Text

QA Program for Operation,Policy Documents
	ML20033H064
Person / Time
Site:	Cooper
Issue date:	04/06/1990
From:	; NEBRASKA PUBLIC POWER DISTRICT
To:	;
Shared Package
ML20033H063	List: ML20033H064; NLS9000138, Forwards Rev 6 to QA Program for Operation,Policy Document, Reflecting Current Organization & Practices & Clarifying Responsibilities;
References
	NUDOCS 9004180065
	Download: ML20033H064 (94)
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Corporate-Policy Statement. . c. ';.. v- .1 f. 1 ~. 0. PROGRAM DEFINITION .x. 11' l'.1 Purpose-1-2 -1.2 . Policy 11' 2. l.3 Objectives' ^ '14. 1.4- ' Scope l ' 1.5-Definition of Terms 1 8.. 2.0

SUMMARY

DESCRIPTION 2 1 s: 'b 1 2.1. Organization 21 2.2= zQuality Assurance Program-2 ' 2.3 ' Design Control' 25 2.4 . Procurement Document Controli c2 11.

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2.17. Quality Assurance Records 2.18 Audits

- r. 2-30 g Additional' ANSI. Standards. '2-32! 2 19 3.0 ORGANIZATION AND RESPONSIBILITIES -3 l' 3 3.1 General' 3-1 3.~ 2 '. Nuclear Power Group' Management '3-2s a .32 -3.2.1-Vice President -: Power-Production- . l -3.2.2 Nuclear Power Group Manager ~ c3-21 '[ v 3.2.3 Division Manager,-Quality Assurance 3-3L .{ 1 1.3 4' h 3.2.4 iQuality Assurance' Manager CNS'- t -3.2;5 Quality Assurance Manager - CGO' 36~ I 1 Si ',l. ! D j 11-Revision 6L R' l.; g * ~ L a; y, l ^' ' m g g mm. _g:'!I w-mm ..e

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Quality Assurance Supervisors 3.2.7 . Quality Assurance Staff.. ~ 3-8 L 3.2.8 Division Manager i a Nuclear Engineering and Construction... 3 10 j 3.2.9l Division Manager f . Nuclear Operations. 3 10- .a 3 3.2.10 - Division Manager - Nuclear Support 3.2.11 CGO Department Managers 3 11 3.2.12. CNS Department Managers. 3-12 l l L3.3 Cooper Nuclear Station' Personnel. 3 12 3.4 CCO Personnel 3 12 3.5 . Safety Review and Audit Board'(SRAB) 3-13 5 3.6 Station Operations Review Committee'(SORC). 3-13 3.7 Outside Suppliers, Contractors, Subcontractors, and Consultants 3 13' 4.0 QUALITY ASSURANCE DOCUMENTS 4-1 4.~1 NPPD Internal Documents 4-1 4.1.1 Quality Control Inspection 4-2 4.1.2~ Quality Assurance Instructions (QAI) 4-4 4.1.3-Quality Assurance' Plans (QAP) 4-4 i 111 Revision 6 .7

~ rc.,.v.n '-g ~ i. 4 t .i 1 ' TABLE OF CONTENTS '-(Cont' d). 5.0< METHOD OFl IMPLEMENTATION; ... ~.... '5..... c 6.- 0 . RECORDS RETENTION AND. DISPOSITION.. 6-1$ 7.0 ' REFERENCES 7-1 .4 8,0; FIGURES 81 si ) 8.1 - Quality Assurance Organizational. Chart-(Figure 1) 8-lj y i e 'l 9.0 TABLES 9-1' d q-9.1 - Systems and Components Within Scope of the CNS QA' Program (Table 1) 9.....,............... 1 9.2 Three Level QA Program (Table 2) '9-4 -i

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l -CORPORATE' POLICY STATEMENT This document establishes and describes the policies and practices of the + Quality Assurance Program applicable to the' operation' of the Cooper Nuclear .L Station and the support activities of all NPPD Nuclear Divisions. The District's policy with respect to nuclear safety and quality assurance is detailed in _Section 1.2 ofLthis document. Each Nuclear Division is responsible for: the development of policies and procedures which implement this Quality Assurance Program. Other divisions and - departments at NPPD may also have responsibilities under this program and shall-comply as described in appropriate implementing procedures, The '-Quality Assurance Division and established Safety Committees shall i monitor the District's nuclear. program and provide management with evaluations and assessments regarding the effectiveness of the implementation of the program. When evaluations and assessments identify a concern, management shall take expeditious action to correct any undesirable condition (s) including, where. appropriate, action to preclude repetition of.such condition (s). l District personnel shall have the organizational freedom to identify l i concerns and propose corrective and preventive action necessary to enhance the l District's-nuclear program, l The assurance of safe and -reliable operation of Cooper Nuclear Station is-3 l everyone's duty. Quality shall be everyone's responsibility. APPROVED: s I J b // oY ~ $f I P'esident r Nuclear Power Group Manager k } jlsion Manager.- Quality Assurance (L o Ch M .Vicb-Pfesipent - Power Production Div v Revision 6

i; ' t lg COOPER NUCLEAR STATION Ti - OUALITY ASSURANCE PROCRAM FOR-OPERATION I POLICY DOCUMENT s 3 i L1,0 -PROGRAM DEFINITION ~f In faccordance with the - conditions: of the Nuclear Regulatory -- Commission - construction permit and operating license for the Cooper Nuclear Station', the? r

management of Nebraska Public. Power District recognizes its responsibility:for assuring that the Cooper Nuclear Station-is designed, constructed, and operated -

in.such a manner as to provide for the safety of the public. The importance of Quality Assurance in contributing - to this ' safety as well as contributing to.- t station reliability is also recognized. The initial phases of-the overall Quality Assurance. Program, implemented a during design and construction,. provided an independent check for the worka performed on components, structures, and: systems of the station to assure that l, the design, analysis, materials of construction, manufacture,. installation, L. erection, and construction met quality standards required to assure reliable and safe' operation. The CNS Quality Assurance Program for Operation, as described-l herein-, is implemented to provide an independent quality check on all phases of ~ . station operation, maintenance, and modification.

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s.- t 1.11 Purnose i The purpose of this policy document is to provide a description of the . Quality' Assurance Program to be followed during Cooper Nuclear Station . operational' phase'and.to provide guidelines for implementation of the policies; o and procedures described herein. This CNS Quality Assurance Program l for Operation was developed by Nebraska Public Power District.in response to the c requirements of 10CFR50 Appendix B. .This policy document provides a general-y description of the Quality Assurance Program for Operation and requires that ] detailed Quality Assurance Documents be set forth in writing and carried out by each of the responsible organizations or individuals within the District. !q 1.2' Poliev It is the policy of. Nebraska Public Power District. (NPPD) to use its best efforts to assure that the Cooper Nuclear Station is designed, constructed, maintained, and operated in-a manner. that will provide-the highest practical, degree of safety and reliability. Structures, components, and ' systems are i designed, fabricated, erected, maintained, and modified to quality standards appropriate to their importance in the safety function. The Quality Assurance Documents will identify those structures, systems, and-major components to be i covered by the Quality Assurance Program in order to provide continuing i compliance with these standards throughout the operating life of the station. Additionally, it is the policy of NPPD that activities affecting quality shall be ' documented by approved instructions, procedures, or drawings and such activities shall be implemented as documented. And further, such documentation i 1-2 Revision 6 ~

p 4 t shallLcontain adequate' qualitative and/or. quantitative' acceptance criteria to

provide a measure of accomplishment, f

It is the policy -of-Nebraska Public, Power District (NPPD) to staff the Nuclear Power Group (NPG)' with properly-trained' personnel in all responsible positions. and. job ? assignments.' Sufficient numbers of licensed and senior 111:ensed-operating personnel vill be. available 'to assure proper operation of the f ' station' under all reasonably -foreseeable circumstances of personnel turnover, l l vacations,. disability, and the like. 1 .1 All District personnel, as well as non-District personnel who are working ,J: under NPPD's QA Program, responsible for operating, maintaining, or designing-safety-related systems and equipment shall receive formal instruction in Quality - Assurance, including basic principles,10CFR50, Appendix B, -the contents of this policy document, and Quality Assurance Documents as applicable. i

Trained technical, engineering, and-Quality Assurance Personnel shall be

. assigned surveillance and audit tasks to ensure compliance with the requirements i of the documents which control station operation, such as the NRC license, Saft.ty Analysis Report, ' Technical Specifications, Operating Manual', QA Program for Operation, and other such controlling documents. During the time personnel are performing QA functions, they shall be responsible to the QA Division to maintain the organi::ational independence required by the QA Program. f i It is the policy of Nebraska Public Power District to maintain quality standards for Cooper Nuclear Station which will ensure the high degree of l l l l-3 Revision 6 ... _. ~. - ~ _...

? reliability and safety. needed - to meet the overall ' objectives of supplying ~ dependable electric service to its customers. r ' The CNS QA Program.for Plant Operations will' utilize the guidance provided ? by NRC publications WASH 1283 (5-24 74), WASH-1284 (10-26-73), and WASH-1309: (510-74) (" rainbow" series) except where specific exceptions and clarifications I are noted' within this -document. 'Where specific requirements included in the standards are in conflict with original desi n requirements set forth in the USAR ' f 5 and other. appropriate desf.gn documents, the original design requirements shall -i govern. Later. revisions may be specifically ' invoked by'the design requirements where deemed appropriate, consistent with the overall commitment to maintain the plant in an " equal to or better than original" condition. ~In summary, NPPD is. committed to the continuous development of a. Quality- - Assurance Program which will meet the requ*.rements of' 10CFR50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants, and other applicable regulations as may be promulgated'by the Nuclear Regulatory Commission.- This commitment applies to all NPPD organizations to assure that a high standard of i quality will be maintained during nuclear plant operation. Section 2 of this document presents a summary discussion of the QA Program as applicable to the [ 18 criteria of 10CFR50, Appendix B, o 1.3 Obiectives In accordance with the policy statements above, the overall objective of the CNS Quality ' Assurance Program for Operation,- as defined in Quality Assurance Instructions (QAIs) and Quality Assurance Plans (QAPs), is to set forth the 1-4 Revision 6

1 " Quality Assurance organizational structure and personnel responsibilities and -to set forth general requirements for the preparation of written procedures and controls necessary for quality surveillance and auditing to verify the following: l a). - Regulatory criteria, codes. and standards, and design bases for-i safety related systems (as defined in.the CNS QA Program) are incorporated into the test, operating, modifications, and maintenance procedures and instructions to-meet all-requirements for nuclear safety and station reliability; b) Results of all preoperational and operational tests of safety-related systems and components conform to,the requirements ~ of the drawings, specifications, procedures, and instructions, and that appropriate reports are prepared to document that all results of tests meet prescribed acceptance criteria; c) ' Nuclear Fuel -is purchased, designed, manufactured, inspected, packaged, shipped, received, installed, and operated in the reactor in accordance with approved procedures, instructions, regulatory requirements, and license-stipulations; L d) The Station is operated, maintained, tested, refueled, repaired, and modified, in _accordance with approved procedures, instructions, regulatory requirements, and license stipulations, consistent with quality standards equal to or better than those in effect during design and construction; l-5 Revision 6 i

j . e)' A _ system is established and= maintained to-control,- safeguard,. and - ' [ i permit ready. retrieval of quality-related documentation generated for materials and components during the design,. fabrication, modification, maintenance, and 1 operation of CNS;. J s (f) Appropriate and complete reports, records, and logs are established and maintained so as to provide.a continuing record of quality related activities the life of ~ the ascociated - with station safety and reliability throughout station; The.NPG personnel are subjected to periodic trainitig, retraining, g) requalification, and examination such as to maintain.and improve their job skills

'l which are essential to safe and reliable ~ operation of. the station; i

1 i

h)' Station security and nuclear fuel accountability and safeguards are l} maintained in accordance with approved procedures and instructions, i i Nonconformance reports are to be properly resolved and filed in the j i) quality-related record files- .l properly resolved and j) inspection reports issued by the NRC are documented; I k) Spent fuel shipment activities are to be accomplished in accordance with regulatory requirements (10CFR Part 71). 4 Revision ~6 1-6 ,.m..* W-t. . A

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wll0l $ ' x. ,, Q j : 7, ; ~ w i g g,< + n< g 4 2 41 Scope s W 8e mgg I ' ~ (The(QA;Phogram-for' Operation applies l: to;those nuclear station structures?,1 m Esystems; fand components that are' designhd to preventfor mitigate the consequences - j-Loff postul'atedf>$csidentshwhichi couldicause undue : risk ?toi the. health (and= safetyy. 4 ? y, ~ Lofi,the npublic, 1 andG to y othsr j selested 1systemsEand 4 programs / as. definedi in: u R ' / implementing QAkPlans. -yThe (requikements of this program: apply to alliactivitiesi - which Taffect' the?safetyp related functions?of" those ~ structures =,g systems,t and? -f L

components, fin'cludingidesigning,J pur$hasing,j fabricating, chandling, shipping,,

t y storing! icleaning,' : erecting, " installing, Tinspe'c' ting,1 1 testing,; operating, 1 maintaining,irepairing,l refueling, in-serviceiinspection,-and: modifying. This program specifically appliesLeo,'but isonot necessarily limited to ' the nuclear fuel,'thecreactor coolant-system'and;its auxiliaries and controls, the reactor protectien ~ and engineered safety L systems,7 the=:: reactor; containment. h a Esystem,: portions of the radioactive waste disposal system,.and ;other systems. and; components: required for, safe, efficient,.andDreliable operation;of the planti. I4 A tabulation of those structures, systems, and components which are covered by the QA Program is given in Table 1. k l _ The Quality Assurance activities governing those structures, systems, and - major components _ shall be. performed as' described in the -Quality Assurance Plans ~- (QAPs) (see-Section 4.l~.3). JThe Quality Assurance _ Criteria in '10CFR50, Appendix'B, are. oriented primarily toward engineering, - manufacturing, and -construction activities. ]} Therefore, it is_necessary to define, by specific Quality. Assurance Documents,

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[, ~ ~ ] the' manner in which the NRC Quality Assuranco Criteria are to be applied to the - station operating activities. Such Quality Assurance Documents shall be prepared 'in accordance with the requirements specified.in Sections ~2.0 and 4.0 of this policy document. The < spe'cifications,. principles, and procedures which controlled: the original procurement,. fabrication, and construction havra been carried,over into the-QA aspects of station operation to'the greatest extent practicable. 'It is. the intent of'NPPD management to maintain, as a minimum, thei quality level i achieved in the original design and construction, } ( 1.5 Definition of Terms y i Key words and phrases used to characterize this-QA Program' are defined. .i g herein to. establish a-basis for uniform and consistent interpretation of the j f - Quality Assurance requirements. Definitions of these terms are based upon i documents and standards issued by the American National Standards Institute i I (ANSI), 'NRC Safety and Ragulatory Guides, professional societies involved in standards work (ANS, ASME, IEEE, et al.), and on' the basis of contemporary usage i in the nuclear power industry; or shall be defined specifically to convey the I' intent of this particular program. Specific to the -related ANSI Standard for, -i this subject, the following commitment. applies: ) l i 1, ANSI N43.2.10-1973 " Quality Assurance Terms and Definitions," and the~ associated Regulatory Guide 1.74, are applicable to the CNS' Operational l ) QA Program, with the following clarification: 1-8 Revision 6 4

t There may be instances where existing procedures contain definitions that may not be in ' strict accordance with those provided by this standard. As l

existing procedures.are revised, however, such definitions shall be' evaluated to, assure that all' definitions meet those provided by this standard.

f 'To facilitate review and understanding of this policy document, the following basic ' terms are : defined below along with appropriate QA Program requirements. Class For piping and valves, CLASS' is determined by the applicable ASME Code. For seismic considerations, CLASS.is determined by the USAR. (See also Essential, Non Essential, and Essential Commercial-Crade.) Codes and Standards Documents issued by qualified organizations which contain standardi::ed applications. (e.g., ? ASTM Material requirements for particular equipment or l Standards, ASME Pressure Vessel Code, etc.). l l (Refer also to ANSI N45.2.10 for definition of " Standard".) 1' Contro111ne Documents All those drawings, specifications, procedures, instructions, manuals, data books, Safety Analysis Reports (SAR), Technical Specifications, and the like, 1-9 Revision 6 v.

