the basis for calibration shall be documented and approved by designated responsible management.
- 6. Prior to use, M&TE and installed safety-related I&C devices shall be identifiable and traceable to applicable calibration records.
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B. Unique Requirements for M&TEControls for M&TE shall include the following requirements.
These requirements are inaddition to those noted in Section 9.5.2A.1. M&TE shall be stored, calibrated, and used in environments that will not adversely affect its accuracy.
- 2. M&TE shall be identified to indicate the date of the last calibration, by whom itwas calibrated, and when the next calibration is due.3. Methods shall be established to identify previous usage of M&TE when found tobe out of calibration.
These methods shall require that inspections or tests berepeated or a documented evaluation be performed when the integrity.
of pastmeasurements obtained with the suspect equipment or device cannot bedemonstrated.
- 4. Calibration standards, including test stands that are used as a standard (i.e.,multiple M&TE) shall have an accuracy of at least four times the requiredaccuracy of the equipment being calibrated.
When this is not possible, standards shall have an accuracy that ensures the equipment being calibrated will be withinrequired tolerances.
The basis of acceptance shall be documented andauthorized by identified responsible management.
- 5. M&TE shall be conspicuously
- labeled, tagged, or otherwise controlled to ensureperformance of required calibrations on or before the established due date.6. M&TE which are consistently found out of calibration shall be identified asnonconforming, removed from service, and repaired or replaced.
C. Unique Requirements for Installed Safety-related I&C DevicesControls for installed safety-related I&C devices shall include the following requirements.
These requirements are in addition to those noted in Section 9.5.2A.1. The calibration of installed safety-related I&C devices that provide finalmeasurements data or controls shall be against M&TE that have an accuracyequal to or better than the required accuracy of the devices being calibrated.
- 2. Installed safety-related I&C devices shall be controlled to ensure performance ofrequired periodic calibrations.
- 3. Environmental qualification controls for 10 CFR 50.49 installed safety-related I&Cdevices shall be established in applicable design documents.
These controlsshall be maintained when installed safety-related I&C devices are opened in placeor removed for calibration in a laboratory.
- 4. Installed safety-related I&C devices which are consistently found to be out ofcalibration shall be identified and repaired or replaced.
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Page 62 of 137%cr%9.5.2 Program Elements (continued)
D. Unique Requirements for Installed Compliance I&C DevicesControls for installed compliance I&C devices shall include the following requirements.
These requirements are in addition to those noted in Sections 9.5.2A and 9.5.2C.1. Methods shall be established to identify previous usage of installed compliance I&C devices when found to be out of calibration.
These methods shall require thatinspections or tests be repeated or a documented evaluation be performed whenthe integrity of past measurements obtained with the suspect equipment or devicecannot be demonstrated.
9.5.3 Responsibilities
A. The management position responsible for a nuclear site is responsible for thedevelopment of controls for M&TE and installed safety-related I&C devices.
Theprogram elements in Section 9.5.2 and the related source requirements contained within the documents listed in Section 9.5.4 shall be addressed.
B. For WBN 2 construction completion
- project, the General Manager WBN U2Engineering
& Construction is responsible for the development of controls for M&TEand installed safety related I&C devices.
The program elements in Section 9.5.2 andthe related source requirements contained within the documents listed in Section 9.5.4shall be addressed.
C. For BLN 1 & 2, the management position responsible for BLN Project is responsible forthe development of controls for M&TE and installed safety related I&C devices.
Theprogram elements in Section 9.5.2 and the related source requirements contained within the documents listed in Section 9.5.4 shall be addressed.
D. The management position responsible for a nuclear site, (delegated to themanagement position responsible for site engineering) is responsible for providing qualitative/quantitative criteria in design output documents for licensed plants.E. For WBN 2 construction completion, the responsibility for providing qualitative
/quantitative criteria in design output documents is assigned to General Manager WBNU2 Engineering
& Construction.
F. For BLN 1 & 2, the responsibility for providing qualitative
/ quantitative criteria in designoutput documents is assigned to the management position responsible for BLN Project.9.5.4 Source Requirement Documents The applicable source requirement documents and their exceptions are noted in Appendix Bof this program description.
These establish mandatory controls which must be addressed in the development of programs and procedures for the control of M&TE and installed safety-related I&C devices.
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Page 63 of 137%cr0/69.5.3 Responsibilities (continued) 9.6 Handling,
- Storage, and Shipping9.6.1 GeneralMeasures shall be established such that items, including consumables, under the scope ofthe QA program are handled, stored, and shipped by qualified individuals in a manner toprevent deterioration, contamination, damage, or loss of identification in accordance withapproved engineering and procurement documents.
9.6.2 Program ElementsA. MarkingItems and/or their containers shall be adequately marked so that the items may beproperly identified, maintained, and preserved during shipping, receiving, and storage.Marking shall also indicate the presence of special environments or the need forspecial controls.
B. Packaging and Cleaning1. Packaging shall be adequate to provide protection against effects such ascorrosion and contamination, which would lower the quality of items or causedeterioration beyond specified limits.2. Special coverings, special equipment, and special protective environments shallbe provided and maintained, as required, by procurement documents and vendorinstructions determined to be applicable by the responsible engineer.
- 3. Cleaning operations shall be performed, as required, prior to coating, packaging,
- storing, or installing items.C. Shipping and HandlingSpecial protection required for shipping shall be provided and maintained, as specified, by procurement documents or vendor instructions.
Specified instructions andprecautions for handling shall be followed.
D. Storage1. Methods of controlling stored items, including shelf life, shall be established tominimize the potential for damage or deterioration during storage.2. Appropriate facilities shall be provided for storage of items requiring specialenvironmental conditions.
- 3. Periodic assessments of storage areas and stored items shall be performed anddocumented to verify compliance with storage requirements.
- 4. Proper maintenance shall be provided for stored items, where necessary toprevent deterioration.
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Page 64 of 137%cr%9.6.2 Program Elements (continued)
9.6.3 Responsibilities
A. The management position responsible for procurement is responsible for thedevelopment of program controls for handling,
- storing, and shipping.
The programelements in Section 9.6.2 and the related source requirements contained within thedocuments listed in Section 9.6.4 shall be addressed.
B. The management position responsible for procurement is responsible forimplementation of programs for handling,
- storage, shipping, and issuance of materials.
C. The management position responsible for nuclear engineering is responsible forestablishing
- storage, handling, and shipping requirements and preventive maintenance requirements during storage.9.6.4 Source Requirement Documents The applicable source requirement documents and their exceptions are noted in Appendix Bof this program description.
These establish mandatory
- controls, which must be addressed in the development of programs and procedures for the control of handling, storage,shipping,
- cleaning, and preservation of items.9.7 Inspection, Test, and Operating Status9.7.1 GeneralMeasures shall be established and documented to ensure that the operating status iscurrent and the acceptability of items is known throughout fabrication,
- storage, construction, installation, operation, maintenance, and modification.
9.7.2 Program ElementsA. Inspection and Test Status1. The status of inspections and tests shall be identified either on the items or indocuments traceable to the items to ensure that required inspections and testsare performed and to preclude inadvertent bypassing.
- 2. The status of inspections and tests shall be maintained through the use ofindicators such as tags, markings, shop travelers, routing cards, stamps,inspection
- records, or other suitable means.3. The authority for application and removal of tags, markings, labels, and stampsshall be specified.
- 4. Deletions or alterations of required inspections, tests, and other critical operations shall be controlled through appropriate changes to applicable procedures.
Thesechanges shall be handled in accordance with Section 6.1.2F of this programdescription.
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Page 65 of 137B. Operating Status1. The operating stafus of items (including temporary alterations) shall be indicated by status indicators such as tags on valves and switches to prevent inadvertent operation.
- 2. Plant instructions that require items to be removed from service for maintenance,
- testing, or modification shall require designated personnel permission and thecompletion of the appropriate clearance (hold order or approved plantprocedures) before commencement of the activity.
9.7.3 Responsibilities
A. The management position responsible for a nuclear site is responsible for thedevelopment of controls to maintain inspection, test, and operating status. Theprogram elements in Section 9.7.2 and the related source requirements contained within the documents listed in Section 9.7.4 shall be addressed.
B. The management position responsible for a nuclear site, (delegated to themanagement position responsible for site engineering) is responsible for establishing applicable inspection and test acceptance criteria to ensure the acceptability of items ismaintained.
C. The General Manager WBN U2 Engineering
& Construction, is responsible for theimplementation of programs for maintaining inspection, test, and system status forWBN Unit 2 construction completion activities.
D. The management position responsible for BLN Project is responsible for theimplementation of programs for maintaining inspection, test, and system status for BLN1 & 2 construction permit activities.
E. The management position responsible for a nuclear site is responsible for theimplementation of programs for maintaining inspection, test, and operating status atlicensed units.9.7.4 Source Requirement Documents The applicable source requirement documents and their exceptions are noted in Appendix Bof this program description.
These establish mandatory
- controls, which must be addressed in the development of programs and procedures for the control of inspection, test, andoperating status.
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Page 66 of 137%cr0/69.7.3 Responsibilities (continued) 9.8 Control of Maintenance 9.8.1 GeneralThe nuclear maintenance
- program, including corrective and preventive maintenance, shallensure that quality-related structures,
- systems, and components are maintained (including appropriate equipment qualification maintenance) at a level sufficient to perform theirintended functions.
9.8.2 Program ElementsA. Preventive Maintenance A preventive maintenance program prescribing the frequency and type of maintenance activities to be performed shall be established and maintained.
B. Procedures and Instructions Maintenance shall be carried out in accordance with procedures or instructions toensure quality at least equivalent to that specified in the approved design basis orapproved alternatives.
Procedures or instructions shall be written to the level of detailthat is normally expected of the user group. Training, experience, and the technical complexity of the work are factors which should be considered in determining the levelof detail the procedure or instruction should contain.
Guidelines shall be established forthe use of these procedures or instructions.
C. Maintenance Preplanning Maintenance shall be preplanned to include as appropriate:
- 1. Review of work-initiating documents to ensure quality requirements have beenaddressed.
- 2. Evaluation of the use of special processes, equipment, and materials including potential hazards to personnel and equipment and ALARA considerations.
- 3. The potential for common-mode failures when working on similar multiple orredundant systems and components.
- 4. Documented approval by designated personnel to release equipment or systemsfor maintenance.
- 5. Inspection and testing, as appropriate, to ensure a suitable level of confidence.
This includes post maintenance testing commensurate with the maintenance performed to ensure that the equipment is capable of being returned to service,that the original deficiency (if any exists) has been corrected, and that no newdeficiency has been created.
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Page 67 of 137%cr%9.8.2 Program Elements (continued)
D. Malfunctions The cause of malfunctions shall be evaluated and documented in accordance withTVA's nuclear corrective action program.E. TrendingThe Maintenance Program shall establish the parameters for trending maintenance activities and describe the methods for evaluating and documenting adverse trends.9.8.3 Responsibilities A. The management position responsible for a nuclear site is responsible for thedevelopment of the nuclear maintenance program.
The program elements in Section9.8.2 and the related source requirements contained within the documents listed inSection 9.8.4 shall be addressed.
B. The General Manager WBN U2 Engineering
& Construction is responsible for theimplementation of the nuclear maintenance program during construction phaseactivities for WBN Unit 2.C. The management position responsible for BLN Project is responsible for theimplementation of the nuclear maintenance program during construction phaseactivities for BLN 1 & 2.D. The management position responsible for a nuclear site is responsible for theimplementation of the nuclear maintenance program during operations phase activities.
9.8.4 Source Requirement Documents The applicable source requirement documents and their exceptions are noted in Appendix Bof this program description.
These establish mandatory
- controls, which must be addressed in the development of programs and procedures for the Nuclear Maintenance Program.9.9 Plant Reviews9.9.1 GeneralA. The plant staff organization provides reviews of day-to-day activities to ensure they areconducted in a safe manner. Qualified Reviewers provide for reviews of procedures, procedure
- changes, and proposed changes to structures,
- systems, and components that affect nuclear safety in their area of expertise.
B. The Plant Operations Review Committee (PORC) is a multi-disciplined committee responsible for providing an oversight review of documents required for the safeoperation of the plant. The PORC advises the management position responsible forplant operations on matters related to nuclear safety.
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Page 68 of 137%cr%/69.9.1 General (continued) 9.9.2 Plant ReviewsA. Activities which affect nuclear safety shall be conducted as follows:1 Proposed changes or modifications to plant nuclear safety-related structures,
- systems, and components shall be reviewed in accordance with approved writtenprocedures.
Such modifications shall be reviewed by an individual/group otherthan the individual/group which designed the modification, but who may be fromthe same organization as the individual/group, which designed the modification.
Proposed modifications to plant nuclear safety-related structures,
- systems, andcomponents shall be approved by the manager responsible for plant operations, or designee, prior to implementation.
- 2. Written procedures shall be established, implemented, and maintained coveringthe following activities:
- a. The applicable procedures recommended in Regulatory Guide 1.33,Revision 2, Appendix A, February 1978 and in accordance with Appendix Bof this program description;
- b. The emergency operating procedures which implement NUREG-0737 andNUREG-0737, Supplement 1, as stated in Generic Letter 82-33;c. Security Plan implementation;
- d. Radiological Emergency Plan Implementation;
- e. Offsite Dose Calculation Manual implementation;
- f. Fire Protection Program Implementation;
- g. Radiation Protection Program;h. Process Control Program Implementation (radwaste packaging andshipping);
- i. In Plant Radiation Monitoring;
- j. Quality Assurance Program for effluent and environmental monitoring, usingthe guidance contained in Regulatory Guide 4.15, December 1977,Regulatory Guide 1.21, Revision 1, 1974 and Regulatory Guide 4.1,Revision 1, 1975; andk. ISFSI activities as required by 10 CFR 72.
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Page 69 of 137%cr*Yo9.9.2 Plant Reviews (continued)
- 3. Procedures required by Section 9.9.2A.2, procedures and programs required bysite-specific technical specifications, other procedures which affect plant nuclearsafety, and changes (other than editorial or typographical changes)
- thereto, shallbe prepared and reviewed in accordance with approved administrative procedures prior to implementation except as specified in Section 9.9.2A.6.
Procedures or procedure changes shall be reviewed by a qualified individual knowledgeable in the subject matter other than the preparer.
The reviewer maybe from the same or different organization.
Procedures not reviewed by PORCshall be approved by the responsible management in accordance with established program requirements.
Procedures reviewed by PORC shall be approved by themanager responsible for plant operations, or designee.
- 4. Qualified Reviewers responsible for reviews performed in accordance withSection 9.9.2A.3 shall be designated and qualified.
Qualifications of qualified reviewers shall be as specified in written procedures.
Such reviews shall includea determination of whether additional cross-disciplinary review is necessary.
Ifdeemed necessary, such review shall be performed by review personnel of theappropriate discipline.
- 5. Procedures and intent changes to these procedures within the scope of 10 CFR50.59 or 10 CFR 72.48 shall be reviewed to determine whether a licenseamendment is required.
- 6. Temporarily approved changes to procedures of Section 9.9.2A.2 shall be madein accordance with ANSI N18.7-1976/ANS 3.2, as modified in Appendix B of thisprogram description.
Such changes shall be documented,
- reviewed, andapproved in accordance with Sections 9.9.2A.3 and 9.9.2A.4 within 14 days andin accordance with approved administrative procedures.
B. Plant Operations Review Committee (PORC)Each plant shall have a PORC which shall function to advise the management positionresponsible for plant operations in matters related to nuclear safety. This advisoryfunction shall be performed by the PORC acting in a formal meeting periodically and assituations demand. PORC shall be organized, and conduct business as described below. The Chairperson and members shall be appointed in writing by themanagement position responsible for plant operations.
PORC members shall meet theexperience requirements of ANSI N18.1-1971 and ANSI/ANS 3.1-1981 as endorsed byRegulatory Guide 1.8, Revision 2, April 1987, "Qualification and Training of Personnel for Nuclear Power Plants,"
as outlined in Appendix B of this program description.
Thisapplies to the correlated ANSI N18.1-1971 and ANSI/ANS 3.1-1981 Manager orSupervisor position for the represented organization.
(Operations representatives whohold or who have held SRO licenses at the station are considered qualified.)
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Page 70 of 137%cr%/69.9.2 Plant Reviews (continued)
- 1. Composition The composition of PORC shall be as follows:Chairperson:
Operations ManagerMember: operations representative(s)
Member: maintenance representative(s)
Member: chemistry control representative(s)
Member: radiological protection representative(s)
Member: engineering representative(s)
- 2. Alternates Alternate chairpersons and members shall be appointed in writing by themanagement position responsible for plant operations.
- 3. Meeting Frequency The PORC shall meet at least once per calendar month and as convened by thePORC Chairperson or designated alternate.
- 4. QuorumThe PORC shall consist of the chairperson or designated alternate and three ofthe five functional area representatives.
- 5. Reporting The PORC reports to the management position responsible for plant operations on its activities and findings.
The meeting minutes shall serve as the officialcorrespondence from PORC to the management position responsible for plantoperations.
PORC recommendations shall be recorded in the minutes andsubmitted to the management position responsible for plant operations.
