ML17352B195
| ML17352B195 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie, Turkey Point  |
| Issue date: | 11/23/1994 |
| From: | FLORIDA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML17352B194 | List: |
| References | |
| FPLTQAR-1-76A, NUDOCS 9506160176 | |
| Download: ML17352B195 (203) | |
Text
UALITYASSURANCE MANUAL Rev. 41 TABLE OF CONTENTS Date 11 23 94 Pa e 1 or 2 TOPICAL QUALITYASSURANCE REPORT REV CHANGE RELEASE TITLE NO NO DATE Title Page 16 June 12, 1990 Abstract June 24; 1988 NRC Staff Evaluation Letter July 28, 1994 NRC Letter & Certificate - Quality August 10, 1994 Assurance Program Approval for Radioactive Material Packages Table of Contents 41 November 23, 1994 Quality Assurance Program Policy June 21, 1991 Introduction 13 February 1, 1994 Topical Quality Requirements TQR 1.0 Organization 27 February 1, 1994 TQR 2.0 Quality Assurance Program November 23, 1994 TQR 3.0 Design Control Sepetcmber 30, 1994 TQR 4.0 Procurement Document Control February 1, 1994 TQR 5.0 Instruction, Procedures & Drawings 10 February 1, 1994 TQR 6.0 Document Control February 1, 1994 TQR 7.0 Control of Purchased Items & Services February 1, 1994 TQR 8.0 Identification & Control of Material, Parts February 1, 1994
& Components TQR 9.0 Control of Special Processes September 30, 1994 TQR 10.0 Inspection February 1, 1994 TQR 11.0 Test Control February 1, 1994 TQR 12.0 Control of Measuring &, Test Equipment February 1, 1994 TQR 13.0 Handling, Storage & Shipping February 1, 1994
-- TQR 14.0 Inspection, Test & Operating Status 10 February 1, 1994 9506i60i76 '750607 PDR ADOCK 05000250 p PDR
UALITYASSXHbkNCE MANUAL Rev. 41 TABLE OF CONTENTS Date 11 23 94 Pa e 2 of 2 TOPICAL QUALITYASSURANCE REPORT REV CHANGE RELEASE TITLE NO NO DATE TQR 15.0 Nonconforming Materials, Parts or Components 10 February 1, 1994 TQR 16.0 Corrective Action 8 February 1, 1994 TQR 17.0 Quality Assurance Records February 1, 1994 TQR 18.0 Audits February 1, 1994 Appendices A - Organizations & Figures
, Figure 1-1: Organization of Departments 21 February 1, 1994 Affecting Quality Figure 1-2: Turkey Point Nuclear February 1, 1994 Site Organization Figure 1-3: St. Lucie Nuclear February 1, 1994 Site Organization B - Qualification & Experience Requirements June 12, 1990 for Quality Assurance Personnel C - Baseline Document Matrix October 31, 1994 D - Cancelled May 7, 1982 E - List of Corporate Quality Assurance 19 ~ February 1, 1994 Procedures (QPs) .
F - Topics to be Addressed in Safety May 7, 1982 Analysis Reports GLOSSARY I'lossary 19 October 31, 1994
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TOPICAL QUALITY ASSURANCE REPORT Rev. 9 QUALITY ASSURANCE PROGRAM POLICY Da<<
Page 1 oi 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 teliable, efficient and safe manner.
8 The Chairman of the Board and Chief Executive Officer of Florida Power & Light Company has delegated responsibility for execution of the Quality Assurance Program for Florida Power & Light Company nuclear plants to the President, Nuclear Division. The authority for developing and verifying execution of the program is delegated to the Vice President Nuclear Assurance.
The head of each organization performing quality-related activities is responsible for: identifying those activities within their organization which are quality-related as defined by the QA Program; establishing and clearly defining the duties and responsibilities 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 J.H.G 'd rg President, Nuclear Division
3.
TOPICAL QUALITYASSURANCE REPORT Rev. 13 INTRODVCTION Date 02/01/94 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 m XQJz summarizes the FPL approach to activities related to materials;parts;., components, systems and services included in the Quality Assurance Program. The third.pa+n>Appendices, which provide supporting statements, tabulations, and technical analyses or>deviations which are not, in themselves, the subject of the report.
The corporate Quality Assurance Manual (FPL-NQA-100A) consists of the Topical Quality
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Assurance Report and a Glossary of commonly, used. terms. The Topical Quality Assurance Report delineates the generic requirements and responsibilities by which FPL implements the corporate Quality Assurance Program. Revisions and changes to this report are made in accordance with a Quality Instruction outlined in.TQR 2.0.
<r; In addition to the Quality Assurance Manual,".Quality Instructions (Qls) 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 Ke Quality Assurance Manual. The Quality
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Instructions describe actions and responsibilities to be performed within a department or organization and address the requirements of the appropriate Topical Quality Requirements.
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.
The requirements of this Topical Quality Assurance Report apply to safety-related materials, parts, components, systems and structures; services employed for design, procurement construction, operation, maintenance, refueling, repair, and modification; and packaging and shipping of radioactive material (but not design and fabrication of packages for which a license, certificate of
-.--- compliance, or other approval must. be issued by the NRC) in accordance with 10 CFR part 71.
The safety-related systems for each plant are specified in the respective plant Safety Analysis Report.
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TOPICAL QUALITYASSURANCE REPORT Rev. 13 INTRODUCTION Date 02/01/94
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2 of 2 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 organizations structures that are unique to a particular plant shall be addressed in the respective SAR document.
ice President Nuclear Assurance
TOPICAL QVALITYASSVRANCE REPORT TQR 1.0 Rev. 27 ORGANIZATION Date 02/01/94 1 of 21 1.1 E ERAL RE IREMENT The Florida Power 8c 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 A.g,.>> .
performing quality assurance and quality control functions shall be described, and shall
+avr>>r illustrate the organizational independence and authority necessary to identify problems; to
~~+ Xp 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 ihdependenttof the person or groups responsible for performing the activity.
1.2 MPLEMENTATT N
..0 The FPL Chairman'of the Boardand Chief Executive Officer is ultimately responsible for the execution. of-thewQuality Assurance Program for FPL nuclear power plants. The f ~W 'r gm '
authority for developing-and ver'ifying execution of the program is delegated to the President-Nuclear Division and the Vice President Nuclear Assurance. The reporting relationship of each department involved with the Quality Assurance Program is shown in Appendix A.
To provide for a review and evaluation of Quality Assurance Program policies and activities, the President Nuclear Division has established the Company Nuclear Review Board (CNRB). This organization's responsibilities are defined in Section 1.3.1. !
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 affected department heads.
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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev. 27 ORGANIZATION Date 02/01/94 (
FPL 2 of" 21 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 matters within the member's department, with the Quality Assurance Department, and with other departments.
The head of each department or organization performing activities affecting quality is responsible for: a) identifying those activities within the organization which affect quality as defined by the Quality Assurance Program; b) establishing and clearly defining the
. duties and responsibilities of personnel within his organization who execute those activities affecting quality; and c) planning, selecting, and training personnel to meet the requirements of the Quality Assurance Program. The responsibility, authority, and organizational relationship for performing actvities affecting quality within each organization shall be established and delineated in organizational charts and written job or functional descriptions.
Activities affecting quality may be performed by FPL or be 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 cont'ractor 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.
I.3 RE P N IBILITIE The organization charts in Appendix A illustrate the lines of authority and areas of responsibility for each of the organizations that are involved in activities affecting quality.
Below are listed the departments and organizations that have'quality assurance Organizational responsibilities for implementation of the Quality Assurance 'esponsibilities.
Program are described in the Topical Quality Requirements (TQRs).
TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev. 27 ORGANIZATION Date 02/01/94 3 of 21 1.3.1 Nuclear Division 1.3.2 Su ort De artments 1.3.1.1 Plant Vice Presidents 1.3.2.1 Administrative Services Corporate Records
~Documentary Files 1.3.1.2 Nuclear Services 1.3.1.3 Nuclear Engineering 1.3..2'.2'nvironmental Affairs and Licensing
!.3.2~3/Protecdon tt.Control Systems 1.3.1.4 Nuclear Assurance
.3.2.4 Information Management 1.3.1.5 Nuclear Business Services 1.3.1 Nuclear Division Throughout plant'life, the Nuclear. Division, maintains control of and responsibility for power plant design, preoperational and.start-up testing, operation, maintenance,
'~,r'uclear refueling, and modification of the plant~in )! accordance with written and approved procedures.
The President~Nuclear Division has overall responsibility for the Nuclear,Division's activities including corporate responsibility for overall plant nuclear safety. Reporting to the PresidentvNuclear Division are: the Vice President - Turkey Point Plant, Vice President
- St. Lucie Plant, Vice President Nuclear Assurance, Vice President Nuclear Engineering and Licensing, Director Nuclear Services,, and the Manager Nuclear Business Services.
The Company Nuclear Review Board (CNRB), reporting to the President Nuclear Division, is comprised of executive level members of management with responsibilities for the execution of the Quality Assurance Program. The CNRB reviews, or directs the performance of reviews of, activities concerning the technical aspects of the operating nuclear power plant insofar as they impact 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.
TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev. 27 ORGANIZATION Date 02/01/94 4 of 21 The CNRB composition is described in Section 6.0 of each facility's Technical Specifications. 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.
The CNRB is responsible for reviewing and evaluating Quality Assurance Program policies and activities. Quality Assurance Program status reports shall be periodically given by the Quality Assurance Department.
CNRB meetings shall be held by the Chairman to keep members apprised of conditions including significant problems that require management attention. Periodic audits of the Quality Assurance Department shall be performed by a team independent of the Quality Assurance Department. The results of this audit are presented to the Vice President Nuclear Assurance and the CNRB.
1.3.1.1 Plant Vice Presidents 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, including procurement and control of material. The Plant Vice President has overall responsibility for implementation of the Environmental Protection Plans at their respective sites.
0 TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev. 27 ORGANIZATION Date 02/01/94 5 of 21 Reporting to the Plant Vice President - Turkey Point Plant are the Plant General Manager, the Services Manager, the Human Resources Manager, the Business Systems Manager, the Materials Management Manager, and the Licensing Manager. Also, the Plant Vice President has functional responsibility over the Site Engineering Manager g providing work direction to this group.
Reporting to the Vice President - St.. Lucie>Plant are the Plant General Manager, the
~~ XP.
Services Manager, the Licensing Manager, the Materials Management Manager, and the Human Resources Manager. Also, the PlantVice President has functional responsibility over the Site Engineering Manager, <providing work direction to this group.
The Plant General Managerr-..'PSL~and,Plant General Manager - PTN, through the r* '..%
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
,+e P Group (FRG) at the St. Lucie Plan't are comprised of key plant management and staff
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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 A
procedures and activities that impact plant safety and the facility operating license.
1.3.1.2 Nuclear Services The Director Nuclear Services is accountable for technical staff support to the Nuclear I
Plants and certain centralized special functions. Reporting to the Director Nuclear Services are the Manager Nuclear Training, Manager Nuclear Security, Manager Nuclear Health Physics/Chemistry and the Manager Nuclear Emergency Preparedness.
- a. The Manager Nuclear Training prepares policy documents regarding nuclear training and provides support to secure the necessary resources to ensure that Nuclear Division personnel pre adequately trained. They must have adequate technical and job-related skills to provide safe and efficient operation while complying with NRC requirements.
0 TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev. 27 ORGANIZATION Date 02/01/94 6 of 21
- b. The Manager Nuclear Security is responsible for coordinating the overall development and implementation of the FPL nuclear security program
- c. The Manager Nuclear Health Physics/Chemistry provides technical support and assistance to the plants in the areas of health physics, chemistry, radioactive waste and hazardous material control.
- d. The Manager Nuclear Emergency Preparedness provides technical support and assistance to plant and corporate management for activities associated with radiological emergency plans and procedures.
1.3.1.3 Nuclear Engineering and Licensing The Vice President Nuclear Engineering and Licensing is responsible for nuclear plant design, materials management at Juno Beach, contract activities and maintaining the operating licenses.
Reporting to the Vice President Nuclear Engineering and Licensing are the Manager-Turkey Point Engineering, Manager - St. Lucie Engineering, Manager - Licensing and Special Programs, Manager - Materials Management, Director - Technical Support, Manager Component Support and Inspections, and the Manager - St. Lucie Steam Generator Repair Project.
- a. Nuclear Engineering Nuclear Engineeringt includes personnel located at both nuclear sites and at rhe corporate office. 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 Piogram, and Nuclear Engineering is responsible for approval of the design output.
19 TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev. 27 ORGANIZATION Date 02/01/94 7 of 21 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
<>.r'J contractor organizations, Nuclear Engineering ensures that the contractor is C<~2 ..
technically qualified to perform the design-related activity. ~
The Manager - Turkey Point Engineering and the Manager - St. Lucie Engineering provide on-,site engineering support~and direct the engineering aspects of all FPL nuclear power plant projects'dunng>construction and operation to assure efficient, economical and reliable.pow'e~r'plant design, conformance with engineering
/Mw *.
schedules and budgets and compliance with regulatory requirements.