~ i i which have been approved ~and issued by:the appropriate-authorities, and which. prescribe.the conditions and limitations lunder which^ work is to be performed. 4. I (Refer also to ANSI.N45.2.10 for definition of'" Documentation".) Desien Change A-design change is considered.to be 'any -change f to a component, equipment, or' structure-that changes the design criteria or margin' of' safety for a' system aor component which could impact nuclear safety, equipment and~ system integrity, r 1, or personnel' safety. ? v . Emercency Procedures' (Operating, Maintenance, or Repair) Those activities which must be performed without delayLin order to: 1 a) Avoid further degradation of off-normal. conditions which, in i -themselves, do not constitute an accident, but which could lead to an accident if not corrected promptly; i b) Reduce the consequences of an accident or hazardous condition which has already occurred;- s c) Implement an emergency plan; d) Prepare for an anticipated act of nature. 1-10 Revision 6-

4 Essential e t For purposes of applying and implementing this Quality Assurance Program, the term " Essential" shall apply to the following: a). All systems, ' structures, equipment', and components which are; identified in the SAR as having been designed - and built to Seismic Class I requirements; I b) All systems, structures, equipment, components, instruments, and controls which are identified in the SAR as being required to shut down the plant .l and maintain it in a safe shutdown condition;. ~ c) All other systems, structures, ' equipment, components, instruments,. -and controls which are placed in the " Essential" category by NPPD. Essential Commercial Grade Are essential items that are not subject E to design or. specification requirements which are unique to nuclear facilities or activities, are used in applications other than nuclear facilities or activities, and are to be ordered from. the manufacturer's published-product description, e.g., catalog,.as f -off-the-shelf items. Examples include, but are not limited to: a) Mechanical components, belts, screws, nuts, seals, washers, and gaskets which'have been accepted for use in essential assemblies. 1-11 Revision 6 l l is

e I 4 b). Electrical components,Lresistors,- diodes, capacitors,Jtransistore, ~ j wire,.. fuses.,. terminal blocks', aand lights which have zbeen accepted for use in-l s 'l s " essential assemblies 1 . Functional Organ.ization~ Chart s I l . A pictorial' description' of the. organization as It actually works. showing l 1

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.actualI lines of ' direction, supervision, responsibility,.' authority. and E . i. . communication. Such functional lines may or - may not coincide with regular - ) ) administrative channels, 1 1 i + i Insoection 3 } l The determination that physical characteristics meet predetermined ) requirements by visual checks'or by other techniques such'as X-ray,' ultrasonic-i or dye penetrant examination, etc..(See also. Quality Control).- l i '(Refer also to ANSI'N45,2,10 for definition of'" Inspection".)~ .i i I Licensed Station I A nuclear station which is designed and constructed so as '.to meet. requirements of applicable regulatory criteria and is thereby eligible to receive 1. a construction permit and operating license from the=U.S. Nuclear Regulacory Commission. I 1-12 Revision 6 q.m,-

JT"") .s' Maintenance Procedures Written:instruchions which define a preplanned maintenance program and d to be used to assure continuing . prescribe the methods, materials, an ~ processes ~ within required performance- . quality - and J continuing, operation ' of - equipment y characteristics. s . Maior Maintenance. Reonir. or Modifiestion Those maintenance, repair, or modification activities performed on nuclear safety-related structures, systems, or components which involve: i a) Special craft or procedure qualifications to meet Code, Standard, i or Regulatory requirements; l 1 l b) Alterations which affect overall structural integrity, essential i performance characteristics, or margins of safety in. design for nuclear safety related structures, systems, or components. 3 c) Any permanent change to the facility that requires a Technical Specification change or creation of an unreviewed safety question. i Minor Maintenance. Repair. or Modification s Those maintenance or repair activities which-are within a journeyman craftsman's capability, and which: l-13 Revision 6

r a) Are prescribed in the equipment. manufacturer's instruction books as necessary or desirable for most effective operation; i of' a preplanned 'and approved routine or b) Are prescribed.as 'part preventative maintenance program;- c) Any permanent change-to the facility judged significant enough to - warrant documentation that 'does not require a c ange-in Technical Specification h or present an unreviewed safety question. Monitor Periodically observe on a formal or informal basis whether work is being performed according to the requirements of the controlling documents (see also Surveillance). None s sentia,,1 1 Any structures, equipment, and components which may be important to reactor operation, but are not required for preventing an accident which would endanger the public health and safety, and are-not required ~ for the mitigation of the consequences of these accidents. A Nonessential - designated item shall ;not degrade the integrity of any item designated Essential. 1-14 Revision 6 I

h ' Station Permanent Record File The file which is established for'the purpose of accumulating and storing 7 ) i all documents and records pertaining to quality-related activities throughout the life of the nuclear plant. Off-Normal Condition d b i' A condition which results when an operating variable departs from its normal range. To restore normal operating conditions following ~such a perturbation, action is taken under off normal procedures so as-to correct'the condition'which. if not corrected, could degenerate into a condition requiring i action under an emergency procedure. I i Oneratine Procedures 1 Written instructions which define the normal method, means, and. limits iaf. i operation, in all modes, of a nuclear power station, a system or systems within ) the station, or station processes. Ouality Assurance i All those planned and systematic actions performed for the purpose of establishing a high level of confidence that: 1-15 Revision 6 l

j; c) ~ Work performed on* the project conforms with the requirements of the l- - applicablei codesi standards, license-stipulations, safety analyses, design ^ drawings,' specifications, procedures, and instructions; and- - b). A structure, system, f or component will perform satisfactorily in ~

service,

's c) Appropriate records, - documentatiion and/or drawings are : maintained. to show compliance with a) and b) above. Ouality Assurance Documents Those documents inclusive of the QA Policy' ' Document, 'QA Plans, -QA Instructions, Procedures ' (and associated data sheets), ' logs,.etc., which have been approved for,use, and whose intended function is, to provide ' direction, verification, or documentation for activities affecting quality. Ouality Assurance Instructions Quality Assurance Instructions define the responsibilities 'for ' implementation of the QA Program in accordance with policies and practices' hereiri defined. In addition, they provide guidance for surveillance, and _ audit activities to be performed by the QA Staff. 1-16 -Revision 6

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i Ouality' Assurance Plans Quality 1. Assurance Plans are those documents specifically _ designed to provide detailed quality requirements for-a given functional' area. - The plans. r - are - generated by applying the l'8 criteria of.10CFR50, - Appendix' B, to each . functional area and' then deriving the specific quality requirements for-that' area. 7 Quality Assurance RecpyJ;1g Those quality-related records (see Reference 7.~10) wh'ich. have been ? completed and furnish documentary evidence' of the quality of items and/or activities'affecting quality. A document becomes a Quality Assurance Record-when the activity related to the ' document becomes part of the operating condition of the plant. c; Ouality Control 4 Those activities which deal directly with the measurement, observation, or verification of physical characteristics of materials, components, or systems which provide a basis for controlling quality to within predetermined limits, or requirements, including adequate quantitative and/or qualitative acceptance . criteria by which an activity can be measured. 1-17 Revision 6

.g 3 Ouality Reauirements e Those factors which define limits which must be met so that the product s wili perform its intended function reliably throughout its design life..They include, but are ' not limited-to, conditions important to proper material selection, manufacture, construction, and inspection; substantiation that: material' or parts conform to all specification requirements,.testin'g to i demonstrate adequacy of performance; -protection of finished parts to. prevent ; deterioration; and conditions for operation, maintenance, and repair which enable. continuing operation within prescribed margins of safety and within prescribed performance limits. 4 Reculatory Criteria That body of NRC publications which define the conditions which must be met to obtain and hold an NRC Construction Permit, Operating License, and Licenses for individual operators. Review A deliberately critical examination. The term includes the routine monitoring of station -operation performed by the Division Manager of Nuclear Operations and his staff as a normal management function, and the formal independent evaluations of certain contemplated actions and after-the-fact I investigation of anomalies conducted by a duly constituted review and audit i group. 3 i 1-18 Revision 6 1

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~ .e -i? -;g;. ~ ej I!! ! j j t safeguard ~(of Nuclear Material)' 0 y ' Measure taken.to prevent diversion of nuclear materials <isto unauthorized': i or' illegal 2uses (see-also Accountability). ,p v a, Safetv-Related' y i' i -(Seej" Essential"). f Sienificant' Conditions' Adverse To Ouality' a' ? ,? .? or: Any conditions that could affect safety-related structures,' : systems, components ability to function within design requirements-or adversely alter. l -': performance characteristics, 3 r l 1 Suco11er Evaluation j i' i- .'Those activities which determine the effectiveness-of-implementation of; .i the supplier's Quality Assuranc'e Program. Avarietyofmetho'dsmay[beused:co-I perform a supplier evaluation and are described-in QA Instructions. Surveillance i 4 Surveillance.is the QA Audit function consisting of formal and-informal observations to determine that work is being performed in accordance with the requirements ' of-the controlling documents ' and. drawings - (see also Audit and ,] l 1-19 Revision 6 4 .,mq w - i

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~ Surveillance _ - activities. ; shalli be7 performed in:. accordance with - irequirements specified in QAPs=and QAIs. Surveillance:Testine-Periodic-testing of structures, components, and systems related to nuclear i safety,. for :the purpose _of" verifying that : such safety-related ' structures,_ + . components, and systems: continue-to function or are in a' state of readiness to. perform their. safety functions. Testine i The determination or verification of the capability of an item to meet specified requirements by subjecting the item.co a set of physical,' chemical, environmental, or operating conditions. (Refer also to ANSI N45.2.10 for definition of " Testing".)- haceability The capability to identify a particular component or material and to discover its entire history, back through the written records of its material formulation (heat number), manufacture, inspection, ins tallation,

test, operation, maintenance, repair, and replacement.

t 1-20 Revision 6 0 ~..... .. ~

5 =.I. Witness .i Formal observation by a knowledgeable person of a particular, prescheduled event-during ' manufacturing, inspection, installation, testing, operation,z ~ J .\\ maintenance, or repair, The purpose' of - witnessing is ' to provide.. direct. observation and evaluation of an event, independent of the group performing:the' ~ particular-operation. Desienated Reoresentatives

1 An individual or organization autherized by the purchaser' to perform j

I function in procurement process, !l 3 Lower Tier Procurement Procurement by a supplier from a subsupplier of items. or services. - t Purchaser i A The organization responsible for issuance or administration. or both of-' . procurement documents, ' h (Refer also to ANSI N45.2.10 for definition of " Purchaser".) -1 l t 1-21 Revision 6

-p q l!.! Rieht of Access i - i - i ' The ' right fof the purchaser 1 or designated representative to - enter; the-- - premises'of a supplier for the purpose'of inspection, surveillance, or. quality t . as surance au'dits. ,d '1 sj - Services i - The ' performance by ' a supplier-of. activities such.as design, fabrication, t . inspection," nondestructive examination, repairs, installation, or training. .j 0 ':t 3 ll r lf t! l i 4 ,,;a 4 i

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SUMMARY

DESCRIPTION This section defines the NPPD commitment for compliance. to 10CFR50, .' Appendix B, as applied to. safety-related structures, systems,'and components. - j 4 associated with Cooper Nuclear Station. i; In addition to describing' commitments to 10CFR50, Appendix B, this Section- '} also identifies NPPD's commitment to selected ANSI Standards and their associated ~ Regulatory Guides, y Li 1 1 2.1 Oreanization .j .i The President and Chief Executive 0fficer (C.E.O.) (Figure 1) represents. the highest level of management ' responsible for establishment of Quality f i Assurance policies, goals, and objectives. The responsibility and authority for j nuclear facility and General Office support activities (including QA)'has been ) h delegated to the Nuclear Power Group Manager through the Vice-President - Power Production. This authority includes the right to direct, enforce, and perform f any action required to ensure all activities conducted'at Cooper Nuclear Station are in compliance with 10CFR50, Appendix B. In addition, the personnel assigned to the Quality Assurance Division shall have complete independence to perform audits, surveillances, inspections, verifications and shall.be independent of those groups performing, designing, purchasing, fabricating, shipping, storing, cleaning, erecting, installing, inspecting, testing, oparating, maintaining, y repairing, refueling, in-service inspecting, and modifying. Figure 1 of this q d document outlines the QA Division functional organization. Quality Assurance Personnel shall have sufficient authority and organizational freedom to: ) J 2-1 Revision 6 T

,g (1) . Identify quality problems;

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i '(2) - Initiate, recommend, or provide solutions: for conditions adverse to quality; and, ) (3) Verify implementation of solutions, y 4 12.2 Ouality Assurance Procram ] The program shall be implemented in accordance with written, approved-Quality Assurance ' Plans and - Instructions developed. by : the Quality Assurance h! ~ Division. The District's QA Program will comply with the ' Quality ' Assurance j Guidelines contained in the Orange Book - WASH, 1284-10-26-73. Design Control,- l Procurement Control, Quality Control,' and Quality Assurance activities associated with plant modifications will similarly conform to the guidances provided within' j 1309 10-74. l the Gray-Book - WASH, 1283-Rev. and the Green. Book ' WASH, Procedures will be prepared for each important activity of: station operation-which will clearly define the work to be performed on a step-by-step. basis'and will identify, where appropriate,. the results to be achieved. Mandatory QC Inspections or Tests will be performeci on -an independent basis to verify that procedures are being followed (correct results obtained) and will be incorporated ' . l into the_ work procedures directly or by attachment. QA Audit activities will-j t verify that the Quality Control Program is implemented. 5 Specific to the related ANSI Standards for this criterion, the following lj commitments apply: 2-2 Revision 6 1 l