- 6. Functions
- a. Advise the management position responsible for plant operations on mattersrelated to nuclear safety;b. Recommend to the management position responsible for plant operations approval or disapproval of items considered under Section 9.9.2B.7; andc. Provide written notification to the management position responsible for anuclear site and the NSRB of safety-significant disagreements between thePORC and the management position responsible for plant operations within24 hours. The management position responsible for plant operations shallhave responsibility for resolution of such disagreements.
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Page 71 of 137%cr0/%9.9.2 Plant Reviews (continued)
- 7. Responsibilities The PORC shall be used to conduct, as a minimum, reviews of the following.
ThePORC may delegate the performance of reviews, but shall maintain cognizance over and responsibility for them, e.g., subcommittees.
- a. New procedures or changes to existing procedures recommended byRegulatory Guide 1.33, Revision 2, Appendix A, February 1978; that requirean evaluation in accordance with 10 CFR 50.59.b. The emergency operating procedures which implement NUREG-0737 andNUREG-0737, Supplement 1, as stated in Generic Letter 82-33;c. Physical Security Plan;d. Radiological Emergency Plan;e. Offsite Dose Calculation Manual;f. Process Control Program (radwaste packaging and shipping);
- g. Additional PORC reviews specifically required by site-specific technical specifications or the plant's licensing basis;h. Proposed changes to TS; Technical Requirements Manual; their bases;amendments to the Operating License; andi. Selected 10 CFR 50.59 evaluations.
- j. Selected 10 CFR 72.48 evaluations.
9.9.3 RecordsThe PORC shall maintain written minutes of PORC meetings that, at a minimum, documentthe results of its activities.
Copies shall be provided to the management positionresponsible for a nuclear site. At a minimum, the PORC minutes shall include results of theactivities conducted under the provisions of Section 9.9.10.0 ADVERSE CONDITIONS 10.1 GeneralMeasures shall be established to ensure that items that do not conform to requirements arecontrolled to prevent their inadvertent installation or use. Adverse conditions, including nonconforming items or nonhardware problems such as failure to comply with operating
- license, technical specifications, or procedures, shall be identified, evaluated, corrected,
- tracked, trended, and when required, reported to appropriate levels of management.
Procedures or instructions implementing the corrective action program shall establish thecriteria for documenting and tracking adverse conditions.
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Page 72 of 13710.2 Program Elements10.2.1 Control of Nonconforming ItemsA. Organizations responsible for items determined to be nonconforming during receiptinspection, construction, maintenance, modifications, or operations shall identify(physical identification) and segregate the nonconforming items from acceptable itemsto prevent further processing,
- delivery, installation, or inadvertent use. Whensegregation is not practical,
- tagging, marking or other means of identification isacceptable.
B. In cases where a nonconforming item is needed for use prior to correcting thenonconformance, a conditional release request document is required.
The conditional release request document requires appropriate reviews and approvals.
In addition, forequipment to be energized,
- operated, or pressurized an evaluation and justification isrequired.
10.2.2 Corrective Action For Adverse Conditions A. NPG organizations, NC, and onsite non-NPG service organizations performing quality-related activities at nuclear facilities shall promptly identify and resolve adverseconditions.
B. Minor deficiencies, which may be brought into compliance within an acceptable timeframe, shall be corrected on the spot in accordance with established instructions.
C. Adverse conditions shall be dispositioned by organizations with defined responsibility and authority; and shall be corrected in accordance with documented plans.D. Disposition actions for nonconforming items may be accept-as-is, repair, rework, scrap,or return to vendor. Dispositions of accept-as-is or repair shall be reviewed andapproved by Corporate or Site Engineering or, for nuclear fuel-related items, NuclearFuels. Reworked or repaired, and replaced items shall satisfy the original inspection and test requirements or acceptable alternatives.
E. The cause of significant adverse conditions shall be determined and corrective actiontaken to preclude recurrence.
F. Significant adverse conditions shall be reported to appropriate levels of management.
G. The satisfactory completion of corrective actions shall be verified and documented bythe appropriate organization.
H. Independent verification of corrective action implementation is performed as specified within the corrective action program.10.2.3 Escalation of Adverse Conditions Commensurate with their importance to quality or safety, adverse conditions which are notbeing effectively or timely resolved shall be escalated to appropriate levels of management in a timely manner.
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Page 73 of 13710.2.4 TrackingProcedures describing the corrective action program shall establish the requirements forthose adverse conditions, which shall be tracked.10.2.5 QA TrendingTrend analysis shall be performed on adverse conditions and quality indicators associated with QA verification activities.
Trend results shall be used to advise management of thequality status, identify adverse trends that need increased management attention, andcompare quality of performance among organizations.
The trend analysis program shall bedescribed in procedures or instructions and shall include the following items as a minimum.A. Identify the quality indicators associated with QA verification activities to be trended.B. Specify the process of data handling such as gathering, collecting,
- sorting, grouping, and coding.C. Specify the process to be used in analyzing data and trend determination.
D. Describe the actions to be taken when an adverse trend is identified.
E. Describe the type, distribution, and frequency of issue of trend results reporting.
10.2.6 Stop WorkWork shall be stopped under any of the following conditions:
A. Work is proceeding in violation of approved and controlling documents.
B. A condition, which clearly indicates that cessation of an activity, is the only meansavailable to protect the health and safety of the public and/or plant personnel.
C. An activity, which if continued, will require extensive rework or repair for corrective action.D. An activity, which if continued, may jeopardize nuclear safety.E. A condition that represents continual failure to comply with technical or administrative controls.
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Page 74 of 13710.3 Responsibilities A. The management position responsible for nuclear oversight is responsible for thedevelopment of the NPG corrective action program.
The program elements in Section10.2 and the related source requirements contained within the documents listed inSection 10.4 shall be addressed.
The General Manager, NPG QA, reviews andapproves the NPG corrective action program.B. For WBN U2 construction completion, the General Manager, WBN U2 Engineering andConstruction is responsible for the development of the corrective action program.
Theprogram elements in Section 10.2 and the related source requirements contained within the documents listed in Section 10.4 shall be addressed.
The SM WBN U2 QAreviews and approves the WBN U2 corrective action program.C. For the BLN project, the management position responsible for BLN Project isresponsible for the development of the corrective action program.
The program,elements in Section 10.2 and the related source requirements contained within thedocuments listed in Section 10.4 shall be addressed.
The SM BLN QA reviews andapproves the BLN corrective action program.D. Line managers are responsible to stop any work within their areas of responsibility when a continuation of activities could meet the criteria of Section 10.2.6E. QA is responsible to issue a formal Stop Work Order, as required, if a line managerfails to act on a stop work condition.
Stop Work Orders shall remain in effect untilproper evaluation can be made and adequate corrective action can be applied.F. The management position responsible for nuclear oversight is responsible to establish and maintain trend analysis procedures for adverse conditions and the qualityindicators generated by QA verification activities such as audits, assessments, inspection, and vendor audits and surveillances.
The General Manager, NPG QA, isresponsible for oversight and independent analysis of NPG CAP trending.
G. The SM WBN U2 QA and the SM BLN QA are responsible for independent analysis ofthe CAP trending at their respective sites.10.4 Source Requirement Documents The applicable source requirement documents and their exceptions are noted in Appendix Bof this program description.
These establish mandatory controls which must be addressed in the development of programs and procedures for the corrective action program.11.0 INDOCTRINATION,
- TRAINING, QUALIFICATION, AND CERTIFICATION 11.1 GeneralPersonnel performing quality-related activities shall receive indoctrination and training, asnecessary, to ensure that adequate proficiency is achieved and maintained.
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Page 75 of 13711.2 Program Elements11.2.1 Indoctrination and TrainingA. Personnel performing quality-related activities shall receive training related toadministrative controls and the purpose, scope, and implementation of the NQAP.B. For personnel performing quality-related activities, proficiency shall be maintained anddemonstrated through activities such as annual performance evaluation, retraining, reexamining, or recertifying.
C. Training of employees performing quality-related activities shall be conducted, asappropriate, when new programs or procedures affect the scope of their work andwhenever changes in their duties or responsibilities occur.D. The scope, method, and objectives of formal training for quality-related activities shallbe documented.
E. Records documenting the date, attendance,
- content, instructor, and duration of trainingsessions shall be prepared and maintained to demonstrate individual qualification andtraining program implementation for employees performing quality-related activities.
11.2.2 Qualification and Certification Qualification and certification programs shall be established and maintained to include thefollowing:
A. Certification of personnel, as needed, to perform inspections, tests, examinations, special processes, or lead audits prior to performance of the activity.
Certifications shall delineate the functions personnel are qualified to perform and the criteria used forqualification.
B. Personnel qualification criteria for applicable inspection, test, or examination techniques, audits, special processes, and capabilities necessary to perform theactivity safely and in compliance with applicable requirements.
C. A method to assess the performance of certified individuals and the qualifications ofemployees performing quality-related activities, to determine their initial and continued acceptability for performing their duties and to provide an assessment of the currentlevel of qualification and certification.
D. Development and maintenance of qualification and certification records and documents in accordance with applicable commitments and regulatory requirements.
11.3 Responsibilities A. The management position for nuclear operations support is responsible for thedevelopment of the program for indoctrination and training.
B. Other NPG managers are responsible for delineating training requirements in theirapplicable areas of responsibility and providing these requirements to the management position for nuclear operations support.
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Page 76 of 137%cr% 11.3 Responsibilities (continued)
C. The management position for nuclear oversight, through human resources, isresponsible for establishing a position qualification documentation and validation program.D. Managers are responsible for implementing the indoctrination and training programand, as appropriate, developing a certification program and implementing thecertification requirements in their area of responsibility.
E. The program elements in Section 11.2 and the related source requirements contained within the documents listed in Section 11.4 shall be addressed in the development andimplementation of indoctrination,
- training, qualification, and certification activities.
11.4 Source Requirement Documents The applicable source requirement documents and their exceptions are noted in Appendix Bof this program description.
These establish mandatory controls which must be addressed in the development of programs and procedures for the indoctrination,
- training, qualification, and certification program.12.0 AUDITING12.1 GeneralMeasures shall be established to implement a comprehensive audit program, which consistsof internal audits, including NPG, NC, and other TVA organizations, which support thenuclear program and contractor/supplier audits to determine and assess the adequacy andeffectiveness of the QA program.12.2 Program ElementsA. An audit plan shall be prepared identifying the audits to be performed and theirfrequencies and schedule.
B. Audits shall include:
a determination of the effectiveness of QA program elements; evaluation of work areas, activities, processes, and items; review of documents andrecords; review of audit results with responsible management; follow up on corrective action taken for deviations identified during the audit; and escalation to appropriate senior management of any safety significant disagreement between the auditingorganization and the organization or function being audited.C. Audits shall be performed in accordance with written procedures or checklists byqualified, certified, and appropriately trained personnel not having direct responsibilities in the areas being audited.D. Audited organizations shall provide access to facilities, documents, and personnel needed to perform the audits. They shall take necessary action to correct deviations identified by the audit in a timely manner.
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Page 77 of 137%cr%1 2.2 Program Elements (continued)
E. Internal Audits1 The scope of an audit shall be determined by considering such factors as workareas, activities, processes, or items and the specific organizations involved.
- 2. The auditing organizations shall ensure that audit procedures and instructions adequately cover applicable elements of the NQAP.3. Audits of Design and Construction Phase units and the Fitness for Duty Programare in accordance with the Code of Federal Regulations.
- 4. Audits of operational phase units shall be performed with oversight by the NSRB.Except as noted in 12.2E.4.f, 12.2E.4.g, 12.2E.4.h, 12.2E.4.m, and 12.2E.4.n below, audit frequencies shall be biennially.
These audits shall encompass:
- a. The conformance to provisions contained within the Technical Specifications and applicable license conditions.
- b. The performance, training and qualifications of the plant staff.c. The results of actions taken to correct deficiencies occurring in siteequipment, structures,
- systems, components, or method of operation thataffect nuclear safety.d. The performance of activities required by the Nuclear Quality Assurance Program to meet the criteria of Appendix B, 10 CFR Part 50 and 10 CFRPart 72, Subpart G.e. Any other activities and documents considered appropriate by the NSRB orthe Executive Vice President, and CNO.f. The fire protection programmatic controls including the implementing procedures at least once per 24 months.g. An independent fire protection and loss prevention program inspection andaudit shall be performed at a maximum interval of 24 months utilizing eitherqualified offsite license personnel or an outside fire protection firm.h. An inspection and audit of the fire protection and loss prevention programshall be performed by an outside qualified fire consultant at intervals nogreater than three years.i. The Radiological Environmental Monitoring program and the results thereof.j. The performance of activities required by the NQAP to meet the criteria ofRegulatory Guide 4.15, December 1977, Regulatory Guide 1.21, Rev. 1,1974, and Regulatory Guide 4.1, 1975.k. The Offsite Dose Calculation Manual and implementing procedures.
- 1. The Process Control Program and implementing procedures for solidification of wet radioactive wastes.
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Page 78 of 137%cr%/612.2 Program Elements (continued)
- m. The site Radiological Emergency Plan and implementing procedures inaccordance with the Code of Federal Regulations.
- n. The site Physical Security/Contingency Plan and implementing procedures in accordance with the Code of Federal Regulations.
- 5. A grace period not to exceed 90 days can be applied to audits with a biennialfrequency, with the following exceptions.
No grace period is permitted for theaudits of Emergency Preparedness,
- Security, or Access Authorization.
- 6. Audit reports, including recommendations to the management of the organization being audited, shall be maintained.
F. Contractor/Supplier Audits1. Audits of selected suppliers shall be conducted to verify implementation andadequacy of specified QA requirements.
- 2. Contractors/suppliers to be audited shall be selected on the basis of theimportance of their products or services to safety, status of contract
- activity, historical performance of the supplier, and potential QA problems that may bediscovered during source surveillance inspection activities or earlier audits.3. Audit schedules shall be prepared and audits shall be conducted in accordance with the schedules.
- 4. Audit reports shall be prepared and reviewed by the audit team, approved bymanagement, and transmitted to the supplier and appropriate management withinTVA.12.3 Responsibilities A. The General Manager, NPG QA, is responsible for the development of the NPG auditprogram.
The program elements in Section 12.2 and the related source requirements contained within the documents listed in Section 12.4 shall be addressed.
B. The SM WBN U2 QA and the SM BLN QA are responsible for the development of theaudit program for nuclear plants with construction permits.
The applicable elements inSection 12.2 and related source requirements contained within the document listed inSection 12.4 shall be addressed.
C. QA is responsible to conduct audits, including audits of selected suppliers, to verifyimplementation and adequacy of specified QA requirements.
12.4 Source Requirement Documents The applicable source requirement documents and their exceptions are noted in Appendix Bof this Program.
These establish mandatory
- controls, which must be addressed in thedevelopment of programs and procedures for the control of audits.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 79 of 13713.0 COMPUTER SOFTWARE AND DATA13.1 GeneralThe program elements in Section 13.2 of this program description apply to application software meeting the criteria of Appendix E of this Program, whether procured or developed at TVA. The controls established shall be commensurate with the importance of theapplication software to nuclear safety.13.2 Program ElementsA. Controls shall be established for the development of application software andassociated documentation, including requirements specification, design specifications, coding conventions, and user documentation.
B. Controls shall be established for changes to application software and associated software documentation.
C. Software documentation shall be controlled in accordance with Section 6.2 of thisprogram description.
D. Software documentation specified as QA records shall be controlled in accordance withSection 6.3 of this program description.
E. Documentation shall be provided for application software describing the correct usage.F. A central list of application
- software, which meets the criteria of Appendix E of thisprogram description, with appropriate levels of classification shall be established andmaintained.
Involved personnel shall be trained on the intent and purpose of the list.G. Prior to implementation, application software shall be verified to demonstrate that thesystem requirements are satisfied in the system design, implemented in the computercode, validated through documented tests, and the test results independently reviewed.
H. Controls shall be established to verify the accuracy and integrity of data input intoautomated computer databases.
- 1. For currently active application software developed or purchased prior to October 16,1986, only the requirements of Section 13.2B, 13.2E, and 13.2F apply. In addition, thisapplication software shall be validated through documented tests and test resultsindependently reviewed.
13.3 Responsibilities The management position responsible for nuclear engineering is responsible for thedevelopment of controls for computer software and data. The program elements in Section13.2 and the criteria of Appendix E of this program description shall be addressed.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 80 of 13713.4 Source Requirement Documents The applicable source requirements documents and their exceptions are noted in AppendixB of this program description.
These establish mandatory
- controls, which must beaddressed in the development of programs and procedures for the control of computersoftware and data.
14.0 REFERENCES
14.1 Regulations 10 CFR 20, "Standards for Protection Against Radiation."
10 CFR 21, "Reporting of Defects and Noncompliance."
10 CFR 50, "Domestic Licensing of Production and Utilization Facilities."
10 CFR 50.49, "Environmental Qualification of Electrical Equipment Important to Safety forNuclear Power Plants."10 CFR 50.54, "Conditions of Licenses."
10 CFR 50.55, "Conditions of Construction Permits."
10 CFR 50.55a, "Codes and Standards."
"Conditions of Construction Permits."
