Text

Rev 16 to Topical QA Rept.
	ML17348A300
Person / Time
Site:	Saint Lucie, Turkey Point
Issue date:	06/30/1990
From:	; FLORIDA POWER & LIGHT CO.
To:	;
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ML17348A299	List: ML17348A298; ML17348A300;
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	NUDOCS 9006210327
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0 Florida Power & Light Topical Quality Assurance Report Change Summary June, 1990 ENCLOSURE I Summary of changes to the Florida Power and Light Topical Quality Assurance Report (FPLTQAR 1-76A)

FPL has extensively revised the organization in TQR 1.0 rev. 16 to create an independent Nuclear Division. A marked version of the previous revision would not be practical, therefore this management summary will describe the nature of the changes. Copies of TQR 1.0 Rev. 15, Appendix A Figure 1-1 Rev. 15, Appendix A Figure 1-2 Rev. 2, and Appendix A Figure 1-3 Rev. 3 are enclosed for comparison. USNRC senior management has been involved with FPL senior management through correspondence and frequent meetings as the new organization has taken shape, and internal reviews indicate that the changes do not reduce the commitments in the Quality Assurance program description previously accepted by the NRC.

ff Ev October 19, 1988 to July 13, 1989 The NRC Letter of Evaluation has been updated. Included in this revision is the NRC Letter & Certificate - Quality Assurance Program Approval for Radioactive Material Packages.

2. T~II IR I The Table of Contents has been revised at each revision of a portion of the TQAR to reflect the most recent revision of all'ocuments within the TQAR.

3. i A r Pr mP li Rev.7toRev.8

4. I~

The responsibility section has been revised to reflect the new organizational structure.

R .IR R .II The authorization signature has been changed from the Director - Quality Assurance to Vice President Nuclear Assurance.

Page 1 of 6 cjtPP6Q, f P327 ADOCK 5 PPPg5P PDP pNU P

Florida Power & Light Topical Quality Assurance Report Change Summary June, 1990 R 1 - i i Rev. 15 to Rev. 16 The Organization has been revised to reflect the creation of a Nuclear Division within FPL, and to add corporate support groups in the area of mainframe computers.

The Nuclear Division is led by the President Nuclear Division. This position retains responsibilities of the Executive Vice president as outlined in L 344, September 12, 1989, J.H. Goldberg to USNRC Re: Organization Changes.

Reporting to the President Nuclear Division are the Senior Vice President Nuclear Operations, Vice President Nuclear Engineering and Licensing, Vice President Nuclear Assurance, and Director Nuclear Administrative Services.

The Senior Vice President Nuclear Operations is responsible for nuclear power.

production, including:

operation, maintenance, and modification of FPL nuclear plants through the respective Plant Vice President, Plant Manager, and on-site support organizations; Nuclear Security, Nuclear Training, and Nuclear Energy Services, formerly reporting to the Vice President Nuclear Energy.

The Vice President Nuclear Engineering and Licensing is responsible for:

Nuclear Engineering, now augmented by functional areas supporting the technical aspects of fuel design and related activities formerly reporting to Fuel Resources; providing equipment support specialists formerly reporting to Nuclear Energy Services; directing activities in support of major plant maintenance projects formerly reporting to the Maintenance Manager Nuclear, and welding program support activities formerly reporting to the Construction Department.

Nuclear Materials Management, a new organization responsible for procurement of materials and services in support of FPL nuclear power plants. This organization incorporates functions formerly reporting to Corporate Contracts, Purchasing, Inventory Resources, and Fuel Resources.

Nuclear Licensing, remaining essentially unchanged. Interface activities at the plant sites are now augmented by resident Licensing Superintendents.

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Florida Power & Light Topical Quality Assurance Report Change Summary June, 1990 Nuclear Construction Services, a new organization responsible for activities previously assigned to the Project Management Department and a portion of the activities assigned to the Construction Department (see Quality Assurance, below).

The Vice President Nuclear Assurance is responsible for:

Quality Assurance, now incorporating the various quality control organizations previously reporting to the Plant Manager and Construction Department into a single Quality Control group at each plant reporting to the on-site Quality Manager, and administrative responsibilities for NDE Level III support previously assigned to the Construction Department.

The Company Nuclear Review Board, for administrative support. The CNRB continues to report to the Executive Vice President (President Nuclear Division), as required by technical specifications.

Nuclear Safety Speakout, a new organization to provide a forum for employees and contractors to communicate their concerns to FPL.

The Director Nuclear Administrative Services is responsible for.

coordinating budget, rate and cost control support; directing the planning, administration and control of computerized information management systems; coordinating office services, document control, personnel related issues, and human resources for Nuclear Division staff groups, all previously assigned to the Manager Planning 8r, Control;.

Computer Operations and Information Systems have been added. to show the.

support these organizations provide the Nuclear Division in the area of main&arne computer installation and maintenance, and computer software development and maintenance.

R2 - li Pr Rev. 8 to Rev. 9 Vice President Nuclear Assurance has been substituted for Director Quality Assurance; Quality Manager - Juno Beach replaces Manager of Quality Assurance Services; and Company Nuclear Review Board (CNRB) replaces Quality Assurance Committee.

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Florida Power & Light Topical Quality Assurance Report Change Summary June, 1990 R - i Rev. 7 to Rev. 8 References to the Fuel Resources Department have been removed to indicate that Nuclear Engineering has primary design responsibility within the Nuclear Division; in section 3.2.2, reference to plant Quality Control has been changed to indicate a single Quality Control group; section 3.2.5 terminology has been updated Rom computer code to computer programs/software.

4 -Pr rm D Rev. 3 to Rev. 4 Reference to Change Notice 32 has been deleted due to incorporation in this current revision; Purchasing, Fuel Resources, and Corporate Contracts have been combined into the Nuclear Materials Management Department.

R -In Pr r win Rev. 8 to Rev..9 References to Project Site Manager and Project General Manager Nuclear have been changed to Site Construction Services Manager to reflect the combination of Construction and Project Management into Nuclear Construction Services; reference to the Nuclear Fuel Department has been deleted to indicate Nuclear Engineering's primary role.

m n n Rev.6toRev.7 Software has been included under the General Requirements; Nuclear Fuel has been deleted to indicate Nuclear Engineering's primary role.

n l f h I m rvi Rev. 5 to Rev.-6 Section 7.2.1 has been revised to correct organizational titles.

n f i Pr Rev. 7 to Rev. 8 .

The Fuel Resources Department has been deleted.to indicate Nuclear Engineering's primary role; reference to Construction Quality Control has been deleted to indicate a single Quality Control group; Project Site Manager has been changed to Site Construction Services Manager.

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Florida Power 8c Light Topical Quality Assurance Report Change Summary June, 1990

13. T R1 -In i Rev.8toRev.9 Section 10.2.1 has been revised to include maintenance and modification to the scope of activities; references to the Nuclear Energy and Construction Management have been revised to Nuclear Division, Nuclear Assurance or Quality Control, as appropriate; the second paragraph of section 10.2.1 has been deleted as the Construction Department no longer has= inspection responsibilities; the last sentence of paragraph 4 has been deleted as the Construction Department no longer has inspection responsibilities; in- section 10.2.5, appropriate has been deleted to indicate a single Quality Control group.

14. 2 - n l 'n T E i m n Rev;3toRev.4 Section 12.1 was revised to broaden the scope of applicability; section 12.2.3 was revised to update the title of the National Institute of Standar~d Technology (NIST).

15. -H in ra hi in Rev. 6 to Rev. 7 In section 13.2.4, reference to the Plant Manager has been deleted. Quality Assurance is now responsible for all verification of handling, storage, and shipping.

16. 4 -n inT 'n Rev. 6 to Rev. 7 Reference to Nuclear Energy Department has been changed to Nuclear Division or Nuclear Operations, as appropriate; Project Management has been changed to Nuclear Construction Services; Project Site Manager has been changed to Site Construction Services Manager.

17. 1 - n nf rmin M ri I P r m nn Rev. 8 to Rev. 9 References to Nuclear Fuel and Nuclear Energy have been deleted to indicate that Nuclear Engineering has responsibility for evaluation and disposition of nonconforming items; A/E and contractor contact for NCR's has been changed to indicate removal of Construction Department and Nuclear Energy Department, and to comply with procurement documents.

18. rr 'v A i Rev. 5 to Rev. 6 Quality Control and Quality Assurance have been combined into Nuclear Assurance; final authority for corrective action now rests with the President Nuclear Division.

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i Florida Power & Light Topical Quality Assurance Report Change Summary June, 1990

19. T~R4 -6 '

.5 R .6 Section 18.2.6 has been revised to substitute the Company Nuclear Review Board (CNRB) for the QA Committee.

20. n 'xAFi r 1 i i n fD n Aff 'n Rev. 15 to Rev. 16 Extensively revised to reflect the creation of a separate Nuclear Division, new departments, and reporting relationships. Page 2 of 2 added for support

~94 departments previously on the same page as nuclear departments.

21. A n'xB- ific in Ex rin R irmn frFPL ali R .4 R .5 Titles have been revised to reflect the current organization, arid the position of Assistant Manager of Quality Assurance has been deleted.

22. n 'x -Ba lin m n M 'ev.7toRev.8 Under Regulatory Guide 1.144, Rev. 1/ANSI N45.2.12-1977, references to ANSI N18.7-1972 were updated to ANSI N18.7-1976/ANS-3.2. to comply with a baseline document change originally made in June, 1983.

23. A n 'xE-Li t f i A n Rev. 11 to Rev. 12 Revised to include the new Quality Procedure QP 2.15, Control of Computer Software.

24. A ndixE-Li t f ali A n Pr r Rev. 12 to Rev. 13 Revised to delete QP's 4.1, 4.2, 4.4, 4.5, and 7.8 which were consolidated into the new QP 4.6.

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TOPICAL QUALITYASSURANCE REPORT Rev. Draft 8 QUALITY ASSURANCE PROGRAM POLICY Date 5/9/90 FPL Page 1 of1 NEED FOR POLICY To avoid undue risk to the health and safety of the public and company employees, it is necessary to design, construct, operate and modify nuclear power plants with a high degree of functional integrity, quality and reliability.

STATEMENT OF POLICY It is the policy of Florida Power & Light Company to design, construct, operate and modify nuclear power plants of a quality level that will meet or exceed government regulations and will merit public confidence by providing electricity in a reliable, efficient and safe manner.

RESPONSIBILITY The President of Florida Power & Light Company is responsible for the execution of the Quality Assurance Program for Florida Power & Light Company nuclear power plants. The authority for d ]pig d 'fyig '

l P g i Blg d h Asseraaee Vice President Nuclear Assurance, through the President Nuclear Division.

The head of each organization performing quality-related activities is responsible for: identifying those activities within his organization which are quality-related as defined by the QA Program; establishing and clearly defining the duties and responsibilities of personnel within his organization who execute those quality related activities; and planning, selecting, and training personnel to meet the requirements of the QA Program.

R. E. Talion, President Florida Power & Light Company

TOPICAL QUALITYASSURANCE REPORT Rev. Draft 11 INTRODUCTION Date 5/9/90

@PL Page 1 p<2 The Topical Quality Assurance Report (FPLTQAR 1-76A) contains the description of the Florida Power 8i: Light Company (FPL) Quality Assurance Program relative to its nuclear power plants.

This report consists of three parts: The Introduction, which delineates the purpose and summarizes the scope and applicability of the Topical Quality Assurance Report. The second part, Topical Quality Requirements (TQRs), which delineate Quality Assurance Program requirements and summarizes the FPL approach to activities related to materials, parts, components, systems, and services included in the Quality Assurance Program. The third part, Appendices, which provide supporting statements, tabulations, and technical analyses or deviations which are not, in themselves, the subject of the report.

The Topical Quality Assurance Report shall be an integral part of the corporate Quality Assurance Manual (FPL-NQA-100A), and shall delineate the generic requirements and 0 responsibilities by which FPL implements the corporate Quality Assurance Program. Revisions and changes to this Report will be made in accordance with a Quality Procedure as outlined in TQR 2.0. The remainder of the Quality Assurance Manual is comprised of Quality Procedures (QPs) which serve as the documents which describe how the interfacing of tasks between departments or organizations is achieved. The Quality Procedures also cover those technical elements which require a common corporate position for interfaces or resolution of problem areas.

In addition to the Quality Assurance Manual, Quality Instructions (QIs) are developed as required by each of the implementing plants and departments. Quality Instructions describe the measures to be used to implement the quality requirements of the Quality Assurance Manual. The Quality Instructions describe actions and responsibilities to be performed within a department or organization and address the requirements of the appropriate Topical Quality Requirements, and Quality Procedures.

The FPL Quality Assurance Program meets the requirements provided by the NRC Regulatory Guidance and Industry Standards as listed in Appendix C of this Topical Quality Assurance Report.

TOPICAL QUALITYASSURANCE REPORT Draft 11'ate INTRODUCTION 5/9/90 Page 2 of 2 The requirements of this Topical Quality Assurance Report apply to safety-related materials, parts, components, systems and structures; and to services employed for design, procurement, construction, operation, maintenance, refueling, repair, and modification. The safety-related systems for each plant are specified in the respective plant Safety Analysis Report.

The FPL Quality Assurance Program fully addresses the requirements of Appendix B to 10 CFR Part 50. The Topical Quality Assurance Report shall be applicable to all existing nuclear plants, those under construction, and supporting FPL departments, and will be referenced in the Safety Analysis Report (SAR). For future plants, the description of activities, requirements, and organizational structures that are unique to a particular plant shall be addressed in the respective SAR document.

Vice President Nuclear Assurance

TOPICAL QUALMY ASSURANCE REPORT TQR 1.0 Rev. 15 .

ORGANIZATION Oate June 9 1989 Page 1 of 32 1- 1 GENERAL UIREMENTS The FPL organizational structure shall be defined such that the responsibilities for establishment and implementation of the Quality Assurance Program are clearly identified. The 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 IMPLEMENTATION The President of Florida Power & Light is ultimately responsible for the execution of the Quality Assurance Program for Florida Power & Light Company (FPL) nuclear power plants. The authority for developing and verifying execution of the program is delegated to the Director of Quality Assurance, the Senior Vice President Nuclear and the Executive Vice President; The reporting relationship of each department involved with the Quality Assurance Program is shown in Appendix A, Figure 1-1.

To provide for a review and evaluation of Quality Assurance Program policies and activities, the President has established the Quality Assurance Committee, chaired by the Executive Vice President. This Cl organization's responsibilities are defined in Section 1.2.1.

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TOPICAL QUhIZZY ASSURhNCE REPORT TQR 1.0 Rev. 15 ORGhNIZATI08 Date June 9, 1989 Page 2 of 32

1. 2 INPLEK9&ATION: (Cont ')

In addition, a Quality Assurance Program Review Committee (QAPRC) (formerly the QA/QC Coordinators) has been established to review changes to the Quality Assurance Program and to provide an interface for quality matters in each department affecting quality. This organization's responsibilities are defined in Section 1.2.2.

The head of each department or organization performing quality-related activities is responsible for: a) identifying those activities within the organization which are quality-related as defined by the Quality Assurance Program; b) establishing and clearly defining the duties and responsibilities of personnel within his organization who execute those

,0 quality-related activities; and c) planning, selecting, and training personnel to meet the requirements of the Quality Assurance Program. The responsibility, authority, and organizational relationship for performing quality-related activities within each organization shall be established and delineated in organizational charts and written job or functional descriptions.

A Quality Assurance Program Review Committee (QAPRC) Member shall be designated by the head of each department or organization except for the Quality Assurance Committee, since this committee is a policy forming body (of which the Director of Quality Assurance is a member). The QAPRC Member is the prime interface for coordination of quality-related matters within the member's department, with the Qualitv Assurance Department, and with other departments.

The organization chart, Appendix A, Figure 1-1, illustrates the lines of authority and areas of responsibility for each of the organizations that are involved in quality-related activities. The Project Management organization shown in this figure is applicable during design, procurement, construction, repairs and preoperational start-up and testing of power

i TOPICAL QUALITY ASSURANCE REPORT TQR 1. 0.

Rev. 15 Oate June 9, 1989 Page 3 of 32.

l. 2 IHPLEMEÃZhTION: (Cont ')

plant and modifications of power plants (determined by management on a case-by-case basis) as described in Section 1.2.4. Below are listed the departments and organizations that have Quality Assurance responsibilities. Specific organizational responsibilities for implementation of the Quali.ty Assurance Program are described in the corresponding section numbers.

1.2.,1 Quality Assurance Committee 1.2.8 Construction-1.2.2 Quality Assurance Program 1.2.9 Power Supply Review Committee 1.2.10 Inventory Resources 1.2. 3 Nuclear Energy Department 1.2.11 Company Nuclear

- Nuclear Power Generation Review Board

- Nuclear Corporate Staff 1.2.12 Nuclear Fuel 1.2.13 Corporate Records 1.2.4 Projec't Management Department Services 1.2.5 Corporate Contracts Department 1.2.14 Documentary Files 1.2.6 Environmental Affairs 1.2.7 Purchasing 1.2.1 Quality Assurance Committee The Quality Assurance Committee, chaired by the Executive Vice President, is comprised of executive level members of management with responsibilities for the execution of the Quality Assurance Program within their responsibilities. This Committee's composition is delineated in its current charter and it' CD CC reporting relationship is shown in Appendix A, Figure 1-1.

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TOPICAL QUhLITY ASSURANCE REPORT TQR 1.0 Rev. 15 ORGANIZATION Date June 9, 1989 paga 4 ot 1.2.1 alit Assurance Committee: (Cont'd)

Policy changes shall be initiated when Committee findings indicate the necessity. Quality Assurance Program status reports shall be periodically prepared by the Quality Assurance Department and routed to the members of the Quality Assurance Committee for their review.

In addition, Quality Assurance Committee meeting's shall be held by the Executive Vice President to keep members apprised of conditions including signif icant problems that require management attention. The Quality Assurance Committee shall be the final authority for resolution of contested quality policies, differences of opinion, and stop-work or other corrective action requests when lower-level agreement cannot be reached between Quality Assurance or Quality Control and other departments.

Periodic audits of the Quality Assurance Department shall be performed by a team independent of th'e Quality Assurance Department, which is selected and approved by the Chairman of the Quality Assurance committee. The results of this audit are presented to the Quality Assurance Committee.

1.2.2 Quality Assurance Program Review Committee (QAPRC)

The QAPRC (formerly the QA/QC Coordinators) was formed as an organization with the responsibility to review and resolve recommended changes to the Quality Assurance Program. This

'D committee is administered by the Quality Assurance Services Cl CV group. Quality Assurance Program changes reviewed by the QAPRC D

C are reviewed and signed by the department heads or individuals t7 0

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TOPICAL QUALZ1Y ASSURANCE REPORT TQR 1.0 Rev. 15 ORGANIZATION Date June 9, 1989 Page ~ of

1. 2. 3 Nuclear Energy Department Nuclear Energy responsibility for the plant begins with the Department's acceptance of a system or portion thereof from FPL Project Management. Throughout the remainder of plant life, Nuclear Energy maintains control of and responsibility for any plant modifications coordinated by Nuclear Energy and for the preoperational and start-up testing, operation, maintenance, refueling, and modification of the plant in accordance with written and approved procedures.

The organizational structure of Nuclear Energy is shown in Appendix A, Figure l-l. The Senior Vice President Nuclear has overall responsibility for Nuclear Energy's activities. The Senior Vice President Nuclear is designated as the Senior Corporate Nuclear Officer of Section 6.0, Administrative Controls, of each Unit's Technical Specifications.

Reporting to the Senior Vice President Nuclear are: The Site Vice President - St. Lucie, the Site Vice President - Turkey Point, the Vice President Nuclear Energy, Assistant, the Director of Quality Assurance and Director - Nuclear Licensing.

Additionally, reporting to the Senior Vice President is the Vice President responsible for overview of regulatory activities.

1.2.3.1 Nuclear Power Generation The Site Vice President-St. Lucie and Site Vice President-Turkey CO N Point are accountable for the operation, maintenance, and D

modification of their respective nuclear plant, as well as the selection, development and direction of the assigned staff. They C

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TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev. 15 ORGANIZATION June 9, 1989 Page 6 of 32 1.2.3.1 Nuclear Power Generation (Cont'd) policies and procedures are properly implemented and continued at the nuclear site.

The Plant Manager (Plant Manager Nuclear at PTN) through the Vice Presidents - Turkey Point and St. Lucie Plants (as applicable) is responsible for the operation of the nuclear plant. The plant manager is additionally responsible for the establishment and implementation of plant Quality Control policy which implements the quality control aspects of the Quality, Assurance Program.

Reporting directly to the Plant Manager is the plant Quality Control Supervisor who has the authority and freedom to administer the plant Quality Control program and, when necessary, to stop activities adverse to quality. The Quality Control Supervisor, his staff, 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 Control effort includes preparation and review of plant procedures, PCMs, quality-related instructions and procurement documents; Quality Control personnel are also responsible for inspection, monitoring, surveillance, and review of plant activities to verify compliance with the provisions of the facility operating license and the Quality Assurance Manual. The Quality Control Supervisor shall take corrective action for deficiencies identified, where applicable, and shall follow up on corrective action taken by other organizations until close out. He shall receive quality program direction from the Director of Quality Assurance.

TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev. 15 ORGANIZATION Dace June 9, 1989 Page 7 of 32 1.2.3.1 Nuclear Power Generation (Cont'd)

The Plant Nuclear Safety Committee (PNSC) at Turkey Point Plant or the Facility Review Group (FRG) at the St. Lucie Plant is 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 on plant safety and the facility operating license.

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 procedures 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 the sole function of this organizationally independent department, the Director of Quality Assurance and his staff, both on-site and off-site, are C

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TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev.

ORGANIZATION Oa<8 June 9, 1989 page 8 of 32 1.2.3.1 Nuclear Power Generation (Cont'd) design, procurement, 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 Director of Quality Assurance reports to the Senior Vice Presi.dent Nuclear. He is responsible for the technical direction and the administrative control (e.g., performance appraisal, salary review, hire/fire, position assignment) of all members of the Quality Assurance Department.

The Manager of Quality Assurance Services, the Superintendent of Quality Assurance - St. Lucie and the Superintendent of Quality Assurance - Turkey Point report administratively and functionally to the Director of Quality Assurance. The Superintendents of Quality Assurance receive technical direction from the Manager of Quality Assurance Services.

The Director of Quality Assurance, the Senior Vice President Nuclear, and the Vice President Nuclear Energy are each members of the Quality Assurance Committee. This reporting relationship and memberships on the Quality Assurance Committee assure that the Quality Assurance Department has direct access to the levels of management necessary to assure effective implementation of the Quality Assurance Program. Further, the Operations Quality Control Supervisors of both Turkey Point and St. Lucie receive quality program direction from, the Director of Quality 'Assurance.

TOPICAL QUhLITY ASSURANCE REPORT TQR 1.0 Rev. 15 ORGANIZhTION Oate June 9, 1989 Page 9 of 32 1.2.3.1 Nuclear Power Generation (Cont'd)

The Manager of Quality Assurance Services directs and administers the Corporate Quality Assurance Program, including developing and verifying implementation of policies, plans, requirements, procedures and audits which assure compliance with the baseline documents listed in Appendix C of this Topical Quality Assurance Report. Additionally, the Manager of Quality Assurance Services is responsible for assuring the quality of safety related items and services, and their vendors, through the Quality Assurance Procurement Group.

0 The duties, responsibilities, and authorities of Assurance group are described in the sections which follow.

each Quality

a. Quality Assurance Systems and Audits Group Quality Assurance Systems and 'Audits is responsible for the development and maintenance of the overall Quality Assurance Program, including the following:

o Deve'lop and maintain the Quality Assurance Department Quality Instructions, Quality Assurance Department Training 8c Organization Manual, and the corporate Quality Assurance Manual; including the administration of the Quality Assurance Program Review Committee (QAPRC)

Assist other departments in the development of Quality Instructions by review and comment and through interpretation of corporate Quality Assurance requirements; Develop and implement a Quality Assurance indoctri-Vl C

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TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev. 15 ORGANIZhTION June 9, 1989 Page 10 of 32 1.2.3.1 Nuclear Power Generation (Cont'd)

Prepare reports on Quality Assurance Program activities for presentation to the Quality Assurance Committee by the Manager of Quality Assurance Services; Maintain a file system for documentation of quality assurance activities performed by the Quality Assurance Department; Review Regulatory Guides, Codes, SAR Document Commitments and Standards for impact on the Quality Assurance Program and recommend appropriate program changes; Review documents submitted to the Company Nuclear Review Board (CNRB) as requested by the Quality Assurance Department CNRB member; Plan, coordinate and implement a comprehensive system of periodic internal audits with support from the other Quality Assurance groups, when necessary; Initiate, recommend or provide solutions and verify implementation of solutions for quality problems identified; Review FPL originated design specifications for inclusion of appropriate quality requirements.

b. Quality Assurance Procurement Group Quality Assurance Procurement is responsible for assuring the quality of safety-related items and services, and their vendors, including the following:

o Assist in the development and implementation of policies, plans, requirements and procedures for the requisition and purchase of materials, equipment and

TOPICAL QUALI'.EY ASSURANCE REPORT TQR 1. 0 Rev.

Oete ORGANIZhTION June 9, 19g9

>>ge 11 <<32 1.2.3.1 Nuclear Power Generation (Cont'd) services related to nuclear power plants and to the acceptance and storage of equipment and material; o Perform appropriate surveillance of hardware during manufacture; Develop and implement a program for'uditing of supplier Quality Assurance/Quality Control programs including architect/engineer/ Nuclear Steam Supply System Suppliers; Review and approve FPL procurement documents and changes to these documents to assure that the necessary quality requirements are imposed; 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; Review, approve and periodically audit the execution of FPL contractor quality assurance programs; Maintain a file system for documentation of quality assurance activities performed by the Quality Assurance Procurement group; Evaluate the Quality Assurance capability of suppliers requested by Purchasing and Corporate Contracts and maintain the Quality Assurance Department "Approved Suppliers List".

ID The responsibility of this group, in terms'f phases of Cll procurement, begins with the preparation of the procurement I!

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TOPICAL QUAGGY ASSURANCE REPORT TQR 1.0 Rev. 15 Oate ORGANIZATION June 9 ]9g9 Page 12 <<32 1.2.3.1 Nuclear Power Generation (Cont'd)

This group, through audits and surveillances, assures that the contractors'rganizations performing Quality Assurance functions have sufficient authority and organizational freedom to implement effective Quality Assurance programs.

c. Quality Assurance Group - Turkey Point The Superintendent of Quality Assurance-Turkey Point has responsibility for on-site development and implementation of the Quality Assurance Program, including the following:

Coordinate in the development and implementation of policies, plans, requirements, and procedures for portions of the quality assurance program related to the operation and modification of nuclear power plants at Turkey Point Units 3 and 4 (PTN);

Perform audits, assessments and other observations at PTN 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; Identify requirements, ensure inclusion of commitments in documents and verify implementation of the Quality Assurance Program during the backfit activities at PTN through audits of FPL and contractor organizations;

TOPICAL QUALITY ASSURANCE REPORT TQR 1. 0 Rev. 15 Date June 9, 1989 Page 13 of 32 1.2.3.1 Nuclear Power Generation (Cont'd)

Recommend stoppage of work or operations adverse to quality at PTN in accordance with the appropriate Quality Procedures; Review and comment on Quality Instructions or equivalent quality-related administrative procedures prior to issue, with respect to the requirements of the FPL Quality Assurance Program, the PTN Final Safety Analysis Report, and the PTN Technical Specifications; Assure that the status is tracked for all PTN open items identified by the FPL Quality Assurance Turkey Point group, and inform appropriate management when there is an indi. cation that a commitment will not be met on time; Maintain a file system for documentation of quality assurance activities performed by the Turkey Point group; Assure design-related activities performed by the Architect Engineer meet the quality aspects of the contract; Review backfit procedures with respect to the FPL Quality Assurance Program (for procedure review requirements see TQR 5.0);

Review site generated FPL procurement documents and changes to procurement documents in accordance with the appropriate Quality Procedures; ID Perform audits of PTN architect engineer and Nuclear EO N Steam Supply System suppliers both on-site and a

off-site, in conjunction with the Quality Assurance Procurement group.

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TOPICAL QUALZIY ASSURANCE REPORT TQR 1.0 Rev. 15 ORGANIZATION Date June 9, 1989 Page 14 of 32 1.2.3.1 Nuclear Power Generation (Cont'd)

The interface with the Quality Assurance Procurement 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 Quality Assurance Turkey Point group.

Off-site interfaces for the resolution of quality-related problems and NRC items are with Project Management, Nuclear Engineering, Nuclear Corporate Staff and the architect engineer and Nuclear Steam Supply System Quality Assurance Department. This group is called upon to audit the Turkey Point operating plant. The Turkey Point group interfaces with the Site, Vice President and his staff on-site by assisting in the resolution of quality-related problems.

d. Quality Assurance Group - St. Lucie (PSL)

The Superintendent of Quality Assurance St. Lucie has responsibility for on-site development and implementation of the. Quality Assurance Program, including the following:

Coordinate in the development and implementation of policies, plans, requirements and procedures for portions of the quality assurance program related to the operation or modification of St. Lucie Unit 1 &

Unit 2 (PSL);

Perform audits, assessments and other observations at PSL to verify compliance with Quality Assurance Program commitments, identify quality problems and ensure

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TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 e ORGANIZhTION Rev.

Page 15 15'ate June 9, ],989 of 32 Nuclear Power Generation (Cont'd)

'.2.3.1 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; Identify requirements, ensure inclusion of commitments in documents and verify implementation of the Quality Assurance Program during the backfit activities at PSL through audits of FPL and contractor organizations; Maintain a file system for documentation of quality assurance activities performed by the St. Lucie Projects-Quality Assurance group; Assure design-related activities performed by the Architect Engineer meet the quality aspects of the contract Review backfit procedures with respect to the FPL Quality Assurance Program (for procedure review requirements see TQR 5.0);

Review site-generated FPL procurement documents and.

Y changes thereto, in accordance with appropriate Quality Procedures; Perform audits of PSL architect engineer/Nuclear Steam Supply System suppliers both on-site and off-site, in conjunction with the Quality Assurance Procurement ID group; OI Recommend stoppage of work or operations adverse to O

quality at PSL in accordance with the appropriate Quality Procedures; Vl C

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TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev. 15 ORGANIL!lTION June 9, 1989 Page 16 of 32 1.2.3.1 Nuclear Power Generation (Cont'd)

Review and comment on Quality Instructions or.

equivalent quality-related administrative procedures prior to issue, with respect to the requirements of the FPL Quality Assurance Program, the PSL Final Safety Analysis Reports and the plant Technical Specifications; Assure that the status is tracked for all PSL open items identified by FPL St. Lucie Projects Quality Assurance group, and inform appropriate management when there is'n indication that a commitment will not be met on time; The interface with the Quality Assurance Procurement 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 St. Lucie Projects Quality Assurance group.