1 1. ANSI N18.1-1971 Selection and Training of Nuclear ' Power Plant- 'l Personnel." shall provide direction for selecting and trainin'g of personnel for - 1 i the' Nuclear Power Group. '2. ANSI N18.17-1972 "American National. Standard for Administrative' Controls for: Nuclear Power Plants," and the' associated Regulatory Guide 1.'33, apply to the CNS-Operational'QA Program with the same exceptions -as.those taken -in other sections of~this Policy Document.to' ANSI N45.2-13. ~ 'l 3. ANSI N45.2-1977 " Quality Assurance Program Requirements for Nuclear y 1 Facilities," and associated Regulatory Guides 1.28 and 1,33, shall apply to the - "h] ~ J CNS Operational QA. Program, with the following exceptions: J q (a) Where Section 11 " Inspection" identifies the reporting relationship between the inspector and the "immediate supervisors who are responsible for the j d work being inspected," the CNS QC Program -only requires-that the individual. \\j f t performing the verification function shall not perform or directly supervise the 1 q work being inspected, q ] Table 1 identifies the structures, systems, and major components associated f 1 with Cooper Nuclear Station covered by this program - *The Nuclear. Operations j n and Nuclear Engineering and Construction Divisions, with the assistance of the j QA Division, will identify essential structures, systems, and components to be included within the scope of the QA Program. The Quality Assurance Program is' lj -)I designed to provide control over all activities affecting quality of essential i items to a degree consistent with their safety-related importance. These 1 2-3 Revision 6 I j -l

=~ activities will be governed by approved plans and instructions and these documents shall be followed under controlled conditions. The Quality Assurance Plans end Instructions will be reviewed periodically to assure that the requirements of the program are being met and new requirements are being incorporated. In addition to essential structures, systems, and components, applicable portions of this program shall be applied to selected nonessential structures, systems, and components important to station reliability and performance. Specific application will be identified in dedicated Quality Assurance Plans. s Special process controls, test equipment, tools, skills (training, if required) shall be used during the conduct of inspection, verification and checking activities to assure a high standard of quality and reliability has been obtained on safety related items covered by the Quality Assurance Program. Test equipment and special tools will be calibrated against a specified secondary standard. Experienced individuals (which may include personnel from other divisions of the Nuclear Power Group (NPG), and/or outside qualified individuals) msy be requested to assist in performing audits and inspections of certain CNS quality-related activities at the direction of the Division Manager of Quality Assurance. During these assignments, these individuals will have sufficient organizational freedom to identify and recommend corrections for quality deficiencies noted. 2-4 Revision 6 7 F'

e n. f .l i i 1 The Nuclear Training Department, in addition to QA Staff personnel, provides QA indoctrination for NPG employees as described in nuclear trsining program descriptions. In addition, QA Staff members will attend a minimum of-one training seminar per year sponsored by a qualified' agency and/or school. For the purposes of meeting this requirement, activities such as attendance at. l national' conventions, participation in owners group committee's activities, and other such related items may be considered equivalent to seminar. Such instances shall be specifically approved by the Division Manager of Quality Assurance.- Ongoin5 QA-training for personnel with nuclear. plant responsibilities will be provided. Training activities will be audited periodically by the QA Staff to -) verify its scope and effectiveness. I 2.3 Desien Control Implementing procedures outline the method for identifying, controlling, and implementin6 design changes within the Cooper Nuclear. Station. The procedures provide the mechanism for correctly translating' the design changes i P and regulatory requirements into specifications, drawings, procedures, and 1 instructions. They also establish the method of reviews, interface requirements t (with original design organization, if required), approvals, and the o organizations delegated the authority to implement the design change. Design control measures shall include the review for suitability of application of items that are essential.to the safety-related function of the 3 system involved. 'A necessary part of this review concerns the safety classification of items to be procured. In those instances where-the normal l 'l methods of Section 2.7 cannot be applied and it is necessary to purchase 2-5 Revision 6 l J.. ,, _i.. I

i " commercial-grade" ' off-the shelf items. for use in essential applications, verification will be performed to ensure that the part utilized is functionally acceptable for the' essential application. This verification may. include l. dedication upon receipt, analysis, or other definitive method. All design changes initiated for Cooper Nuclear Station will be forwarded - These reviews-shall to the QA Division for review and independent evaluation. verify that design engineer has considered the compatibility of the design change Additional items - with applicable codes, standards, and regulatory requirements. considered by the design engineer include reactor physics, stress, thermal hydraulic and accident analyses, compatibility of materials, accessibility for in service inspection, maintenance, repairs, and delineation of acceptance criteria for inspection and tests. Final acceptance of the design change will require an independent verii'ication or check of the design adequacy such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the 7 performance of a suitable testing program, Specific to the related ANSI Standards for this criterion, the following commitments apply: 1. ANSI N45,2.11-1974 " Quality Assurance Requirements for the Design i of Nuclear Power Plants," and the associated Regulatory Guide 1. 64, shall be applied to design activities involving safety related modification work and the revision or development of plant design documents occurring during the operational phase of CNS. However, where codes, standards, or design 2-6 Revision 6 i h P4 W M 4 MSW

IF 'O L t requirements are referenced, or are incorporated into the ' standard by reference, forth in the which are in conflict.with original desi n commitments as set 5 Later' Updated Safety Analysis Report (USAR), the USAR commitments shall govern. revisions of applicable codes and standards may be specifically invoked by' the design requirements where deemed appropriate, - consistent with the overall commitment to maintain the plant in an " equal to or better than" original'

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ANSI N45.2.4 1972 " Installation, Inspection, and Testing Requirements 2. for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations," and its associated Re5ulatory Guide 1.30, shall be applicable to the CNS Operational QA Program for safety related modification work, with the following exceptions / clarifications: The definition of Class I and Class IE electrical equipment set forth (a) Electrical by this standard does not conform to the equipment categories of CNS. items upon which the Operational QA Program is based-are included in Table 1 of this policy document and the CNS "Q" List. The scope and applicability of this standard shall necessarily be limited to these defined areas. (b) Appropriate requirements for installation, inspection, and tests are defined in job specifications and work instructions developed as a part of the modification work package. It'is not intended that separate procedures be-established which specifically address the various areas of this ' standard. During the development of work packages, consideration will be given to the areas -l outlined in Section 2.3, as appropriate. 2-7. Revision 6

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'(c) The requirements - for insta13ation; inspections, verifications, and 3i ; ' tests shall be. included in the work instructions. :In the development of,these-i instructions; consideration. will; be'-given to. the _ = guidance : provided by ) Sections 4.0, 5.0, and 6.0 of this standard, and appropriate-requirements.will. L be incorporated 71nto the instructions. It. is. not intended that - separate procedures be established to specifically. address,all of the' areas referenced. (d) ~ 5pplication_ of the: guidance ' provided by the additional'. codes add standaYds listAd-in Appendix B will be considered to the extent-that such codes and standards provide'useful and practica1' guidance for_ the work being performedi. Commitments. to the ' guidance of N45.2.4 shall not include. commitments 1 to the guidance.of referenced standards. ANSI N45.2.5-1974 " Supplementary Quality Assurance itequirements-for. 3. Installation, Inspection, and Testing of Structural-Concrete and Structural' Steel. . During the Construction Phase of Nuclear Power Plants,". and. its associated Regulatory Guide 1.94, r. hall be applicable to the-CNS Operational QA Program; for= safety related. modification work, ' with'. the. following ; exceptions /; 1 clarifications: ILQ.T3 y With respect tof structural concrete, acceptability shall be documented " in accordance with the District's' Dedication Proced'ures. (a) Appropriate requirements for installation, inspection, and tests will' be set' forth by job specifications and work instructions-developed as a part of 2-8 ~Rev'ision-6 .m.x

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the modification work package. It is not intended that separate procedures be established which specifically address the various areas of this standard. However, in the development of the work package, consideration will be given to the areas outlined in Section 2.2, as appropriate. (b) The requirements of control and calibration of measuring and test equipment set forth by this standard shall be applied to all measuring and test ~ Such equipment used by NPPD or their agents, test laboratories, and contractors. requirements, however, will not be imposed on commercial batch plant facilities. Instrumentation at commercial batch plant facilities will be evaluated by NPG construction management personnel, or their designated representative, to determine that sufficient accuracy can be obtained. d (c) For small quantities of concrete involved in modification work, all concrete must be purchased from commercial concrete batch plants. For these ] small quantities of concrete, it is unreasonable to expect commercial facilities to shut down normal. operations to -provide certified aggregate, cement, - l admixtures, fly ash, water, etc. In this respect the qualification tests required by Table'A for aggregate; cement, admixtures, fly ash, and pozzolans; water and ice will not be required. Appropriate evaluations will be made to determine that good quality and generally acceptable materials are used. NPG construction management evaluation, coupled with slump. tests, air entrainment tests, and concrete cylinder strengths, will provide adequate control' and j qualification of the concrete. (d) Design mixes consistent with, or equivalent to, original requirements will be specified and the results of the cylinder tests will be evaluated by NPG 2-9 Revision 6

construction management based on tho' acceptance criteria associated with the-original design mix requirements. t (e) The inspection requirements of-Section 4.2 will not generally be' l performed as the small quantities of concrete involved in modification work wil1 ~ a no doubt be mixed using materials already in the batch plant bins. Control of I storage of materials would not be practicable. (f) If'available, appropriate certifications shall be obtained from the concrete supplier which verify the adequacy of truck mixers per the requirements of ACI-304, ASTM C-94 Where certifications are not available, two concrete test cylinders representing the first and last one third of truck mixer contents shall-be taken for evaluation of the mixer truck, over and above the normal concrete-cylinders taken to evaluate the in place concrete. -.The concrete batch plant facility shall be inspected by NPG construction management and the CNS. QA Staff. to assure that reasonable controls are being exercised with reference toLthe inspection guidelines set forth by Section 4.3(1)'and (2).- (g) Inspaction of fills and earthwork will meet the general requirements set forth. The extent to which individual inspection requirements 1are met will. depend upon the nature and scope of the work to be performed'. i (h) Except for normal batch qualification tests (slump, air content, temperature, and compressive strength) and initial reinforcing steel certifications, the in-process tests required by Table' B are generally applicable to ' the periodic control which must be exercised with ~ reference ~ to ' long-term construction type programs. The in-process test requirement of Table B are not ' 2-10 Revision 6' ... 1 -

= v y 4_ t r l =I considered' applicable 4 to short-term: modification-work as-would be required'by a 'I -.QA at CNS. J i I 4 ANSI N45.2.81975 " Supplementary Quality Assurance Requirements for l Installation,' Inspection, and Testing of Mechanical Equipment and Systems for; i the Construction Phase of Nuclear Power Plants," shall be applicable to the CNS operational.QA Program for safety related modification work, with the following ' clarification: (a) Where - specific design ' requirements included in this standard 'or referenced codes and standards are in conflict with original design requirements set forth in the USAR and other appropriate design documents, the original design - requirements shall govern. I 2.4 Procurement Document Control i Cooper Nuclear Station Procedures, Nuclear Engineering.and-CSnstruction. Department Procedures, and Quality Assurance Plans and Instructions are required to define the applicable requirements, design basis methods, and procedures for procurement of spare parts,. materials, equipment,: and services for essential t nuclear systems. These instructions and procedures shall also include provisions .j for assuring that the necessary quality requirements are incorporated directly into the procurement documents for essential spare parts, material, equipment, and services. 'These instructions and procedures shall also include provision l L ' for assuring that the necessary records are specified and provided to the lI District by the supplier, i != 2-11 Revision 6 i l -- - (- c i, _, ' .~ I- ~ C.

ckl { . The. basic principles and practices ; included 'in these procedures are l expected to be applicable to any purchasing activity necessary for operation of i' the station; however, additional special controls may be necessary for major modification or repair activities. 'I Procedures covering procurement provide for independent Quality Assurance I review of the essential and essential commercial' grade, purchasing ' documents; review and approval of suppliers; and QA Audit of contractor and, supplier i activities. Change Orders issued on any procurement document will be subjected to the - same review and approval as the original order, t .I \\ All procurement documents issued to suppliers >of safety-related items or i services require that the supplier implement a Quality Assurance Program that meets the intent of 10CFR50 Appendix B (with the exception of those suppliers q performing all' work at Cooper Nuclear Station or in the Columbus General Offices i under the District's QA Program). The Quality Assurance Program submitted by the supplier will be evaluated by NPPD ' QA to ascertain that they. meet. the criteria established in 10CFR50, Appendix B. All safety related suppliers'shall appear on the applicable section of the NPPD Approved Suppliers List,- a To the maximum extent practicable, the as-built drawings and specifications. for Cooper Nuclear Station will be used in procurement of spare parts, material, and replacement parts. t 'i 2-12 Revision 6 ,..._.-x .~,

i Where necessary, because of design modifications, or where it is necessary or desirable to upgrade quality in replacement parts or mate.tial, necessary modifications will be made to drawings and specifications to incorporate These modifications or requirements for currently appropriate quality level. upgrading of replacement parts will be accomplished in accordance with approved instructions, procedures, and drawings. These documents will be subject to required reviews before being implemented. the following Specific to the ANSI Standard related to this criterion, commitment applies: ANSI N45.2.13-1976 " Quality Assurance Requirements for Control of 1. Procurement of Items and Services for Nuclear Power Plants," is applicable to the CNS Operational QA Program, with the following clarification: f (a) It must be acknowledged that equipment and components purchased [ during the design and construction phase were not purchased on the basis of present-day standards, especially with reference to supplier approval aad i supplier Quality Assurance Programs. In this respect, replacement parts and { j i spare parts for existing equipment are often limited to sole source suppliers, Such replacement parts or spare parts are purchased to appropriate quality f standards, verified by NPPD QA, to maintain an " equal to or better than" condition but it is not considered practicable to backfit the requirements of i this standard to all such suppliers. i i i. l i 2-13 Revision 6 l l

1 p, L 2.5l Instructions: Proceduras. and Drawinen j i i Quality Assurance activities and other activities which have nuclear' safety significance will be prescribed by documented instructions, drawings, and procedures' as appropriate and shall be accomplished in -accordance with these instructions, procedures and drawings.. These instructions will be sufficiently i [ detailed.and explicit so that any supervisor, inspector, or auditor can, by. s ? h being' satis' factorily

j observation,. determine -' whether or not activities are accomplished.and' documented. These documents shall include the qualitative and

'l quantitative acceptance criteria necessary to assure satisfactory completion of . ;1 the test procedure.- Those acceptance criteria shall, where appropriate, require

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post installation testing prior to returning the component or system to service. i Repair maintenance activities on essential. systems are performed in accordance 1 [ with the Maintenance Work Request process. The required documentation for - 4 special processes are forwarded to the CNS QA Staff for review along with special test procedures and special maintenance procedures.. 4': i 2.6 Document control ? 1 Administrative control procedures shall be established"by the Columbus i- General Office (CGO) and Cooper Nuclear Station (CNS) to control-the 4 identification, indexing, filing, retention, retrieval, and distribution ^ of [ quality related records and documents. Control procedures shall be reviewed and F approved by authorized personnel and are distributed to and used at the site of f the activity. These procedures shall piso ensure that changes to quality-related records and documents receive the same level of review and approval as the-1

original document.