10 CFR 50.59, "Changes, Tests, and Experiments."
10 CFR 50, Appendix A, "General Design Criteria for Nuclear Power Plants."10 CFR 50, Appendix B, "Quality Assurance Requirements for Nuclear Power Plants andFuel Reprocessing Plants."10 CFR 50, Appendix R, "Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979."10 CFR 50.62, "Requirements for Reduction of Risk From Anticipated Transients WithoutScram (ATWS) Events for Light-Water-Cooled Nuclear Power Plants."10 CFR 50.72, "Immediate Notification Requirements for Operating Nuclear PowerReactors."
10 CFR 50.73, "Licensee Event Report System."10 CFR 50.120, "Training and Qualification of Nuclear Power Plant Personnel."
10 CFR 55, "Operators' Licenses."
10 CFR 70, "Domestic Licensing of Special Nuclear Material."
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 81 of 137%crYo14.1 Regulations (continued) 10 CFR 71, Subpart H, "Quality Assurance (Packaging and Transportation of Radioactive Material)."
10 CFR 72, Subpart F, "General Design Criteria.
10 CFR 72, Subpart G, "Quality Assurance (Licensing Requirements for the Independent Storage of Spent Nuclear Fuel and High-Level Radioactive Waste)."10 CFR 72, Subpart K, "General License for Storage of Spent Fuel at Power Reactor Sites."10 CFR 72, Subpart I, "Training and Certification of Personnel."
10 CFR 72.48, "Changes, Tests, and Experiments.
10 CFR 73.55, " Requirements for Physical Protection of Licensed Activities in NuclearPower Reactors Against Radiological Sabotage."
10 CFR 73.71, "Reporting of Safeguards Events."10 CFR 74, "Material Control and Accounting of Special Nuclear Material."
10 CFR 75, "Safeguards on Nuclear Material
-Implementation of US/IAEA Agreement."
10 CFR 100, "Reactor Site Criteria."
14.2 Regulatory GuidanceRefer to listing in Appendixes B and C of this program description.
14.3 TVA Licensing Submittal Documents Browns Ferry Nuclear Plant Technical Specifications, Administrative Controls Section.Sequoyah Nuclear Plant Technical Specifications, Administrative Controls Section.Watts Bar Nuclear Plant Technical Specifications, Administrative Controls Section.14.4 QA ManualsASME Section III Quality Assurance Manual (ASME III QAM).14.5 OtherINPO 84-010, "Vendor Equipment Technical Information Program (VETIP),"
March 1984.NRC Certificate of Compliance for the Holtec International HI-STORM 100 Cask System,Docket No. 72-1014.NRC letter from H. J. Thompson, Jr., dated April 16, 1985, "Quality Assurance Guidance forATWS Equipment That Is Not Safety Related,"
Generic Letter 85-06 (A02 850422 044).
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 82 of 137%cr%/614.5 Other (continued)
NRC letter from D. G. Eisenhut dated April 24, 1986, "Implementation of Fire Protection Requirements,"
Generic Letter 86-10 (A02 860512 005).NUREG 0800, Section 9.5.1, Branch Technical
- Position, CMEB 9.5-1 (formerly BTP ASB9.5-1), Rev. 2, July 1981, "Fire Protection for Nuclear Power Plants."Appendix A to Branch Technical Positions APCSB 9.5-1, August 23, 1976.NOTEThe terms and definitions identified in this section are important in order to have a consistent understanding of requirements of the NQAP. Regulatory Guide 1.74, which endorses ANSIN45.2.10, contains terms and definitions applicable to the nuclear industry.
This section identifies acceptable alternatives to these definitions with an asterisk
(*).15.0 DEFINITIONS Adverse Conditions
-Deficiencies including nonconforming
- material, parts, or components; failures; malfunctions; deviations; hardware problems involving noncompliance withlicensing commitments, specifications, or drawing requirements; abnormal occurrences; andnon-hardware problems such as failure to comply with the operating
- license, technical specifications, licensing commitments, procedures, instructions, or regulations.
Assessment
-An evaluation of the adequacy and effectiveness of quality programs, processes, ongoing tasks or activities, or management controls to identify opportunities forimprovement, performance
- problems, or verify resolution of problems.
- Audit -A documented activity performed in accordance with written procedures orchecklists to verify, by examination and evaluation of objective
- evidence, that applicable elements of the NQAP have been developed, documented, and effectively implemented inaccordance with specified requirements.
An audit should not be confused with assessment or inspection for the sole purpose of process control or product acceptance.
-Refer to 10 CFR 21 for definition of basic component.
Commercial-Grade Items -Refer to 10 CFR 21 for definition of commercial grade items.Construction Tests -Those tests which are performed on safety-related and other plantcomponents and systems on nuclear units which may satisfy prerequisites to thepreoperational test program.
Construction tests include pressure and other integrity tests;component and piping system cleaning and flushing; and equipment
- checkout, initialoperation, and adjustments.
Corrective Action -The action taken to correct an adverse condition.
Corrective actionincludes interim measures and corrective and preventive actions.Dedication
-Refer to 10 CFR 21 for definition of dedication.
-A program which ensures the preparation and implementation of plans and procedures to provide, in the event of an emergency, protective measures forhealth and safety of TVA personnel and the public.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 83 of 137%cr%/61 5.0 DEFINITIONS (continued)
Environmental Protection
-A program that provides
- controls, mainly in association withEnvironmental Protection Agency (EPA) requirements, for nonradiological environmental monitoring and compliance activities.
These include hazardous and nonradiological wastematerial (solid, liquid, and gas) which could be released to the environment.
Features
-Refers to either individual structures,
- systems, and components specifically called out by the scope of this Program (such as seismic Category 1 [L] items) or structures,
- systems, and components that may be integral to, or associated with, the programsidentified in Section 5.1B of this Program.Fire Protection
-A program that provides controls necessary for the protection of the lifeand health of TVA plant personnel and the public, to limit damage of property, and tominimize loss of generating capacity resulting from fire or explosion.
Functional Test -The manual operation or initiation of a system, subsystem, or component to verify that it functions within design tolerances (e.g., the manual start of a core spraypump to verify that it runs and that it pumps the required volume of water.)Graded Approach
-A methodology of applying a grading criteria based on an item's impacton safety, quality history, and other factors such that determination can be made as to thetype and degree of QA program requirements which need to be applied.
Refer to Section5.2.Greater than Class C waste (GTCC waste) -Low-level radioactive waste that exceeds theconcentration limits of radionuclides established for Class C waste in 10 CFR 61.55.Handling
-The act of physically moving items by hand or by mechanical means but notincluding transport modes.Hold Point -A designated stopping place during or following a specific activity at whichinspection or examination is required before further work can be performed.
Important to Safety (10 CFR 72) -A system, structure, or component condition/function required to store spent nuclear fuel safely; to prevent damage to spent nuclear fuel or high-level waste container during handling and storage, and to provide reasonable assurance that spent nuclear fuel can be received,
- handled, packaged, stored and retrieved withoutundue risk to the health and safety of the public.Independent Offsite Safety Review -Safety reviews performed by the Nuclear SafetyReview Board (NSRB) which provide additional assurance that TVA licensed nuclear plantsare operating without undue risk to the health and safety of plant personnel and the public.Independent Spent Fuel Storage Installation (ISFSI) -A complex designed andconstructed for the interim storage of spent nuclear fuel, solid reactor-related GTCC waste,and other radioactive materials associated with spent fuel and reactor-related GTCC wastestorage.
An ISFSI, which is located on the site of another facility, licensed under 1OCFR72or a facility licensed under 1OCFR50 and which shares common utilities and services withthat facility or is physically connected with that other facility may still be considered independent.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 84 of 137%cr%/61 5.0 DEFINITIONS (continued)
- Inspection
-A phase of quality control performed by certified inspection personnel or otherqualified individuals approved by QA that, by means of examination, observation, and/ormeasurement determines the conformance of materials,
- supplies, components, parts,appurtenances,
- systems, processes, or structures to predetermined quality requirements.
Installed Compliance Instrumentation and Control (I&C) Devices -Process instruments which are used to determine or verify compliance with plant technical specification requirements for parameters such as flows, pressures, temperatures, levels, voltages, andcurrents.
Item -Any level of unit assembly, including structure, system, subsystem, subassembly, component, part, or material.
Line Verification
-A routine verification by a qualified individual who is in the work-performing organization who did not perform or directly supervise the activity to be verified.
Examples:
second-party verification where a participating craftsman verifies that work and/ortesting has been accomplished.
Measuring and Test Equipment (M&TE) -Equipment or devices used to calibrate,
- measure, gauge, examine,
- compare, test, inspect,
- monitor, or control in order to acquiredata to determine compliance with design, specification, licensing, or other established requirements.
M&TE includes both laboratory and portable instruments, gauges, tools,fixtures, test or analytical test stands, reference and transfer standards, nondestructive examination equipment, etc., where data obtained will be used to determine acceptability orbe the basis for design or engineering evaluations.
Nonsafety-Related Anticipated Transient Without Scram (ATWS) -Special features that,as referenced in 10 CFR 50.62, fall into a category of items which could be related to anexpected operational transient (such as loss of feedwater, loss of condenser vacuum, orloss of offsite power to the reactor) which is not accompanied by the reactor trip systemshutting down the reactor.Notification Point -A specific preestablished point within a selected activity where workmay proceed after contacting and receiving concurrence from the organization responsible for the notification point.Nuclear Plant Security
-A program which provides controls to ensure continued operability of security equipment and the integrity of nuclear plant security.
This includes prevention ofsabotage, safeguard information and material, plant access, and physical security events.Operational Phase -That period of time during which the principal activity is associated with normal operation of the plant. This phase of plant life is considered to begin formallywith receipt of the operating license onsite and ends with commencement of plantdecommissioning.
In addition, there are certain preoperational activities (for example,testing,
- training, maintenance) proceduralized in accordance with operations NQAPrequirements and initiated by the operations staff prior to receipt of the operating licensewhich are considered to be operational phase activities at the time these activities begin.Post maintenance Tests -Testing performed after completion of maintenance to verify theoperational/functional acceptability of components/systems upon completion ofmaintenance.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 85 of 137%cr%1 5.0 DEFINITIONS (continued)
Post modification Tests -Tests performed after completion of a plant modification todemonstrate conformance with as-designed requirements and to determine the effect of themodification on the overall system.Preoperational Tests -Tests identified in a facility's Safety Analysis Report and performed on any system or plant feature for the purpose of proving its ability to perform its designedfunction.
-Contractually binding documents that identify and define therequirements that items or services must meet in order to be considered acceptable by thepurchaser.
Programs
-Programs which administer and control activities and associated features asidentified in Section 5.1B of this Program that require control based on regulatory requirements or TVA commitments.
Quality Assurance Records -Those records which furnish documentary evidence of thequality of items and of activities affecting quality.
A document is considered to be a QArecord when the document has been completed.
Quality Control Inspectors
-Personnel whose qualifications are not required to meet thosespecified in ANSI N18.1 and who are performing inspection, examination and testingactivities during the construction or operational phases of the plant shall be qualified to ANSIN45.2.6-1978 as certified Quality Control Inspectors.
Quality-Related
-Quality-related is a term which encompasses quality assurance programrequirements that describe activities which affect structures,
- systems, and components.
These requirements provide reasonable assurance that the facility can be operated withoutundue risk to the health and safety of the public. In addition to safety-related structures,
- systems, components, and activities, the term "quality-related" encompasses the broadclass of plant features covered (not necessarily explicitly) in the General Design Criteria of10 CFR 50, Appendix A, that contribute in an important way to the safe operation andprotection of the public in all phases and aspects of facility operation (i.e., normal operation and transient control as well as accident mitigation).
Radioactive Material Shipment
-A program that provides controls for handling and/orshipping of radioactive material (NRC-licensed packages only).Radwaste Management
- Systems, Structures, and Components
-Special featurescontaining radioactive materials (i.e., liquids, gases, or solids) that, by design or operating
- practice, provide a means of processing prior to final disposition.
Reference Standards
-Standards (primary, secondary, and working standards whereappropriate) used in a calibration program.
These standards establish the basic accuracylimits for the calibration program.Reportable Events -Any of those conditions specified in 10 CFR 50.73.
Safety-Related Structures,
- Systems, and Components
-Those items that are necessary to ensure:A. The integrity of the reactor coolant pressure boundary.
B. The capability to shutdown the reactor and maintain it in a safe condition.
C. The capability to prevent or mitigate the consequences of accidents which could resultin potential offsite exposures comparable to the applicable guideline exposures setforth in 10 CFR 50.34(a)(1) or 10 CFR 100.11, as applicable.
Seismic Category I(L) -Special features that apply to nonsafety-related systems,structures, and components which provide structural integrity in preventing damage to asafety-related system, structure, and component in case of a failure and/or damage during asafe shutdown earthquake (SSE).Significant Adverse Condition
-A documented adverse condition that is determined to bea QA programmatic deficiency.
Criteria for significance are specified in the corrective actionprogram.Special Nuclear Material Management
-A program which provides for special nuclearmaterial (SNM) control and accountability as required by 10 CFR 70, 74, and 75. Thisprogram includes SNM inventories and system reviews, inspections, records management, and DOE/NRC inventory and transfer reports.Special Tests -A test that is (a) an engineering test including qualification testing for designverification or evaluation of components, structures, or systems, (b) a general test that is notspecifically related to plant systems or features, such as the material testing and producttesting that is normally performed by a testing lab, or (c) tests or experiments not described in the facilities Safety Analysis Report which may affect the operation of systems described therein (reference 10 CFR 50.59 and 10 CFR 72.48).Startup Tests -Those tests as identified in the Final Safety Analysis Report that commenceafter receipt of an operating license allowing fuel loading and testing at ranges through zeropower, power escalation, and 100% warranty run. Startup tests prove that the unit has beenproperly designed and constructed and will meet all licensing requirements and specificcontractual criteria.
Startup tests are also referred to as Power Ascension Tests.*Storage
-The act of holding items at the construction or operating Site in an area otherthan its permanent location in the plant.Surveillance Tests -Periodic tests to verify that structures,
- systems, and components continue to function or are in a state of readiness to perform their functions.
Test Record Drawings
-A set of as-constructed drawings which depict the configuration ofa system as tested.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 87 of 137%cr0/%1 5.0 DEFINITIONS (continued)
Test Scoping Documents
-Documents which include descriptions of each test to beperformed including safety precautions to be followed, specific identification of testobjectives, the means of performing the test, prerequisites that must be completed, environmental conditions required for testing, justification for a proposed degree ofsimulation less than full simulation, and specific acceptance criteria or a description of themeans of determining acceptance criteria from functional testing requirements.
Test Deficiency
-Any condition during which the equipment or system being tested: (1)fails to operate (e.g., pump will not operate, no control room annunciation),
(2) operates in asuspected adverse manner (e.g., motor operates but smokes, questionable vibration),
or (3)operates outside limits of documented acceptance criteria (e.g., inadequate flow, slow valveclosure time).Trend Analysis
-Evaluation of data that has been compiled or grouped onto charts,diagrams,
- reports, or other formats such that the prevailing tendency of selected parameters can identify areas that need improving and areas of past successes.
- Verification
-An act of confirming, substantiating, and ensuring that an activity or condition has been implemented and accomplished in conformance with specific requirements.
Thisincludes line verifications.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 88 of 137Appendix A(Page 1 of 1)Comparison Matrix of Quality Assurance Program Requirements with those of 10 CFR 50,Appendix B, 10 CFR 72, Subpart G, and Selected ANSI Standards 10 CFR 50, Appx BCriterion NQAPI 4.0; 4.1II 5.0III 7.0IV 8.1V 6.0; 7.0; 9.9VI 6.0; 7.0; 9.910 CFR 72,Subpart G72.14272.14472.14672.14872.15072.152ANSI N45.2 -1971Section NQAP2.0 5.03.0 4.0; 4.14.0 7.05.0 8.16.0 6.0; 7.0; 9.97.0 6.0; 7.0; 9.9ANSI N18.7 -1976Section NQAP3.1 4.1; 5.03.2 4.0; 4.13.3 11.03.4 4.0; 11.04.0 4.1.8C; 5.3;6.04.1.7; 9.9;12.0VIIVillIXXXlXIIXillXIVXVXViXVIlXVill8.28.39.39.19.49.59.69.710.010.06.312.072.15472.15672.15872.16072.16272.16472.16672.16872.17072.17272.17472.1768.09.010.011.012.013.014.015.016.017.018.019.08.28.39.39.19.49.59.69.710.010.06.312.05.15.2.15.2.25.2.35.2.45.2.55.2.65.2.75.2.85.2.95.2.105.2.115.2.125.2.135.2.145.2.155.2.165.2.175.2.185.2.195.35.3.15.3.25.3.35.3.45.3.55.3.65.3.75.3.85.3.95.3.105.04.06.06.06.06.06.0; 9.76.0; 9.86.0; 9.1; 9.45.1; 6.04.1.2; 6.06.0; 10.06.0; 6.36.0; 8.0; 9.66.0; 10.06.06.0; 9.56.0; 9.16.0; 9.36.0; 9.46.06.06.06.06.06.0; 9.86.0; 5.16.0; 9.56.0; 5.16.0; 5.16.0; 9.1; 9.4 TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 89 of 137Appendix B(Page 1 of 28)Regulatory Guide Conformance StatusTable 1 (pages 1 through 10) is a matrix of the source requirement documents (e.g., Regulatory Guides and ANSI Standards) which apply to applicable portions of the NQA programdescription.