Off-site interfaces for the resolution of quality-related problems and NRC items are with Project Management, Nuclear Engineering, Nuclear Corporate Staff and the architect engineer and Nuclear Steam Supply System Quality Assurance Department.

This group is called upon to audit the St. Lucie operating plant. The St. Lucie Projects Quality Assurance group interfaces with the Site Vice President and his staff on-site by assisting in the resolution of quality-related problems.

The Director - Nuclear Licensing is responsible for coordinating the NRC interface, distributing NRC documents requiring actions,

'valuating potential impact and responding to all NRC action

TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 0

Rev. 15 Date June 9, 1989 Page 17 of 32 1.2.3.1 Nuclear Power Generation (Cont'd) items. He is also responsible for assuring that the status is tracked for all open items identified by the NRC or other federal, local and state agencies and for informing appropriate management when there is an indication that a commitment will not be met on time.

1.2.3.2 Nuclear Corporate Staff 1

The Vice President Nuclear Energy is responsible for the selection, staffing, training and development of personnel required for supervisory and operating continuity of staff groups supporting nuclear power generation. Reporting to the Vice

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President Nuclear Energy are the Director - Nuclear Engineering, Maintenance Manager Nuclear, Manager Nuclear Energy Services, Manager of Nuclear Training and Manager of Planning and Control.

The Nuclear Engineering Department (JPN) is responsible for power plant design-related aspects of the FPL Quality Assurance Program throughout all phases of plant life except as specified for the Fuel Resources Department inSection 1.2.13. This responsibility extends from initial engineering evaluations of plant design-related site characteristics, through preliminary and detailed design, construction, operation and decommissioning.

JPN performs design-related activities and delegates design-related activities to qualified contractors. For activities performed by JPN, the work is governed by FPL's Quality Assurance Program, and JPN is responsible for approval of the design output. Delegated activities are performed in accordance with C an FPL approved Quality Assurance Program and the contractor is "20 Ol C4 0

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TOPICAL QUALITY ASKJRhHCE REPORT TQR 1.0 Rev. 15 Date June 9, 1989

, Page..18 of 32 1.2.3.2 Nuclear Corporate Staff (Cont'd) responsible for approval of design output. JPN 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, JPN ensures that the contractor is technically qualified to perform the design-related activity.

JPN is responsible for development and maintenance of the design control program governing design-related activities performed by JPN and for providing technical'upport to the Quality Assurance Department for assessing the adequacy, implementation and effectiveness of contractor design control programs.

DPN is responsible for the preparation, revision, approval and distribution of plant design drawings that are identified to be maintained as "as constructed" drawings during plant operation.

The Director - Nuclear Engineering reports to the Vice President

- Nuclear Energy as shown in Appendix A, Figure 1-1.

The Director - Nuclear Engineering directs 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 Maintenance Manager Nuclear is responsible for directing activities in support of major plant maintenance projects, modifications and upgradings, as well as the development of work

TOPIChL QUhLZI,'Y hSSURhNCE REPORT TQR 1.0 e

Rev. 15 ORGhNIZhTION Oate June 9, 1989 Page 19 of 32 1.2.3.2 Nuclear, Corporate Staff (Cont'd) methods, specifications and systems to promote increased productivity.

The Manager Nuclear Energy Services is accountable for technical staff support to the generating department and certain centralized special functions. This group consists of section supervisors and technical specialists, with functions including Health Physics, Chemistry, Radiological Waste, Emergency Planning, Plant Support, and Materials, Codes and Inspections.

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

The Manager of Planning and Control - Nuclear directs or coordinates the planning, administration and control of information management, budgeting and cost control, nuclear security, personnel, and rate regulatory activities for the Nuclear Energy Department.

The Manager of Nuclear Security reports to the Manager of Planning and Control and is responsible for coordinating the overall development and implementation of nuclear security policy for the Nuclear Energy Department.

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TOPICAL QlMMY ASSURANCE REPORT TQR 1.0 Rev. 15 Date June 9 1989 Page 20 of 32 1.2.4 Project Management Department The Project Management Department, through the Project General Manager, exercises management control of assigned projects.

This management control begins when a Project is assigned to the Project Management Department and continues until the facility is accepted for operation or the project is complete. This management'control includes the responsibility for coordination of specifications and requisitions, repair, construction and may include preoperational start-up and testing .of power plant modi.fications. The Project Management Department organization is shown in Appendix A, Figure 1-1.

The Director of Projects, reporting to the Vice President - Plant Support, has overall responsibility for the activities of the Project Management Department. A Project General Manager, reporting to the Director of Projects, is responsible for 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.

~ ~aAWCS The ~~~Cedet'aX Manageze is responsible for obtaining from any contractor's management when

.'P'iR" .;; "-'f5ij'.:~/mt. sitf management level and, when ~cessary, can exercise his authority to 4 . n project activities adverse to quality.

The overall responsibility for Plant Changes and Modifications to operating plants is defined in each plant's Technical Specifications. However, frequently the work of installation and administration of Plant Changes and Modifications is assigned

TOPICAL QUhLITY ASSURANCE REPORT TQR 1.0 Rev. 15 ORGhNIZhTION Date June 9, 19/9 Page 21 of 32 1.2.4 Project Management Department (Cont'd) to FPL Project Management Department. The Project Site Manager will report to the appropriate nuclear site Vice President but will also receive guidance and advice from the Project General Manager. The Project Site Manager is additionally responsible for the functional direction of construction Quality Control for the purpose of coordinating inspection activities which implement the quality control aspects of the quality assurance program for modifications of projects assigned to Project Management.

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, whi'ch 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.

t Project Team Members are appointed by their home department heads as the departmental representative on the respective project, when requested by the Project General Manager. Team Members, other than Quality Assurance and Stores Department, report functionally to the Project General Manager, or the Project Site Manager, but continue to receive administrative support and ID technical direction from their home department. Team members CO N are responsible to the Project General Manager for home D

department support to the project.

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TOPICAL QUALITY ASSURANCE REPORT TQR 1. 0 Rev. 15 ORGANIZhTION Oate June 9, 19/9 Page 22 of 32 1.2.5 Corporate Contracts Department The Corporate Contracts Department is responsible for generation, negotiation and issuance of contracts over specified time periods and dollar limits for turbine generators, steam generators, nuclear steam supply systems (NSSS), new items, repairs, constructors, construction managers, and Architect Engineer (A/E) and consulting services. CorporateContracts is also responsible for assuring that technical and quality requirements developed by others are incorporated in such contracts, as appropriate, and that these contracts have the required approvals. Details of the activities of the department in fulfilling this responsibility shall be delineated in the appropriate Quality Procedures. The Manager of Corporate Contracts reports to the Director of Procurement & Material Management. The Corporate Contracts Organization is shown in Appendix A, Figure 1-1.

1.2.6 Environmental Affairs Environmental Affairs is responsible for obtaining the federal and state environmental 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 of Environmental Technical Servic: -, the Manager of Environmental Resources and Planning and the Manager of Environmental Permitting and Programs report to the Director of Environmental Affairs as illustrated in Appendix A, Figure 1-1.

The Director of Environmental Affairs has overall responsibility for implementation of the Environmental Protection Plans at nuclear power plant sites.

TOPICAL QUALZIY hSSURhNCE REPORT TQR 1.0 Rev.

Date June 9, 19/9 Page 23 of 32 1.2.6 Environmental Affairs (Cont'd)

The Environmental Affairs Department through its management of the Company Environmental Review Group (CERG) is responsible for overall coordination of environmental monitoring programs and 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 of Environmental Affairs and the Chairman of the CNRB on environmental matters for which requirements are included in Environmental Protection Plans.

1.2.7 Purchasing The Purchasing Department is responsible for the purchase of materials and services by FPL for its nuclear power plants. with the exception of those materials and services secured by Corporate Contracts and Nuclear Fuels. Materials and services for nuclear safety-related application are secured only from approved suppliers, or as commercial grade, as applicable.

I0 The Department is responsible for assuring that technical and CO CIC quality requirements developed by others are reviewed and approved by the designated quality departments, as applicable, are incorporated in the procurement document which the department Vl 0

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TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev. 15 June 9, 1989 Page 24 of 32 1.2.7 Purchasing (Cont'd) purchase records from acceptance of requisitions through payment of the purchase order invoices.

The Manager of Power Plant Purchasing reports to the Director of Procurement &, Material Management who reports to the Vice President of Corporate Services, Chief Financial Officer as shown in Appendix A, Figure 1-1.

1.2.8 Construction The Juno Construction Management Department (JCM) is responsible for providing direction and coordination regarding construction, supervision and management, equipment utilization, quality control, welding, NDE and other construction support activities.

The Director of Construction reports di'rgctly to the Vice 4 President -Plant Support. He is responsible for directing and administering effective management of the department to ensure compliance to the corporate policies, practices and procedures.

Reporting to the Director of Construction Management . are the Manager of Plant Construction and the Manager of Construction Quality Control, Welding and NDE.

The Manager of Plant Construction is responsible for providing qualified construction support personnel to the Project Site Manager. Reporting administratively to the Manager of Plant Construction are the Lead Construction Supervisors.

The Lead Construction Supervisor is responsible for conformance of project construction activities to the requirements of

TOPIChL QUhLITY hSSURhNCE REPORT TQR 1.0 Rev.:- 15 ORGANIZhTION Oate June 9, 1989 Page 25 of 32 1.2.8 Construction (Cont'd) specifications, codes, regulations and site procedures., He supervises the construction personnel assigned to the project, coordinates construction activities, including the scheduling of construction personnel'requested by the Project Site Manager.

The Manager of Construction Quality Control, Welding and NDE is responsible for directing and administering the Construction Quality Control and Welding Programs and for the technical direction and administrative control of all personnel within the Construction Quality Control and Welding organizations. This includes the development and implementation of policies, plans and procedures to meet the requirements of the Quality Assurance program, codes and standards.

Reporting to the Manager of Construction Quality Control, Welding and NDE are the site Project Quality Control Supervisors, NDE Level III Supervisor, FPL Welding Superintendent and a staff of Quality Control Coordinators.

Construction Quality Control is responsible for providing .

inspections as required, 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 Nuclear Energy Department. It also includes verification of conformance of an item or activity accomplished during this period to quality requirements (e.g.,

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TOPIChL QUhLZFY hSSURhHCE REPORT TQR 1.0 Rev. 15 ORGhNIZhTION Date June 9, ]989 Page 26 of 32 Construction (Cont'd)

Each nuclear power plant is assigned a Project Quality Control Supervisor, who directs the on-site backfit Quality Control organization. The Project Quality Control Supervisor reports administratively and technically to the Manager of Construction Quality Control, Welding and NDE, however, he also reports functionally to the Project Site Manager for the purpose of coordinating and scheduling inspection activities. The functional/administrative reporting roles provide the necessary independence of the site Construction Quality Control organization and also maximizes the communication between the Construction staff, the Quality Control staff and the Nuclear Energy staff.

The Project Quality Control Supervisor is responsible for first line verification of the conformance of backfit activities to quality requirements, specifications, codes and local, State and Federal regulations. He directs on-site implementation of the Construction Quality Control Program which includes supervision, and daily coordination, and scheduling of inspection activities, and review of inspection results. The freedom and independence of the on-site Quality Control organization to assure the effectiveness of the Quality Control Program from pressures of cost and scheduling is derived from the Project Qu lity Control Supervisor's administrative and technical reporting relationship to the Manager of Gcastruction Quality Control, Welding and NDE. Both the Manager of Construction Quality Control, Welding and NDE, and the Project Quality Control Supervisor have the authority to stop work or operations adverse to quality if the need arises.

TOPICAL QUAIZTY ASSURANCE REPORT TQR 1.0 Rev. 15 ORGANIZATION Oate June 9, 1989 Page 27 of 32 1.2.8 Construction (Cont'd)

The NDE Level III Supervisor is responsible d'or directing and monitoring the NDE activities performed under the control of the Construction Management Department. He is responsible for preparation, revision and implementation of NDE procedures, and the training, testing and qualification of the NDE personnel performing these activities. He is also responsible for providing the programs and direction for performance of NDE activities meeting the ASME, AWS and other NDE code requirements.

The Quality Control Coordinators provide staff technical and administrative support to the Manager of Construction Quality Control, Welding and NDE in the preparation, review, issue and monitoring of the Construction Quality Control program to ensure effective implementation.

The FPL Welding Superintendent reports to the Manager of Construction Quality Control, Welding and NDE. His responsibilities are to develop, maintain and control the FPL Welding Control Manual with assistance from Nuclear Engineering, to originate and qualify welding procedure specifications'nd "

qualification of welders and welding operators to meet the applicable code requirements. He provides administrative and technical direction to the personnel within the FPL welding control program to meet engineering welding standards and code requirements., Reporting to the FPL Welding Superintendent are lO the Welding Supervisors at each Nuclear site.

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i TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev. 15 ORGANIZATION June 9, 1989 Page 28 of 32 1.2.9 Power Supply Within the Power Supply Department only equipment and services provided by the System Protection Group and Power Supply Technical Services Group are subject to the requirements of the Quality Assurance Program. Appendix A Figure l-l illustrates the reporting relationship.

System Protection is responsible for test, calibration and maintenance of certain high voltage electrical protective relays for safety-related systems of the nuclear plant. Activities of System Protection include final wiring connection checks, preoperational check-out and test of system protection devices and providing inspection of equipment under their cognizance.

Power Supply Technical Services is responsible for providing certain setpoint and checkpoint values for protective devices.

1.2.10 Inventory Resources The Inventory Resources Department is responsible for the receipt, handling, storage, shipping and issue of items received at the plant site .for control by Inventory Resources. This responsibility encompasses spare and replacement parts and components for plant equipment through all phases of plant life.

During operations, Inventory Resources also performs add'"ional quality-related activities such as handling and segregation for nonconforming items received for stores control. The Manager of Power Plant Stores reports to the Manager of Inventory Resources who reports to the Director of Procurement 8, Material Management as shown in Appendix A, Figure 1-1.

TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev. 15 Oate ]9g9 ORGANIZATION June 9 Page 29 of 32 1.2.11 Company Nuclear Review Board The Company Nuclear Review Board (CNRB) reviews or directs the performance of reviews of activities concerning the technical aspects of the operating nuclear power plant insofar as they impact on 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.

Where necessary, the Board may use consulting services to perform required reviews. The management level to which the CNRB reports is illustrated in Appendix A, Figure 1-1. Its composition is delineated in Section 6.0 of each facility's Technical Specifications. The Senior Vice President responsible for Power Delivery, Construction, Power Plant Engineering, and Projects will perform his CNRB membership duties as Acting Group Vice President.

Subjects within the purview of the Board 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 direction, minutes of meetings or appointed subcommittees.

1.2.12 Nuclear Fuel The Nuclear Fuel Section (FRN) of the Fuel Resources Department is responsible for the procurement, management, and accountability of FPL's nuclear fuel assets, and for providing technical support to fuel users within FPL. The Nuclear Fuel Section is under the direction of the Manager of Nuclear Fuel IA C

0 who has the responsibilities described below:

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TOPICAL QUALMY ASSURANCE REPORT TQR 1.0 Rev. 15 June 9, 1989 Page 30 of 32 1.2.12 Nuclear Fuel (Cont'd)

Forecasting FPL's nuclear fuel requirements and the availability and price of nuclear fuel; Preparing the procurement specifications for components of the nuclear fuel cycle; Determining sources of supply and evaluating alternatives; Making commercial arrangements, including contract negotiations with vendors for acquisition, processing and delivery of nuclear fuel and related services for the nuclear fuel cycle; o 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 contractual obligations are met, and serving as FPL liaison in all matters of nuclear fuel and fuel-related contracts; Providing support to the Quality Assurance Department for their auditing of nuclear fuel design and fuel assembly manufacturing; Performing fuel management and safety analyses of nuclear cores to support plant licensing; Development and/or review of fuel and nuclear physics design; Performing the project management function with respect to nuclear fuel; Reviewing core-related changes to Safety Analysis Reports and Technical Specifications for compliance with design criteria and regulatory requirements;

TOPICAL QUAIZ1Y ASSURANCE REPORT TQR 1. 0 Rev. 15 ORGANIZhTION Date June 9, 1989 Page 31 of 32 1.2.12 Nuclear Fuel (Cont'd)

Participating in start-up physics tests and providing other technical support for operating nuclear power plants; Planning, maintenance and implementation of the Corporate Special Nuclear Materials program.

The Manager of Nuclear Fuel reports to the Director of Fuel Resources as shown in Appendix A, Figure 1-1.

The Fuel Services Section of the Fuel Resources Department is responsible for the accountability reporting of FPL's nuclear fuel assets to other FPL groups, and for providing support in computer code maintenance to the Nuclear Fuel Section (FRN).

The Fuel Services Section is under the direction of the Manager of Fuel Services who has the responsibilities described below:

Provide and maintain computer codes and procedures available for Fuel Resources'ine functions and other departments for daily use in maintaining records, performing safety analysis and core design, reporting of off-site nuclear fuel management activities and providing economic data; Maintain effective and controlled computer access to nuclear applications; Performing audits and coordinating accountability reporting on all nuclear fuel; Develop and provide, to appropriate FPL groups, information necessary to determine FPL's fuel-related costs and to finance fuel-related expenditures.

The Manager of Fuel Services reports to the Director of Fuel Resources.

TOPICAL QUAIZ1Y ASSURANCE REPORT TQR 1.0 Rev. 15 Date June 9, 1989 Page 32 of 32 1.2.13 Corporate Records Services The Manager of Corporate Records Services is responsible for:

ensuring the Quality Assurance records program activities are managed in accordance with applicable laws and regulations; assisting with the development and implementation of effective and compatible records and micrographics programs; developing, approving and maintaining record retention schedules; establishing parameters for indexing in the corporate Record Management System (RMS); locating acceptable records'omputerized record storage areas when requested; storage, retrieval and control of records/documents as requested by other departments; leading the evaluation of specially designated "Quality Assurance approved" storage facilities and maintaining the records of this evaluation. The Corporate Record's Services organization is shown in Appendix A, Figure 1-1.

1,2.14 Documentary Files The Supervisor of Documentary Files is responsible for receiving, maintaining, retrieving and storing the Quality Assurance records in connection with licenses and contracts received from other departments. The Documentary Files organization is shown in Appendix A, Figure 1-1.

ii TOPICAL QUALITYASSURANCE REPORT TQR '2.0 Rev. Draft 9 QUALITYASSURANCE PROGRAM Date 5/9/90 Page 1of 8 GENERAL RE UIREMENTS Florida Power & Light Company has established a Quality Assurance Program which complies with the criteria of 10 CFR 50 Appendix B, and meets the requirements of Regulatory Guides and Industry Standards referenced in Appendix C of this report. The Topical Quality Requirements and attached Policy Statement, together with the Quality Procedures and Quality Instructions document the Program and the FPL policy with regard to Quality Assurance. This Program shall be instituted for each plant site in a schedule consistent with accomplishing the required activity and shall be carried out throughout the life of FPL nuclear plants.

The requirements of the FPL Quality Assurance Program shall only apply to nuclear safety-related structures, systems, and components as identified in the Safety Analysis Report for each nuclear unit. Additionally, the requirements of the FPL Quality Assurance Program shall apply to all FPL, contractor, or consultant organizations performing activities affecting the quality of safety-related structures, systems, and components of FPL nuclear power plants.

Documented procedures shall require and define indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.

Periodic program reviews of the status and adequacy of the FPL Quality Assurance Program shall be accomplished by the independent audit team described in Section 1.2.1.3.a and by Quality Assurance Department audits.

TOPICAL QUALITY ASSURANCE REPORT T R 20 Rev. Draft 9 QUALITYASSURANCE PROGRAM Date 5/9/90 Page 2of 8 2.1 (Continued)

Management of organizations outside Florida Power & Light Company participating in the Program shall be required to regularly review the status and adequacy of that part of the FPL Quality Assurance Program which they are executing. The,FPL Quality Assurance Department shall review and concur in the Quality Assurance Program of contractors.

2.2 IMPLEMENTATION 2.2.1 Goals and Objectives As stated in the Policy Statement of the President of Florida Power & Light Company, the goal of the FPL Quality Assurance Program is to maintain quality levels in an effective and efficient manner, and to assure the high degree of functional integrity and reliability of nuclear safety-related structures, systems, and components. To meet this goal, the following objectives of the FPL Quality Assurance Program have been defined:

Define through documented procedures and instructions the quality activities that apply to the design, fabrication, procurement, modification, testing, operation, refueling, maintenance, and repair of nuclear power plants; .

b. Establish, assign, and document the responsibilities for those activities affecting quality of safety-related structures, systems, and components; C. Establish confidence that the design, fabrication, modification, and operation of nuclear power generation facilities are performed in a manner consistent with FPL policies by assuring quality-related activities are performed by responsible personnel; Apprise management of unresolved problems and trends which could have a

'significant effect on nuclear power plant safety; and

e. Prevent schedule delays and high cost due to poor quality.

TOPICAL QUALITYASSURANCE REPORT TQR 2.0 Rev. Draft 9 QUALITY ASSURANCE PROGRAM Date 5/9/90 FPL Page 3ot 8 2.2.2 Program Documentation The Topical Quality Assurance Report, which defines the policy, goals, and objectives regarding the Quality Assurance Program, shall be contained in the FPL Quality Assurance Manual, and used as guidance for the development of corporate level Quality Procedures which are also contained in the Quality Assurance Manual. Revisions to the Topical Quality Assurance Report will be made, as needed, to reflect current FPL program requirements and descriptions of activities. These revisions shall be made in accordance with a Quality Procedure. If a program revision reflects a reduction of the commitments from the baseline documents contained in Appendix C, the revision shall be submitted to and approved by the NRC prior to implementation. In all other cases, amendments to the Topical Quality Assurance Report will be submitted to the NRC to reflect implemented program revisions on an annual or more frequent basis.

Quality Procedures shall be written by the department with major responsibilities for an activity, or by the Quality Assurance Department when requested. These dp Assurance.

Appendix E.

'lh -pl fbi'& ~Vi procedures shall be reviewed by all the departments with responsibility for some portion of that procedure, and shall be approved by the major implementing A listing of corporate level Quality Procedures'is P id t N contained in Each Quality Procedure shall be written to further address criteria contained in the Topical Quality Requirements and to further define the FPL Quality Assurance policies, plans, and program where action is required by more than one department.

TOPICAL QUALITYASSURANCE REPORT TQR 2.0 Re" Draft 9 QUALITY ASSURANCE PROGRAM 5/9/90 Page 40f S 2.2.2. (Continued)

Each department head shall have the responsibility for implementation of the Quality Assurance Program, which includes compliance with procedure requirements applicable to his department. In addition, he shall be responsible for the preparation, approval, and distribution of Quality Instructions, operating procedures, testing procedures, or other instructions where further guidance is necessary for implementation of the Quality Assurance Program requirements within his department. Quality Instructions shall be reviewed by the Quality Assurance Department at each revision.

2.2.3 Structures, Systems, and Components The requirements of the FPL Quality Assurance Program shall apply to nuclear safety-related structures, systems, and components, as defined in the SAR.

Safety-related structures, systems, and components are listed as those necessary to assure the integrity of the reactor coolant boundary, the capability to shutdown the reactor and maintain it in a safe shutdown condition, or the capability to prevent or mitigate the consequences of accidents which could result in off-site exposures

- comparable to the guideline exposures of 10 CFR 100.

Control over activities affecting the quality of safety-related structures, systems, and components shall be to the extent consistent with their importance to safety.

Such control shall include use of appropriate equipment, establishment of suitable environmental conditions, and assurance that all prerequisites for a given activity have been satisfied. The Program shall provide for controls over special processes and skills necessary to attain the required quality, and the need for verification of quality by inspection and test.

TOPICAL QUALITYASSURANCE REPORT T R 20 Rev. Draft 9 QUALITYASSURANCE PROGRAM Date 5/9/90

@PL Page Sot 8 2.2.3 (Continued)

Advance planning is required, for the control of management and technical interfaces between FPL and contractors, during the phase-out of design and construction and during preoperational testing and plant turnover. This is achieved through periodic meetings of concerned organizations and the development of procedures which define responsibilities and interfaces, and control the testing and turnover of plant systems to FPL.

P 2.2.4 Participating Organizations The FPL organizations with responsibilities for activities affecting quality of nuclear safety-related structures, systems, and components are identified in TQR 1.0, which also briefly describes their assigned responsibilities.

Florida Power & Light Company may delegate activities to contractor organizations and equipment vendors. Delegated activities are subject to the external organization's FPL approved Quality Assurance Program or the FPL Quality Assurance Program, or some FPL approved combination thereof.

However, FPL shall retain overall responsibilities for the Quality Assurance Program. Procurement documents shall define the scope of delegated activities, as well as Quality Assurance Program requirements that shall govern these activities.

The Quality Assurance Department shall review and approve the Quality Assurance Program governing contracted activities prior to award of contract except for activities for which the output is of a conceptual and/or prototype nature. In all cases, final approval shall occur at a point in the process to ensure that the output complies with the requirements of the FPL approved Quality Assurance Program. The object of this review shall be to verify that the program is in compliance with the applicable requirements of Appendix B, 10CFR50, and

TOPICAL QUALITY ASSURANCE REPORT T R 20 0 QUALITY ASSURANCE PROGRAM Rev.

Date Draft 9 5/9/90 Page 60f 8 ANSI N45.2. Audits shall be conducted periodically to verify the acceptable implementation of the contractor's FPL approved Quality Assurance Program governing delegated activities. The Quality Assurance Department is responsible for conducting these audits. The initial review and periodic audits shall be performed by qualified Quality Assurance Department personnel, and as appropriate, by technical specialists from other FPL departments and contractor organizations.

2.2,5 Indoctrination and Training A program shall be established and maintained for quality assurance indoctrination, and for training which assures that the required level of personnel competence and skill is achieved and maintained in the performance of quality related activities. Quality Procedures shall delineate the requirements for an indoctrination program to assure that personnel responsible for performing quality activities are instructed in the purpose, scope, and implementation of the quality related manuals, instructions, and procedures and that compliance to these documents is a mandatory requirement.

Quality Procedures shall also require the head of each department (including the Quality Assurance Department) to be responsible for a training plan which assures that personnel performing quality related activities are trained in the principles and techniques of the activity being performed. This training shall maintain the proficiency of personnel in the skills necessary for the quality related activities through retraining, requalifiication or reexamination, as appropriate. When personnel are assigned to perform their functions under the direction of personnel from other than their home department, the department head of the organization providing direction is responsible for the indoctrinaton and training of personnel who perform quality-related activities under his direction.

i TOPICAL QUALITYASSURANCE REPORT TQR 2.0 Rev. Draft 9

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QUALITY ASSURANCE PROGRAM Date 5/9/90 APL Page 70f 8 2.2.5 (Continued)

Quality Procedures shall specify the requirements for documenting indoctrination and training sessions, including a course description, attendance, location, and date.

2.2.6 Management Participation In addition to the involvement of department heads in implementing the Quality Assurance Program within their departments and the involvement of the X4reeter-Vi F id t N I A d U Quality Manager - Juno Beach in the development, coordination, and review of the Program,'he Company Nuclear Review Board (CNRB) shall be apprised of the status and adequacy of the Quality Assurance Program on a periodic basis. The following actions shall be instituted to assure that the CNRB remains informed and meets its Program responsibilities:

The Cemmhtee CNRB shall review a summary of the results of management level Quality Assurance audits of FPL Departments.

b. The Quality Assurance Department shall circulate monthly reports of quality-related activities to members of the CNRB and affected department heads. The monthly reports may include such items as the status of audits, a summary of audit findings, the status of development projects, and descriptions of policy matters or problems requiring management attention.

C. The CNRB shall review the status of the Quality Assurance Program on a semiannual basis. The review will include assessment of the Program goals, objectives, and accomplishments.

TOPICAL QUALITY ASSURANCE REPORT T R 20 Re" Dna 9 QUALITYASSURANCE PROGRAM 5/9/90 Page 80f 8 2.2.6 (Continued)

Periodic audits of the Quality Assurance Department and Program shall be conducted by an independent audit group under the direction of the Chairman of the CNRB. This audit group shall employ FPL audit procedures and shall distribute the audit report to the Vice President Nuclear Assurance, and to the CNRB for review of findings and corrective action. Auditor certifications of independent audit teams will be retained by the Quality Assurance Department.

The programs of contractor organizations that perform quality related activities shall be reviewed by Quality Assurance to assure that their management regularly reviews the status and adequacy of that part of the FPL Quality Assurance Program which they are executing.

i TOPICAL QUALITY ASSURANCE REPORT TQR 3.0 e DESIGN CONTROL Rev.

Date Draft 8 5/30/90 Page 10< 6 3.1 GENERAL RE UIREMENTS A Quality Assurance Program shall be established for design-related activities.

This design control program shall ensure that the design is defined, controlled and verified; that applicable design inputs are specified and correctly translated into design output documents; that design interfaces are identified and controlled; that design adequacy is verified by persons other than those who designed the item; and that design changes, including field changes, are governed by control measures commensurate with those applied to the original design.

Design records shall be developed to provide evidence that the design process and design verification were performed in accordance with the requirements of FPL's Quality Assurance Program. The design organization (Nuclear Engineering ,the .

or designated contractor organization) shall be responsible for the content of these records.

Design records shall include design output documents and the important steps in the design effort. The intent of this documentation is to allow a technically qualified person to understand how the design was developed, and to allow that person to verify the design based on the design documentation and engineering data sources referenced therein.

3.2 IMPLEMENTATION The design organization's Quality Assurance Program for design control shall be approved by the FPL Quality Assurance Department prior to the release of approved design output by the design organization. The design organization is the organization responsible for approval of design output.

TOPICAL QUALITYASSURANCE REPORT T R 3.0 Rev. Draft 8 DESIGN CONTROL Date 5/30/90 Page 20' 3.2 (Continued)

Quality Procedures and Quality Instructions shall be developed to delineate design control requirements governing design-related activities performed by Nuclear Engineering and for the4: delegating activities to contractor organizations.

3.2.1 Design Process The design organization shall specify and document its design activities to the level of detail necessary to permit the design to be developed in a correct manner and to permit verification that design output, documents satisfy design input requirements.

Design methods, materials, parts, equipment and processes, iricluding those associated with commercial grade items that are essential to the function of the structure, system or component shall be selected, reviewed and approved for suitability of application by the design organization.