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.q v l A 'I d' s The overall objectives of NPPD document control are to: p p: 'a). Identify those > records and ' documents which. are used to control.. maintain,~ modify, or docrament quality related activities both at the CGO and at - CNS ~. b). Establish an index of quality-related records located atihe CGO'and at CNS to enable personnel involvedlin safety related activities to determine the proper documents to be used in the activity.- c) -Establish a filing system. .d) Establish periods'of retention. e) Establish measures to control distribution and revisions. The CGO Manager of Office Systems Services, CNS, station management,?and-L. the Quality Assurance Division will jointly establish. lines : of specific 1' 1 I responsibility, interfaces, and document control procedures. l. l-l :. Specific to the ANSI Standard related to this criterion, the'following commitment applies: 1. ANSI N45.2. 974 " Requirements for Collection, Storage,- and-Maintenance of Quality Assurance Records for Nuclear Power Plants," and - its 2 15 Revision 6 r.. ., g... c.. sy_.

' associated-Regulatory Guide 1.88 shall be applicable. to the ' CNS. Operational QA Program, with the following exception / clarification: For those design, manufacturing, construction, and operating records (a) t generated prior ' to implementation of this standard, it is not our intent to backfit the detailed requirements of this standard to those records. All such. records, however, have been initia11y' designated for lifetime storage, until specific review dictates otherwise,- and will be stored in the record storage facility. Record -indexes and filing systems shall be established to permit b reasonable identification and retrieval. .The records will - be stored and preserved par the requirements of Section 6.0 of:this standard. I 2.7 Control of Purchased Material. Eauiement. and Services E NPPD receiving inspection instructions provide' for determining that all. purchased materials, equipment, and services purchased directly or through a contractor, supplier, or subcontractor meet the requirements specified on the original procurement specifications, such as code, standards.. specifications, -dedication, material identification, etc. The completed receipt inspection report will become part of the purchase order package. Procurement documents shall be available at the receiving area to identify the receiving-inspections-required. Quality Assurance Instructions provide for evaluation of supplier's quality program to determine effectiveness and compliance to the applicable 10CFR50 criteria as part of the supplier selection process. These' instructions shall 2-16 Revision 6 i J-n n '. iO ,.y

describe the methods and techniques used to evaluate the supplier's Quality Assurance Program. The QA Division shall re evaluate the supplier's quality program at intervals consistent with the importance, complexity, and quantity of the item or services to effectively maintain control of quality. Procurement-documentation will specify mandatory hold points for witnessing or inspection of purchased materials, equipment, or services, if required by NPPD. Upon receipt at the station, material, parts, and equipment purchased and identified as " Essential" or " Essential-Commercial Grade" will be placed in a e segregated storage area until all inspections are complete and all required certifications and documentation is received. Items in segregated areas will not be issued, by the Warehouse, without che written permission of the Division Manager of Nuclear Operations or desi n*6 6 and only then after proper arrangements have been made to assure that r.ocessary steps will be taken to bring all aspects of the particular item into conformance with normal requirements prior to the system containing components in " Hold" status being returned to service. Suppliers of essential equipment shall be required to provide certified documentary evidence' that the material supplied conforms to the purchase document requirements such as material test report, code required test'and inspection, f I documentation, etc. A complete set of documentation required by the procurement { document for all essential materials, equipment, and services will be filed at I Cooper Nuclear Station. 2-17 Revision 6 l l

g (" .I 2.8 Identification and Control of Parts. Materials. and Components To the maximum extent practicable, activities carried out during operation .of the Cooper Nuclear. Station will comply with the requirements for identification and control of materials, parts, and components as set forth in the as built drawings and specifications for the station. Where special measures are required to assure proper identification of materials, parts, and compor.ents, such requirements will be incorporated directly into the procurement documents for such parts and assemblies. Such identifications which may include heat numbers, serial numbers, or other means of identification of the item will be incorporated into the procurement documents to provide means of traceability. Material received at the station (which has not been properly identified) will 2 be segregated and tagged to indicate a " Hold" status. Except as indicated in Section 2.7 above, such parts will not. be issued or used prior to final acceptance. CNS procedures will incorporate requirements necessary to assure that the identification measures are properly carried out at the station, that -t unacceptable items will not be used in essential. systems, and that the components to be used in essential systems receive independent verification of component identity prior to installation. 2 2.9 Control of Special Processes I General maintenance procedures provide for performance of special processes by qualified personnel using qualified and approved procedures. Control procedures provide for QA review, inspection, documentation of activities, and l for proper integration of QA/QC Inspection. In most cases, the procedures will j I i 2 18 Revision 6 1 l . ~. +,

t j be prepared only when a specific process is required in the maintenance, repair, . or modification.'of essential equipment at.CNS. These procedures shall also require:special processes, such as welding, heat treating, and NDE, to be are controlled and performed by qualified personnel in accordance with qualified procedures. ~ Maintenance modification control methods and Station Operating procedures reviewed by CNS.QA personnel. .This review includes - verification that. are -necessary codes,-standards, quality requirements, and acceptance criteria are incorporated to contro1'special processes within established limits. 2.10 Insoection Quality Control inspections have been assigned in this policy document to the organization basically responsible for the performance of the activity; A Peer QC Program will be utilized in which QC inspections are normally performed by QC Inspectors who have been selected from within the Nuclear Power Group, and. -who are many-times just as qualified to perform the work as they are to inspect i the work. QC personnel will be qualified / certified, and will conduct the QC Program, in accordance with NPPD's commitment to' ANSI N45.2.6. This conduct of the QC ' Program will be within the detail established in the CNS Operations -Manual, Volume 12. Quality Assurance Audits and ' Surveillance of activities such as r maintenance, repair and modifications will include direct observation; whereas operating functions will be monitored indirectly by observation and examination of individual operating personnel and documentation at intervals consistent with 2-19. Revision 6 -r s.....,4.-

7 Hi-l' l the importance of the activity. Direct QA or' QC -inspection will also be - conducted for activities such as refueling, radiochemistry, and environmental monitoring. Special inspections, such as those requiring qualification to - ASNT TC-1A, will be contracted to approved suppliers.- If direct inspection is-impossible, indirect control methods will be specified in the instructions to - provide'a method of monitoring process methods and equipment. The results of. all inspections will be placed in permanent record storage. Controlling documents pertaining to quality related activities receive QA ' ~ . review to ensure incorporation of appropriate quality requirements. Specific to the ANSI Standard related to this criterion, the following commitment applies: 1. ANSI N45.2.6-1978 " Qualifications of ' Inspection, Examination, and. Testing Personnel for Nuclear Power Plants," and ' its - associated Regulatory l Cuide 1.58 is applicable to the CNS-Operational QA Program, with the following exceptions / clarifications: (a) It has always been the belief of NPPD that,. in order to be effective,. Quality Control must be built into the operation of the plant. With this in-mind, Quality Control and test functions performed at CNS are incorporated directly into the station procedures. Inspection points are then performed andi signed off by qualified personnel not directly performing or supervising.the step (s) being inspected. Selection' of QC candidates"for certification is :a.- function.of Station Management. Actual certification of QC inspectors.is the responsibility of the QA Division. 2-20 Revision 6- =

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l (b) CNS does not have the in house capability to perform nondestructive - j . examinations in accordance with SNT-TC-1A. These. services are currently contracted to an approved supplier. Any required' nondestructive examinations -

will' be performed by personnel who are qualified and certified per SNT-TC 1A.

4 2.11 Test control Each type of test program performed by the station operating group' will ] ' be defined by written procedures-and instructions. These test programs < include the preoperational tests, start up test instructions, operational testing and surveillance testing of structures, systems, and components to demonstrate their capability to perform satisfactorily as a _ part of an. integrated system. Acceptance tests.will be developed for structures, systems,.and components-to demonstrate their capability to perform satisfactorily following repairs or I modification prior to returning to service. Test procedures.will identify.the: . inspector, test performer, date, and data recorder. Each type of -acceptance test has -individual test procedures which -include Quality Control. provisions, ~ acceptance criteria, and check points for observation or checking of important aspects. These test procedure prerequisites will include-- the test instrumentation requirements and environmental conditions. All:Special Test c Procedures, Special Maintenance Procedures, and Station Operating Procedures are i routinely reviewed by SORC, of which QA is a member, q ~ Quality Assurance Audit and Surveillance activities will be ' performed by the Quality Assurance Staff members to assure that tests are being performed in. !accordance with the requirements of the procedures, that results are evaluated 2-21 Revision'6; l _y1 i .A

r p l h and compared to ' the specified acceptance criteria, and that. tests are being performed by appropriately trained personnel. In addition, test procedures shall j specify-test requirements and quantitative and qualitative acceptance criteria where appropriate. 2.12 Control of Measurina'and Test Eouinment i Procedures shall define the requirements of inspection, maintenance, repair and calibration of all' tools, gauges, instruments, and other measuring and testing devices which are used in activities which : affect quality of safety-related equipment. Each permanent or temporary installed plant instrument performing an essential function has been identified and placed on a ' regularly scheduled : program of inspection, test, and recalibration. All test and' measuring equipment required for calibration of the above equipment will also be placed on a regular program of inspection, test, and recalibration and will be appropriately tagged. Documented calibration records are reviewed, as required,_ to evaluate calibration performance and frequency, and chan5es are made as may be necessary. A Quality Assurance' Plan will prescribe the QA functions to be performed relative to the calibration program. Quality Control and Quality Assurance practices require independent checks of calibration activities. . Quality Assurance Surveillance performed by the QA Staff members will verify that~ procedures are being properly followed; that adequate t records of ' calibration and testing of measuring and test equipment are being generated,. maintained, and: l -. that regularly scheduled adjustments are made to maintain necessary accuracy. l 2-22 Revision 6-t- +

i { For equipment used to calibrate process equipment, procedures will define action j -to be taken should regularly scheduled calibration checks reveal an out of specification condition exists. LTnen inspection, measuring, and. test equipment are found to be out of calibration, an evaluation shall be made, and. documented, t 1 of the validity of previous inspection or test results and of the acceptability [ I of' items previously inspected or tested. Should the evaluation determine that previous inspection or test results obtained with the affected instrument are unacceptable, a Nonconformance Report (NCR) will be issued. Reference and transfer standards, traceable to. the National Institute of Standards and t Technology (formerly NBS) will be maintained at CNS. j Scheduled and/or unannounced audits or surveillances by the Quality Assurance Staff, the Safety Review and Audit Board, or NPPD management will l include review of the calibration program. .I 2.13 Handline. Storare. and Shinoinc as i The procedures for procurement and control of essential spare parts, materials, replacement parts, and equipment include the. requirements for the ~ control, handling, cleaning, shipping, receiving, and storage of essential parts . and material. Quality Assurance Plans and Instructions provide for surveillance t and audit to assure-that procedures are followed'and that essential parts and materials are received, inspected, stored, and controlled in such a manner so as to prevent degradation. L Specific to the ANSI Standard relating to this criterion, the following i commitment applies: 2-23 Revision 6 t ~-

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p .n i 1 1 1. ANSI N45.2.2-1972 " Packaging, Shiphing, Receiving, Storage, and- ..,4 Handling of Items for Nuclear Power Plants," ar 1 its associated ~ Regulatory - s ' Guide 1,38 is applicable to the CNS Operational QA Program, with the following i exceptions / clarifications: 3 7 ur program.is structured to identify safety-related 'equipmentiand '(a) 0 1

l provide for designation of packaging, shipping, receiving, storage, and handling-requirements for purchased parts and materials.

The classifications of this - ) '? standard cannot be applied directly to individual spare parts or subassemblies, j of the parent equipment. Due to difference in volume ~, complexihy, ' l 3 inspectability, etc., the packaging, shipping, handling, and storage requirements of spare parts and subassemblies will. necessarily be different - from the r requirements which may be imposed on the entire component or piece of parent equipment. (b) The majority of items purchased for an operating plant consist -of components, subassemblies, and individual spare parts which could be used in'a multitude of different applications. Such items. are purchased to the most ' stringent requirement for their intended use. The volume and characteristics 5 of. procurement during the operational. phase differ, significantly. from those-purchases made during the design and construction phase. ~ Items requiring special - storage protection will be identified on the purchasing documents. Items that' must be stored outdoors (equivalent of Level D) and items that must be stored in covered but unheated conditions' (equivalent of Level C) will be evaluated on an individual case basis.