Table 1 specifies the particular sections of the source documents (e.g., ANSI N18.7, Section 5.2.12) that establish mandatory
- controls, which must be addressed in thedevelopment of the associated implemented programs and procedures.
Table 2 (pages 11 through 29) identifies alternatives to sections of the source requirement documents listed in Table 1.TABLE I0 EC) M CL2 8 E >O 0 a aa)ANSI a) -a1.71,and 4))C C) W Cw L) 5ca (n Do 4) MA 2 3. -198M,0 2 M wC) vC 12 Wo (U c.ca =Co a s 0. $? 0V) 0 a aVS F4) I-V (U2a~. a- ~C) 0 0( E 0 ClE -5a 4) E .8 a~ T 0 7PSOURCE REQUIREMEN
- 0. 00 2LW : un X S 0 aDOCUME<NT 6.1.4 6.2.4 6.3.4 7.4 8.1.4 8.2.4 8.3.4 9.1.4 9.3.4 9.4.4 9.5.4 9.6.4 9.7.4 9.8.4 10.4 11.4 12.4 13.4 15.0Reg. Guide 1.8 R/2 April 1987 X xANSI N18.1 -1971, andANSI/ANS 3.1 -1981,"Personnel Selection
& Training" Reg. Guide 1.33 R/2 X X X X X X X X X X X X X X X X XFebruary 1978ANSI N18.7 -1976/ANS-3.2, Sect. 5 Sect. Sect. Sect. Sects. Sect. Sect. Sects. Sects. Sects. Sect. Sect. Sects. Sects. Sects. Sect. Sect."Administrative Controls and Quality Assurance 5.2.15 5.2.12 5.2.7.2 5.2.13 5.2.13.2 5.2.13.3 5.2.8 5.2.12 5.2.8 5.2.16 5.2.13.4 5.2.6 5.2.7 5.2.11 3.3 4.5forthe Operational Phase of Nuclear Power 5.2.13.1 5.2.17 5.2.18 5.2.19 5.2.8 5.3.5 5.2.14Plants" 5.2.14Reg. Guide 1.28 R/3 X X X X X X X X X X X X X X X XAugust 1985ANSI N45.2 -1971 Sect. 6 Sect. 7 Sect. Sect. 4 Sect. 5 Sect. 6 Sect. 9 Sect. Sect. Sect. Sect. Sect. 14 Sect. Sects. Sect. 2 Sect. 19"Quality Assurance Program Requirements for 18 11 10 12 13 15 16Nuclear Power Plants" 17 TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 90 of 137Appendix B(Page 2 of 28)Regulatory Guide Conformance StatusTABLE 1* c 0 ) _ So 8 c o " _0) o oReg.Guie 130 /0 X) X2) 50-. 0 0 0E '5 09 a)0A 2 3 Sect* 9C 0 a) C 0 3 2 21C o y A 2.2 0 0 2.5Rg. E X XX CXANSI N aecs. Sect. aSec 64:~c C9 -6 .w ) 0 aS pteme W 1a) 0 MCLC -) 2-- N a M 3.3a) 0)O 0 ID~ofL 0ula Poe PlatsE a) o) -E o- C5 0P 0 t) 0O. l a) Z' 12 2 :5 *L 2 ~ ~Z0 a ) 2 a) ~-a)SOURCE REQUIREMEN no 0 L 8~ W' :2 8 59 0, M U) 0 4)DOCU<MENT 6.1.4 16.2.4 6.3.4 17.4 8.1.4 18.2.4 8.3.4 19.1.4 9.3.4 19.4.4 9.5.4 19.6.4 9.7.4 19.8.4 10.4 111.4 12.4 113.4 15.0Reg. Guide 1.37 R/O X X X X X X XMarch 16, 1973ANSI N45.2.1 -1973, Sects. Sect. 9 Sect. Sect,"Cleaning of Fluid Systems and Associated 2.1 2.5 2.5Components During Construction Phase of 2.2Nuclear Power Plants"Reg. Guide 1.38 R/2 X X X X X X X X XMay 1977ANSI N45.2.2 -1972 Sects. Sect. 8 Sect. 5 Sects. Sects. Sect. Sect. 6"Packaging,
- Shipping, Receiving.
Storage.
and 2.1 5.2 2.3 2.5Handling of Items for Nuclear Power Plants 2.2 7.4 2.5(During the Construction Phase)"Reg. Guide 1.39 R/2 X X X XSeptember 1977ANSI N45.2.3 -1973 Sects. Sect 4 Sect. 3.3"Housekeeping During the Construction Phase 2.1,2.2of Nuclear Power Plants" TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 91 of 137Appendix B(Page 3 of 28)Regulatory Guide Conformance StatusTABLE 1z .~C 0 C-0)' £ £ C.- )0 W> U. 0L')-0 o 0 0 0oa~.- )) 0.0 r- (-1 5 )Cz 2C/) .0 0S£0 o. ..° ....~ G d 0 .., oSOURCE REQUIREMENT
- a. o u o i 8~ "" a < 8L, -0 ra v 8DOCUMENT 6.1.4 6.2.4 6.3.4 7.4 8.1.4 8.2.4 8.3.4. 9.1.4 9.3.4 9.4.4 g.5.4 9.6.4 9.7.4 9.8.4 10.4 11.4 12.4 13.4 15.0Reg. Guide1,3000 X X X X X X X X X XAugust 11, 1972AN~SI N45.2.4 -1972, Sects. Sect. Sect. 8 Sect. 2.2 Sects. Sect. Sect. 2.2"Installation, Inspection, and Testing 2.1 2.3 2.4,5.1 2.6Requirements for Instrumentation and Electric 2.3 6.1,7.0Equipment During the Construction of NuclearPower Generating Stations" Reg. Guide1.94 Ra1 X X X X X X X XApril 1976ANSI N45. 2.5 -1974 Sect. Sect. Sect. 7 Sect. 7 Sects. Sect. Sects.Supplementary Quality "Assurance 2.1 2.2 2.3, 2.5 3,Requirements for Installation, Inspection, and 2.2 4, 4,Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear 6Power Plants"Reg. Guide 1.58 R/ XSeptember 1980ANSI/ASME N45.2.6 -1978 Sect. 6"Qualifications of Inspection, Examination, andTesting Personnel for Nuclear Power Plants" TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 92 of 137Appendix B(Page 4 of 28)Regulatory Guide Conformance StatusTABLE Iz4o -.--c -o C 0) o r 0 CDSO 0 R) a) C1 -00o a) *20F_ W' 3§a) 0cIpiaTt oM nl) 5.1 > .5-Octbe 219761e fr 00 a a) M4a) a)aANSI N45U20 a) 1 _ 3Qaiysu 0 ance T n iReg. Guid 1.64 RMC. 25 0 : ' a )NL -a. S0 W 11 0<f L ) 'i -tC 0C% E) a) Ea)SZ o NE L Plan > ts)SOURCE REQUIREMEN 0 0.- 222 2, rDOCUMENT 6.1.4 6.2.4 6.3.4 7.4 8.1.4 8.2.4 8.3.4 9.1.4 9.3.4 9.4.4 9.5.4 9.6.4 9.7.4 9.8.4 10.4 11.4 12.4 13.4 15.0Reg. Guide1. 116 R/O-R X X X X X X X X X X XJune 1976ANSI N45.2.8 -1975, -Supplementary Quality Sects. Sect. Sect. 7 Sect. 7 Sects. Sect. Sects. Sects. Sects.Assurance Requirements for Installation, 2.1 2.2 2.3, 2.8 2.5 4.2 3.1Inspection, and Testing of Mechanical 2.2 3 5.1 3.5-HEquipment and Systems for the Construction 4, 4.5-8,CPhase of Nudlear Power Plants"5Reg. Guide 1.88 R12 X X XOctober 1976ANSI N45.2.9 -1974 Sects."Requirements for Collection,
- Storage, and 4.2,maintenance of Quality Assurance Records for 6.2Nuclear Power Plants" 7.211Reg. Guide 1.74 XFebruary 1974ANSI N45.2.10O-1973"Quality Assurance Terms and Definitions" Reg. Guide 1.64 R/2 X X X XJune 1976ANSI N45.2.11
-1974 Sects. Sect. 11 Sect.'Quality Assurance Requirements for the 2.2.7 6.1Design of Nuclear Power Plants" TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 93 of 137Appendix B(Page 5 of 28)Regulatory.Guide Conformance StatusTABLE I-0C) C 0 0Ia,-C n , OC). r CO. .0 00) -0 .U ) C) 'SORERQIEET 0- 8 8 )o C 0-" C) < 0wU 2 CC > 0 (C1V03)C)2 0-0 2.V r CC)Reg. Gude 1V1CR/1ANSIC N45.2.12
-1977.0 V C C CL) 0 00C, Gui0e 0.123 R/1 V5 XEXXCLC 0 E -C C .9 )To~ C CC, C, (L 'C) 0 C. 2~ 0c 0 0)0CD 0)C E) a).ANSIN452.1-.176 ect 2 ect Sec. SCs VSect.C)
~00 0 0. a) 'a .D C, C,SOURCE REQUIREMEN 0- a (L W3f -~ .0 i.- U%& EEO9 0 :2 :2<80 <DOCUMENT 6.1.4 6.2.4 6.3.4 7.4 8.1.4 8.2.4 8.3.4 9.1.4 9.3.4 9.4.4 9.5.4 9.6.4 9.7.4 9.8.4 10.4 11.4 12.4 13.4 15.0Reg. Guide 1.144 R/ XSeptember 1980ANSI N45.2.12
-1977'Requirements for Auditing of QualityAssurance Programs for Nuclear Power Plants"Reg. Guide 1.123R11 X X X X X X XJuly 1977ANSI N45.2.13
-1976 Sect. 2 Sect. Sect. Sects. Sect."Quality Requirements for Control of 11 3.0 7 7.4Procurement of Items and Services for Nuclear 10Power Plants"Reg. Guide 1.146 R/O X xAugust 1980ANSI N45. 2.23 -1978"Qualification of Quality Assurance ProgramAudit Personnel for Nuclear Power Plants"Reg. Guide 1.152 XNovember 1985 ScsANSI/IEEE-ANS-7-4.3.2
-1982, Scs'Application Criteria for Programmable Digital 6Computer Systems in Safety Systems of 7Nuclear Power Generating Stations" TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 94 of 137Appendix B(Page 6 of 28)Regulatory Guide Conformance StatusTABLE 1°G0~ CL0_ a >ui WOV M CL a).4 c*~ a)0 ) 0 9 .0 E z C -.- -_ -0 C 6.0 S2l 22 _ Ci) a)a 4) E -P .0oC 0 M n E a) Z a) Q, 0 aO Vf Q. t, > E .Ca_ _ 2 2 = 00 a0a 2 o D- a), M. 0 0~ M, M 0 a,-SOURCE REQUIREMEN 0- o .Q. ,,, L ,, -r o)o < o oDOCUMENT 6.1.4 6.2.4 6.3.4 7.4 8.1.4 8.2.4 8.3.4 9.1.4 9.3.4 9.4.4 9.5.4 9.6.4 9.7.4 9.8.4 10.4 11.4 12.4 13.4 15.0Reg. Guide 1.189, April 2001 X"Fire Protection for Operating Nuclear PowerPlants" 1.7.10.110 CFR 21 X X X10 CFR 50 X X X X X X X X X X X X X X X X XAppendix BCrit. V Crit. VI Cdt. Crit. III Crit. IV Crit. VII Crit. VIII Crit. X Crit. IX Crit. XI Crit. XII Crit. XIII Crit. Crit. Crit. II Crit.XVII XIV XVXVI XVIII10 CFR 50.49 X X X10 CFR 50.55a X10 CFR 50.55e X10 CFR 50.59 X X10CFR 72.4810 CFR 50.72 X TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 95 of 137Appendix B(Page 7 of 28)Regulatory Guide Conformance StatusTABLE 10 Q.0 0 V 10 U.2 Co0 E "2 -1 010 CF '_0 0 70 -' E 4~ )0o10 CF 500120 EU) a) U) 00 TU * ) (1310 CFM7E a) V. XASM Eet IX- =X)a) 2 U)U M 16 U) 0 2 D (SORERQIEE
-2 0 a. Lu : U c n ) 0 2a10 0F 5012 E Xo~ 0 0UASME Sect. II, R le fo Inevc Inspectio X X X X X X XofM SetNX,'ulesafr Pow ervPlantspeto" of) N u l a 0o e Pla ts 0 TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 96 of 137Appendix B(Page 8 of 28)Regulatory Guide Conformance StatusTABLE 1z (C 00-T 0 .9 00 0 ) .2-o-,,,. o0 .~o0 0 0 0 W-o 0, -Eo Ca o0oo-O- C o0 V REURMNT,,Q 0 -0 o° C o < < oLi2 0 *oO a) COCI a) L) 0 0-a_ (D 0 .E jSU rAWS, "StruCctural Welding0Code D1.1" X4) 00 wAS0 X a a .0C"Personna Quliiato ano Cetcto Cn0L C) 2 2 M 2>. C 0 00ca) 0 0) E 0 4) oE C .2 0 0 00 0) 0~~SOURCE REQUIREMEN 02 Uu :2 -0 20 5DOCUMENT 6.1.4 16.2.4 16.3.4 7.4 18.1.4 8.2.4 18.3.4 9.1.4 19.3.4 9.4.4 19.5.4 9.6.4 19.7.4 9.8.4 110.4 11.4 112.4 13.4 115.01AWS, *Structural Welding Code D1." XAISC, X"Specification for the Design. Fabrication, andErection of Structural Steel for Buildings"
- ASNT XSNT-TC-IA-1984 "Personnal Qualification and Certification inNondestructive Testing"Plant Technical Specifications (Administrative XControls Section)NUTAC Report on Generic Letter 83-28, X X X X"Required Actions Based on GenericImplications of Salem ATWS Events,"
Section2.2.2 (letter from L. M. Mills to H. R. Dentondated September 17, 1984)
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 97 of 137Appendix B(Page 9 of 28)Regulatory Guide Conformance StatusTABLE 1U) a o o =, Cz -o C o0 _o A? 0 0c o 8 E3§0uia 2 E, U)~ cU)0CI-ASN CP 189-19912n M Qi 0nd Certifi 0 ato VNodsrcie ig 2: 2e)Vs. E 0 Q a. M C00 0CO a .)0 0 CW-6 00 -0 C, _- 0) -(ASME 2 Ca 0o C Operati) 76 an Xa X XZ nacrac ihAM Coe Se tio I, Diiio1 .19 Ediio U)t Adena hrug 19 (19/9), CriceUWA Paagp IWA2' M U) ) Q. U) M U)n 0 U)SOURCE 0EUREE 0. (a 0 w ~ ~ a C 0 < 0 <0 0DOCU<MENT 6.1.4 16.2.4 6.3.4 17.4 8.1.4 18.2.4 8.3.4 19.1.4 9.3.4 19.4.4 9.5.4 19.6.4 9.7.4 19.8.4 10.4 111.4 12.4 113.4 15.01ANSpASNT CP-189-1991 X"Standard tor Qualification and Certification ofNondestructive Testing Personnel" ASME OM Code "Code for Operation and X X X XMaintenance of Nuclear Power Plants"I*In accordance with ASMVE Code, Section Xl, Divisioni, 1995 Edition with Addenda through 1996 (1995/A96),
Article IWA, Paragraph IWA,2310, "Personnel performing nondestructive examination (NDE) shall be qualified in accordance with ANSI/ASNT CP-189 ... Certifications basedon SNT-TC-1 A are valid until re-certification is required.
Re-certification shall be in accordance with ... ANSI/ASNT CP-189..."
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 98 of 137Appendix B(Page 10 of 28)Regulatory Guide Conformance StatusTable 2REGULATORY GUIDE CONFORMANCE STATUSNRC Regulatory Guide 1.8 -"Personnel Selection and Training,"
Revision 2, 4/87, endorses ANSIN18.1-1971 and ANSI/ANS 3.1-1981.
The Nuclear Quality Assurance Plan (NQAP) follows this Guide with the following alternatives:
- 1. TVA will meet the requirements of Regulatory Guide 1.8, Revision 2 (4/87) for all new personnel qualifying on positions identified in regulatory position C.1 after January 1, 1990. Personnel qualified on these positions prior to this date will still meet the requirements of Regulatory Guide1.8, Revision 1-R (5/77). As specified in regulatory position C.2, all other positions will meet therequirements of ANSI/ANS N18.1-1971.
- 2. Section 4.3.2 -There may be occasions where TVA will utilize a composite crew (multidiscipline) during operations phase activities to efficiently perform a task. As such, a foreman may not havethe experience required in one of the disciplines he supervises.