Design inputs shall be identified, documented, reviewed and approved by the design organization. They shall be specified to the level of detail necessary to permit the design activity to be carried out in a correct manner, and to provide a consistent basis for making design-related decisions, performing design.

verification and evaluating design changes. Changes to approved design inputs, including the reason for the changes, shall be approved, documented and controlled by the design organization.

The design organization shall identify aspects of manufacture, construction, inspection and testing critical to achieving the function of the structure, system or component. Quality standards and quality requirements shall be specified on

>> design output or procurement documents. Changes from approved quality-related

TOPICAL QUALITYASSURANCE REPORT TQR 3.0 Rev.

DESIGN CONTROL Date 5/30/90

@PL Page 3 of 6 3.2.1 (Continued) requirements specified in design output, including the reason for the changes, shall be approved, documented and controlled by the design organization.

Design analyses shall be controlled and documented. Approved design output documents and approved changes thereto shall be relatable to the design input by documentation in sufficient detail to permit verification. The design organization shall establish procedures to review industry design experience. As appropriate, this experience shall be made available to cognizant design personnel.

3.2.2 Design Change Control Changes to approved design output documents, including field changes, shall be justified, subjected to control measures commensurate with those applied to the .

original design, and shall be reviewed and approved by the same design organization that approved the original design unless other organizations are specifically designated.

Where a significant design change is necessary because of an incorrect design, as ayprepaate, Nuclear Engineering shall determine the cause of the incorrect design. As necessary, design and verification procedures shall be reviewed and modified to correct the cause of the incorrect design.

plant management 'nd During the operations phase, design changes shall also be reviewed by operating Quality Control. The intent of this review is to ensure that implementation of the design change is coordinated with any necessary changes to operating procedures and practices, and required Quality Control Surveillance activities.

TOPICAL QUALITYASSURANCE REPORT T R 3.0 0 DESIGN CONTROL Rev.

Date Page Draft 8 5/30/90 40' 3.2.2 (Continued)

In accordance with plant technical specification requirements, nuclear safety-related design changes are reviewed by the Plant Nuclear Safety Committee (PNSC) or Facility Review Group (FRG) and the Company Nuclear Review Board (CNRB).

3.2.3 Design Interface Control The design organization shall be responsible for identification, control, resolution and documentation of design interface requirements. Procedures shall establish interface controls between participating organizations and between the various technical disciplines within the design organization. These procedures shall include the assignment of responsibility, and be in sufficient detail to cover the e preparation, review, approval, release, distribution and revision documents.

of design output For interdisciplinary design, approval documentation of each involved discipline

,of the design organization shall appear on the design output document or on a separate document directly traceable to the design output. The design organization shall designate a discipline(s) responsible for resolution of the comments of participating organizations. The designated discipline(s) approval of a design output shall. also document resolution of the comments of participating.

organizations.

3.2.4 Design Verification Ch Design control measures shall be established to independently verify the design IV inputs, design process, and that design inputs are correctly incorporated into design output. The design organization shall develop procedures that govern design verification. These procedures shall require that the design organization

TOPICAL QUALITY ASSURANCE REPORT T R 3.0 Rev.

Draft 8 Date DESIGN CONTROL 5/30/90 APL Page 5 of 6 3.2.4 (Continued) identify and document the verification method utilized and that the documentation clearly identify those individuals performing the design verification.

Design verification shall be performed by technically qualified individual(s) or group(s) other than those who performed the design. The original designers and verifiiers may both be from the design organization. Design verification by the 1

designer's immediate supervisor shall be limited to those instances where the supervisor is the only qualified individual available within the design organization. These instances are further restricted to designs 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.

The design organization'shall be responsible for determining the extent of design verification and methods to be employed. The methods may include one or more of the following: the performance of design reviews, the use of alternate calculations, or the performance of qualification tests. This shall apply to original design and to changes to approved design output. Where reverification is not required for a design change, the bases shall be documented by the.design organization. Cursory supervisory reviews and mathematical checks for calculation accuracy do not satisfy the independent design verification requirement.

Design verification shall normally be completed prior to release of design output for procurement, manufacture or release by the design organization for use in design activities by a participating organization. Verification shall be conducted based on the status of design at the time of release of design documents. Where this timing cannot be met, verification may be deferred provided that the

TOPICAL QUALITY ASSURANCE REPORT T R 3.0 e DESIGN CONTROL Rev.

Date Draft 8 5/30/90 Page 60' 3.2.4 (Continued) unverified portion of the design output, and all design output documents,

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structures, systems and components based on the unverified portion of design are identified and controlled. In all cases verification shall be completed prior to relying on any affected items to perform their design functions.

3.2.5 Computer Cedes ProgramslSoftware Organizations utilizing computer eedes programs/software as 'a method for design shall maintain instructions or procedures to effect the following:

1. That such eche programs/software are verified for their particular use using benchmark problems, alternate calculations, comparison with other cede programs/software or experimental results, design review or similar methods,

2. That such eedee programs/software have been qualified for their specific application sufficient to ensure valid results,

3. That such eedee programslsoftware are provided with user instructions sufficient for a technically competent individual to follow,

4. That configuration controls are provided to assure that such cede programslsoftware changes or modifications are documented and controlled.

TOPICAL QUALITYASSURANCE REPORT TQR 4.0 Re~. Draft 4 PROCUREMENT DOCUMENT Date 5/8/90 CONTROL FPL Page I of 3 4.1 GENERAL RE UIREMENTS 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.

4.2 IMPLEMENTATION 4.2.1

~ ~ Procurement Document Provisions Quality Procedures and Quality Instructions shall identify the responsibilities and actions required of the organizations originating, reviewing, approving, and controlling procurement documents. These procedures shall require. the procurement documents to specify:

L The scope of work to be performetL

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.

TOPICAL QUALITYASSURA.NCE REPORT TQR 4.0 Rev. Draft 4 PROCUREMENT DOCUMENT Date 5/8/90 CONTROL FPL Page 20f 3 4.2.1 Procurement Document Provisions (Cont'd)

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 quality assurance records which will not be delivered to FPL shall be prescribe 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.

The preparation and control of design documents and purchase orders is described in TQR 3.0.

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 includetL This review shall be documented and performed by designated technical and quality evaluators, and shall assure that the procurement document was prepared, reviewed and approved as required. Spare or replacement parts for safety-related

TOPICAL QUALITY ASSURANCE REPORT TQR 4.0 Rev. Draft 4 PROCUREMENT DOCUMENT Date 5/8/90 CONTROL Page 3 of 3 4.2.2(Continued) 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 7 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 if the 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.

TOPICAL QUALITYASSURANCE REPORT TQR 5.0 Rev. Draft 9 INSTRUCTIONS, PROCEDURES Date 5/30/90

& DRAWINGS Page 10f 3 5.1 GENERAL RE UIREMENTS Activities affecting quality of nuclear safety-related structures, systems, and components shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. These documents shall include appropriate quantitative criteria such as dimensions, tolerances, and operating limits, and qualitative criteria such as comparative workmanship samples, to assure that the quality assurance activity has been satisfactorily accomplished.

5.2 IMPLEMENTATION 5.2.1 Quality Assurance Program Documents The FPL Quality Assurance Manual described in TQR 2.0 contains corporate Quality Procedures which comply with the criteria of 10 CFR 50, Appendix B.

Quality Procedures and department level Quality Instructions provide direction for activities affecting quality. The Quality Assurance Department reviews and comments on Quality Instructions written by other departments. Comments concerning compliance with corporate Quality Assurance commitments and regulatory requirements are resolved prior to issuance. The Quality Assurance Department receives controlled copies of Quality Instructions issued by other'epartments.

5.2.2 Procedures and Instructions Instructions and procedures for activities affecting quality shall be prepared, reviewed, and approved in accordance with written Quality Procedures or Quality Instructions.

TOPICAL QUALITYASSURANCE REPORT T R 5.0 Rev.

Draft 9 INSTRUCTIONS, PROCEDURES Date 5/30/90 8c DRAWINGS Page 2 of 3 5.2.2 (Continued)

For plant operations, on-site plant procedures shall be prepared, reviewed, and approved in accordance with written instructions which includes a review for concurrence by Quality Assurance or Quality Control personnel. These plant procedures include operating procedures, off-normal and emergency procedures, test procedures, and calibration procedures. Also included are maintenance and repair procedures for subcontracted maintenance and repair activities which are outside the normal scope of plant craft capability.

For backfit activities, contractors shall be required to have Quality Assurance Programs which contain written instructions for preparation, review, and approval pp ~ ly or Me designee, personnel IWL ~St of procedures, instructions, and drawings affecting quality. In addition, Contractor's site procedures and Quality Control inspection procedures shall be C t ti ~ i following reviews by Quality Assurance or Quality Control to assure compliance with Corporate commitment and regulatory M g requirements.

Q duly A surveillance implemented.

activities shall assure Contractor programs Ch dl that such

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During the design, modification, and procurement phases, the Architect/Engineer or other contractors may be delegated responsibility for maintaining, issuing and verifying the implementation of appropriate program documents. In this case, Dp measures shall clearly delineate accomplished in the preparation, review and control of are Qaily C established the actions and to be instructions, procedures-and drawings, and the methods for complying with the appropriate criteria of 10 CFR 50, Appendix B. A plant change or modification of a magnitude requiring the assignment of a Site Construction Services Manager shall be subject to the Quality Assurance Program as discussed 4 above.

TOPICAL QUALITYASSURANCE REPORT T R 5.0 Rev.

Draft 9 INSTRUCTIONS, PROCEDURES Date 5/30/90

& DRAWINGS Page 3 of 3 5.2,3 Drawings dig dd ig 'ii,~N 1 Eji 'g~

The design organization is responsible for review and approval of drawings.

Feet Department may approve changes to drawings. The technical control of drawings, i.e., review and approval of the drawing and all changes thereto shall For be governed by procedures. A means shall be developed and updated as required to identify approved drawings and revisions thereto. A Master Drawing List is the normal means used for this.

5.2.4 Acceptance Criteria Quality Procedures and Quality Instructions require that quality-related instructions, procedures, and drawings include adequate quantitative and qualitative acceptance criteria, as appropriate, for determining satisfactory work performance and quality compliance. These acceptance criteria requirements apply to important activities such as design, operations, test control, inspection, and plant modifications.

TOPICAL QUALITY ASSURANCE REPORT TQR 6.0 Rev. Draft 7 DOCUMENT CONTROL Date 5/8/90 Page log 3 6.1 GENERAL RE UIREMENTS The distribution of documents such as instructions, procedures, aad drawings, and software which provide guidance, specifications, or requirements'affecting the quality of nuclear safety-related structures, systems, and components shall be controlled.

These documents shall be prepared, reviewed for adequacy, and approved for release by authorized personnel in the effected affected organization. These documents shall be

'I distributed to locations where the activity is performers Changes to controlled documents shall be so identified and shall be reviewed and approved by the same organization that performed the original review and approval unless otherwise specified in the implementing procedures. In'ddition, procedures shall provide for controlling obsolete documents to preclude the possibility of use of documents. 'utdated 6.2 IMPLEMENTATION Responsibility Quality Procedures shall delineate the control measures for controlled documents including direction for the review for adequacy, approval by authorized personnel, distribution of controlled documents and verification that changes are received. These control measures shall apply to documents affecting the quality of nuclear safety-related

='.2.1 structures, systems, and components such as:

L design specifications;

b. design, manufacturing, construction, and installation drawings;

c. quality program manuals, procedures, and instructions; inspection, manufacturing, and test procedures and instructions; 8 e. plant operating and maintenance procedures;

f. plant Safety Analysis Reports and related design criteria documents.

TOPICAL QUALITY ASSURANCE REPORT TQR 6.0 Rev. Draft 7 DOCUMENT CONTROL Date 5/8/90 Page 2 of 3 6.2.1 (Continued)

The requirements for control of procurement documents are contained in TQR 4.0.

During all phases of the plant life, it shall be the responsibility of each organization issuing and using controlled documents to use document control procedures. Procedures shall document the responsibility for review, approval, maintenance and distribution of documents including assuring revisions are initiated to interfacing documents within their organization.

During the design and construction phase and for operating plant changes under their cognizance, the Architect/Engineer, Nuclear Steam Supply System vendor, and other contractors shall be responsible for assuring that all revisions required as a result of FPL comments, nonconformances, or engineering work are incorporated into revised documents.

6.2.2 Distribution of Controlled Documents Quality Procedures shall specify that controlled documents and revisions be distributed to locations where the activity is performed.

6.2.3 Drawing Control FPL assumes control of the drawings and Master Drawing List after initial operation of I

the facility or delegates this activity to a qualified contractor. Nuclear Engineering shall require that participating design organizations update the drawings and Master Drawing List to reflect the as-built conditions of the facility prior to FPL's acceptance of these documents.

Maintenance, distribution and control of the drawings and the Master Drawing List by 2

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FPL during the operation phase shall be assigned to a drawing custodian. Revision to drawings shall be approved prior to release by the drawing custodian, approval shall be d ig td d ig CV E

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TOPICAL QUALITYASSURANCE REPORT T R 60 Rev. Draft 7 Date DOCUMENT CONTROL 5/8/90 Page 3 of 3 6.2.3 (Continued)

During the operation phase a system shall be established to provide ready access and availability of. drawings to engineering and operations personnel; to identify drawings affected by approved plant design changes; and to update drawings and the Master Drawing List to reflect implemented design changes.

6.2.4 Instruction & Procedure Control Participating organizations shall be responsible for development, maintenance and control of those documents identified in paragraph 6.2.1 issued by them as controlled documents. Each organization shall be responsible for the adequacy of their procedures.

6.2.5 Obsolete Documents Controls established by Quality Procedures and Quality Instructions shall assure that outdated copies of controlled documents are not inadvertently used.

TOPICAL QUALITY ASSURANCE REPORT TQR 7.0 Rev. Draft 6 CONTROL OF PURCHASED Date 5/14/90 ITEMS & SERVICES Page 1 of 3 7.1 GENERAL RE UIREMENTS Measures shall be established to assure that safety-related items or services purchased by or for FPL conform to the requirements of the procurement document. These measures shall include documented evidence of source selection, verification activities and examination of items or services to assure compliance with the procurement document. The- effectiveness of the control of quality by contractors and subcontractors shall be assessed at intervals consistent with the importance, complexity, and quantity of the product or service.

7.2 IMPLEMENTATION 7.2.1 Initial Evaluation of Suppliers Procurement source evaluation and selection measures shall be specified in Quality Procedures and Quality Instructions which shall identify the responsibility of qualified individuals for determining supplier capability. The evaluation may require integrated action involving Quality Assurance and one or more organizations (e.g., Nuclear Engineering, Nuclear Construction Services, or Nuclear Materials Management) based upon the item or service being procured.

This evaluation is to ensure that the FPL contractors comply with the applicable,.

portions of 10 CFR 50, Appendix B. Documented evidence of the evaluation, and the acceptance of the contractor's quality program and procedures shall be retained in the Quality Assurance Department files. The determination of supplier approval shall be based on such factors as prior performance, historical quality performance data, source surveys or audits, and evaluation of the supplier's Quality Assurance Program. The basis shall be consistent with the importance, complexity, and quality required for the items or services involved.

TOPICAL QUALITYASSURANCE REPORT TQR 7.0 Rev. 'raft 6 CONTROL OF PURCHASED Date 5/14/90

. ITEMS & SERVICES Page 2 of 7.2.2 Verification Activities Quality Procedures shall define the requirements for verification activities such as surveillance, inspection, or audit to assure conformance of procured items and services to identified requirements. These verification activities shall be performed in accordance with written procedures, procurement documents and their references, which specify the documentation required and the characteristic or process to be witnessed, inspected, verified, or accepted. FPL verification activities shall be accomplished by qualified personnel to verify that the supplier complies with quality requirements, and depending on the importance/complexity, shall be performed on those items where verification of procurement requirements cannot be determined upon receipt.

7.2.3 Receiving Inspection Quality Procedures and Quality Instructions shall delineate requirements and responsibilities for the performance of receiving inspection. This inspection shall verify that suppliers have fulfilled their contractual obligation and that the procured items meet the appropriate quality requirements. Receiving inspection shall include, as appropriate:

a. Measures for verifying that the shipment is complete, properly identified, undamaged, and corresponds with the purchase order documentation;

b. Measures for inspection of the item and review of supporting documentation (e.g., mill test reports, NDE reports) as required by the purchase documents; C. Measures for disposition of items to inspection instructions; Measures for identifying and controlling items including identification of inspection status prior to release from the receiving inspection area;

e. Measures to ascertain that inspection records or Certificates of Conformance are available prior to release.

TOPICAL QUALITYASSURANCE REPORT TQR 7.0 Rev. Draft 6 CONTROL OF PURCHASED Date 5/14/90 ITEMS & SERVICES FPL Page of 7.2.4 Supplier Furnished Records Records required to be furnished by the supplier shall be specified in the procurement document. Certifications or documentation verifying conformance provided by the supplier shall identify the specific procurement requirements met (either by reference to the purchase order or by referenced requirements therein). Such certification shall identify any procurement requirements which have not been met and provide a description of those nonconformances dispositioned "accept as is" or "repair".

TOPICAL QUALITYASSURANCE REPORT TQR 9.0 Rev. Draft 8 CONTROL OF SPECIAL PROCESSES Date 5/8/90 Page lot 3 9.1 GENERAL RE UIREMENTS Measures shall be established to assure that special processes such as welding, heat treating, and nondestructive examination, are controlled and accomplished by qualified personnel using qualified procedures and equipment in accordance with applicable codes, standards, specifications, criteria, and other special requirements.

9.2 IMPLEMENTATION

'I Nuclear Engineering, or the delegated contractor organization, as appropriate, shall include special process requirements in their design outputs and changes thereto. Special processes used during plant operations shall be the responsibility of the plant manager, who shall ensure that procedures are developed, reviewed, approved and controlled, and that personnel and equipment are qualified.

9.2.1 Identification of Special Processes Special processes are those processes which must be qualified and controlled where quality is highly dependent on close control of process variables or operator skills, and objective verification (inspection, examination or testing) of end quality is difficult.

As a further clarification, special processes identified as such by applicable codes and standards shall be controlled, qualified, and implemented in accordance with those codes and standards. Examples of special processes include (but are not limited to) welding, heat treating, and nondestructive examination. Others, i.e.,

flushing, protective coating, plating applications and nuclear cleaning should be 1

reviewed to determine if they are special processes.

TOPICAL QUALITYASSURANCE REPORT TQR 9.0 Draft 8 CONTROL OF SPECIAL PROCESSES 5/8/90 Page 2of 3 9.2.2 Procedure Qualification and Control Process control procedures written by FPL organizations or their'contractors shall be used and qualified as required by applicable specifications, codes, or standards.

Where FPL assigns work to outside contractors, the contractors shall make. their procedures and personnel qualifications available for review to FPL prior to the start of work. The ArchitectfEngineer, Nuclear Steam, Supply System vendor, or other organization designated by FPL shall be responsible for the evaluation and acceptance of on-site contractor special process procedures, and shall interface with the appropriate FPL department, as necessary, to resolve review comments with the contractor. The contractor shall also be responsible for the control and approval of sub-contractor procedures.

9.2.3 Personnel Qualification and Certification Procedures or instructions shall specify personnel qualification and certification requirements. Personnel responsible for the performance and .verification of special processes shall be trained, tested, and certified as required by applicable specifications, codes and standards. Requirements for the period of certification, retesting, and recertification of personnel shall also be specified. Contractors shall qualify personnel and maintain records of qualified personnel in accordance with applicable codes, standards, specifications, and contract or procurement document requirements.

9.2.4 Special Process Records'he Plant Manager is responsible. for the review and retention of records.

Records shall provide objective evidence that special processes were performed in compliance with approved procedures by qualified personnel and equipment.

Records shall also be maintained for verification activities when required by

TOPICAL QUALITYASSURANCE REPORT TQR 9.0 R'" Draft 8 CONTROL OF SPECIAL PROCESSES Date 5/8/90 Page 3 of 3 9.2.4 (Continued) procedure, code or specification. Results of nondestructive examinations shall be recorded in accordance with applicable specifications, codes and standards. These records shall be retained by the vendor or supplied to FPL as required by contract or purchase orders. If records are to be retained by the vendor, the contract or purchase order shall specify the retention period and instructions" for final disposition of such records.

P b bB<<ii',b ~C'l llpC l g l*'

for the review of nondestructive examination documents for acceptance.

p lbl The Mt C g l M g l p lbl l assuring that documents for special processes utilized for modifications are properly collected, reviewed, accepted and transmitted for retention of records.

f TOPICAL QUALITYASSURANCE REPORT TQR 10.0 0 INSPECTION Rev.

Date Page Draft 9 5/30/90 10f 5 10.1 GENERAL RE UIREMENTS A program for inspection shall be established and executed by or for FPL to verify conformance with the documented instructions, procedures and drawings for accomplishing an activity. Such inspections shall be performed by individuals or groups other than those who performed the activity being inspected. Examinations, measurements and tests of materials or products processed shall be performed for each work operation, where necessary, to assure conformance to established requirements. If direct inspection of processed materials or products is impossible or disadvantageous, indirect control by surveillance or monitoring shall be provided. Mandatory inspection, witness, or hold points beyond which work shall not proceed without the consent of FPL or a designated representative shall be indicated in the appropriate documents.

102 IMPLEMENTATION 10.2.1 Inspection Responsibilities

~Q For plant operations, maintenance, or modification activities, a program for on-site inspection of activities affecting quality shall be established by the Nuclear Saeva y yyp lpyc t y yappy y p surveillance and monitoring of plant activities ~~aalu including operations, maintenance or modifications as required by established plans, schedules and/or procedurally required inspection,'witness or hold points. In all cases, the personnel performing the inspection shall be independent of the group performing the work.

1

I TOPICAL QUALITYASSURANCE REPORT INSPECTION Rev.

Oate T R Draft 9 5/30/90 10.0

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Page 2 of 5 10.2.1 (Continued) p p pp pip . p Nuclear Assurance Department may delegate the establishment and execution of this program to a contractor or other designated FPL representative, but shall retain ultimate responsibility for the program.

For preoperational start-up and testing of plant modifications, Nuclear Raergy Division personnel may report functionally to the Site Construction Services Manager and establish plans, schedules and procedurally required inspection, witness or hold points. In all cases, the personnel performing the inspection shall be independent of the group performing the work.

The System Protection Group may perform inspections of equipment within their purview during operations. Inspections shall be performed in accordance with approved, written procedures by qualified personnel.

Quality Procedures and Quality Instructions shall be written which delineate the requirements and responsibilities for the performance of inspections.

Documented inspection plans may be either a separate document or an integral part of work instruction documents. The plans shall be based on design specifications, procurement documents, drawings, other specifications or previous experience, as appropriate. Inspections shall be scheduled to assure that sufficient time and resources are available, and to assure inspections are not inadvertently omitted or bypassed.

TOPICAL QUALITYASSURANCE REPORT T R 10.0 e INSPECTION Rev.

Date Draft 9 5/30/90

@PL Page 3 of 5 10.2.2 Inspection Plans and Schedules Documented inspection plans may be either a separate document or an integral part of work instruction documents. The plans shall be based on design specifications, procurement documents, drawings, other specifications or previous experience, as appropriate. Inspections shall be scheduled to assure that sufficient time and resources are available, and to assure inspections are not inadvertently omitted or bypasseL 10.2.3 Inspection Personnel a - Inspections shall be performed by individuals other than those who performed or directly supervised the activity being inspected. Inspection personnel shall be qualified and certified in accordance with appropriate codes, standards and/or company training programs. Qualifications and certifiications shall be kept current.

b. Prior to performing inspections, inspection personnel shall have access to the drawings, procedures, specifications or other documented criteria necessary for performance of the inspection.

10.2.4 Inspection Procedures Required inspection, surveillance or monitoring activities shall be performed and documented according to written, approved instructions or procedures. Inspection procedures, instructions or checklists shall contain the following:

o Identification of characteristics to be inspected; o Identification of the individual or groups responsible for performing the, inspection; o Acceptance criteria or reference to the acceptance criteria; o A description of the method of inspection; o Verification of completion and certification of inspection.

TOPICAL QUALITYASSURANCE REPORT TQR 10.0 Rev. Draft 9 INSPECTION Date 5/30/90 Page 4 of 5 10.2.4 (Continued)

b. Inspection records shall identify:

o Inspector or data recorder, o Method or type of observations; o Test or inspection results; o Statement of acceptability; o Date of observation; o Deficiencies and nonconformances, and 'the action taken in connection with these deficient conditions, either by inclusion or by reference to other documents.

c. Inspection procedures shall be reviewed by QC personnel to determine the need for an independent inspection and the degree and method if such an inspection is required, and to assure the identification of inspection personnel and the method of documentation of inspection results.

d. Written approved instructions shall specify surveillance or monitoring of processing methods, or testing and operation of equipment when inspection is impossible, inaccessible or not applicable.

e. Modification, repair, replacement or rework items shall be inspected in accordance with original inspection requirements or acceptable alternatives.

10.2.5 Inspection, Witness, and Hold Point Identification Appropriate inspection, witness or hold. points shall appear in process documents (e.g.,

construction, testing, operating and maintenance procedures). These process procedures are subject to the review of the apprepaate Quality Control organization for adequacy of inspection, witness, and hold points.

lI TOPICAL QUALITYASSURANCE REPORT TQR 10.0 Rev. Draft 9 INSPECTION Date 5/30/90 Page 5 of 5 10.2.5 (Continued)

Mandatory hold points shall be used when witnessing and inspecting must be performed and signed-off by the responsible personnel before work can proceed.

FPL shall indicate FPL witness or hold points applicable during the manufacture of an item in procurement documents. A distinction shall be made between witness points and mandatory hold points.

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TOPICAL QUALITY ASSURANCE REPORT TQR 12.0 Rev.

CONTROL OF MEASURING AND TEST EQUIPMENT Sept. 1, 1989 Page 1 of 1'2. 1 Measures shall be established to assure that tools,, gages, instruments, and other measuring and testing devices used In activities affecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits. It Is the responsibility of each department maintaining calibrated instruments to provide for the calibration and control of such instruments.

1 2.2 12,2.1 Control of Measuring and Test Equipment Procedures shall be written to delineate the methods and responsibilities for the control, maintenance, and calibration of measuring and test equipment (M8TE).

M&TE control procedures or calibration program documents shall contain the following:

a A listing of M&TE to be controlled;

b. Frequency of calibration of listed M&TE. The frequency may be based on calendar time or relate to usage, and be based on such factors as experience, ID CO OI inherent stability, instrument purpose, or accuracy required; C

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c. A method for controlling issue and recall of portable.M&TE;

d. A method to identify controlled M&TE (e.g., labeling) required calibration C

frequency and calibration test data applicable to the M8TE; 0

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TOPICAL QUALITY ASSURANCE REPORT TQR 12.0 Rev.

CONTROL OF MEASURING AND TEST EQUIPMENT Sept. 1, 1989 Page 2 of 3 12.2.1 Control of Measuring and Test Equipment (Cont'd)

FPL may delegate the control and/or calibration of M8TE to other organizations.

FPL, however, retains ultimate responsibility for control and calibration, and the contractor shall meet the requirements of this TQR or an acceptable alternative program as required by the procurement document for the contracted services.

12.2.2 Calibration Procedure M&TE shall be calibrated in accordance with written approved procedures. The calibration procedures shall contain, as a minimum:

a Identity of M&TE to which the procedure applies;

b. Calibration equipment and reference standards to be used;

c. Acceptance criteria;

d. Sequence of operations and special instructions;

e. Documentation and data collection requirements;

f. A requirement that M&TE be checked and results recorded before adjustments or repairs are made;

g. Calibration frequency required.

12.2.3 Calibration Standards M&TE shall be calibrated using reference standards whose calibration has a known, documented, valid relationship to nationally recognized standards or accepted values of natural physical constants. If no national standard exists, the basis for calibration shall be documented. Standards and reference standards shall have an accuracy level, range and stability which are adequate to verify that the equipment being calibrated is within tolerance and adequate for the programmatic requirements of the equipment being calibrated.

TOPICAL QUALITY ASSURANCE REPORT TQR 12.0 Rev. 4 CONTROL OF MEASURING AND TEST EQUIPMENT oa<<Sept. <, <g8g Page 3 of 3 12.2.3 Calibration Standards (Cont'd)

MBTE shall be calibrated against working standards having an accuracy of at least four times the required accuracy of the equipment being calibrated. When this is not practical, working standards shall have an accuracy that assures that the M&TE being calibrated will be within required accuracy tolerances and that the basis of acceptance is documented and authorized by designated responsible management, The meaqing of this paragraph may be diagrammed as follows:

NATIONAL INSTITUTE OF STANDARDS AND TECHNOLOGY (NIST)

"greater than" tolerance PRIMARY STANDARD (if applicable)

"greater than" tolerance SECONDARY STANDARD (if applicable)

"greater than" tolerance WORKING STANDARD "1:4 ratio" tolerance (except, as noted above)

MBTE (installed instruments and measuring and test equipment used

'or inspection, maintenance, etc.)

The accuracies of M&TE and reference standards shall be chosen such that the equipment being calibrated can be calibrated and maintained within the required tolerances.

12,2.4 "Out of Tolerance" Control M&TE and reference standards; when found out of tolerance, shall be so identified and removed from service. An investigation shall be conducted to determine the C

validity of previous inspection or test results gained through use of the 0

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TOPICAL QUALITYASSURANCE REPORT TQR 13.0 Re~. Draft 7 HANDLING, STORAGE AND SHIPPING Da'e 5/8/90 Page 10f 2 13.1 GENERAL RE UIREMENTS Written instructions or procedures shall be established and implemented for the cleaning, shipping, storage, preservation, packaging, and handling of specified items. These instructions and procedures shall delineate measures which prevent degrading an item through damage or deterioration. When necessary for particular products, special protective environments such as inert gas atmosphere, specific moisture content levels, and temperature levels shall be specified and provided.

132 IMPLEMENTATION 13.2.1 General Instructions or procedures shall be written to define the requirements and responsibilities for the cleaning, packaging, preservation, handling, storage, and shipping of equipment and material, and shall require implementation of the established design and specification requirements by personnel having appropriate qualifications. FPL may delegate any portion of the responsibility for handling, storage and shipping of .material and equipment, but shall retain Where any of the functions in the section which follow is ultimate'esponsibility.

delegated to a contractor, the contractor shall be required to adhere to the FPL requirements stated herein.

13.2.3 Handling, Storage,:and Shipping Procedures Materials and equipment which are to be incorporated into a safety-related system of a nuclear power plant shall be handled, stored, and shipped in accordance with written procedures, where necessary, to implement the design document and purchase order requirements. These procedures shall assure that

,n TOPICAL QUALITYASSURANCE REPORT TQR 13.0 Rev. Draft 7 HANDLING, STORAGE AND SHIPPING Oate 5/8/90 FPL Page 20f 2 13.2.3 (Continued) cleaning, handling, storing, packaging, shipping, and preserving materials, components and systems will preclude damage, loss, or deterioration by environmental conditions, such as temperature or humidity.

