ML17227A714

Rev 24 to Topical QA Rept.

ML17227A714
Person / Time
Site:	Saint Lucie
Issue date:	01/11/1993
From:	FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML17227A713	List: ML17227A712 ML17227A714
References
NUDOCS 9302100181
Download: ML17227A714 (83)

Text

TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev24 Draft/R770D ORGANIZATION Date 1/11/93 CPL 1 of 24 The Florida Power & Light (FPL) organizational structure shall be defined such that the responsibilities for establishment and implementation of the Quality Assurance Program are clearly identified. 'Ihe authority and duties of individuals and organizations performing quality assurance and quality control functions shall be described, and shall illustrate the organizational independence and authority necessary to identify problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions. In addition, the description shall illustrate that persons or groups responsible for verifying the correct performance of an activity are independent of the person or groups responsible for performing the activity.

1.2 The FPL Chairman of the Board and Chief Executive Officer is ultimately responsible for the execution of the Quality Assurance Program for FPL nuclear power plants. The authority for developing and verifying execution of the program is delegated to the President Nuclear Division and the Vice President Nuclear Assurance. The reporting relationship of each department involved with the Quality Assurance Program is shown in Appendix A.

To provide for a review and evaluation of Quality Assurance Program policies and activities, the President Nuclear Division has established the Company Nuclear Review Board (CNRB). This organization's responsibilities are defined in Section 1.2.1.5.a.

In addition, a Quality Assurance Program Review Committee (QAPRC) has been established to review changes to the Quality Assurance Program and to provide an interface for quality matters in each department affecting quality. The QAPRC is an interdepartmental organization with the responsibility to review and resolve recommended changes to the Quality Assurance Program.

This committee is administered by the Quality Assurance Services group. Quality Assurance Program changes reviewed by the QAPRC are reviewed and signed by the department heads or individuals listed on each Quality Procedure.

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l C TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev.24 Draft/R770D ORGAMZATION Date 1/11/93 FPL 2 of 24 A Quality Assurance Program Review Committee (QAPRC) Member shall be designated by the head of each department or organization. The QAPRC Member is the prime interface for coordination of quality~elate4 matters within the member's department, with the Quality Assurance Department, and with other departments.

The head of each department or organization performing activities affecting qualityM@ed aeQvities is responsible for; a) identifying those activities within the organization which ae affect quality~&ed as defined by the Quality Assurance Program; b) establishing and clearly ff igqgi~:d defining the duties and responsibilities of personnel within his organization who execute those fpf ig,*i ig,dg personnel to meet the requirements of the Quality Assurance Program. The responsibility, authority, and organizational relationship for performing actvities affecting qualitymlated ae&Aties within each organization shall be established and delineated in organizational charts and written job or functional descriptions.

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The organization charts in Appendix A illustrate the lines of authority and ff areas of responsibility Below are listed the departments and organizations that have Quality Assurance responsibilities.

Specific organizational responsibilities for implementation of the Quality Assurance Program are described in the corresponding sections.

1.2.1 1.2.2 1.2.1.1 Plant Vice Presidents 1.2.2.1 Administrative Services Corporate Records Documentary Files 1.2.1.2 Nuclear Services 1.2.1.3 Nuclear Construction Services 1.2.2.2 Environmental Affairs 1.2.1.4 Nuclear Engineering 1.2.2.3 Protection &Control Systems and Licensing 1.2.2.4 Information Management 1.2.1.5 Nuclear Assurance 1.2.1.6 Nuclear Analysis and Controls

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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rcv.24 Draft/R770D ORGANIZATION Date 1/11/93 FPL 3 of 24 1.2.1 Throughout plant life, the Nuclear Division maintains control of and responsibility for nuclear power plant design, preoperational and start-up testing, operation, maintenance, refueling, and modification of the plant in accordance with written and approved procedures.

The President Nuclear Division has overall responsibility for the Nuclear Divisions's activities including corporate responsibility for overall plant nuclear safety. Reporting to the President Nuclear Division are: the Vice President - Turkey Point Plant, Vice Ptesident

- St. Lucie Plant, Vice President Nuclear Assurance, Vice Pn:sident Nuclear Engineering and Licensing, Director Nuclear Services, Director Nuclear Construction Services, and the Manager Nuclear Analysis and Controls.

1.2.1.1 Plant Vice Presidents

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The Vice President-St. Lucie Plant and Vice President-Turkey Point Plant are accountable for the operation, maintenance, and modification of their respective nuclear plant, as well as the selection, development and direction of the assigned staff. They will act as liaison between the plants and corporate headquarters, and are accountable for ensuring that company policies and procedures are properly implemented and continued at the nuclear site.

Reporting to the Plant Vice President - Turkey Point Plant are the Plant General Manager, the Services Manager, the Human Resources Manager, the Business Systems Manager and the Licensing Manager. Also, the Plant Vice President has functional responsibility over the Site Engineering Manager providing work direction to this group.

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Reporting to the Vice President - St. Lucie Plant are the Plant General Manager, the Services Manager, the Licensing Manager, and the Human Resources Manager. Also, the Plant Vice President has functional responsibility over the Site Engineering Manager, M M '8 M g*

• Sav@es Manager providing work direction to those groups.

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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev.24 Draft/R770D ORGANIZATION Date 1/11/93 FPL 4 of 24 The Plant General Manager - PSL and Plant General Manager - PTN, through the respective Plant Vice President, are responsible for the operation of the nuclear plant.

The Plant Nuclear Safety Committee (PNSC) at, Turkey Point Plant and the Facility Review Group (FRG) at the St. Lucie Plant are comprised of key plant management and staff personnel as described in the plant Technical Specifications. The PNSC/FRG serves the plant manager in a technical advisory capacity for the review of all safety-related procedures and activities that impact plant safety and the facility operating license.

1.2.1.2 Nuclear Services The Director Nuclear Services is accountable for technical staff, support to the Nuclear Plants and certain centralized special functions. Reporting to the Director Nuclear Services are the Manager Nuclear Training, Manager Nuclear Security, Manager Nuclear Health Physics/Chemistry and the Manager Nuclear Emergency Preparedness.

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a. The Manager Nuclear Training prepares policy documents regarding nuclear training and provides support to secure the necessary resources to ensure that Nuclear Division personnel are adequately trained. They must have adequate technical and job-related skills to provide safe and efficient operation while complying with NRC requirements.

b. The Manager Nuclear Security is responsible for coordinating the overall development and implementation of the FPL nuclear security program

c. The Manager Nuclear Health Physics/Chemistry provides technical support and assistance to the plants in the areas of health physics, chemistry, radioactive waste, and hazardous material control.

d. The Manager Nuclear Emergency Preparedness provides technical support and assistance to plant and corporate management for activities associated with radiological emergency plans and procedures.

TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev.24 Draft/R770D ORGANIZATION Date 1/11/93 FPL 5 of 24 1.2.1.3 Nuclear Construction Services The Diicctor - Nuclear Construction Services is responsible for directing and administering effective management of the department to ensure compliance to the corporate policies, practices and procedures; and providing qualified construction support personnel to the Site Construction Managers, Reporting to the Director - Nuclear Construction Services are the Manager Construction Control and the Site Construction Managers.

a. The Manager Construction Control is responsible for.

monitoring budget performance against planned engineering activities as budgeted by the Construction Services organization; I

0 monitoring the efficient utilization of resources expended against Construction Services budgeted activities and ensuring economic utilization of capital construction equipment at all Construction Services locations.

b. The Site Construction Manager is responsible for.

o completing the assigned project in compliance with technical and other project specifications, and for the application of the provisions of the Quality Assurance Manual during the project; o obtaining corrective action (along with Nuclear Materials Management) from contractor's management and, when necessary, exercising the authority to stop work on project activities adverse to quality.

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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev.24 Draft/R770D ORGANIZATION Date 1/11/93 FPL 6 of 24 Reporting to the Site Construction Manager are the Lead Construction Supervisors.

The Lead Construction Supervisor is responsible for conformance of project construction activities to the requirements of specifications, codes, regulations and site procedures. The Lead Construction Supervisor supervises the construction personnel assigned to the project, and coordinates construction activities, including the assignment of construction personnel.

The overall responsibility for Plant Changes and Modifications to operating plants is defined in each plant's Technical Specifications. The work of installation and administration of Plant Changes and Modifications can be assigned to Nuclear Construction Services. The Site Construction Manager will report to the Dmxtor-Nuclear Construction Services; however, the Vice President- PSL or Services Manager - PTN has functional responsibility over the Site Construction Manager by providing work direction.

~ L Project Team Members are appointed by their home department heads as the departmental representative on the respective project, when requested by the Site Construction Seabees Manager. Team Members, other than Quality Assurance, report functionally to the Site Construction Manager, but continue to receive administrative support and technical direction from their home department. Team members are responsible to the Site Construction Manager for home department support to the project.

Activities affecting quality may be performed by FPL or contracted. Should any of these functions be contracted, the contractor may perform the activities under his own Quality Assurance Program, which must have prior approval by FPL Quality Assurance, or the contractor may directly adopt the requirements of the FPL Quality Assurance Manual. If the contractor implements the Quality Control function directly to the FPL Quality Assurance Manual requirements, the contractor's Quality Control Supervisor shall have the authority and freedom to administer the Quality Control program.