Nuclear Engineering;,is responsible for:
o power'plant design related aspects of the FPL Quality Assurance Program throughout all phases of plant life. 'his responsibility extends from initial
~P engineering evaluations of p1ant design-related site characteristics, through preliminary and detailed design, construction, operation and decommissioning; o development and maintenance of the design contml 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 items and services procurement, including establishment of procurement standards, the technical evaluation, equivalency evaluation, and commercial grade dedication-of replacement parts/components for nuclear plants;
TOPICAL QUALITYASSURANCE REPORT TQR 1eo Rev. 27 .
ORGANIZATION Date 02/01/94
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8 of 21 review of the technical and quality requirements in procurement requisitioning documents and changes thereto for safety related and quality related items and services, as well as configuration control activities for controlled design documentation associated with procurement. The review shall be performed by individuals other than the document originator.
Aspects of the above activities are performed by the Juno Beach Engineering organization as determined by the Vice President Eny'neering and Licensing.
- b. Licensing and Special Programs Licensing and Special Programs is responsible for engineering activities at the Juno Beach office and licensing activities as follows:
Engineering assurance; Probalistic risk management; Electrical engineering support; Civil engineering support; Mechanical engineering support; Configuration management and document control; Nuclear Division corporate interface with the NRC; Nuclear Division corporate administrative point of contact with INPO; Managing NRC safety and regulatory issues and developing effective strategies to resolve them; Advising senior Nuclear Division management on a regular basis of important developments in licensing areas which could significantly affect the Nuclear Division; Providing Nuclear Division licensing hearing and legal services; Providing corporate licensing support and guidance to onsite licensing organizations; >>
o Administering the Nuclear Problem Reporting System;
TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev. 27 ORGANIZATION Date 02/01/94 9 of 21 o Administering the Commitment Tracking System; o Administering the Operating Experience and Feedback System
- c. Materials Management
~Qg Materials Management is responsible for:
o negotiation, generation, issuance, and management of contracts (except nuclear fuel) and purchase orders for required contracted services supporting the operation, licensing, maintenance, modification, and inspection of FPL
, j.~
nuclear plants, and for materials and-equipment to support Nuclear Division staff; o reviewingiprocurement documents to assure that technical and quality requirements 'developed by others are incorporated into the procurement documents, which. it authorizes; o ensuring that requisitioning documents have the required approvals;
".A ..'
/'maintaining traceability of procurement document records for which they are responsible until transmitted to an approved storage facility.
- d. Nuclear Technical Support Nuclear Technical Support is responsible for the identification, design, development, implementation, on-going maintenance, and control of all Nuclear Division data processing information systems excluding process applications.
This encompasses the following accountabilities:
0 directing the development, implementation, and on-going maintenance of information management systems; 0 coordinating end directing the computer hardware and telecommunication planning and control within the Nuclear Division;
TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev. 27 ORGANIZATION Date 02/01/94 (
10 of 21 ensuring that the Nuclear Division's information management program is in full compliance with software quality assurance regulations and guidelines; administering and controlling system access; executing software production release and change control activities; administering physical databases and providing on-going technical support.
Nuclear Technical Support is also responsible for nuclear fuel engineering and procurement activities including the following:
determining sources of supply, evaluating alternatives, and negotiating and establishing arrangements with suppliers for acquisition, processing and delivery of nuclear fuel and related services for the nuclear fuel cycle; assuring that technical and quality requirements (including inputs from other FPL departments) are incorporated in fuel contracts. and letters of authorization, and that these documents have the necessary approvals; administering and managing contracts for nuclear fuel and related services to assure that technical and quality obligations are met, and serving as FPL liaison in all matters of nuclear fuel and fuel-related contracts; administering and managing spent fuel disposal contracts with Department of Energy and serving as FPL liaison in matters of nuclear fuel and high level waste disposal; performing the project management function with respect to fuel management, design, licensing, delivery and other technical aspects of nuclear fuel; all fuel related design, analyses, reviews, and technical assistance necessary to ensure the safe, reliable, and economic operation of the nuclear plants; the optimization of nuclear fuel cycle economics within nuclear safety and operating constraints, as well as providing fuel related information, such as forecasts of nuclear fuel requirements to support licensing and regulatory requirements; 0 the development and/or review of fuel and nuclear physics design;
TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev. 27 ORGANIZATION Date 02/01/94 11 of'1 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
~ Xhh,.AJ nuclear fuel design and fuel assembly manufacturing; o performing audits and coordinating accountability reporting on all nuclear fuel.
The Nuclear Records Official, reporting to the Director Technical Support, is responsible for:
o ensuring the Quality.Assurance records program activities are managed in accordance with applicable. laws and regulations; o developing, approving and maintaining record retention schedules; o establishing. parameters for,.records indexing; o locating'acceptable record storage areas when requested; o storage, retrieval and control of records/documents as requested by other depamnents; o leading the evaluation of specially designated QARSET approved storage facilities, maintaining records of this evaluation, and establishing schedules to assure that re-evaluations are performed every two (2) years.
- e. Component Support and Inspections Component Support and Inspections is responsible for providing support to the plants as follows:
o providing technical support of activities associated with component reliability, materials evaluations, inspections, corrosion protection, non-destructive examination,and ASME Section XI implementation/problem resolution for plant components; i'uclear
TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev. 27 ORGANIZATION Date 02/01/94 12 of 21 providing specific component expertise, metallurgical support, and non-destructive examination and inspections; r
establishing the FPL Welding Program to meet the requirements of the Quality Assurance Program and applicable codes and standards; developing, maintaining, and controlling the procedures and instructions to implement the FPL Welding Program; originating and qualifying welding procedure specifications; and providing technical direction to personnel within the FPL Welding Program.
1.3.1.4 Nuclear Assurance 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 and the Nuclear Safety Assessment Group. The Vice President Nuclear Assurance also initiates QA Program policy changes when necessary. In addition, the Vice President Nuclear Assurance is responsible for selecting a team independent of the Quality Assurance Department to perform periodic audits of the Quality Assurance Department. The results of these audits are presented to the Vice President, Nuclear Assurance and the Company Nuclear Review Board (CNRB).
Reporting to the Vice President Nuclear Assurance are the Director Nuclear Safety Assessment, the Site Quality Manager- Turkey Point, the Site Quality Manager- St. Lucie and the Quality Manager - Juno Beach.
- a. Nuclear Safety Assessment The Director Nuclear Safety Assessment has responsibility for the management and implementation of Nuclear Safety Speakout, PSL and PTN Independent Safety Engineering Groups (ISEG), and the CNRB subcommittee, and serves as the CNRB Chairman.
TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev. 27 ORGANIZATION Date 02/01/94 13 of 21 The Nuclear Safety Speakout Program 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.
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 jl 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 x'equirements.
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 corYectiye action; and d) recommend the stoppage of work or operations adverse to quality, when necessary. The Quality Manager - Juno Beach, the Site Quality Manager - St. Lucie and the Site Quality Manager - Turkey
TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev. 27 ORGANIZATION Date 02/01/94 14 of 21 Point report administratively and functionally to the Vice President Nuclear Assurance. These reporting relationships assure that the Quality Assurance Department has direct access to the levels of management necessary to assure effective implementation of the Quality Assurance Program.
The duties, responsibilities, and authorities of each Quality Assurance group are described in the sections which follow.
- 1) Quality Assurance Services The Quality Manager - Juno Beach directs and administers the Corporate Quality Assurance Program assuring compliance with the baseline documents listed in Appendix C of this Topical Quality Assurance Report. Quality Assurance Services activities include the following:
o develop and maintain the Quality Assurance Department Quality Instructions and the corporate Quality Assurance Manual, including the administration of the Quality Assurance Program Review Committee (QAPRC);
o assist other departments in the development of Quality Instructions by review and comment and through interpretation of corporate Quality Assurance requirements; (
o develop and implement a Quality Assurance indoctrination program for FPL personnel, and a training program for the Quality Assurance Department; o prepare reports on Quality Assurance Program activities for review by the CNRB; o review Regulatory Guides, Codes, SAR Document Commitments and Standards for impact on the Quality Assurance Program and recommend appropriate program changes;
TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev. 27 ORGANIZATION Date 02/01/94 15 of 21 review documents submitted to the CNRB as requested by the Nuclear 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; review FPL originated design specifications for inclusion of appropriate quality requirements; perform periodic activity auditsgof FPL procurement and associated documents and changes to these documents to assure that the necessary quality requirements are imposed; assist in the-development andqimplementation 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 Cp erfo~rm appropriate surveillance of hardware during manufacture; g>>
evelop and implement a program for auditing of supplier Quality
'ssurance/Quality Control programs including Architect Engineer/Nuclear team Supply System Suppliers;
~o as sure design-related the quality aspects activities performed by the Architect Engineer meet of the contract; 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; assure that the contractors'rganizations performing Quality Assurance functions have sufficient authority and organizational freedom to implement effective Quality Assurance programs; evaluate the Quality Assurance capability of suppliers requested by Materials'Management and maintain the Quality Assurance Department list of approved suppliers;
)
TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev. 27 ORGANIZATION Date 02/01/94 16 of 21 o provide NDE Level III services-including technical direction and monitoring of NDE activities performed by Quality Control at the plant sites (PTN and PSL); preparation, revision and implementation of NDE procedures; training, testing and qualification of NDE personnel, and providing the programs and direction for NDE activities meeting the ASME, AWS and other NDE code requirements; o maintain a file system for documentation of quality assurance activities performed.
For purchased items and services, the responsibility of this group extends through receipt of shipment or performance of contract.
- 2) Site Quality Assurance - Turkey Point Nuclear (PTN) and St. Lucie (PSL)
Quality Assurance activities at the plant sites (PTN and PSL) are accomplished by the respective site Quality Assurance groups, reporting to the Site Quality Manager. The Site Quality Manager has responsibility for on-site development and implementation of the Quality Assurance Program, including the following:
o coordinate the development and implementation of policies, plans, 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, material storage, health physics, chemistry, plant security and fire protection;
TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev. 27 ORGANIZATION Date 02/01/94 17 of 21 o perform periodic activity audits of site generated FPL procurement and associated documents and changes to these documents to assure that the necessary quality requirements are imposed; o identify requirements, ensure inclusion ofcommitments in documents and verify implementation of the Quality>Assurance Program during construction activities at the plant,stte~through audits of FPL and contractor organizations; o recommend stoppage of work or. operations adverse to quality at the plant site in accordance with the. appropriate instructions;
/" W><W o review and comm~ent on Quality Instructions or equivalent quality administrative. procedures prior"to issue, with respect to the requirements of the FPL~Quality Assurance Program, the applicable Final Safety AnalysistReport, 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"ss indicationf that a commitment will not be met on time;
<<o perform audits of the architect engineer and Nuclear Steam Supply System suppliers both on-site and off-site, in conjunction with the Quality Assurance Services group; o maintain a file system for documentation of quality assurance activities performed by the Site Quality Assurance group.
The interface with the Quality Assurance Services group ends with the receipt of a shipment of nuclear safety-related equipment at the plant site. The Quality Assurance program for the shipment is then within the purview of the Site Quality Assurance group.
The Quality Manager - Turkey Point and Quality Manager - St. Lucie are additionally responsible for the establishment and implementation of quality control aspects of the Quality Assurance Program at the plant site. Reporting
TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev. 27 ORGANIZATION Date 02/01/94 (
18 of 21 directly to the Site Quality Manager are the Quality Control Supervisors who have the authority and freedom to administer the Quality Control program and, when necessary, to stop activities adverse to quality. The Quality Control Supervisors and personnel performing Quality Control inspection functions are required to be independent of groups or persons performing activities that they may be required to verify or inspect.
Quality Control responsibilities include:
o preparation and review of plant procedures, design control documents, and instructions for activities affecting quality; o inspection, monitoring, surveillance, and review of plant activities to verify compliance with the provision of the facility operating license and the Quality Assurance Manual; o inspections to assure that activities meet the requirements of engineering drawings, specifications, codes and standards; o receipt inspections of material; o acceptance of the installed items; o verification of conformance of items or activities to 'quality requirements (e.g., records review, NDE, inspections);
o corrective action for deficiencies identified, where applicable; o follow up on corrective action taken by other organizations until close out.
Off-site interfaces for the resolution of quality 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 problems.
TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev. 27 ORGANIZATION Date 02/01/94 19 of 21 1.3.1.5 Nuclear Business Services The ManagerNuclear Business Services isresponsible for. coordinating the budget, rate, and cost control support to the plants and staff organizations; and coordinating Division business planning, target setting and monitoring~of f Jceyiperformance indicators, and operations analysis activities.
1.3.2 Su ort De artments Providing support activities for the Nuclear Division are Administrative Services, Environmental Affairs, Protection Ec Control Systems, and Information Management. The reporting relationship of each;department>is>described in the following sections and is shown in Appendix A.