The preparation'and/or implementation of these procedures may be delegated to other organizations, but. FPL shall retain the ultimate responsibility for proper material handling, storage, and shipping.

13.2.4 Verification of Proper Handling, Storage, and Shipping.

The Quality Assurance Department shall be responsible for verification of proper e handling, storage and shipping at vendor facilities.

and at the plant.

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TOPICAL QUALITYASSURANCE REPORT TQR 14.0 Rev. Draft 7 INSPECTION, TEST AND Date 5/8/90 OPERATING STATUS Page 10f 2 14.1 GENERAL RE UIREMENTS Measures shall be established to indicate by the use of markings such as stamps, tags, labels, routing cards or other suitable means, the status of inspections and tests performed on material, equipment, or systems. These measures shall provide for the identification of items which have satisfactorily passed required inspections and tests.

Measures shall also be established for indicating the" operating status of structures, systems and components to prevent inadvertent operations.

142 IMPLEMENTATION 14.2.1 General I'pll,bN Dp did I libi pp and maintenance I

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~Mii a suitable system and operating status of materials, equipment, systems; and components.

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ti pbi for identifying the inspection, test, Construction Services Manager is responsible for establishing a suitable system for

~OE identifying, inspecting and testing for material, equipment, systems and components E I y established, implemented and maintained in accordance with written Quality Procedures E

I'establishment For plant bdlb and Quality Instructions. The Architect/Engineer or Contractors shall develop and implement procedures to comply with contractual responsibilities, and applicable codes, standards, specifications, and criteria governing the status identification of procurement items being tested, installed, or fabricated. The Architect/Engineer (where applicable),

suppliers and contractors shall be required to maintain a system for identifying the inspection, test and processing status of materials, parts, and components. Elements of e=: this system require that suppliers and contractors have a controlled manufacturing and test operation in order to preclude the inadvertent bypassing of processing, inspections

TOPICAL QUALITYASSURANCE REPORT T R 14.0 Rev.

Draft 7 Date INSPECTION, TEST AND 5/8/90 OPERATING STATUS Page 2 of 2 14.2.1 (Continued) or test, and to provide a positive identification of component status throughout all phases of manufacturing, testing, and inspecting, by means of tagging, routing cards, stamping, manufacturing or test reports, labeling or other appropriate methods. The Vice Presidents - Turkey Point or St. Lucie and the Quality Assurance Department shall verify adequacy of the controls established and implemented, as appropriate for their site.

14.2.2 Status Identification and Control Quality Procedures and Quality Instructions shall describe control of the application and removal of markings such as stamps, tags, labels, routing cards, and other suitable means to indicate the status of non-operational, nonconforming, or malfunctioning nuclear safety related structures, systems and components to prevent inadvertent operation, and to prevent omission of inspections, tests, or other critical operations.

'These procedures and instructions shall delineate the requirements, methods and responsibilities for indicating the status of the affected items. These procedures will clearly delineate the individuals or groups responsible for application and removal of status indicators.

TOPICAL QUALITYASSURANCE REPORT TQR 15.0 Rev. Draft 9 NONCONFORMING MATERIALS; Date 5/8/90 PARTS OR COMPONENTS Page 10f 3 15.1 GENERAL RE UIREMENTS Measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation. These measures shall include, as appropriate, procedures for identification, documentation, segregation, disposition and notification to affected organizations. Nonconforming items shall be reviewed and accepted, rejected, repaired or reworked in accordance with documented procedures.

C 15.2 IMPLEMENTATION 15.2.1 0 Quality Procedures and Quality Instructions shall define the responsibilities and methods for identifying, documenting, segregating and dispositioning nonconforming items. For procedure review requirements, see TQR 2.0 and TQR 5.0. Each department shall be responsible for the identification, control and disposition of nonconformances within the scope of their departmental responsibilities.

Throughout plant life, FPL may delegate any portion of the identification and control of nonconforming items and services to an Architect/Engineer (A/E),

constructor, NSSS vendor or other contractors. In any case, FPL retains the responsibility for assuring that requirements are met, and shall assure that the contractor's actions conform to requirements set by FPL.

15.2.2 Documenting and Controlling Nonconformances All nonconformances in safety related items shall be documented and reported for corrective action. Measures shall be delineated in Quality Procedures and Quality 0

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TOPICAL QUALITYASSURANCE REPORT,. TQR 15.0, Rev. Draft 9 NONCONFORMING MATERIALS, Date '/8/90 PARTS OR COMPONENTS Page 2 of 3 15.2.2 (Continued)

Instructions which control further processing, installation, or operation of nonconforming items. These measures shall include:

a. Physical identification of the item as nonconforming.

b. Segregation of nonconforming items until properly dispositioned.

%here physical segregation is not practical, suitable tags, marking or documentation shall be used to assure control.

15.2.3 Documentation Documentation of the nonconforming item shall: identify the item; describe the nonconformance; show disposition of the nonconformance and inspection

'requirements; and include the signature of the person approving the disposition.

15.2.4 Evaluation and Disposition Nuclear Engineering, or the delegated contractor organization, as specified by procedure, shall evaluate nonconformances and disposition them based on the results of the evaluations. These evaluations and dispositions shall be reviewed, approved and documented in accordance with procedures.

An evaluation to determine the disposition of nonconforming items shall be performed. The evaluation shall determine whether an item is to be accepted as-is, repaired, reworked or rejected. A technical evaluation shall be performed when an item is accepted as-is or is repaired to an acceptable condition. Records of the disposition of these items shall be made part of the nonconformance report. This evaluation shall assure that the final condition does not adversely effect safety, operability or maintainability of the item, or of the component or system in which it is installed.

TOPICAL QUALITYASSURANCE REPORT TQR 15.0 Rev. Draft 9 NONCONFORMING'MATERIALS, Date 5/8/90 PARTS OR COMPONENTS Page 3 of 3 15.2.4 (Continued)

The A/E, or other contractors on-site, shall be required to inform @e FPL as specified in procurement documents prior to use or installation of a nonconforming item.

The nature and extent of a nonconformance and the reason for proposing its use or installation shall be justified. Nonconforming items dispositioned "accept as-is", or repaired to an acceptable condition, shall be so identified.

Nonconformance reports for those items shall be made part of the item records and forwarded with the material to FPL.

The determination of the need and the a'dvisability of releasing nonconforming e fgg Pg considerations in making this determination:

.fll 'gf<<yl materials or items, is made by the, Nuclear Engineering, PP ~

a. Effect on the orderly progress of work if material or items are released;

b. Safety of personnel;

c. Suitability of material or items in "as-is" condition, i.e., probability of eventual satisfactory resolution of the nonconformance without repair, rework, or replacement; d.. A'ccessibility of material or items after release;

e. Cost of removal and repair of replacement should, material or. items eventually have to be removed, repaired, or replaced;

f. Impact on plant safety.

Items shall be reworked or repaired in accordance with documented procedures and shall be verified by reinspecting the item as originally inspected or by a documented method which is at least equal to the original inspection method.

Qe@hy Nuclear Assurance 'ersonnel shall periodically review nonconformance reports to identify quality trends. The results of these analyses shall be reviewed with appropriate members of upper level management.

TOPICAL QUALITYASSURANCE REPORT TQR 16.0 0 CORRECTIVE ACTION Rev.

Date Draft 6 5/30/90 Page 101 3 16.1 GENERAL RE UIREMENTS Documented measures shall be used to assure that conditions adverse to quality such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances, are promptly identified and corrected as soon as practicable. In the case of significant conditions adverse to quality, the cause of the condition shall be determined and action taken to preclude repetition. The identification of significant conditions adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management.

16.2 IMPLEMENTATION

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16.2.1 Corrective Action and Follow-Up Quality Procedures and Quality Instructions shall define responsibilities and methods for identifying and correcting conditions adverse to quality. When an adverse condition is detected, a determination shall be made by plant p ii QA'eN I A whether immediate or routine corrective action is required.

a "Immediate Corrective Action" applies to conditions which pose a threat to plant safety or to the health and safety of the public, which could result in major equipment and material damage, or could, if not corrected, produce defects of significantly greater consequences than those immediately resulting from the condition. "Immediate Corrective Action" is accomplished through stopwork requests/orders Cll CO P1 to appropriate levels of management, requiring that work be stopped, i the plant be shut down or other appropriate actions be taken.

TOPICAL QUALITYASSURANCE REPORT T R 16.0 0 CORRECTIVE ACTION Rev.

Date Draft 6 5/30/90 Page 2 of 3 16.2.1 (Continued)

b. "Routine Corrective Action" applies to conditions which do not require immediate corrective action. Routine corrective action is assured through the distribution and disposition associated with inspection reports, surveillance reports, nonconformance reports, and audit reports; and the investigation analysis and action associated with reportable 'conditions.

Follow-up to verify implementation of corrective action and close-out of corrective action documentation is accomplished by the QA or QC organization responsible for verifying the corrective action. The e Quality Assurance Department shall track, follow-up, and closeout open items identified by QA Department audits and vendor surveillances. The respective department or plant shall track those items charged to its operating license by the NRC. Each department shall be responsible for follow-up and close-out of corrective action resulting from their departmental inspections, tests, or operations.

If corrective action is inadequate or not timely, the follow-up organization shall request corrective action from management, as delineated iri procedures. The President Nuclear Division is the final authority in the event that agreement is not reached at lower levels regarding stop work requests or other corrective action.

Where corrective action is required of contractor personnel, FPL shall define in procedures and contracts

'i the corrective action interface between FPL and the contractor. FPL shall require the A/E, NSSS vendor, constructor and other suppliers of safety related materials and services to have a documented corrective action system.

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TOPICAL QUALITYASSURANCE REPORT TQR 16.0 Rev. Draft 6 CORRECTIVE ACTION Date 5/30/90 FPL Page 3 of 3 16.2.2 Recurrence Control It is the responsibility of the organization which identifies the significant condition adverse to quality to verify that corrective action description not only corrects the immediate condition, but also precludes the condition Rom recurring. The organization(s) that provide(s) the corrective action disposition and implementation is responsible to assure that the corrective action taken not only corrects the immediate condition, but also precludes recurrence.

16.2.3 Incidents and Reportable Occurrences Reporting Operating Reportable Occurrences and reports of incidents shall be investigated, documented as to cause and corrective action, and reported to the NRC in accordance with, the applicable plant Technical Specifications.

Reportable Occurrences and reports of incidents that are safety-related or that result in damage shall be forwarded to the Company Nuclear Review Board (CNRB) for review. Conditions adverse to quality are reported to operating plant management through:

distribution of QA audit reports, QC inspection reports, corrective action requests, and the investigation and reporting of Reportable Occurrences in accordance with plant Technical Specifications.

TOPICAL QUALITY ASSURANCE REPORT TQR 18.0 Rev. Draft 6 AUDITS Date 5/8/90 FPL Page 10' 18.1 GENERAL RE UIREMENTS A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program. The audits shall be performed in accordance with the written procedures or checklists by appropriately trained personnel not having direct responsibilities in the 'areas'being audited. Audit results shall be documented and reviewed by management having responsibility in the area audited. Follow-up action, including reaudit of deficient areas, shall be taken, where necessary.

A comprehensive program of audits is carried out by the Quality Assurance Department during the design, procurement, construction, and operations phase of nuclear power plants. These audits are performed to verify that all safety related activities associated with nuclear power plants are carried out in accordance with the requirements of the FPL QA Program, and that the implementation is effective.

18.2.1 Personnel Quality Procedures provide instructions for the training of QA Department personnel who perform audit activities, to assure that they are adequately indoctrinated and trained, and that they are qualified to carry out these activities. Quality Procedures provide for personnel qualified as Lead Auditors to be formally certified by Quality Assurance Department management. Certification shall be based on education, experience, training and other specified criteria.

I TOPICAL QUALITY ASSURANCE REPORT T R 18.0 Rev. Draft 6 AUDITS 5/8/90 Page 2 of 5 18.2.2 Planning and Scheduling Quality Procedures and Quality Instructions provide requirements for written audit plans and schedules. The audits are planned and scheduled on the, basis of the following requirements, as appropriate:

L Activities shall be audited as early in their life as practicable.

Auditing shall be initiated early enough to assure effective quality assurance during the design, procurement and contracting activities.

b. Applicable elements of the internal and on-site QA Programs shall be audited at least once every two years during the operation phase of plant life following initial fuel loading. For other plants'hases, the applicable elements shall be audited at least once every year or once within the life of a quality related activity, whichever is shorter.

C. An annual evaluation of suppliers'uality performance history shall be performed to determine reaudit requirements. Reaudit requirements for suppliers shall be based on the supplier's quality performance and the complexity and criticality of the equipment or service being procured. A facility evaluation (audit) will be performed at least every three years and shall be conducted in accordance with Quality Procedures and Quality Instructions for supplier evaluations.

d. Audits shall be regularly scheduled for on-going activities.

e. Regularly scheduled audits shall be supplemented, as required to cover unforeseen events or changes in requirements.

TOPICAL QUALITYASSURANCE REPORT T R 18.0 0 AUDITS Rev.

Date Draft 6 5/8/90

@PL Page 3 of 5 18.2.2 (Continued)

The scope of audit activities shall include, as a minimum:

a. The determination of site features which affect plant safety (e.g., core sampling, site preparation, and meteorology).

b. The preparation, review, approval, and control of the SAR, designs, specifications, procurement documents, instructions, procedures, and drawings.

c. Evaluation of bids.

d. Indoctrination and training programs.

e. Receiving and plant inspections.

f. Operation, maintenance/repair and modification.

g. The implementation of operating and test procedures.

h. All criteria in Appendix B to 10 CFR Part 50.

i. Validity of Certificates of Conformance.

External audits shall be performed by the Quality Assurance Department on Architect/Engineers, NSSS vendors, constructors, and "other suppliers of safety related materials and services to evaluate their QA programs, procedures and activities. Procurement documents require that FPL suppliers and contractors in turn perform audits on their sub-tier suppliers and contractors.

TOPICAL QUALITYASSURANCE REPORT TQR 18.0 Rev. Draft 6 AUDITS Date 5/8/90 FPL Page 40' 18.2.3 Conduct of Audits Quality Procedures and Quality Instructions shall delineate requirements for the conduct of audits. These procedures and instructions shall require that:

a Audits be conducted by trained and qualified personnel.

b. Personnel conducting audits shall not have direct responsibility in the area audited.

c. Checklists or procedures shall be used to ensure depth and continuity of audits.

Objective evidence shall be examined for compliance with quality assurance program requirements. This shall include examination of procedures and activities to assure that documented objective evidence is meaningful and in compliance with the overall Quality Assurance Program.

e. Audits shall include evaluation of work areas, activities, processes and items; and the review of documents and records.

18.2.4 Reporting of Audit Findings Audit findings shall be documented in written reports. Audit reports shall be distributed to the responsible management of the audited FPL organization within thirty calendar days after completion of the audit.

TOPICAL QUALITYASSURANCE REPORT TQR 18.0 Draft 6 AUDITS 5/8/90 Page 5 of 5 18.2,5 Follow-up Responsible management of the audited organization shall take action to correct the deficiencies identified in the audit report and provide a written response within thirty calendar days after receipt of the report. This response shall include action taken and/or planned to correct deficiencies and to prevent recurrence of the deficiencies, and commitment dates for actions not yet complete. The mechanism for evaluation and follow-up of corrective action is described in TQR 16.0. The status of correction of deficiencies shall be followed until the corrective actions have been accomplished and verifietL 18.2.6 Reports to Management p

Quality Assurance Program status reports are periodically prepared by the QA Dp d d P P f d Company Nuclear Review Board (CNRB) for their review. This status report summarizes the results of QA Department audit activities for the period, keeps all Cema&tee CNRB members apprised of current conditions and program effectiveness, and when necessary, directs management attention to significant trends and problems.

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TOPICAL QUALITYASSURANCE REPORT APP. B Rev. Draft 5 QUALIFICATIONAND EXPERIENCE REQUIREMENTS FOR FPL QUALITY Date 5/8/90 ASSURANCE PERSONNEL FPL Page 1 f1 TITLE EDUCATION AND BACKGROUND EXPERIENCE*

Quality Managers Shall satisfy the following set of requirements:

(JB/PTN/PSL)

Graduate of a four year accredited engineering or science college or university, plus seven years of industrial experience, including five (5) years in positions of leadership such as lead engineer, project engineer, audit team leader, etc. At least two (2) years of this five (5) years experience shall be nuclear power plant experience in the implementation of the Quality Assurance Program. Six (6) months of the two (2) years experience shall be obtained within a Quality Assurance organization. A masters degree in engineering or business management is considered equivalent to two (2) years of general industry experience.

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P The education and experience requirements should not be treated as absolute when similar C

training or an outstanding record will provide reasonable assurance that a person can perform '.

the required tasks.

TOPICAL QUALITY ASSURANCE REPORT APP. C 0 BASELINE DOCUMENT MATRIX Rev.

Date Page ~

DRAFT 8 5/30/90 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 QUALITY ASSURANCE REPORT APP. C Rev.

DRAFT 8 BASELINE DOCUMENT MATRIX . Date 5/30/90 Page 2 of 23 REFERENCE INDUSTRY DRAFT REV.

TOPICAL QUALITYASSURANCE REPORT APP. C Rev. DRAFT 8 BASELINE DOCUMENT MATRIX Date 5/30/90 Page 3 of 23 Florida Power & Light Company position regarding conflicting guidance and exceptions:

T ARA ni l fi n AN IAN 1-1 L-2 I

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.

R I i 1 R 1 ANIN1 1-1 1 ANIAN 1 L-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.

R l 4 24-1 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".

TOPICAL QUALITYASSURANCE REPORT APP. C 0 BASELINE DOCUMENT MATRIX Rev.

Date Page DRAFT 8 5/30/90 of 23 R lt i 1 Rv2ANI 1 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'eview 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 NUTMEG 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.

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 to the requirements of ANSI N18.7-1976, Paragraph 5.2.18. Further, TQR 9.0,' an'lternative

TOPICAL QUALITYASSURANCE REPORT APP. C Rev.

DRAFT 8 Date BASELINE DOCUMENT MATRIX 5/30/90 Page 5 of 23 Paragraph 9.2 explains the review of potential special processes and determination of their status I 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 received 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.

In order to avoid duplication of requirements invoked in our licensing documents, the FPL C T Quality Assurance Program does not list those required operating procedures specified in Appendix A.

TOPICAL QUALITYASSURANCE REPORT APP. C Rev.

DRAFT 8 BASELINE DOCUMENT MATRIX Date 5/30/90 Page 6 of 23 R lat i 1 AN I 4 21-1 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 will be properly considered and controlled.

i 1 Rv2A 4 22- 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 constrasting will only be applied to the extent that these colors are dissimilar or otherwise distinguishable. This does not preclude using other tapes when precuations are taken to ensure these tapes do not come in contact with austentic stainless steel or nickel alloy materials.

Vapor barrier material (other than metal) shall be colored to contrast with or be otherwise distinguishable from safety related systems to prevent undisclosed entry into the system.

TOPICAL QUALITYASSURANCE REPORT APP., C R<<DRAFT 8 BASELINE DOCUMENT. MATRIX SSoi90 FPL page 7 of 23 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 are 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.

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

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DRAFT 8 BASELINE DOCUMENT MATRIX Date 5/30/90 APL Page 8 of 23

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 Rom 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".

TOPICAL QUALITYASSURANCE REPORT APP. C Rev. DRAFT 8 BASELINE DOCUMENT MATRIX Date 5/30/90 Page 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 are present (i.e. hurricanes, paint sprays, concrete pours, etc.) precautions or additional steps will be taken to further protect the items.

R I Rv2A IN4 2 -1 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.'n.

lieu of the zone designation, 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.

TOPICAL QUALITYASSURANCE REPORT APP. C Rev. DRAFT 8 BASELINE DOCUMENT MATRIX Oate 5/30/90 Page 10 of 23 Documented cleanliness inspections are performed immediately prior to system closure. Control of personnel, 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.

11 1 4 2 ANSI N45.2.6-1978, Paragraphs 1.1,'.1, 3.2.2(a) and 4-(Table-1) identic 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 4 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 APP. C Rev. DRAFf 8 BASELINE DOCUMENT MATRIX Date 5/30/90 Page 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 III of 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 Regulatory 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 inspection, examination 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 determine the capabilities in his qualified areL If during this review or at any other time, it is determined that the individual's 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 areL

TOPICAL QUALITYASSURANCE REPORT APP. C Rev. DRAFI' BASELINE DOCUMENT MATRIX Date 5/30/90 FPL Page 12 of 23 i 1 4 Rv 2AN IN4 211-1 4 FPL's exception to Regulatory Guide position C.2 is as follows:

I I

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 from the design organization. Design verification by the designer's immediate supervisor shall be limited to those instances where the supervisor is the only qualified individual available within the design organization. These instances are further restricted to designs where the designs 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 Assur'ance 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 will include evaluations of the adequacy of the practices which are the implementation of these policies, procedures and.

instructions.

R 1 Regulatory 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".'o avoid duplication of requirements, FPL will address Regulatory .

-' Guide 1.68 in the FSAR.

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TOPICAL QUALITYASSURANCE REPORT APP. C DRAFr 8 BASELINE DOCUMENT MATRIX 580i9O FPL page 13 of 23 1 4AN IN4 21 -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 control 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.

TOPICAL QUALITYASSURANCE REPORT, APP. C Rev. DRAFI' BASELINE DOCUMENT MATRIX Date 5/30/90 Page 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, 'ncluding 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.

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 ihe physical characteristics or material, structure, component or system, which provide a means to control the quality of the material, structure, component or system to predetermined requirements.

TOPICAL QUALITYASSURANCE REPORT APP. C Rev. DRAFT 8 BASELINE DOCUMENT MATRIX Date 5/30/90 Page 15 of 23 Storage That period following the release of an item for shipment until turnover for start-up preoperational testing. This would include in-place 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 irmn" l fii nfr I 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'nternal requirements not enforceable under current NRC practices.

R l v2A I 42-14 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.

TOPICAL QUALITYASSURANCE REPORT APP. C Rev. DRAFT 8 .

BASELINE DOCUMENT MATRIX Date 5/30/90 Page 16 of 23 Non-permanent Records: Records which are required by the NRC facility operating licen'se, 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 records shall be stored in a manner as to protect contents &om possible destruction by causes such as fire, flooding, tornados, insects, rodents, and Rom 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

- Juno Beach, the Loss Prevention Engineer, and the Manager of Corporate Record 'anager Services, who shall be responsible for maintaining records of evaluations and establishing schedules to assure that reevaluations are performed every two (2) years. If necessary, the above QARSET Committee 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.

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

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

a Early warning fire detection and automatic fire suppression shall be provided, with electronic 'supervison 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 or records shall be permitted on the

.floor 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.

Smoking,and eating/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.

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 record 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.

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

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DRAFT 8 BASELINE DOCUMENT MATRIX Date 5/30/90 Page 18 of 23 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.

(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.

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

i 111 ANI 4 2 -1 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&TE issue log which provides traceability between M&TE and the applicable inspections.

TOPICAL QUALITY ASSURANCE REPORT APP. C 0 I BASELINE DOCUMENT MATRIX Rev.

Date Page DRAFT 8 5/30/90 19 of 23 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.

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 used 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 controls to preclude adverse effects on safety and suitability for use.

e i 2 Rv AN IN4 21-1 ANSI N45.2.13-1976 Section 1.1 states that the extent to which the individual requirements of this standard will apply will depend upon the nature and scope of the work to be performed and the required quality of the items or services purchasers 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 are 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 commercial 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, if required, was received.

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TOPICAL QUALITY ASSURANCE REPORT APP. C Rev.

DRAFT 8 BASELINE DOCUMENT MATRIX Date 5/30/90 Page 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" contained in ANSI N45.2.10-1973 as modified by Regulatory Guide 1.74.

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 with the exception of these accomplished by "Confirming Purchase Order". A "Confirming Purchase Order" is an order which is initially placed 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 normal review and approval cycle. 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".

(1) Quality Assurance must be contacted prior to contacting the supplier to place the order unless it is an emergency purchase after normal working hours in which case Quality Assurance is contacted the next working day.

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

(3) 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.

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 all .

nonconformances which consist of one or more of the following:

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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 shall be submitted to the Purchaser for evaluation.

This policy assures that all 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..

1 R l i 11 AN I 4 24-1 2 ANSI N45.2.4-1972, Paragraph 2.5.2 requires that equipment be "suitably marked to indicate date'f next required calibration". In lieu of marking 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.

44 R I 4 212-1 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.

143334993 ANSI NISII 1976/ANS33, 9 6 Pl 4445 ( d d 37 3 6 I N 3 ld 1.33 Revision 2) states in part; "Audits of selected aspects of plant eyeradea operational phase activities shall be performed with a frequency commensurate with their safety significance, and .

e'= in such a manner as to assure that an audit of safety related aeh~Qes functions is completed within a period of two years."

TOPICAL QUALITYASSURANCE REPORT APP. C Rev. DRAFT 8 BASELINE DOCUMENT MATRIX Date 5/30/90 page 22 p f 23 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.

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 pre-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 are 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.

TOPICAL QUALITY ASSURANCE REPORT APP. C Rev.

DRAFT 8 BASELINE DOCUMENT MATRIX Date 5/30/90 FPL Page 23 of 23

'nnin 1 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.

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 are 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.

r 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 QUALITY ASSURANCE REPORT APPENDIX E Rev. 12 LIST OP CORPORATE QUALITY Oate 10/3 0/89 ASSURANCE PROCEDURE Page 3 of 11 P NUMBER TITLE SECTION DESCRIPTION 2.14 IMPLEMENTATION OF .Describes the program and ASME XI responsibilities for controlling activities defined by ASME Section XI.

2.15 CONTROL OF COMPUTER SOFTWARE Specifies basic requirements for control of the lifecycle of computer software on mainframe, stand-alone, and PC computers.

2 '7 ENVIRONMENTAL'QUALIFICATION(EQ) Delineates the responsibilities OF ELECTRICAL EQUIPMENT and requirements for maintaining the environmental qualifications of nuclear plant components.

3.1 CANCELLED 3 '

IDENTIFICATION AND CONTROL OF Describes measures employed for DESIGN 'INTERFACES identifying and controlling design interfaces, changes in design interfaces, and modifications that affect documents.

3.4 PLANT CHANGES AND MODIFICATIONS stablishes measures for controlling FOR OPERATING PLANTS design changes or modifications in operating nuclear power plants.

3.5 DESIGN CONTROL AT THE Defines the responsibilities and CONSTRUCTION SITE methods employed for the initiation, review, evaluation, approval and disposition of field initiated design changes and miscellaneous 'esign documents such as field sketches and isometrics.

TOPICAL QUALITYASSURANCE REPORT APPENDIX E Rev.

LIST OF CORPORATE QUALITY 3/28/90 FPL ASSURANCE PROCEDURES Page 3 of Ip 3.2 IDENTIFICATIONAND CONTROL OF Describes measures employed for identifying and DESIGN INTERFACES controlling design interfaces, changes in design interfaces, and modifications that affect documents.

3.4

. PLANT CHANGES AND MODIFICATIONS Establishes measures for controlling design changes FOR OPERATING PLANTS or modifications in operating nuclear power plants.

3.5 DESIGN CONTROL AT THE Defines the responsibilities and methods CONSTRUCTION SITE employed for the initiation, review, evaluation, approval and disposition of field initiated design changes and miscellaneous design documents such as field sketches and isometrics.

3.6 CONTROL OF FPL ORIGINATED Covers the preparation, review, and approval of DESIGN design input documents, design analysis specifications, and design verification for safety related design work originated by FPL.

3.7 EVALUATIONAND CONTROL OF Describes the evaluation and control of contractor CONTI&CI'ORDESIGN FOR NUCLEAR designs for fuel related components and analysis.

FUEL AND RELATED SYSTEMS 4.3 CANCELLED

TOPICAL QUALITYASSURANCE REPORT APPENDIX E 0 LIST OF CORPORATE QUALITY ASSURANCE PROCEDURES Rev.

3/28/90 Page 4 of 10 4.6 PROCUREMENT CONTROL Delineates the sequence of actions in the preparation, review, approval, and control of procurement documents.

5.1 OPERATING PLANT PROCEDURES Describes measures which ensure that instructions and procedures used in operating plants are identified, prepared, reviewed, approved, issued and revised in accordance with regulatory and FPL requirements.

5.2 BACKFlTPROCEDURES Describes the generation, review and control of backfit procedures.

6.1 CONTROL OF CONSTRUCTION PROJECT Defines responsibilities and methods for the control CONTRACTOR DRAWINGS, and issue of contractor drawings, specifications and SPECIFICATIONS AND PROCEDURES procedures to be used during the construction phase of nuclear power plants.

6.2 CONTROL OF DOCI.JMENTS Instructions are provided for controlling documents ISSUED BY FPL issued by FPL which prescribe activities affecting the quality of safety related items.

6.3 CANCELLED

TOPICAL QUALITYASSURANCE REPORT APPENDIX E Rev.

LIST OF CORPORATE QUALITY m8I90 ASSURANCE PROCEDURES Page 6 of 10 7.9 CONTROL OF ON-SlTE VENDOR , This procedure provides a system to assure that SERVICES vendors who provide on-site services by contract or purchase order to FPL at nuclear power plants are controlled.

8.1 IDENTIFICATIONAND CORIROL OF Delineates measures for assuring traceability, MATERIALS,PARTS, AND COMPONENTS identification and control of items Sum the AT THE PLANT SlTE time they are received through usage at operating plants.

8.2 CANCEIZZD 9.1 CONTROL OF SPECIAL PROCESSES Delineates the responsibilities of organiiations and personnel, and the control and documentation of special processes that are applied to safety related items.

9.2 CANCEL'LED (Combined with 9.1) 9.4 CONTROL OF WELDINGFOR NUCLEAR Delineates responsibilities and requirements for POWER PLANTS control FPL welding processes for nuclear power plants.

10.1 CANCELLED

FPLTQAR 1-76A .

(FPL-NQA-100A)

REVISION 16 JUNE 12, 1990

TOPICAL QUALITY ASKJRANCE REPORT Rev. 4 Date June 24, ].988 Page ] "

of ]

Florida Power 6 Light Company (FPL) has established and implemented a Quality Assurance Program to provide assurance that the design, procurement, modification and operation of nuclear power plants conform with applicable regulatory requirements. The FPL Quality Assurance Program described in this Topical Report is in compliance with the requirements of Appendix B to 10 CFR Part 50.