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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev.24 Draft/R770D ORGANIZATION Date 1/11/93 7 of 24 Nuclear Engineering and Licensing The Vice President Nuclear Engineering and Licensing is responsible for nuclear plant design, materials management and maintaining the operating licenses.

Reporting to the Vice President Nuclear Engineering and Licensing are the Director-Nuclear Engineering, Manager - Turkey Point Engineering, Manager - St. Lucie Engineering, Director - Nuclear Licensing, Director - Nuclear Materials Management, Manager - Nuclear Information Services, Manager - Project Controls, and the Nuclear Records Official.

a. Nuclear Engineering Department The Nuclear Engineering Department includes personnel located at both nuclear sites and at the corporate office. Nuclear Engineering performs design-related

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activities and delegates design-related activities to qualified contractors. For activities performed by Nuclear Engineering, the work is governed by FPL's Quality Assurance Program, and Nuclear Engineering is responsible for approval of the design output. Delegated activities are performed in accordance with an FPL approved Quality Assurance Program and the contractor is responsible for approval of design output. Nuclear Engineering is responsible for defining the scope of delegated activities and the responsibilities of the contractor. Prior to the release of design outputs by contractor organizations, Nuclear Engineering ensures that the contractor is technically qualified to perform the design-related activity.

The Director - Nuclear Engineering, Manager - Turkey Point Engineering and the Manager - St. Lucie Engineering direct the engineering aspects of all FPL nuclear power plant projects during construction and operation to assure efficient, economical and reliable power plant design, conformance with engineering schedules and budgets and compliance with regulatory requirements. The Manager Turkey Point Engineering and Manager- St. Lucie Engineering are res onsible for on-site en ineerin su ort to the nuclear units. The Director-

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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev.24 Draft/R770D ORGANIZATION Date 1/11/93 FPL 8 of 24 Nuclear Engineering is responsible for engineering projects and support at the Corporate Nuclear Engineering Office. Project Managers are assigned to provide overall management and control of designated projects as required by the Vice President - Nuclear Engineering and Licensing.

The Nuclear Engineering Department is responsible for.

o power plant design-related aspects of the FPL Quality Assurance Program throughout all phases of plant life. This responsibility extends from initial engineering evaluations of plant design-related site characteristics, through preliminary and detailed design, construction, operation and decommissioning; o development and maintenance of the design control program governing design-related activities performed by Nuclear Engineering and for providing technical support to the Quality Assurance Department for assessing the adequacy, implementation and effectiveness of contractor design control programs; o the preparation, revision, approval and distribution of plant design accords that are identified to be maintained as "as constructed" drawings during plant operation; o the development, control, and performance of certain aspects of items and services procurement, including establishment of procurement standards, the technical evaluation, equivalency evaluation, and commercial grade dedication of replacement parts/components for nuclear plants. Zhirmhe o review of the technical and quality requirements'n procurement requisitioning documents and changes thereto for safety related and quality related items and services, as well as configuration control activities for controlled design documentation associated with procurement. The review shall be performed by individuals other than the document ori inator

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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev.24 Draft/R770D ORGANIZATION Date 1/11/93 9 of 24 forecasting FPL's nuclear fuel requirements and the availability of nuclear fuel; determining sources of supply, evaluating alternatives, and negotiating and establishing arrangements with suppliers for acquisition, processing and delivery of nuclear fuel and related services for the nuclear fuel cycle; assuring that technical and quality requirements (including inputs from other FPL departments) are incorporated in fuel contracts and letters of authorization, and that these documents have the necessary approvals; administering and managing contracts for nuclear fuel and related services to assure that technical and quality obligations are met, and serving as FPL liaison in all matters of nuclear fuel and fuel-related contracts; administering and managing spent fuel disposal contracts with Department of Energy and serving as FPL liaison in matters of nuclear fuel and high, level waste disposal; performing the project management function with respect to fuel management, design, licensing, delivery and other technical aspects of nuclear fuel; all fuel related design, analyses, reviews, and technical assistance necessary to ensure the safe, reliable, and economic operation of the nuclear plants; the optimization of nuclear fuel cycle economics within nuclear safety and operating constraints, as well as providing fuel related information, such as forecasts of nuclear fuel requirements to support licensing and regulatory requirements; the development and/or review of fuel and nuclear physics design; implementing and maintaining the FPL corporate nuclear material accountability program as outlined in the FPL Special Nuclear Material Control Manual; providing support to the Quality Assurance Department for their auditing of nuclear fuel design and fuel assembly manufacturing; performing audits and coordinating accountability reporting on all nuclear fuel;

TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rcv24 Draft/R770D ORGANIZATION Date 1/11/93 10 of 24 developing and providing, to appropriate FPL groups, information necessary to determine FPL's fuel-related costs and to finance fuel-related expenditures; providing technical support of activities associated with component reliability, materials evaluations, inspections, corrosion protection, non-destructive examination, and ASME Section XI implementation/pmblem resolution for nuclear plant components; providing specific component expertise, metallurgical support, and non-destructive examination and inspections; establishing the FPL Welding Program to meet the requirements of the Quality Assurance Program and applicable codes and standards; developing, maintaining, and controlling the FPL Welding Control Manual to implement the FPL Welding Program; originating and qualifying welding procedure specifications; and providing technical direction to personnel within the FPL Welding Program.

b. Nuclear Licensing Department The Nuclear Licensing Department is responsible for.

Nuclear Division corporate interface with the NRC; Nuclear Division corporate administrative point of contact with INPO; Managing NRC safety and regulatory issues and developing effective strategies to resolve them; Advising senior Nuclear Division management on a regular basis of important developments in licensing areas which could significantly affect the Nuclear Division; Providing Nuclear Division licensing hearing and legal services; Providing corporate licensing support and guidance to onsite licensing organizations; Administering the Nuclear Problem Reporting System; Administering the Commitment Tracking System; Administerin the eratin Ex rience and Feedback S stem.

TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev24 Draft/R770D ORGANIZATION Date 1/11/93 FPL 11 of 24

c. Nuclear Materials Management Department lhN g ',p" I hl 'IMg**h*p*

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" f (except nuclear fuel), purchase and control of materials, and the administrative N I D

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duties reqe4e4to support these activities 4ssetieris, Reporting to the Director

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Nuclear Materials Management (Turkey Point and St. Lucie).

1) Nuclear Contracts Nuclear Contracts is responsible for negotiation, generation, aegeQahea and issuance of contracts and purchase orders for required contracted services supporting the operation, licensing, maintenance, modification, and inspection of FPL nuclear plants, and for materials and equipment to support Nuclear Division staff.

The Site Managers of Nuclear Materials Management (Turkey Point and St. Lucie) are responsible for Nuclear Contracts activities performed at the respective sites. The Supervisors of Contracts (Juno Beach) are responsible for Nuclear Contracts activities performed at the Juno Beach Office.

Nuclear Contracts is also responsible for asi~Hiereviewing procurement documents to assure that technical and quality requirements developed by others are incorporated into the procurement documents which it authorizes and that these the requisitioning documents have the required approvals. Services for nuclear safety related applications are secured only from approved suppliers, or as commercial rade as a licable. Nuclear Contracts is res onsible for maintainin

TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev24 Draft/R770D ORGANIZATION Date 1/11/93 FPL 12 of 24 traceability of procurement document records until transmitted to an approved storage facility.

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2) Purchasing and Warehousing TI*W g I'hl 'IM g IT hy Point and St. Lucie) are responsible for the procurement and control of FPLN I Pl M 'I dMIP Purchasing is responsible for the procurement of materials and equipment by FPL for its nuclear power plants with the exception of @nuclear A'uel procurement. Materials and equipment for nuclear safety related application are secured only from approved suppliers, or as commercial grade, as applicable. Purchasing is responsible for asseaag reviewing procurement documents to assure that technical and quality requirements developed by authorizes, and that ~

others are incorporated into the procurement document which it the requisitioning documents have the required approvals. 4 Purchasing is responsible for maintaining traceability of procurement document records until transmitted to an approved storage facility.

Warehousing is responsible for the receipt, handling, storage, a~me' issue and shipping

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of materials and equipment Ihllly p material, parts and components for plant equipment@red~

hll I hl d Idy.p 'g operations, Warehousing also performs additional quality related activities such as receipt inspection of other than safety

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@PL 13 of 24 related materials and equipment and handling and segregation for nonconforming items received for material control.

d. Project Controls Department The Project Controls Department is responsible for.

Coordinating the establishment of scope baseline for the Nuclear Engineering, Nuclear Materials Management, and Nuclear Licensing Departments, Developing estimates for the scope, and annually establishing budgets for the work to be performed.

Monitoring cost and schedule performance.

Reforecasting costs and schedule based on performance history and emergent trends.

Providing management with corrective action recommendations, and implement same into revised scope, cost, and schedule baselines.

e. Nuclear Information Services Department The Nuclear Information Services Department is responsible for the identification, design, development, implementation, on-going maintenance, and control of all Nuclear Division data processing information systems excluding process applications.