'Q 1.3.2.1 Administrative Services y
The Manager Administrative Ser'vices is responsible for:
o A
storage, retrieval and control of Quality Assurance records received from other departments; o assisting with the development and implementation of records and micrographics programs; o maintaining a QARSET approved storage facility; o receiving, maintaining, retrieving and storing the Quality Assurance records transmitted from other departments in connection with licenses and contracts.
1.3.2.2 Environmental Affairs Environmental Affairs is responsible for obtaining the federal and state environmental permits'equired for FPL facilities and operations. Environmental Affairs is also responsible for providing technical support on environmental regulatory requirements, including regulatory development, enforcement actions, compliance with environmental
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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev. 27 ORGANIZATION Date 02/01/94 21 of 21
'1.3.2.4 Information Management Information Management consists of Computer Operations4ervices, Client Services, and Quality Management reporting to the Vice President of Informanon Management.
4~~'he Computer Operations Services Department is>responsible for the installation and maintenance of the operating system software"and the operation of the computer hardware for FPL's corporate computer systems.~The application pregame used by the nuclear departments executes on these corporate. computers.
Client Services is responsible. for software libraries on FPL's in-house time-sharing-Computer System (CMS) that are under its-cont'rol.
Quality Management, provides support to the Nuclear Division in their development and maintenance of computer applications'in'the area of software library controls.
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TOPICAL UALITYASSUIUXCE REPORT TQR 2.0 Rev. 13 QUALITYASSURANCE PROGRAM Date 11 23 94 Pae 1 'Of 8 2.1, 'ENERAL 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 PolicypStatement, together with 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 therre'quired 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 Pr'ogram shall apply to-all FPIcontractor, or consultant organizations performing. activities affecting the quality of safety related structures, systems, and
(( 0 components of FPL nuclear power plants. Portions of the FPL Quality Assurance Program requirements are also applicable to Quality Related items and services.
Those portions applicable to specific Quality Related items or services shall be delineated in appropriate instructions.
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 2.2.6.d and by Quality Assurance Department audits,
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TOPICAL UALFIYASSVIUKCE REPORT TQR 2.0 Rev. 13 QVALITYASSVIUXCE PROGRAM Date 11 23 94 Pare 2 of 8 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 Po'licy Statement of the President of the Nuclear Division, the goal of the FPL,Quality Assurance Program is to maintain quality levels in an effectiveI 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:
- a. 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 activities affecting quality are performed by responsible personnel;.
TOPICAL UALHYASSXHUXCE REPORT TQR 2.0 Rev. 13 QUALITYASSURANCE PROGRAM Date 11 23 94 Pa e 3 of 8
- 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 deflnes the policy, goals, objectives, V/
responsibilities and interfaces regarding~the Quality Assurance Program, shall be.
contained in the FPL Quality Assurance )Mariual, and used as guidance for the development of Quality Instructions.v Revisions to the Topical Quality Assurance Report will be made, as needed, to reflect current FPL program requirements and
(( . 3) descriptions of activities, These revisions'shall be made in accordance with a Quality Instruction.>If a program reflects a reduction of the commitments from the baseline documents contained in Appendix C, the revision shall be submitted to and y~J 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.
Each department head shall have the responsibility for implementation of the Quality Assurance Program, which includes compliance with procedure requirements applicable to the department. In addition, each department head shall be responsible for the preparation, approval, and distribution of Quality Instructions, operating procedures, testing procedgres, or other instructions where further guidance is necessary for implementation of the Quality Assurance Program requirements within the department. Quality Instructions shall be reviewed by the Quality Assurance Department at each revision.
TOPICAL UALFIYASSURANCE REPORT TQR 2.0 Rev. 13 QUALITYASSUIbLNCE PROGRAM Date 11 23 94 Pae'4 of' 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 t'tat 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.
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 Powe'r & 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.
1X)PICAL UALFIYASSUIUXCE REPORT QUALITYASSVIUACE PROGRAM
'QR Rev..
Date 13 2.0 11 23 94 Pa e 5 or 8 However, FPL shall retain overall responsibilities for the Quality Assurance Program. Procurement documents shall deGne 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'onceptual and/or prototype nature. In all cases, final approval shall occur at a potnttin 'thetprocess to ensure that the output
)J complies with the requirements of. the FPL approved Quality Assurance Program.
The object of this review shall be'to verify th~at the program is in compliance with the applicable requirements ofAppendix B;10CFR50, and ANSI N45.2. Audits shall be
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conducted periodically,to verify.thesacceptable implementation of the contractor's
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FPL approved Quality Assurance. Program governing delegated activities. The Quality Assurance Department is'responsible for conducting these audits. The initial review a'nd>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 activities affecting quality.
Instructions shall delineate the requirements for an indoctrination program to assure that personnel responsible for performing activities affecting quality are instructed in the purpose, scope, and implementation of. the manuals, instructions, and procedures and that compliance to these documents is a mandatory requirement.
TOPICAL UALITYASSXHHNCE REPORT TQR 2.0 Rev. 13 QUALITYASSUIUACE PROGRAM Date 11 23 94 Pa e 6 of 8 Instructions shall also require the head of each department to be responsible for a training plan which assures that personnel performing activities affecting quality are trained in the principles and techniques of the activity being performed. This training shall maintain the proficiency of personnel in the skills necessary through retraining, requalification or reexamination, as appropriate. This training shall be conducted to reQect significant procedure changes, or plant modifications which significantly affect the operation of the department. 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 indoctrination and training of personnel who perform activities under their direction, Instructions shall specify the requirements for documenting indoctrination and training sessions, including a course description, attendance, location, and date. Records shall contain sufficient information to identify persons in attendance with the corresponding lesson plans.
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:
- a. The CNRB shall review a summary of the results of management level Quality Assurance audits of FPL Departments;-
TOPICAL UALITYASSUIUWCE REPORT TOR 2.0 Rev. 13 QUALITYASSURANCE PROGRAM Date 11 23 94 Pa e 7 or 8
- b. The Quality Assurance Department shall periodically, but not less than quarterly, circulate reports of activities to members of the CNRB and affected department heads. The 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 accomptishments~
- d. Periodic audits of the Quality A'ssurance Department and Program shall be conducted by an independent;audit<group under the direction of the Vice President Nuclei~A surance~This audit group shall employ FPL audit
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procedures and'shall distribute, the. audit report to the Vice President Nuclear Assurance, and t'o"'the CNRB",for review of findings and corrective action.
Auditorgcertifications of independent audit teams will be retained by the Quality Assurance Department.
The programs of contractor organizations that perform activities affecting quality 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.
2.3 RESPONSIBILITIES s..
2.3.1 Each direct report of the President, Nuclear Division and Department Heads of organizations supporting the Nuclear Division shall be responsible for:
- 1. Reviewing changes to the FPL QA Manual and determining the need for departmental instructions, revising existing instructions, and approving instructions;
TOPICAL UALITYASSURANCE REPORT, TQR 2.0 Rev. 13 QUALITYASSUIUACE PROGRAM Date 11 23 94 Page 8 of 8 Controlling distribution and coordinating the use of the instructions with affected organizations and functions;
. 3. Submitting Quality Assurance Indoctrination (QAI) lesson plans to the Vice President Nuclear Assurance for approval to conduct their own QAI.
.2.3,2 The Vice President Nuclear Assurance has overall responsibility for':
- 1. Development, coordination, and periodic reviews of the status and adequacy of the FPL Quality Assurance Program;
- 2. Establishing, conducting, reviewing and authorizing the implementation of FPL's requirements for QAI;
- 3. Coordinating revisions to the Topical Quality Assurance Report.
TOPICAL UAGHYASSURANCE REPORT TQR 3.0 Rev. 11 DESIGN CONTROL Date 9 30 94 P e 1 of 10 3.1 GENERAL RE UIREMENTS A Quality Assurance Program shall be established, for. design-related activities. The design control program shall ensure that the design is de6ned, controlled and veri6ed; that applicable design inputs are speci6ed aad correctly translated into design output documents; that design interfaces are identi6ed and controlled; that design adequacy is veri6ed by persons other than those who designed the item; and that design changes, including Beld'hanges, are governed by control measures commensurate with those<apitlied to the original design.
Design records shall be,'developed to provide evidence that the design process and design veri6cation-were performed-in accordance with the requiremeats of FPL's
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Quality Assurance)Program.. g Design records shall include design output documents aad the important steps in the Q~f design.eKort. The intent of this documentation is to allow a technically quali6ed 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.
Documents aad databases designating safety related and quality related items and any revisions thereto shall be controlled in accordance with the FPL QA Program requirements.
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TOPICAL VALIDLYASSXHUWCE REPORT TQR 3.0 Rev. 11 DESIGN CONTROL Date 9 30 94 P e 2 of 10 32 IMPLEMENTATION The controlling document for the identi6cation of safety related items shall be the FSAR. %here the FSAR is not de6nitive for a speci6ed plant, Nuclear Engineering shall develop and maintain documents/databases identifying those items which are safety related (e.g., plant equipment database, Instrument List, Valve List, Line List, drawings, etc). These documents/databases shall clearly identify the boundaries of safety related systems and may take the form of identifying boundaries on engineering drawings. For quality related items, Nuclear Engineering shall specify explicitly those aspects of design, manufacture, procurement, installation, and testing that shall be subject to the FPL QA Program requirements, as appropriate, in the design output documents (e.g,, Plant Change/Modi6cation package).
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 Instructions shall be developed to delineate design control requirements governing design-related activities performed by Nuclear Engineering and for delegating activities to contractor organizations.
Design data approved by the design organization shall be transmitted in design output documents such as speci6cations, drawings, and other documents de6ning technical requirements or in correspondence which may reference these documents.
Transmittals shall identify the status of design information or documents provided, and where necessary, identify incomplete items which require further evaluation, review, or approval.
TOPICAL VALI'SSUIbLNCEREPORT TQR 3.0 Rev. 11
. DESIGN CONTROL Date 9 30 94 P e 3 of 10 A standard PC/M and numbering system shall be established and used at each plant to ensure that all PC/Ms are handled in a uniform manner and properly documented. Nuclear Engineering shall fonvard therapproved PC/M,.to the applicable Plant Vice President. Internal plant coordination and review of design control documents shall be controlled by'ap roved instructions.
32.1 Design Process The design organization shalll 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 outputtdocuments 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 item shall be selected, reviewed and approved for suitability of application by the design organization.
Design inputs shall be identiGed, documented, reviewed and approved by the design organization. They shall be specifted 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 veriGcation 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.
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0'he design organization shall identify aspects of manufacture, construction, inspection and testing critical to achieving the function of the item. Quality standards and quality requirements shall be specified on design output documents.
Changes from approved quality- requirements specified in design output, including
TOPICAL UALITYASSURANCE REPORT. TQR 3.0 Rev. 11 DESIGN CONTROL FPL Date P e 4 9 30 94 a 10 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 veriGcation. The design organization shall establish procedures to review industry design experience. As appropriate, this experience shall be made available to cognizant design personnel.
322 Design Change Control Changes to approved design output documents, including Geld changes, shall be justiGed, 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 speciGcally designated.
Where a signiGcant 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 modiGed to correct the cause of the incorrect design.
Design changes shall be reviewed to ensure that implementation of the design change is coordinated with any necessary changes to operating procedures and practices, and required Nuclear Assurance activities, such as inspections and
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TOPICAL VAHHTASSURANCE REPORT TQR 3.0 Rev. 11 DESIGN COXIROL '
Date 9 30 94 e 5 of 10 In accordance with plant technical speci6cation requirements, nuclear safety-related design changes are reviewed by'he Plant Nuclear>Safety Committee (PNSC) or paciTity Review Group (FRG) and the Company>NucleaptReview Board (CNItB).
3.23 Design Interface Control Quality Instructions shall establish interface controls between participating
(('t'.t the~variouscechnical disciplines within the design organizations and between organization. These Quality~lnsnuctions shall include the assignment of gg/J responsibility, and be'in suKctent detail to cover the preparation, review, approval, release, distribution and~revision of design output documents.
g~ j 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.
32,4 Design Veri6cation Design control measures shall be established to independently verify the design inputs, design process, and that design inputs are correctly incorporated into design output. The design organization shall develop instructions that govern design veri6cation. These instructions shall require that the design organization identify and document the veri6cation method utilized and that the documentation clearly identify those individuals performing the design veri6cation.
TOPICAL VARYASSVKUWCE RIZ'ORT . TQR 3.0 Rev. 11 DESIGN CONTROL Date 9 30 94 P e 6 of 10 Design veriGcation shall be performed by technically qualiGed individual(s) or group(s) other than those who performed the design. The original designers and
-veriGers may both be from the design organization. Design veri6cation by the designer's immediate supervisor shall be limited to those instances where the supervisor is the only qualiQed 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 speciGed design inputs have already been independently veri6ed). Justi6cation for veriGcation 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 veriQcation 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 qualiGcation tests. This shall apply to original design and to changes to approved design output.