The FPL Quality Assurance Program meets the requirements provided by the NRC Regulatory Guidance and Industry Standards as listed in Appendix C of this Topical Quality Assurance Report.

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Isa ICOS UNIT EO STATES r~ NUCLEAR REGULATORY COMMISSION 0

REGION II

'IOI MARIETTA STREET. N.W.

ATLANTA.GEORGIA 30323 July 13, 1989 Docket Nos. 50-250, 50-251, 50-335 and 50-389 Florida Power and Light Company gl ATTN: Mr. C. 0. Woody, Acting rg V /$JS Senior Vice President - Nuclear -. ,~ CW<R P. 0. Box 14000 C s~C OeOgpu SSO Juno Beach, FL 33408-0420 Gentlemen:

SUBJECT:

ACCEPTANCE OF CHANGE TO THE OPERATIONAL QUALITY ASSURANCE PROGRAM (FPL TQAR I-76A) FOR FLORIDA POWER AND LIGHT FOR ST. LUCIE UNITS I AND 2 AND TURKEY POINT UNITS 3 AND 4 We have reviewed the changes addressed in Revision 15 of the Quality Assurance (QA) program description for Florida Power and Light - St. Lucie Units I and 2 and Turkey Point Units 3 and 4. Our review of the FPL QA program included the following material:

QA Program

Description:

Topical I-76A Commitments to Regulatory Guides: Topical I-76A Appendix C Scope: St. Lucie FSAR Section 3.2.1 Amendment 4-Turkey Point FSAR Section 1.9 Revision 6 This review indicates that FPL TQAR I-76A (Revision 15) continues to satisfy 10 CFR 50, Appendix B requirements and its therefore acceptable.

Any questions you may have concerning this review should be directed to F. Jape of my staff on 404/331-4182.

Sincerely,

~-r-Albert F. Gibson, rector Division of Rea or Safety.

cc: D. A. Sager, Vice President St. Lucie Nuclear Plant G. J. Boissy, Plant Manager L-J-. B. Harper, QA Superintendent J. S. Odom, Vice President Turkey Point Nuclear Plant J. Cross, Plant Manager L. W. Bladow, Plant QA Superintendent J. Arias, Jr., Regulatory and Compliance Supervisor State of Florida

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<<i gr c NUCLEAR REGULATORY COMMISSION Vl WASHINGTON, O. C. 20555

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~O 4k*<<<< GEP 0 1 10;3 SGTB:LLG 71-0169 Florida Power 5 Light Company ATTN: Mr. C. 0. Woody, Acting Vice President P.O. Box 128 Ft. Pierce, FL 33450 Gentlemen:

Enclosed is guality Assurance Program Approval for Radioactive Material Packages No. 0169, Revision 3.

Please note conditions in the approval.

Sincerely, MfA QD Transportation Branch Division of Safeguards and Transportation, NMSS

Enclosure:

As stated

NRC FORM 311 U. S. NUCLEAR REGULATORY COMMISSION I go)OVAL NUMBE4 1

%4n QUALlTYASSURANCE PROGRAM APPROVAL REVI)ION NUM854 FOR RAOIOACTIVE MATERIALPACKAGES oi Fed'e Pursuar'.I to the AtonliC Energy Act ot 1954. as amended. the Energy Reorganization Act of 1974, as amended. and T lie 10. Code and representations heretofore made in liam the person named in item Regulations. Chapter I perl 71. and in reliance on statements 5 by

2. the Quality Assurance program identified in Item 5 is hereby approved This approval is issued to satisfy the requirements of section 71 101 of 10 cFR part 71, This approval is sublect to all applicable rules, regulations. and orders of the Nuclear Regulatory Commiss or now Or hereafter in effect and to any conditions specified below.

3, EXPIRATION OATE Florida Power 5 Light Company STREET ADDRESS August 31, 1994 4 OOCKET NUMBER P.O. Box 128 CITY STATE ZIP CODE Ft. Pierce FL 33450 71-0169 5, QUALITY ASSURANCE PROGRAM APPLICATION DATE(SI April 23, 1979, and July 17, 1989

6. CONOITIONS Activities conducted under applicable criteria of Appendix B of 10 CFR Part 50 for operations at the Turkey Point Units 3 and 4 (NRC Docket Nos. 50-250 and 50-251) and St. Lucie Units 1 and 2 (NRC Docket Nos. 50-335 and 50-389) to be executed in accordance with FPL gA Topical Report FPL-TAHAR-76A with regard to transportation packages.

FO THE U.S. NUCLEAR REGULATORY COMMISSION Char les . HacDonald ~EP 0 t l989 CHIEF. TRANSPORTATION 8RANCH OATE OIVISION OF SAFEGUAROS ANO TRANSPORTATION OFFICE OF NUCLEAR MATERIALSAFETY ANO SAFEGUAROS

TOPICAL QUALITYASSURANCE,REPOR Rev.

22 Date TABLE OF CONTENTS 6/12/90 Page of REVISION SLURB~

Title Page 16 June 12, 1990 Abstract 4 June 24, 1988 NRC Staff Evaluation Letter July 13, 1989 NRC Letter & Certificate - Quality September 1, 1989 Assurance Program Approval for Radioactive Material Packages Table of Contents 22 June 12, 1990 Quality Assurance Program Policy 8 June 12, 1990 Introduction 11 June 12, 1990 Topical Quality Requirements TQR 1.0 Organization 16 June 12, 1990 TQR 2.0 Quality Assurance Program 9 June 12, 1990 TQR 3.0 Design Control 8 June 12, 1990 TQR 4.0 Procurement Document Control 4 June 12, 1990 TQR 5.0 Instruction, Procedures & 9 June 12, 1990 Drawings TQR 6.0 Document Control 7 June 12, 1990 TQR 7.0 Conttol of Purchased Items 6 June 12, 1990

& Services TQR 8.0 Identification & Control of 2 June 10, 1986 Materials, Parts & Components TQR 9.0 Control of Special Processes 8 June 12, 1990 TQR 10.0 Inspection 9 June 12, 1990 TQR 11.0 Test Control 2 June 10, 1986 TQR 12.0 Control of Measuring &Test Equipment 4 January 18, 1990 TQR 13.0 Handling, Storage &'Shipping 7 June 12, 1990 TQR 14.0 Inspection, Test & Operating Status 5 June 12, 1990

TOPICAL QUALITYASSURANCE REPOR 0 TABLE OF CONTENTS Rev.

Page 2 22 6/12/90 Of REVISION TQR 15.0 Nonconforming Materials, Parts or June 12, 1990 Components TQR 16.0 Corrective Action June 12, 1990 TQR 17.0 Quality Assurance Records June 10, 1986 TQR 18.0 Audits June 12, 1990 Appendices A - Organizations &Figures Figure 1-1: Organization of Departments 16 June 12, 1990 Affecting Quality Figure 1-2: Turkey Point Nuclear June 12, 1990 Site Organization Figure 1-3: St. Lucie Nuclear June 12,'1990 Site Organization B - Qualification & Experience Requirements June 12, 1990 for Quality Assurance Personnel C - Baseline Document Matrix June 12, 1990 D - Cancelled May 7, 1982 E - List of Corporate Quality Assurance 13 March 28, 1990 Procedures (QPs)

F - Topics to be Addtessed in Safety May 7, 1982 Analysis Reports Z

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TOPICAL QUALITY ASSURANCE REPORT Rev.

QUALITY ASSURANCE PROGRAM POLICY Date g>~p Page I of I To avoid undue risk to the health and safety of the public and company employees, it is necessary to design, construct, operate and modify nuclear power plants with a high degree of functional integrity, quality and reliability.

It is the policy of Florida Power & Light Company to design, construct, operate and modify nuclear power plants of a quality level that will meet or exceed government regulations and will merit public confidence by providing electricity in a reliable, efficient and safe manner.

The President of Florida Power &'LightCompany is responsible for the execution of the Quality Assurance Program for Florida Power & Light Company nuclear power plants. The authority for 0 developing and verifying execution of the Program is delegated to the Vice President Nuclear Assurance, thtough the President Nuclear Division.

The head of.each organization performing quality-related activities is responsible for: identifying those activities within their organization which are quality-mlated as defined by the QA Program; establishing and clearly defining the duties and resp'onsibilities of personnel within their organization who execute those quality related activities; and planning, selecting, and training personnel to meet the requirements of the QA Program.

R. E. Talion, President Florida Power & Light Company

TOPICAL QUALITY ASSURANCE REPORT Rev.

INTRODUCTION 0 t 06/12/90 Page 1 of 2 The Topical Quality Assurance Report (FPLTQAR 1-76A) contains the description of the Florida Power & Light Company (FPL) Quality Assurance Program relative to its nuclear power plants.

'This report consists of three parts: The Introduction, which delineates the purpose and summarizes the scope and applicability of the Topical Quality Assurance Report. The second part, Topical Quality Requirements (TQRs), which delineate Quality Assurance Program requirements and summarizes the FPL approach to activities related to materials, parts, components, systems, and

'ervices included in the Quality Assurance Program. The third part, Appendices, which provide supporting statements, tabulations, and technical analyses or deviations which are not, in themselves, the subject of the report.

The Topical Quality Assurance Report shall be an integral part of the corporate Quality Assurance Manual (FPL-NQA-100A), and shall delineate the generic requirements and responsibilities by which FPL implements the corporate Quality Assurance Program. Revisions and changes to this Report will be made in accordance with a Quality Procedure as outlined in TQR 2.0. The remainder of the Quality Assurance Manual is comprised of Quality Procedures (QPs) which serve as the documents which describe how the interfacing of tasks between departments or organizations is achieved. The Quality Procedures also cover those technical elements which require a common corporate position for interfaces or resolution of problem areas.

In addition to the Quality Assurance Manual, Quality Instructions (QIs) are developed as required by each of the implementing plants and departments. Quality Instructions describe the measures to be used to implement the quality requirements of the Quality Assurance Manual. The Quality Instructions describe actions and responsibilities to be performed within a department or organization and address the requirements of the appropriate Topical Quality Requirements, and Quality Procedures.

The FPL Quality Assurance Program meets the requirements provided by the NRC Regulatory Guidance and Industry Standards as listed in Appendix C of this Topical Quality Assurance Report.

TOPICAL QUALITY ASSURANCE REPORT Rev.

INTRODUCTION 06/12/90 Page 2 of The requirements of this Topical Quality Assurance Report apply to safety-related materials, parts, components, systems and structures; and to=services employed for design, procurement, construction, operation, maintenance, refueling, repair, and modification. The safety-related systems for each plant are specified in the respective plant Safety Analysis Report.

The FPL Quality Assurance Program fully addresses the requirements of Appendix B to 10 CFR Part 50. The Topical Quality Assurance Report shall be applicable to all existing nuclear plants, those under construction, and supporting FPL departments, and will be referenced in the Safety Analysis Report (SAR). For future plants, the description of activities, requirements, and organizational structures that are unique to a particular plant shall be addressed in the respective SAR document.

Vice President Nuclear Assurance C

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TOPICAL QUALITY ASSURANCE REPORT TQR 1,0 Rev. 16 ORGANIZATION Date 6/12j90 Page 1 of 25 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. The 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.

The FPL President and Chief Operating 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, who is an Executive Vice President of the utility, 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 FPL President has established the Company Nuclear Review Board (CNRB). This" organization's responsibilities are defined in Section 1.2.1.3.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.

TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev. 16 ORGANIZATION Date 6/12/90 Page 2 of 25 (Continued)

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-related matters within the member's department, with the Quality Assurance Department, and with other departments.

The head of each department or organization performing quality-related activities is responsible for. a) identifying those activities within the organization which are quality-related as defined by the Quality Assurance Program; b) establishing and clearly defining the duties and responsibilities of personnel within his organization who execute those quality-related activities; and c) planning, selecting, and training personnel to meet the requirements of the Quality Assurance Program. The responsibility, authority, and organizational relationship for performing quality-related activities within each organization shall be established and delineated in organizational charts and written job or functional descriptions.

The organization charts in Appendix A illustrate the lines of authority and areas of responsibility for each of the organizations that are involved in quality-related activities. 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.

121 122 1.2.1.1 Nuclear Operations 1.2.2.1 Corporate Secretary Coqerate Records

,. 1.2.1.2 Nuclear Engineering Documentary Files and Licensing 1.2.2.2 Environmental Affairs 1.2.1.3 Nuclear Assurance 1.2.2.3 Power Supply 1.2.1.4 Nuclear Administrative Services 1.2.2.4 Computer Operations 1.2.2.5 Information Systems ~

TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev. 16 ORGANIZATION Date 6/12I'90 Page 3 of 25 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.

The President Nuclear Division shall act as the Senior Vice President Nuclear as required by Section 6.0 of the Turkey Point and St. Lucie Technical Specifications.

Reporting to the President Nuclear Division are: the Senior Vice President Nuclear Operations, Vice President Nuclear Assurance, Vice President Nuclear Engineering and Licensing, and the Director Nuclear Administrative Services.

1.2.1.1 Nuclear Operations The Senior Vice President Nuclear Operations is responsible for nuclear power production.

Reporting to the Senior Vice President Nuclear Operations are the Vice President-Turkey Point Plan't, Vice President-St. Lucie Plant, Manager Nuclear Security, Manager Nuclear Training, and Manager Nuclear Energy Services.

ao 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 are the Plant Manager, the Services Manager, the Human Resources Manager, the Superintendent-Plant Licensing, and, at Turkey Point, the Safety Engineering Group.'lso, the Plant Vice President has functional l

responsibility over the Site Construction Services Manager and the Engineering Project Manager, providing work direction to those groups.

F

TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev. 16 ORGANIZATION Date 6/12/90 Page 4 of 25 1.2.1.1 (Continued)

The Plant Manager - PSL and Plant 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 aH safety-related procedures and activities that impact plant safety and the facility operating license.

b. 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.

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

d. The Manager Nuclear Energy Services is accountable for technical staff support to the Nuclear Operations Department and certain centralized special functions. This group consists of section supervisors and technical specialists, with functions including Health Physics, Chemistry, Radiological Waste, and Emergency Planning.

1.2.1.2 Nuclear Engineering and Licensing The Vice President Nuclear Engineering and Licensing is responsible for nuclear plant design, construction services, materials management and maintaining the operating

\

licenses. The Vice President Nuclear Engineering and Licensing shall act as the Vice President Nuclear Energy when required by Section 6.0 of the Turkey Point and St. Lucie Technical Specifications.

TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev. 16 ORGANIZATION 6/12/90 FPL Page 5 of 25 1.2.1.2 (Continued)

Reporting to the Vice President Nuclear, Engineering and Licensing are the Director-Nuclear Engineering, Director - Nuclear Licensing, Director - Nuclear Construction Services and Director - Nuclear Materials Management.

a. Nuclear Engineering Department Nuclear Engineering performs design-related 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 directs the engineering aspects of all FPL nuclear power plant projects during construction and operation to assure eKcient, economical and reliable power plant design, conformance with engineering schedules and budgets and compliance with regulatory requirements.

The Director - Nuclear Engineering reports to the Vice President Nuclear Engineering and Licensing. Nuclear Engineering 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 decoIllnlissloning;

TOPICAL QUALITY ASSURANCE REPORT TQR 1.0.

Rev. 16 ORGANIZATION Date 6/12/90 Page 6 of 25 1.2.1.2 (Continued) 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 records that are identified to be maintained as "as constructed" drawings during plant operation; o the development, control, and performance of certain aspects of procurement, including the technical evaluation, equivalency evaluation, and commercial grade dedication of replacement parts/components for nuclear plants. This also includes configuration 'control activities for controlled design documentation associated with the procurement of items; o 'roviding technical support of activities associated with component reliability, materials evaluations, inspections, corrosion protection, non-destructive examination, and ASME Section XI implementation/problem resolution for nuclear plant components; o for all fuel related design, analyses, reviews, and technical assistance necessary to ensure the safe, reliable, and economic operation of the nuclear plants; o 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 tequirements; o the development and/or review of fuel and nuclear physics design; o implementing and maintaining the FPL corporate nuclear material accountability program as outlined in the FPL Special Nuclear Material Control Manual; o providing support to the Quality Assurance Department for their auditing of nuclear fuel design and fuel assembly manufacturing; o providing specific component expertise, metallurgical support, and non-destructive examination and inspections;

TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev. 16 ORGANIZATION Date 6/12/90 APL Page 7 of 25 1.2.1.2 (Continued) directing and administering the Welding Program and for the technical direction and administrative control of all personnel within the Welding organization.

This includes the development and implementation of policies, plans and procedures to meet the requirements of the Quality Assurance program, codes and standards; developing, maintaining and controlling the FPL Welding Control Manual to originate and qualify welding procedure specifications and qualification of welders and welding operators to meet the applicable code requirements; and providing administrative and technical direction to personnel within the FPL welding control program to meet engineering welding standards and code requirements.

b. Nuclear Licensing Nuclear Licensing is responsible for.

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

TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev. 16 ORGANIZATION Date @1~

FPL Page 8 of 25 1.2.1.2 (Continued)

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c. Nuclear Materials Management Department I.

The Nuclear Materials Management Department is responsible for nuclear fuel procurement, negotiation, and administration of contracts, purchase and control of materials, and the administrative duties required to support these functions. Reporting to the Director Nuclear Materials Management are the Manager Nuclear Contracts, the Superintendents Site Material Management (Turkey Point and St. Lucie), and the Supervisor of the Nuclear Fuel Supply Group.

1) Nuclear Contracts Department The Nuclear Contracts Department is responsible for generation, negotiation and issuance of contracts and purchase orders for services associated with repairs, constructors, construction managers, Architect Engineer (A/E) and consulting services, and material and equipment as required to support Nuclear Division support staff. Nuclear Contracts is also respqnsible for assuring that technical and quality requirements developed by others are incorporated into the procurement documents which it authorizes and that these documents have the required approvals. Services for nuclear safety-related applications are secured only from approved suppliers, or commercial grade, as applicable. It is responsible for maintaining traceability of procurement document records until transmitted to an approved storage facility.

2) Site Material Management The Site Superintendents Material Management (Turkey Point and St. Lucie) are responsible for the procurement and control of FPL's nuclear materials and equipment. Each department is comprised of three operations: Purchasing, Warehousing, and Procurement Engineering.

TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev. 16 ORGANIZATION Date 6/12/90 Page 9 Df 25 1.2.1.2 (Continued)

Purchasing is responsible for the procurement of materials and equipment by FPL for its nuclear power plants with the exception of Nuclear Fuels. Materials and equipment for nuclear safety-related application are secured only from approved suppliers, or as commercial grade, as applicable. Purchasing is responsible for assuring that technical and quality requirements developed by others are incorporated in the proctuement document which it authorizes, and that these documents have the required approvals. It is responsible for, maintaining traceability of procurement document records until transmitted to an approved storage facility.

Warehousing is responsible for the receipt, handling, storage, shipping and issue of materials and equipment received at the plant site for control by Site Material Management. This responsibility encompasses spare and replacement parts, components, and equipment for plant equipment through all phases of plant life. During operations, Warehousing also performs additional quality-related activities such as handling and segregation for nonconforming items received for material control.

Procurement Engineering is responsible for the establishment of procurement standards for material and equipment purchased for'use at'PL s nuclear sites. This responsibility includes review and approval of procurement documents for safety-related materials and equipment.

It also includes the preparation of commercial grade dedication packages for spare or replacement parts, components, and equipment.

TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev. 16 ORGANIZATION Date 6/12/90 Page 100f 25 1.2.1.2 (Continued)

3) Nuclear Fuel Supply Group The Nuclear Fuel Supply Group is responsible for the procurement, management, and accountability for FPL's nuclear fuel assets, and for providing support to fuel users within FPL. The Supervisor Nuclear Fuel Supply is responsible for:

forecasting FPL's nuclear fuel requirements and the availability of nuclear fuel; determining sources of supply and evaluating alternatives and negotiating and establishing arrangements with suppliers for acquisition, processing and delivety 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; providing support to the Quality Assurance Department for their'uditing of nuclear fuel design and fuel assembly manufacturing, 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;

TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev. 16 ORGANIZATION Date 6/12/90 Page 110f 25 1.2,1.2 (Continued)

The Nuclear Fuel Economics and Planning Section is responsible for the accountability reporting of FPL's nuclear fuel assets to other FPL groups, and for providing support in computer code maintenance to the Nuclear Fuel Supply Group. The Supervisor Nuclear Fuel Economics and Planning reports to the Supervisor Nuclear Fuel Supply. The Supervisor Nuclear Fuel Economics and Planning is responsible for.

providing and maintaining computer programs/software and procedures available for Nuclear Material Management's line functions and other departments for daily use in maintaining records, and reporting of off-site nuclear fuel management activities; 0 maintaining effective and controlled computer access to nuclear applications; 0 performing audits and coordinating accountability reporting on all nuclear fuel; 0 develop and provide, to appropriate FPL groups, information necessary to determine FPL's fuel-related costs and to finance fuel-related expenditures.

d. Nuclear Construction Services Nuclear Construction Services exercises management control of assigned projects.

This management control begins when a project is assigned to Nuclear Construction Services and continues until the facility is accepted for operation or the project is complete. This management control includes the responsibility for coordination of specifications and requisitions, repair, construction and may include preoperational start-up and testing of power plant modifications.

z Ol cv C

0

TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev. 16 ORGANIZATION Date 6/12/90 FPL Page 12of 25 1.2.1.2 (Continued)

The Director - Nuclear Construction Services is responsible for:

0 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 Services Manager.

The Director - Nuclear Construction Services reports directly to the Vice President Nuclear Engineering and Licensing.

Reporting to the Director -'uclear Construction Services are the Manager Construction Control and the Site Construction Services Managers.

The Manager Construction Control is zesponsible for:

0 monitoring budget performance against planned engineering activities as budgeted by the Construction Services organization; monitoring the efficient utilization of resources expended'against Construction Services budgeted activities; and 0 ensuring economic utilization of capital construction 'equipment at all Construction Services locations.,

The Site Nuclear Construction Services Manager is responsible for.

0 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; 0 obtaining corrective action from any contractor's management and; when necessary, exercising the authority to stop work on project activities adverse to quality.

TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev. 16 ORGANIZATION Date 6/12/90 Page 13of 25 1.2.1.2 (Continued)

Reporting to the Site Construction Services Manager are the Lead Construction Supervisors. The Lead Construction Supervisor is responsible for conformance construction activities to the requirements of specifications, codes, regulations of'roject 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. Frequently the work of installation and administration of Plant Changes and Modifications is assigned to Nuclear Construction Services. The Site Construction Services Manager will report to the appropriate Plant Vice President but will also receive guidance and advice from the Director - Nuclear Construction Services.

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

TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev. 16 ORGANIZATION Date 6/12/90 Page 14of 25 1,2.1.3 Nuclear Assurance Department The Vice President Nuclear Assurance is responsible for the selection, technical direction, 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 CNRB administrative support. The Vice President Nuclear Assurance also initiates QA Program policy changes when necessary. In addition, the Vice President Nuclear Assurance is responsible for a team independent of the Quality Assurance Department to perform periodic audits of 'electing 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 are 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.

a. Company Nuclear Review Board (CNRB)

The Company Nuclear Review Board (CNRB), reporting to the Executive Vice President Nuclear, is comprised of executive level members of management with responsibilities for the execution of the Quality Assurance Program. The CNRB reviews, or directs the perfoimance of reviews of, activities concerning the technical aspects of the operating nuclear power plant insofar as they impact on 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 charter. 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.

TOPICAL, QUALITY ASSURANCE REPORT TQR 1.0 R-.. 16 ORGANIZATION 6nmm Page 15 of 25 1.2.1.3 (Continued)

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 Department. The results of this audit are presented to the Vice President 'ssurance Nuclear Assurance and the CNRB.

r The Senior Vice President responsible for Power Delivery, Construction, Power Plant Engineering, and Projects will perform his CNRB membership duties as Acting Group Vice President.

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 procedures 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.

TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev. 16 ORGANIZATION Date 6/12j90 Page 16of 25 1.2.1.3 (Continued)

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, procurement, 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.

L'ucie 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 Quality Manager - Juno Beach directs and administers the Corporate Quality Assurance Program, including developing and verifying implementation of policies, plans, tequirements, procedures and audits which assure compliance with the baseline documents listed in Appendix C of this Topical Quality Assurance Report.

Additionally, the Quality Manager - Juno Beach is responsible for assuring the quality of safety-mlated items and services, and their vendors.

The duties, responsibilities, and authorities of each Quality Assurance group are described in the sections which follow.

1) Quality Assurance Services Group Quality Assurance Services, reporting to the Quality Manager - Juno Beach, consists of the Quality Assurance Systems and Audits Group, the Quality Assurance Procurement Group, and the NDE Level III.

TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev. 16 ORGANIZATION Date 6/12/90 FPL Page 17of 25 1.2.1.3 (Continued)

Quality Assurance Systems and Audits is responsible for the development and maintenance of the overall Quality Assurance Program, including the following:

develop and maintain the Quality Assurance Department Quality Instructions, Quality Assurance Department Training & Organization Manual, and the corporate Quality Assurance Manual; including the administration. of the Quality Assurance Program Review-Committee (QAPRC) t assist other departments in the development of Quality Instructions by review and comment and through interpretation of corporate Quality Assurance requirements; develop and implement a Quality Assurance indoctrination program for FPL personnel, and a training program for the Quality Assurance Department; prepare reports on Quality Assurance Program activities for review by the Company Nuclear Review Board; 0 maintain a file system for documentation of quality assurance activities performed by the Quality Assurance Department; Regulatory Guides,.Codes, SAR Document Commitments and

'eview Standards for impact on the Quality Assurance Program and recommend appropriate program changes; review documents submitted to the Company Nuclear Review Board (CNRB) as requested by the Quality Assurance Department CNRB member, plan, coordinate and implement a comprehensive system of periodic internal .

audits with support from the other Quality Assurance groups, when necessary; 0 review FPL originated design specifications for inclusion of appropriate quality requirements.

Quality Assurance Procurement is responsible for assuring the quality of safety-related items and services,'and their vendors, including the following:

TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev. 16 ORGANIZATION Date 6/12/90

@PL Page 18of 25 1.2.1.3 (Continued) 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; o review and approve FPL procurement documents and changes to these documents to assure that the necessary quality requirements are imposed; 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 maintain a file system for documentation of quality assurance activities performed by the Quality Assurance Procurement group; o evaluate the Quality Assurance capability of suppliers requested by the Nuclear Materials Management Department and maintain the Quality Assurance Department "Approved Suppliers List".

The responsibility of this group, in terms of phases of procurement, begins with the preparation of the procurement document, extends through bid evaluation, vendor selection, fabrication and shipment; and ends upon receipt of shipment at the operating plant or warehouse.

. This group, through audits and surveillances, assures that the contractors'rganizations performing Quality Assurance functions have sufficient authority and organizational freedom to implement effective Quality Assurance programs.

TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev. 16 ORGANIZATION SnW90 APL Page 19<<25 1.2.1.3 (Continued)

The NDE Level IIIis responsible for technical direction and monitoring the NDE activities performed by Quality Control at the plant sites (PTN and PSL). He is responsible for preparation, revision and implementation of NDE procedures, and the training, testing and qualification of NDE personnel performing these activities. He is also responsible for providing the programs and direction for performance of NDE activities meeting the ASME, AWS and other NDE code requirements.

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

Quality Assurance activities at the plant sites (FIX 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 in the development and implementation of policies, plans, requirements, and procedures for portions of the quality 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 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 accoidance with the appropriate Quality Procedures;

TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev. 16 ORGANIZATION Date 6/12/90 Page 20of 25 1.2.1.3 (Continued) o review and comment on Quality Instructions or equivalent quality-related 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);

o review site generated FPL procurement documents and changes. to procurement documents in accordance with the appropriate Quality Procedures; 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 Procurement group.

The interface with the Quality Assurance Procurement 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 quality control aspects of the Quality Assurance Program at the plant site. Reporting directly to the Site Quality Manager is the Quality Control Superintendent who has the authority and freedom to administer the Quality Control program and, when necessaiy, to stop activities adverse to quality. The Quality Control

TOPICAL'UALITYASSURANCE REPORT TQR 1.0 Rev. 16 ORGANIZATION Date 6/12/90 Page 21of 25 1.2.1.3 (Continued)

Superintendent, his staff, 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 Control efforts include preparation and review of plant procedures, PCMs, quality-related instructions and procurement documents; Quality Control personnel are also responsible for inspection, monitoring, 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 pf an item or activity accomplished during this period to quality requirements (e.g., records review, NDE, inspections). The Quality Control Superintendent 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-related 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-related problems.

TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev. 16 ORGANIZATION Date 6/12/90 Page 22of 25 1.2.1.3 (Continued)

c. Nuclear Safety Speakout The Manager Nuclear Safety Speakout has responsibility for the management and implementation of the Nuclear Safety Speakout Program. Speakout provides a forum for employees and contractors to communicate their concerns to FPL. Concerns are documented, investigated and corrective 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.

1.2.1.4 Nuclear Administrative Services The Director Nuclear Administrative Services, reporting to the President Nuclear Division, is responsible for coordinating the budget, rate, and cost control support to the plants and staff organizations, directing the planning, administration and control of computerized information management activities, coordinating the office services and document control activities, personnel related issues, and human resources for the Nuclear Division staff groups.

~-

1.2.2 Providing support activities for the Nuclear Division are the Corporate Secretaty, Environmental Affairs, Power Supply, Computer Operations, and Information Systems. The reporting relationship of each department is described in the following sections and is shown in Appendix A.

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

TOPICAL QUALITY ASSURANCE REPORT , TQR 1.0 Rev. 16 ORGANIZATION Date 6/12/90 Page 23of 25 1.2.2.1 (Continued)

a. Corporate Records Services The Manager Corporate Records Services is responsible for: ensuring the Quality Assurance records program activities are managed in accordance with applicable laws and regulations; assisting with the development and implementation of effective and compatible records and micrographics programs; developing, approving and maintaining record retention schedules; establishing parameters for indexing in the corporate records'omputerized Record Management System (RMS); 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 "Quality Assurance approved" storage facilities and maintaining the records of this evaluation.

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 fiom other departments.

1.2,2'.2 Environmental Affairs Environmental Affairs is responsible for obtaining the federal and state environmental 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.

P The Manager Environmental Technical Services, the Manager Environmental Resources and Planning and the Manager Environmental Permitting and Programs report to the Director Environmental Affairs. The Director Environmental Affairs has overall responsibility for implementation of the Environmental Protection Plans at nuclear power plant sites.

TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev.

16 Date ORGANIZATION 6/12/90 Page 24of 25 1.2.2.2 (Continued)

The Environmental Affairs Department through its management of the Company Environmental Review Group (CERG) is responsible for overall coordination of environmental monitoring programs and requirements related to the Environmental Piotection 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 environmental matters for which requirements are included in Environmental Protection Plans.