This encompasses the following accountabilities:

direct the development, implementation, and on-going maintenance of information management systems; coordinate and direct the computer hardware and telecommunication planning and control within the Nuclear Division;

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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev24 Draft/R770D ORGANIZATION Date 1/11/93 FPL 14 of 24 ensure that the Nuclear Division's information management program is in full compliance with software quality assurance regulations and guidelines; administer and control system access; execute software production release and change control activities; administer physical databases and provide on-going technical support.

f. Nuclear Records Official The Nuclear Records Official is responsible for: ensuring the Quality Assurance records program activities are managed in accordance with applicable laws and regulations; developing, approving, and maintaining record retention schedules; establishing parameters for records indexing; locating acceptable record storage areas when requested; storage, retrieval and control of records/documents as requested by other departments; leading the evaluation of specially designated QARSET approved storage facilities, maintaining the records of this evaluation, and establishing schedules to assure that re-evaluations are performed every two (2) years.

1.2.1.5 Nuclear Assurance Department The Vice President Nuclear Assurance is responsible for the selection, technical dimction, administrative control (e.g. performance appraisal, salary review, hire/fire, position assignment) staffing, training and development of personnel required for supervisory and operating continuity of the Quality Assurance Department, Nuclear Safety Speakout Group and Company Nuclear Review Board (CNRB) administrative support. 'Ihe Vice President Nuclear Assurance also initiates QA Program policy changes when necessary. In addition, the Vice President Nuclear Assurance is responsible for selecting a team independent of the Quality Assurance Department to perform periodic audits of the Quality Assurance Department. The results of these audits are presented to the Vice President, Nuclear Assurance and the CNRB. Reporting to the Vice President Nuclear Assurance an:

the Manager Nuclear Safety Speakout, the Site Quality Manager - Turkey Point, the Site Quality Manager - St. Lucie, the Quality Manager - Juno Beach, and for administrative support, the CNRB Chairman.

TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev24 Draft/R770D ORGANIZATION Date 1/11/93 APL 15 of 24

a. Company Nuclear Review Board+XR+

The NRBg reporting to the President Nuclear Division, is comprised of executive level members of management with responsibilities for the execution of the Quality Assurance Program, The CNRB reviews, or directs the performance of reviews of, activities concerning the technical aspects of the operating nuclear power plant insofar as they impact ea plant safety, the health and safety of the public, and laws, regulations and licensing commitments.

In addition, audits of these areas are performed under the cognizance of the CNRB.

The CNRB composition is described in Section 6.0 of each facility's Technical Specifications and in its current policy. Subjects within the purview of the CNRB are listed in the appropriate plant Technical Specifications. The CNRB has the authority to carry out its responsibilities by way of written action letters, verbal directions, meeting minutes or appointed subcommittees. Where necessary, the CNRB may use consulting services to perform required reviews.

1 The CNRB is responsible for reviewing and evaluating Quality Assurance Program policies and activities, Quality Assurance Program status reports shall be periodically prepared by the Quality Assurance Department and routed to the members of the CNRB for review.

CNRB meetings shall be held by the Chairman to keep members apprised of conditions including significant problems that require management attention.

Periodic audits of the Quality Assurance Department shall be performed by a team independent of the Quality Assurance Department. The results of this audit are presented to the Vice President Nuclear Assurance and the CNRB.

The Chairmen of the Independent Safety Engineering Groups, at Turkey Point and St. Lucie, report to the Chairman of the CNRB.

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TOPICAL QUALITYASSURANCE REPORT TQR 1.0, Rev.24 Draft/R770D ORGANIZATION Date 1/11/93 FPL 16 of M

b. Quality Assurance Department The Quality Assurance Department shall be responsible for administering the FPL Quality Assurance Program. This includes developing and verifying implementation of corporate policies, plans, requirements, and ptocedures affecting quality. This is accomplished through the Quality Assurance Department. The Quality Assurance Department retains responsibility for delegated portions of the Quality Assurance Program by performing initial evaluation and subsequent periodic audits of the contractors'uality Assurance Programs. The Quality Assurance Program responsibility further extends to the performance of audits within the Company to assure management that the established requirements and procedures are being implemented, and that the Program complies with the baseline document requirements.

The organizational freedom of the Quality Assurance function is accomplished through the corporate structure, illustrated in Appendix A, which provides independence from those departments responsible for design, procurement, engineering, construction and operation. With quality assurance as its sole function the Quality Assurance Department, both on-site and off-site, is completely free from the cost and scheduling pressures of design, proem@ment, construction and operation. The Quality Assurance Department has the freedom and authority to: a) identify quality problems; b) initiate, recommend or provide corrective action; c) verify implementation of the corrective action; and d) recommend the stoppage of work or operations adverse to quality, when necessary. The Quality Manager - Juno Beach, the Site Quality Manager - St.

Lucie and the Site Quality Manager - Turkey Point report administratively 'and functionally to the Vice President Nuclear Assurance. These reporting relationships assure that the Quality Assurance Department has direct access to the levels of management necessary to assure effective implementation of the Quality Assurance Program, The duties, responsibilities, and authorities of each Quality Assurance group are described in the sections which follow.

TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev.24 Draft/R770D ORGANIZATION Date 1/11/93 17 of 24

1) Quality Assurance Services Group The Quality Manager - Juno Beach directs and administers the Corporate Quality Assurance Program assuring compliance with the baseline documents listed in Appendix C of this Topical Quality Assurance Report.

Quality Assurance Services Group activities include the following:

o develop and maintain the Quality Assurance Department Quality Instructions and the corporate Quality Assurance Manual, including the administration of the Quality Assurance Program Review Committee (QAPRC) o assist other departments in the development of Quality Instructions by review and comment and through interpretation of corporate Quality Assurance requirements; o develop and implement a Quality Assurance indoctrination program for FPL personnel, and a training program for the"Quality Assurance Department; o prepare reports on Quality Assurance Program activities for review by the (CNRB);

o maintain a file system for documentation of quality assurance activities perfoITIled; o review Regulatory Guides, Codes, SAR Document Commitments and Standards for impact on the Quality Assurance Program and recommend appropriate program changes; o review documents submitted to the

+NRBP as requested by the Nuclear Assurance Department CNRB member, o plan, coordinate and implement a comprehensive system of periodic internal audits with support from the other Quality Assurance groups, when necessary; o review FPL originated design specifications for inclusion of appropriate quality requirements.

TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev24 Draft/R770D ORGAMZATION Date 1/11/93 FPL 18 of 24 o perform periodic activity audits of FPL procurement and associated documents and changes to these documents to assure that the necessary quality requirements are imposed.

o assist in the development and implementation of policies, plans, requirements and procedures for the requisition and purchase of materials, equipment and services related to nuclear power plants and to the acceptance and storage of equipment and material; o perform appropriate surveillance of hardware during manufacture; o develop and implement a program for auditing of supplier Quality Assurance/Quality Control programs including Architect Engineer/Nuclear Steam Supply System Suppliers; o assure design-related activities performed by the Architect Engineer meet the quality aspects of the contract; Qapesed-;

o assist other FPL departments in the identification of quality problems associated with procurement and storage; initiate, recommend, or provide solution; and verify implementation of solutions; o review, approve and periodically audit the execution of FPL contractor quality assurance programs; o assures that the contractors'rganizations performing Quality Assurance functions have sufficient authority and organizational freedom to implement effective Quality Assurance programs; o evaluate the Quality Assurance capability of suppliers requested by the Nuclear Materials Management Department and maintain the Quality Assurance Department "Approved Suppliers List";

o provide NDE Level III services including technical direction and monitoring of NDE activities performed by Quality Control at the plant sites (PTN and PSL); preparation, revision and implementation of NDE procedures; training, testing and qualification of NDE personnel, and rovidin the ro s and direction for NDE activities meetin

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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev24 Draft/R770D ORGANIZATION Date 1/11/93 19 of 24 the ASME, AWS and other NDE code tcquirements.

For purchased items and services, the responsibility of this group begias extends though nceipt of shipment or performance of contract.

2) Site Quality Assurance Groups - Turkey Point Nuclear (PTN) and St.

Lucie (PSL)

Quality Assurance activities at the plant sites (PTN and PSL) are accomplished by the respective site Quality Assurance Groups, reporting to the Site Quality Manager. The Site Quality Manager has responsibility for on-site development and implementation of the Quality Assurance Program, including the following; o coordinate the development and implementation of policies, plans,

~ ~ I requirements, and procedures for portions of the'uality assurance program related to the operation and modification of nuclear power plants at the plant site; o perform audits, assessments and other observations as specified in procedures and instructions to verify compliance with Quality Assurance Program commitments, identify quality problems and ensure timely corrective actions are taken in the areas of plant operation, system turnover, modification and maintenance; including such areas as refueling, inservice inspection and testing, procurement of spare/replacement parts, material storage, health physics, chemistry, plant security and fire protection; o perform periodic activity audits of site generated FPL procurement and associated documents and changes to these documents to assure that the necessary quality requirements are imposed;

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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev24 Draft/R770D ORGANIZATION Date 1/11/93 20 of 24 o identify requirements, ensure inclusion of commitments in documents and verify implementation of the Quality Assurance Program during construction activities at the plant site through audits of FPL and contractor organizations; o recommend stoppage of work or operations adverse to quality at the plant site in accordance with the appropriate Quality Procedures; o review and comment on Quality Instructions or equivalent quality-

~&e4 administrative procedures prior to issue, with respect to the requirements of the FPL Quality Assurance Program, the applicable Final Safety Analysis Report, and the applicable Technical Specifications; o assure that the status is tracked for all open items identified by the Site Quality Assurance group, and inform appropriate management when there is an indication that a commitment willnot be met on time; o maintain a file system for documentation of quality assurance activities performed by the Site Quality Assurance group; o review backfit procedures with respect to the FPL Quality Assurance Program (for procedure review requirements see TQR 5.0);

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o perform audits of the architect engineer and Nuclear Steam Supply System suppliers both on-site and off-site, in conjunction with the Quality Assurance Services group.