In these instances, the foremanwill meet the requirements of ANSI N18.1 in at least one of the disciplines, and additional technical
- support, procedure
- support, and/or discipline support will be available to the foremanfor the task period.3. In lieu of the training guidelines endorsed by Regulatory Guide 1.8, Revision 2, specified inRegulatory Position Sections C. 1 .b and C. 1 .f, TVA shall comply with the requirements of 10 CFR55.31(a)
(4) and 10 CFR 55.59 as they apply to training programs based on a Systems Approachto Training (SAT) as defined in 10 CFR 55.4 and using a plant-referenced simulator as requiredby 10 CFR 55.45.4. TVA uses the methodology for equating education and experience contained in ANSI 3.1-1987for guidance to evaluate equivalent related experience for a degree.5. In addition to the training guidelines in subsections 5.3.2, 5.3.3, 5.3.4, and 5.5 of ANSI N18.1-1971, TVA shall comply with the requirements of 10 CFR 50.120 as it applies to trainingprograms based on a systems approach to training.
- 6. In lieu of the one year of experience in the implementation of the quality assurance program forSite Quality Assurance Managers (ANSI/ANS 3.1-1981, Section 4.4.5.b),
TVA requires five yearsexperience in QA-related activities.
NRC Regulatory Guide 1.28 -"Quality Assurance Program Requirements (Design and Construction),"
Revision 3, 8/85, allows continued implementation of ANSI N45.2-1971 as previously committed.
The NQAP follows this Guide.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 99 of 137Appendix B(Page 11 of 28)Regulatory Guide Conformance StatusTable 2REGULATORY GUIDE CONFORMANCE STATUSNRC Regulatory Guide 1.30 -"Quality Assurance Requirements for the Installation, Inspection, andTesting of Instrumentation and Electric Equipment,"
8/72, endorses ANSI N45.2.4-1972.
The NQAP follows this Guide with the following alternatives:
- 1. ANSI N45.2.4 states that the Appendixes are not a part of the standard; therefore, TVA does notconsider the Appendixes to be mandatory.
- 2. Section 2.1, "Planning"
-The intent of this section shall be met in different forms depending onmagnitude and scope of work.3. During the operational phase, tests are performed as determined by the site engineering organization, modification, or maintenance engineers, as appropriate, based upon the equipment or system functions that could be impacted by the work performed.
- 4. TVA's alternative to the tagging of in plant process instruments for calibration status (ANSIN45.2.4, Section 6.2.1) is that each item of process control instrumentation is uniquely identified with an instrument number. This number is utilized in an instrument maintenance record so thatthe current calibration status and data attesting to the status of each item are documented alongwith the identification of the person performing the calibration.
In addition, this record systemprovides a mechanism for evaluating equipment performance and adjusting calibration frequencies to ensure quality performance.
- 5. Section 6.2.2 -For modifications, TVA interprets this section as not requiring that an entiresystem be retested after modifications.
Testing will be performed on equipment that has or couldbe impacted by the modification in accordance with applicable design and testing requirements toverify that operability requirements are met and that interfacing components and equipment functions have not been degraded.
- 6. TVA implements the requirements of N45.2.4 Sections 5.1 and 6.1 with a performance-based graded QA verification program consisting of quality control inspection, line verification, andquality assessments.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 100 of 137Appendix B(Page 12 of 28)Regulatory Guide Conformance StatusTable 2REGULATORY GUIDE CONFORMANCE STATUSNRC Regulatory Guide 1.33 -"Quality Assurance Program Requirements (Operations),"
Revision 2,2/78 endorses ANSI N18.7-1976/ANS 3.2.The NQAP follows this Guide with the following alternatives:
- 1. ANSI N18.7-1976 references certain other standards to which TVA takes exception.
TVA'sexception and appropriate alternatives to the other standards are listed in this Appendix in theappropriate location.
- 2. Section 5.2.2 -The guidelines of this section are accepted with the following interpretations:
- a. Temporary changes which clearly do not change the intent of the approved procedure shallas a minimum be approved by two members of the plant management staff, at least one ofwhom holds a Senior Reactor Operator License on the unit affected or as defined in Section9.9 of this Program, the FSAR, or appropriate plant procedures.
- b. For facilities holding a construction permit where system(s) and/or components have beenreleased to the operations organization, temporary changes to procedures, as described above, shall as a minimum be approved by two members of the plant management staff, atleast one of whom shall be a designated member of the plant operations management staff.3. Section 5.2.13.1
-The statement that changes made to procurement documents be subject tothe same degree of control as was used in the preparation of the original documents is appliedconsistent with the requirements of ANSI N45.2.1 1, paragraph 7.2. Minor changes todocuments, such as inconsequential editorial corrections or changes to commercial terms andconditions, may not require that the revised document receive the same review and approval asthe original documents.
- 4. Section 5.2.15 -The guidelines of this section are accepted with the following alternatives:
- a. Minor changes to documents are processed as delineated in Section 6.1.2F.3 of thisProgram.b. TVA has programmatic controls in place that make a biennial review process unnecessarily duplicative.
These programmatic controls ensure procedures are periodically reviewed andmaintained current when pertinent source material is revised; the plant design changes;and/or any deficiencies occur. TVA has determined that this approach better addresses thepurpose of the biennial review process and that, from a technical and practical standpoint, isbetter suited to ensure the validity of operational phase site procedures and instructions.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 101 of 137Appendix B(Page 13 of 28)Regulatory Guide Conformance StatusTable 2REGULATORY GUIDE CONFORMANCE STATUS5. Section 5.2.17 -The statement that deviations, their cause, and any corrective action completed or planned shall be documented will apply to significant deviations.
Other identified deviations will be documented and corrected.
This interpretation is consistent with Appendix B to 10 CFR50, Criterion XVI, "Corrective Action."6. TVA will comply with regulatory position C.4 except that audit frequencies are specified in NQAPSection 12.2E. A grace period not to exceed 90 days will be applied to the biennial frequency forinternal audits described in Section 4.5 of ANSI N 18.7-1976 which states that audits of safety-related activities are completed "within a period of two years." This grace period will not beapplied to audits of the Radiological Emergency Plans to satisfy the requirements of 10 CFR50.54 (t) (1), Security to satisfy the requirements of 10 CFR 50.54 (p) (3) and 10 CFR 73.55 (m),Access Authorization to satisfy the requirements of 10 CFR 73.56 (n) (1) and (n) (2).7. Section 4.3.4.4.c
-The independent review body implements this section by reviewing reportable events that are reported to the NRC in accordance with 10 CFR 50.73.8. When purchasing commercial grade calibration services from certain accredited calibration laboratories, the procurement documents are not required to impose a quality assurance program consistent with ANSI N45.2-1971.
Alternative requirements described in Regulatory Guide 1.123 may be implemented in lieu of imposing a quality assurance program consistent withANSI N45.2-1971.
NRC Regulatory Guide 1.37 -"Quality Assurance Requirements for Cleaning of Fluid Systems andAssociated Components of Water Cooled Nuclear Power Plants,"
3/73, endorses ANSI N45.2.1-1973.
The NQAP follows this Guide with the following alternatives:
- 1. The phrase "when applicable" used in Regulatory Guide 1.37, paragraph C.2, leaves open tointerpretations which specific requirements and recommendations contained in ANSI N45.2.1-1973 are applicable to and achievable during the construction or operation phase. Theinterpretation of "when applicable" will be made with appropriate concurrence in a writtenprocedure before its application.
- 2. The second sentence of paragraph C.3 should be amended to read:"The water quality for final flushes of fluid systems and associated components during theoperations phase shall be at least equivalent to the quality required for normal operation.
Thisrequirement does not apply to dissolved oxygen or nitrogen limits nor does it infer that otheradditives normally in the system water will be added to the flush water."3. Temporary ink markings placed by the fabricator as mill marks may remain on components thatoperate at temperatures greater than 140OF (normal or accident) and have a 40 year integrated radiation dose less than 106 rads.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 102 of 137Appendix B(Page 14 of 28)Regulatory Guide Conformance StatusTable 2REGULATORY GUIDE CONFORMANCE STATUS4. Control of halogen, sulfur, or low-melting metal contents is not required for abrasive tools such asgrinding wheels, cutoff wheels, sanding paper, and flapper wheels. Use of abrasive tools oncorrosion-resistant alloys shall be followed by cleaning with an approved solvent.
Particulate residue shall be removed by vacuum, brush, dry wiping cloth, or air, with special attention tocrevices.
- 5. Temporary tape and markings (ink and paint) may remain on components that operate attemperatures less than 140OF (normal or accident).
- 6. Section 2.1, "Planning
-For operations phase activities, the required planning is frequently performed on a generic basis for application to many systems and component installations.
Thisresults in standard procedures for cleaning, inspection, and testing which meet the requirements of the standard.
Individual plans for each item or system are not normally prepared unless thework operations are unique; however, standard procedures are reviewed for applicability in eachcase. Cleaning procedures are limited in scope to those actions or activities, which are essential to maintain or achieve required quality.
This is consistent with Section 5.2.17, paragraph 5, ofANSI N18.7-1976, which provides for examination, measurement, or testing to ensure quality orindirect control by monitoring of processing methods.7. TVA intends to conform to the cleanness requirements of Section 3.1 of ANSI N45.2.1-1973 withthe exception of permissible particle sizes for cleanness Classes B and D. In these cases, TVAwill conform to the requirements of ANSI N45.2.1-1980, Section 3.2.2.1 (b), which states, "Thereshall be no particles larger than 1/32 inches by 1/16 inches long (0.8 mm by 1.6 mm)" forcleanness Class B, and Section 3.2.4.4 which states, "Particles no larger than 1/16 inch by 1/8inch long (1.6 mm by 3.2 mm) on a 14 mesh (1.4 mm, ASTM E-1 1, "Specification for Wire ClothSieves for Testing Purposes) or finer filter, or the equivalent" for cleanness Class D.NRC Requlatory Guide 1.38 -"Quality Assurance Requirements for Packaging,
- Shipping, Receiving,
- Storage, and Handling of Items for Water Cooled Nuclear Power Plants,"
Revision 2, 5/77 endorsesANSI N45.2.2-1972.
The NQAP follows this Guide with the following alternatives:
- 1. Storage requirements at the site are determined by the responsible engineering unit. Thisdetermination involves an evaluation of the complexity of the item and its importance to safety.The various types of storage are provided (yard, warehouse, humidity controlled, etc.) but theclassification levels of N45.2.2 are not necessarily employed.
- 2. In accordance with ASME QA Case 78-N45.2.2-01-0, welding electrodes hermetically sealed inmetal containers may be stored under conditions described for level C items unless other storagerequirements are specified by the manufacturer.
Storage conditions for level C items may alsoapply to bare wire and consumable inserts unless specified otherwise by the manufacturer.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 103 of 137Appendix B(Page 15 of 28)Regulatory Guide Conformance StatusTable 2REGULATORY GUIDE CONFORMANCE STATUS3. Austenitic stainless steel and nickel alloy items may have markings applied directly to the baremetal surfaces provided the requirements of TVA internal procedures, which control the chemicalcontent of the marking materials, are met.4. Tubing and piping materials shall have end caps or plugs while in storage unless specified otherwise by engineering specification.
End caps or plugs are not mandatory on tube or pipefittings provided the requirements of TVA internal procedures to store under cover with protection from the elements are met. These materials are required to be in a visually clean condition andfree of visually detectable defects prior to installation.
- 5. Section 6.4.1 -TVA will meet this section through periodic inspection of randomly selected storeditems by QC inspection personnel certified to ANSI N45.2.6.
The criteria and factors regarding frequency and degree are established in Section 5.2A and 5.2B of this Program.6. TVA takes exception to ANSI N45.2.2, Section 5.2.1. TVA's alternative is that shipping damageinspection shall be done before unloading if evidence of possible shipping damage would be lostin unloading, such as when the item is secured to the carrier, covered by tarpaulin, accompanied by a visible impact recorder, or when the contract requires any of the above. Personnel performing preliminary visual observations (prior to unloading) per Section 5.2.1 need not bequalified to ANSI N45.2.6.
Item inspections per Section 5.2.2 are performed by personnel qualified to ANSI N45.2.6.
The item inspections also ensure that no damage has occurred duringshipping.
- 7. Section 6.4.2(8)
-TVA will follow either vendor recommendations for preventive maintenance, anengineering evaluation, or engineering requirements documents delineating appropriate maintenance requirements, for items in storage.
Engineering evaluations and engineering requirement documents will consider vendor recommendations.
- 8. Section 6.5 (last sentence)
-During a period of installed storage or extended layup after releaseof an item from permanent
- storage, vendor recommendations for preventive maintenance, or anengineering evaluation or an engineering requirements document delineating appropriate maintenance requirements will be followed.
Engineering evaluations and engineering requirement documents will consider vendor recommendations.
- 9. TVA's alternative to the requirements of Section 6.6 of ANSI N45.2.2 is that Procurement willmaintain written records of pertinent information such as storage location and receipt inspection results and will take necessary action to provide packaging for items not suitably packaged forstorage.
Written records of personnel access to nuclear stores are kept for entry during timeswhen nuclear stores personnel are not on duty. All other times, the storeroom is locked andadmittance is controlled by stores personnel.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 104 of 137Appendix B(Page 16 of 28)Regulatory Guide Conformance StatusTable 2REGULATORY GUIDE CONFORMANCE STATUS10. TVA does not utilize specific levels for classification of items (ANSI N45.2.2, Section 2.7);however, the specific requirements identified in the Standard are used as a guide with respect toprotecting the equipment.
- 11. TVA does not utilize specific levels for packaging (ANSI N45.2.2, Section 3.2). All purchased items have been properly packaged.
Additionally, periodic storage inspections are conducted toensure protective measures specified in the Standard to prevent damage or deterioration arecomplied with and is imposed until the item or component is issued for use. Purchased itemsundergo receiving inspection using the graded approach.
This inspection verifies that items havebeen properly packaged for shipment and will ensure that any special protective measuresspecified in the Standard to prevent damage, deterioration, or contamination will be imposed untilthe item or component is issued for use.12. TVA takes exception to the requirement (ANSI N45.2.2, Section 6.2.4) that salt-tablet dispensers in any storage area shall not be permitted.
TVA Procurement stores salt-tablet dispensers insealed containers for use outside of the storage area only.13. Sections 7.3.2 and 7.4.2 -Use of hoisting equipment beyond its rated load is acceptable whenspecifically approved with technical justification by engineering.
- 14. Section 5.2.2(1)
Physical Properties
-QC Inspectors, Engineers, or other technically competent individuals assure that physical properties conform to specified requirements and that chemicaland physical test reports meet the requirements.
- 15. Section 2.4 -Off-site inspection, examination or testing is audited by personnel who are qualified in accordance with ANSI N45.2.23 rather than ANSI N45.2.6 as stated in the ANSI Standard.
NRC Regulatory Guide 1.39 -"Housekeeping Requirements for Water-Cooled Nuclear Power Plants,"Revision 2, 9/77 endorses ANSI N45.2.3-1973.
The NQAP follows this Guide with the following alternative:
The zone designations of Section 2.1 of N45.2.3 and the requirements associated with each zone arenot consistent with the requirements for an operating plant. Instead, NPG procedures or instructions for housekeeping activities which include the applicable requirements outlined in Section 2.1 ofN45.2.3 and which take into account radiation control considerations, security considerations, fireprotection considerations, and personnel and equipment safety considerations are developed on acase basis.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 105 of 137Appendix B(Page 17 of 28).Regulatory Guide Conformance StatusTable 2REGULATORY GUIDE CONFORMANCE STATUSNRC Requlatory Guide 1.58 -"Qualification of Nuclear Power Plant Inspection, Examination andTesting Personnel,"
Revision 1, 9/80 endorses ANSI N45.2.6-1978.
The NQAP follows this Guide with the following alternatives:
- 1. TVA complies with Regulatory Position C. 1 of this Regulatory Guide, as follows:, Construction testing personnel are qualified to Regulatory Guide 1.28 (ANSI N45.2)., Operations, maintenance, and modification testing personnel are qualified to Regulatory Guide 1.8 (ANSI N18.1) as endorsed in Appendix B of this program description.
, Quality control inspection personnel are qualified to ANSI N45.2.6.2. Certifications may not correspond to the levels established in N45.2.6.
Inspection, examination, and testing personnel may be classified by disciplines (mechanical, civil, electrical, instrumentation, hanger, etc.) and certified by procedure to perform the functions identified inN45.2.6, Tables I, L-1, and L-II.3. Medical eye examinations for inspection,
- testing, and examination personnel are made inaccordance with TVA eye examination requirements.
- 4. TVA complies with Regulatory Position C.2 as follows:
For containment leak rate testingpersonnel, TVA as a minimum will meet the qualification requirements of ANSI N45.2.6 asendorsed by Regulatory Guide 1.58, Revision
- 1.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 106 of 137Appendix B(Page 18 of 28)Regulatory Guide Conformance StatusTable 2REGULATORY GUIDE CONFORMANCE STATUSNRC Re-gulatory Guide 1.64 -"Quality Assurance Requirements for the Design of Nuclear PowerPlants,"
Revision 2, 6/76, endorses ANSI N45.2.11-1974.
The Nuclear Quality Assurance Program follows this Guide with the following alternative to Regulatory Position C.2:If in an exceptional circumstance, the engineer's supervisor is the only person technically qualified to perform the review, the design verification review will be conducted by the supervisor, provided that:1. The other provisions of this Regulatory Guide and ANSI N45.2.11, Section 6.1 are satisfied.