Where reveriQcation 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 veriQcation requirement. Design veriQcation 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. VeriGcation shall be conducted based on the. status of design at the time of release of design documents. Where this timing cannot be met, veriGcation may be deferred provided that the unveriGed portion of the design output, and all design output documents, structures, systems and components based on the unveriQed portion of design are
TOPICAL VALI'SSURANCE R1H'ORT TQR 3.0 Rev. 11 DESIGN CONTROL Date 9 30 94 P e 7 of 10 identi6ed and controlled. In all cases veriGcation shall be completed prior to relying on any affected items to perform their design functions.
325 Computer Programs/Software Organizations utilizing purchased or FPL developed computer programs/software in the performance of activities affecting quality r as defmed in the TQAR, shall maintain instructions or procedures'to effect the following:
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- a. That such programs/software within the scope of the quality assurance program are identi6edand included in a computer software index. The controlled distribution of ithis index shall include the Manager Information
, Management~(IM) /Operations. The method for determining which programs/software fall'withinthe scope of the QA program shall be described
)I in these procedures or instructions;
- b. That such programs/software are veri6ed for their particular use using benchmark problems, alternate calculations, comparison with other code or experimental-results, design review or similar methods;
- c. That such programs/software have been quali6ed for their speci6c application suKcient to ensure valid results;
- d. That such programs/software are provided with user instructions suf'6cient for a technically competent individual to follow;
- e. 'hat con6guration controls are provided to assure that such programs/software changes or modifications are documented and controlled;
- f. That errors in such programs/software are identiGed, evaluated, provided with
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a disposition and corrected.
TOPICAL VALHYASSURANCE REPORT TQR 3.0 Rev. 11 DESIGN CONTROL Date 9 30 94 P e 8 of 10 39 RESPONSIBILITIES 3.3.1 The Vice President Nuclear Engineering and Licensing is responsible for:
- a. Determining and documenting which items are nuclear safety related or quality related; b, The review and coordination of design interfaces;
- c. Assuring that design documents are reviewed for possible design interfaces, that interface problems are resolved and that design criteria and design interface changes are reviewed by participating organizations prior to approval of design documents;
- d. Preparing design documents, including performing the safety evaluation or screening to determine ifthe proposed design change involves an Unreviewed Safety Question or a change to the Technical Specifications;
- e. Performing design verification, including evaluation of the effects of proposed design changes on overall design adequacy (design integration);
Providing Nuclear Engineering approval of design documents;
- g. Updating design documents and drawings according to applicable procedures; Coordinating the NRC interface for 10 CFR 50.59 reports.
332 The Site Vice President is responsible for:
Reviewing, tracking the status of, and maintaining a file on proposed PC/Ms;
- b. Reviewing proposed PC/Ms for inclusion of appropriate quality criteria, standards, and hold points, including human factors considerations for design changes involving the Control Room or Remote Shutdown Panel;
TOPICAL VALFIYASSXQUXCE REPORT TQR 3.0 Rev. 11 DESIGN CONTROL Date 9 30 94 P e 9 of 10 C. reviewing completed PC/Ms, af'ter implementation for compliance with governing procedures, including a review of~all~endorsements, sign-ofts, completion of required acceptance testing/inspection, and any necessary to operating practices and procedures;+ V'hanges
- d. maintaining design documents as Quality Assurance records.
- e. assuring that all plant design changes and drawing changes are coordinated through Nuclear Engineering; ~
(~ X3 detertnining whether or not a proposed. design change affects nuclear safety;
- g. approving or disapprov'ing implementation of the proposed design change after receipt of a recommendation from the Plant Nuclear Safety Committee c~> ~
(PNSC) or Facility~ReviewiGroup (FRG);
ensuring~the Environmental Affairs Department is included in the proposed PC/M-review
(( 9 if the~design change may have an adverse impact on the environment;
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reviewing design changes to ensure that the implementation of the design
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change is coordinated with any necessary changes to operating practices and
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procedures. 4 3.3.3 The Plant Nuclear Safety Committee (PNSC) or Facility Review Group (FRG) is responsible for:
0'. b.
Reviewing all proposed PC/Ms for plant systems or equipment related to nuclear safety; Rendering a determination in writing (PNSC/FRG meeting minutes) as to whether or not the proposed design change constitutes an Unreviewed Safety Question.
TOPICAL UALITYASSX94LNCE REX'GRT TQR 3.0 Rev. 11 DESIGN CONTROL Date 9 30 94 P e 10 of 10 3.3.4 The Vice President Nuclear Assurance is responsible for:
- a. reviewing PC/Ms for inclusion of appropriate quality criteria, standards, hold points, and Nuclear Assurance activities.
3.35 The Company Nuclear Review Board (CNRB) is responsible for:
a Reviewing Safety Evaluations for design changes to verify that the design changes did not constitute an Unreviewed Safety Question. CNRB review of evaluations involving screening rather than Safety Evaluation is not mandatory;
- b. Reviewing proposed design changes which involve an Unreviewed Safety Question or a change in Technical Specifications or License.
33.6 Each direct report to the President, Nuclear Division and Department Heads of organizations supporting the Nuclear Division shall be responsible for:
- a. identiGcation of computer programs/software used to accomplish activities affecting quality;
- b. establishment of departmental instructions which prescribe the methods and techniques used to meet the QA program requirements for control of computer programs/software.
33.7 The Manager Information Management (IM) Operations is responsible for evaluating all hardware or operating system software changes or problems occurring on'computer systems under IM control to determine if the answers produced or the affected. If the Manager IM
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integrity of data maintained in databases may be Operations determines applications may be affected, then he/she is responsible for notifying user departments.
TOPICAL QUALITYASSURANCE REPORT TQR 4.0 Rev. 7 PROCUREMENT DOCUMENT Date 02/01/94 CONTROL 1 of 5
- 4. 1 E ERAL RE IREMENT Procurement of items and services shall be performed in accordance with procedures and instructions which assure that applicableregulatory requirements, design bases, code N
requirements, and other requirements necessary to assu e quality shall be included or invoked by reference in the procurement document.r These procedures and instructions shall delineate the sequence of actions to be accomplished in the preparation, review, Esrg
- 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 4e2 PLEMENTATI 4.2.1 Procurement Document Provisions p Quality Instructions-shall identify the-responsibilities and actions required of the organizations, originating, reviewing, approving, and controlling procurement documents.
These instructions)shell require the" procurement documents to specify:.
a.
(P~h iThe scope of work to be performed;
- b. Technical requirements (by specifying or referencing) which shall include the applicable components and materials identification requirements, drawings, specifications, procedures, instructions, codes, and regulations and provide for identification of applicable test, inspection and acceptance requirements, or special process instructions;
- c. Quality Assurance Program requirements to be imposed on contractors which shall include the applicable portions of 10 CFR 50, Appendix B;
- d. Right of access which provides, as appropriate, for access to contractor facilities and records for inspection or audit by FPL or its designated representative, and to access for events such as witness and hold points; Qua) to
TOPICAL QUALITYASSURANCE REPORT TQR 4.0 Rev; 7 PROCUREMENT DOCUMENT Date 02/01/94 (
CONTROL 2 of 5
- 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 subminal 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 ensure on-site implementation of the special handling, shipping, and storage requirements for items received and controlled by their organization.
'I Special handling, preservation, storage, cleaning, packaging, and shipping requirements shall be specified, as appropriate, in the design documents or purchase orders. The requirements established in the design documents or purchase orders shall be consistent with industry accepted standards, the importance of equipment or material to nuclear safety, and the material or equipment's sensitivity to damage. The preparation of these design documents or purchase orders may be delegated by FPL to other organizations.
4.2.2 Procurement Document Review
~
Procurement documents shall be reviewed for correctness, and inspectability and controllability of quality requirements in accordance with Quality Instructions to assure that the appropriate provisions of Section 4.2.1 are included. This review shall be documented and performed by designated personnel who have been trained and qualified in quality assurance practices and concepts. These reviewers shall have access to pertinent information and have an adequate understanding of the quality and technical requirements and intent of the procurement documents.
Spare or replacement parts for safety related structures, systems, and components are subject to'technical or quality requirements equivalent to, or better than, those used for the original equipment.
TOPICAL QUALITYASSURANCE REPORT TQR 4.0 Rev. 7 PROCUREMENT DOCUMENT Date 02/01/94 CONTROL 3 of 5 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 It shall be verifed 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. Verbal purshaseorders,shall be made in accordance with TQAR Appendix C exceptions to ANSI N45.2.13. Supplier approval is not necessary if the
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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 instruction's'." ~
4.3 RE P IBILITIE 4.3.1 6
Direct reports of the President, Nuclear Division, and Department Heads of organizations supporting the Nuclear Division originating a procurement requisition shall be responsible for.
- a. Clearly describing the technical and quality considerations for the procurement of items or services;
- b. Specifying any special requirements; C. Specifying documentation required from the supplier;
- d. Specifying special handling, preservation, storage, cleaning, packaging, and shipping requirements, as appropriate.
l 0
TOPICAL QUALITYASSURANCE REPORT TQR 4.0 Rev. 7 PROCUREMENT DOCUMENT 0ate 02/01/94 (
CONTROL 4 of 5 4.3.2 The Vice President Nuclear Engineering and Licensing is responsible for:
ae Performing technical evaluations to verify and/or establish technical and quality requirements for permanent and temporary power plant items and services;
- b. Reviewing procurement documents and changes thereto to assure that ordering requirements are technically correct and complete for items and services as specified in 4.2.1, including quality requirements; C. ~ Valuating the interchangeability of items that are not identical to what is currently installed.
4.3.3 The Vice President Nuclear Assurance is responsible for:
a.. Assisting in the resolution of quality requirements;
- b. approving suppliers for safety related procurement and commercial grade item procurement (when applicable);
- c. Identifying surveillance witness and/or hold points at the supplier's facility for safety related procurement when supplier QA pro~ is relied upon and programmatic deficiencies dictate;
- d. Performing supplier surveillance.
4.3.4 The Plant Vice President and Vice President Nuclear Engineering and Licensing, cognizant for the issuance of a procurement document is responsible for:
- a. Incorporating requisition technical and quality requirements into the procurement documents;
- b. ,Notifying Nuclear Assurance of discrepancies and/or changes in supplier activities which may conflict with the work scope of Nuclear Assurance approved suppliers; C. Reviewing each procurement document to ensure that it is correct, in accordance with Nuclear Assurance approved supplier work scope and restrictions (when applicable) and the orig'nating procurement requisition;
TOPICAL QUALITYASSURANCE REPORT TQR 4.0 Rev. 7 PROCUREMENT DOCUMENT Date 02/01/94 CONTROL 5 of 5 Referencing and attaching appropriate Quality Assurance Program requirements, as referenced on respective procurement requisitions, requests for bid proposals, purchase orders and contracts; verifying that the procurement document haa been reviewed and approved and
+M/
issuing procurement documents to suppliers, as approved'by FPQ Nuclear Assurance when supplier QA programs are required; maintaining traceability of procurement document records until transmitted to an approved storage facility.
TOPICAL QUALITYASSURANCE REPORT TQR 5.0 Rev. 10 INSTRUCTIONS, PROCEDURES Date 02/01/94 FPL AND DRAVQNGS 1 of 3
- 5. I E RAL RE IREME T 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 accomplishedin accordance with these instructions, procedures, or drawings. These documents shall include appropriate Nfl+
quantitative criteria such as dimensions, tolerances, and operating limits, and qualitative criteria such as comparative workmanship samplesto assure that the quality assurance activity has been satisfactorily accomplished.
5.2 PLEMENTATI
<<>>3 5.2.1 Quality Assurance ProgramG3ocuments
~> (Q>.
The FPL Quality. Assurance Manu'al described in TQR 2.0 contains the Topical Quality gf Assurance Report. which complies with the criteria of 10 CFR 50, Appendix B. Quality Instructions<provide direction fo'r activities affecting quality. The Quality Assurance Depanment" reviews and comments on Qualtty Instructions written by other departments.
A Comme'nts 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 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 Assurance or Quality.. Control personnel and provisions for temporary changes and temporary procedures. These plant procedures include operating procedures, off-normal and emergency procedures, test procedures, and calibration t3>> (3'>> '>> 2
0 TOPICAL QUALITYASSURANCE REPORT TQR 5.0 Rev. 10 INSTRUCTIONS, PROCEDURES Date 02/01/94 (
AND DRAWINGS 2 of 3 procedures. Also included are maintenance and repair procedures for subcontracted maintenance and repair activities which are outside the normal scope of plant craft capability. Temporary procedures may be issued during testing, refueling, maintenance, modifications, unusual situations not within the scope of normal procedures, and for short periods when the plant, system or component is performing in a manner not covered by existing detailed procedures or has been modified in such a manner that portions of existing procedures do not apply.
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 the Plant General 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 or Quality Control audit or 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.
5.2.3 Drawings The design organization is responsible for review and approval of drawings. For delegated design activities, the Nuclear Engineering and Licensing 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.
C TOPICAL QUALITYASSURANCE REPORT TQR 5.0 Rev. 10 INSTRUCTIONS, PROCEDURES Date 02/01/94 AND DRAWINGS 3 of 3 5.2.4 Acceptance Criteria I
Quality Instructions shall require that instructions, procedures, and drawings affecting quality include adequate quantitative and qualitative acceptance criteria, as appropriate, for
.w XXA/
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.