However, it' is not considered practicable to 5

preclassify individual parts by levels as required by Section 2.7 of..this 2-24 Revision.6~- 4 w.

top +* 7 m u o g .p a T .f l '\\ 4 i . standard.- Shipping and packaging requirements for'such items' will likewise be . handled in the procurement documents,.as appropriate. -} performedito verify that the l -(c); QA Audits 'and Surveillance are requirements of N45.'2.2 are met-except as noted in (a). and'(b)' above. t . 2.14.-Insnectioni Test. and Ooeratine Status The NPPD status tagging' procedure,ialready:in use throughout the system,, has been adapted for ' use in the Cooper Nuclear ' Station. Where' practical',' particular emphasis shall be placed on tagging to prevent unauthorized ' operation-or adjustment which could endanger' the safety l of personnel, L damage -equipment, or invalidate the results of tests already performed. These tags shall-indicate-abnormal equipment test and inspection status and reference special instructions - for equipment located throughout the Cooper Nuclear Station. Tagging procedures, where necessary, will require that equipment be ' tagged : and that the associated power supplies, starters, switches and centrols'on the main control panel are tagged as well, to warn against operation. In some cases, power supplies will be disconnected and tagged to prevent inadvertent operation. 'I Tagging will be controlled by the Shift Supervisor by requiring that.L serially-numbered tags, obtained from the Control Room,' be used for all tagging. purposes. Records will be maintained in the. Control Room to enable' operators and Shif t Supervisors to determine the status of the equipment tagged. A Temporary Modifications Control Program-will be maintained. to provide a method for recording the installation and removal of jumpers, fuses, or wire I 2-25 Revision 6 a 2. a u.. ,-U 1. 1

pg .y 4 ,.r; E terminal; disconnections. This record will include the location, reason, name ~ of person' authorizing, action,'.and name of person performing.the installation.. Requirements for tagging are included in the applicable procedures. Status tagging will be verified by audit.and surveillance. 2.15. Nonconformine Materials. Parts: or Comoonents Warehouse -and maintenance procedures include : requirements for' the { ,t identification and tagging of nonconforming materials, parts, or components, (See r Sectio'n 2.8). e The Nonconformance Reporting. Program shall be used by all persons' 4 performing operation, maintenance, modification, and quality related functions; t-to record and report: j [i a) Deviations from approved-procedures;- a i. b) Nonconforming materials, parts, orl components received' from outside' ? suppliers on essential purchase orders; t i i L f c) Nonconforming materials,' parts,-or' components within the plant;. j

(

d) Nonconforming materials brought on site'without following established receiving and inspection procedures; i e)' orders or recommendations to stop work; lf 2-26 Revision 6 r i -l =.. i I ../._.- m.. ~ -. s- ,.g

l s

f) -

, Reportable occurrences;. j i . g)l Any other deficiency which violates the intent of the Quality l c Assurance Program and which could have a'significant adverse effect e on quality;

I 3

h)' Deviations which could be reportable under 10CFR21, 5 A separate report'shall be prepared for each nonconformance.. The-intent 4 of'this separate report requirement is to-simplify followsup, correctivefaction,. and record' keeping. Deficiencies and/or deviations identified by QA. Staff - l. personnel shall be reported on a Quality Assurance finding form. Nonconforming items will~be controlled in such a way as to prevent their t inadvertent use or installation. Such parts will be. reinspected and reviewed. for adequacy prior, to -returning them to - the manufacturer, scrapping them,. or

arranging for them to be reworked'to^ conform. -Disposition: of a nonconforming itein will be determined by the responsible supervisor in conjunction with the-QA Staff. Written reports of decisions to repair or rework essential items will be reviewed and approved in accordance with maintenance and/or design control' f

precedures, P -i 1 Any decision to reduce requirements to permit use of nonconforming parts, .i materials, or components in essential systems,.will be documented and will be- -subject to Station Operations Review Committee (SORC) review and approval. 2-27 Revision 6- .c.

I Approved Procedures'will be ut!.lized_for-repair"and rework'of' essential parts and equipment. All such rework will be thoroughly documented.. including 1 Quality Control and Quality Assurance-Surveillance activities,. to assure conformance with the requirements of the specifications, procedures, and other controlling documents. - Essential equipment classified as scrap'will be identified and segregated - in such a manner to prevent inadvertent use or installation: inf an essential system. l The CGO QA Department will issue a quarterly trend report to the Nuclear l t Power Group Manager to identify adverse trends which may ' require corrective action. i 2.16 Corrective Action i NRC Regulations which require formal reporting to. the : NRC. of failures, malfunctions, deficiencies, unusual operating experiences, and deviatiens which may have a significant effect on quality or safety will be reviewed and evaluated i by the Station Operations Review Committee and, where appropriate', by the Safety. Review.and Audit Board. It will be the responsibility of the Nuclear Group. r personnel to identify and promptly correct all such deficiencies or malfunctions either by improved maintenance, repairs, replacements, or modification. In all cases, the' objective and the corrective action will not only be to correct the existing defect or deficiency, but also to include measures to determine'cause and prevent recurrence.of similar failures. Quality Assurance activities will verify that corrective action is performed in accordance with approved written. 2-28 Revision 6 i .. 2 g.n._. - - e -. -

,4 li ( $I< [ .o ~ procedures and that the details of the corrective action are properly documented - for the permanent station records. A monthly status report of open NCR's shall be' prepared and' distributed . to: Vice Precident - Power Production x. Nuclear. Power Group Manager L ] SRAB Administrator I Division Manager - Nuclear Operations . Division Manager - Nuclear Engineering'and Construction Division Manager - Quality Assurance Division Manager - Nuclear Support CGO Quality Assurance Manager CNS Regulatory Compliance Specialist CNS Department Managers I 2.17 Ouality Assurance Records y All activities having a significant effect on quality and safety will be. thoroughly documented, and all such documentation'will-be incorporated into the - j record storage system. Procedures will require appropriate' physical storage and personnel to maintain-these files. Record identification,' storags, retrieval, access, control, recention, and safeguarding of all quality-related I records associated with CNS will be in accordance with approved procedures. i Records to be maintcained include all records accumulated during engineering and-construction and those records generated durin5 station oporation, maintenance, 2-29 Revision-6 1 ..j i 1 } .~..-:,w.

i -and modification as defined in the CNS Technical Specifications.. These records shall also include qualification of personnel, equipment, and procedures. Inspection and test records shall identify the inspector, data recorder, method of observation, results, acceptarice, and all nonconformance reports issued to document noted deficiencies. CNS and/or Columbus General Office personnel will be allowed to maintain active working files at their work stations. The time frame for submitting these records to record storage facilities will-be determined by their respective i administrative procedures. Administrative procedures shall provide for methods for changing records that provide clear identification of the change and must be initialed and dated by the person making the change and by persons authorized to approve the changes. The program will include Audits of record storage facilities to assure that the procedures and controls are properly implemented. The CGO Manager of Office Systems Services and CNS station management will prepare detailed procedures for receiving records into the facilities and for making decisions on removal and disposal of outdated or superseded records. Refer to. Section 2.6 " Document Control" for the commitment to ANSI N45.2.9. 2.18 Audits Scheduled and unscheduled audits will be performed to verify compliance to CNS QA Program requirements and to determine the effectiveness of.the area audited. Quality Assurance Plans for each functional area of station operating 2-30 Revision 6

p i activities have been or will be prepared. These QA Plans identify the nature t and extent of Quality Assurance audit activities to be performed by QA Personnel or under the direction of management. Audit responsibilities are assigned to the Division Manager of Quality Assurance. Audits performed under this direction (working with the Safety Review and Audit Board (SRAB) as - referenced in Section 3.4) will be conducted according to the QA Plans to verify compliance l with the Quality Assurance Program. Audits shall be performed in accordance with written instructions or checklists and conducted by trained personnel not directly responsible for areas being audited.- NPPD Management may request audits of specific activities of particular concern to them. However, all such' internal audits will be coordinated to avoid interference with the operating activities r at the station. Upon completion of the audit, a formal report will be prepared and transmitted to the organization audited which will include an evaluation statement regarding the program's effectiveness. All audit findings identified [ will be documented and appropriate follow up action will be taken to assure that corrective action has been implemented. Follow-up action, including reaudits to verify corrective action, shall be fully documented. Specific to the ANSI Standards relating to this criterion, the'following commitments apply: 1. ANSI N45.2.12-1977 " Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants," and its associated Regulatc,ry Guide 1.33, is applicable to the CNS Operational QA Program, and to the Supplier Audit Program. I I r i 2-31 Revision 6 .-w.g op. m e e. 'N

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-ag r G [4;piGg y,, /M ' ~ m. g' A wi ~;-l2 g c 4 ++ m m}.,, 4 44 ?* 2 Sedtion 440(of' ANSI!N18*.7'-1972Y" Administrative Controls for Nuclea'r! > tm .).3., s, .., -= QO af 3 ~ Power Plants," will be used as;a" guide for schedulin5 and= conducting auditsi f 2 [ , n s 5 i . 2.19 [ Additional ANSI Standards-1 x c 4 ,e 3, i )- [ m { ANSI Standards ' applicable,to the CNS. QA'. Program:for= Operation.hnot directl'yi 7o a(" ' lrelated to : thel preceding: sections, ~ are discussed = in this t sectionb l -4 ..., ~ 1

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ANSI N45.2.1-19731 " Cleaning. off.; F'luid.. Systems : 'land ' 5 Associated '

'j ~ .1! t 3 4 y y ' Components During; Construction Phas's of Nuc1' ar Power Plants,'" and its _associatsd:- y e o s ~ Regulatory Guide 1.37,';is applicable'to the CNS Oper'ational QAl Programfwith the ;. t ' r;-; l +

following exceptions /clariftcations:

iL 1 s' l S (a): Cleaning ' requirements for almost : a111: maintenance - repair, 'and' j 4 t modification work will be: considered as a part ofothe'overall jobfrequirements. }a In;this respect, -detailed' cleaning' procedures' will-not generally be prepared as - -separate documents,. Necessary requi_rements Mconsistentlwith1ch'e;scopeLof the '. work, ; will be Lincluded as-a part of' the overally work. instructions ; System 'q s -cleanness is controlled at CNS by..the-following methodsi

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i i H. c(1)- Parts. and components are checked. for: cleanness.-during receipt- -j G J linspection and stored in,a manner that.will; ensure adequate levels of cleanness = l a are being maintained.~ d 1 NV ] c: q e .a 2 (2) Work instruction will be-reviewed by Quality : Control.co assure that-3 K.n i. 3 g - adequate cleaning and access -controls are incorporated into work instruction and

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ausociated safety-related activities.

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2-32 Revision 6 j m 'j qi z.-- s &q .y: V ? ,q+~ n y _ta . -m - ~, e

8 -. o 1 9 -(3): Parts. and ' components -are' inspected for cleanness! prior-to-1 .. installation-in'accordance with CNS maintenance procedures. 2 -J. -(4) Work ' areas are maintained at = a cleanliness level _ appropriate to theb i 1 maintenance or modification activity being performed, j (5)- . uality Control' or Engineering Inspections before, during, and after Q safety-related maintenance or modification retivities address system cleanness. . i i 1 '(6)- Random QA Audit and Surveillance of safety-relate'd-maintenance or j modification activities requires verification of 'part, component, >and-~ system . cleanness, i i (b) For cleanness classifications where the scope of plant modification. 1 i work-is such as to make application of the guidance provided by: this standard ] -i practicable, the cleanness classifications.and requirements thereof shall be ~ evaluated and applied, as appropriate, as

a. part of the overall work 3

requirements, (c) For most modification or maintenance work, however,--involving only j i small portions or individual components of larger systems, it -is' not considered : zi practicable to conduct cleanness tests with ASTM E11-70 Series. ' Appropriate! ) ? cleanness will be maintained during the work and preoperational flushing will be conducted, cor.sistent with the scope of the work performed and the original design requirements. Controlling the parts and components and the work area has provided CNS with reasonable levels of assurance that system cleanness will be 2-33 Revision 6 j +>4 +w '%+A m.-+- c- .ee ,sq. w s e.4 m e+ 1 r,r h f

maintained.. In addition to;the1above, the' Water Chemistry, Department routinely samples and tests for system cleanlinessi corrosion, crud buildup, etc. 2. -- ANSI N45.2.3-1973 " Housekeeping ~ During the l Construction. Phase of: Nuclesr Power Plants," and its associated. Regulatory Guide 1.39, is applicable to the CNS Operational QA' Program, with the following' exceptions / clarifications: -(a) The plant has been divided.in zones for fire. protection.and security ' purposes'. The zone designated for-cleanness. in the ANSI Standard are primarily_ intended for control or work during construction.of the plant.- Therefore,Jthe~ Lj 1 CNS facilities will not be-classified by the zones designated-in.the Standard i. l general housekeeping rules.. Limitations-on' eating, drinking,' andl smoking are -j already' provided in existing CNS procedures. Where special cleanliness controls, - i tool, and ' material accountability are required for -particular - types - of work, -i temporary clean areas will be designatedMand defined in then procedures for accomplishing the work. -j j (b) Fire protection and prevention will'be provided in accordance with NPPD evaluation of the CNS fire protection system as required by NRC regulations. (c) Station procedures have been reviewed to determine the need for particular cleanness, housekeeping, and control provisions. Where indicated, i procedures have been revised to incorporate such provisions, using the guidance [ of ANSI.N45.2.3. 1 - j ) 1 l i 2-34 Revision 6 i ..d n -. e c.- ~

I E 1 t 3,0i ORGANIZATION AND RESPONSIBILITIES: k . Nebraska Public Power District is' solely responsible for the operation. of the~ Cooper Nuclear Station and will fulfill.the objectives' set forth in the , Quality Assurance Program for. Operation through its own organization and : by h contract with qualified contractors and consultants. i 3.1 Egneral e The overall Quality Assurance Program for Operation shal1 ~ be ' conducted ' [ - in1accordance with the-three divisions tof responsibility which provides for- . Quality Control, independent Quality -Assurance '. Surveillance, and Quality-Assurance Audits. Table 2 defines the-three levels of QA as they,are to be -implemented for station operation and also shows.the comparison with similar. principles which - shall apply to nuclear fuel procurement and any future = major. engineering and, construction activities for the Cooper Nuclear Station, It is intended that clearly separate-lines of responsibility be maintained between those responsible for the operation of Cooper Nuclear Station and those responsible for auditing to verify that all quality and licensing requirements are consistently being met. QA responsibilities will vary depending upon the type of activity involved-(See Section 4.1.3). Additional details on individual QA responsibilities are given in the paragraphs which follow, together with 3-1 Revision 6

N + v. nadditional explanation of the. interrelationships between the various supervisors-I ~ and managers: involved. 3.2 Fuelear Power Grouo Manarement 3.2;1 Vice-President - Power Production The Vice-President Power ' Production is : the responsible' executive officer for all CNS Quality Assurance-related'. activities. He.may= delegate : responsibility.to the Nuclear. Power Group Manager as in 3.2.2.below. 3.2.2 Nuclear Power Groun Manager As delegated by the-Vice-President - Power. Production,: this ' responsibility includes the Quality Assurance requirements 1 governing. those structures, systems, and components that prevent or mitigate the consequences-of postulated accidents that could cause. undue risk to the health and safety of the public. Pertinent activities include designing, purchasing, fabrication,. handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, in-service-inspection and modifications that are associated with Cooper Nuclear Station. The responsibility and authority over the Safety Review and Audit Board 'has been delegated to the Nuclear Power Group Manager. The Nuclear Power Group Manager reserves the authority to conduct, or order the auditing or monitoring of any operations activity, at any time, to ascertain the effectiveness of the 3-2 Revision 6 --..n;n

(( ll ~ J c a 'overall'QA' Program and to determine that all aspects of:the QA-Program are beingt ' complied lwith. .t t 3.2l3 Division Manager. Quality Assurance-4 The.Div' sion Manager of Quality Assurance,: a member, of? the, executive. i staff,=. reporting ~'to.'the, Nuclear ~- Power. Group.. Manager,. shall havef the responsibility and. authority for ~ administrating : and-maintaining : a(Qbality-- Assurance ~ Program for Operation which is-in.accordance with 10CFR50, Appendix 1B.H .j

t Inherent' in this. responsibility is the'. authority to accept or-reject any or all.