The interface with the Quality Assurance Services group ends with the receipt of a shipment of nuclear safety-related equipment at the plant site.

The Quality Assurance program for the shipment is then within the purview of the Site Quality Assurance group.

The Quality Manager - Turkey Point and Quality Manager - St. Lucie are additionally responsible for the establishment and implementation of ualit control as ects of the uali Assurance Pro at the lant site.

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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev24 Draft/R770D ORGANIZATION Date 1/11/93 21 of 24 Reporting directly to the Site Quality Manager are the Quality Control Supervisors who have the authority and freedom to administer the Quality Control program and, when necessary, to stop activities adverse to quality.

The Quality Control Supervisors and personnel performing Quality Control inspection functions are required to be independent of groups or persons performing activities that they may be required to verify or inspect. Quality d~i Control efforts include preparation and review of plant procedures, PCMs, yy id'y g gg Igy;Q Control personnel are also responsible for inspection, monitoring,

~y surveillance, and review of plant activities to verify compliance with the provision of the facility operating license and the Quality Assurance Manual. Inspections are also performed to assure that backfit activities meet the requirements of engineering drawings, specifications, codes and standards. This responsibility extends from receipt inspections of material on-site to acceptance of the installed items prior to turnover to the Plant. It also includes verification of conformance of an item or activity accomplished during this period to quality requirements (e.g., records review, NDE, inspections). The Quality Control Supervisors shall take corrective action for deficiencies identified, where applicable, and shall follow up on corrective action taken by other organizations until close out.

Off-site interfaces for the resolution of quality~ted. problems and NRC items are with Nuclear Corporate Staff, FPL support departments as indicated in this Topical Quality Assurance Report, the architect engineer and the Nuclear Steam Supply System (NSSS) Quality Assurance Department. The Site Quality Assurance group interfaces with the Plant Vice President and his staff on-site by assisting in the resolution of quality-rehh4 problems.

c. Nuclear Safety Speakout The Manager Nuclear Safety Speakout has responsibility for the management and implementation of the Nuclear Safety Speakout Program. Speakout rovides a forum for em lo ees and contractors to communicate their concerns

TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev.24 Draft/R770D ORGANIZATION Date 1/11/93 FPL 22 of 24 to FPL. Concerns are documented, investigated and co@ective actions are taken when necessary. The program offers confidentiality. Reporting to the Manager Nuclear Safety Speakout are the Turkey Point and St. Lucie Speakout Supervisors.

1.2.1.6 Nuclear Analysis and Controls The Manager Nuclear Analysis and Consols, reporting to the President Nuclear Division, is responsible for coordinating the budget, rate, and cost control support to the plants and staff organizations; and coordinating Division business planning, target setting and monitoring of key performance indicators, and operations analysis activities.

1.2.2 Providing support activities for the Nuclear Division are Administrative Services, Environmental Affairs, Protection & Control Systems, and Information Management. The reporting relationship of each department is described in the following sections and is shown in Appendix A.

1.2.2.1 Administrative Services Reporting to the Manager Administrative Services are the Supervisor Corporate Records Services and the Supervisor Documentary Files.

a. Corporate Records Services The Supervisor Corporate Records Services is responsible for: storage, retrieval and control of Quality Assurance records received from other departments; assisting with the development and implementation of records and micrographics programs; maintaining a QARSET approved storage facility.

TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev24 Draft/R770D ORGANIZATION Date 1/11/93 FPL 23 of 24

b. Documentary Files The Supervisor Documentary Files is responsible for receiving, maintaining, retrieving and storing the Quality Assurance records in connection with licenses and contracts received from other departments.

1.2.2.2 Environmental Affairs Environmental Affairs is responsible for obtaining the federal and state envhonmental permits required for FPL facilities and operations. Environmental Affairs is responsible for overall coordination of non-radiological environmental monitoring (federal and state) programs at the nuclear power plant sites.

The Manager Hazardous Substances Regulation, the Manager New Construction Licensing and Planning, the Manager Air and Water Permitting and Programs, the Chief Ecologist, and the Environmental Toxicologist report to the Director Environmental Affairs. The Plant Vice President has over'all responsibility for implementation of the Envnonmental Protection Plans at nuclear power plant sites.

The Environmental Affairs Department through its management of the Company Environmental Review Group (CERG) is responsible for overall coordination of non-radiological environmental monitoring programs and oversight of other requirements related to the Environmental Protection Plans. The CERG provides review of proposed changes to the Environmental Protection Plans, review of any violations of monitoring and/or limitation requirements of federal and state permits and Environmental Protection Plans and review of plant activities as described in those Environmental Affairs Department Environmental Procedures subject to QA requirements.

The CERG provides information to the Director Environmental Affairs and the CNRB Chairman on envitonmental matters for which requirements are included in Environmental Protection Plans.

TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev.24 Draft/R770D ORGANIZATION Date 1/11/93 FPL 24 of 24 1.2.2.3 Protection & Control Systems Protection & Control Systems is responsible for test, calibration and maintenance of certain high voltage electrical protective relays for safety-related systems of the nuclear plant.

Activities of Protection & Control Systems include final wiring connection checks, preoperational check-out and test of system protection devices and providing inspection of equipment under their cognizance. Additional responsibilities include providing certain setpoint and checkpoint values for protective devices.

The Director of Protection & Control Systems reports to the Vice President of Power Delivery.

1.2.2.4 Information Management Information Management consists of Computer Operations Services, Client Services, and Quality Management reporting to the Vice President of Information Management.

The Computer Operations Services Department is responsible for the installation and maintenance of the operating system software and the operation of the computer hardware for FPL's corporate computer systems. The application programs used by the nuclear departments executes on these corporate computers.

The Manager Computer Center, the Manager Operations Support Services, and the Manager Technical Systems report to the Director Computer Operations Services.

Client Services is responsible for software libraries on FPL's in-house time-sharing Computer System (CMS) that are under its control.

Quality Management provides support to the Nuclear Division in their development and maintenance of computer applications in the area of software library controls.

OPICAL QUALITYASSURANCE REPORT T R40 6 Draft GJR772 PROCUREMENT DOCUMENT 772 CONTROL Page of 4el Procurement of items and services shall be performed in accordance with procedures which assure that applicable regulatory requirements, design bases, code requirements, and other requirements necessary to assure quality shall be included or invoked by reference in the procurement document. These procedures shall delineate the sequence of actions to be accomplished in the preparation, review, approval, and control of procurement documents.

Changes to procurement documents shall be subjected to the same degree of control as utilized in the preparation of the original documents.

4e2 P F 4.2.1 Procurement Document Provisions Quality Procedures and Quality Instructions shall identify the responsibilities and actions required of the organizations originating, rev'teviiPg, approving,utnd controlling procurement documents. These procedures shall require the procurement documents to specify:

a. The scope of work to be performed.

b. Technical requirements (by specifying or referencing) which shall include the applicable components and materials identification requirements, drawings, specifications, procedures, instructions, codes, and regulations and provide for identification of applicable test, inspection and acceptance requirements, or special process instructions,

c. Quality Assurance Program requirements to be imposed on contractors which shall include the applicable portions of 10 CFR 50, Appendix B.

d. Right of access which provides, as appropriate, for access to contractor facilities and records for inspection or audit by FPL or its designated representative, and to access for events such as witness and hold points.

OPICAL QUALITYASSURANCE REPORT T R 4.0 Rev.

Date PROCUREMENT DOCUMENT CONTROL Page 2 "3 4.2.1 (Continued)

e. The documentation required to be prepared, maintained, and/or submitted to FPL or its representative for review, approval, or historical record. The time of submittal of this documentation and the retention and disposition of qQuality aAssurance rRecords which willnot be delivered to FPL shall be prescribed.

Consideration shall be given to the need for special requirements in the preparation and review of procurement documents. Procedures and instructions shall be prepared and implemented for special on-site handling or storage requirements. The receiving department shall be responsible for on-site implementation of the special handling, shipping, and storage requirements for items received and controlled by their organization.

Special handling, preservation, storage, cleaning, packaging, and shipping requirements shall be specified, as appropriate, in the design documents or purchase orders. The requirements established in the design documents or purchase orders shall be consistent with industry accepted standards, the importance of equipment or material to nuclear safety, and the material or equipment's sensitivity to damage. The preparation of these design documents or purchase orders may be delegated by FPL to other organizations.

4.2.2 Procurement Document Review Procurement documents shall be reviewed for correctness, and inspectability and controllability of quality requirements in accordance with Quality Procedures and Quality Instructions to assure that the appropriate provisions of Section 4.2.1 are included. This review shall be documented and performed by designated personnel who have been trained and qualified in quality assurance practices and concepts. These reviewers shall have access to pertinent information and have an adequate understanding of the quality and hi I qi di f h p td

OPICAL QUALITYASSURANCE REPORT Rev.