1.2.2.3 Power Supply Within the Power Supply Department only equipment and services provided by the System Protection Group and Power Supply Technical Services Group are subject to the requirements of the Quality Assurance Program. Appendix A illustrates the reporting relationship.

System Protection is responsible for test, calibration and maintenance of certain high voltage electrical protective relays for safety-related systems of the nuclear plant. Activities of System Protection include final wiring connection checks, preoperational check-out and test of system protection devices and providing inspection of equipment under their cognizance.

Power Supply Technical Services is responsible for providing certain setpoint and checkpoint values for protective devices.

TOPICAL QUALITY ASSURANCE REPORT TQR 1.0 Rev. 16 ORGANIZATION Oate 6/12/90 Page 250f 25 1.2.2.4 Computer Operations The Computer Operations 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 and the Manager Technical Systems report to the Director Computer Operations who reports to the Group Vice President and Chief Financial Officer.

1.2.2.5 Information Systems Information Systems gS) is responsible for the development, maintenance, support, and control of corporate non-nuclear computer applications. IS provides support to Nuclear Division in their development and maintenance of Nuclear applications, including data security, and, software library controls. In addition, Information Systems is responsible for software libraries on FPL's in house time-sharing computer system (CMS) that are under its control.

TOPICAL QUALITY ASSURANCE REPORT TQR 2.0 Rev. 9 QUALITY ASSURANCE PROGRAM Date 6/12/90 Page 1 of 7 Florida Power & Light Company has established a Quality Assurance Program which complies with the criteria of 10 CFR 50 Appendix B, and meets the requirements of Regulatory Guides and Industry Standards referenced in Appendix C of this report. The Topical Quality Requirements and attached Policy Statement, together with the Quality Procedures and Quality, Instructions document the Program and the FPL policy with regard to Quality Assurance. This Program shall be instituted for each plant site in a schedule consistent with accomplishing the required activity and shall be carried out thmughout the life of FPL nuclear plants.

The requirements of the FPL Quality Assurance Program shall only apply to nuclear safety-related structures, systems, and components as identified in the Safety Analysis Report for each nuclear unit. Additionally, the requirements of the FPL Quality Assurance Program shall apply to all FPL, contractor, or consultant organizations performing activ'ities affecting the quality of safety-related structures, systems, and components of FPL nuclear power plants.

Documented procedures shall require and define indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.

Periodic program reviews of the status and adequacy of the FPL Quality Assurance Program shall be accomplished by the independent audit team described in Section 1.2.1.3.a and by" Quality Assurance Department audits.

of organizations outside Florida Power & Light Company participating in the

'anagement Program shall be required to regularly review the status and adequacy of that part of the FPL Quality Assurance Program which they are executing. The FPL Quality Assurance Department shall teview and concur in the Quality Assurance Program of contractors.

TOPICAL QUALITY ASSURANCE REPORT 2.0 Rev. 9 QUALITY ASSURANCE PROGRAM'QR Date 6/12/90 Page 2 of 7 2.2 2.2.1 Goals and Objectives As stated in the Policy Statement of the President of Florida Power & Light Company, the goal of the FPL Quality Assurance Program is to maintain quality levels in an effective and efficient manner, and to assure the high degree of functional integrity and reliability of nuclear safety-structures, systems, and components. To meet this goal, the following objectives of the 'elated FPL Quality Assurance Program have been defined:

ao Define though documented procedures and instructions the quality activities that apply to the design, fabrication, procurement, modification, testing, operation, refueling, maintenance, and repair of nuclear power plants;

b. Establish, assign, and document the responsibilities for those activities affecting quality of safety-related structures, systems, and components; C. Establish confidence that the design, fabrication, modification, and operation of nuclear power generation facilities are performed in a manner consistent with FPL policies by assuring quality-related activities are performed by responsible personnel;

d. Apprise management of unresolved problems and trends which could have a significant effect on nuclear power plant safety; and

e. Prevent schedule delays and high cost due to poor quality.

2.2.2 Program Documentation The Topical Quality Assurance Report, which defines the policy, goals, and objectives regarding the Quality Assurance Program, shall be contained in the FPL Quality Assurance Manual, and used as guidance for the development of corporate level Quality Procedures which are also contained in the Quality Assurance Manual. Revisions to the Topical Quality Assurance Report will be made, as needed, to refiect current FPL program requirements and descriptions of activities. These revisions shall be made in accordance with a Quality Procedure. Ifa program

TOPICAL QUALITY ASSURANCE REPORT TQR 2.0 Rev.

QUALITY ASSURANCE PROGRAM Date 9] ~p Page 3 of 7 2.2.2 (Continued) reflects a reduction of the commitments from the baseline documents contained in Appendix C, the revision shall be submitted to and approved by the NRC prior to implementation.

In all other cases, amendments to the Topical Quality Assurance Report will be submitted to the NRC to reflect implemented program revisions on an annual or more frequent basis.

Quality Procedures shall be written by the department with major responsibilities for an activity, or by the Quality Assurance Department when requested. These procedures shall be reviewed by all the departments with responsibility for some portion of that procedure, and shall be approved by the major implementing departments with co-approval by the Vice President Nuclear Assurance. A listing of corporate level Quality Procedures is contained in Appendix E.

Each Quality Procedure shall be written to further address criteria contained in the Topical Quality Requirements and to further define the FPL Quality Assurance policies, plans, and program where action is required by more than one department.

Each department head shall have the responsibility for implementation of the Quality Assurance Program, which includes compliance with procedure mquirements applicable to his department.

In addition, he shall be responsible for the preparation, approval, and distribution of Quality Instructions, operating procedures, testing procedures, or other instructions where further guidance is necessary for implementation of the Quality Assurance Program requirements within his department. Quality Instructions shall be reviewed by the Quality Assurance Department at each revision.

TOPICAL QUALITY ASSURANCE REPORT TQR 2.0 Rev. 9 ASSURANCE PROGRAM Date 6/12/90 'UALITY Page 4 of 7 2.2.3 Structures, Systems, and Components The requirements of the FPL Quality Assurance Program shall apply to nuclear safety-related structures, systems, and components, as defined in the SAR. Safety-related structures, systems, and components are listed as those necessary to assure the integrity of the reactor coolant boundary, the capability to shutdown the reactor and maintain it in a safe shutdown condition, or the capability to prevent or mitigate the consequences of accidents which could result in off-site exposures comparable to the guideline exposures of 10 CFR 100.

Control over activities affecting the quality of safety-related structures, systems,- and components shall be to the extent consistent with their importance to safety. Such control shall include use of appropriate equipment, establishment of suitable environmental conditions, and assurance that all prerequisites for a given activity have been satisfied. The Program shall provide for controls over special processes and skills necessary to attain the required quality, and the need for verification of quality by inspection and test.

Advance planning is required, for the control of management and technical interfaces between FPL and contractors, during the phase-out of design and construction and during preoperational testing and plant turnover. This is achieved through periodic meetings of concerned organizations and the development of procedures which define responsibilities and interfaces, and control the testing and turnover of plant systems to FPL.

2.2.4 Participating Organizations The FPL organizations with responsibilities for activities affecting quality of nuclear safety-related structures, systems, and components are identified in TQR 1.0, which also briefly describes their assigned responsibilities.

Florida Power & Light Company may delegate activities to contractor organizations and equipment vendors. Delegated activities are subject to the external organization's FPL approved Quality Assurance Program or the FPL Quality Assurance Program, or some FPL approved combination thereof.

TOPICAL QUALITY ASSURANCE REPORT TQR 2.0 Rev. 9 QUALITY ASSURANCE PROGRAM 6/12/90 Page 5 of 7 2.2.4 (Continued)

However, FPL shall retain overall responsibilities for the Quality Assurance Program.

Procurement documents shall define the scope of delegated activities, as well as Quality Assurance Program requirements that shall govern these activities.

The Quality Assurance Department shall review and approve the Quality Assurance Program governing contracted activities prior to award of contract except for activities for which the output is of a conceptual and/or prototype nature. In all cases, final approval shall occur at a point in the process to ensure that the output complies with the requirements of the FPL approved Quality Assurance Program. The object of this review shall be to verify that the program is in compliance with the applicable requirements of Appendix B, 10CFR50, and ANSI N45.2. Audits shall be conducted periodically to verify the acceptable implementation of the contractor's FPL approved Quality Assurance Program governing delegated activities. The Quality Assurance Department is responsible for conducting these audits. The initial review and periodic audits shall be performed by qualified Quality Assurance Department personnel, and as appropriate, by technical specialists from other FPL departments and contractor organizations.

2.2.5 Indoctrination and Training A program shall be established and maintained for quality assurance indoctrination, and for training which assures that the tcquircd level of personnel competence and skill is achieved and maintained in the performance of quality related activities. Quality Procedures shall delineate the requirements for an indoctrination program to assure that personnel responsible for performing quality activities are instructed in the pmpose, scope, and implementation of the quality related manuals, instructions, and procedures and that compliance to these documents is a mandatory requirement.

Quality Procedures shall also require the head of each department (including the Quality Assurance, Department) to be responsible for a training plan which assures that personnel performing quality related activities am trained in the principles and techniques of the activity

TOPICAL QUALITY ASSURANCE REPORT TQR 2.0 Rev. 9 QUALITY ASSURANCE PROGRAM 6/12190 Page 6 'of 7 2.2.5 (Continued) being performed. This training shall maintain the proficiency of personnel in the skills necessary for the quality related activities through retraining, requalification or reexamination, as appropriate. When personnel are assigned to perform their functions under the direction of personnel from other than their home department, the department head of the organization providing direction is responsible for the indoctrinaton and training of personnel who perform quality-related activities under his direction. Quality Procedures shall specify the requirements for documenting indoctrination and training sessions, including a course description, attendance, location, and date.

2.2.6 Management Participation In addition to the involvement of department heads in implementing the Quality Assurance Program within their departments and the involvement of the Vice President Nuclear Assurance and the Quality Manager - Juno Beach in the development, coordination, and review of the Program, the Company Nuclear Review Board (CNRB) shall be apprised of the status and adequacy of the Quality Assurance Program on a periodic basis. The following actions shall be instituted to assure that the CNRB remains informed and meets its Program responsibilities; ao The CNRB shall review a summaty of the results of management level Quality Assurance audits of FPL Departments.

b. The Quality Assurance Department shall circulate monthly reports of quality-related activities to members of the CNRB and affected department heads. The monthly reports may include such items as the status of audits, a summary of audit findings, the status of development projects, and descriptions of policy matters or problems requiring management attention.

C. The CNRB shall review the status of the Quality Assurance Program on a semiannual basis. The review will include assessment of the Program goals, objectives, and accomplishments.

TOPICAL QUALITY ASSURANCE REPORT TQR 2.0 Rev. 9 QUALITY ASSURANCE PROGRAM elmo FPL Page 7 of 7 2.2.6 (Continued)

d. Periodic audits of the Quality Assurance Department and Program shall be conducted by an independent audit group under the direction of the Chairman of the CNRB. This audit group shall employ FPL audit procedures and shall distribute the audit report to the Vice President Nuclear Assurance, and to the CNRB for review of findings and corrective action. Auditor certifications of independent audit teams will be retained by the Quality Assurance Department.

The programs of contractor organizations that perform quality related activities shall be reviewed by Quality Assurance to assure that their management regularly reviews the status and adequacy of that part of the FPL Quality Assurance Program which they are executing.

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TOPICAL QUALITY ASSURANCE REPOR TQR 3.0 Rev. 8 DESIGN CONTROL Date 6/1290 1 of page 3.1 A Quality Assurance Program shall be established for design-related activities. This design control program shall ensure, that the design is defined, controlled and verified; that applicable design inputs are specified and correctly translated into design output documents; that design interfaces are identified and controlled; that design adequacy is verified by persons other than those who designed the item; and that design changes, including field changes, are governed by control measures commensurate with those applied to the original design.

Design records shall be developed to provide evidence that the design process and design verification were performed in accordance with the requirements of FPL's Quality Assurance Program. The design organization (Nuclear Engineering or designated contractor organization) shall be responsible for the content of these records.

Design records shall include design output documents and the important steps in the design effort. The intent of this documentation is to allow a technically qualified person to understand how the design was developed, and to allow that person to verify the design based on the design documentation and engineering data sources referenced therein.

3.2 The design organization's Quality Assurance Program for design control shall be approved by the FPL Quality Assurance Department prior to the release of approved design output by the design organization. The design organization is the organization responsible for approval of design output. Quality Procedures and Quality Instructions shall be developed to delineate design control. requirements governing design-related activities performed by Nuclear Engineering and for delegating activities to contractor organizations.

TOPICAL QUALITY ASSURANCE REPORT TQR 3.0 Rev. 8 DESIGN CONTROL 6/1290 Page 2 of 3.2.1 Design Process The design organization shall specify and document its design activities to the level of detail necessary to permit the design to be developed in a correct manner and to permit verification that design output documents satisfy design input requirements.

Design methods, materials, parts, equipment and processes, including those associated with commercial grade items that are essential to the function of the structure, system or component shall be selected, reviewed and approved for suitability of application by the design organization.

Design inputs shall be identified, documented, reviewed and approved by the design organization.

They shall be specified to the level of detail necessary to permit the design activity to be carried out in a correct manner, and to provide a consistent basis for making design-related decisions, performing design verification and evaluating design changes. Changes to approved design inputs, including the reason for the changes, shall be approved, documented and controlled by the design organization.

The design organization shall identify aspects of manufacture, construction, inspection and testing critical to achieving the function of the structure, system or component. Quality standards and quality requirements shall be specified on design output or procurement documents.

Changes from approved quality-related requirements specified in design output, including the reason for the changes, shall be approved, documented and controlled by the design organization.

Design analyses shall be controlled and documented. Approved'design output documents and approved changes thereto shall be relatable to the design input by documentation in sufficient detail to permit verification. The design organization shall establish procedures to review industry design experience. As appropriate, this experience, shall be made available to cognizant design personnel.

TOPICAL QUALITY ASSURANCE REPORT TQR 3.0 Rev. 8 DESIGN CONTROL Date 6/1290 APL Page 3 of 3.2.2 Design Change Contml Changes to approved design output documents, including field changes, shall be justified, subjected to control measures commensurate with those applied to the original design, and shall be reviewed and approved by the same design organization that approved the original design unless other organizations are specifically designated.

Where a significant design change is necessary because of an incorrect design, Nuclear Engineering shall determine the cause of the incorrect design. As necessary, design and verification procedures shall be reviewed and modified to correct the cause of the incorrect design.

During the operations phase, design changes shall also be reviewed by operating plant management and Quality Control. The intent of this review is to ensure that implementation of the design change is coordinated with any necessary changes to operating procedures and practices, and required Quality Control Surveillance activities.

In accordance with plant technical specification requirements, nuclear safety-related design changes are reviewed by the Plant Nuclear Safety Committee (PNSC) or Facility Review Group (FRG) and the Company Nuclear Review Board (CNRB).

3.2.3 Design Interface Control The, design organization shall be responsible for identification, control, resolution and documentation of design interface requirements. Procedures shall establish interface controls between participating organizations and between the various technical disciplines within the design organization. These procedures shall include the assignment of responsibility, and be in sufficient detail to cover the preparation, review, approval, release, distribution and revision of design output documents.

TOPICAL QUALITY ASSURANCE REPORT, TQR 3.0 Rev. 8 DESIGN CONTROL Date 6/1290 pag 4 Or 5 3.2.3 (Continued)

For interdisciplinary design, approval documentation of each involved discipline of the design organization shall appear on the design output document or on a separate document directly traceable to the design output. The design organization shall designate a discipline(s) responsible for resolution of the comments of participating organizations. The designated discipline(s) approval of a design output shall also document resolution of the comments of participating organizations.

3.2.4, Design Verification Design control measures shall be established to independently verify the design inputs, design process, and th'at design inputs are correctly incorporated into design output. The design organization shall develop procedures that govern design verification. These procedures shall require that the design organization identify and document the verification method utilized and that the documentation clearly identify those individuals performing the design verification.

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 from the design organization. Design verification by the designer's immediate supervisor shall be limited to those instances where the supervisor is the only qualified individual available within the design organization. These instances are further restricted to designs 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.

The design organization shall be responsible for determining the extent of design verification and methods to be employed. The methods may include one or more of the following: the performance of design reviews, the use of alternate calculations, or the performance of qualification tests. This shall apply to original design and to changes to approved design output.

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TOPICAL QUALITY ASSURANCE 'REPORT TQR 3.0 Rev. 8 DESIGN CONTROL Date 6/1290 FPL Page 5 0~ 5 3.2.4 (Continued)

Where reverification is not required for a design change, the bases shall be documented by the design organization. Cursory supervisory reviews and mathematical checks for calculation accuracy do not satisfy the independent design verification requirement. Design verification shall normally be completed prior to release of design output for procurement, manufacture or release by the design organization for use in design activities by a participating organization.

Verification shall be conducted based on the status of design at the time of release of design documents. Where this timing cannot be met, verification may be deferred provided that the unverified portion of the design output, and all design output documents, structures, systems and components based on the unverified portion of design are identified and controlled. In all cases verification shall be completed prior to relying on any affected items to perform their design functions.

3.2.5 Computer Programs/Software Organizations utilizing computer programs/software as a method for design shall maintain instructions or procedures to effect the following:

1. That such programs/software are verified for their particular use using benchmark problems, alternate calculations, comparison with other code or experimental results, design review or similar methods,

2. That such programs/software have been qualified for their specific application sufficient to ensure valid results,

3. That such programs/software are provided with user instructions sufficient for a technically competent individual to follow,

4. That configuration controls are provided to assure that such programs/software changes or modifications are documented and controlled.

TOPICAL QUALITY ASSURANCE REPORT TQR 4.0 Rev.

PROCUREMENT DOCUMENT 6nmo CONTROL Page 1 of 3 4.1 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.

4.2 4.2.1 Procurement Document Provisions Quality Procedures and Quality Instructions shall identify the responsibilities and actions required of the organizations originating, reviewing, approving, and controlling procurement documents. These procedures shall require the procurement documents to specify:

a.'he 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'nclude 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.

TOPICAL QUALITY ASSURANCE REPORT TQR 4.0 Rev.

PROCUREMENT DOCUMENT 6nmo CONTROL Page 2 of 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 quality assurance records which will not 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 standaxds, 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. The preparation and control of design documents and purchase orders is described in TQR 3.0, 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 technical and quality evaluators, and shall assure that the procurement document was prepared, reviewed and approved as required. Spare or replacement parts for safety-related

TOPICAL QUALITY ASSURANCE REPOR TQR 4.0 Rev. 4 PROCUREMENT DOCUMENT Oate 6/12390 CONTROL Page 3 of 3 4.2.2 (Continued) 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 Procure'ment 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.

TOPICAL QUALITY ASSURANCE REPORT TQR 5.0 Rev.

INSTRUCTIONS, PROCEDURES Date 6/12/90 R DRAWINGS Page 1 of 3 5.1 Activities affecting quality of nuclear safety-related structures, systems, and components shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. These documents shall include appropriate quantitative criteria such as dimensions, tolerances, and operating limits, and qualitative criteria such as comparative workmanship samples, to assure that the quality assurance activity has been satisfactorily accomplished.

5.2 5.2.1 Quality Assurance Program Documents The FPL Quality Assurance Manual described in TQR 2,0 contains corporate Quality Procedures which comply with the criteria of 10 CFR 50, Appendix B. Quality Procedures and department level Quality Instructions provide direction for activities affecting quality. The Quality Assurance Department reviews and comments on Quality Instructions written by other departments. Comments concerning compliance with corporate Quality Assurance commitments and regulatory requirements are resolved prior to issuance. The Quality Assurance Department receives controlled copies of Quality Instructions issued by other departments.

5.2.2 Procedures and Instructions Instructions and procedures for activities affecting quality shall be prepared, reviewed, and approved in accordance with written Quality Procedures or Quality Instructions.

For plant operations, on-site plant procedures shall be prepared, reviewed, and approved in accordance with written instructions which includes a review for concurrence by Quality

TOPICAL QUALITY ASSURANCE REPORT TQR 5.0 Rev.

INSTRUCTIONS, PROCEDURES Date 6/12/90

& DRAWINGS Page 2 of 3 5.2.2 (Continued)

Assurance or Quality Control personnel. These plant pamedures include operating procedures, off-normal and emergency procedures, test procedures, and calibration procedures. Also included are maintenance and repair procedures for subcontracted maintenance and repair activities which are outside the normal scope of plant craft capability.

For backfit activities, contractors shall be required to have Quality Assurance Programs which contain written instructions for preparation, review, and approval of procedures, instructions, and drawings affecting quality. In addition, Contractor's site procedures and Quality Control inspection procedures shall be approved by an FPL Site Construction Services Manager, or designee, following reviews by Quality Assurance or Quality Control personnel to assure compliance with Corporate commitment and regulatory requirements.

During the design, modification, and procurement phases, the Architect/Engineer or other contractors may be delegated responsibility for maintaining, issuing and verifying the

.implementation of appropriate program documents. In this case, Quality Assurance Department audit and/or Quality Control surveillance activities shall assure that such measures are established and implemented. Contractor programs shall clearly delineate the actions to be accomplished in the preparation, review and control of instructions, procedures and drawings; and the methods for complying with the appropriate criteria of 10 CFR 50, Appendix B. A plant change or modification of a magnitude requiring the assignment of a Site Construction Services Manager shall be subject to the Quality Assurance Program as discussed above.

5.2.3 'rawings The design organization is responsible for review and approval of drawings. For delegated design activities, Nuclear Engineering Department may approve changes to drawings. The technical control of drawings, i,e., review and approval of the drawing and all changes thereto shall be governed by procedures. A means shall be developed and updated as required to identify approved drawings and revisions thereto. A Master Drawing List is the normal means used for this,

TOPICAL QUALITY ASSURANCE REPORT TQR 5.0 Rev.

INSTRUCTIONS, PROCEDURES Date 6/12/90

& DRAWINGS Page 3 of 3 5.2.4 Acceptance Criteria Quality Procedures and Quality Instructions require that quality-related instructions, procedures, and drawings include adequate quantitative and qualitative acceptance criteria, as appropriate, for determining satisfactory work performance and quality compliance. These acceptance criteria requirements apply to important activities such as design, operations, test control, inspection,

~ and plant modifications.

TOPICAL QUALITY ASSURANCE REPORT TQR 6.0 Rev.

DOCUMENT CONTROL Date 6/12j90 Page 1 of 3 6.1 The distribution, of documents such as instructions, procedures, drawings, and software which provide guidance, specifications, or requirements affecting the quality of nuclear safety-related structures, systems, and components shall be controlled. These documents shall be prepared, reviewed for adequacy, and approved for release by authorized personnel in the affected organization. These documents shall be distributed to locations where the activity is performed.

Changes to controlled documents shall be so identified and shall be reviewed and approved by the same organization that performed the original review and approval unless otherwise specified in the implementing procedures. In addition, procedures shall provide for controlling obsolete documents to preclude the possibility of use of outdated documents.

6.2 6.2.1 Responsibility Quality Procedures shall delineate the control measures for controlled documents including direction for the review for adequacy, approval by authorized personnel, distribution of controlled documents and verification that changes are received. These control measures shall apply to documents affecting the quality of nuclear safety-related structures, systems, and components such as:

a. design specifications;

b. design, manufacturing, construction, and installation drawings;

c. quality program manuals, procedures, and instructions;

d. inspection, manufacturing, and test procedures and instructions;

e. plant operating and maintenance procedures;

f. plant Safety Analysis Reports and related design criteria documents.

TOPICAL QUALITY ASSURANCE REPORT TQR 6.0 Rev.

DOCUMENT CONTROL Date 6/12/90 FPL Page 2 of 3 6.2.1 (Continued)

The requirements for control of procurement documents are contained in TQR 4.0.

During all phases of the plant life, it shall be the responsibility of each organization issuing and using controlled documents to use document control procedures. Procedures shall document the responsibility for review, approval, maintenance and distribution of documents including assuring revisions are initiated to interfacing documents within their organization.

During the design and construction phase and for operating plant changes under their cognizance, the Architect/Engineer, Nuclear Steam Supply System vendor, and other contractors shall be responsible for assuring that all revisions required as a result of FPL comments, nonconformances, or engineering work are incorporated into revised documents.

6.2.2 Distribution of Controlled Documents Quality Procedures shall specify that controlled. documents and revisions be distributed to locations where the activity is performed.

6.2.3 Drawing Control FPL assumes control of the drawings and Master Drawing List after initial operation of the facility or delegates this activity to a qualified contractor. Nuclear Engineering shall require design organizations update the drawings and Master Drawing List to reflect. the that'articipating as-built conditions of the facility prior to FPL's acceptance of these documents.

Maintenance, distribution and control of the drawings and the Master Drawing List by FPL during the operation phase shall be assigned to a drawing custodian. Revision to drawings shall be approved prior to release by the drawing custodian, approval shall be by Nuclear Engineering, or a designated design organization.

TOPICAL QUALITY ASSURANCE REPORT TQR,6.0 Rev.

DOCUMENT CONTROL Date 6/12/90 FPL Page 3 of 3 6.2.3 (Continued)

During the operation phase a system shall be established to provide ready access and availability of drawings to engineering and operations personnel; to identify drawings affected by approved plant design changes; and to update drawings and the Master Drawing List to refiect implemented design changes.

6.2.4 Instruction & Procedure Control Participating organizations shall be responsible for development, maintenance and control of those documents identified in paragraph 6.2.1 issued by them as controlled documents. Each organization shall be responsible for the adequacy of their procedures.

6.2.5 Obsolete Documents Controls established by Quality Procedures and Quality Instructions shall assure that outdated copies of controlled documents are not inadvertently used.

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TOPICAL QUALITY ASSURANCE REPORT TQR 7.0 Rev. 6 CONTROL OF PURCHASED 6/12/90 ITEMS & SERVICES Page 1 of 3 7.1 Measures shall be established to assure that safety-related items or services purchased by or for FPL conform to the requirements of the procurement document. These measures shall include documented evidence of source selection, verification activities and examination of items or services to assure compliance with the procurement document. The effectiveness of the control of quality by contractors and subcontractors shall be assessed at intervals consistent with the importance, complexity, and quantity of the product or service.

7.2 7.2.1 Initial Evaluation of Suppliers Procurement source evaluation and selection measures shall be specified in Quality Procedures and Quality Instructions which shall identify the responsibility of qualified individuals for determining supplier capability. The evaluation may require integrated action involving Quality Assurance and one or more organizations (e.g., Nuclear Engineering, Nuclear Construction Services, or Nuclear Materials Management) based upon the item or service being procured.

This evaluation is to ensure that the FPL contractors comply with the applicable portions of 10 CFR 50, Appendix B. Documented evidence of the evaluation, and the acceptance of the contractor's quality program and procedures shall be retained in the Quality Assurance Department files. The determination of supplier approval shall be based on such factors as prior" performance, historical quality performance data, source surveys or audits, and evaluation of the supplier s Quality Assurance Program. The basis shall be consistent with the importance, complexity, and quality required for the items or services involved.

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TOPICAL QUALITY ASSURANCE REPORT TQR 7.0 Rev. 6 CONTROL OF PURCHASED 6/12/90 FPL ITEMS & SERVICES Page 2 of

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7.2.2 Verification Activities Quality Procedures shall define the requirements for verification activities such as surveillance, inspection, or audit to assure conformance of procured items and services to identified requirements. These verification activities shall be performed in accordance with written procedures, procurement documents and their references, which specify the documentation required and the characteristic or process to be witnessed, inspected, verified, or accepted. FPL verification activities shall be accomplished by qualified personnel to verify that the supplier complies with quality requirements, and depending on the importance/complexity, shall be performed on those items where verification of procurement requirements cannot be determined upon receipt.

7.2.3 Receiving Inspection Quality Procedures and Quality Instructions shall delineate requirements and responsibilities for the performance of receiving inspection. This inspection shall verify that suppliers have fulfilled their contractual obligation and that the procured items meet the appropriate quality requirements.

Receiving inspection shall include, as appropriate:

a. Measures for verifying that the shipment is complete, properly identified, undamaged, and corresponds with the purchase order documentation;

b. Measures for inspection of the item and review of supporting documentation (e.g.', mill

test reports, NDE reports) as required by the purchase documents; C. Measures for disposition of items to inspection instructions;

d. Measures for identifying and controlling items including identification of inspection status prior to release from the receiving inspection area;

e. Measures to ascertain that inspection records or Certificates of Conformance are available prior to release.

TOPICAL QUALITY ASSURANCE REPORT TQR 7.0 Rev. 6 CONTROL OF PURCHASED 6/12/90 ITEMS & SERVICES Page 3 of 3 7.2.4 Supplier Furnished Records Records required to be furnished by the supplier shall be specified in the procurement document. Certifications or documentation verifying conformance provided by the supplier shall identify the specific procurement requirements met (either by reference to the putchase order or by referenced requirements therein). Such certification shall identify any procurement requirements which have not been met and provide a description of those nonconformances dispositioned "accept as is" or "repair".

TOPICAL QUALITYASSURANCE REPORT T R 30 Rev.

e FLORIDA POWER 8 LIGHT COMPANY IDENTIFICATIONAND CONTROL OF MATERIALS, PARTS, AND COMPONENTS Date Page l

3une 10 1986 t;f 2

8.1 GENERAL RE UIREMENTS Materials, parts, and components, including partially fabricated assemblies, shall be identified and controlled as required throughout fabrication, receipt, handling, storage, installation, and use of the item. The identification of the item shall be maintained by heat number, part number, serial number, FPL MRS number, or other suitable means, and shall be physically marked on the item or on records traceable to the item. The object of these controls shall be to prevent the use of incorrect or defective materials, parts, and components. (The FPL Material and Supplies MRS number is a number given to each unique type of item in inventory to distinguish it from each other type of item in inventory).

8.2 IMPLEMENTATION Quality Procedures and Quality Instructions shall establish the responsibilities and requirements for the identification and control of materials, parts and components. The procedures and instructions used by all organizations shall assure that identification and control is maintained throughout fabrication, receipt, handling, storage, installation and use of items. Provisions include:

Requirements for traceability to appropriate documentation, such as:

procurement documents, manufacturing documents, drawings, specifications, inspection and test records, and nonconformance reports.

b. Controls to assure that the correct identification of an item is verified and documented prior to fabrication, receipt, handling, storage, installation and use.

