ML17309A645
| ML17309A645 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 12/21/1998 |
| From: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| To: | Vissing G NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17265A501 | List: |
| References | |
| NUDOCS 9901060060 | |
| Download: ML17309A645 (32) | |
Text
CATEGORY j.
REGULA'1 RY INFORMATION DISTRIBUTIO SYSTEM (RIDS)
ACCESSION NBR:9901060060 DOC.DATE: 98/12/21 NOTARIZED: NO DOCKET FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 AUTH. NAME AUTHOR AFFILIATION MECREDY,R.C. Rochester Gas & Electric Corp.
RECIP.NAME RECIPIENT AFFILIATION VISSING,G.S.
SUBJECT:
Forwards Rev 26 to "QA Program for Station Operation," in accordance with 10CFR50.54(a)(3).Rev 26 incorporates organization related changes associated with reorganization of Nuclear Operations Group &. cl'arification of methods.
DISTRIBUTION CODE: Q004D TITLE: QA COPIES RECEIVED:LTR l ENCL Topical Report, Change, Amendment, or Correspondence J SIZE: $
(Docket/Utile NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72). 05000244 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL VISSING,G. 1 1 INTERNAL: DRS/RGN.+. 1 1 FILE CE TER 01 1 1 NRR/DISP/PIMB 1 1 NRR/DRCH 1 1 NUDOCS-ABSTRACT 1 1 OC/LFDCB 1 1 RGN1 FILE 1 1 EXTERNAL:. DMB/OSS 1 1 IHS 1 1 NRC PDR 1 1 D
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ANn ROCHESTERGASANDELECTRICCORPORATION e 89EASTAtrrENUE, ROCHESTER, N.Y Id6d9-000I AREA CODE716 546-27M ROBERT C. MECREDY Vice President Nvctear Operations December 21, 1998 U. S. Nuclear Regulatory Commission Document Control Desk ATTN: Mr. Guy S. Vissing Project Directorate I-1 Washington, DC 20555
SUBJECT:
Revised Submittal of Quality Assurance Program for Station Operation R. E. Ginna Nuclear Power Plant Docket Number 50-244
Dear Mr. Vissing:
In accordance with 10 CFR 50.54(a)(3), enclosed is Revision 26 to the Quality Assurance Program for Station Operation. Revision 26 incorporates the following changes:
Organization related changes associated with the reorganization of the Nuclear Operations Group.
Clarification of methods used to control supplier performance.
The above changes do not impact commitments in the Quality Assurance Program description previously approved by the Nuclear Regulatory Commission (NRC) and therefore do not require NRC prior approval. These Quality Assurance Program changes have already been incorporated into station directives and procedures.
Additionally, Revision 26 of QA Program for Station Operations incorporates the following changes:
Change commitment to Regulatory Guide 1. 58, Rev. 1. An alternative to the use of SNT-TC-1A-1975 for the qualification and certification of nondestructive testing personnel is requested.
Change commitment to Regulatory Guide 1. 88, Rev. 2 which incorporates ANSI N45.2.9-1974. The use of alternative facilities to requirements of Section 5.6 (Facility) of ANSI N45.2.9-1974 are requested.
Change commitment to Regulatory Guide 1. 144, Rev. 1. In lieu of the 30 day requirement of Section 4. 5.1 of ANSI N45.2.12-1977, an alternative is proposed. fit
'st'st010b00b0 'stsi 221 PDR ADGCK 05000244, P \T PDR
Change commitment to Regulatory Guide 1. 146, Rev. 0. A alternative is proposed to Section 2.3.4 of ANSI N45.2.23-1978 for certification of prospective lead auditors.
~ Revise Audit Topic Areas listed in Table 17.3.2-1. The use of the word "all" is being deleted from the audit descriptions for items a, c and d.
The above changes impact the commitments (Reduction in Commitment) in the Quality Assurance Program description previously approved by the NRC, and therefore require NRC approval prior to implementation.
All of the changes are described in the attached Synopsis of Changes (Attachment 1) and in the enclosed program revision. also provides the basis for concluding that the revised program continues to satisfy the 10CFR50 Appendix B criteria. Changes made to Revision 25 of the Quality Assurance Program for Station Operation are denoted by a single revision bar in the left margin. Attachment 2 is a copy of the enclosure with changes highlighted or struck out.
Very truly yours, Robert C. Mec dy RCM/cjk~qap sub.R26 Attachments 1 and 2
Enclosure:
QA Program for Station Operation Revision 26 xc: U.S. Nuclear Regulatory Commission Mr. Guy S. Vissing (Mail Stop 14B2)
Project Directorate I-1 Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident Inspector
ATTACHMENT 1 Or anization Chan es The following organization changes were made and are reflected throughout the text of the document and on the Figure 17.1.2-1 Organization Chart:
~ The Department Manager, Nuclear Training now reports to the Vice President, Nuclear Operations Group. Additionally, the responsibility for Nuclear Emergency Preparedness was transferred from the Department Manager, Nuclear Assessment to the Department Manager, Nuclear Training.