Date PROCUREMENT DOCUMENT CONTROL Page of 4.2.2 (Continued)

Spare or replacement parts for safety related structures, systems, and components are subject to technical or quality requirements equivalent to, or better than, those used for the original equipment.

Changes to procurement documents, whether initiated by FPL or their representative, are subjected to the same degree of control as that utilized in the preparation of the original document.

4.2.3 Selection of Procurement Sources The Nuclear Materials Management Department shall verify that the procurement document has been reviewed and approved, and that the supplier has been approved prior to issuing the purchase order for safety related materials or services. Supplier approval is not necessary ifthe important characteristics of the item can be verified by inspection or test.

The overall procurement requirements, including those related to planning, bid evaluation, and review and concurrence of suppliers Quality Assurance programs, are described in Quality Procedures and Quality Instructions.

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TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev. 11 Draft B/R773 BASELINE DOCUMENT MATRIX FPL 6 of 23 In order to avoid duplication of requirements invoked in our licensing documents, the FPL Quality Assurance Program does not list those required operating procedures specified in Appendix A.

Re lato Guide 1. 7 ANSI N4,2,1-1 73 ANSI N45.2.1-1973, Paragraph 5 states in part that, "Fitted and tackwelded joints (which will not be immediately sealed by welding) shall be wrapped with polyethylene or other non-halogenated plastic film until the welds can be completed". The FPL QA Manual shall require that the weld be covered to prevent entry of moisture and contaminants but will not specify the material to be employed. Materials employed to cover openings shall meet the requirements of Regulatory Guide 1.37, Position 4.

ANSI N45.2.1-1973, Paragraph 7.1 states in part, "provisions shall be made to collect leakage and protect insulation from being wetted". FPL Quality Assurance Program includes the above requirements..However, FPL's program. allows the wetting of metallic type insulations which are not adversely affected by wetting.

ANSI N45.2.1-1973, Paragraphs 7.2.2, 7.2.3, and 7.3 address specific cleaning methods (Alkaline, Chelate, Acid) and make recommendations associated with several types of cleaning methods. FPL's QA manual does not specifically delineate these paragraphs. However, the procedure developed per Paragraph 2.2 of ANSI N45.2.1 will ensure that any specific cleaning method chosen willbe properly considered and controlled.

Re ulato Guide l. 8 Rev.2AN IN4,2.2-1 2 FPL will meet the requirements of Reg. Guide 1.38, Rev. 2, Position 2C, D and E for safety related applications during preoperational and operational activities. Restrictions imposed for tapes to be color contrasting will only be applied to the extent that these colors are dissimilar or otherwise distinguishable. This does not preclude using other tapes when precautions are taken to ensure these tapes do not come in contact with austenitic stainless steel or nickel alloy materials.

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev. 11 Draft B/R773 BASELINE DOCUMENT MATRIX Date 6/24/92 FPL 7 of 23 Vapor barrier material (other than metal) shall be colored to contrast with or be otherwise distinguishable fiom safety related systems to prevent undisclosed entry into the system.

These requirements do not apply to components in storage which would require removal of such tapes and barriers to effect installation.

ANSI N45.2.2-1972 Section 2.7 requires that items governed by this standard be classified into one of four levels by the buyer or the contractor. FPL intends to consider what care is appropriate for each item individually rather than generically classifying the material into protection levels and providing care required of that level. The following shall be considered when determining the handling, storage, and shipping requirements;

1. The vendor's recommended handling, shipping, and storage standards,

2. Environmental requirements which may include such requirements as inert gas atmosphere, humidity. limits, temperature limits, chemical requirements, acceleration (g force) requirements.

3. Special tools or equipment which are provided and controlled as necessary to ensure safe and adequate handling. These tools or equipment shall be inspected and tested at specified times to verify that they am adequately maintained.

4. Packaging, covering or coatings required to meet environmental requirements such as barrier and wrap material, desiccants, pipe caps, plugs, contact preservatives, etc.

5. Container, crating, skids of sufficient strength to support the item (including stacking).

6. Cushioning, blocking, bracing, and anchoring to prevent movement during shipment or handling.

7. Special handling or storage procedures for unique situations.

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev. 11 Draft B/R773 BASELINE DOCUMENT MATRIX FPL 8 of 23

8. Marking and identification of the item and its packaging.

9. Anticipated "shelf life" of the item.

FPL considers this to be a more effective approach since the quantity of spare and replacement material, parts and components governed by this standard will be afforded protection commensurate with the recommendations of Section 2.7 of this standard.

ANSI N45.2.2-1972 Sections 3.0, 4.0, and the Appendix address all the requirements applicable to the packaging and shipping of material. FPL in general does not package or ship material governed by this standard. Suppliers of material are required by purchase order to provide adequate packaging and shipping protection. Isolated cases of material packaging or shipping are treated on a case-by-case basis and receive protection comparable to that required by the manufacturer of that material. Loading, rigging and handling precautions identified in Section 4.3 are applied to material unloaded by FPL from a transport vehicle.

ANSI N45.2.2-1972 Section 5.2 requires that specific attributes of material and components received by FPL be inspected. For plants with operating licenses FPL verifies conformance to procurement documents during receipt inspections. Any of these attributes identified in these procurement documents are verified during this inspection.

ANSI N45.2,2-1972 Section 5.2, paragraph 5.2.1, requires certain preliminary inspections to be done "prior to unloading" of material which is received. We believe that the sequence specified in the standard is to facilitate commercial claims, and should these preliminary inspections occur "after unloading" that control of materials quality would not be degraded. Accordingly, required shipping damage inspections may be performed after unloading.

The requirements of ANSI N45.2.2, Paragraph 7.2 for items that require special handling instructions is clarified by FPL to be limited to those items covered in the scope of NUREG 0612, entitled "Control of Heavy Loads at Nuclear Power Plants".

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@PL 9 of 23 ANSI N45.2.2-1972, Paragraph 7.4 requires that an inspection program be established for handling equipment and rigging, including methods for identifying acceptable and nonconforming items. In lieu of having a program of periodic, documented inspections of rigging and handling equipment, FPL's practice is to have the individual user determine the equipment's acceptability prior to each use. This prior-to-use inspection is exactly the same as that required during periodic inspections, and uses criteria identified in ANSI N45.2.2-1972, paragraph 7.4. This practice also precludes the need for a system to indicate the acceptability of rigging and handling equipment. Implementation of this prior-to-use inspection will be assured through periodic surveillances and audits performed by Quality Assurance and Quality Control.

Cranes are inspected on a periodic basis and will not be subjected to this prior-to-use inspection.

Certain mechanical components of the PSL-2 nuclear unit have been designed for a service environment of the site area because portions of the plant are exposed to the temperature, humidity, and ocean salt spray during operations. Extreme air temperature variations, snow or slush are not encountered during operations or in the out-of-doors storage environment. As an alternative to the. rigid requirements of storage levels B and C in paragraph 6.1 of ANSI N45.2.2-1972, FPL proposes to store these particular mechanical components outdoors, but within controlled areas, with sufficient periodic surveillances and inspections to minimize the possibility of damage or lowering of quality due to corrosion, contamination, deterioration, or physical damage. In cases where special environmental conditions an: present (i.e., hurricanes, paint sprays, concrete pours, etc.) precautions or additional steps willbe taken to further protect the items.

Re ulato uide 1.39 Rev. 2 ANSI N4,2. -1 7 For FPL's operating nuclear plants, alternative methods are followed to achieve equivalent objectives for the below listed sections of ANSI N45.2.3-1973:

The zone designations of Section 2.1 of N45.2.3 and the requirements associated with each zone are not consistent with the FPL Housekeeping requirements at our operating nuclear units.

In lieu of the zone d'esignation, cleanliness is maintained at a level consistent with the work being performed, so as to prevent the entry of foreign material into safety related systems. Documented cleanliness inspections are performed immediately prior to system closure, Control of personnel,

I TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev. 11 Draft B/R773 BASELINE DOCUMENT MATRIX Date 6/24/92 FPL 10 of 23 tools, equipment, and supplies is established with approved procedures when the safety function of a system, component, or item may be jeopardized and also while the reactor system is opened for inspection, maintenance, or repair.

Re lato uide 1. Revision 1 ANSI N45.2. 1 ANSI N45.2.6-1978, Paragraphs 1.1, 3.1, 3.2.2(a) and 4 (Table-1) identify requirements which apply to personnel who perform inspections, tests or nondestructive examinations or who participate in the approval of procedures, the handling of data or test results, or the control of reports and records.

FPL proposes an alternative to capability requirements for those who participate in: (1) the approval of procedures, (2) the handling of data or test results and (3) the control of reports and records. FPL accomplishes this by having personnel determined to be qualified and competent by management through consideration of education, training, and experience.

The Florida Power & Light Company position on the scope of ANSI N45.2.6-1978 is that personnel participating in testing who take data or make observations, where special training is not required to perform this function, need not be qualified in accordance with ANSI N45.2,6 but need only be trained to the extent necessary to perform the assigned function.