5.3 RE P N, IBILTTIE 5.3.1 Ar.
Each direct report to the President-Nuclear Division and Department Heads of organizations supporting the Nuclear. Division is responsible for:
- a. Establishment of a documentedi'system for the preparation, review, approval and revision of procedures. This system shall comply with regulatory requirements, the applicable Pdant Technical Speciftcarions and Topical Quality Requirements.
5.3.2 (0)
The Vic'e President Nuclear Assurance is responsible for:
- a. Review and concurrence of procedures affecting quality in accordance with paragraph 5.2.
0 st 0
'I e
TOPICAL QUALITYASSURANCE REPORT TQR 6.0 Rev. 9 DOCUMENT CONTROL Date 02/01/94 1 of 3
- 6. 1 E ER L RE IREMENT The distribution of documents such as instructions, procedures, drawings, and software which provide guidance, specifications, or requirements~affecting the quality of nuclear Xg f]
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 thatperformed'the original review and approval unless otherwise specified in the<implementinggprocedures. In addition, procedures shall preclude the possibility of use of outdated documents.
6.2 MPLEME TATI 6.2.1 Quality Instructions shall delinea'te t e control measures that provide for:
- 1. Identification of individuals or organizations responsible for preparing, reviewing, approving, and issuing documents and revisions thereto;
- 2. Identifying the proper documents to be used in performing the activity;
- 3. Coordination and control of interface documents;
- 4. Ascertaining that proper documents are being used;
- 5. Establishing current and updated distribution lists.
These control measures shall apply to documents affecting the quality of nuclear safety-related structures, systems, and components such as:
aa design specifications; design, manufacturing, construction, and installation drawings; C. quality program manuals, procedures, and instructions;
- d. inspection, manufacturing, and test procedures and instructions;
TOPICAL QUALITYASSURANCE REPORT TQR 6.0 Rev. 9 DOCUMENT CONTROL Date 02/01/94 (
2 of 3
- e. plant operating and maintenance procedures;
- f. plant Safety Analysis Reports and related design criteria documents.
The requirements for control of procurement documents are contained in TQR 4.0 Drawing Control.
6.2.2 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 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 FPL during the operation phase shall be assigned to a drawing custodian. Revision shall be approved prior to release by the drawing custodian. Approval shall beto'rawings by Nuclear Engineering, or a designated design organization.
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.
6.2.3 Design Documents Other Than Drawings Ascertaining that proper design documents are accessible and are being used shall be accomplished by periodic issuance of master document lists showing the latest applicable revision, or by a document receipting system.
TOPICAL QUALITYASSURANCE REPORT TQR 6.0 Rev. 9 DOCUMENT CONTROL Date 02/01/94 3 of 3 6.3 E P N IBILITIE 6.3.1 Direct reports to the President, Nuclear Division, and Department Heads of organizations supporting the Nuclear Division shall be responsible for:
- a. the development, maintenance and control of those documents identified in Section 6.2 issued by them as controlled documents;
- b. the adequacy of their instructions,~including the instructions for control of the documents and changes thereto,to preclude the possibility of use of outdated or inappropriate documents.
6.3,2 Each recipient of a controlled document is responsible for ensuring that the appropriate latest revision is being used.
6.3.3
,Q& Licensing, The Vice Presiderit','Nuclear Engineering is responsible for assuring that the rrq Architect-Engineer,'Nuclear Sieam. Supply System vendor, and other contractors, as a minimum: ~@~i
- a. provide for the development, control and distribution of drawings, specifications and procedures; and the development and periodic distribution of a master drawing list for each project;
- b. provide for all revisions required as a result of FPL comments, nonconformances, or engineering work are incorporated into revised documents.
6.3.3 The Site Vice President is responsible for establishing a document distribution and control system to assure that the latest appropriate revisions of documents are used for construction and installation at each project site.
TOPICAL QUALITYASSURANCE REPORT TQR 7.0 Rev. 7 CONTROL OF PURCHASED Date 02/01/94 ITEMS 4 SERVICES 1 of 3 7el E ERAL RE IREMENT Measures shall be established to assure that items or services. purchased by or for FPL conform to the requirements of the procurement document.>These measures shall include
- m. <~J documented evidence of source selection, verificationvactivitiestand examination of items or services to assure compliance with the procurement document. The effectiveness of the V/
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 MPLEMENTATI N 7.2.1 Evaluation of Suppliers Procurement source~evaluation and:selecrion measures shall be specified in 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 based upon the item or service being procured.
This evaluation. is to ensure that the FPL contractors comply with the applicable portions ff of 10 CFR50, 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.
7.2.2 Verification Activities Quality,instructions shall define the requiremems 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
TOPICAL QUALITYASSURANCE REPORT TQR 7.0 Rev. 7 CONTROL OF PURCHASED Date 02/01/94 (
ITEMS A SERVICES 2 of 3 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 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. Receipt inspections shall be planned. The receipt inspection plans shall identify the characteristics to be verified and the documentation to be reviewed at receipt inspection. Receiving inspection shall include, as appropriate:
Measures for verifying that the shipment is complete, properly identified, a.'.
undamaged, and corresponds with the purchase order documentation; 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; Measures verifying completion of Commercial Grade Item dedication requirements.
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
TOPICAL QUALITYASSURANCE REPORT TQR 7.0 Rev. 7 a
CONTROL OF PURCHASED Date 02/01/94 ITEMS & SERVICES 3 of 3 v
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.".
7.3 E P N IBILITIE 7.3.1 Direct reports of the President, Nuclear Division, and Department Heads of organizations supporting the Nuclear Division are responsible for:~
- a. Determining the methods of acceptance for services requested by them; 2)
- b. The performance of the acceptance, methods selected, when assigned to them.
7.3.2 "
The Vice President Nuclear>>'Engineering and Licensing is responsible for:
a.
(Q)
Requesting that Nuclear Assurance perform a supplier evaluation; b.
ff Determining the methods of acceptance for items and services.
(Q>>
7.3.3 The Vice President Nuclear Assurance is responsible for:
- a. Assuring that evaluations of suppliers are performed and the results documented in accordance with approved Quality Instructions;
- b. Determining the methods of source verification;
- c. Performing receipt inspections in accordance with approved Quality Instructions; 7.3.4 The Site Vice President is responsible for:
av Requesting that Nuclear Assurance perform a supplier evaluation;
- b. Examining items for shipping damage upon receipt; C. Performing receipt inspection in accordance with approved Quality Instructions.
TOPICAL QUALITYASSURANCE REPORT TQR 8.0 Rev. 3 IDENTIFICATIONAND CONTROL OF Date 02/01/94 MATERIALS, PARTS AND COMPONENTS 1 of 3 S.l E RAL RE IREMENT 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 itemhshall be maintained by heat Azz number, pm number, sen~ number, FPL M8 S 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 non-inspected, incorrect or defective materials, parts, and components. (The FPL Material and Supplies M8cS number is a number given to each unique type of item in inventory to distinguish it from each other type of item in inventory).
Se2 MPLEMENTATI N+
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 organizaiions shall assure that identification and control is maintained throughout fabrication, receipt, handling, storage, installation and use of items. this shall include welding material traceabitity to the point of consumption.
Provisions include:
- a. Physical identification shall be used to the maximum extent possible. When physical identification is impractical or insufficient, items shall be physically segregated and identified by batch, lots, etc.;
- b. When items are subdivided, their identification shall be maintained by transferring the identification to each of the subdivided pans or their container, C. Post-installation identification of items that cannot feasibly be physically marked shall be traceable by record verification;
- d. Items requiring identification, but whose identification was lost during storage, shall be'egregated and documented as nonconforming and dispositioned in accordance with established procedures;
TOPICAL QUALITYASSURANCE REPORT TQR 8.0 Rev. 3 IDENTIFICATIONAND CON TROI. OF Date 02/01/94. (
MATERIALS, PARTS AND COMPONENTS 2 of 3
- e. Requirements for traceability to appropriate documentation, such as: procurement documents, manufacturing documents, drawings, specifications, inspection and test records, nonconformance or deficiency reports or other Quality Assurance Records, in sufficient detail to preclude any possibility of doubt or confusion concerning the traceability of an item to the documentation, or the documentation of the item;
- f. Controls to assure that the correct identification of an item is verified and documented prior to fabrication, receipt, handling, storage, installation and use;
- g. Requirements which assure that the method or location of markings are not detrimental to, and do not affect the function or quality of an item; are clear, unambiguous and indelible; are in plain unobstructed view; do not provide conflicts with other requirements; are not obliterated by any surface treatment unless other means of identification are substituted; withstand normal shipping, handling and environmental effects and are able to be retained;
- h. Establishment of identification requirements by specifications, drawings, procurement documents, instructions or procedures during initial planning; Requirements to ensure that dedicated Commercial Grade Items are identifiable to the specific component or equipment for which they are dedicated.
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.
8.3 RE P N IBTLTTIE, 8.3.1 The Site Vice President has overall responsibility for:
- a. Assuring that an identification and control system is developed and implemented for items to be utilized within the plant;
TOPICAL QUALITYASSURANCE REPORT TQR 8.0 Rev. 3 IDENTIFICATIONAND CONTROL OF Date 02/01/94 MATERIALS, PARTS AND COMPONENTS 3 of 3
- b. Receiving, controlling and ensuring the security of items;
- c. Segregating items until the required receipt inspection is performed;
- d. Assuring the placement of any necessary markings on+the items as required by applicable procedures or as requested in accordance with applicable purchase orders, specifications or commercial grade dedication packages; and
- e. Incorporating applicable pre-installation and/or post-installation inspections, tests, and QC hold points (including Commercial Grade Item Dedication requirements) ssays" into applicable work control documents.
8.3.2 The Vice President Engineering and Licensing has ov'erall responsibility for:
- a. Determining and specifying end',use appii'cations for items.
II 4
TOPICAL UAHHYASSUIUWCE REPORT TQR 9.0 Rev. 11 CONTROL OF SPECIAL PROCESSES Date 9 30 94 Pa e 1 of 5 9.1 GENERAL RE UIREMENTS, Measures shall be established to assure that special processes such as welding, heat treating, and nondestructive examination items, are controlled and accomplished by XE~ Y qualified personnel using q'ualified procedures and equipment in accordance with applicable codes, standards, specifications,"criteria, and other special requirements.
92 IMPLEMENTATION Special process requirements shall be"included in'esign outputs and changes thereto. Special process procedures shall be developed, reviewed, approved and controiied, and speciai'process personnel and equipment shall be quali6ed.
9.2.1 IdentiQcation of Special Processes Special processes are those processes which must be qualiQed and controlled where
+~j quality-is highly dependent on close control of process variables or operator skills, and objective verification (inspection, examination or testing) of end quality is difBcult.
Special processes identiQed by applicable codes and standards shall be controlled, qualiQed, 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, (e.g., flushing, protective coating, plating applications and nuclear cleaning) should be reviewed to determine if they are special processes.
1 0
1
VOPmu. UALm. ASSmVerCE REPORT TQR 9.0 Rev. 11 COXIOL OF SPECIAL PROCESSES Date 9 30 94 Pa e 2 of 5 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 Architect/Engineer, 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.
Special process procedures shall be:
- a. Sufficiently detailed fox a qualified person to perform the technique and achieve the desired results;
- b. Reviewed and approved prior to use to ensure the procedure complies with applicable codes, standards, and specifications, and that specified materials, equipment, and techniques are suitable for the intended application; C. Qualified prior to or during initial use.
Special process procedures and revisions thereto which specify acceptance criteria (other than thos'e identified in the ASME code) shall have the concurrence of the acceptance criteria by Nuclear Engineering prior to issuance and use.
TOPICAL UAL11T ASSURANCE REPORT TQR 9.0 Rev. 11 CONTROL OF SPECIAL PROCESSES Date 9 30 94 P e 3 of 5 9.2.3 Personnel Qualification and CertiQcation
~ ~
Procedures or instructions shall specify personn'el qualiQcation and certiQcation requirements. Personnel responsible for the performance and verification of.special processes shall be trained, tested, gV/ as and<certiQed required by applicable speciQcations, codes and standards. Requirements for the period of certification, retesting, and recertiGcation of personnel shall also be speciQed. Contractors shall
'Ch~"
qualify personnel and maintain records of"qualiGied personnel in accordance with applicable codes, standards(speciQcations, and contract or procurement document requirements.
9.2.4 Control of Equipmen~t Q
Equipment that;must be of a specific type, range, or accuracy to provide conformance fM; to speciGed requirements shall be controlled to ensure that it is qualiQed, maintained, and calibrated in accordance with those requirements.
9.2.5 Special Process Records Records shall provide objective evidence that special processes were performed in compliance with approved procedures by qualiGed personnel and equipment.
Records shall also be maintained for veriQcation activities when required by procedure, code or specification. Results of nondestructive examinations shall be recorded in accordance with applicable speciQcations, codes and standards. For contracted work, these records shall be retained by the vendor or supplied to FPL as required by contract or purchase order. If records are to be retained by the vendor, the contract or purchase order shall specify the retention period and instructions for Qnal disposition of such records.