The positions of Director, Operating Experience and Manager, Nuclear Assurance have been eliminated. The responsibilities for these positions have been assumed by the newly created position of Manager, Operational Review.
The responsibility for the fire protection program has been transferred from the Department Manager, Nuclear Engineering Services to the Plant Manager, Ginna Station.
~ Nuclear Engineering Services reorganized internally. This change affected the Figure 17.1.2-1 Organization Chart only.
These changes are reflected throughout the revised document and are not identified at each occurrence in the following summary of changes.
- 17. 1 MANAGEMENT Table 17.1.7-1 Conformance of Ginna Station Pro ram to ualit Assurance Standards Re uirements and Guides Regulatory Guide 1.58 Current Commitments RGRE commits to Reg. Guide 1.58, Rev. 1, which references SNT-TC-1A-1975 for the qualification and certification of nondestructive testing personnel RGEE's ISI Plan currently endorses ASME Code Section XI-1986 Edition. This edition of the ASME code references SNT-TC-1A-1980.
)
3....9901060060
ATTACHMENT 1 Re uested Chan e RGEE is requesting the following exception to the Reg. Guide 1.58, Rev. 1 commitment to eliminate the current conflicts in our commitments as follows:
RG&E's ISI Plan endorses ASME Code Section XI. The version of the ASME code endorsed is updated periodically. ASME Code Section XI references standards for the qualification and certification of nondestructive testing personnel. The standard referenced in the ASME code is used in lieu of SNT-TC-1A-1975, which is referenced by Reg. Guide 1.58, Rev.
1.
Justification for Chan e This change is being made to eliminate the current conflict and prevent future conflicts in our commitments.
A review was performed of the difference between the 1975 and 1980 editions of SNT-TC-1A. One issue was identified:
~ The number of initial training hours for personnel with a grammar school education in the 1975 edition are greater than those required by the 1980 edition.
However, this difference is not considered significant.
Since these versions of SNT-TC-1A do not significantly differ, this change does not reduce the scope of the Quality Assurance Program.
Regulatory Guide 1.88 Current Commitment RGGE is currently committed to Reg. Guide 1.88, which endorses ANSI N45.2.9-1974. Section 5.6 of ANSI N45.2.9-1974 mandates the use of a four hour fire rated facility for non-duplicated records.
ATTACHMENT 1 Re uested Chan e RG8E is requesting that the requirements in Section 5.6 (Facility) of ANSI N45.2.9-1974 be supplemented by the following alternatives:
~ Records may be stored in a 2-hour rated facility meeting the requirements described in QAPSO Section 17.2.15.
~ Records may be stored temporarily in 1-hour fire rated cabinets provided that the requirements of QAPSO Section 17.2.15 are met.
These alternatives are not allowed by our current commitment.
Justification for Chan e NFPA 232 2-Hour Rated Protection The requirements contained in QAPSO Section 17.2.15 for alternate records storage facilities are consistent with the guidance provided by the NRC NUREG-0800 Chapter 17.1 A Durin the Desi n and Construction Phases. Section 17.4 of this chapter under Quality Assurance Records 17.1.17 describes the use of 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rated records storage facilities meeting NFPA 232 requirements. Based on this NRC endorsement of the use of alternate single facilities for the storage of records, this change should be considered acceptable.
This change does not reduce the scope of the Quality Assurance Program.
Tem orar Stora e of Records The use of temporary storage is requested to allow the use of one-hour fire rated cabinets to store records that are awaiting processing for permanent storage (i.e. duplication or transfer to a single facility).
The storage of these records in one-hour rated cabinets will be controlled by procedures which specify a maximum allowable time limit.
The records processing room in which the one-hour fire rated containers are stored is protected by sprinklers.
The use of sprinklers in this room would limit the spread of a potential fire, and provides additional protection to the records stored in the cabinets.
Therefore, the records stored in these cabinets are
ATTACHMENT 1 effectively provided greater than one-hour rated protection. Since this protection provides reasonable assurance that the records will not be lost or damaged, this change does not reduce the scope of the Quality Assurance Program.
Regulatory Guide 1.144 Current Commitment RGEE is currently committed to Reg. Guide 1.144, Rev. 1, which endorses ANSI N45.2.12-1977. Section 4.5.1 of ANSI N45.2.12-1977 requires "In the event that corrective action cannot be completed within thirty days, the audited organization's response shall include a scheduled date for corrective action."