- 2. The justification is individually documented and approved in advance by the supervisor's management.
- 3. QA will audit the use of supervisors as design verifiers to guard against abuse.NRC Regulatory Guide 1.74 -"Quality Assurance Terms and Definitions,"
2/74, endorses ANSIN45.2.10-1973.
The NQAP follows this Guide with applicable alternatives noted in Section 15.0 of this Program.NRC Regulatory Guide 1.88 -"Collection,
- Storage, and Maintenance of Nuclear Power Plant QualityAssurance Records,"
Revision 2, 10/76, endorses ANSI N45.2.9-1974.
Requirements of Regulatory Guide 1.88 (and the alternatives listed below) apply to 10 CFR 72required records including:
Records required by 10 CFR 72 must be maintained in duplicate storage.The NQAP follows this guide with the following alternatives:
Section 2.2.1 -TVA may also define lifetime QA records to be "life of the nuclear liability policy, plusthe subsequent 10 years during which claims may be covered by the policy."
This definition isconsistent with ANI/MAELU Information Bulletin 80-1A, Revision 2, and the requirements of ournuclear insurer.Section 5.4.3 -In order to preclude deterioration, manufacturer's packaging and storagerecommendations for special process records will be considered.
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 107 of 137Appendix B(Page 19 of 28)Regulatory Guide Conformance StatusTable 2REGULATORY GUIDE CONFORMANCE STATUSSection 5.6 -TVA will provide two-hour minimum fire-rated protection for QA records and utilize one ofthe following alternatives as single storage facilities:
- 1. A fire-resistive vault or file room that meets the applicable requirements of ANSI N45.2.9-1974 with the following exceptions:
- a. Records will be afforded the protection of a two-hour rated facility.
- b. Records will be stored in fully enclosed cabinets.
- c. Structure, doors, frames, and hardware shall be designed to fully comply with a minimumtwo-hour rating.d. Pipes or penetrations will be allowed for fire protection,
- lighting, temperature, humiditycontrol, or communications.
- e. Work not directly associated with records storage or retrieval will be prohibited in the facility.
- f. Smoking and eating/drinking will be prohibited throughout the records facility.
- 2. One-hour fire-rated cabinets if the following conditions are met:a. The records are recreatable, ORb. Are contained within a facility of fire-resistive construction with adequate smoke detection orfire-suppression systems:
ORc. Are within a facility with a fuel loading less than 25 pounds/square foot as defined by NFPA232-1980.
QA records may be temporarily stored for 60 days or less in steel file cabinets or drawers if thefollowing conditions are met:1. The records are recreatable, OR2. Are contained within a facility of fire-resistive construction with adequate smoke detection or fire-suppression systems:
OR3. Are within a facility with a fuel loading less than 25 pounds/square foot as defined by NFPA232-1980.
For storage of film and other processed
- records, humidity and temperature controls shall be providedto maintain a stable environment.
Recommendations by the manufacturer will be considered indetermining an acceptable range of tolerance.
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Page 108 of 137Appendix B(Page 20 of 28)Regulatory Guide Conformance StatusTable 2REGULATORY GUIDE CONFORMANCE STATUSIn addition to the records specified in Appendix A to ANSI N45.2.9-1974, the following records andretention times are applicable to WBN:1. Licensee Event Reports required by 10 CFR 50.73 (3 years).2. Records of changes made to the procedures required by NQAP Section 9.9.2B.7.a for WBN only(3 years).3. Records of surveillance activities, inspections, and calibrations required by the Technical Specifications and the Fire Protection Program (5 years).4. Records of sealed source and fission detector leak tests and results (5 years).5. Records of annual physical inventory of all sealed source material of record (5 years).6. Records of reactor tests and experiments (lifetime).
- 7. Records of inservice inspections performed pursuant to the Technical Specifications (lifetime).
- 8. Records of quality assurance activities required by the NQAP not listed in items 1 through 5above and which are classified as permanent records by applicable regulations, codes, andstandards (lifetime).
- 9. Records of 50.59 screening reviews and evaluations performed for changes made to equipment pursuant to 10 CFR 50.59 (lifetime).
Records of 50.59 screening reviews and evaluations performed for changes made to procedures or tests and experiments pursuant to 10 CFR 50.59(5 years).10. Records of the reviews required by NQAP Sections 9.9.2 and 4.1.8C (lifetime).
- 11. Records of the service lives of all hydraulic and mechanical snubbers required by Technical Requirement (TR) 3.7.3, "Snubbers,"
including the date at which the service life commences, andassociated installation and maintenance records (lifetime).
- 12. Records of secondary water sampling and water quality (lifetime).
- 13. Records of analyses required by the Radiological Environmental Monitoring Program that wouldpermit evaluation of the accuracy of the analysis at a later date (these records should includeprocedures effective at specified times and QA records showing that these procedures werefollowed (lifetime).
- 14. Records of reviews performed for changes made to the Offsite Dose Calculation Manual and theProcess Control Program (lifetime).
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Page 109 of 137Appendix B(Page 21 of 28)Regulatory Guide Conformance StatusTable 2REGULATORY GUIDE CONFORMANCE STATUS15. Records of steam generator tube surveillance (lifetime).
In addition to the records specified in Appendix A to ANSI N45.2.9-1974, the following records andretention times are applicable to SQN:1. Licensee Event Reports required by 10 CFR 50.73 (five years).2. Records of surveillances activities, inspections and calibrations required by the Technical Specifications (five years).3. Records of changes made to the procedures required by NQAP 9.9.2A.2 for SQN only (fiveyears).4. Records of sealed source and fission detector leak tests and results (five years).5. Records of annual physical inventory of all sealed source material of record (five years).6. Records of gaseous and liquid radioactive material released to the environs and the resulting calculated dose to an individual member of the public (lifetime).
- 7. Records of reactor tests and experiments (lifetime).
- 8. Records of in-service inspections performed pursuant to the Technical Specifications (lifetime).
- 9. Records of 50.59 screening reviews and evaluations performed for changes made to equipment pursuant to 10 CFR 50.59 (lifetime).
Records of 50.59 screening reviews and evaluations performed for changes made to procedures or tests and experiments pursuant to 10 CFR 50.59(5 years).10, Records of analyses required by the radiological environmental monitoring program (lifetime).
11, Records of secondary water sampling and water quality (lifetime) 12 Records of the service life monitoring of all safety-related hydraulic and mechanical
- snubbers, required by Technical Specification 3.7.9, including the maintenance performed to renew theservice life (lifetime).
- 13. Records for Environmental Qualification which are covered under the provisions of Paragraph 2.c(12) (b) of License No. DPR-77 (lifetime).
- 14. Records of reviews performed for changes made to the OFFSITE DOSE CALCULATION MANUAL and the PROCESS CONTROL PROGRAM (lifetime).
- 15. Records required by 10 CFR 72 (retained for the life of the Storage Cask License).
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Page 110 of 137Appendix B(Page 22 of 28)Regulatory Guide Conformance StatusTable 2REGULATORY GUIDE CONFORMANCE STATUS16. Records of screening reviews and evaluations performed for changes made to spent fuel storagecask design, procedures, tests or experiments pursuant to 10 CFR 72.48 (retained for the life ofthe Storage Cask License).
In addition to the records specified in Appendix A to ANSI N45.2.9-1974, the following records andretention times are applicable to BFN. These records shall be kept in a manner convenient for review.1. Reportable Events2. Checks, inspections, tests and calibrations of components and systems, including such diverseitems as source leakage.3. Records of 50.59 screening reviews and evaluations performed for changes made to equipment pursuant to 10 CFR 50.59 (lifetime).
Records of 50.59 screening reviews and evaluations performed for changes made to procedures or tests and experiments pursuant to 10 CFR 50.59(5 years).4. Records of screening reviews and evaluations performed for changes made to the facility, spentfuel storage cask design, procedures, tests or experiments pursuant to 10 CFR 72.48 (retained for the life of the Storage Cask License).
- 5. Test results in units of micro curies for leak tests.6. Record of annual physical inventory verifying accountability of sources on record.7. Records of gaseous and liquid radioactive waste released to the environs, and the resulting calculated dose to individual, MEMBERS OF THE PUBLIC8. Reactor coolant system inservice inspection.
- 9. Records required by 10 CFR 72 (retained for the life of the Storage Cask License).
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Page 111 of 137Appendix B(Page 23 of 28)Regulatory Guide Conformance StatusTable 2REGULATORY GUIDE CONFORMANCE STATUS10. Design fatigue usage evaluation.
Monitoring and recording requirements below will be met for various portions of the reactorcoolant pressure boundary (RCPB) for which detailed fatigue usage evaluation per the ASMEBoiler and Pressure Vessel Code Section III was performed for the conditions defined in thedesign specification.
In this plant, the applicable codes require fatigue usage evaluation for thereactor pressure vessel only. The locations to be monitored shall be:1. The feedwater nozzles2. The shell at or near the waterline.
- 3. The flange studs.Transients that occur during plant operations will be reviewed and a cumulative fatigue usagefactor determined.
For transients which are more severe than the transients evaluated in the stress report, codefatigue usage calculations will be made and tabulated separately.
In the annual operating report, the fatigue usage factor determined for the transients definedabove shall be added and a cumulative fatigue usage factor to date shall be reported.
When thecumulative usage factor reaches a value of 1.0, an in-service inspection shall be included for thespecific location at the next scheduled inspection (3-1/3-year interval) period and 3-1/3-year intervals thereafter, and a subsequent evaluation performed in accordance with the rules ofASME Section Xl Code if any flaw indications are detected.
The results of the evaluation shall besubmitted in a Special Report for review by the Commission.
- 11. Reviews performed for changes made to the Offsite Dose Calculation Manual and the ProcessControl Program.Except where covered by applicable regulations, items 1 through 5 above shall be retained for aperiod of at least five years and items 6 through 9 shall be retained for the life of the plant. Acomplete inventory of radioactive materials in possession shall be maintained current at all times.
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Page 112 of 137Appendix B(Page 24 of 28)Regulatory Guide Conformance StatusTable 2REGULATORY GUIDE CONFORMANCE STATUSNRC Re-gulatory Guide 1.94 -"Quality Assurance Requirements for Installation, Inspection, andTesting of Structural Concrete and Structural Steel During the Construction Phase of Nuclear PowerPlants, " Revision 1, 4/76, endorses ANSI N45.2.5-1974.
The NQAP follows this Guide with the following alternatives:
- 1. The qualification requirements for quality control (QC) inspectors are stated in our position onRegulatory Guide 1.58 in this table.2. Testing frequency and QC acceptance criteria for concrete construction is described in the SafetyAnalysis Report for each plant.3. Burning of bolt holes is acceptable when specifically approved by engineering.
- 4. The installation method for high strength bolting may be either the automatic cutoff impactwrench method, turn-of-nut method, or direct tension indicator method.5. Torque wrench inspection of completed connections installed by the turn-of-nut method shall notbe required but may serve to resolve disagreements concerning the results of inspection of bolttension.6. Torque wrench inspection of the load indicator washer type of direct tension indicator shall not berequired.
- 7. Bolts shall be considered long enough if the bolt point is flush with or outside the face of the nut.8. When specified by the design output document, TVA's alternative for visual welding acceptance criteria will be NCIG-01, May 7, 1985, Revision 2, "Visual Weld Acceptance Criteria for Structural Welding of Nuclear Power Plants."9. For modifications or repairs to structures within the scope of N45.2.5-1974, plant management shall refer to the Site Engineering organization for any design analyses.
- 10. Verification of pre-weld activities, including fit-up, will be verified through a graded QC inspection
- program, unless 100 percent inspection is specified in design output documents.
- 11. Much of N45.2.5 applies to construction and preoperational testing.
As a result, many of thelisted tests are not appropriate in an operational plant. In lieu of this, TVA utilizes the appropriate engineering organizations to establish the need for specific tests or test procedures during theoperational phase, and the guidance provided in ANSI N45.2.5-1974 is considered forapplicability.
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Page 113 of 137Appendix B(Page 25 of 28)Regulatory Guide Conformance StatusTable 2REGULATORY GUIDE CONFORMANCE STATUS12. TVA implements the requirements of N45.2.5 Section 3, 4, and 5 with a performance-based graded QA verification program consisting of quality control inspection, line verification, andquality assessments.
NRC Regulatory Guide 1.116 -"Quality Assurance Requirements for the Installation, Inspection, andTesting of Mechanical Equipment and Systems,"
6/76, endorses ANSI N45.2.8-1975.
The NQAP follows this Guide with the following alternatives:
- 1. QA programmatic/administrative requirements included in the Regulatory Guide shall apply toconstruction, maintenance, and modification activities.
Technical requirements associated withmaintenance and modifications shall be the original requirements or better (e.g., coderequirements, material properties, design margins, manufacturing processes, and types ofinspection requirements).
- 2. Much of N45.2.8 applies to construction and preoperational testing.
As a result, many of thelisted tests are not appropriate in an operational plant. In lieu of this, TVA utilizes the appropriate engineering organizations to establish the need for specific tests or test procedures during theoperational phase and the guidance provided in ANSI N45.2.8-1975 is considered forapplicability.
- 3. TVA implements the requirements of N45.2.8 Sections 4.4 and 5.1 with a performance based,graded QA verification program consisting of quality control inspection, line verification, andquality assessments.
NRC Regulatory Guide 1.123 -"Quality Assurance Requirements for Control of Procurement of Itemsand Services for Nuclear Power Plants,"
Revision 1, 7/77, endorses ANSI N45.2.13-1976.
The NQAP follows this Guide with the following alternative:
Section 4.2 -In the special case of "commercial grade items: the supplier may not be evaluated byone of the methods identified;
- however, the procurement documents shall contain acceptance requirements (special receipt inspection requirements, special tests, or functional tests) specific to theitem being procured.
The acceptance (dedication) of commercial grade items intended for safety-related applications meets the intent of EPRI NP-5652 as accepted by the NRC.Section 7.5 -Personnel responsible for performing verification activities are qualified in accordance with ANSI N45.2.6 or ANSI N45.2.23 as applicable.
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Page 114 of 137Appendix B(Page 26 of 28)Regulatory Guide Conformance StatusTable 2REGULATORY GUIDE CONFORMANCE STATUSSection 3.2.3 -When purchasing commercial grade calibration services from calibration laboratories accredited by a nationally recognized accrediting body, the procurement documents are not requiredto impose a quality assurance program consistent with ANSI N45.2-1971.
Nationally-recognized accrediting bodies include the National Voluntary Laboratory Accreditation Program (NVLAP)administered by the National Institute of Standards and Technology (NIST) and other accrediting bodies recognized by NVLAP via a Mutual Recognition Agreement (MRA). In such cases,accreditation may be accepted in lieu of the Purchaser imposing a QA Program consistent with ANSIN45.2-1971, provided all the following are met:1. The accreditation is to ANSI/ISO/IEC 17025.2. The accrediting body is either NVLAP or an accrediting body recognized by NVLAP through anMRA (limited to NVLAP and to American Association for Laboratory Accreditation, which isrecognized by NVLAP through the International Laboratory Accreditation Cooperation).
- 3. The published scope of accreditation for the calibration laboratory covers the neededmeasurement parameters, ranges, and uncertainties.
- 4. The purchase documents impose additional technical and administrative requirements, asnecessary, to satisfy TVA QA Program and technical requirements (must explicitly imposeNUPIC clause 14.1 .C.7 which requires that the calibration certificate/report include identification of the laboratory equipment/standards used).5. The purchase documents require reporting as-found calibration data when calibrated items arefound to be out-of-tolerance.
NRC Re-gulatory Guide 1.144 -"Auditing of Quality Assurance Programs for Nuclear Power Plants,"Revision 1, 9/80, endorses ANSI N45.2.12-1977.
The NQAP follows this Guide with the following alternatives:
- 1. Paragraph 2.3 -Technical specialists who assist in performing audits in their area of specialexpertise will perform their audit duties under the supervision of a certified lead auditor.2. TVA implements the requirements of Regulatory Guide paragraph C.3.a and Sections 3.4 and3.5 of ANSI N45.2.12 with a performance-based, graded QA audit program.
Real timeadjustments are made to the audit scope, depth, and frequency based on an item's or subject's importance to safety and performance history.
Real-time adjustments allow emphasis to beplaced in areas where performance is weak and decrease emphasis where performance isevaluated to be good.3. Section 4.5.2 -QA will have a certified lead auditor or a manager of the auditor either conduct therequired follow up or attest to the acceptability of the follow up conducted by audit personnel.
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Page 115 of 137Appendix B(Page 27 of 28)Regulatory Guide Conformance StatusTable 2REGULATORY GUIDE CONFORMANCE STATUS4. Regulatory Guide 1.144, Section C.3.b(2)When purchasing commercial grade calibration services from calibration laboratories accredited by a nationally recognized accrediting body, the accreditation process and accrediting body maybe credited with carrying out a portion of the Purchaser's duties of verifying acceptability andeffective implementation of the calibration service supplier's quality assurance program.Nationally recognized accrediting bodies include the National Voluntary Laboratory Accreditation Program (NVLAP) administered by the National Institute of Standards and Technology (NIST)and other accrediting bodies recognized by NVLAP via a Mutual Recognition Agreement (MRA).In lieu of performing an audit, accepting an audit by another licensee, or performing a commercial grade supplier survey, a documented review of the supplier's accreditation shall be performed bythe Purchaser.