For leak testing conducted as part of the preoperational and operational testing programs, FPL considers that the qualification requirements of Regulatory Guide 1.8 (ANSI N18.1-1971) and ANSI N45.2.6-1978, Paragraph 3.0 to be an acceptable alternative to SNT-TC-1A-1975 requirements for leak testing, except for leak testing defined in and performed under Section III of the ASME Code, where in such cases, the Code shall govern.

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev. 11 Draft B/R773 BASELINE DOCUMENT MATRIX APL 11 of 23 For preoperational and operational inspection, examination and testing by Quality Control Inspectors, FPL considers that Position C.1 of Regulatory Guide 1.58, Revision 1 and ANSI N45.2,6-1978, Paragraph 3.0 are acceptable requirements for training and qualification, except for inspections, tests and examinations defined in and performed under Section IIIof the ASME Code, where in such cases, the Code shall govern.

For all other preoperational and operational inspection, examination and testing performed by operating plant and support personnel, FPL considers that training and qualification to the requirement of ANSI N18.1-1971 and Regulatoty Guide 1.8 are sufficient for the type and scope of activities performed and that qualifications to ANSI N45.2.6-1978 is unnecessary and redundant. These preoperational and operational inspections, examinations and tests shall be supervised or directed by personnel qualified to Position C.1 of Regulatory Guide 1.58, Revision 1.

FPL shall comply with Position C.10 of Regulatory Guide 1.58, Revision 1, effective with Revision 4 of the. Topical Quality Assurance Report, in that all new certifications issued for personnel shall meet the education and experience requirements or shall document objective evidence demonstrating that the individual indeed does have comparable or equivalent competence to that which would be gained from having the required education and experience.

FPL's position on ANSI N45.2.6-1978, Paragraph 2.3 is that an initial and periodic review (not to exceed two years) of personnel shall deteimine the capabilities in his qualified area. If during this review, or at any other time, it is determined that the individuals capabilities are not in accordance with the specified requirements, that individual shall be removed from that activity until the required capability has been demonstrated. In addition, during this review a determination shall be made that an individual has been actively involved in the inspection process in his qualified area.

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev. 11 Draft B/R773 BASELINE DOCUMENT MATRIX Date 6/24/92 FPL 12 of 23 Re 1 i 1 Rev 2 ANSI N4 2.11-1 4 FPL's exception to Regulatory Guide position C.2 is as follows:

Design verification shall be performed by technically qualified individual(s) or group(s) other than those who performed the design. The original designers and verifiers may both be fmm the design organization. Design verification by the designer's immediate supervisor shall be limited to those instances where when the supervisor is the only qualified individual available within the dig gi i .ll *i **hh'%dig where the supervisor did not specify a singular design approach, or did not restrict design methods or alternatives, or did not specify design inputs (unless the specified design inputs have already been independently verified). Justification for verification by the designer's immediate supervisor should be documented along with the extent of the supervisor's involvement in the design.

ANSI N45,2.11-,1974, Paragraph 11,4 requires that "audits shall include an evaluation of design quality assurance policies, practices, procedures and instructions...." FPL's design quality assurance (and all other QA elements) policies, procedures and instructions are included in FPL's Quality Assurance Program documentation. The Quality Assurance Department evaluates all of this documentation in reviews performed during its development and revision. Accordingly, FPL does not require subsequent (and redundant) evaluations of these Quality Assurance Program policies, procedures and instructions during audits. FPL audits willinclude evaluations of the adequacy of the practices which are the implementation of these policies, procedures and instructions.

Re ulato Guide 1.6 11 Regulatoiy Guide 1.68 (11/73) entitled "Preoperational and Initial Start-up Test Programs for Water Cooled Power Reactors" is addressed in Section 14.2.1 of the St. Lucie Unit 2 FSAR which states in part, "The start-up test program is developed using the recommendations of Regulatory Guide 1.68". To avoid duplication of requirements, FPL will address Regulatory Guide 1.68 in the FSAR.

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev. 11 Draft B/R773 BASELINE DOCUMENT MATRIX Date 6/24/92 FPL 13 of 23 R lt i 1. 4 AN IN4 2.1 -1 ANSI N45.2.10 - 1973 identifies terms and their definitions important to the uniform understanding of the intent of required quality assurance practices for the construction of nuclear power plants. Regulatory Guide 1.74 (2-74) endorses these terms and definitions and extends them through the operational phase and includes a clarification of procurement documents.

FPL has developed a glossary of terms and their definitions as part of the Quality Assurance Manual which is being used throughout its nuclear construction and operating plant activities.

The following definitions are currently listed in our glossary and are alternatives or clarifications to those listed in the ANSI Standard and Regulatory Guide:

Assembly A combination of subassemblies or components or both, fitted together to form a workable unit.

Audit A documented activity performed in accordance with written procedures or checklists to verify, by examination and evaluation of objective evidence, that applicable elements of the quality assurance program have been developed, documented and effectively implemented in accordance with specified requirements. An audit does not include surveillance or inspection for the purpose of process contxol or product acceptance.

Guidelines Particular provisions which are considered good practice but which are not mandatory in programs intended to comply with Standards.

The term "should" denotes a guideline; the term "shall" denotes a requirement; and the word "may" denotes permission, neither a requirement nor a recommendation.

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TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev. 11 Draft B/R773 BASELINE DOCVMENT MATRIX Date 6/24/92 FPL 14 of 23 Inspector (Owner's or Installer's) A qualified inspector employed by the Owner or Installer, whose duties include the verification of quality related activities on installations.

Inspection Examination, observation, or measurement to determine the conformance of materials, supplies, components, parts, appurtenances, systems, processes, or structures to predetermined requirements.

Procurement Documents Contractually binding documents, including such documents as contracts, letters of intent, work orders, purchase orders or proposals and their acceptances which authorize the seller to perform services or supply equipment, material, or facilities on behalf of the purchaser, For control purposes, procurement requisitions are considered procurement documents in the context of this definition, Qualification (Personnel) The characteristics or abilities gained through training or experience or both as measured against established requirements such as standards or tests that qualify an individual to perform a required function.

Quality Assurance All those planned and systematic actions necessary to provide adequate confidence that a structure, system or component will perform satisfactorily in service. Quality Assurance includes quality control.

Quality Control Those quality assurance actions related to the physical characteristics or material, structure, component or system, which provide a means to conti the quality of the material, structure, component or system to predetermined requirements.

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev. 11 Draft B/R773 BASELINE DOCUMENT MATRIX Date 6/24/92 FPL 15 of 23 Storage That period following the release of an item for shipment until turnover for start-up preoperational testing. This would include inplace storage.

System An integral part of a nuclear power plant comprised of electrical, electronic, or mechanical components (or combinations thereof) that may be operated as a separate entity to perform a specific function.

Testing Performance of those steps necessary to determine that systems or components function in accordance with predetermined specifications.

"R uirement " Clarification for Glos.

I RE E MENT:. A mandatory action, denoted by the word shalL, (See "Guidelines" )

Requirements are generally based on statutes or regulations, but may be internally generated within the company. "Shall" is therefore used for both external, legally enforceable actions and internal requirements not enforceable under current NRC practices.

Re ula o Guid 1.88 Rev. 2 ANSI N45.2. -1 4 ANSI N45.2.9-1974, Section 3.2.5 requires Quality Assurance records be classified as lifetime or non-permanent and further defines lifetime and non-permanent in Section 2.2 of the Standard.

FPL provides the following definitions as an alternative to the above.

Lifetime Records: Records which are required by the NRC facility operating license, the NRC construction permit, applicable parts of 10CFR, the FSAR, or other NRC commitments to be retained for the life of the plant.

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TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev. 11 Draft B/R773 BASELINE DOCUMENT MATRIX 16 of 23 Non-permanent Records: Records which am required by the NRC facility operating license, the NRC construction permit, applicable parts of 10CFR, the FSAR, or other NRC commitments to be retained for periods of time less than the life of the plant.

ANSI N45.2.9-1974, requirements for Section 5.6, "Facility", are clarified by FPL as follows:

QA rRecords shall be stored in a manner as to protect contents from possible destruction by causes such as fire, flooding, tornados, insects, rodents, and from possible. deterioration by a combination of extreme variations in temperature and humidity conditions.

A QA Record Storage Evaluation Team (QARSET) shall be responsible for determining methods utilized to assure that QA Records are adequately stored and protected.

The QARSET shall consist of the following: the Quality Manager - Juno Beach, the Loss Prevention Engineer, and the Nuclear Records Official, who shall be responsible for maintaining records of evaluations and establishing. schedules to assure that reevaluations areyerformed every two (2) years. If necessary, the abeve QARSET Cemmhtee may delegate appropriate designees to serve as team members.

As part of their responsibility, the QARSET shall evaluate the status of existing facilities and the adequacy of additional records facilities prior to the construction of a new facility or the conversion of existing structures. Preferably, such evaluations should be performed during the design phase.

ANSI N45.2.9-1974 will be utilized in the evaluation of potential record storage facilities.

Section 5.6 "Facilities" is modified as follows and shall be the basis for QARSET approved QA Record Storage Facilities.