Re uested Chan e In lieu of the 30 day requirement of Section 4.5.1 of ANSI N45.2.12-1977 the following is proposed: The audited organization shall respond to audit findings prior to the requested date. In the event that corrective action can not abc completed prior to the response due date, the audited organization's response shall include a scheduled date for completion of the corrective action.
Justification for Chan e Ginna uses a single point corrective action process. This process is used to identify all items requiring corrective action at Ginna Station, including audit findings. During the initial review of each item requiring corrective action, a priority is assigned based on its significance.
The current 30 day requirement for audit findings, in audit findings receiving a high level priority however,'esults regardless of their significance. The proposed change will allow audit findings to be prioritized using the same process as other items.
Since the prioritization process used in the corrective action process is acceptable for items identified by other plant personnel, it should be considered acceptable for the prioritization of findings identified by audit personnel.
This process will support meeting 10CFR50, Appendix B Criterion II expectations that activities affecting quality be accomplished using controls consistent with their importance to safety. This change does not reduce the scope of the Quality Assurance Program.
~ ~
ATTACHMENT 1 Regulatory Guide 1.146 Current Commitment RG&E is currently committed to Reg. Guide 1.146, Rev. 0, which endorses ANSI N45.2.23-1978. Section 2.3.4 of ANSI N45.2.23-1978 requires that prospective lead auditors participate in a minimum of five QA audits within a 3 year period prior to qualification.
Re uested Chan e In lieu of the requirements of 2.3.4 of ANSI N45.2.23-1978 the following change is requested:
"Prospective lead auditors shall demonstrate their ability to effectively implement the audit process and effectively lead an audit team. RGRE will describe this demonstration process in written procedures and shall evaluate and document the results of the demonstration. Regardless of the methods used for the demonstration, the prospective lead auditor shall have participated in at least one nuclear quality assurance audit within the year preceding the individual's effective date of qualification. Upon successful demonstration of the ability to effectively implement the audit process and effectively lead audits, and having met the other provisions of Section 2.3 of ANSI N45.2.23-1978, the individual may be certified as being qualified to lead audits."
Justification for Chan e The revised requirements for certification of lead auditors are consistent with the guidance provided by the NRC in a letter titled "Review of Nuclear Energy Institute Proposed Improvements to QA Programs", dated October 24, 1996. The revised requirement meets the intent of Section 2.3.4 of ANSI N45.2.23-1978 to have the prospective lead auditor demonstrate the ability to effectively implement the audit process and to lead an audit team.
Since the revised requirements meet the intent of the original requirement and the NRC has proposed this approach as an acceptable alternative, this change does not reduce the scope of the Quality Assurance Program.
ATTACHMENT 1 17.2 PERFORMANCE/VERIFICATION 17.2.4 Procurement Control Text under "Control of Supplier Performance" was changed to read:
Control of supplier performance shall include:
~ Monitoring supplier activities through audits and surveillances.
~ Evaluation by requesting submittal of supplier documents for review.
~ Identifying under what conditions suppliers are to report nonconformances.
The existing paragraph in the QAPSO could not be easily interpreted by the plant staff. Through a review of previous revisions of the QAPSO, the purpose and intent of this paragraph was confirmed. This paragraph was rewritten to provide clarification. This change is not considered a reduction in commitment.
17.2.15 Records The records section was revised to provide detailed implementation of the revised Reg. Guide 1.88 commitment.
Justification for this change is described in the change to Table 17.1.7-1, Conformance of Ginna Station Program to Quality Assurance Standards, Requirements and Guides.
ATTACHMENT 1 17.3 ASSESSMENT Table 17.3.2-1 Audit List Re uested Chan e The following line items were revised as follows:
- a. The conformance of facility operation to ~provisions contained within the Technical Specifications and applicable license conditions.
- c. The results of eked.actions taken to correct deficiencies occurring in facility equipment, structures, systems, or methods of operation that affect nuclear safety.
- d. The performance of ~activities required by the Quality Assurance Program to meet the criteria of 10CFR50, Appendix B.
Justification for Chan e The word "all" as used in these audit descriptions implies an excessive requirement. The existing wording could be interpreted to mean that:
- a. ALL Technical Specification provisions are audited every 24 months. This would include a verification of each and every surveillance test, LCO etc.
ALL action taken to correct deficiencies are audited every 24 months. This would include a review of each and every ACTION Report affecting safety-related items and the corrective action taken.
ALL activities required by the QA Program. This would include a verification of each and every safety-related work order, purchase order, calibration, procedure change, test, inspection, design change etc.