This review shall include, at a minimum, verification of all the following:
- a. The accreditation is to ANSI/ISO/IEC 17025.b. The accrediting body is either NVLAP or an accrediting body recognized by NVLAP throughan MRA.c. The published scope of accreditation for the calibration laboratory covers the neededmeasurement parameters, ranges, and uncertainties.
NRC Regulatory Guide 1.146 -"Qualification of Quality Assurance Program Audit Personnel forNuclear Power Plants,"
8/80, endorses ANSI N45.2.23-1978.
The NQAP follows this Guide with the following alternative:
- 1. In addition to the State agencies and technical societies recognized by ANSI N45.2.23, Section2.3.1.3, TVA may grant two points for professional competency to those individuals licensed aseither a Reactor Operator (RO) or Senior Reactor Operator (SRO) by the NRC.2. Replace Section 2.3.4 of ANSI N45.2.23 with the following:
"Prospective Lead Auditors shall demonstrate their ability to effectively implement the auditprocess and effectively lead an audit team. This process is described in written procedures which provide for evaluation and documentation of the results of this demonstration.
Aprospective Lead Auditor shall participate in at least one nuclear quality assurance audit withinthe year preceding the individual's effective date of qualification."
TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 116 of 137Appendix B(Page 28 of 28)Regulatory Guide Conformance StatusTable 2REGULATORY GUIDE CONFORMANCE STATUSNRC Regqulatory Guide 1.152 -"Criteria For Programmable Digital Computer System Software inSafety-Related Systems of Nuclear Power Plants,"
November 1985, endorses ANSI/IEEE-ANS 4.3.2-1982.
The NQAP follows this Guide consistent with Section D of the Guide, with the following alternative:
For programmable digital computer system software installed in safety-related protection
- systems, TVA will follow this guide for the verification and validation of program elementsspecified in Sections 13.2G and 13.2H of the NQAP.
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Page 117 of 137Appendix C(Page 1 of 4)Guidelines for Determination of TVA Identified Quality-Related Classifications
1.0 INTRODUCTION
The guidelines for classifying components,
- systems, and activities as quality related dependon the relationship of the terms quality related and safety related as discussed in 2.0 and 3.0below. The guidelines are contained in Section 4.0 of this Appendix.
2.0 QUALITY-RELATED A. Quality-related (QR) is a term, which encompasses quality assurance programrequirements that describe activities, which affect structures,
- systems, andcomponents.
These requirements provide reasonable assurance that the facility canbe operated without undue risk to the health and safety of the public. In addition tosafety-related structures,
- systems, components, and activities, the term "quality-related" encompasses the broad class of plant features covered (not necessarily explicitly) in the General Design Criteria of 10 CFR 50, Appendix A, that contribute inan important way to the safe operation and protection of the public in all phases andaspects of facility operation (i.e., normal operation and transient control as well asaccident mitigation).
B. Quality-related is more encompassing than the term safety related.
Appendix D showsthe scope of the Nuclear Quality Assurance Program.
All quality-related items andactivities are not necessarily safety-related.
Appendix D illustrates the programmatic relationships.
3.0 SAFETY-RELATED A. Use of the term safety-related (or variations thereof) and the methodology forclassifying items and activities as safety-related has been established in the GeneralDesign Criteria and Safety Analysis Report for TVA's Browns Ferry, Sequoyah, andWatts Bar, and Bellefonte Nuclear Plants. The term safety-related as used in thisappendix, this program description and other Nuclear Quality Assurance Programdocuments is generic in nature.B. Items and activities classified as safety-related are subject, without exception, to therequirements of 10 CFR 50, Appendix B. All safety-related items and activities are alsoquality-related.
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Page 118 of 137Appendix C(Page 2 of 4)Guidelines for Determination of TVA Identified Quality-Related Classifications
4.0 GUIDELINES
Some items and activities are classified as quality-related but not safety-related.
However,because some items and activities classified as quality-related are considered important tothe continued reliable operation of TVA's nuclear facilities, TVA shall apply the requirements of all or selected parts of the NQAP to such items and activities.
A. Structures,
- systems, and components shall be classified as quality-related but notsafety-related if they fit one or more of the following categories:
- 1. Contain radioactive material and have not been identified as safety-related.
- 2. Are required by ANS 3.2/ANSI N18.7-1976, "Administrative Controls and QualityAssurance for the Operational Phase of Nuclear Power Plants,"
and are notidentified as safety-related (e.g., plant security system).3. Are fire protection features that provide protection for safety-related structures,
- systems, or components.
- 4. Are structures,
- systems, and components that have environmental or operability requirements important to the safe operation of the unit (as specified in the PlantTechnical Specifications).
- 5. Are structures,
- systems, and components that could impact reliability andoperability goals recommended by NPG management and approved by theExecutive Vice President, and CNO.B. Those components or systems designated as Seismic Category I (L) (Class II for BFN)in nuclear plant FSARs shall be classified as quality-related.
Seismic Category I (L) isthe nonsafety-related portion of Seismic Category I. (Refer to Appendix D.)C. Additional components or systems, not identified in the FSARs as NNS or SeismicCategory I (L,) can be designated as quality-related but not safety-related.
Suchadditional components or systems could include the following:
- 1. Plant security system.2. Plant radiological controls and radwaste systems.3. Other structures,
- systems, and components which have special environmental oroperability requirements.
- 4. Structures,
- systems, or equipment designated by NPG management as requiring some level of quality control because of their importance to plant reliability oroperability.
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Page 119 of 137Appendix C(Page 3 of 4)Guidelines for Determination of TVA Identified Quality-Related Classifications
%cr%/o4.0 GUIDELINES (continued)
D. Items to which one or more of the following regulatory documents are applicable should be considered for classification as quality-related.
- 1. Regulatory Guide 1.143, "Design Guidance for Radioactive Waste Management
- Systems, Structures, and Components Installed in Light-Water-Cooled NuclearPower Plants."2. 10 CFR 71, Subpart H, "Quality Assurance (Packaging and Transportation ofRadioactive Material)."
- 3. Regulatory Guide 1.29, "Seismic Design Classification."
- 4. 10 CFR 73.55, "Requirements for Physical Protection of Licensed Activities inNuclear Power Reactors Against Radiological Sabotage."
- 5. 10 CFR 50.62, "Requirements for Reduction of Risk From Anticipated Transients Without Scram (ATWS) Events for Light-Water-Cooled Nuclear Power Plants."6. 10 CFR 50, Appendix R, "Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979."7. ANS 3.2/ANSI N18.7-1976, "Administrative Controls and Quality Assurance forthe Operational Phase of Nuclear Power Plants."8. Regulatory Guide 1.33, Revision 2, February 1978, "Quality Assurance ProgramRequirements (Operation)."
- 9. NRC letter from H. J. Thompson, Jr., dated April 16, 1985, "Quality Assurance Guidance for ATWS Equipment That is Not Safety Related,"
Generic Letter 85-06,(A02 850422 044).10. NRC letter from D. G. Eisenhut dated April 24, 1986, "Implementation of FireProtection Requirements,"
Generic Letter 86-10 (A02 860512 005).11. NUREG 0737, "Clarification of TMI Action Plan Requirements."
- 12. NUREG 0800, Section 9.5.1, Branch Technical
- Position, CMEB 9.5-1 (formerly BTP ASB 9.5-1), Revision 2, July 1981, "Fire Protection for Nuclear PowerPlants."13. 10 CFR 72, Licensing Requirements for the Independent Storage of SpentNuclear Fuel and High-level Radioactive Waste.
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Page 120 of 137Appendix C(Page 4 of 4)Guidelines for Determination of TVA Identified Quality-Related Classifications
%cr%/o4.0 GUIDELINES (continued)
E. New systems (or items being added as a result of approved modifications) shall beclassified on the same basis as the existing components or systems.F. Classification of components or systems as quality-related but not safety-related shallbe performed in accordance with approved corporate or site engineering procedures orat NPG management direction.
5.0 CLASSIFICATION OF DRY CASK STORAGE SYSTEMThe Dry Cask Storage System is engineered to provide safe storage of spent fuel on theISFSI pad. These components will be designated as important to Safety (ITS) classification category A, B, C in accordance with NUREG/CR-6407.
For procurement
For onsite activities 10 CFR72 ITS Category A and B components will be treated as safety-related under NPG's existingQA Program.
Similarly, 10 CFR 72 ITS Category C components will be treated as quality-related but not safety-related.
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Page 121 of 137Appendix D(Page 1 of 1)Scope of Nuclear Quality Assurance ProgramThis diagram displays the relationship of safety-related to quality-related items and activities.
Examples of these items and activities are shown. It is not intended to show each specific item andactivity within the scope of the Nuclear QA Program.
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Page 122 of 137Appendix E(Page 1 of 1)Computer SoftwareThe requirements of Section 13.0 apply to application
- software, which performs any of the following:
A. Directly operate safety-related plant equipment.
B. Generates design output for the design of safety-related or quality-related functions, structures,
- systems, or components.
C. Used by control room personnel, without further verification, to make plant operating decisions affecting:
- 1. The integrity of the reactor coolant pressure boundary.
- 2. The capability to shutdown the reactor and maintain it in a safe condition.
- 3. The capability to prevent or mitigate the consequences of accidents which could result inpotential offsite exposures comparable to the applicable guideline exposures set forth in 10CFR 50.34(a)(1) or 10 CFR 100.11, as applicable.
D. Perform calculations, the results of which are used, without further verification to operate,maintain,
- inspect, or test safety-related or quality-related structures,
- systems, and components.
E. Performs engineering calculations, the results of which are used, without further verification tosupport the design of safety-related and quality-related structures,
- systems, and components.
F. Generates output used to procure safety- or quality-related items.G. Maintains,
- controls, or distributes information to be used without further verification in theprocurement, design, operation, and maintenance of safety-related or quality-related structures,
- systems, and components.
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Page 123 of 137Appendix F(Page 1 of 5)Watts Bar Unit 2 Construction Completion Project1.0 GENERALThis appendix to the Tennessee Valley Authority (TVA) Nuclear Quality Assurance Plan(NQAP) describes the top level policy that assigns major functional responsibilities forconstruction completion activities conducted by or for TVA Watts Bar Unit 2 (WBN 2)Construction Completion Project.
The NQAP describes the methods and establishes theadministrative control requirements that meet 10 CFR 50, Appendix B and the WBN 2construction permit.Current TVA Nuclear Power Group (NPG) programs and procedures that implement theNPG Nuclear Quality Assurance
- Program, as well as the existing NPG organizational structures, focus heavily toward an operating plant structure.
This appendix is developed totake into account the unique requirements and commitments necessary to ensure effective quality assurance program implementation and oversight for the WBN 2 Construction Completion Project.
The NQAP incorporates lessons learned from WBN Unit 1 (WBN 1),Browns Ferry Nuclear Plant (BFN) recoveries, and construction projects in the late 1970sand early 1980s (NRC IN 2007-04 and INPO 83-011).The execution and accountability for the WBN 2 construction completion, construction phasetests and inspections, and related QA activities has been delegated through a TVA contractto Bechtel Power Corporation (Bechtel) and is implemented through the project specific TVAapproved Bechtel Nuclear Quality Assurance Manual (QAM). The TVA review and approvalof the QAM and any changes thereto, ensures that regulatory requirements and TVAspecific commitments of this NQAP are incorporated and that WBN 2 is completed by aquality assurance program as rigorous as that used for completion of WBN 1. The BechtelASME Quality Assurance Manual is included by reference in the QAM and is audited inaccordance with TVA Owners ASME QA Manual. As part of the execution of the QAM theBechtel organization is accountable for performing the regulatory required quality controlinspection and quality assurance audit functions for the construction phase activities.
TVAretains and exercises the overall responsibility for the establishment and execution of aneffective QA program for the construction completion of WBN 2. This appendix describes the Bechtel program and the TVA oversight methods for ensuring the adequacy andeffectiveness of the contractor QA organization execution of QAM related activities forconstruction completion.
Procedures and instructions that control engineering, procurement, construction, andQAIQC activities will be developed by Bechtel prior to commencement of those activities andare reviewed and approved by TVA. A part of the review is to identify those procedures forwhich future changes must be approved by TVA.2.0 SCOPE/APPLICABILITY This appendix applies only to WBN 2 construction permit construction phase activities affecting the quality and performance of safety-related structures,
- systems, and components through component testing and prior to fuel load, including, but not limited to:
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Page 124 of 137Appendix F(Page 2 of 5)Watts Bar Unit 2 Construction Completion Project2.0 SCOPE/APPLICABILITY (continued)
Designing Procuring Fabricating Shipping Receiving StoringHandling Constructing Installing Erecting Inspecting Repairing Cleaning Construction Testing Licensing TrainingThe policy of TVA is to assure a high degree of availability and reliability of its nuclear plantswhile ensuring the health and safety of its workers and the public. To this end, selectedelements of the QAM are also applied to certain equipment and activities that are not safetyrelated, but support safe, economic, and reliable plant operations, or where other NRCguidance establishes quality assurance requirements.
Implementing documents establish program element applicability.
3.0 ORGANIZATION
This section describes the TVA organizational structure, functional responsibilities, levels ofauthority and interfaces for establishing, executing, and verifying the implementation ofquality assurance requirements for WBN 2. The organizational structure includes offsite andon-site functions including interface responsibilities for multiple organizations performing non-safety-related functions.
Implementing documents assign more specific responsibilities and duties, and define the organizations interfaces involved in conducting activities andduties within the scope of this NQAP. Management gives careful consideration to thetiming, extent and effects of organizational structure changes.The Senior VP, NC, is responsible to ensure the TVA WBN U2 QA organization and theBechtel Quality Assurance organizations are sized commensurate with the duties andresponsibilities assigned.
This is accomplished through the use of dedicated andexperienced QA organization performing oversight of the contractor activities both onsiteand off and applying lessons learned from the recent completion of BFN 1 and providing feedback to TVA and Bechtel management.
The TVA WBN 2 organization is responsible for plant licensing, engineering, procurement, construction, and pre-operational activities.
WBN 2 organization will support the WBNoperating organization as necessary for initial fuel loading, pre-critical, low power, andpower-ascension testing.Engineering, procurement, construction, QA/QC and construction testing services areprovided to the TVA through a contract with Bechtel that was reviewed by TVA QA to ensureappropriate TVA QA requirements were addressed.
This contract will extend the qualityassurance requirements described in this document to all applicable contractors andsubcontractors through the TVA approved QAM. The transfer of accountability forimplementation of the QA program from Bechtel to TVA will be defined in project procedures and will occur prior to fuel load.The following sections describe the reporting relationships, functional responsibilities andauthorities for organizations implementing and supporting the Nuclear Quality Assurance Program.
The TVA Nuclear Power Group and the NC organization are described herein.
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Page 125 of 137Appendix F(Page 3 of 5)Watts Bar Unit 2 Construction Completion Project3.0 ORGANIZATION (continued)
The Bechtel QA/QC corporate organization and lines of communication to project QAIQCare consistent with those described in the NRC reviewed and accepted Bechtel QA TopicalReport BQ-TOP-1, Rev 4A, Bechtel Quality Assurance Program for Nuclear Power Plants.The project specific QA/QC organization is described in the TVA approved QAM andensures independence is maintained between the organization performing the checking(quality assurance and quality control) functions and the organizations performing thefunctions.
Organization charts for various TVA departments/locations are contained in the Final SafetyAnalysis Report that references the TVA organizational description (TVA-NPOD89) or theorganization charts describe with more detail the organizational positions and specificfunctions and responsibilities of those implementing the NQAP.3.1 President and Chief Executive Officer (CEO)The CEO is responsible for all aspects of design, construction, and operation of TVA'snuclear plants. The CEO is also responsible for all technical and administrative supportactivities provided by TVA and contractors.
The CEO directs the Executive Vice President and Chief Generating Officer (CGO), Executive Vice President and Chief Nuclear Officer(CNO), and the Senior Vice President NC. The CEO also directs the executive responsible for Administrative Services.
The CEO reports to the TVA Board of Directors with respect toall matters.3.2 Senior Vice President Nuclear Construction (NC)The Senior Vice President NC (SVP NC) reports to the CEO and is responsible for newnuclear plant licensing, engineering, procurement, construction, and preoperational testingactivities and for the implementation of this NQAP for NC activities for WBN 2 construction completion.
The SVP NC also directs the planning and development of the NC staff andorganization resources.
3.2.1 General Manager WBN U2 Engineering
& Construction The General Manager WBN U2 Engineering
& Construction reports to the SVP NC and isresponsible for the overall implementation of quality assurance requirements in the areasspecified by this NQAP.3.2.2 General Manager WBN U2 Technical ServicesThe General Manager WBN U2 Technical Services reports to the SVP NC and isresponsible for the implementation of quality assurance requirements in the areas specified by this NQAP.