C, Requirements which assure that the method or location of markings do not affect the function or quality of an item.

d. Establishment of identification requirements by specifications, drawings,

,I procurement documents, instructions or procedures during initial planning;-

TOPICAL QUALITYASSURANCE REPORT TQR 8.0 Rev. 2 IDENTIFICATIONAND CONTROL OF MATERIALS, PARTS, AND COMPONENTS Date 3une 10, 1986 FLORIDA POWER 4 LIGHT COMPANY Page 2 of 2 8.2 Implementation (Cont'd)

FPL may delegate any portion of the implementation of the identification and control program to the Architect/Engineer, Constructor, Nuclear Steam Supply System vendor or other contractors. If delegated, contracts shall require that the contractor establish an identification and control program which meets the requirements of this TQR.

TOPICAL QUALITY ASSURANCE REPORT TQR 9.0 Rev. 8 CONTROL 'OF 'SPECIAL PROCESSES 6/12/90 Page 1 of 3 9.1 Measures shall be established to assure that special pamesses such as welding, heat treating, and nondestructive examination, are controlled and accomplished by qualified personnel using qualified procedures and equipment in accordance with applicable codes, standards, specifications, criteria, and other special requirements.

9.2 Nuclear Engineering or the delegated contractor organization, as appropriate, shall include special process requirements in their design outputs and changes thereto. Special processes used during plant operations shall be the responsibility of the plant manager, who shall ensure that procedures are developed, reviewed, approved and controlled, and that personnel and equipment are qualified.

9.2.1 Identification of Special Processes Special processes are those processes which must be qualified and controlled where quality is highly dependent on close control of process variables or operator skills, and objective verification (inspection, examination or testing) of end quality is difficult.

As a further clarification, special processes identified as such by applicable codes and standards shall be controlled, qualified, and implemented in accordance with those codes and staridards."

Examples of special processes include (but are not limited to) welding, heat treating, and nondestructive examination. Others, i.e., flushing, protective coating, plating applications and nuclear cleaning should be reviewed to determine ifthey are special processes.

9.2.2 Procedure Qualification and Control Process control procedures written by FPL organizations or their contractors shall be used and qualified as required'pplicable specifications, codes,.or standards.

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TOPICAL QUALITY ASSURANCE REPORT TQR 9.0 Rev. 8 CONTROL OF SPECIAL PROCESSES "'/12/90 Page 3 of 3 9.2.4 (Continued)

For backfit activities, the Quality Control organization is responsible for the review of nondestructive examination documents for acceptance. The Site Construction Services Manager is responsible for assuring that documents for special processes utilized for modifications are properly collected, reviewed, accepted and transmitted for retention of records.

TOPICAL QUALITY ASSURANCE REPORT TQR 10.0 Rev. 9 INSPECTION Date 6/12/90 Page 1 of 4 10.1 A program for inspection shall be established and executed by or for FPL to verify conformance with the documented instructions, procedures and drawings for accomplishing an activity. Such inspections shall be performed by individuals or groups other than those who performed the activity being inspected. Examinations, measurements and tests of materials or products processed shall be performed for each work operation, where necessary, to assure conformance to established requirements. If direct inspection of processed materials or products is impossible or disadvantageous, indirect control by surveillance or monitoring shall be provided. Mandatory inspection, witness, or hold points beyond which work shall not proceed without the consent of FPL or a designated representative shall be indicated in the appropriate documents.

10.2 10.2.1 Inspection Responsibilities For plant operations, maintenance, or modification activities, a program for on-site inspection of activities affecting quality shall be established by the Nuclear Assurance Department. Quality Control shall perform inspections, surveillance and monitoring of plant activities including operations, maintenance or modifications as required by established plans, schedules and/or procedurally required inspection, witness or hold points. In all cases, the personnel performing the inspection shall be independent of the group performing the work.

For these plant activities, the Nuclear Assurance Department may delegate the establishment and execution of this program to a contractor or other designated FPL representative, but shall retain ultimate responsibility for the program.

TOPICAL QUALITY ASSURANCE REPORT TQR 10.0 Rev. 9 INSPECTION Date 6/12/90 Page 2 of 4 10.2.1 (Continued)

For preoperational start-up and testing of plant modifications, Nuclear Division personnel may report functionally to the Site Construction Services Manager and establish plans, schedules and procedurally required inspection, witness or hold points.

In all cases, the personnel performing the inspection shall be independent of the group performing the work.

The System Protection Group may perform inspections of equipment within their purview during operations.* Inspections shall be performed in accordance with approved, written procedures by qualified personnel.

Quality Procedures and Quality Instructions shall be written which delineate the requirements and responsibilities for the performance of inspections.

10.2.2 Inspection Plans and Schedules Documented inspection plans may be either a separate document or an integral part of work instruction documents. The plans shall be based on design specifications, procurement documents, drawings, other specifications or previous experience, as appropriate. Inspections shall be scheduled to assure that sufficient time and resources are available, and to assure inspections are not inadvertently omitted or bypassed.

10.2.3 Inspection Personnel

a. Inspections shall be performed by individuals other than those who performed or directly supervised the activity being inspected. Inspection personnel shall be qualified and certified in accordance with appropriate codes, standards and/or company training programs. Qualifications and certifications shall be kept current.

b. Prior to performing inspections, inspection personnel shall have access to the drawings, procedures, specifications or other documented criteria necessary for performance of the inspection.

TOPICAL QUALITY ASSURANCE REPORT TQR 10.0 Rev. 9 INSPECTION Date 6/12/90 Page 3 of 4 10.2.4 Inspection Procedures

a. Required inspection, surveillance or monitoring activities shall be performed and documented according to written, approved instructions or procedures. Inspection procedures, instructions or checklists shall'contain the following:

o Identification of characteristics to be inspected; o Identification of the individual or groups responsible for performing the inspection; o Acceptance criteria or reference to the acceptance criteria; o A description of the method of inspection; o Verification of completion and certification of inspection.

b. Inspection records shall identify:

o Inspector or data recorder; o Method or type of observations; o Test or inspection results; o Statement of acceptability; o Date of observation; o Deficiencies and nonconformances, and the action taken in connection with these deficient conditions, either by inclusion or by reference to other documents.

c. Inspection procedures shall be reviewed by QC personnel to determine the need for an independent inspection and the degree and method if such an inspection is required, and to assure the identification of inspection personnel and the method of documentation of inspection results.

d. Written approved instructions shall specify surveillance or monitoring of processing methods, or testing and operation of equipment when inspection is impossible, inaccessible or not applicable.

TOPICAL QUALITY ASSURANCE REPORT TQR 10.0 Rev. 9 INSPECTION 6/12/90 APL Page 4 of 4 10.2.4 (Continued)

e. Modification, repair, replacement or rework items shall be inspected in accordance with original inspection requirements or acceptable alternatives.

10.2.5 Inspection, Witness, and Hold Point Identification Appropriate inspection, witness or hold points shall appear in process documents (e.g.,

construction, testing, operating and maintenance procedures). These process procedures are subject to the review of the Quality Control organization for adequacy of inspection, witness, and hold points.

Mandatory hold points shall be used when witnessing and inspecting must be performed and signed-off by the responsible personnel before work can proceed.

FPL shall indicate FPL witness or hold points applicable during the manufacture of an item in procurement documents. A distinction shall be made between witness points and mandatory hold points.

TOPICAL QUALITYASSURANCE REPORT TQR 11.0 Rev.

TEST CONTROL 3une 10, 1986 FLORIDA POWER 8 LIGHT COMPANY Page 1 of 3 11.1 GENERAL RE UIREMENTS A test program shall be established to assure that testing required to demonstrate that structures, systems and components will perform satisfactorily in service is identified, accomplished, and documented in accordance with written procedures. The test program shall include, as appropriate, proof tests, prior to installation, preoperational tests, start-up tests, and operational tests, and retest following repairs, replacements or modifications.

11.2 IMPLEMENTATION 11.2.1 Test Program Testing requirements shall be identified in the engineering/design documents, SAR documents, procedures, or procurement documents, as appropriate. Retest following repairs, replacements, or modifications shall be performed in accordance with the original design and test requirements or acceptable alternatives. Retest shall be performed when the original test results are invalidated.

Quality Procedures and Quality Instructions shall be written which delineate the methods and responsibilities for controlling, accomplishing, and documenting testing.

FPL may delegate the implementation of all or any part of the test program to other organizations but shall retain ultimate responsibility for the program. The contractor shall be required to control, perform and evaluate tests in accordance with written procedures and shall be required to prepare a written test program detailing the testing required.

TOPICAL QUALITYASSURANCE REPORT TQR 11.0 Rev.

TEST CONTROL Date 3une 10, 1986 FLORIDA POWER 8 LIGHT COMPANY Page 2 of 3 11.2.2 Test Procedure. Preparation and Test Performance Testing shall be accomplished in accordance with written approved test procedures which incorporate or reference the requirements and acceptance limits in the applicable design and procurement'ocuments. The test procedure or test program documents shall include the following as a minimum:

a. Instructions for the testing method used;

b. Required test equipment and instrumentation;

c. Test requirements and acceptance criteria;

d. Hold, witness, inspection and data collection points;

e. Test prerequisites such as: calibrated instrumentation; trained,

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qualified, and licensed or certified personnel; preparation, condition and completeness of item to be tested; suitable and controlled envir'onmental conditions.

f. Methods for documenting or recording test data and results;

g. Test records shall identify:

1) Inspector or data recorder;

2) Method or type of observations;

3) Test or inspection results;

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TOPICAL QUALITYASSURANCE REPORT TQR 11.0 Rev.

TEST CONTROL 3une 10, 1986 FLORIDA POWER a LIGHT COMPANY Page 3 of 3 11.2.2 Test Procedure and Test Performance (Cont'd)

5) Date of observation; and

6) Deficiencies and nonconformances, and the action taken in connection with these deficient conditions, either by inclusion or by reference to other documents.

11.2.3 Evaluation of Test Results The documented test results shall be evaluated against the predetermined acceptance criteria by a group or individual having appropriate qualifications. The acceptance status of the test shall be documented.

Deficiencies noted during the evaluation shall be documented and dispositioned in accordance with approved Quality Procedures or Quality Instructions.

The evaluation of the test results may be delegated to other organizations; however, FPL shall retain the responsibility for the evaluation. The evaluating organization shall be required to use qualified personnel, evaluate the data against predetermined criteria, and document the results of the evaluation and acceptance status of the test.

TOPICAL QUALITYASSURANCE REPORT TQR 12.0 Rev. 4 CONTROL OF MEASURING AND TEST EQUIPMENT 0't'an 18 1990 FPL Page 1 of 3 12.1 Measures shall be established to assure that tools, gages, instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits, It is the responsibility of each department maintaining calibrated instruments to provide for the calibration and control of such instruments.

12,2.1 Control of Measuring and Test Equipment Procedures shall be written to delineate the methods and responsibilities for the control, maintenance, and calibration of measuring and test equipment (M&TE).

M&TE control procedures or calibration program documents shall contain the-following:

a. A listing of MATE to be controlled;

b. Frequency of calibration of listed M&TE. The frequency may be based on calendar time or relate to usage, and be based on such factors as experience, inherent stability, instrument purpose, or accuracy required;

c. A method for controlling issue and recall of portable M&TE;

d. A method to identify controlled MATE (e.g., labeling) required calibration frequency and calibration test data applicable to the M&~

e. Method to document and maintain the status of M&'IK FPL may delegate the control and/or calibration of M&TE to other organizations.

FPL, however, retains ultimate responsibility for control and calibration, and the contractor shall meet the requirements of this TQR or an acceptable alternative program as required by the procurement document for the contracted services.

TOPICAL QUALITYASSURANCE REPORT TQR 12.0 Rev.

4 CONTROL OF MEASURING AND TEST EQUIPMENT Jan. 18, 1990 Page 2 of 3 12.2.2 Calibration Procedure M&TE shall be calibrated in accordance with written approved procedures. The calibration procedures shall contain, as a minimum:

a. Identity of M&TEto which the procedure applies;

b. Calibration equipment and reference standards to be used;

c. Acceptance criteria;

d. Sequence of operations and special instructions;

e. Documentation and data collection requirements;

f. A requirement that M&TEbe checked and results recorded before adjustments or repairs ate made;

g. Calibration frequency required.

12,2.3 Calibration Standards M&TEshall be calibrated using reference standards whose calibration has a known, documented, valid relationship to nationally recognized standards or accepted values of natural physical constants. If no national standard exists, the basis for calibration shall be documented. Standatds and reference standards shall have an accuracy level, range and stability which are adequate to verify that the equipment being calibrated is within tolerance and adequate for the progrmunatic requirements of the equipment being calibrated.

M&TE shall be calibrated against working standards having an accuracy of at least four times th'e required accuracy of the equipment being calibrated. When this is not practical, working standards shall have an accuracy that assures that the M&TE being calibrated will be within required accuracy tolerances and that the basis of acceptance is documented and authorized by designated responsible management.

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TOPICAL QUALITY ASSURANCE REPORT TQR 13.0 Rev. 7 HANDLING, STORAGE'ND SHIPPING '<e 6/12/90 Page 1 of 2 13.1 Written instructions or procedures shall be established and implemented for the cleaning, shipping, storage, preservation, packaging, and handling of specified items. These instructions and procedures shall delineate measures which prevent degrading an item through damage or deterioration. When necessary for particular products, special protective environments such as inert gas atmosphere, specific moisture content levels, and temperature levels shall be specified alld provided.

13.2 13.2.1 General Instructions or procedures shall be written to define the requirements and responsibilities for the cleaning,'ackaging, preservation, handling, storage, and shipping of equipment and material, and shall require implementation of the established design and specification requirements by personnel having appropriate qualifications. FPL may delegate any portion of the responsibility for handling, storage and shipping of material and equipment, but shall retain ultimate responsibili Where any of the functions in the section which follow is delegated to a contractor, the contractor shall be required to adhere to the FPL requirements stated herein.

13.2.3 Handling, Storage, and Shipping Procedures Materials and equipment which are to be incorporated into a safety-related system of a nuclear power plant shall be handled, stored, and shipped in accordance with written procedures, where necessary, to implement the design document and purchase order requirements. These procedures shall assure that cleaning, handling, storing, packaging, shipping, and preserving materials, components and systems will preclude damage, loss, or deterioration by environmental conditions, such as temperature or humidity.

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TOPICAL QUALITY ASSURANCE REPORT TQR 14.0 Rev. 7 INSPECTION, TEST AND 6/12/90 APL OPERATING STATUS Page 1 of 2 14.1 Measures shall be established to indicate by the use of markings such as stamps, tags, labels, routing cards or other suitable means, the status of inspections and tests performed on material, equipment, or systems. These measures shall provide for the identification of items which have satisfactorily passed required inspections and tests. Measures shall also be established for indicating the. operating status of structures, systems and components to prevent inadvertent I

operations.

14.2 14.2.1 General For operations activities, the Nuclear Division is responsible for establishment and maintenance of a suitable system for identifying the inspection, test, and operating status of materials, equipment, systems, and components. For plant modifications assigned to Nuclear Construction Services Department or when requested by the Plant Manager, the Site Construction Services Manager is responsible for establishing a suitable system for identifying, inspecting and testing for material, equipment, systems and components, which is approved by Nuclear Operations. Each system shall be established, implemented and maintained in accordance with written Quality Procedures and Quality Instructions. The Architect/Engineer or Contractors shall develop and implement procedures to comply with contractual responsibilities, and applicable codes, standards, specifications, and criteria governing the status identification of procurement items being tested, installed, or fabricated. The Architect/Engineer (where applicable), suppliers and contractors shall be required to maintain a system for identifying the inspection, test and processing status of materials, parts, and components. Elements of this system require that suppliers and contractors have a controlled manufacturing and test operation in order to preclude the inadvertent bypassing of processing, inspections or test, and to provide a positive identification of component status throughout all phases of manufacturing, testing, and inspecting, by means of tagging, routing cards, stamping, manufacturing or test reports,

TOPICAL QUALITY ASSURANCE REPORT TQR 14.0 Rev.

INSPECTION, TEST AND Date 6/12/90 OPERATING STATUS Page 2 of 2 14.2.1 (Continued) labeling or other appropriate methods. The Vice Presidents - Turkey Point or St. Lucie and the Quality Assurance Department shall verify adequacy of the controls established and implemented, as appropriate for their site.

14.2.2 Status Identification and Control Quality Procedures and Quality Instructions shall describe control of the application and removal of markings such as stamps, tags, labels, routing cards, and other suitable means to indicate the status of non-operational, nonconforming, or malfunctioning nuclear safety related structures, systems and components to prevent inadvertent operation, and to prevent omission of inspections, tests, or other critical operations. These procedures and instructions shall delineate the requirements, methods and responsibilities for indicating the status of the affected items.

These procedures willclearly delineate the individuals or groups responsible for application and removal of status indicators.

TOPICAL QUALITY ASSURANCE REPORT TQR 15.0, Rev. 9 NONCONFORMING MATERIALS, 6/12/90 PARTS OR COMPONENTS Page 1 of 3 15.1 Measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation. These measures shall include, as appropriate, procedures for identification, documentation, segregation, disposition and notification to affected organizations. Nonconforming items shall be reviewed and accepted, rejected, repaired or reworked in accordance with documented procedures.

15.2 15.2.1 Program Quality Procedures and Quality Instructions shall define the responsibilities and methods for identifying, documenting, segregating and dispositioning nonconforming items. For procedure review requirements, see TQR 2.0 and TQR 5.0. Each department shall be responsible for the identification, control and disposition of nonconformances within the scope of their departmental responsibilities.

Throughout plant life, FPL may delegate any portion of the identification and control of nonconforming items and services to an Architect/Engineer (A/E), constructor, NSSS vendor or other contractors. In any case, FPL retains the responsibility for assuring that requirements are met, and shall assure that the contractor's actions conform to requirements set by FPL.

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15.2,2 Documenting and Controlling Nonconformances All nonconformances in safety related items shall be documented and reported for corrective action. Measures shall be delineated in Quality Procedures and Quality Instructions which control further processing, installation, or operation of nonconforming items. These measures shall include:

TOPICAL QUALITY ASSURANCE REPORT TQR 15.0 Rev.

Date NONCONFORMING MATERIALS, 6/12/90 PARTS OR COMPONENTS Page of 3 15.2.2 (Continued)

a. Physical identification of the item as nonconforming.

b. Segregation of nonconforming items until properly dispositioned.

Where physical segregation is not practical, suitable tags, marking or documentation shall be used to assure control.

15.2.3 Documentation Documentation of the nonconforming item shall: identify the item; describe the nonconformance; show disposition of the nonconformance and inspection requirements; and include the signature of the person approving the disposition.

15.2.4 Evaluation and Disposition Nuclear Engineering, or the delegated contractor organization, as specified by procedure, shall evaluate nonconformances and disposition them based on the results of the evaluations. These evaluations and dispositions shall be reviewed, approved and documented in accordance with procedures.

evaluation to determine the disposition of nonconforming items shall be performed. The evaluation shall determine whether an item is to be accepted as-is, repaired, 'reworked or rejected; A technical evaluation shall be performed when an item is accepted as-is or is repaired to an L'n lO pl acceptable condition. Records of the disposition of these items shall be made part of the nonconformance report. This evaluation shall assure that the final condition does not adversely effect safety, operability or maintainability of the item, or of the component or system in which it is installed.

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TOPICAL QUALITY ASSURANCE REPORT TQR 15.0 Rev. 9 NONCONFORMING MATERIALS, Date glop PARTS OR COMPONENTS Page 3 of 3 15.2.4 (Continued)

The A/E, or other contractors on-site, shall be required to inform FPL as specified in procurement documents prior to use or installation of a nonconforming item. The nature and extent of a nonconformance and the reason for proposing its use or installation shall be justified.

Nonconforming items dispositioned "accept as-is", or repaired to an acceptable condition, shall be so identified. Nonconformance reports for those items shall be made part of the item mcords and forwarded with the material to FPL.

The determination of the need and the advisability of releasing nonconforming materials or items, is made by the Nuclear Engineering Department. The following factors may be appropriate considerations in making this determination:

at Effect on the orderly progress of work ifmaterial or items are released;

b. Safety of personnel; C. Suitability of material or items in "as-is" condition, i.e., probability of eventual satisfactory resolution of the nonconformance without repair, rework, or replacement;

d. Accessibility of material or items after release;

e. Cost of removal and repair of replacement should material or items eventually have to be removed, repaired, or replaced; Impact on plant safety.

Items shall be reworked or repaired in accordance with documented procedures and shall be "

verified by reinspecting the item as originally inspected or by a documented method which is at least equal to the original inspection method.

Nuclear Assurance personnel shall periodically review nonconformance reports to identify quality trends. The results of these analyses shall be reviewed with appropriate members of upper level management.

TOPICAL QUALITY ASSURANCE REPORT TQR 16.0 Rev. 6, CORRECTIVE, ACTION Date 912/90 Page 1 of 3 16.1 Documented measures shall be used to assure that conditions adverse to quality such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances, are promptly identified and corrected as soon as practicable. In the case of significant conditions adverse to quality, the cause of the condition shall be determined and action taken to preclude repetition. The identification of significant conditions adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels-of management.

16.2 16.2.1 Corrective Action and Follow-Up Quality Procedures and Quality Instructions shall define responsibilities and methods for identifying and correcting conditions adverse to quality. When an adverse condition is detected, a determination shall be made by plant supervision or Nuclear Assurance personnel as to whether immediate or routine corrective action is required.

Pt ao "Immediate Corrective Action" applies to conditions which pose a threat to plant safety or to the health and safety of the public, which could result in major equipment and material damage, or could, ifnot corrected, produce defects of significantly greater consequences than those immediately resulting from the condition. "Immediate Corrective Action" is through stopwork requests/orders to appropriate levels of management, 'ccomplished requiring that work be stopped, the plant be shut down or other appropriate actions be taken.

b. "Routine Corrective Action" applies to conditions which do not require immediate corrective action. Routine corrective action is assured through the distribution and disposition associated with inspection reports, surveillance reports, nonconformance reports, and audit reports; and the investigation analysis and action associated with reportable conditions.

TOPICA'L QUALITY ASSURANCE REPORT TQR 16.0 Rev.

CORRECTIVE ACTION Date 6(1~0 Page 2 of 3 16,2.1 (Continued)

Follow-up to verify implementation of-corrective action and close-out of corrective action documentation is accomplished by the QA or QC organization responsible for verifying the corrective action. The Quality Assurance Department shall track, follow-up, and closeout open items identified by QA Department audits and vendor surveillances. The respective department or plant shall track those items charged to its operating license by- the NRC. Each department shall be responsible for follow-up and close-out of corrective action resulting from their departmental inspections, tests, or operations.

If corrective action is inadequate or not timely, the follow-up organization shall request corrective action from management, as delineated in procedures. The President Nuclear Division is the final authority in the event that agreement is not reached at lower levels regarding stop work requests or other corrective action.

Where corrective action is required of contractor personnel, FPL shall define in procedures and contracts the corrective action interface between FPL and the contractor. FPL shall require the A/E, NSSS vendor, constructor and other suppliers of safety related materials and services to have a documented corrective action system.

16.2.2 Recum:nce Control It is the responsibility of the organization which identifies the significant condition adverse to verify that corrective action description not only corrects the immediate condition, but to'uality also precludes the condition from recurring. The organization(s) that provide(s) the corrective action disposition and implementation is responsible to assure that the co+ective action taken not only corrects the immediate condition, but also precludes recurrence.

TOPICAL QUALITY ASSURANCE REPORT TQR 16.0 Rev. 6 CORRECTIVE ACTION Date 6/1~0 Page 3 of 3 16.2.3 Incidents and Reportable Occurrences Reporting Operating Reportable Occurrences and reports of incidents shall be investigated, documented as to cause and corrective action, and reported to the NRC in accordance with the applicable plant Technical Specifications. Reportable Occurrences and reports of incidents that are safety related

'r that result in damage shall be forwarded to the Company Nuclear Review Board (CNRB) for review. Conditions adverse to quality are reported to operating plant management through:

distribution of QA audit reports, QC.inspection reports, corrective action requests, and the investigation and reporting of Reportable Occurrences in accordance with plant Technical Specifications.

TOPICAL QUALITYASSURANCE REPORT TQR 17.0 Rev.

QUALITYASSURANCE RECORDS Date June 10, 1986 Page 1 of" 2 t

17.1 GENERAL RE UIREMENTS Sufficient records shall be maintained to furnish documented evidence of the quality of safety related structures, systems, and components, and of activities affecting their quality. The records shall include, as appropriate, data such as qualifications of personnel, procedures, and equipment; and other documentation such as inspection or test acceptance criteria, and the action taken in connection with deficiencies noted during inspection.

The records required to furnish documentary evidence of quality, herein called quality assurance records, shall be identifiable and retrievable. These records shall be maintained in facilities that provide a suitable environment to minimize deterioration or damage and to prevent loss.

The requirements 7

and responsibilities for quality assurance record control, transmittal, retention, and maintenance shall be established and documented.

These record requirements shall 'be consistent with applicable design,,

manufacturing, and installation codes and standards, and with procurement document requirements.

17.2 IMPLEMENTATION 17.2.1 Records Identification Quality Procedures shall define the quality assurance records necessary to furnish documentary evidence of the quality of safety related structures, systems, and components; and activities affecting quality. These records shall include plant operating logs; results of design reviews, inspections, tests, audits, and material analyses; qualification of personnel, procedures, and equipment; design records such as drawings and specifications; procurement documents; calibration records; and nonconformance or corrective action reports.

TOPICAL QUALITYASSURANCE REPORT TQR 17.0 Rev. 2 QUALITYASSURANCE RECORDS 3une 10, 1986 FLORIDA POWER I LIGHT COMPANY Page 2 Gf 2 17.2.2 Responsibilities Responsibilities shall be established and documented for the control, transfer, maintenance, and retention of quality assurance records. Quality Procedures shall provide guidance for determining the ret'ention requirements of quality assurance records. Each organization responsible for the conduct of a quality activity shall be responsible for the maintenance of the subsequent quality assurance records unless retention responsibilities have been transferred by a prearranged agreement. In any case, the organization initiating the quality assurance records shall be responsible for their validity and approval.

17.2.3 Retrieval Quality Procedures shall require that quality assurance records submitted for retention be legible, completely filled out, and adequately identifiable and retrievable for each item. The records shall be filed in the storage area or facility using a documented system to provide retrievability. Quality Procedures additionally require control of corrections and supplements issued for quality assurance records that are previously approved and filed, and that documented methods for control and accountability of records removed from the storage area be instituted.

17.2.0 Storage Specified in the Quality Procedures are the construction features and location requirements for record storage facilities which assure that quality assurance records are protected from possible destruction by causes such as fire, flooding, theft, tornadoes, insects, rodents, and from possible deterioration by a combination of extreme variations in temperature and humidity. Specific instructions regarding the storage area are given for special processed records and for temporary storage facilities.

TOPICAL QUALITY ASSURANCE REPORT TQR 18,0 Rev. 6 AUDITS 6/12/90 page 1 of 4 18.1 A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program. The audits shall be performed in accordance with the written procedures or checklists by appropriately trained personnel not having direct responsibilities in the areas being audited.

Audit results shall be documented and reviewed by management having responsibility in the area audited. Follow-up action, including reaudit of deficient areas, shall be taken, where necessary.

18.2 A comprehensive program of audits is catried out by the Quality Assurance Department during the design, procurement, construction, and operations phase of nuclear power plants. These audits are performed to verify that all safety related activities associated with nuclear power plants are carried out in accordance with the requirements of the FPL QA Program, and that the implementation is effective.

18.2.1 Personnel Quality Procedures provide instructions for the training of QA Department personnel who perform audit activities, to assure that they are adequately indoctrinated and trained, and that they are qualified to carry out these activities. Quality Procedures provide for personnel qualified as

Lead Auditors to be formally certified by Quality Assurance Department management.

Certification shall be based on education, experience, training and other specified criteria.

18.2.2 Planning and Scheduling Quality Procedures and Quality Instructions provide requirements for written audit plans and schedules. The audits are planned and scheduled on the basis of the following requirements, as appropriate:

TOPICAL QUALITY ASSURANCE REPORT TQR 18.0 Rev.

AUDITS 6/12/90 Page 2 of 4 18.2.2 (Continued) a., Activities shall be audited as early in their life as practicable.. Auditing shall be initiated early enough to assure effective quality assurance during the design, procurement and contracting activities.

b. Applicable elements of the internal and on-site QA Programs shall be audited at least once every two years during the operation phase of plant life following initial fuel loading. For other plants'hases, the applicable elements shall be audited at least once every year or once within the life of a quality related activity, whichever is shorter.

C. An annual evaluation of suppliers'uality performance history shall be performed to determine reaudit requirements. Reaudit requirements for suppliers shall be based on the supplier's quality performance and the complexity and criticality of the equipment or service being procured. A facility evaluation (audit) will be performed at least every three years and shall be conducted in accordance with Quality Procedures and Quality Instructions for supplier evaluations.

d. Audits shall be regularly scheduled for on-going activities.

e. Regularly scheduled audits shall be supplemented, as required to cover unforeseen events or changes in requirements.

The scope of audit activities shall include, as a minimum:

a. The determination of site features which affect plant safety (e.g., core sampling, site preparation, and meteorology).

b. The preparation, review, approval, and control of the SAR, designs, specifications, procurement documents, instructions, procedures, and drawings.

c. Evaluation of bids.

TOPICAL QUALITY ASSURANCE REPORT TQR 18.0 Rev. 6 AUDITS 6/12/90 Page 3 of 4 18.2.2 (Continued)

d. Indoctrination and training programs.

e. Receiving and plant inspections.

f. Operation, maintenance/repair and modification.

g. The implementation of operating and test procedures.

h. Allcriteria in Appendix B to 10 CFR Part 50.

i. Validity of Certificates of Conformance.

External audits shall be performed by the Quality Assurance Department on Architect/Engineers, NSSS vendors, constructors, and other suppliers of safety related materials and services to

,evaluate their QA programs, procedures and activities. Procurement documents require that FPL suppliers and contractors in turn perform audits on their sub-tier suppliers and contractors.

18.2.3 Conduct of Audits Quality Procedures and Quality Instructions shall delineate requirements for the conduct of audits. These procedures and instructions shall require that:

a. Audits be conducted by trained and qualified personnel.

b. Personnel conducting audits shall not have direct responsibility in the area audited.

c. Checklists or procedures shall be used to ensure depth and continuity of audits.

TOPICAL QUALITY ASSURANCE REPORT TQR 18.0 Rev. 6 AUDITS 6/12/90 Page 4 of 4 18.2.3 (Continued)

d. Objective evidence shall be examined for compliance with quality assurance program requirements. This shall include examination of procedures and activities to assure that documented objective evidence is meaningful and in compliance with the overall Quality Assurance Program.

e. Audits shall include evaluation of work areas, activities, processes and items; and the review of documents and recoids.