A 2-hour vault meeting NFPA No. 232 without additional provisions,

2. 2-hour rated fire resistant file room as defined in NFPA No. 232- 1980 if the following additional provision are provided:

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TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev. 11 Draft B/R773 BASELINE DOCUMENT MATRIX Date 6f24/92 FPL 17 of 23

a. Early warning fire detection and automatic fire suppression shall be provided, with electronic supervision at a constantly monitored central station.

b. Records shall be stored in fully enclosed metal cabinets. Records shall not be permitted on open steel shelving, No storage er-of records shall be permitted on the fioor of the facility. Adequate access and aisle space shall be maintained at all times throughout the facility.

c. Work not directly associated with records storage or retrieval shall be prohibited within the storage facility.

d. Smoking, aalu eating/and drinking shall be prohibited throughout the records storage facility.

e. Ventilation, temperature, and humidity control equipment shall be provided with approved fire dampers where they penetrate fire barriers.

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3. Other conditions from the above may be approved by the QARSET if, in their judgement, the condition meets the established level of protection defined above.

There are two acceptable alternatives to the establishment of an approved QA rRecord storage facility:

1. The maintenance of duplicate QA Records stored in separate locations which are not subject to the same destructive force at the same time.

2. The use of QARSET approved factory built record protection e'quipment, such as insulated record containers, fire-resistive safes, and insulated filing devices.

Where a specially constructed storage room is maintained to store the only copy of QA records, at least the following features should be considered in its construction:

(1) Reinforced concrete, concrete block, masonry, or equal construction.

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev. 11 Draft B/R773 BASELINE DOCUMENT MATRIX 18 of 23 (2) Concrete floor and roof with sufficient slope for drainage; if a floor drain is provided, a check valve (or equal) shall be included.

(3) Structure, doors, frames and hardware should be fire-rated with a recommended two hour minimum rating.

(4) Sealant applied over walls as a moisture or condensation barrier.

(5) Surface sealant on floor providing a hard-wear surface to minimize concrete dusting.

(6) Foundation sealant and provision for drainage.

(7) Forced-air circulation with filter system.

(8) Adequate fire detection and/or suppression system.

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(9) No pipes other than those providing fire protection to the storage facility are to be located within the facility.

Re ulato uide 1.116 ANSI N45.2.8-1975 ANSI N45.2.8-1975, Paragraph 2.3 requires that Measuring and Test Equipment (M&TE) used for inspection be identified on the Inspection Report. FPL may, as an option, employ a M&1K issue log which provides traceability between M&TEand the applicable inspections.

ANSI N45.2.8-1975, Paragraph 4.6 addresses care of items to the extent that temporary use of equipment or facilities to which the standard applies that are to become part of the completed project may be desirable.

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TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev. 11 Draft B/R773 BASELINE DOCUMENT MATRIX Date 6/24/92 19 of 23 The following clarification applies to the above statement. For FPL plants in the construction phase (to the point of plant operation license) temporary use of equipment and facilities may be ese4 required according to need and/or situation. In this case, authorization for usage shall be provided along with all the documents, conditions, safeguards and evaluations to verify permanent plant equipment adequacy.

In the operations phase all equipment, including temporary equipment, is subject to identical contmls to preclude adverse effects on safety and suitability for use.

Re ulato Guide 1.123 Rev. 1 ANSI N4 .2.13-1 6 ANSI N45.2.13-1976 Section 1.1 states that the extent to which the individual requirements of this standard will apply willdepend upon the nature and scope of the work to be performed and the required quality of the items or services purchased. For commercial grade items, FPL has determined that certain aspects of the individual requirements of ANSI N45.2.13 need not apply.

Commercial grade. items are those (1) not subject to design or specification requirements that ate unique to facilities or activities licensed by the NRC, and (2) used in applications other than facilities or activities licensed by the NRC, and (3) to be ordered from the manufacturer/supplier on the basis of specifications set forth in the manufacturer's published product description.

These commetcial items are subject to varying degrees of control as indicated in the FPL Quality Assurance Manual.

As a minimum, an evaluation is performed by qualified personnel to assure that the commercial item satisfies the necessary technical and quality requirements and the item is checked upon receipt to assure that the item received was the one ordered, damage was not sustained during shipment, and documentation, ifrequired, was received.

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TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev. 11 Draft B/R773 BASELINE DOCUMENT MATRIX Date 6/24/92 FPL 20 of 23 ANSI N45.2.13-1976 Section 1.3 provides a definition of "procurement document" which is different from the definition contained in ANSI N45.2.10-1973 and Regulatory Guide 1.74. The Florida Power & Light (FPL) Quality Assurance Program uses the definition of "procurement document" listed in Appendix C which is an alternative to that listed in the ANSI Standard and Regulatory Guide.

ANSI N45.2.13-1976 Section 3.3.(a) requires that procurement documents be reviewed prior to release for bid and contract award. The FPL Quality Assurance Program requires procurement document reviews prior to bid and contract award for all safety related purchases ~!Whe A "Confirming Purchase Order" is an order which is initiallyplaced verbally with the supplier and then later confirmed with a written Purchase Order. A "Confirming Purchase Order" is only used when time restraints would prohibit the issuance of a written purchase order. The following controls are provided in the FPL Quality Assurance Manual to assure that the intent of ANSI N45.2.13 is satisfied for "Confirming Purchase Orders".

(Ql) Prior to verbally placing the order, it must be verified that the intended supplier is on the FPL Quality Assurance Approved Supplier List.

(Q2) The verbally placed order must be promptly followed-up (confirmed) with a written procurement document which is subject to all reviews and approvals required for safety related purchases.

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev. 11 Draft B/R773 BASELINE DOCUMENT MATRIX Date 6/24/92 FPL 21 of 23 Section 8.2 of ANSI N45.2.13 identifies those nonconformances which shall be submitted to the Purchaser. Florida Power & Light's (FPL) position regarding the nonconformances to be reported is as follows. Suppliers (including A/E's and Contractors) shall submit aH nonconformances which consist of one or more of the following:

1) Technical or material requirements are violated.

2) Requirement in supplier documents which have been approved by the Purchaser is violated.

3) Nonconformances which would affect the quality of the item in regard to function of safety related features. In cases where the supplier cannot make this determination, they shaH be submitted to the Putchaser for evaluation.

This policy assures that aH nonconformances affecting safety related functions will be reviewed and approved by FPL. In all cases, the supplier's documentation on nonconformances is available for FPL's review.

~ I I Re ulato Guide 1.144 Rev. 1 ANSI N45.2.12-1 77 Regulatory Guide 1.144, Positions C.3 a&b, states in part that applicable elements of an organization's Quality Assurance Program should be audited at least annually or at least once within the life of the activity, whichever is shorter.

ANSI N18.7-1976/ANS-3.2, Paragraph 4.5 (endorsed by Regulatory Guide 1.33 Revision 2) states in part; "Audits of selected aspects of operational phase activities shall be performed with a frequency commensurate with their safety significance, and in such a manner as to assure that an audit of safety related functions is completed within a period of two years."

FPL has chosen a two year cycle for auditing elements of the internal and on-site QA Program during the operation phase of plant life following initial fuel loading. FPL's position is that the two year cycle: (1) allows more in-depth and meaningful audits in each regularly scheduled area, (2) permits more audits of ongoing activities, and (3) in conjunction with the planning and scheduling requirement of TQR 18.0 provides for a comprehensive audit program. The audit frequency requirements of Regulatory Guide 1.144 will be followed during other plants'hases.

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TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev. 11 Draft B/R773

'PL BASELINE DOCUMENT MATRIX 22 of 23 In the case of suppliers, an annual evaluation of quality performance history shall be performed to determine reaudit requirements. Reaudit requirements for suppliers shall be based on the quality performance, and the complexity and criticality of the equipment or service being procured.

ANSI N45.2.12, Paragraph 4.3.1 states; "A brief pm-audit conference shall be conducted at the audit site with cognizant organization management. The purpose of the conference shall be to confirm the audit scope, present the audit plan, introduce auditors, meet counterparts, discuss audit sequence and plans for the postaudit conference, and establish channels of communication."

FPL will not require the pre-audit conference for audits of limited scope and of specific site activities conducted by the Construction and Operations Groups. This conference is omitted because the day-to- day contact of the auditors and plant management, the awareness on the part of plant management that these audits are conducted without pre-audit conferences, and the limited scope of the audits meet the intent of a pre-audit conference.

ANSI Standard N45.2.12-1977, Paragraph 4.5,1 states in part "The audited organization shall provide a follow-up report stating the corrective action taken and the date corrective action was completed". The FPL QA Program requires the QA Department to followup on all action taken by the audited department. This is documented on the corrective action followup form by the QA Department and closed by the QA Department instead of the audited department. This assures that all actions taken by the audited department ate verified by the QA Department and that the QA Department concurs with the resolution. We feel that it is appropriate for this to be documented by the QA Department instead of the audited department.

Plannin Clarification ANSI N45.2.4-1972, Paragraph 2.1; ANSI N45.2.6-1973, Paragraph 2.1; ANSI N45.2.13-1976, Paragraph 7,2; ANSI N18.7-1976/ANS 3-2, Paragraph 5.2.7.1; ANSI N45.2.8-1975, Paragraph 2.1 and Paragraph 2.2 include plans and/or planning as required.