TOPICAL VALHYASSURANCE REPORT TQR 9.0 Rev. 11 CONTROL OF SPECIAL 9 30 94 FPL PROCESSES Date Pa e 4 of 5 Nondestructive examination documents shall be reviewed for acceptance by an individual who is certiGed in the applicable method.
9.3 RESPONSIBILITIES 9.3.1 Direct reports of the President, Nuclear Division, and Department Heads of organizations supporting the*Nuclear Division involved in special process activities are responsible for:
Ensuring that special process procedures used by their department are reviewed, approved, controlled, and are qualiGed prior to or during initial use;
- b. Ensuring that special process personnel in their department are qualiGed and certiGed; C. Ensuring that records associated with special processes under their control are reviewed and maintained; 4
- d. Performing special process inspections, examinations; and activities, when assigned to their department, as required by applicable codes, standards, criteria, or other special requirements identiGed;
- e. Ensuring that work documents under their control contain adequate requirements for the identiGcation and control of special processes; Ensuring special process procedures and revisions which specify acceptance criteria (other than identified in the ASME code) have Nuclear Engineering concurrence of acceptance criteria prior to use;
- g. Ensuring nondestructive examination documents are reviewed by an individual certiGed in the applicable method.
Ensuring that welding activities requiring a qualiGed program are implemented in accordance with the welding program developed by Nuclear Engineering and Licensing.
TOPICAL UAIJITASSURANCE REPORT . TQR 9.0 Rev. 11 CONTROL OF SPECIAL PROCESSES Date 9 30 94 Pa e 5 of 5 9.3.2 The Vice President Nuclear Engineering and Licensing is responsible for:
- a. Determirung (as requested) if a speciQc activity~constitutes a special process;
- b. Identifying applicable codes,
<(r>.
standards; specifications, criteria, and other requirements related to special processes; Q~P
- c. Preparation, qualification, issuance, and control of Visual Test (VT) and
~
XX p Nondestructive Examination (NDE) procedures, instructions, and technique
. (6 sheets for all ASME Section XI examination activities; Direction, including>technical~direction to all personnel, of the welding
~ "x(~
d.
program to meet the>requirements of applicable codes and standards. This
~/
shall include the~development, program; maintenance, and control of a welding
- e. Review'and approval'of contractor welding programs.
9.3.3 The fgitefvice President is responsible for:
Welding activities performed at the site including issuance and control of weld documentation packages, welding material and equipment;
- b. Maintaining a current report of qualiGed welders and weld operators and assigning welder symbols;
- c. Ensuring that the Authorized Nuclear Inspector/Authorized Nuclear Inservice Inspector (ANI/ANII)is permitted access to all parts of the plant site or supplier facilities while work on an item or system is being performed that concerns the welding fabrication, modification, repair, or replacement of the item or system; including inspections, examinations, and tests.
Vn~, q TOPICAL QUALITYASSURANCE REPORT TQR 10.0 Rev. 11 INSPECTION Date 02/01/94 1 of 5 10.1 ENERAL RE IREMENT 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. Inspections shall be performed by~ndividuals 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. Ifdirect inspection of processed materials or products is impossible or disadvantageous, surveillance or monitoring shall r~xM h bejprovided. Mandatory inspection, indirect control witness, by or hold
'xM.d]
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 PLEMENTATI N 10.2.1 Inspection Program+ Qg
. (V3 For plant. operations, maintenance, or modification activities, a program for on-site inspecti~on of activities affecting quality shall be established. This program shall ensure the performance of 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 preoperational start-up and testing of plant modifications, Nuclear Division personnel may report functionally to the manager responsible for the start-up and testing 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.
TOPICAL QUALITYASSURANCE REPORT TQR 10.0 Rev. 11 INSPECTION Date 02/01/94 (
2 of 5 Protection Ec Control Systems personnel may perform inspections of equipment within their purview during operations. Inspections shall be performed in accordance with approved, written procedures by qualified personnel.
Quality Instructions shall be written which delineate therequirements and responsibilides 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. The frequency and timing of inspections shall be scheduled according to the activities being conducted and to assure that sufficient time and resources are available, and inspections are not inadvertently omitted or bypassed.
Inspection planning should include a review for the acceptability of sampling. Ifsampling is permitted, the sampling procedure shall be based on nationally recognized standard practices.
10.2.3 Inspection Personnel Inspections shall be performed by individuals other than those who performed or directly supervised the activity being inspected. Inspection personnel shall have current qualifications and certifications in accordance with appropriate codes, standards and/J'or company training programs. These qualificatiotis and certifications shall be documented.
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 QUALITYASSURANCE REPORT TQR 10.0 Rev. 11 INSPECTION Date 02/01/94
@PL 3 of 5 10.2.4 . Inspection Procedures Required inspection, surveillance or monitoring activities shall be performed and documented according to written, approved instructions or. procedures.
- a. Inspection procedures, instructions or checklists:shall contain the following:
gV/
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;
)J o A description of the~ethod'.of.inspec'tion;+g 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
A Test or inspection results; ]
o Stateme'nt of acceptability; O'ate 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 Nuclear Assurance personnel to determine the need for an independent inspection and the degree and method ifsuch 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.
TOPICAL QUALITYASSURANCE REPORT TQR 10.0 Rev. 11 INSPECTION Date 02/01/94 (
4 of 5 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 identified in process documents when witnessing and inspecting must be performed and signed-off by the responsible personnel before work can proceed.
FPL procurement documents shall indicate FPL witness or hold points applicable prior to a
during, or after the manufacture of an item or the performance of a service. A distinction shall be made between witness points and mandatory hold points.
10.3 RE. P N. TBTLTTTE, 10.3.1 Direct Reports of the President, Nuclear Division, and Department Heads of organizations supporting the Nuclear Division that perform inspection activities are responsible for;
- a. Implementation of a program for inspection activities;
- b. Ensuring that this program verifies compliance with applicable portions of Technical Specifications, SAR requirements, procurement documents, other operating license requirements and the QA Manual; C. Ensuring coordination with QC for incorporation of QC inspection and hold points into procedures and work documents;
- d. Ensuring that inspections are not inadvertently omitted or bypassed;
- e. Ensuring that personnel assigned to perform inspections are appropriately qualified and certified; Ensuring inspection procedures are reviewed by Nuclear Assurance personnel to determine the need for an independent inspection and the degree and method if such an inspection is required, and to ensure the identification of inspection personnel and the method of documentation of ins ection results.
TOPICAL QUALITYASSURANCE REPORT TQR 10.0 Rev. 11 INSPECTION Date 02/01/94 5 of 5 10.3.2 The Vice President Nuclear Assurance is responsible for.
- a. Implementation of a program for inspection and surveillance activities;
- b. Ensuring that required QC inspections are incorporated into inspection/test/
maintenance procedures, design change documents, and work process control documents; C. Ensuring that inspections and surveillances are correctly performed and documented;
- d. Reviewing inspection procedures to<determine the need for an independent inspection and.the degree and method if such an inspection is required, and to V,. JJ ensure the identification of inspection persorinel=and the method of documentation of inspection results.
ft
. TOPICAL QUALITYASSURANCE REPORT TQR 11.0 Rev. 4 TEST CONTROL Date 02/01/94
@PL 1 of 4 11.1 E ERAL RE IREMENTS 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, operational tests, and retest following repairs, replacements or modifications.
1 1. 2 MPLEMENTATI 11.2.1 Test Program Testing requirements shall be identified inithe engineering/design documents, SAR documents, procedures, or procurement documents, as appropriate. Retest following repairs, replacements,- or,modifica'tions'shall be performed in accordance with the original ff design and test requirements or accepiable alternatives. Retest shall be performed when A schedule shall
~ ~~/
the original test results are invalidated.
provide assurance'that be provided and maintained to all tests are performed and properly evaluated on a timely basis.
Quality Instructions shall be written which delineate the methods and responsibilities for scheduling, 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.
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
1>>
0
TOPICAL QUALITYASSURANCE REPORT TQR 11.0 Rev. 4 TEST CONTROL Dare 02/01/94 (
2 of 4 and procurement documents. Test procedures shall be revised as necessary to assure that tests are performed in accordance with the latest approved information. The test procedure or test program documents shall include or reference the following as a minimum:
(
ae Instructions for the testing method used (including precautions, limitations, and restoration of normal conditions upon test completion);
- 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, qualified, and licensed or certified personnel; preparation, condition and completeness of item to be tested; suitable and controlled environmental conditions; defined system interfaces; initial plant conditions; Methods for documenting or recording test data and results; (
- g. Test records shall identify:
- 1) Identification of personnel performing the testing activities;
- 2) Method or type of observations;
- 3) Test or inspection results (to include pertinent test data);
- 4) Specific measuring and test equipment utilized for testing;
- 5) As found and as left condition (as applicable);
- 6) Statement of acceptability;
- 7) Date of observation; and
- 8) Deficiencies and nonconformances, and the action taken in connection with these deficient conditions, either by inclusion or by reference to other documents.
TOPICAL QUALITYASSURANCE REPORT TQR 11.0 Rev. 4 TE<ST CONTROL Date 02/01/94 3 of 4 11.2.3 Evaluation of Test Results The documented test results shall be evaluated against the predetermined acceptance criteria by a group or individual'aving appropriate qualifications. The acceptance status of the test shall be documented. Deficiencies noted'during the evaluation shall be documented and dispositioned in accordance with TQR 15.0 and approved 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.
11.3 RE P N IBILITIE 11.3.1 (P~
The Site Vice President is responsible. for:
- a. Assuring-that plant tests are identified, scheduled, controlled, performed and documented;
- b. Assuring that plant test procedures are reviewed and approved.
11.3.2 The Vice President Nuclear Assurance is responsible for:
- a. Assuring that test procedures specify necessary quality requirements such as witness and hold points, and adequate data sheets.
11.3.3 The Director Protection 8c Control Systems is responsible for:
ao Assuring the identification, scheduling, control, performance, and documentation of tests performed by Protection 8c Control Systems;
- b. Submitting test procedures to the Plant General Manager for review; C. Coordinating test schedules with the Plant General Manager.
TOPICAL QUALITYASSURANCE REPORT TQR 11.0 Rev. 4 TEST CONTROL Date 02/01/94 (
of 4 11.3.4 The Vice President Nuclear Engineering and Licensing is responsible for:
- a. Specifying the need for pre-installation and post-installation testing of items within his purview; a
- b. Writing test procedures as requested; (
C. Evaluating test results as requested.-
~e
TOPICAL QUALITYASSURANCE REPORT TQR 12.0 Rev. 5 CONTROL OF MEASURING Date 02/01/94 AND TEST EQUIPMENT 1 of 4 12.1 ENERAL RE IREMENT 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 .A ~A department maintaining calibrated instruments to provide for the calibration and control of such instruments.
12.2 PLEMENTATI N 12.2.1 Calibration and Control of Measuring,and Test'Equipment
-.G) 4k Procedures shall be written to delineate-the methods and responsibilities for the control, maintenance, and calibration ofmeasuring and test equipment (M&TE)and installed plant instrumentation and control equipm'ent. M&TE"control procedures or calibration program documents shall contain the
.f(
followin'g:~
(<"~
a A complete<listing of M&TE and installed plant instrumentation and control equipment to be controlled;
- b. rThe frequency of calibration of listed M8'eTE and installed plant instrumentation and control equipment. The frequency may be based on calendar time or relate to usage and shall be based on such factors as licensing commitments, regulatory requirements, experience, inherent stability, manufacturer's recommendations, purpose of use, frequency of service, or company standards. A schedule for calibration shall be established and shall'indicate as a minimum the instrument, calibration frequency, and procedure to be used or the identification of the approved supplier qualified to provide calibration services;
- c. A method for controlling issue and recall of portable M&TE;
- d. A method to uniquely identify controlled M&TE (e.g., labeling), required calibration frequency and calibration test data applicable to the M&TE and installed plant instrumentation and control equipment;
- e. A method to document and maintain the status of MATE and installed plant instrumentation and control equipment.
TOPICAL QUALITYASSURANCE REPORT TQR 12.0 Rev. 5 CONTROL OF MEASURING AND TEST EQUIPMENT Date 02/01/94
(
2 of 4 MEcTE shall be calibrated in environments which will not adversely affect their accuracy.
When inaccuracy due to environmental effects cannot be avoided, compensating cotrections shall be determined and applied in accordance with the manufacturer technical instructions.
MEcTE and reference standards shall be suitably marked so that the calibration status can be determined.
FPL may delegate the control and/or calibration of M8cTE 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 MATE, reference standards, and listed installed plant instrumentation and control equipment shall be calibrated in accordance with written approved procedures.
Calibration procedures shall contain, or reference as a minimum:
- a. Identity of MEcTE or equipment to which the procedure applies;
- b. Calibration equipment and reference standards to be used; C. Acceptance criteria;
- d. Sequence of operations;
- e. Special instructions (such as, prerequisites, power level requirements, precautions, limitations) as applicable; Documentation and data collection requirements;
- g. A requirement that equipment to be calibrated, be checked and results recorded before adjustments or repairs are made;
- h. Calibration frequency required.