ANSI N45.2.12-1977 Section 4.3.2.3 states "Selected elements of the quality assurance program shall be audited to the depth necessary to determine whether or not they are being implemented effectively".
ATTACHMENT 1 Ginna uses a sampling approach to meet this requirement, rather than a review of every safety-related activity. It is not necessary to perform a 100'. review of activities to determine the effectiveness of the implementation of the program being audited.
This approach has been proven effective throughout the life of the plant.
The revised program, as described above, continues to satisfy the 10CFR50, Appendix B criteria and does not reduce the scope of the Quality Assurance Program.
Attachment 2 ROCHESTER GAS AND ELECTRIC CORPORATION R.E. GINNA NUCLEAR POWER PLANT Quality Assurance Program for Station Operation Revision 26 DOCKET NO. 50-244 December 21, 1998
1~
The Nuclear Policy Manual provides a method of applying a graded y QA Program to systems, components, items, and services which are not classified as safety related (SR), but are considered necessary for reliable plant operation.
Special terms used in this document which are not found in ANSI N45.2.10 "Quality Assurance Terms and Definitions" are defined in Table 17.1.1-2, Supplementary Glossary.
17.1.2 Organization The major organizations participating in the Quality Assurance Program fall within the Generation unit, under the leadership of the Senior Vice President, Generation. They are:
a Nuclear 0 erations including Ginna Station, Nuclear Engineering Services, Nuclear Assessment, Nuclear Training, and the Plant Operations Review Committee
~ Nuclear Safet Audit and Review Board NSARB Under the Corporate Services Unit, the following organizations participate in the QA Program:
~ Information Services
~ Support Services - including Strategic Supply Management, Laboratory and Inspection Services, Physical Services, and Technical Services.
Additionally, the Energy Delivery Group provides support for the QA Program.
Figure 17.1.2-1 is an organization chart showing these organizations and their relationship to the corporate organization. Chapter 13 of the UFSAR augments the Figure with organization charts for the various departments.
Positions responsible for the principal elements of the quality assurance program are:
Chairman of the Board, President, and Chief Executive Officer Senior Vice-President - Corporate Services Senior Vice President, Generation Vice President, Nuclear Operations Group
~ Plant Manager, Ginna Station
~ Department Manager, Nuclear Engineering Services
~ Department Manager, Nuclear Assessment
~ Manager, Quality Assurance
~ Manager, Gpixatiap'a3.':,:::;:::;:::::Rev'ie, I
~ Department Manager, Nuclear Training RG&E QAPSO, Revision 26 December 21, 1998
Group Manager, Support Services
~ Group Manager, Energy Delivery
~ Group Manager, Information Services SENIOR MANAGEMENT Chairman of the Board President and Chief Executive Officer The Chairman of the Board, President, and Chief Executive Officer of the Rochester Gas and Electric Corporation directed the establishment of the Quality Assurance Program and issued the governing policy statement. He established the Nuclear Safety Audit and Review Board to review and audit plant operations. The Chairman of the NSARB is responsible to the Chairman of the Board, President, and Chief Executive Officer on all activities of the NSARB ~
Senior Vice President Generation The Senior Vice President, Generation reports to the Chairman of the Board, President and Chief Executive Officer. He oversees all organizations involved in the operation and support of Ginna Station, including the Quality Assurance Program. He is also responsible for those items delineated in the Administrative Controls section of the Technical Specifications.
Senior Vice President Cor orate Services The Senior Vice President, Corporate Services reports to the Chairman of the Board, President and Chief Executive Officer and oversees Support Services'nd Information Services'ctivities supporting Ginna Station.
NUCLEAR OPERATIONS Vice President Nuclear 0 erations Grou The Vice President, Nuclear Operations Group is responsible to the Senior Vice President, Generation and has corporate responsibility for operation of Ginna Station in accordance with applicable regulatory requirements. In addition, he has overall responsibility and authority for directing the Quality Assurance Program and is responsible for the approval of the Nuclear Policy Manual. He is responsible for establishing the policies and requirements necessary to assure safe and reliable operation of Ginna Station and for oversight of Ginna Station and those support activities associated with Nuclear Engineering Services, Nuclear Assessment, and Nuclear Training.
RG6E QAPSO, Revision 26 December 21, 1998
Plant Mana er Ginna Station The Plant Manager, Ginna Station is responsible to the Vice President, Nuclear Operations Group for the overall on-site safe operation of Ginna Station. He is responsible for:
a the performance of all Ginna Station quality affecting activities in accordance with the requirements of the Quality Assurance Program
'd' >>'
activities in accordance with approved drawings, 1'ffecting specifications, and procedures
~ implementation of those items delineated in the Administrative Controls Section of Technical Specifications
~ timely referral of appropriate matters to management and the NSARB
~ assuring that significant conditions adverse to quality are identified and corrected.