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev. 11 Draft B/R773 BASELINE DOCUMENT MATRIX Date 6/24/92 23 of 23 The terms plan and/or planning are included in FPL's activities as indicated in the following clarification:

Planning is considered to be a management process or analytical tool used as an aid to help develop identification and/or development of program requirements, implementation activities, assignments and staffing, inspections, surveillances and audits, controls and other activities to assure completeness of the requirements. Planning, as such, is not always documented nor addressed as an end item and is considered to be an integral "process" within the developed item.

Plans which am considered to be end type or output type documents have the term "plan" in the title, such as ISI Master Plan, Audit Plan, Start-up Plan, and others, which as such will reflect directly the requirement of these standards in the appropriate documents, Plans which are not considered to be end type or output type documents do not have the word plan. in the title. However, certain procedures, instructions, flow charts, schedules and checklists may be considered to be plans reflecting planned actions which especially require step-by-step accomplishments. In these cases, the term plan may not appear in the title but considered to be a plan only in the indirect sense and identified as a procedure or other document. FPL considers the above practice to be in compliance with the "plan" requirements of these standards.

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev. 11 Draft B/R773 BASELINE DOCUMENT MATRIX Date 6f24/92 FPL 1 of 23 This topical report contains the program requirements for Florida Power & Light Company's Quality Assurance Program. The Quality Assurance Program is described in detail in the Florida Power & Light Company Quality Assurance Manual.

The Regulatory Guides, codes, and standards specifically listed in the matrix of this appendix (on page 2) represent the baseline documents used in the preparation of FPL's QA Manual and this topical report. These documents, therefore, provide the basis for the FPL QA Program, but they are not considered to be part of the QA Program unless specifically addressed in the applicable SAR, technical specifications, etc.

The FPL Quality Assurance Program meets the requirements of the documents referenced in this appendix. Any alternatives or clarifications made to the requirements contained in these documents are stated on pages subsequent to the second page of this appendix.

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev. 11 Draft B/R773 BASELINE DOCUMENT MATRIX Date 6/24/92 FPL 2 of 23 REFERENCE INDUSTRY DRAFT REV.

IhQHK 10 CFR PART 50, APPENDIX B 2/19/75 ANSI-N45.2 1971 10 CFR PART 50.55a ASME B&PV Code Specified in the Section III& SAR document of XI the respective plant Regulatory Guide 1.8 Rev. 1 9/75 ANSI-N18.1 1971 ANS//ANS 3.1 1978 Regulatory Guide 1.28 6/7/72 ANSI-N45,2 1971 Regulatory Guide 1.30 8/1 1/72 ANSI-N45.2.4 1972 Regulatory Guide 1.33 Rev. 2 2/78 ANSI-N1 8.7 1976 Regulatory Guide 1.37 3/16/73 ANSI-N45.2.1 1973 Regulatory Guide 1.38 Rev. 2 5/77 ANSI-N45.2.2 1972 Regulatory Guide.1.39 Rev.,2 9/77 ANSI-N45.2.3, 1973 Regulatory Guide 1.58 Rev. 1 9/80 ANSI-N45.2.6 1978 Regulatory Guide 1.64 Rev. 2 6n6 ANSI-N45.2.11 1974 Regulatory Guide 1.74 2/74 ANSI-N45.2.10 1973 Regulatory Guide 1.88 Rev. 2 10n6 ANSI-N45.2.9 1974 Regulatory Guide 1.94 Rev. 1 4n6 ANSI-N45.2.5 1974 Regulatory Guide 1.116 6n6 ANSI-N45.2.8 1975 Regulatory Guide 1.123 Rev. 1 7/77 ANSI-N45.2.13 1976 Regulatory Guide 1.144 Rev. 1 9/80 ANSI-N45.2.12 1977 Regulatory Guide 1.146 8/80 ANSI-N45.2.23 1978

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TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev. 11 Draft B/R773 BASELINE DOCUMENT MATRIX Date 6/24/92 FPL 3 of 23 Florida Power &Light Company position regarding conflicting guidance and exceptions:

T ARA ndix Clarification AN IANS .1-1 78 PSL-2 The Regulatory Guides and industry standards listed in Appendix C to the Topical Quality Assurance Report take precedence over any Regulatory Guide or industry standard which may be referenced in any one of these documents.

Re lat uide1. Rev. 1 ANSI N1 .1-1 1 ANSI ANS .1 PSL-2 ANSI N18.1 describes the training and education requirements for plant staff positions and is endorsed by Reg. Guide 1.8 with an exception. That exception is the requirements for the Supervisor - Radiation Protection. ANSI N18.1 is invoked by Technical Specifications (Appendix A of the Facility Operating License) at the Turkey Point plants and PSL-1.

ANSI/ANS 3.1-1978 is invoked by Technical Specification at PSL-2. Reg. Guide 1.8 is also invoked by Technical Specifications at our St. Lucie plant and a license amendment has been approved for our.Turkey Point plant to specify. the Health Physics Supervisor qualifications addressed in Reg. Guide 1.8.

To avoid duplication of requirements, FPL will address Plant Staff Qualifications in only the Technical Specifications.

Re lato Guide 1. 0 ANSI N45.2.4-1 2 ANSI N45.2.4-1972, Paragraph 2.3 addresses installation specifications and requires the inclusion of inspection and test objectives. FPL maintains that test values and inspection scope are inherently contained in the applicable procedures.

ANSI N45.2.4-1972, Paragraph 6.1.2 requires that the inspection of installed equipment verify that "good and proper workmanship" has prevailed. FPL maintains that acceptable parameter compliance with codes and standards along with company preference is the verification of "good and proper workmanship".

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TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev. 11 Draft B/R773 BASELINE DOCUMENT MATRIX Date 6/24/92

@PL 4 of 23 ANSI N45.2.4-1972, Paragraph 6.2.1 requires that "Items requiring calibration shall be tagged or labeled on completion indicating date of calibration and identity of person that performed the calibration." In lieu of tagging or labeling equipment, FPL has chosen to control calibration of installed instrumentation and control equipment by maintaining records for each piece of equipment by instrument tag number (or equivalent) to show that established schedules and procedures for calibration have been followed.

Re lat uide 1 Rev. 2 ANSIN18. -19 6 FPL's method of addressing Paragraphs 4.0, 5.2.2, 5.2.15 and 5.3 of ANSI 18.7 - 1976 as modified by Regulatory Guide 1.33, Rev. 2 is covered in Section 6 of each individual plant's Technical Specifications.

ANSI N18.7-1976, Section 4.3, requires that personnel performing the independent review and audit be specified in number and technical discipline. This standard is invoked by the Technical Specifications (Appendix A of the Facility Operating Licenses) which have been approved for the FPL nuclear plants at St. Lucie and Turkey Point. Specifically this function is performed by the Company Nuclear Review Board (CNRB) identified in Section 6.5.2 of the Technical Specifications.

To avoid duplication of requirements, FPL will address the personnel and functions of this independent review and audit only in the Technical Specifications.

FPL's method of addressing Section 5.2 of ANSI N18.7-1976, as modified by Regulatory Guide 1.33, Rev. 2, is by administratively controlling licensed operator hours on shift and by our Duty Call Supervisor system. Further, FPL has developed a response to NUREG 0654 which provides staffing availability.

FPL's method of addressing Paragraph 5.2.8 of ANSI N18,7-1976, as modified by Regulatory Guide 1.33, Rev. 2, is covered in Section 4 of each plant's Technical Specifications.

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev. 11 Draft B/R773 BASELINE DOCUMENT MATRIX Date 6/24/92 .

FPL 5 of 23 FPL's method of addressing Paragraph 5.2.9 of ANSI N18,7-1976, as modified by Regulatory Guide 1.33, Rev. 2, is covered in 10 CFR 73 and each plant's Security Plan, and as such is not included in the Quality Assurance Program.

Chemical cleaning is not presently controlled as a special process per se; however, the requirements of ANSI N45.2.1-1973 and Regulatory Guide 1.37 dated 3/16/73 are part of the FPL QA Program and are met in our program. FPL proposes these requirements to be an alternative to the requirements of ANSI N18.7-1976, Paragraph 5.2.18. Further, TQR 9.0, Paragraph 9.2 explains the review of potential special processes and determination of their status as special processes.

FPL meets the intent of Section 5.2.19.3 of ANSI N18.7-1976 as modified by Regulatory Guide 1.33, Rev. 2, as applied to significant changes to operating procedures, by the technical review of the procedure change by knowledgeable plant professionals, by the safety review of the procedure change by the on-site facility review group, by the regulatory and QA review of the procedure by plant Quality Control, by training the licensed operators in the change through the training report system, and by trained, licensed operators using the revised operating procedure and observing the proper result. In addition, procedure changes will be reviewed to assure 10 CFR 50.59 requirements are met.

Paragraph 5.3.5(4) - Clarification - When FPL uses vendor manuals and drawings which provide adequate instructions for maintenance, these documents are attached or referenced with Plant Work Orders which are reviewed and approved by Supervisory and Quality Control personnel and are considered to be adequate procedures in themselves. These vendor manuals and drawings, when icceived at site, are controlled documents and changes to the applicable sections and instructions of these documents require the same level of review and approval as the operating procedures.

Appendix A of Regulatory Guide 1.33 lists "typical safety related activities which should be covered by written procedures". Regulatory Guide 1.33 is invoked by the Technical Specifications at FPL Nuclear Plants.