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Page 126 of 137Appendix F(Page 4 of 5)Watts Bar Unit 2 Construction Completion Project3.2.3 NC Quality Assurance The Quality Assurance organization is responsible for independently planning andperforming activities to verify the effective implementation of the NRC approved NuclearQuality Assurance Plan described in this document for WBN 2 activities, including, but notlimited to engineering, QAIQC, licensing, document
- control, corrective action program, andprocurement that support plant completion.
A. Senior Manager WBN U2 Quality Assurance (SM WBN U2 QA)SM WBN U2 QA reports directly to the SVP NC, and has line of communication to theGeneral Manager WBN U2 Engineering
& Construction and the General ManagerWBN U2 Technical Services.
The SM WBN U2 QA is responsible for the verification ofimplementation of the Nuclear Quality Assurance Plan described in this document.
The SM WBN U2 QA is responsible for assuring compliance with regulatory requirements and procedures through audits, assessments and technical reviews; formonitoring organization processes to ensure conformance to commitments andlicensing document requirements; and for ensuring that vendors providing qualityservices, parts and materials to TVA are meeting the requirements of 10 CFR 50,Appendix B through Nuclear Procurement Issues Committee (NUPIC),
Bechtel or TVAvendor audits. The SM WBN U2 QA has sufficient independence from other NCpriorities to bring forward issues affecting safety and quality and makes judgments regarding quality in all areas necessary regarding NC activities.
The SM WBN U2 QAmay make recommendations to the NC management regarding improving the quality ofwork processes.
If the SM WBN U2 QA disagrees with any actions taken by the WattsBar Unit 2 organization relative to Nuclear Quality Assurance Program implementation and is unable to obtain resolution, the SM WBN U2 QA shall inform the GeneralManager WBN U2 Engineering
& Construction, and if necessary, bring the matter tothe attention of the SVP NC, who will determine the final resolution.
The SM WBN U2 QA is required to have a bachelor's degree in an engineering orscientific discipline, or equivalent related experience.
The manager shall have at leastten years experience in plant design, construction, power plant operations, maintenance or a combination, including five years experience in managing andexecuting the quality assurance oversight responsibilities.
3.3 Executive Vice President and Chief Administrative OfficerAdministrative ServicesThe Executive Vice President and Chief Administrative
- Officer, Administrative Servicesreports to the CEO and is responsible for managing the overall Administrative Servicesorganization including assuring that Supply Chain Management support NC activities inaccordance with the Nuclear Quality Assurance Program.
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Page 127 of 137Appendix F(Page 5 of 5)Watts Bar Unit 2 Construction Completion Project3.4 Executive Vice President and Chief Generation OfficerThe Executive Vice President and Chief Generation Officer reports to the CEO and isresponsible for assuring that Inspection and Testing Services management support NCactivities in accordance with the Nuclear Quality Assurance Program.3.5 Executive Vice President and Chief Nuclear OfficerThe Executive Vice President, and CNO reports to the CGO and CEO. The CNO is theTVA executive responsible for the safe, reliable, and efficient operation of licensed TVAnuclear plants. The Executive Vice President and CNO directs the operating plants throughthe management position responsible for nuclear operations (NO) and the General ManagerNPG QA.3.5.1 WBN site management positionThe management representative responsible for nuclear site operating organization reportsthrough the management position responsible for nuclear operations (NO). The sitemanagement position is responsible for the overall implementation of quality assurance requirements in the areas specified by the NQAP Section 4.1.2. In addition to therequirements of Section 4.1.2, the WBN site management position is responsible for theWBN 2 Initial Fuel Loading, Pre-critical Tests, Initial Criticality and Low Power Testing, andPower-Ascension Tests.3.6 Authority to Stop WorkTVA WBN 2 QA and Bechtel quality assurance and inspection personnel have the authority, and the responsibility, to stop work in progress, which is not being done in accordance withapproved procedures or where safety or structure, system, or component integrity may bejeopardized.
This extends to off-site work performed by suppliers furnishing safety-related materials and services to TVA.3.7 Organizational Independence For the WBN 2 Construction Completion
- Project, independence shall be maintained between the organization performing the checking (quality assurance and quality control)functions and the organizations performing the functions.
This provision is not applicable todesign review/verification.
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Page 128 of 137Appendix G(Page 1 of 5)Quality Assurance Programs for Bellefonte Units 1 and 21.0 GENERALThis appendix to the Tennessee Valley Authority (TVA) Nuclear Quality Assurance Plan(NQAP) describes the top level policy that assigns major functional responsibilities foractivities conducted by or for TVA Bellefonte Units 1 and 2 (BLN) while the construction permits for the units remain in deferred status. The NQAP describes the methods andestablishes the administrative control requirements that meet applicable 10 CFR 50,Appendix B requirements, NRC Generic Letter 87-15, "Policy Statement on DeferredPlants,"
and the BLN 1 & 2 construction permits as reinstated in accordance with the termsof the NRC order reinstating the BLN Units 1 & 2 construction
- permits, dated March 9, 2009.Current TVA Nuclear Power Group (NPG) programs and procedures that implement theNuclear Quality Assurance
- Program, as well as the existing NPG organizational structures, are primarily focused on an operating plant structure.
This appendix is developed to takeinto account the unique requirements and commitments necessary to ensure effective quality assurance program implementation and oversight of BLN 1 & 2.The execution and accountability for quality assurance for the BLN 1 & 2 units remains withTVA, but may be delegated to support contractors for specific tasks and activities.
Contracted activities are implemented through a TVA approved contractor Nuclear QualityAssurance Manual (QAM) or may be implemented through direct implementation of the TVAQA program through TVA procedures.
TVA's review and approval of a contractor QAM, andany changes thereto, ensures that regulatory requirements and TVA specific commitments of this NQAP are met. TVA retains and exercises the overall responsibility for theestablishment and execution of an effective QA program for BLN 1 & 2.Procedures and instructions that implement the requirements of the Nuclear QualityAssurance Program are developed prior to commencement of those activities and arereviewed and approved by TVA.2.0 BACKGROUND TVA's Power Supply Plan identifies the need for a flexible range of options and alternatives required to meet, among other things, the Tennessee Valley region's base load power forfuture years. Until decisions on generating options to meet future load forecasts arefinalized, maintaining BLN 1 & 2 Units in a deferred status, is consistent with TVA's needs.3.0 SCOPE/APPLICABILITY This appendix applies to BLN 1& 2 plant activities while TVA evaluates, maintains andpreserves the units for the consideration of possible reactivation of construction andcompletion activities.
TVA will take the actions necessary to maintain and preserve the unitsin order to maintain the option of plant reactivation in accordance with Generic Letter 87-15,"Policy Statement on Deferred Plants" and the terms of the NRC order reinstating the BLNUnits 1 & 2 construction
- permits, dated March 9, 2009.
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Page 129 of 137Appendix G(Page 2 of 5)Quality Assurance Programs for Bellefonte Units I and 24.0 ORGANIZATION This section describes the TVA organizational structure, functional responsibilities, levels ofauthority and interfaces for establishing, executing, and verifying the implementation ofquality assurance requirements for BLN 1 & 2. The organizational structure includes offsiteand on-site functions including interface responsibilities for multiple organizations performing nonsafety-related functions.
Implementing documents assign more specific responsibilities and duties, and define the organizations interfaces involved in conducting activities andduties within the scope of this Nuclear Quality Assurance Program.
Management givescareful consideration to the timing, extent and effects of organizational structure changes.TVA BLN 1 & 2 management is responsible for ensuring that TVA BLN QA organization issized commensurate with assigned duties and responsibilities.
This is accomplished through the use of a dedicated and experienced QA organization performing oversight activities both onsite and offsite, and applying the experience and lessons learned from therecent completion of Browns Ferry Unit I and ongoing construction completion activities atWatts Bar Unit 2.The following sections describe the reporting relationships, functional responsibilities, andauthorities for organizations implementing and supporting the Nuclear Quality Assurance Program as it applies to BLN Units 1 & 2 in a terminated or deferred plant status. The TVANuclear Power Group and the Nuclear Construction (NC) organization are described herein.4.1 President and Chief Executive Officer (CEO)The CEO is responsible for all aspects of design, construction and operation of TVA'snuclear plants. The CEO is also responsible for all technical and administrative supportactivities provided by TVA and contractors.
The CEO directs the CGO and the Senior VicePresident NC. The CEO also directs the executive responsible for Administrative Services.
The CEO reports to the TVA Board of Directors with respect to all matters.4.2 Senior Vice President Nuclear Construction (NC)The Senior Vice President NC (SVP NC) reports to the CEO and is responsible for newnuclear plant licensing, engineering, procurement, construction quality assurance andquality control and preoperational testing activities and for the implementation of this NQAPfor NC activities at BLN. The SVP NC also directs the planning and development of the NCstaff and organization resources.
The SVP NC is also responsible for establishing andmanaging the contracts for the development of new nuclear generation.
4.2.1 Management position responsible for BLN ProjectThe management position responsible for the BLN Project reports to the SVP NC and isresponsible for the overall implementation of quality assurance requirements in the areasspecified by the Nuclear Quality Assurance Program for BLN 1 & 2 plant activities.
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Page 130 of 137Appendix G(Page 3 of 5)Quality Assurance Programs for Bellefonte Units I and 24.2.2 NC Quality Assurance The Quality Assurance organization is responsible for independently planning andperforming activities to verify the effective implementation of the NRC approved NuclearQuality Assurance Plan described in this document for BLN 1 and 2 activities including, butnot limited to engineering, QAIQC, licensing, document
- control, corrective action program,and procurement that support plant completion.
The Quality Assurance organization is responsible for independently planning andperforming activities to verify the effective implementation of the NRC approved NuclearQuality Assurance Plan described in this document for BLN 1 & 2 activities.
A. Senior Manager BLN Quality Assurance (SM BLN QA)The SM BLN QA reports directly to the SVP NC. The SM BLN QA is responsible forthe verification of implementation of the Nuclear Quality Assurance Program described in this document.
The SM BLN QA is responsible for ensuring compliance withregulatory requirements and procedures through audits, assessments and technical reviews; for monitoring organization processes to ensure conformance to commitments and licensing document requirements.
The SM BLN QA has sufficient independence from other NC priorities to bring forward issues affecting safety and quality and makesjudgments regarding quality in all areas necessary regarding NC activities.
If the SMBLN QA disagrees with any actions taken by the BLN organization relative to NuclearQuality Assurance Program implementation and is unable to obtain resolution, the SMBLN QA shall inform the management position responsible for BLN Project, and ifnecessary, bring the matter to the attention of the SVP NC, who will determine the finalresolution.
The SM BLN QA is required to have a bachelor's degree in an engineering or scientific discipline, or equivalent related experience.
The SM BLN QA shall have at least tenyears experience in plant design, construction, power plant operations, maintenance ora combination, including five years experience in managing and executing the qualityassurance oversight responsibilities.
4.3 Executive Vice President and Chief Administrative Officer-Administrative ServicesThe Executive Vice President and Chief Administrative
- Officer, Administrative Servicesreports to the CEO and is responsible for managing the overall Administrative Servicesorganization including assuring that Supply Chain Management support NC activities inaccordance with the Nuclear Quality Assurance Program.4.4 Executive Vice President and Chief Generation OfficerThe Executive Vice President and Chief Generation Officer reports to the CEO and isresponsible for assuring that Inspection and Testing Services management support NCactivities in accordance with the Nuclear Quality Assurance Program.
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Page 131 of 137Appendix G(Page 4 of 5)Quality Assurance Programs for Bellefonte Units 1 and 24.5 Executive Vice President and Chief Nuclear Officer (CNO)The Executive Vice President and CNO reports to the CGO and CEO. The CNO is the TVAexecutive responsible for the safe, reliable, and efficient operation of licensed TVA nuclearplants. The Executive Vice President and CNO direct the operating plants through themanagement position responsible for nuclear operations (NO) and the General ManagerQuality Assurance.
4.6 Authority to Stop WorkTVA BLN QA and Contractor quality assurance and inspection personnel have the authority, and the responsibility, to stop work in progress which is not being done in accordance withapproved procedures or where safety or structure, system or component integrity may bejeopardized.
This extends to off-site work performed by suppliers furnishing safety-related materials and services to TVA.4.7 Organizational Independence For the BLN Plant, independence shall be maintained between the organization performing the checking (quality assurance and quality control) functions and the organizations performing the functions.
This provision is not applicable to design review/verification.
5.0 PROGRAMA. During the period that BLN units 1 & 2 remain in terminated or deferred status asdescribed in Generic Letter 87-15, "Policy Statement on Deferred Plants" the QualityAssurance elements described in this appendix and the body of the NQAP will beaccomplished through written, reviewed and approved procedures.
B. Site procedures that were not used in the period of deferral before the construction permits were withdrawn were placed in inactive status. As activities necessary toconsider the viability of construction completion are required, the applicable procedures will be reactivated, reviewed and reissued prior to the conduct of the activity.
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Page 132 of 137Appendix G(Page 5 of 5)Quality Assurance Programs for Bellefonte Units 1 and 26,0 PLANT EQUIPMENT POLICYA. An important factor in considering the viability of construction reactivation andcompletion includes the impact of equipment age on its continued suitability for use.Considerations regarding age degradation due to design life, outdated or obsoleteequipment, design improvements, any impact associated with resource recoveryactivities, and economic feasibility to replace rather than preserve equipment indefinitely under a lay-up program must be taken into account given the age of certainexisting equipment.
For these reasons, in August 2003 TVA submitted and in May2004 the NRC approved a change to the NQAP that allowed preventive maintenance to be terminated on selected equipment and to allow that equipment to be entered intothe corrective action program as "deferred equipment".
TVA procedure controlsprohibited and will continue to prohibit "deferred equipment" from being used in nuclearsafety related applications without further evaluation and having been fully restored orreplaced.
B. Structures, systems or components that have been affected in the course of resourcerecovery activities will likewise be entered in to the corrective action program andprohibited from being returned to service without evaluation and having been restoredor replaced.
TA.B.C.D.E.F.G.H.I.J.K.L.M.N.0.P.Q.R.S.VA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 133 of 137Appendix H(Page 1 of 1)Types of Controlled Documents and ManualsDesign Specifications and DrawingsSafety Analysis Reports for the 10 CFR 50 Reactor Power Facilities Program ManualsPlant Instructions Radiological Protection PlanNuclear Engineering Procedures ManualSite Engineering Project ManualsASME Section III Quality Assurance ManualsNuclear Procedures System ManualsAs-built Documents Computer ProgramsNonconformance ReportsNuclear Quality Assurance PlanSystem Descriptions Topical ReportSafety Analysis Reports for the 10 CFR 72 ISFSI Facilities Radiological Emergency PlanFire Protection ReportsPart 52 Plants Safety Analysis Reports and QAPD TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 134 of 137Appendix I(Page 1 of 2)TVA NQAP Organization Charts________________________
Iii IresIdent IIration III I TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 135 of 137Appendix I(Page 2 of 2)TVA NQAP Organization ChartsSenior Vice President Nuclear Construction TVA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 136 of 137Appendix J(Page 1 of 2)List Of Abbreviations The following abbreviations are used in this program description:
AISC -American Institute of Steel Construction ALARA -As Low as Reasonably Achievable ANS -American Nuclear SocietyANSI -American National Standards Institute ASL -Approved Suppliers ListASME -American Society of Mechanical Engineers ASME III QOAM -ASME Section III Quality Assurance ManualASNT -American Society for Nondestructive TestingATWS -Anticipated Transient Without ScramAWS -American Welding SocietyBFN -Browns Ferry Nuclear PlantBLN -Bellefonte Nuclear PlantCEO -Chief Executive OfficerCFR -Code of Federal Regulations DOE -Department of EnergyEPRI -Electric Power Research Institute FSAR -Final Safety Analysis ReportI&C -Instrument and ControlIEEE -Institute of Electrical and Electronics Engineers ISFSI -Independent Spent Fuel Storage Installation ITS -Important to SafetyM&TE -Measuring and Test Equipment NDE -Nondestructive Examination NFPA -National Fire Protection Association TA Quality Nuclear Quality Assurance Plan TVA-NQA-PLN89-A Assurance (NQAP) Rev. 0028Program (Quality Assurance Program Description)
Page 137 of 137Appendix J(Page 2 of 2)List Of Abbreviations NC -Nuclear Construction NNS -Non-nuclear SafetyNO -Nuclear Operations NPG -Nuclear Power GroupNPS -Nuclear Procedures SystemNQAP -Nuclear Quality Assurance PlanNRC -Nuclear Regulatory Commission NSRB -Nuclear Safety Review BoardNSSS -Nuclear Steam Supply SystemPI -Performance Improvement PORC -Plant Operations Review Committee QA -Quality Assurance QAM -Quality Assurance ManualQAPD -Quality Assurance Program Description QC -Quality ControlSM BLN QA -Senior Manager, Bellefonte Quality Assurance SM WBN U2 QA -Senior Manager, Watts Bar Unit 2 Quality Assurance SNM -Special Nuclear MaterialSQN -Sequoyah Nuclear PlantSVP -Senior Vice President TVA -Tennessee Valley Authority TVAN -.Tennessee Valley Authority NuclearWBN -Watts Bar Nuclear Plant