1 ' work, materials or aquipment associated with Cooper Nuclear Station.and Columbus: .p7 i CGO' The Division Manager of Quality Assurance shallidirect'the preparation'of-plans ~ and instructions for defining the Qua'ity Assurance - functions: associated Y with Cooper Nuclear Station to ensure that such activities - are ' conductedL in accordance.with the Operating License 'and1 appended TechnicaliSpecifications. - 1 He shall also. approve all plans and instructions for defining and auditing the_; -i safety-related activities within the Cooper Nuclear Station-and General Office. The actual audit functions-to be performed are defined more completely.by the body of Quality Assurance Instructions and Plans required by Section 4,0 of this policy -document. He shall also have direct responsibility for evaluating suppliers of nuclear safety-related equipment, materials, and spare parts and t. for auditing the QA/QC activities of such suppliers. The Division Manager of Quality Assurance and Staff' shall have the necessary organizational' freedom and access within Columbus CGO and Cooper a Nuclear Station to institute the necessary Quality Assurance requirements, i 3-3 Revision 6 1 t' .' 5 s" ' y N f s.-- ,,a y,, LJ-

s: l t identify problemt, and pursue" prompt corrective' action. Figure:1 outlines the . QA' Division-functional-. organization. The; Division' Manager-of Quality 1 Assurance shall' ? monitor ~ the -. Quality ; Assurance activities to the'~ extent. necessary for assuring compliance with then i . program. He shall review the effectiveness of the Quality Assurance Program with' I the Nuclear Power Group. Manager-on a regular basis. In' addition, the Division: I ' Manager of QA has. a direct-line =of communication with thel President ;and C.E.O.' He shall serve ' as a member of the~ Safety Review iand. Audit Board and; provideL j additional QA Personnel to participate in SRAB activities.when requested. i NPPD Quality Assurance Staff, under the' direction of the Division Manager of Quality Assurance, shall have r.h e responsibility and authority for; q implementation and ongoing development-of the Quality Assurance Program; for ] i Operations. In addition, it.shall be the responsibility of the Quality Assurance-9 Division to monitor. the interface between the Nuclear -Operations and I Nuclear ' [ s i Engineering and Construction Division to ensure that plant modification and-i repairs receive the proper design reviews and approvals. 'l As shown in Table 2, he shall have responsibility for accomplishment of l third level QA Audits and shall obtain assistance and special expertise when necessary to complete such audits effectively. 3,2,4 Ouality Assurance Manacer Cid The CNS' Quality Assurance Manager, reporting administratively to the Division Manager of Quality Assurance, shall have the responsibility and 3-4 Revision 6

ff. r ~ ' authority for ; implementing-and~~ maintaining l the Quality. Assurance Program" for Operation at'CNS; He shall also be responsible ~and have the authority to perform, direct,' ~ or coordinate.QA Surveillance and Audit activities within~ Cooper. Nuclear Station- . to determine if: conformance - with NPPD: Quality. Assurance Manual ~ and applicable. federal regulations as. defined in the NPPD.QA Manual are being maintained. The- ) -{ = CNS QA-Manager shall advise' and assist the Division Hanager.'of Nuclear Operations j i 'in all^ matters which. affect the' quality of1 the station..Similarly,-he~shall ) -7 advise andJassist all1 station personnelrin matters' regarding Quality Assurance ]-i and Quality, Control. The CNS. QA ' Manager shall' designateE members - of the CNS) ,'l QA Staff upon request to provide training and-instruction programs' to enable CNS < q. H personnel to effectively execute the District QA' Program. The:CNS QA Manager l is also responsible for monitoring the tracking of open audit-items and' interface -j with NRC during inspections at CNS. In addition,.he shall also be responsible to verify that solutions to safety related problems':have been implemented ~and to perform scheduled audits of those-activities listed'.in Section 4.1.3-on an 't i announced basis. Additional' specific duties shall be defined in the Quality . Assurance Instructions and Plans issued in accordance with Section 4'.0 of this ~ Policy Document. The CNS QA Manager or designee shall also serve as a non-voting j member of-the Station Operating Review Committee (SORC). j i b The CNS QA Manager and Staff will observe operations, maintenance,. in-service inspection, special processes, repair 'or modifications, and other safety-related activities covered by the Quality Assurance Program, and 'to retemmend that work stop when such activity, in their opinion, does not comply with approved controlling document as defined in Section 3.2.2 The Division 3-5 Revision 6 .q 1

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= l g b m r h' s iManager NSfi Nuclear (Operation 7 or (designeeVis h responsible

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U ~ s: I = p i recommendation-and..actually-stop?workcunlessihe has determined sucht stoppaget , jwould(result in, a; violation off the Technica15Specificationc.or otherf approved;; h documentsc(governing. station : operation 3ior0 whother; there;:areJ overridingn 0 yconsiderations.of safety'involyed. 1 v 'N 4 ..~p ) + c 7,., + n; = .TheMCNS4QA ManagerLwill3 provide ifor : 'a coordination ( function'; forg, i L U' (QC activitiesf atiCNSi = - This,tincludesJ reviews 9of inspector l'certificationsFand!- "+ f h>erfo anceland hhe-establishment of a tsainths program. Th'sfunctionwilfalso?

provideithe: communication 1 path for the resolution!.of:QCJInsoector' concerns, iDering' absence of! the'CNS QA Managerf,d antiddiv'idual from his'staffYill 2

- be designated to act.on his behalf and serve'as <the nonvoting member 'of SORC;: '3.2.5

Ou'litv' Assurance Manager'- CGO' a

J y The General'Offico Quality Assurance Manager,0 reporting administrative 1y; - to the; Division Manager of Quality Assurance,Jshall haveithe: responsibilityJand ' f q authority for implementing and maintaining the: Quality > Assurance Program within. 1:j - 3 i the CGO. J! R 4 The-General ' Office Quality-Assurance: :: Manager ' shall have the : ) - -l - responsibility. and authority for. the controlling,.; administrating,1 distributing, j and. coordinating changes --and additions :to ' the' Quality Assurance Program ifor:5 h 1 -Operation, subject to the requirements : of Sec tion 4. 0: of - the ' Policy Document. +,. q The Cenoral Office Quality Assurance Staff Shall; support the CNS.- QA" Staff in

quali.ty matters-such as internal audits.and outage coverage upon request,;-as' 3-6 Revision 6' l

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im, .e o '8 l a n;; O, )f, e d.-: lh-i l W i .f',^- p: + y A' W. + w< . w ~ $)ys i agreeddbbtween f thei Genera 19 Office l Qualityf Assurancei Manager? {and' Sthel CNSI m i 1 + , i 4 , J..s (QA; Manager.R //[The e LGenera1T Office; QA Manager:. and):StalfIIshall 5have['thej e .I $4-. i S.n? 1 responsibility for' providing guidance to the CGO Nuclear Divisions' ~in all matters, R .. ?i.. .s y y )af fecting: quality b They.; shal14also ? establish J and; implement: thelprogramj fori p m j 1 ~ g n: m 4 i-- ,g '-3 iI. -[ 1eva'luating. suppliers for/ safety related equipment,Ematerialsyspareiparts/Tand +' t r: g, i f services',-, !.They/shallf also?be f resp.onsible: to performi scheduled;.ccrveillancesid 'witbinithe General;0ffice and verify that corrective;actionihhalbeen imhlemented. t e . ~ .? The ? COO QA' Manager 'shallfestablish a ' programc foryQAireview. of f thel i 1 l s m ..t.. 1.. E ? design / engineering'functionlin the;CGO fincluding configuration managementE 7.: 1 'i 4 g - Additional duties are' defined inLthe Quality Assurance Instructions 'and ~ Plans. ~ y ] y The7: General.. Offices Quality; Assurance Manager fis Drssponsib1'e;.for: 4 interface, - along :with the Division Manager of. QA,1with NRC31nspectionsl at the-W L - General Office. ?In ~ addition, -he.shall, also provide;for training and11nstruction - tprograms to enable. General' Office personnel to-effectiUely execute the;Districti Quality Assurance Program. 'Unless 'otherwise provided for in.writingT the General y 1 Office Quality Assurance Manager shall_act for the: Division Manager'ofl Quality-Assurance in!his absence. .1 ,s

3.2,6 zQuality Assurance Supervisors

] .l.i i The. Quality Assurance Supervisors report to the applicable QA' Manager ' .and are responsible for the performance of work activities assigned. They.are h q responsible to direct the-performance of QA activities, and to identify any j 3 1 0 3-7 Revision'61 a

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{ @ pre.w %x en @ @ mn t . p\\. w ~- _ ; bl Ws v% a bc. T gg ;g, >, %y, a%;- s,, ' >, %v i, xOW, m, y. v t ? + ..g p. a y xy s gy y p Mt ,ct M N' p'k g 76 s C, _ qq ', A jq ygg / 4 r s g( F: @3 - y, + w .o y 3 / w m, o s a.- W, %{ gcondition adverse lto quality to the appropriate (QA1Manageri LThe;QA(Supervisorsj .J,..., i -z-- ~ m. F4 ] y g(yg lare} responsible Afor qtheV; continuedimaintenanceWand Supgradingi of[QAf Program %

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b; , ? c m$ng ' ? -y ~..-, W; y LDocuments. y y .k. 8 g ..f 4 e. s y i # I 4 i - s M '3,2;7) J0uality' Assurance'Staffc &%~ w ~,. ^ IQ a ~ N.. ,(. lW 3 V. ..;[.. ,.f.. ~ General Office OuhlirC Assurance Staff: 1 ^ r s 4 s t'

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H n; 2: J-The General' Office Qual'ity? Assurance-Staff sia11Se, responsible \\tojassistf ' @s \\

a diadvise(the (General fOffice Mality $ssurance[ManagerNin,alNmatters/whiEh3 '

4 p n. r,. v. .,o ' '.could^ affect the!Quslity: Assurande activitiesEwithin the General' Office; LThis? r x y

in61udesladvihing and assis' ting General Office personnk1 it?$,1(ma'tters regaiding; i

,a w Quality Assur,ance;yverification thatisolutionsitoEsafety rsisted problsmsihavef f [been implemented; LandLfor, the1 performance of Laudit' Fand'surveillances "of worki ) s f . activities within.the General Office 1on:an'announcedior unannou'nced basis, &1 + s i .i -The CCO QA Manager has' designated =ythefCG0iQAcSUpervisor? responsibility? y for. the ongoing - development 1 and Limplementation s f.x the ? supplier y evaluationD G o m - program;- review of procurementEspecificationsp andw associated 1 drawings Jto determineDifispecial requirements such as codese standards;gmaterials Jtools, W - and inspections, etc... are properly included; Land ~developmenti and'implementatiion - } ;-. 1 -of the QA engineering function; m P [( I' (g g: ' CNS.Ouality Assurance Staff d d .q The CNS Quality Assurance Staff shall be responsible.to assist and advise y ]j 'the CNS Quality Assurance Supervisors in all matters;affecting the quality of r '^ ~ 3-8 Revision 6 i s if ~.f'- I g 31

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= - M, r w n,hL :q' Wm : m m ~ A Q&if h l l [Q* ,r.. 2 . M. + s i c. q~ ~ " g iC;j, 3 " 7 R t g E '+ RtheirstationL cThesef fdutiesi Lincludel jprocedure preparatio;n,3.z performing / m b' % T QAL:activitie's within the' station dadvise Land [ assist. all' station ~ personne1Lin _ all. e t ~, g > matters regardingiQuality Assuranceland; Quality; Control',} verify:thati-solutions: q

to!: safetysrelated1 L problems havel been? implementedi' perform t audits? Rand?

j L q 1 tsurveillances of work activities'within CNSLon an: announced or unannouncAd b'asisi- 'N 'r L.

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s. n Additionals duties. shallibe as ?.de fined J in the 1 Quality [ Assurance O PlansTahdi N Er e

Instructionslissued51n.'accordancewith: Secti6n:4.0ioflthis policy document.

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Disagreements orl differences of 'opinionion. Quality Assurance matters:are f 4 .m. p a J Lexpected toLbe' documented and-resolved jointly.(by)b'oth the..CNS and General Officek ,3 m Quality-.; Assurance Staff land.? appropriate [CNSlor General [ Office isuperOdory) j[ 4 ( w ~ : .v. ._ r +. ', - personneli Where such resolution is not"achievedi ithin a; reasonable period'of.;- 2 w .y o time,; unresolved Edifferences shall ' be ' promptlyf reporte'd:. to i theNappropriate( Quality Assurance Manager / for resolution? jointly lwith the Division Manager;ofi ~ M Quality Assurance and the other respective DivisiontManager. s 4y i Secretarv to the -Division Mannrer of OA' J 7 b d i 1 4 The ' Secretary to - the ~ Division Manager - of-QA shall; be responsibleJfor~ h c

I administering and documenting the controlled QA program document" distribution.

d Additional specific - duties shall be'- as ' defined in the Quality _- Assurance -. t 4; Instruc tions and Quality Assurance Pl.ans. issued in accordance with Section 4.0__ s of this policy document. ?! u s O -f E 1 4} s 3-9. Revision 6 o - > ;L ,.p+ g.-..q,

=3i2,8-Division Manacer - Nuclear Engineerine and Construction-i The Division Manager of Nuclear Engineering and Construction under the direction' of the Nuclear Power Group Manager shall provide technical assistance for-plant modification activities at Cooper Nuclear Station. .Those Quality ~ Assurance activities : associated with such ' modifications will be conducted in - = l accordance < with - the, CNS Quality Assurance Program for Operations. These

activities will 2be audited--L periodically - by -Quality - Assurance 1 Staff and q

T:ality reltttd :.roblems shtt'.1'be-identified and reported to appropriate levels -of management for resolution. The"QualityLAssurance Scaff will perform the- -necessary follow-up action to assure that-corrective action-is-implemented in l a-timely manner. f. Nuclear Fuel Manaper i For those aspects of Fuel Management QA covered by the QA Program,- the Nuclear Fuel Manager; under the direction of the Division Manager of Nuclear Engineering and Constructien, chall ba rssponsible to furnish technical i assistance as required to the Division Manager - Nuclear. Operation and the QA Staff. Such reviews shall not replace or supersede'the formal audits. 3.2.9 Division Manover - Nuclear Operations The Division Manager of Nuclear Operations, under the direedon of the 5 Nuclear Power Group Manager, shall be re sponsible-and have the e. Tority for assuring that Quality Assurance activities, as defined by this and other approved - QA Program documents are complied with. Some of these responsibilities are 3-10 Revision 6 l l l