TOPICAL QUALITYASSURANCE REPORT TQR 12.0 Rev. 5 CONTROL OF MEASURING Date 02/01/94 AND TEST EQUIPMENT 3 of 4 12.2.3 Calibration Standards MATE shall be calibrated using reference standards whose calibration has a known, documented, valid relationship to nationally recognized standards 'M or accepted values of natural physical constants. Ifno 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'V of the equipment being
'alibrated.
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, AA-.'<
working standards shall have an~ac'curacy that. assures that the M&TE being calibrated will Xr be within required accuracyntoleran'ces~and that. the basis of acceptance is documented and authorized by designated responsible management.
The meaning of this paragraph may be diagrammed as follows:
~NATIONALINSTITUTE OF STANDARDS AND TECHNOLOGY (NIST)
"greater than" tolerance PRIMARY STANDARD (ifapplicable)
"greater than" tolerance SECONDARY STANDARD (if applicable)
"greater than" tolerance WORKING STANDARD "1:4 ratio" tolerance (except as noted above)
M&TE (installed instruments and measuring and test equipment used for 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.
0 TOPICAL" QUALITYASSURANCE REPORT TQR 12.0 Rev. 5 CONTROL OF MEASURING Date 02/0 I/94 AND TEST EQUIPMENT 4 of 4 12.2.4 "Out of Tolerance" Control and Corrective Action The reporting, follow-up, and correction'of conditions adverse to quality found
. during calibration or calibration checks shall be documented. M8:TE and reference ~
standards, when found out of tolerance, shall be so identified and removed from service, tagged to indicate its status and segregated from MEcTE in service, pending disposition of corrective action. A documented investigation shall be conducted to determine the validity of previous inspection or test results gained through use of the instrument, and of the acceptability of items previously inspected or tested.
12e3 RE, P N IBILITIE 12.3.1 Direct reports of the President, Nuclear Division, and Department Heads of organizations supporting the Nuclear Division shall be responsibile for:
ae Assuring that the affected plant departments establish and maintain a calibration control program;
- b. Assuring that written procedures governing calibration activities are reviewed and approved prior to use; C. Assuring that documentation of calibration activities are reviewed and approved.
12.3.2 The Director Protection & Control Systems is responsible for assuring that calibration control procedures for installed plant instrumentation and control equipment under his control are submitted to the Plant General Manager for review, and for coordination of calibration activity schedules with plant supervisors.
TOPICAL QUALITYASSURANCE REPORT TQR 13.0 Rev. 8 HANDLING, STORAGE, SHIPPING CLEANNESS CONTROL, Date 02/01/94 AND HOUSEKEEPING 1 of 3 13.1 ENERAL RE IREMENT 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 deyading an item through damage or deterioration. When necessary fonpamcular products, speciai
((z protective environments such as inert gas atmosphere, specific moisture content'evels, and temperature levels shall be specified and provided~
Housekeeping procedures and instructions shall require cleanness to be maintained at a level consistent with the work per'formed to prevent the entry of foreign material into
)J safety related systems. Control of~personnel tools, equipment and supplies shall be established with approved procedures or~instructions when the safety function of a system, component or item may be-jeopardized and also while the reactor system is fp ~x .~
opened for inspection, maintenance~or repair. Documented cleanness inspections shall be performed prior to.system closure.
P ~
13e2 IMPLEMEN TATI 13.2.1 General Instructions or procedures shall be written to define the requirements and responsibilities for the housekeeping, 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 cleaning, housekeeping, handling, storage and shipping of material and equipment, but shall retain ultimate responsibility. Where any of the functions in the sections which follow is delegated to a contractor, the contractor shall be required to adhere to the FPL requirements stated herein.
TOPICAL QUALITYASSURANCE REPORT TQR 13.0 Rev. 8 HANDLING, STORAGE, SHIPPING CLEANNESS CONTROL, AND HOUSEKEEPING Date 02/01/94 (
2 of 3 13.2.2 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 willpreclude damage, loss, or deterioration by environmental conditions, such as temperature or humidity.
S ite specific procedures or specific work instructions shall be developed which provide guidelines in handling heavy loads that are lifted over, or in proximity to, irradiated fuel or safe shutdown equipment/systems.
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.
13.2.3 Cleanness Procedures Procedures or work instructions for cleaning; cleanness control practices and inspections; examinations or tests to verify cleanness of items; shall be prepared and implemented.
13.2.4 Housekeeping Procedures Methods and techniques for controlling and maintaining housekeeping and documenting housekeeping surveillances and inspections shall be delineated in procedures or instructions.
t TOPICAL QUALITYASSURANCE REPORT TQR 13.0 Rev. 8 HANDLING, STORAGE, SHIPPING CLEANiNESS CONTROL, Date 02/01/94
@PL AND HOUSEKEEPING 3 of 3 X3.3 RE P N IBTLITIE 13.3.1 The Site Vice President has overall responsibility for ensuring that handling, storage, shipping, cleanness and housekeeping requirements are identified, and implemented.
13.3.2 The Vice President Engineering and Licensing is responsible for:
- a. Identifying special handling and storage requirements for site fabricated items in applicable design output documents/work instructions;
- b. Identifying cleaning and cleanness A..
verification methods in appropriate
~,,4j specifications, drawings or procedures.
13.3.3 The Vice President Nuclear Assurance is responsible for:
a.
iQ)
Verifying-proper, handling,.storage, and shipping activities at supplier facilities; b.
i(.
Verification of housekeeping,;handling, storage, shipping and cleanness of items through inspections, surveillances, examinations or tests at the plant site.
TOPICAL QVALIYYASSURANCE REPORT TQR 14.0
.Rev. 10 INSPECTION, TEST AND Date 02/Ol/94 OPERATING STATUS 1 of 2 14.1 E ERAL RE IREME T 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.
14.2 MPLEMENTATI N 14.2.1 General A suitable system for identifying the inspection, test, and operating status of materials, equipment, systems, and.components shall be established. Each system established shall be implemented-and.maintained in,'accordance with written Quality Instructions. The Architect/En'gi~neer or Contractors shall develop and implement procedures to comply with contractual responsibilities, and applicable codes, standards, specifications, and criteria A
governing ihe 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, labeling or other appropriate methods. Methods to verify adequacy of the controls shall be established and implemented, as appropriate.
TOPICAL QUALITYASSURANCE REPORT TQR 14.0 Rev. 10 INSPECTION, TEST AND Date 02/01/94 OPERATING STATUS (
2 of 2 14.2.2 Status Identification and Control Quality Instructions shall describe control of the application and removal of markings such j
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. These procedures shall require independent verifications, where appropriate, to ensure that necessary measures have been implemented.
14a3 E P N IBILITIE 14.3.1 Ditect reports of the President, Nuclear Division, and Department Heads of organizations supporting the Nuclear Division shall be responsible for coordinating activities affecting the inspection, test and operating status of material, equipment, systems and components with the appropriate plant organization.
14.3.2 The Site Vice President is responsible for the establishment, maintenance, and implementation of a suitable system for identifying, inspecting, testing, and providing operating status of material, equipment, systems and components in accordance with written and approved procedures and instructions and the approval of other programs utilized on site which provide for inspection, test and operating status.
14.3.3 The Vice President Nuclear Assurance is responsible for assuring that requirements are implemented per written instructions and procedures.
\
TOPICAL QUALITYASSURANCE REPORT TQR 15.0 Rev. 10 NONCONFORMING MATERIALS, Date 02/01/94 PARTS OR COMPONENTS 1 of 5 15.1 E ERAL RE IREMENT 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,
~.WXdj 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 =
PLEME TATI N 15.2,1 Program Quality Instructions shall~defineithe-responsibilities and methods for identifying, documenting, segregating and.dispositioning nonconforming items. Throughout plant
~p life, FPL may delegate. any portion of the identification and control of nonconforming items and services to,an Architect/En'gineer (A/E), constructor, NSSS vendor or other
/~~~/
contractor. In any> case, FPL retains the responsibility for assuring that requirements am met, and,shall'assure that the contractor's actions conform to requirements set by FPL.
Vi 15.2.2 'Documenting and Controlling Nonconformances Allnonconformances shall be documented and reported for corrective action. Measures shall be delineated in Quality 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.
Where physical segregation is not practical, suitable tags, marking or documentation shall be used to assure control.
k TOPICAL QUALITYASSURANCE REPORT TQR 15.0 Rev. 10
~ FPL NONCONFORMING MATERIALS, PARTS OR COMPONENTS Date 2 of 02/01/94 5
(
The control of, and the documentation generated by the identification, disposition, correction, and verification of nonconformances may be transferred between processing methods. Adequate controls shall be established to assure traceability between processing methods and the identified nonconforming item and to prevent inadvertent cancellation of the corrective action implementing document.
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.
15.2a4 Evaluation and Disposition Nuclear Engineering, or other delegated organizations, as specified by procedure, shall evaluate nonconformances and disposition them based on the results of the evaluations.
Nonconforming conditions which cannot be made acceptable utilizing existing design documents shall be evaluated by Nuclear Engineering for disposition. 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. 10 NONCONFORMING MATERIALS, Date 02/01/94 APL PARTS OR COMPONENTS 3 of 5 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 records and forwarded with the material to FPL.
The determination of the need and the advisability of'releasing nonconforming materials or
>l items, shall be initiated by the Site Vice Presidentand approved by Nuclear Engineering.
A The following factors may be appropriate considerations in making this determination:
- 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 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;
- 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.
Nonconformance reports shall be periodically. reviewed to identify quality trends. The results of these analyses shall be reviewed with appropriate members of upper level management.
hV)
TOPICAL QUALITYASSURANCE REPORT TQR 15.0 Rev. 10 NONCONFORMING MATERIALS, Date 02/01/94 PARTS OR COMPONENTS 4 of 5 15.3 E P NSIBILITIE, 15.3.1 Diect reports of the President, Nuclear Division, and Department Heads of organizations supporting the Nuclear Division are responsible for:
- a. the generation of instructions/procedures to implement requirements for the identification, control, disposition, and verification of nonconformances within their purview;
- b. identifying and documenting nonconforming items within the scope of their departmental responsibilities; C. submitting nonconformances requiring design evaluations to the appropriate engineering organizations;
- d. tracking and control of open nonconforming items within the scope of their departmental responsibilities;
- e. dispositioning and verifying the resolution of nonconforming items within the scrape of their departmental responsibilities; periodically assessing quality trends related to nonconformances.
15.3a2 The Site Vice President is responsible for:
- a. supplier notification and follow-up of nonconformances requiring supplier corrective actions.
15.3.3 The Vice President Nuclear Assurance is responsible for:
- a. periodically assessing quality trends related to nonconformances and reviewing the results of these assessments with appropriate members of upper level management.
TOPICAL QUALITYASSURANCE REPORT TQR 15.0 Rev. 10 NONCONFORMING MATERIALS, Date 02/01/94 PARTS OR COMPONENTS 5 of 5 15.3.4 The Vice President Nuclear Engineering and Licensing is responsible for:
ao the review, evaluation, and disposition of nonconformances submitted by other departments;
- b. approval of release of nonconforming items; C. supplier notification and follow-up of nonconformances requiring supplier corrective actions.
TOPICAL QUALITYASSURANCE REPORT TQR 16.0 Rev. 8, CORRECTIVE ACTION Date 02/01/94 1 of 4 16.1 E ERAL RE IREMENT, 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 praciicable. In the
=
case of significant conditions adverse to quality, th~cause~l of the condition shall be determined and action taken to preclude repedtion>The identification of significant conditions adverse to quality, the cause of the condition, arid the corrective action taken be documented and reported to appropriate levels'of management.
V'hall t6.2 ~MPLRMEN 16.2.1 Corrective Action and Follow:U~p Quality Instructions shall, define responsibili'ties and methods for identifying and
)>
correcting conditions, adverse to quali~ty. 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.
- a. 1'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 to appropriate levels of management, requiring that work be stopped, the plant be shut down or other appropriate actions be taken.
Specific personnel having stop work authority include the Plant General Manager, Site Quality Manager and Plant Vice President.
TOPICAL QUALITYASSURANCE REPORT TQR 16.0 Rev. 8 CORRECTIVE ACTION Date 02/01/94 (
2 of 4
- 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 'nspection reports, surveillance reports, nonconformance reports, and audit reports; and the investigation analysis and action associated with reportable events.
Interdepartmental corrective action shall be requested by use of written correspondence.
Audit reports, nonconformance reports, interoffice letters, and other documents may be used for this purpose.
Follow-up to verify implementation of corrective action and close-out of corrective action documentation is accomplished by the organization responsible for verifying the corrective action. The Nuclear Assurance Department shall track, follow-up, and close-out open items identified by Nuclear Assurance Department. 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.
Ifcorrective 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.