18.2.4 Reporting of Audit Findings Audit findings shall be documented in written reports. Audit reports shall be distributed to the responsible management of the audited FPL organization within thirty calendar days after completion of the audit.

18.2.5, Follow-up Responsible management of the audited organization shall take action to correct the deficiencies identified in the audit report and provide a written response within thirty calendar days after receipt of the report. This response shall include action taken and/or planned to correct deficiencies and to prevent recurrence of the deficiencies, and commitment dates for actions not yet complete. The mechanism for evaluation and follow-up of corrective action is described in 16.0. The status of correction of deficiencies shall be followed until the corrective actions

'QR have been accomplished and verified.

18.2.6 Reports to Management Quality Assurance Program status reports are periodically prepared by the QA Department and routed to the members of the Company Nuclear Review Board (CNRB) for their review; This status report summarizes the results of QA Department audit activities for the period, keeps all CNRB members apprised of current conditions and program effectiveness, and when necessary, directs management attention to significant trends and problems.

CHAIRMAN OF THE BOARD CHIEF EXECUTIVE OFHCER SEE FIGURE 1-1 PREQDENT NUCLEAR DIVISON PAGE 2 OF 2 GROUP EXECUTIVE (EXECUTME VICE PREStDEMIs/

SENOR LACE PRESSENT - NUCLEARs)

CE PREQDEMT VICE PREQDEMT COMPANY NUCLEAR REVIEVI 80ARD SEE flGURE SEE FIGURE 1-1 1-1 PAGE 2 OF 2 PAGE 2 OF 2 VKX PREQDENT VICE PREQDENT DIRECTOR SENOR NUCtEAR NUCLEAR EMGIMEERINC NUCLEAR VICE PRESIDENT-ASSURANCE ADMIMISTRATXVE MUCLEAR OPERATONS AMO UCENQNG (DIRECTOR OUAUIY SERVICES (VICE PREQOEMT NUCLEAR EMERGYr) ASSURANCE v)

DIRECTOR VICE PREQDEMT NUCLEAR TURKEY PONT ENCINEERIMG LIANAGER PLAMT- HULIAN OUAUIY hSSUSWCE RESOURCES DIRECTOR PROGRAM REVIEW SPECIHC QTE NUCLEAR COMLIITTEE LIAMAGER ORGANIZATION UCENQMG PLAMMNC 4 IN FIG. 1-2 OUAUIY i@WAGER CONTROL DIRECIOR TURKEY POINT VICE PREQDENT NUCLEAR SECTION SUPERVISOR ST. LUCIE MATERIALS NFORLlATION OUAUIY CONTROL PLANT LIAMAGELIEMT SERVICES SUPERNTENOENT DXIECTOR SPEOF NUCLEAR OUAUIY MANAGER SUPERVISOR ORGANILATION CONSTRUCTION ST. LUCIE OFflCE N flC. 1-3 SERVICES SERVICES OUAUIY CONTROL LIANAGER SUPERINTENDENT NUCLEAR SECURAY OUAUIY CONTROL SUPERVISORs TOPICAL QUALITY ASSURANCE REPO/T MAMAGER REV. 16 NUCLEAR TRANINC MANAGER ORGANIZATION OF DEPARTMENTS NUCLEAR SAFDY SPEAKOUT AFFECTING QUALITY 06/12/90 MANAGER NUCLEAR FIGURE T-T ENERGY SERVCES APPENDIX A CHAIRLIAN NUCLEAR DMSION PAGE I OF 2 CMR8v v - Indicates posit'on vith occountotiiTties in Technkol Specilicol'ons.

Where mulfiple titles occur. Ihe first position Fisted sholl oct In the capacity ol the olher Ksted titles.

CORPORATE SECRETARY GROUP EXECUTIVE VCE LACE PRESSENT PRESeENT LIANAGER COPORATE RECORDS SERVICES DIRECTOR COLIPUTER SUPERVISOR SENIOR OPERATSNS OOCUUENTARY VICE PRESIDENT ALES DIRECTOR INFO RLIATION SYSTELlS DIRECTOR DIRECTOR EH@RONNE NIR POWER SUPPLY AFFAIRS LIANAGER SIST ELI ENVIRONLIENTAL PROTECTION TECIINICAL SERLACES LIANAGER POWER SUPPLY TECHNICAL SERNCES IIANAGER ENVIRONNOITAL PERUllTING ANO PROGRAIIS TOPICAL QUALITY ASSURANCE REPORT LIANAGER REV. I6 ENNRONLIENTAL RESOURCES 4 ORGANIZATION OF DEPARTMENTS PLANNING AFFECTING QUAUTY 06/L2/90 FIGURE 1-1 APPENDIX A PAGE 2 OF 2 SUPPORT DEPARTMENTS

l555TArrf SUPER STTERCOrf NSTRUARRT ANo ccrnRCL (ttSTRUNTTT (ps / uAerf OORRTTTLATOR ANO COTOTTCL SWEnSOe) srTKCRATKO SCHGIIE PROCRAAT LAARACKR PLNT SWERNSOR NCLEN (SRO)

ASSTSTNf PLATTT OITA AOCESSSAQ 5UPERNSCR 0%QTTIT TTUCLEN (SRO)

TTUCLEN RATOI OTORRER (SRO) fejCLEN CON7RCL COTTER CPKRATOR (Ro TOPICAL OUALITY ASSURANCE REPORT TURKEY POINT NUCLEAR SITE ORGANIZATION OATE: 4/I 2/SO FIGURE 1-2'PPENOIX A

PACE 1 % 1 r - Indicotes posilion Rith occoontobifities in Kechnicof Spen%cotions.

Where mutt(pie lilies occor. the first position 4sted sholl od (n lhe copoc(ty of lhe other listed titles.

VICE PRE9OEHT Sf. LUCJE PuNT ENGINEEFIIHG HUIIAH PROJECT 9TE CONSTRUCTIOH RESOURCE UCEN9NG MANAGER SERVICES MANAGER SUPERINTENDENT MANAGER flRE CONTRACT PROT ECTION BUDGET 4r COST ADMINISTRATION SAFETY PROCEDURES OUTAGE GRAPHICS MANAGEMENT SUPERVISOR PtAHT SECURITY SUPERVISOR TECHNICAL OPERATIONS TRAINING SUPERINTENDENT IfAINIENANCE PERIHTENDEHfr SUPERINTENDENT (fECHNICAL PERIHTENOENTr SUPERVISORr)

AS9STANT-DE9GN SUPER FITEND ENT HEALTH OPERATIONS CONTROL REACfoR OPERATIONS CHEMISTRY INSTRUMENT PHYBCS RAIHIHG PROGRAM SUPERVISOR SUP ERVISORr SUPERVISORr SUPERVISORr AHD COMROL SUP ERVISORr SUPERVISOR RISTRUMENT lh CONfROL SUEPRVISORr)

AS9ST ANT MNNT./5PECIAI.TY SUPER2ff ENDENT G PROGRAM NUCLEAR MECHANICAL ADMINISTRATIVE I RIMARIES/ SUPERVISOR REACTOR MAIHTENANCEr COORDINATOR MONITORS EHCVIEER SUPERVISOR SUPE RVSOR SUPERMSOR (SRO)

SHIFT TRNKIHG TECHNICAL AS9STANT SUPPORT ADVISOR SUPERFff ENOENT AS9STAHT SECONDARIES/ SUPERVISOR OPERATIONS SUPERVISOR ELECTRICAt.

REACTOR NUCLEAR PtANT ENVIRONMEHTAL COORDINATOR MAINTENANCE SUPERVISOR TECHNICIAN SUPERVISOR h ADMINISTRATIVE (SRO) SUPERVISOR REUAsufY HEALTH PHY9CS TECHNICAL CONTROL CENTER APPDIIXX I COUHTWG ROOM

// Cr SUPPORT SUPERVISOR OPERATOR SUPERVISOR SUP ERVI (RO)

UNUCDISED WIP / STP POUSHER OPERATORS SUPERVISOR TOPICAL QUALAY ASSURANCE REPORT, nor. 4 ST. LUCIE PLANT, UNITS 1 4 2 OIIG 4/I2/SO SITE ORGANIZATION FIGURE 1-3 APPENOIX A PACE 'I or I

~ - Indicotes position uith occountoblitfes in Technicol Specificotions.

Where muHIpie titles occur, the first position listed shell oct fn the copocity of the other hsted titles.

TOPICAL QUALITY ASSURANCE REPORT APPENDIX B Rev. 5 QUALIFICATIONAND EXPERIENCE REQUIREMENTS FOR FPL QUALITY Date ASSURANCE PERSONNEL Page I of 1 XXKLK--

Quality Managers (JB/PTN/PSL) Shall satisfy the following set of requirements:

Graduate of a four year accredited engineering or science college or university, plus seven years of industrial experience, including five (5) years in positions of leadership such as lead engineer, project engineer, audit team leader, etc. At least two (2) years of this five (5) years experience shall be nuclear power plant experience in the implementation of the Quality Assurance Program.

Six (6) months of the two (2) years experience shall be obtained within a Quality Assurance organization. A masters degree in engineering or business management is considered equivalent to two (2) years of general industry experience.

'Ihe education and experience requirements should not be treated as absolute when similar training or an outstanding record willprovide reasonable assurance that a person can perform the required tasks.

TOPICAL QUALITY ASSURANCE REPOR APPENDIX C Rev.

BASELINE DOCUMENT MATRIX o ate 6/12/90 Page '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 QUALITY ASSURANCE REPORT APPENDIX C Rev.

Date BASELINE DOCUMENT MATRIX 6/12/90 APL Page 2 of 23 REFERENCE INDUSTRY DRAFT REV.

TOPICAL QUALITY ASSURANCE REPORT APPENDIX C Rev. 8 BASELINE DOCUMENT MATRIX Date 6/12/9P FPL Page 3 of 23 Florida Power & Light Company position regarding conflicting guidance and exceptions:

T ARA n ix I 'ficati n AN IAN 1-1 P L2 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.

i 1 Rv1A IN1 1-1 1ANIAN 1 PL-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.

R l 4 24-1 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".

TOPICAL QUALITY ASSURANCE REPORT APPENDIX C Rev.

BASELINE DOCUMENT MATRIX 6/12/90 Page 4 of 23 R la ui 1 Rv2AN IN1. -1 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 requi'rements, 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.

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,'J and as such is not included in the Quality Assurance Program.

TOPICAL QUALITY ASSURANCE REPORT APPENDIX Rev. -

8 BASELINE DOCUMENT MATRIX Date 6/12/90 Page 5 of 23 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 received 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.

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.

1 TOPICAL QUALITY ASSURANCE REPORT APPENDIX C Rev. 8 BASELINE DOCUMENT MATRIX 6/12/90 FRL Page 6 of 23 i 1 A IN4 2-1 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.

R 1 Rv2 I 4 22-1 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 constrasting willonly be applied to the extent that these colors are dissimilar or otherwise distinguishable. This does not preclude using other tapes when precuations are taken to ensure these tapes do not come in contact with austentic stainless steel or nickel alloy materials.

Vapor barrier material (other than metal) shall be colored to contrast with or be otherwise distinguishable from safety related systems to prevent undisclosed entry into the system.

TOPICAL QUALITY ASSURANCE REPORT APPENDIX C Rev. 8 BASELINE DOCUMENT MATRIX 0 t 6/12/90 Page 7 of 23 These requirements do not apply to components in storage which would require removal of such tapes and baniers 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. Envitonmental 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 are adequately maintained.

4. Packaging, covering or coatings required to meet environmental requirements such as bamer 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.

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

9. Anticipated "shelf life" of the item.

TOPICAL QUALITY ASSURANCE REPORT APPENDIX C Rev. 8 BASELINE DOCUMENT MATRIX Date 6/12/g0 FPL Page 8 of 23 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 NVREG 0612, entitled "Control of Heavy Loads at Nuclear Power Plants".

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

U TOPICAL QUALITY ASSURANCE REPORT APPENDIX C Rev. 8 BASELINE DOCUMENT MATRIX 6/12/90 Page 9 of 23 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 willbe 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 h

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 are present (i.e. hurricanes, paint sprays, concrete pours, etc.) precautions or additional steps will be taken to further protect the items.

R la i 1 Rv 2AN IN4 2. -1 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 designation, 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, 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.

TOPICAL QUALITY ASSURANCE REPORT APPENDIX C Rev. 8 BASELINE DOCUMENT MATRIX 6/12/90 Page 10 of 23 R I i 1 Rvii nlAN IN4 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 alld 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 though consideration of education, training, and experience.

The Florida Power 8c 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.

For preoperational and operational inspection, examination and testing by Quality Control Inspectors, FPL considers that-Position C.l 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.

TOPICAL QUALITY ASSURANCE REPORT APPENDIX C Rev. 8 BASELINE DOCUMENT MATRIX 6/12/90 Pege 11 0< 23 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 Regulatory 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 inspection, examination tests shall be supervised or directed by personnel qualified to Position C.1 of Regulatory Guide 1.58, Revision l.

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 determine the capabilities in his qualified area. Ifduring this review or at any other time, it is determined that the individual's 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 R l R v 2 AN I N4 .211-1 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 V

than those who performed the design. The original designers and verifiers may both be from the design organization. Design verification by the designer's immediate supervisor shall be limited to those instances where the supervisor is the only qualified individual,available within the design organization. Mesc instances are further restricted to designs where the designs where the

TOPICAL QUALITY ASSURANCE REPORT APPENDIX C Rev.

BASELINE DOCUMENT MATRIX 6/12/90 Page 12 of 23 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 will include evaluations of the adequacy of the practices which are the implementation of these policies, procedures and instructions.

R 1 i 1 11 Regulatory 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'f 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.

i 1 4ANIN4 21 -1 ANSI N45.2.10 - 1973 identifies terms and their definitions important to the uniform understanding of the intent of requhed 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.

TOPICAL QUALITY ASSURANCE REPORT APPENDIX C Rev.

BASELINE DOCUMENT MATRIX SnlrteO page 13 of . 23 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 control or product acceptance.

Guidelines Particular provisions which are considered good practice but which are not mandatoiy 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.

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.

TOPICAL QUALITY ASSURANCE REPORT APPENDIX C Rev. 8 BASELINE DOCUMENT MATRIX Oa<<@IMP FPL Page 14 of 23 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.

Quali6cation (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 control the quality of the material, structure, component or system to predetermined requirements.

Storage That period following the release of an item for shipment until turnover for start-up preoperational testing. This would include in-place 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.

TOPICAL QUALITY ASSURANCE REPORT APPENDIX C Rev.

BASELINE DOCUMENT MATRIX 6/12/90 APL Page 15 of 23 Testing Performance of those steps necessary to determine that systems or components function in accordance with predetermined specifications.

"R i m 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.

R l i 1Rv2AN42-14 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.

Non-permanent Recotds: 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 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:

TOPICAL QUALITY ASSURANCE REPORT APPENDIX C Rev. 8 BASELINE DOCUMENT MATRIX Date g12PP FPL Page 16 of 23 QA records 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 Manager of Corporate Record Services, who shall be responsible for maintaining records of evaluations and establishing schedules to assure that reevaluations are performed every two (2) years. If necessary, the above QARSET Committee 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.

1. 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 ifthe following additional provision are provided:

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

TOPICAL QUALITY ASSURANCE REPORT APPENDIX C Rev. 8 BASELINE DOCUMENT MATRIX o t 6/12/90 page 17 of 23

b. Records shall be stored in fully enclosed metal cabinets. Records shall not be permitted on open steel shelving. No storage or records shall be permitted on the floor 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 and eating/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.

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

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

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

2. The use of QARSET approved factory built record protection equipment, 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 QUALITY ASSURANCE REPORT APPENDIX C Rev. 8 BASELINE DOCUMENT MATRIX 6/12/90

+PL Page 18 of 23 (2) Concrete floor and roof with sufficient slope for drainage; ifa 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.

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

i 11 A I 42-1 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&TE 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 Ch project may be desirable.

CO

~ V

TOPICAL QUALITY ASSURANCE REPORT APPENDIX C Rev.

BASELINE DOCUMENT MATRIX Date 6/12/90 Page 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 used 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 controls to preclude adverse effects on safety and suitability for use.

i 112 Rv 1AN IN4 21-1 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 are 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 commercial 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.

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" contained in ANSI N45.2. 10-1973 as modified by Regulatory Guide 1.74.

I

TOPICAL QUALITY ASSURANCE REPORT APPENDIX C Rev.

8 BASELINE DOCUMENT MATRIX 6/12/90 Page 20 of 23 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 with the exception of these accomplished by "Confirming Purchase Order". A "Confirming Purchase Order" is an order which is initially placed 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 normal review and approval cycle. 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".

(1) Quality Assurance must be contacted prior to contacting the supplier to place the order unless it is an emergency purchase after normal working hours in which case Quality Assurance is contacted the next working day.

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

(3) 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.

Section 8.2 of ANSI N45.2.13 identifies those nonconformances which shall be submitted to the Purchaser. Florida Power 8c Light's (FPL) position regarding the nonconformances to be reported is as follows. Suppliers (including A/E's and Contractors) shall submit all 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.

TOPICAL QUALITY ASSURANCE REPORT APPENDIX C Rev. 8 BASELINE DOCUMENT MATRIX 6/12/90 APL >>se 21 << 23

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

This policy assures that all 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 1 4 24-1 2 ANSI N45.2.4-1972, Paragraph 2.5.2 requires that equipment be "suitably marked to indicate date of next required calibration". In lieu of marking 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.

\

R I i 1144 R v 1 AN N4 212-1 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,

TOPICAL QUALITY ASSURANCE REPORT APPENDIX C Rev. 8 BASELINE DOCUMENT MATRIX 0 t 6/12/90 Page 22 of '23 (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.

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 pre-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 are 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.

TOPICAL QUALITY( ASSURANCE REPORT APPENDIX C Rev. 8 BASELINE DOCUMENT MATRIX Date 6/12/9P Page 23 of 23 Pl nin arifi n 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.

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 are 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 requitement 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 D Rev. N/A GRAY, GREEN, AND ORANGE BOOK

<@lay 7,1982 FLORIDA POWER 4 LIGHT COMPANY MATRIXTO QA PROCEDURES APPENDIX D "GRAY, GREEN, AND ORANGE BOOK MATRIXTO QA PROCEDURES CANCELLED IN ENTIRETY Ch cv e

0 4

TOPICAL QUALITYASSURANCE REPORT APPENDIX E Rev.

LIST OF CORPORATE QUALITY 3/28/90 FPL ASSURANCE PROCEDURES Page 1 of 9 1.1 CANCELLED 2.1 CANCELI~

(Terms and Definitions contained in the QA Manual Glossary) 2.2 REVISION OF THE TOPICAL Provides instructions for the revision of the Florida QUALlTYASSUIMNCE REPORT Power & Light Company Topical Quality Assurance Report (FPL TQAR).

2.3 QUALlTYASSURANCE PROGRAM REVIEW Desciibes the instructions and methods used for establishing, preparing, issuing, revising and controlling Quality Procedures employed in supporting quality requirements.

2N4 PREPARATION AND REVISION OF Provides the responsibilities, guidelines and methods QUALMYINSTRUCTIONS used for developing and revising Quality Instructions, based upon QP's, that involve quality activities within a department or organization and are unique to that activity.

2.5 QUALllSASSURANCE NOOCIRINATION Describes the requirements for the indoctrination AND DEPARTMENTALTRAINING and training of personnel who perform, or are responsible for activities that affect quality.

2.6 CANCELL'ED 2N7 IDENTIFICATIONOF SAFEIY Describes the development and approval of RELATED STRUCI'URES, SYSTEMS, documents identifying safety related and safety AND COMPONENTS related design feature structures, systems and components.

2.8 CLEANLINESS CONTROL METHODS Provides criteria for securing good housekeeping.

Assigns responsi-bilities for assuring that the cleanliness of material, systems and structures is maintained.

TOPICAL QUALITYASSURANCE REPORT APPENDIX E Rev.

LIST OF CORPORATE QUALITY 3/28/90 FPL ASSURANCE PROCEDURES Page 2 of 9 2.9 QUALIFICATIONOF QA AUDlT, QC Describes the personnel qualifictaions that are INSPECTION INSPECTION AND required to assute that compentent QC inspectors, CONSTRUCTION TEST PERSONNEL QA auditors, and construction test personnel perform these respective functions, 2.10 HOUSEKEEPING FOR OPERATING Describes the responsibilities and controls for PLANTS housekeeping at operat-ing nuclear power plants.

2.11 CANCELLED 2.12 FPL QA PROGRAM APPLICABILITY Identifies the applicability of the Quality Assurance FOR FIRE PROTECTION SYSTEMS Program for Fire Protection Systems.

2.13 PROCESSING OF NRC CORRESPONDENCE Describes the system for providing responses to NRC initiated action requests.

2.14 IMPLEMENTATIONOF Describes the program and responsibilities for ASME XI controlling activities defined by ASME Section XI.

2.15 CONTROL OF COMPUTER SOFTWARE Specifies basic requirements for control of the lifecycle of computer software on mainframe, stand; alone, and PC computers.

2.17 ENVIRONMENTALQUALIFICATION(EQ) Delineates the responsibilities and requirements for OF ELECTRICALEQUIPMENT maintaining the environmental qualifications of nuclear plant components.

3.1 CANCELLED

TOPICAL QUALITYASSURANCE REPORT APPENDIX E Rev.

LIST OF CORPORATE QUALITY 3/28/90

%PL ASSURANCE PROCEDURES Page 3 of 9 3.2 IDENTIFICATIONAND COYIROL OF Describes measures employed for identifying and DESIGN INTERFACES controlling design interfaces, changes in design interfaces, and modifications that affect documents.

3.4 PLANT CHANGES AND MODIFICATIONS Establishes measures for controlling design changes FOR OPERATING PLANTS or modifications in operating nuclear power plants.

3.5 DESIGN CONTROL AT THE Defines the responsibilities and methods CONSTRUCTION SITE employed for the initiation, review, evaluation, approval and disposition of field initiated design changes and miscellaneous design documents such as field sketches and isometrics.

3.6 CONTROL OF FPL ORIGINATED Covers the preparation, review, and approval of DESIGN design input documents, design analysis specifications, and design verification for safety related design work originated by FPL.

3.7 EVALUATIONAND CONTROL OF Describes the evaluation and control of contractor CONTIMCI'OR DESIGN FOR NUCLEAR designs for fuel related components and analysis.

FUEL AND RELATED SYSTEMS 4.1 CANCELLED 4.2 CANCEI~D 4.3 CANCELLED 4.4 CANCELLED

TOPICAL QUALITYASSURANCE REPORT APPENDIX E Rev.

LIST OF CORPORATE QUALITY 3/28/90 ASSURANCE PROCEDURES Page 4 of 9 4.5 CANCELLED 4.6 PROCUIKMENT CONTROL Delineates the sequence of actions in the preparation, review, approval, and control of procurement documents.

5.1 OPERATING PLANT PROCEDURES Describes measures which ensure that instructions and procedures used in operating plants are identified, prepared, ieviewed, approved, issued and revised in accordance with regulatory and FPL requirements.

5.2 BACKF1T PROCEDURES Describes the generation, review and control of backfit procedures.

6.1 CONTROL OF CONSTRUCTION Defines responsibilities and methods for the control .

DRAWINGS, and issue of contractor drawings, specifications and PROJECI'ONTRACTOR SPECIFICATIONS AND PROCEDURES procedures to be used during the construction phase of nuclear power plants.

6.2 CONTROL OF DOCUMENTS Instructions are provided for controlling documents ISSUED BY FPL issued by FPL which prescribe activities affecting the quality of safety related items.

6.3 CANCEIJZD 6.4 CANCELLED 6.5 CANCEL'LED 6.6 DRAWING CONTROL FOR OPERATING Describes the method to be used for controlling and NUCLEAR POWER PLANTS updating nuclear safety related drawings for operating plants after turnover from the design 0

C organization.

Z Cll cv E

0 U

TOPICAL QUALITYASSURANCE REPORT APPENDIX E 0 LIST OF CORPORATE QUALITY ASSURANCE PROCEDURES Rev.

Page 3/28/90 of 5 9 6.7 CONTROL OF VENDOR MANUALSAND Establishes mquirements for controlling technical VENDOR TECHNICALINFORMATION manuals for operating, maintenance and test equipment.

7.1 RECEIFI'NSPECIION OF MATERIALS, Provides instructions for receipt inspection of PARTS AND COMPONENTS AT THE PLANT materials, parts and components which have been SITE obtained for use in nuclear safety applica-tions at the operating plant site.

7.2 CAN CEILED 7.3 CANCEIJZD 7,4 EVALUATIONOF SUPPLIERS OF Provides standards, measures, and guidelines for SAFETY RELATED HPJvIS OR the evaluation of QA Programs of contractors SERVICES or suppliers supplying items or services.

7.5 CANCELLED 7.6 ACCEPTANCE OF ITEMS AND SERVICES Describes the responsibilities and requirements for accepting nuclear safety related items or services that are being ptocured for nuclear power plants.

7.8 CANCELED 7.9 CONTROL OF ON-SITE VENDOR This procedure provides a system to assure that SERVICES vendors who provide on-site services by contract or purchase order to FPL at nuclear power plants are controlled.

8.1 IDENTIFICATIONAND CONTROL OF Delineates measures for assuring traceability, MATERIALS,PARTS, AND COMPONENTS identification and control of items from the AT THE PLANT SITE time they are received through usage at operating plants.

TOPICAL QUALITYASSURANCE REPORT APPENDIX E Rev.

LIST OF CORPORATE QUALITY 3/28/90 ASSURANCE PROCEDURES

@PL Page 6 of 9 8.2 CANCELLED 9.1 CONTROL OF SPECIAL PROCESSES Delineates the responsibilities of organizations and persorinel, and the control and documentation of special processes that are applied to safety related items.

9.2 CANCELLED (Combined with 9.1) 9.4 COKIROL OF WELDINGFOR NUCLEAR Delineates responsibilities and requirements for POWER PLANTS control FPL welding processes for nuclear power plants.

10.1 CANCELLED 10.2 CANCELLED 10.3 INSPECTION AND SURVEILLANCE Delineates responsibilities and requirements for the inspection and surveillance of safety related plant maintenance activities, operation of safety related systems, and fuel handling activities.

10.4 CANCELLED 10.5 CANCELLED 10.6 CANCEI~D 11.1 CANCEIZZD (Combined with 11.4) 11.2 CANCELLED (Combined with 11.4)

TOPICAL QUALITYASSURANCE REPORT APPENDIX E Rev.

LIST OF CORPORATE QUALITY 3/28/90 ASSURANCE PROCEDURES Page Of 7 .

9 11.3 CANCELLED (Combined with 11.4) 11.4 TEST CONTROL Defines the measures for control of proof test prior to installation, construction tests, preoperational tests, startup tests, operational tests and retests following repairs, replacements or modifications fornuclear safety related systems, structures, and components.

12.1 CALIBRATIONAND CONTROL OF Delineates the responsibilities for implementing MEASURING AND TEST EQUIPMENT the described program for maintenance, calibration and control of measuring and test equipment 0 12.2 CALIBRATIONCONTROL OF INSTALLED (M8tTE).

Describes the calibration program, delineates PLANT INSTRUMENTATIONAND CONTROL responsibilities, and establishes procedures for EQUIPMENT control over the calibration of install instrumentation and plant control equipment.

13.1 HANDLING,STORAGE AND Establishes responsibilities and procedures SHIPPING OF MATERIALS,PARTS to assure that measures are employed by FPL AND COMPONENTS and contractors to: (1) control the handling, shipping and storage of material; (2) protect the quality of material by using proper handling, shipping, and storage techniques; (3) effectively control the disposition of discrepant items.

13.2 CANCEL'LED 13.3 CANCELLED (Combined with 13.1) 14.1 CANCELLED (Combined with 14.3)

TOPICAL QUALITYASSURANCE REPORT APPENDIX E 0 LIST OF CORPORATE QUALITY Rev.

3/28/90 FPL ASSURANCE PROCEDURES Page 8 of 9 14.2 CANCELLED (Combined with 14.3) 14.3 INSPECTION, TEST AND Defines the measuies and responsibilities for the OPERATING STATUS DURING identification of the inspection, test and operating PLANT OPERATION status of structures, systems, and components.

15.1 CANCELLED (Combined with 15.2) 15.2 CONTROL OF NONCONFORhGNG Defines the objectives and responsibilities for PARTS OR MATERIALS,PARTS, controlling nonconforming items or services AND COMPONENTS in order to prevent their inadvertent use, installation or application to operating nuclear power plants.

16.1 CORRECIIVE ACTION Establishes the respective responsibilities of FPL personnel and the procedure for assuring that conditions identified by the FPL QA Department as being adverse to quality, are corrected.

16.2 CANCELLED (Combined with 16.1) 16.3 CANCELED (Combined with 16.1) 16.4 EVALUATINGAND REPORTING OF Specifies the measures and responsibilities within DEFECI'S &DEFECI'S AND Florida Power & Light to assure compliance to NONCOMPLIANCES FOR SUBSTAYI'IAL 10 CFR Part 21.

SAFEIY HAZARDS IN ACCORDANCE WITH 10 CFR PART 21

TOPICAL QUALITY'ASSURANCE REPORT APPENDIX E Rev 13 LIST OF CORPORATE QUALITY 3/28/90 FPL ASSURANCE PROCEDURES Page 9 of 9

.16.6 CANCELLED 17.1 QUALITYASSURANCE RECORDS Identifies records and documents required to I

substantiate quality; and, describes measures employed for their maintenance, retention and retrieval.

18.1 PERFORMANCE OF QUALITYASSUIVWCE Provides instructions for conducting audits of AUDITS FPL Quality Assurance Program activities.

18.2 CANCELL'ED 18.3 CANCELLED 18.4 CANCEL'LED

TOPICAL QUALITYASSURANCE REPORT APPENDIX F Rev.

l TOPICS TO BE ADDRESSED IN

" May 7, 1982 FLORIOA POWER 4 LIGHT COMPANY SAFETY ANALYSIS REPORTS Page I ofi The FPL Topical Quality Assurance Report is the statement of Florida Power R Light Company Quality Assurance Program Requirements which do not vary with plant site.

These stated requirements form a description of the FPL Quality Assurance Program which does not contain identification of the involvement of principal contractors such as the Architect/Engineer, Nuclear Steam Supply System vendor, or Constructor. The contractor involvement in the Program will be described in the plant Safety Analysis Report. In addition, other detailed aspects of the Quality Assurance Program vary from plant-to-plant or with plant site. These aspects will also be described in the plant SAR.

The requirements of the FPL Quality Assurance Program shall apply to the nuclear safety related structures, systems and components as defined in the applicable plant SAR.

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ML17348A300

Text

SUBJECT:

Description:

Enclosure:

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