I 4 delegated to CNS management ' personnel and include Quality Control and' Inspection . - functions.Las defined in Table 2. The actual' functions to be performed shall be defined in lower tier documents such as QAPs, NPG Directives, etc. The Division Manager of Nuclear Operations shall regularly review station; . activities for the purpose of keeping' abreast of significant quality activities, !q 1 i 3 3.2.10 - Division' Manager ' Nuclear Suppogg The - Division Manager of Nuclear - Support,.under the ' direction of the = Nuclear Power Group' Manager, shall be responsible -and have. the. authority for assuring that activities under his control are conducted in accordance with this i QA Program. This includes but is not limited to timely responses to-QA Division i Audit and Surveillance findings and implementation of.. appropriate corrective. - i

actions, j

i i 3.2.11: CCO Denartment Manacers i CGO Departmental Managers report to either the Division Manager - Nuclear 1 i Engineering - and Construction or the Division Manager - Nuclear. Support as I described in the USAR and are responsible for. implementation of QA Program - objectives within their area of responsibility. 3-11 Revision 6 1

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. Operations as describedXin the CNSz USAR s and L are 4 responsible : for f: implementation:-: ' .j z ~ O e & ', T '. s lj [$ ' (of QA$ Programlobjective's;withinitheiriareal of(respo.nsibility; .m s

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c10 d; 3 W .y >f ..4 F, a - s g.: The operational duties and responsibilities of the Cooper Nuclear StationT >4 a P) 'pers onn'e17 are deset ibedkin ithe T CNS E Procedures O Manual', s Reference M,6. ?Inl 1 2 .a, - y " addition', ythe Cooper : Nuclear Station; personnelJ are 3 assigned.QualityiControlj andl, y s v ,4 t. -inspection functions. eStation personnel",,under?the direction ofitheCDivision-z I' Manager H : Nuclear 10perationlJarej responsible sfdr gassuring?th'at ;the Jstation xis. ] ' tested,-l operated, maintained;; and modified in accordance;widhfapproved plans "and c i g_ -m. - procedures. j f ^ '3.4 -COO Personnel q:; 4y The duties and responsibilities;of CGO.personne1T are - described.-. herein t t

y and'in the appropriate. implementing documents. These' documents address the CGO

.1 responsibility for' such -items as design,;. procurement, : modification'y 'and 4 ri ~ ' licensing. Reporting through odepartinent: - and _ division managersaidesuribed; { he lpreviously, theirs is the first line responsibility for implementing this-program ^ i j f n the CGO. i[ a d, .{ 1 3 12 Revision 6' m ( 1 @ W,, 'i 4 e4 .c y, - u W.__ ; ; 1 s,

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companyi,policyfand(rules',fapproved operating proceduresE..and1operatingflicensei

, H. n., r Lprovisions ;m reviewlimportant Lproposed} planti chingpis,7 tes ts,p And ; proc'edtires ;[ 4 verifyi that(licensee even'ts are; promptlylinvestij,atedland;c6rrected:infa; manner T, ..;g .e .. i s i} .,... _i. twhich;reducesithe probabilityhoffrecurrence of[suchievents; ' and detectLtrends5 c s S I-. 'l'; / which.mayin,ot"be$, p~ parent Lto -.a day-to Hdayf observer 6-4 3 m - ^ - 1

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m m I i iSpecific ; duties Land responsibil'ities S of(SRAB..;? incl"uding ;au' diting,i are s ,j ). s I ~. ildentifiedcin Reference 7.15,- CNS Radiological 1 Technical Specifications', and in? ,4 ,m I l JtheiSRABlInstructionsTand Guidelines'. M 4 s +d (l s i l 13.6:

Station Operations Peview'CommitteeL s

1 h The Station' 0perations ' Review /Committeef(SORC)[has been established ( ton ~ 3 ? advise E dhe/Divisionf Managera - Nuclear. Operation ?in LaYlh ~ matters t reg' bding) f a 1 -operational 1 safety. ?Aq !) 0 Specific duties andr esponsibilities 'of..SORC.are? Lidentified.' in r 1 Reference 7.15, CNS Radiological Technica1' Specifications. I M N 3J7x Outside Suco11ers. Contractors. Subcontractors; and Consultants. ] During-the life of Cooper. Nuclear. Starion, it will" be zoccasionall' ; y

r necessary to'obtain assistance from-outside suppliers and-contractors.

At all-times, these outside suppliers, ' contractors, and consultants will work under the? J 3 13 Revision' 6'. j 1 ', l : , j\\ i E Mh5 b (, N ? r ' 1 :', y;

y 4 - direction of the-NPPD ' organization having primary-responsibility for, the i particular work being performed. In those instances in which outside suppliers . or contractors merely furnish personnel to augment the normal-station or CCO j + q staff for' particular activities, - such outside-- contractor personnel shall be required to perform their work in accordance~ with the CNS - Quality hssurance ') -l Documents and other appropriate CNS procedures and. ins tructions. In those instances in ' which outside suppliers, contractors, and subcontractors. ~are assigned primary, responsibility :for a particular activity, such outside _l d contractor shall be required to maintain a Quality Assurance and Qual Lty Control. ll 1 Program and organization appropriate to the work to be performed. AL suppliers, l -contractors, and consultants performing work classified as essential shall be maintained on the appropriate.section of the CNS[ Approved Suppliers List. Selection of. outside suppliers or-contractors shall require the' active. participation of the Quality Assurance Departmentin evaluating and approving their Quality Assurance Program and reviewing the. procurement documents prior to awarding the contract In every instance in which outside contractors have responsibility for l work on safety related nuclear systems, they shall be contractually required toe work to procedures previously approved by the NPPD organization having primary responsibility for the particular work being performed. In addition, they shall be contractually required to prepare, prior to performing the work, QA/QC Procedures specific to the work to be performed for the Cooper Nuclear i Station. Recogni;*ed standards or existing proprietary procedures may be used, but they must be specifically invoked in writing and clearly identified as to their applicability to the CNS work. i 3 14 Revision 6 4 +--..=au 4 o a e eet

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" 4'A]) g 5 i ~ ~ work on.? safety-relat'edh nuclear 3 systems Lis J tsibel Iff any portion ':Lofa = -e 7 :

subcontrac.ted;tthe prime contractor; shdlliimpocel thet appropriatef QAirequirement's i

4 {on thelsubcontkactor.; NPPD QAlshallLhaveldirect access to and communication withi ~ fthe! contractor's;personnellat'all:::levelsib'othfattheiEhome"officeiandlinlthe) s 5 fields ^ N sz g w 1 I,- , iPrior to performing.: work at ^Coopor; Nuclear St'ation,:Loutside' suppliers,, y 1 Leontrac tors, fconsultantis,fand ! selheted representatives from -:tde j NPPDoNudlear L h; q m% 3 LOperationrandf Nuclearo Engineering;: and i Construction' Divisions > shall?. jointly 4 ,q adevelop andienforce written ~ agreements add procedures";which c1'early/ define-ther' N i J y 'limitisLof the kork;fLinterface between contractor and'scation personnel;~statusl and: custody. tagging ~ procedures ; Leontractor-personnelidosimetry;f:andf.any.other) Easpects 'which b' ar. on station or' personnel security and safety.'. :Such agreements? e -i .shall be reviewed by. the?. Quality Assurance DepartmentJto" ensure compliance 'with ] -applicable Quality Assurance Program,

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- At all'. times when outside1 suppliers,L contractors Fand. consultants "are = q obtained to -assist 'in-the execution of. this LQA;programi the responsibility for; -effectiveness of these supporc organizations activities will' remain:with'NPPD,? ij ..'t a .i ?! ..j t .t f; B 1i .4 1 3-15 Revision 6-j 1 i ( , +. -

4 i f f ' 4. 0.- OUALITY ASSURANCE DOCUMENTS - The CNS ' Quality-. Assurance Program is defined by written - policies, procedures' and instructions which shall be implemented throughout the operating life-of the station. 4.1 NPPD Internal Documents. Work procedures are based on the' requirements' of. the Quality Assurance. l ~ Program. Preparation and maintenance of basic work procedures is performed by - F ergineering and operating groups, separately from the QA Plans iand Instructions ~ i Mandatory QA/QC checkpoints shall be incorporated directly in or attached to, the work procedures to facilitate coordination between the specific work activity - and the Quality Control-function. It is 'not the - intent to include the preparation of basic work procedures under the responsibility of.QA,.norlis it. 3 the intent to incorporate basic-work procedures into the QA Program Documents. Work procedures,-however, shall be reviewed by ; Quality l Assurance for : proper ~I , implementation of the QA Program objectives. l The format and content of QAPs and QAIs shall be as specified by a.- Quality Assurance Instruction. Significant. changes shall - be revie wed and i approved by the same levels.of management as for tho. original document. Each change, when approved and issued, shall be distributed through a controlled ^ distribution system. Particular circumstances may occur while some work is.in progress, which necensitates a change to an approved work procedure. When such circumstances 4-1 Revision 6

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I

arise, the. changes _. must ;be authorized 'per proc'edure. : ( Th'e ' written record shall-1I 2

~ < fclearly: sh' w the. nature and extenti oflthe.-L change ' and Lthe'. reason. for. requiring : o. suchLchange., e r 14.1'.1 : - 06ality control Insnection ,'i i. l The. Quality-Control Inspection-function..shall. be Lperformed by; ~ m !

?

individual (s) 'other: than ~ those. who are Jactually performing-the - step (s) being' -[ h inspected or. who are providing direct, hands-on, 'at-the job supervision'. The' l

e Cooper Nuclear Station management, ;as part ofitheir normal management function, are responsible for preparation of the Quality Control-requirements of'the Peer:

[ .QC program;.however, the-CNS QA Managor' is responsible to review and ' accept - l . control methods prior.to implementation. The,CNS ' Quality Assurance Manager, working. with= thel CNS-' station management,.shall verify.' that adequate -Quality;1 Control inspections.are' incorporated directly _in, .or - attached to,- the. work procedures - t and: shall-

periodically inspect work performance -to assure; that the procedures containing Quality Control inspections are being followed.

The QC Program shall identify. the specific work which is to be ' subjected to inspection or verification and shall provide in detail the elements of work to be. inspected:which include: ' 1. Identity of the inspector or. data recorder. l 2. Type of inspection or verification. r - 3. Results (data to be recorded). i 4-2 Revision 6 ss4-- e 4 -e g

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4. / Acceptance (qualitative or quantitative)-criteria.

5'. Method of disposition.of' unsatisfactory. inspection results.. (6it. Reporting requirements. . In addition; clear instruetions. shall be.-'given regarding : the timing,. -frequency,or scheduling,;and notification requirements for such inspections so as to'obtain maximum effectiveness and-to_ minimize delays in completion of the" -work. It.must be recognized, that.certain work, particularly in nonroutine :. maintenance or repair, cannot be anticipated. - Therefore, procedures and Quality Control Inspection requirements cannot be prepared until-a'particular' problem <has been-detected and evaluated, r. Routine maintenance and repair of essential systems and components 4 -I generally requires performance of a complete or partial Surveillance Procedure l prior to placing the system back in service. This type.of QC (actual performance-- or functional testing)' following completion of work ' is considered a unique - advantage on an operating facility. Such. surveillance testing may be performed by the individuals who. performed the' maintenance activity. Records of the surveillance will be reviewed by the system engineer or other supervisory / ' management personnel. 4-3 Revision 6 ~'

j

4.1.2 Ouality Assurance Instructions-(O'AI) 1 The Quality Assurance Staff shall prepare QAIs: approved by the Division Manager of Quality Assurance. ' As previously described in Section 1.5 of this i document,- QAIs define QA division work activities. Mien. approved, QAIs-shall. become a part of the CNS Quality Assurance Program:for Operation. l '4.1.' 3 Ouality Assurance' Plans (OAP) Concurrent with the preparation of work procedures, and during operations - or maintenance activities, Quality Assurance Staff shall develop QAPs as needed. ~ 1 As described in Section 1.5 of this document, these QA Plans ' will -outline -l i specific Quality Assurance activities and shall become a part of.the CNS Quality j Assurance Program for Operation. Distribution of these Plans will be to those individuals who are responsible for that particular~ activity. A QAP shall be developed for each-functional area defining the-scope of the QA program. ] a The format and content of QAPs shall be specified in a QAI to provide uniformity and to assure that each plan is complete and adequate for the incended

purpose, n

The-QAPs shall be prepared by the Quality Assurance Staff and shall be reviewed and approved by the Division Manager of Quality Assurance. In addition, when significant changes have been made to these documents, the QAP will be routed to the following for review and comment: l Division Manager - Nuclear Operations 4-4 Revision 6.

(' K, q s }.' '. 'J'~' C 4 T;I 3 - t Division Manager . Nuclear: Engineering and Construction. LDivision Manager - Nuclear Support-The QAPs J shall" define the specific work which is to 'be: subjected to . Quality Assurance l review, surveillance,' 'and audit,

and the manner in whi'ch such

~ review; surveillance,_and--audit'is to be implemented. ,il'l i - Checklists - shall - be prepared afterEreviewing _ the work - procedures j i describing the.QA Surveillance or QA Auditiguidelines. i a)' Ouality Assurance Surveillance j il 1 The Quality Assurance Surveillance function is intended to provide ] ~ (i an independent verification, on a continuing basis, that work is being performed? d in accordance with the. requirements of the controlling-documents. The Quality - t _ i Assurance Surveillance activities are not intended to duplicate-QC' Inspection activities, however, duplication may occur, in the effort-to satisfy both Quality 1 Assurance Surveillance and Quality Control requirements. l The objectives of Quality Assurance Surveillance are to verify that the Quality Control Inspection Program is being effectively-implemented; that -i personnel performing Quality functions are properly qualified; that adequate q n information is recorded to provide a complete and accurate quality history; and i that deficiencies are identified, corrected, recorded, and corrective action is taken to prevent recurrence. 4-5 Revision 6-j

'f d-i R h i This philosophy shall ' be - - taken into ' account-- in developing the checklists for Quality Assurance Surveillance activities.. QA Surveillance shall'. ' be as prescribed in QAPs and QAIs. 4 ,TheQA checklists shall identify.the area >of_ work to be subjected ~ to surveillance and shall provide necessary instructions. The timing frequency, - s ' or schedule for the surveillance' shall - be L coordinated '.with ~ the bark being l . evaluated to--enstire maximum effectiveness with minimum impact on the progress

)

1 of the work. ] l I b) Ouality Assurance Audits-

j

~ A comprehensive. system of planned and periodic - audits shall' be k implemented to verify compliance with all aspects of: the. Quality Assurance 1 Program and to determine the effectiveness of the program. The audits shall be - performed in accordance with written procedures or checklists by appropriately trained personnel not having direct responsibilities for the work being audited. The audits are supplemented by regular surveillances, the results of which become part of the final audit package. The General Office Quality Assurance Manager. and CNS Quality Assurance Manager shall have the responsibility and authority for planning and executing Quality Assurance Audits identified by approved QAPs. However, the SRAB, or any manager or executive in the chain of organization above Nuclear Operations, or above the Quality Assurance the Division Manager ' Supervisors and Managers may initiate and carry out special Quality Assurance-Audits within the guidelines provided by this Quality Assurance Program. Audit results shall be reported in writing to the NPG Management in accordance with 4-6 Revision 6 y., s..,.

the requirements-of QAI-5 and the resvits shall be review'ed with-the Management responsible for the area of activity audited.! Appropriate follow-up action shall

be taken and documented as directed by the appropriate Quality Assurance Manager or Supervisor.