The Plant Manager, Ginna Station assigns responsibility to Superintendents and designated staff members for the control of all activities involving operation, maintenance, repair, refueling, implementation of modifications, radiation protection, equipment, control and storage of portable material handling equipment, gjij::;;:-::::jY9OteC't'gO~n::';'and plant security. Responsibility is delegated for'the implementation of Quality Assurance Program requirements at the plant for testing, operation and test status control, and calibration and control of measuring and test equipment .
RGEE QAPSO, Revision 26 December 21, 1998
De artment Mana er Nuclear En ineerin Services The Department Manager, Nuclear Engineering Services is responsible to the Vice President, Nuclear Operations Group for:
design of modifications to the facility in accordance with applicable design bases, regulatory requirements, codes, and standards implementation of the licensing/compliance program maintenance of Ginna Station design and licensing basis nuclear fuel management technical support for Ginna corrective action technical support for Ginna operations computer support procurement activities De artment Mana er Nuclear Assessment The De p artment Mana g er Nuclear Assess ment is responsible to the Vice President, Nuclear Operations Group for establishing the overall Quality Assurance Program. He is responsible for assuring that all planned and systematic actions necessary to provide adequate confidence that Ginna Station will operate safely and reliably are established and followed. He provides management with objective information concerning quality, independent of the individual or group directly responsible for performing the specific activity. He has the authority and organizational freedom to assure all necessary quality activities are performed. He is responsible for directing the activities of Quality As su nancejan'8',"",::opal'tat i.';anal'!!Reava eat~,
RG6E QAPSO, Revision 26 December 21, 1998
De artment Mana er Nuclear Trainin The Department Manager, Nuclear Training is responsible to the vx'centi: F7%8K'68<F'~!HQ'C%%T> "op'8VKFS,'ox':
Gro~ggfor maintaining and implementing a N'ational Academy for nuclear Training accredited training program. ~jij','::id4i4a'OA'j:::::,':ih'8,:;.:.48 x@'so'oh"siuLe>::,g'ox,'!::::Nu'chic'i'ri::,.:';;Emergency,::::.,:Bren@re'cnesi','::".>
CORPORATE SERVICES Grou Mana er Su ort Services The Group Manager, Support Services is responsible to the Senior Vice President, Corporate Services for directing certain activities in support of Ginna Station. These activities include:
~ purchasing of materials, services, and components from qualified suppliers, in accordance with applicable commercial, technical, and quality requirements.
~ special processes
~ inservice inspection
~ maintenance of lifting and handling equipment
~ training and qualification of welders and NDE personnel provision of personnel support for Ginna Station maintenance activities chemistry services laboratory testing and calibration of electrical MSTE reference standards.
RG6E QAPSO, Revision 26 December 21, 1998
TABLE 17.1.7-1 (cont'd)
Standard Re uirement or Guide Conformance Remarks Status Regulatory Guide 1.39 Rev.(2)-Housekeeping Conforms RG 1.39 Rev.(2) incorporates ANSI N45.2.3-1973.
Requirements for Water-Cooled Nuclear Power Plants Regulatory Guide 1.54 Rev.(0)-Quality Assurance Alternative Quality assurance requirements apply only when a coating performs a safety related function Requirements for Protective Coatings Applied to instead of the provisions stated in this Regulatory Guide and its referenced standard, ANSI Water-Cooled Nuclear Power Plants N 101.4-1972.
See the UFSAR for quality assurance requirements used for existing coatings. For new coatings and configuration changes to existing coatings, either the quality assurance requirements of the UFSAR or the quality assurance requirements of 10CFR50, Appendix B are used instead of the detailed requirements included in this Regulatory Guide.
Regulatory Guide 1.58 Rev.(1)-Qualification of Alternate RG 1.58 Rev.(1) incorporates ANSI N45.2.6-1978. Ginna conforms to Rej;::;::::.:":.".GutCh'::,::I:::,."58 Nuclear Power Plant Inspection, Examination, and Roy:.:(fj:;::y8:.ANSI N45.2.6-1978 with the foj/598'kg:;::exceptiont:
Testing Personnel
~ A 90 day grace period may be applied to the performance of annual evaluations of inspection, examination and testing personnel qualifications defined in Section 2.3 of mttSI!N4$!2!S-"",,ISsIS.
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fltequallftcatjoji: attd:,'ccittfic'alto'it'.o f;:n'on'des'truct tve":gati'itg::I'Iem'nitci,'";ITIte,'.'jtatidard r@fdrencesd:,'.iit'::th)::A)htP,.cGtjc:,:;:is;:osed-;:i) iererence'd;;,by,:.-::;;Rej:,'::,,Gutde::;:.1'$8:-'::;RE'.::,:).