I f Internal-instructionstinclude descriptions and timing of types of- , audits to be - performed; guidelines : for performing audits, procedures. for initiating an audit', and guidelines for preparing audit reports. Each'QAP will be implemented through the use of -the appropriate checklist. On the basis that some Quality l Assurance Audits'are to be conducted-or directed by - management, it is essential. to maintain ' a. high - degree of flexibility in-the manner of conducting.an audit. It.is intended that the QAPs. provide audit guidelines to assure that-areas to be, audited, are sufficiently -defined in advance and that audit personr,el are adequately: prepared to make.a i meaningful audit with a minimum of interference with the progress of the work. Also, flexibility.is required to permit the auditor to adapt his procedures to-the conditions existing at the time the audit is made'. l 1 i 4-7 Revision 6 l . -,-.--...,n.,

-.s 7 y J i -5,0

METHOD ' 0F IMPLEMENTATION The CNS,.'.QA' Program for. Plant Operations will-utilize. the guidance.

provided : byl NRC' publications WASH 1283 (5-24.74), WASH 1284 ' (10-26-73),~. and WASH 1309: (5 10-74)- (" rainbow". series) except. as - noted: in: the " Specific' t -Exceptions" of this section. l l '.I The. existing operational'QA Program does not address al1~ of the detailed ' 1 a" requirements. set.forth in the " rainbow books." A detailed review has been.made to determine where the CNS QA Program differs from the ANSI Standards cited in i the " rainbow books." 4 N With : respect. to the applicability of.the " rainbow books" and '- the. associated' standards, it'is impracticable to apply all of the requirements set l r l .forth by these documents to a plant for which important,-and (in.some. respects) l i: l . irreversible commitments, were made at the start of commercial operation (197.4). l l It-is also-impracticable to apply requirements.to -an operating plant which.were - l-intended. solely for the design and - construction phase. In. the event that-construction activities are undertaken,.the District will commit to compliance with the applicable portions of the WASH Series ANSI Standards. It is NPPD's intent to apply quality standards. to maintenance, repair, and modification - 1 = t. activities which will provide results which are equal to or -better than the original construction. i The detailed methods of implementation shall be as provided for in QAIs and QAPs prepared in accordance with Section 4.0. 5-1 Revision 6 m..7 .i

p a 4 i + The Quality. Assurance Managers or designees shall review-and comment on i the NPG procedures to ascertain that necessary quality requirements are included, r Procedure changes will be incorporated as necessary to correct identified control' deficiencies or needs. Differences of cpinion on QA comments shall' be resolved 1 .[ as indicatedLin'Section 3.2.3. - After review: of the various NPC procedures and manuals, the - Qual'ity. Assurance Manager shall review the appropriate QAIs and QAPs for the purpose of assuring-that. the overall' QA Program objectives continue to be' accomplished Lin each segment of the~ work to which this QA Program applies. ' f i '. i Quality Assurance activities shall be coordinated with the SRAB and SORC. . QA activities shall be conducted in a manner and on ' a. schedule to assure organization, supervision,. communications, and technical.and ' administrative j 1 practices clearly provide for smooth, orderly, controlled,- and safe execution of all safety-related functions. Written -reports of all QA activities, including descriptions of deficiencies and resolution thereof, shall be incorporated -into the official- -QA file. Corrective action on deficiencies shall include resolution of the - i specific deficiency and verification that corrective action has been implemented to prevent occurrence of similar - deficiencies in the future. A report ' of - i QA Audits performed (internal and external) shall be submitted to the ~ J Vice-President - Power Production by the Division Manager of Quality Assurance annually. 5-2 Revision 6 . -... ~. - ~ ..m,,.

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, -g . y; y 1 s e t + .;}, -The -Quality Assurance Staff shall; maintain' an up_-to-date summary of the : p .q ... r L-CNS :- Quality -! Assurance Policiis, ~ Instructions 7 ~ and: Plans, : showing-.; how this )! o) ~ N QA ProgramT for10peration: implements thef NRC guidelines l contained 'in? 10CFR5'0,j. ' l:4 .) Appendix B.c s .n I i k s" i

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1-j y i j ? .i n 4 , i, 1 ~;j i 1 5-3 Revision 6~ -q i 'f .t 'd i w-

7 }, s. w f k [ 4 h'< 6.0 RECORDS RETMTION AND DISPOSITION j r f f Instructions have been prepared by the responsible organizations to provide guidelines.for CNS and CGO record retention and disposition in accordance - .[ with this policy document and applicable regulatory criteria. As a' minimum, f - these~ procedures-cover.the'following: 1 -p ' t a)' Records content'and location;. - i .b)', Principal' location from which records are to be controlled;

I i
e c)' Complete records inventory and master index: d)' Conditions'of storage, access, and security;' j t e) System of records identification, retrieval, and control; ' l i f) System of records transfer and disposal. [ Quality Assurance records (reference 7.10)' will be entered into the controlled records system after they have been dedicated. This dedication occurs: 1 when the activity to the document becomes part of the operating condition of the plant. 4 6 Revision 6.. f + s + 4 9 4,,,- ,y.
\\ I ' v [
7.0 REFERENCES
The following documents were used in. the preparation ' of the Quality Assurance Program for Operation of the Cooper Nuclear Station. It is intended that these documents be used on a continuing basis in the performance of Quality Assurance activities.for station operation since they offer measurement criteria - against which the QA Program can be evaluated. 7.1-Quality Assurance Criteria for Nuclear Power Plants 10CFR50, Appendix B (USNRC). 7.2 Standard of Administrative Controls for Nuclear Power Plants. American National Standard ANSI 18.7 - 1972. 7.3 Updated Safety Analysis Report, Cooper Nuclear Station Nebraska Public - Power District (NRC Docket 50 298). 7.4 Environmental Report Operating License Stage, Cooper Nuclear Station, Nebraska Public Power District.(NRC Docket 50-298).
7. 5 Cooper Nuclear Station Procedures Manual, j
7.6 Safety Rules, Nebraska Public Power District. 77 Safety-Guides 'for - Water Cooled -Nuclear' Power Plants (USNRC), as appropriate. '1 ) J 7-1 Revision 6 I = = _. ,--aasm_mM->
l; y y :t , x_ p q. --l 1 ..]
7. 8-Quality: Assurancet Requirements for, : Nuclear' Power Plants ANSI l
. N45;2 '- 1977. j 7.9' Requirements for.' Collection,. Storage, and Maintenance of-Quality. 'M Assurance Records for Nuclear Power' Plants ANSI N45.2.9 - 1974. q L - 7.10 ' Quality Assurance Terms and. Definitions ANSI N45.2.10 -;1973. 17.11-Quality Assurance Requiremer.ts for the Design of Nuclear Power Plants-I . ANSI N45.2.11"-c1974. i - i -7.12 Requirements for Auditing of Quali. ty Assurance Programs for Nuclear Power - j Plants ANSI N45.2.12 1977. - 1
. }
7.13 Supplementary Quality Assurance ' Requirements for Control' of Procurement' [ t of Equipment, Materials, and Services for-~ Nuclear Power' Plants ANSI f N45.2.13 - 1976. - i ' { .7.14 CNS Radiological Technical Specifications. . h .t . I iL 9 . 4 l v n t J 7-2 Revision 6 ,4 4y poe t., .e-., $w 4,4an .+.e. .. <*, h h +d+6 -4
m b c 1 1 1 w d N Nebraska Public Power District l . I NUCLEAR POWER GROUP - QUALITY ASSURANCE DIVISION j QA QA Enginee (3). ' 1 Engineering - -- Supervisor Preeldent and - Vice Prealdent Chief Esecutive Production NI'* - Quellty Senior Stoff Assurano. ,,e,,e,,e, a Menager-G.O. i i Nuc!eer Power I I Group Meneger l Secretary ' QA supplier QA Engineer l Supervisor (3) 4 l Adminletrative i Secretary 11 t i i Diviolon Menege-Quellty Assurance Operatione
gg speci,iid OA
~ Supervisor . (4) 1 ' f Quality - Assurance Manager.CNS Quality FIGURE 1 e g,,i Coordinator
Reeponelble for QA Second Level Au n
+ Surveillenoes and Third Level QA Secretary. gg gp,,,,,;,, p .,n III Audits. - QA Supervisor i QA Engineer Direct Communications (*) l l M Rev.6 I s .o .*.-s ,+gy 4 e=
+%
+4me
en' a l'. O i: n. b oo TABLE 1-t t SYSTEMS AND MAJOR C0KPONENTS COVERED BY THE OUALITY ASSURANCE PROGRAM i I. NUCLEAR STEAM SUPPLY SYSTEM a A. Reactor Primary, Vessel 'B. ' Reactor. Primary Vessel Supports 4 f C.' Control Rods and Drive System Equipment Necessary for Scram Operation Control Rod Drive Housing. 'j D. E.. Fuel Assemblies 'F. Core Shroud' G. Steam Dryer. i H. Steam Separator [ r .II. REACTOR COOLANT SYSTEMS l A. - ADS -- Automatic Depressurization System { B. HPCI -' High Pressure Coolant Injection' System C. LPCI Low Pressure Coolant Injection System l r D. CS - Core. Spray System a E. RCIC - Reactor Core Isolation Cooling L -III. REACTOR PROTECTION AND ENGINEERED SAFEGUARD SYSTEMS A. Reactor Protection System B. Rod Sequence Control System C. Standby Liquid Control D. Standby Cas Treatment E. Diesel Generators F. Electrical Aux Power 1. . Critical 4160 V Equipment 2. Critical 480 V Equipment 9-1 Revision 6.- 1 ..= .. L : ,.....,~..%.,. s.%. 4.
' ~ [,'., - ~ ' g,, 1.. u. a ~~. '[i - .}t; l-; to - Table 1~ / Conti.) l d l k G.: Neutron Monitoring Systems .l i 1. - APRM 2. IRM- '3. . LPRM' .i p 4'. . RBM l S. SRM. 1 6. TIP i H. DC Power Supply-ei
1. _._
Nuclear System. Leak Detection 4 c
J.
. Containment Isolation System - K. Nuclear Boiler and'Related Instrumentation L. Primary. Containment - M. Rod Position Indicator- .i IV. NUCLEAR FUEL SYSTEMS-A. Refueling Interlocks for Fuel Handling and Vessel Servicing Equipment b B. Fuel Pool Liner and Gates C. Fuel Pool Cooling and Cleanup V. RADIOACTIVE WASTE DISPOSAL SYSTEMS 1 A. Process Radiation Monitoring System i 1. - Off-Gas Vent Pipe Radiation Monitoring-2. Off-Gas Monitoring ) 3. Aug Off-Gas Monitoring-d 4. Main Steam Line Monitoring 5. . Reactor Building Vent Monitoring (GE) 6. Drywell and Suppression System Leak Rate 7. Liquid Process Radiation Monitoring. -l 1 9-2 Revision'6: a i r ,._ _ [ a.4 b (;- um. 2_..
1 l. -Table 1 (Cont'd.) VI. OTHER SUPPORT SYSTEMS A.- Reactor Equipment Cooling B. Service Water C. Emergency Bypass Function on Control Room Heating, Vent, and AC D. Reactor Recirculating (Pressure Retaining Parts Only) E. Class I, II, and III Code items F. Reactor Feed Pumps (Pressure Retaining Parts Only)' G. Reactor Building H&V H. -Fire Protection I. Security VII. STRUCTURES (SEISMICS) A. Reactor Building B. Control Building C. Elevated Release Point D. Intake Structure E. Diesel Generator Building F. Radwaste Building (Below Grade)
Note -
1. This listing is not intended to be all inclusive. 2. Application of the QA Program to these systems and components shall be consistent with the safety related significance of the system or component. 9-3 Revision 6
Table 2 THREE LEVEL QUALITY ASSURANCE PROGRAM ~EKPLANATION.OF FIRST, SECOND, AND THIRD LEVEL QA RESPONSIBILITIES a) FIRST LEVEL-Work Performance assure that Quality Control and. and Ouality Control. inspection programs are being-implemented and that quality Each person performing work for requirements are in fact being. CNS is charged with the met. This includes first line. responsibility for verification that activities adherence to quality practices are properly performed and and procedures. An individual procedures are adequate for the other ' than. the one doing the activity they prescribe. ' work (not to include immediate supervisor) will have primary c) THIRD LEVEL-Ouality Assurance responsibility for . uality Audit. Q Control. Personnel at this level are charged with the Persons performing these audits responsibility for direct are not directly involved 'in inspection, witnessing, and the day-to-day Inspection or sign-off, attesting that work Quality
Control, functions.
l has been performed in Audits. and/or surveillances accordance with the quality will normally be performed by requirements of the controlling or under the direction:of the documents, appropriate QA Manager-or Supervisor. In addition,; SRAB ) b) SECOND LEVEL-Surveillance / shall-be responsible' for i
Audit, reviewing the results of audits and follow-up.
audita as Supervision and management described in Technical i personnel are responsible for Specifications. The Quality l providing workers and QC people Assurance Staff is also with the proper procedures and responsible.for the evaluation i guidance for performing quality of audit results and for work. These Managers and verifying that identified i Supervisors are then corrective action requirements responsible for second level have been implemented, surveillance / audit as appropriate for work involved. The' CNS Quality Assurance Manager and CGO QA Supervisor are responsible ' for assuring that controlling documents for safety-related activities include appropriate quality requirements. QA Staff is responsible for maintaining 1 surveillance and audits of the j work at CNS and the CGO to 9-4 Revision 6 4 g}}

ML20033H064

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ML20033H064

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