Regulatory Guide 1.64 Rev.(1)-Quality Assurance Conforms RG 1.64 Rev.(1) incorporates ANSI N45.2.11-1974.
Requirements for Design of Nuclear Power Plants Regulatory Guide 1.74 Rev.(0)-Quality Assurance Conforms RG 1.74 Rev.(0) incorporates ANSI N45.2. 10-1973. Some definitions used by Ginna are Terms and Definitions worded differently than those in this standard; however, the general meanings are the same.
RG&E QAPSO, Revision 26 December 21, 1998
TABLE 17.1.7-1 (cont'd)
Standard Re uirement or Guide Conformance Remarks Status Regulatory Guide 1.88 Rev.(2)-Collection, Storage, Ceafeans RG 1.88 Rev.(2) incorporates ANSI N45.2.9-1974.~::.::,Gjidt'nema:;."cort forms.:,:to'"'p'YSl::::N45,':.'2:9,-,'1974 and Maintenance of Nuclear Power Plant Quality gA'Irexnatiye t~m~aooxovo';etc m;',SupylementetI,:"::;Iiy,,':(he,: JOjlOWjvg::.,::ylternaitVes".:tO,;::6e:
Assurance Records fn".O'APSO!Secwt'oIt.':::5, /';2::::fde teufuiitrmetfthyiexneths of'OA'PSO!Svecttun::::fyg':,::l5:':mt"emet".
Regulatory Guide 1.94 Rev. (1)-Quality Assurance Not applicable RG 1.94 Rev.(1) incorporates ANSI N45.2.5-1974. Regulatory Guide applies to plants in the Installation, Inspections, and Testing of Structural construction phase and was issued after Ginna was built.
Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants Regulatory Guide 1.116 Rev.(O-R)-Quality Conforms RG 1.116 Rev.(O-R) incorporates ANSI N45.2.8-1975.
Assurance Requireinents for Installation, Inspections, and Testing of Mechanical Equipment and Systems Regulatory Guide 1.123 Rev.(1)-Quality Assurance Conforms RG 1.123 Rev.(1) incorporates ANSI N45.2.13-1976.
Requirements for Control of Procurement of Items and Services for Nuclear Plants Regulatory Guide 1.143 Rev.(1)-Design Guidance Alternative See the UFSAR for design and quality assurance provisions applied to existing radioactive for Radioactive Waste Management Systems, waste management systems, structures, and components. New systems, structures, and Structures, and Components Installed in Light- components and configuration changes to existing items meet the design and quality assurance Water-Cooled Nuclear Power Plants provisions described in the UFSAR or those specified by this Regulatory Guide.
Regulatory Guide 1.144 Rev.(1)-Auditing of Quality Alternate RG 1. 144 Rev.(1) incorporates ANSI N45.2.12-1977. Ginna conforins to RG 1.144 Rev.(1)
Assurance Programs for Nuclear Power Plants f;.'Aa'tNnsf2rdr."2!'l252'pyy bithcathe toftotv'ittg::,excepdonsi that-a grace period of 90 days may be applied to the performance of triennial supplier audits and annual supplier evaluations described in Section C.3.b.(2).
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RG&E QAPSO, Revision 26 December 21, 1998
TABLE 17.1.7-1 (cont'd)
Standard Re uirement or Guide Conformance Remarks Status Regulatory Guide 1. 146 Rev.(0)-Qualification of QA Alternate RG 1. 146 Rev.(0) incorporates ANSI N45.2.23-1978. Ginna conforms to RG 1. 146 Rev.(0)
Program Audit Personnel for Nuclear Power Plants and.:,AN81".ÃO'SP;:23@&78jwith the fo]l'0%76'g exceptionm that-a grace period of 90 days may be applied to the performance of annual lead auditor recertifications described in Sections 3.2 and 5.3,0J 'A'N8I;Ã45,::2'".."23,":,'.:$978.
'0'emon'st'itatio'ii'jii~ess"it'ibitte'r'i jio'cedi)res':.':a'rid:::::shill:,::,e'v'aliiate':,
'steadies'te'e:::,'ai'i'di't':Sea'jtttmitIt'e"..,":jeettt'te'eaeddti'ig:,ttI'ii::,i'a'djy'td'Oal!S tfeC e"i
- .tee'd teS:s."O' jiialif)'iitioi";-.'Ujoi:.':succdessfIIl.",;dimiisIraIpi)i:'of ihejb)itiy',':::to",esffeca Si-,"iu'dit".p'roces's.".a'ttd::;effmi)v'el'.::lea'd'audit's,":;,"'a'n'd.;:hav1n j':;~:.;thee'jib'e'i",.jim~ist 8etction::S3:::".6'f:,""A)8I."s'N4$'."'2's'23!'::iN8,'"::::,'ts
- jttalified'."to'3ea'd,
- ::audIg>
Regulatory Guide 1.152 Rev.(0)-Criteria for Alternative Ginna conforms to Generic Letter 95-02, and its endorsement of NUMARC/EPRI Report TR-Programmable Digital Computer System Software in 102348 "Guidelines on Licensing Digital Upgrades".
Safety-Related Systems of Nuclear Power Plants Regulatory Guide 4.15 Rev.(1)-Quality Assurance Adopted Ginna conforms to the intent of this Regulatory Guide as addressed in the Process Control for Radiological Monitoring Program (Normal Program and applicable to Ginna effluent and environmental radioactivity measurements.
Operations)-Effluent Streams and the Environment Regulatory Guide 7.10 Rev.(1)-Establishing Quality Adopted Ginna conforms to the intent of this Regulatory Guide as addressed in the Process Control Assurance Programs for Packaging Used in the Program.
Transport of Radioactive Material 10CFR21 Conforms 10CFR50, Appendix A-General Design Criteria Alternative These criteria were in draft form or not written at the time Ginna was designed and built.
For existing systems, see UFSAR for criteria applied. New systems, structures, and components, and configuration changes to existing items meet the criteria as described in the UFSAR or 10CFR50, Appendix A.
RG&E QAPSO, Revision 26 December 21, 1998
FIGURE 1 .2-1 Organiza art CHAIRMANOF THE BOARD, PREStDKNT AND UNES OF SUPERVISION CMKF EXECUTIVE OFFICER SEMOR VICE SEMOR VICE PRESIDENT PRESIDENT.
CORPORATE GENERATION SERVICES GROUPMANAGER CROUP IIANAGER CROUPMANAGER VICE PRKSIDfNT NSARB j EkfRGY DfUVERY INFORMATIONSERVICfS SUPPORT SKRVCES MICLEAR OPERAlloNS GROUP DKPARTIIENT DEPARTMBIT MANAGER, MANAGER FACIUTY WSRIBUTIVE ~PORC DESIGN WFORMATION DKPARTMKNT DEPARTMENT DEPARTMENT SUPEIURSOR SYSTEMS MANACER MANAGER MANAGER BUDGET 4 COST MANAGER SUPPORT NUCLEAR NUCLEAR NUCLEAR GINNA STATION DEPARTMENT CROUP ENCINKERWO ASSESSMENT TRAWWO DEPARTIIENT MANAGER IIANAGER ENGWKKRWO, SERVICES IIANAGKR TECHMCAL STRATEGIC SUBSTAlloN COMMUMCATIONS SERVICES SUPPLY HUMAN DESIGN MANAGEMENT TRAIMNO RESOURCE STRATEGY, OUAUTY SERVICES SUPERWTENDENT SUPERINTENDENT SUPERVISOR SERVICES DEPARTMENT MANAGER FACRBlES, COMPUTER ASSURANCE, 4 CWNA CINNA NUCLEAR MANAGER PRODUCTION SYSTEMS, CUAUTY NUCLEAR PRODUCTION MAINTENANCE SECUIUTY PROIECT MATERIAL OVERHEAD SUI'PORT CONFIGURATION CONTROI EMERGENCY MANAGBIENT PROCIIRBIENT CONSTRUCTHIN SERVICfS SUPPORT, OPERAlloNAL PREPAREDNESS SERVICES. 4 CONTROL NUCLEAR REVIEW,S AND ENVIRONMENTAL ANO ELECTRIC OPERATIONS. MAINTENANCE IAWTENANCK SAFEtY AND RECORDS CHBSSTRYI PIANMNCISYSTKMS.
EMPLOYEE SENhCES AllO 4 GAS METER UCENSWO, MANACEltENT TECHMCAL CORPORATE OPERATIONS RADIATION MC AND ELECTMCAL RELATIONS INFORMATION BALANCEOF SAFETY PROTECTION, MAWTENANCE, AND CENTER. PLANT SAFETY REIAY AND MECHAMCAL INFORMATION ENCWKfRWG, COORWNATOR TESTING SCHEDUUNO MAINTENANCE, SERlhCKS 4 14C/ELECT. INVENTORYCONTROL SKRVICKS MANAGER DEPARTMENt DIVtSION ENGWEKRWO, LABORATORYand MANAGER PRIMARY SYSTEMS INSPECTION PHYSICAL SYSTKMS SERVICES SBMCES ENGWKKRWO, REACTOR KNGWKERWO ENVIRONMENTAL CKNfRAL SCIENCE, IAINTENANCE LABORATORY FIELD 4 SHOP CHBCSTRY FABRICATION SERVICES, SERVICES, MATERIALS WELDWO ENGWEERINO, SENhCES, NDE,IMa TRANS PORTAltoN IIHE INSPKClloN AND SURVEYINO SERVICES AND SERVICES EIECTIUC lASORATORY SKRVCES RG&E QAPSO, Revision 26 December 1, 1998
Acce tance of Items and Services The verification methods for the acceptance of items and services are specified during procurement planning and purchase requisition preparation. Receipt inspection is a verification method common for the acceptance of items.
17.2.5 Procurement Verification The supplier's overall quality assurance organization and program is evaluated in accordance with applicable parts of 10CFR50, Appendix B; codes and standards; and RG&E requirements.
Suppliers on the approved suppliers list are reviewed annually for performance and program changes, and audited on a triennial basis.
The degree of supplier surveillance (including review, inspection, or audit) required during design, fabrication, inspection, testing, and shipping shall be determined and documented. The objectives of supplier surveillance are to provide a sampling review of the supplier's quality assurance program implementation and to verify product conformance with respect to the purchase order requirements. The extent of supplier surveillance will be consistent with the safety significance, complexity, quantity, and frequency of procurement of the item or service. As necessary, this may require verification of the activities of suppliers below the first tier.
The verification responsibilities for evaluation and surveillance of supplier activities are assigned to Quality Assurance.
Department supervision is responsible for receipt and control of items pending their acceptance.
Receipt inspection is performed for items and associated services
, for maintenance, repair, modification, and refueling. Inspections are performed to verify acceptability. To be acceptable, the items and services must conform to procurement documents, have satisfied required inspection and test requirements, and have documentary evidence of conformance available at the plant prior to acceptance for use. Personnel performing receipt inspection and test activities are trained and qualified.
17.2.6 Identification and Control of Items RG&E QAPSO, Revision 26 December 21, 1998
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17.2.15 Records The Nuclear Policy Manual defines responsibility and establishes the basic requirements for quality assurance record retention and maintenance. Organizations performing quality affecting activities are responsible for forwarding the records they initiate to Records Management. Each organization generating records is responsible for preparation, review, approval, and implementation of specific quality assurance record procedures for their area of responsibility.
Records to be controlled are delineated in ANSI N45.2.9-1974.
Sufficient records of items and activities are generated and maintained to document completed work. Items and activities requiring records include:
design engineering procurement manufacturing construction inspection and test (e.g., manufacturer's proof and receipt) installation operations maintenance
~ modification
~ audits Requirements and responsibilities for preparation, inspection, identification, indexing, review, storage, retrieval, maintenance, safekeeping, retention, and disposition of quality assurance records are in accordance with applicable records procedures, codes, standards, and procurement documents.
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RG&E QAPSO, l
Revision 26 December 21, 1998
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The requirements and responsibilities for record accessibility and transmittal are described in the Nuclear Policy Manual.
Removal of records from storage is documented and accountability is maintained by the responsible record control organization.
RGGE QAPSO, Revision 26 December 21, 1998
0 erational Assessment 4.wa~cw ew... +,.
"gaea The Operational:,':,'::.Review' section receives and evaluates informati.on'rom other utilities and vendors. The Nuclear Safety and Licensing section of Nuclear Engineering Services receives and evaluates information from INPO and the NRC. They ensure that relevant and timely recommended actions are provided to management that will eliminate precursors of similar problems at Ginna. This is accomplished through:
coordinating feedback program to measure and improve the internalization of lessons learned from Operating Experience reviewing XNPO SOERs and SERs reviewing vendor 10CFR Part 21 report of defects reviewing NRC information notices.
RG&E QAPSO, Revision 26 December 21, 1998
Table 17.3.2-1 Audit List Audit To ic Areas (24 months)
- a. The conformance of facility operation to allprovisions contained within the Technical Specifications and applicable license conditions.
- b. Performance, training, and qualifications of the operating and technical staff.
- c. The results of aR actions taken to correct deficiencies occurring in facility equipment, structures, systems, or methods of'peration that affect nuclear safety.
- d. The performance of aR activities required by the Quality Assurance Program to meet the criteria of 10CFR50, Appendix B.
- e. Facility Fire Protection Program and implementing procedures.
Inspection and audit of the fire protection and loss prevention program performed by non-licensee personnel. The personnel may be representatives of ANI, an insurance brokerage firm, or other qualified individuals.
- g. The radiological environmental monitoring program and the results thereof.
- h. The Offsite Dose Calculation Manual and implementing procedures.
The Process Control Program and implementing procedures.
RG&E QAPSO, Revision 26 December 21, 1998