0 TOPICAL QUALITYASSURANCE REPORT TQR 16.0 Rev. 8 CORRECTIVE ACTION Date 02/01/94 3 of 4 16.2.2 Recurrence Control It is the responsibility of the organization which identifies the significantcondition adverse to quality to verify that corrective action description not only corrects the immediate condition, but also precludes the condition/from recurring. The organization(s) that provide(s) the corrective actiondisposition 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 Events Reporting Operating reportable events and'reports of incidents shall be investigated, documented as A'2~
to cause and corrective action, and reported to the NRC in accordance with the applicable plant Technical Specifications and Fe'deral~Regulations. Reportable events and reports of
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incidents that are safety related orithat result in damage shall be forwarded to.the Company Nuclear. Review Board (CNRB) for review. Conditions adverse to quality are J
" reported to operating plant management through: distribution of QA audit reports, QC inspection reports, corrective action requests, and the investigation and reporting of reportable events in accordance with plant Technical Specifications.
~~I 16.3 E P N. IBILITIE, 16.3.1 The President Nuclear Division is the final authority in the event agreement relating to stop work requests or other proposed corrective action is not reached at lower management levels.
. TOPICAL QUALITYASSURANCE REPORT TQR 16.0 Rev. 8 CORRECTIVE ACTION owe 4 of 4 16.3.2 Direct reports of the President Nuclear Division and Department Heads of organizations supporting the Nuclear Division are responsible for:
ao Assuring that timely corrective action within their respective organization;
- b. Follow-up and assuring completion of corrective action resulting from their respective department's audits, inspections, surveillances, tests, or operations; C. Reviewing and investigating audit findings to determine and.schedule appropriate corrective action and responding as requested in the audit report.
16.3.3 The Vice President Nuclear Assurance has the responsibility and authority to recommend that work be stopped or appropriate corrective action taken as a result of QA findings P
during department audits and reviews or QC activities.
16.3.4 Allpersonnel detecting conditions adverse to quality or significant conditions adverse to quality are responsible for reporting such conditions to the appropriate authority.
~ \
TOPICAL QUALITYASSURANCE REPORT TQR 17.0 Rev. 3 QUALITY ASSURANCE RECORDS Date 02/01/94 1 of 4 17.1 E ERAL RE IRE<MENT Sufficient records shall be maintained to furnish documented evidence of the quality of safety related structures, systems, and components, and ofiactivities affecting their quality. The records shall include, as appropriate~zdataxsuch 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
)3 assurance records, shall be identifiable and-retrievable. These records shall be maintained in facilities that provide a suitable'tenvironment to minimize deterioration or damage and to prevent, loss.
The requirements"and responsibilities, for quality assurance record control, transmittal,
(~
f~est retention, and~maintenance"..shallibe established and documented. These record
~ Q~ vs')
requirements shall be consistent with applicable design, manufacturing, and installation codes'and standards, and with procuremettt document requirements.
17e2 IMPLEMENTATI N 17.2.1 Records Identification Quality Instructions 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.
e TOPICAL QUALITYASSURANCE REPORT TQR 17.0 Rev. 3 QUALITY ASSURANCE RECORDS Date 02/01/94 2 of 4 Quality assurance records shall be classified as lifetime or non-permanent as required by the NRC facility operating license, the NRC construction permit, applicable parts of 10CFR, the FSAR, or other NRC commitments.
17.2.2 Retrieval Quality assurance records submitted for retention shall be leg'ble, completely filled out, and adequately identifiable and retrievable fop each item. The records shall be filed in a storage area or facility using a documented system to provide retrievability. Quality Instructions shall 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.
17.2.3 Storage Construction features and location requirements for record storage facilities shall be established to 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 shall be given for special processed records and for temporary storage facilities.
A QA Record Storage Evaluation Team (QARSET) shall be established to determine if the methods utilized to store and protect QA records are adequate. The QARSET shall consist of the following: the Quality Manager - Juno Beach, the Loss Prevention Engineer, and the Nuclear Records Official: The QARSET shall maintain records of evaluations and establish schedules to assure that reevaluations are performed every two (2) years. 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. The requirements of the Topical Quality Assurance Report, Appendix C shall be utilized in the evaluation of potential permanent and temporary record storage facilities.
0 TOPICAL QUALITYASSURANCE REPORT TQR Rev.,3 17.0'UALITY ASSURANCE RECORDS Date 02/Ol/94 30f4 17;3 RE. P N, IBILITIES 17.3.1 Direct reports of the President, Nuclear Division, and Department Heads of organizations supporting the Nuclear Division that generate quality assurance records are responsible for:
- a. 'he technical content and accuracy of the records they generate;
- b. transmitting records to the appropriate storage facility or requesting approved storage locations from QARSET,;
- c. establishing a list of quality assurance records generated by the organization and Jg their retention times and assuring that"these quality assurance records are identified in the appropriate'quality 4 assurance record index; vg
- d. the storage and retrieval'o~f quality~assurance records prior to transmittal to permanent record storage facilities; >
- e. performing",,periodic surveys "to ensure that their record control system is adequate; ~>
17.3.2 The,Nuclear'Records Official is respousibTe for:
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- a. ensuring the quality assurance records program activities are managed in accordance with applicable laws and regulations;
- b. developing, approving, and maintaining record retention schedules;
- c. establishing parameters for records indexing;
- d. locating acceptable record storage areas when requested;
- e. storage, retrieval, and control of records/documents as requested by other departments;
- f. leading the evaluation of specially designated QARSET approved storage facilities, maintaining records of this evaluation, and establishing schedules to assure that re-evaluations are performed every two (2) years.
'I TOPICAL QUALITYASSURANCE REPORT TQR 17.0 Rev.'
~
QUALITY ASSURANCE RECORDS Date 02/Ol/94 4 of 4 17.3.3 The Site Vice President is responsible for:
- a. the storage and retrieval of quality assurance records at the site.
17.3.4 The Manager Administrative Services is responsible for:
- a. storage, retrieval, and control of records and documents as requested by other departments.
17.3.5 The Quality Assurance Record Storage Evaluation Team (QARSET) is responsible for:
- a. evaluating the acceptability of storage locations for quality assurance records;
- b. ensuring that evaluations of storage locations are performed every two years.
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TOPICAL QUALITYASSURANCE REPORT TQR 18.0 Rev. 8 AUDITS Date 02/01/94 1 of 5 18.1 E ERAL RE TREMENT, 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,pe'rformed in accordance with the g~,//
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 inthe area audited. Follow-up action, including reau'dit of deficient areas, shall be taken~where necessary.
18.2 MPLEME TATI N Q A comprehensive program. of audits is cerned 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 Instructions shall 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 qualitied to carry out these activities. Quality instructions 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'nstructions provide requirements for written audit plans and schedules. The audits are planned and scheduled on the basis of the following:
TOPICAL QUALITYASSURANCE REPORT TQR 18.0 Rev. 8 AUDITS Date 02/01/94
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2 of 5
- 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. The system of audits devised to verify compliance with aspects of the nuclear plants is described in each unit's technical specifications. Audits of selected aspects of operational phase activities are performed with a frequency commensurate with safety significance. As a minimun, unless otherwise specified by technical specifications, the Code of Federal Regulations or other licensing commitments, these audits are performed at a biennial (2-year) frequency. The audit system is reviewed periodically and revised as necessary to assure coverage commensurate with current and planned activities; 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 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 aminimum:
- a. The determination of site features which affect plant safety (e.g., core sampling, site preparation, and meteorology);
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 in'spections; Operation, maintenance/repair and modification;
- g. The implementation of operating and test procedures;
0 TOPICAL QUALITYASSURANCE REPORT TQR 18.0 Rev. 8 AUDITS Date 02/01/94 3 of 5
- 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 shall require that FPLCsuppliers and contractors in turn perform audits on their sub-tier suppliers and contractors.
18.2.3 Conduct of Audits Quality Instructions shall dehn'cate~requirements for the conduct of audits. These instructions shall require. that:
a.
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Audits be conducted. by trained and qualified personnel; 4
- b. Personnel'conducting audits shall not have direct responsibility in the area audited; c.
f sr" Checklists or instructions shall be used to ensure depth and continuity of audits; d, Objective-evidence shall be examined for compliance with quality assurance program requirements. This shall include examination of instructions 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.
0 Ot't07.92
0 TOPICAL QUALITYASSURANCE REPORT TQR 18.0 Rev. 8 AUDITS Date 02/01/94 4 of 5 18.2.S 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 verified.
18.2.6 Reports to Management The Quality Assurance Department periodically reports on the status of the Quality Program to the members of the Company Nuclear Review Board (CNRB). 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.
I S.3 RESPONSIBILITIES 18.3.1 Ditcct reports to the President, Nuclear Division, and Department Heads of organizations supporting the nuclear division shall be responsible for:
- 1. Taking action to correct deficiencies identified in audit reports;
- 2. Providing a written response within thirty (30) calendar days of receipt the audit report.
18.3.2 The Vice President Nuclear Assurance is responsible for the following:
- a. Scheduling audits on a'regular basis;
- b. Selecting the audit team and the Lead Auditor;
TOPICAL QUALITYASSURANCE REPORT TQR 18.0 Rev. 8 AUDITS Date 02/01/94
'5 .of 5 Reviewing each audit report for accuracy, completeness, proper format and distribution;
- d. Designating a qualified replacement Lead Auditor (in writing) ifthe audit team leader transfers from the respective QA group or is otherwise unable to continue the assigned audit;
- e. The qualification of Lead Auditors.
18.3.3 The Chairman, Company Nuclear Review..Board (CNRB) is responsible for review and
/~
concurrence of Annual Audit Program Plans, review of individual audit scopes and involvement in the audit program for internal audits as defined by CNRB instructions.
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VICE PRESOENT TVRKEYFOIrl PIANTw MATERULS SITE ENQNEERNQ PIANT G ENEIVL WMANRESOURCES BUSPQSS SYSTEMS MANAQEMEN'I MANAGER MNIAGER MANAGERs MANAGER MANAGER SECURRY SUPERYISOR OUTAGE MANAGER MANAGER i, ~~MguGER ~
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~R ~ P CNEMQTRY SVPERYQOR ILECtl4C BIQNEERNG SVPERVSCR STSIEM PERFORMAICE INSTRNI ENT ANQ CCNTRCL SVPERV5OR MAN'TENANCE SVPERYISOR a Q~N STArPNSOA CM SVPCRVSOR x M ECNAN ICAL MAN TTNANCE SVPOlY6M NSSS ENGIIEDYNG SVPERYQOR ELECTRICAL SUPERVISOR MAPITENANCE SVPERYSOR 80P ENQNEERNG CCMPCNENT SPEC REACTOR ENGnzERNG SUPERYSOR x TOPICAL OUAUTY ASSURANCE REPORT REV.6 TURKEY POINT NUCLEAR 2IIls4 STE ORGAMZATION 4 - Indicates position with accountabifities in Technical Specifications. RGURE I 2 APPENDIX A PAGE 1 OF 1 O'ORDP
0 VICE IRESOENT ST.LUCIE RANT SERVICES HANACER ILIHANRESCASCES ff%rfrfETVI HANACER LNEI5trc HANACER HATDYALS IlANACEII TNT IIANACER O I I
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Start RV5CR SVStGI ENCNEER SIPERnSCR TOPICAL QUALITYASSURANCE REPORT REIL7 ST. LUCIE PLANT, UNITS 1 Er 2 SITE ORGANIZATION PIGVRE M APPENDIX A PAGE1OF1
>> - indcaTIS posiion with acccuntab%esin Techrlcat Speolca(ons.
Where nsrfipte it)as occor. the Erst position Isted shaf actin the Capaot)Tnt Lhe Other l5editteS,
0 TOPICAL QUALITY ASSURANCE REPORT APPENDIX 3 Rev. 3 QUALIFICATION AND EXPERIENCE REQUIREMENTS FOR FPL QUALITY Date 6/12/90 ASSURANCE PERSONNEL Page 1 of 1 Quality Managers (SB/PTN/PSL) Shall satisf'y 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.
The education and experience requirements should not be treated as absolute when similar training or an outstanding accord will provide reasonable assurance that a person can perform the required tasks.
TOPICAL UALl'IYASSURANCE REPORT APPENDIX C Rev. 12 BASELINE DOCUMENT MATRIX not 10 31 94 Pa e 1 ot 26 This topical report contains the program requirements for Florida Power Ec, Light Company's Quality Assurance Program. The Quality Assurance Program"is described in detail in the Florida Power 4, Light Company Quality Assurance Manual.~
The Regulatory Guides, codes, and standards speciTically listed in the matrix of this appendix (on page 2) represent the baseline XA documents used in the preparation of FPL's QA Manual and this topical report. These documents, therefore, provide the basis for the i~r ~
FPL QA Program, but they are not considered t+obe part of the QA Program unless
~
specifically addressed in the applicable SA'R, technical<specifications, etc.
The FPL Quality Assurance'Program meets the requirements of the documents referenced in this appendix. Any'alternatives orclarifications made to the requirements contained in these documents are'stated on pages subsequent to the second page of this appendix.
~U
TOPICAL UALITYASSURANCE REPORT APPENDIX C Rev. 12 BASELINE DOCUMENT MATRIX Date 10 31 94 Pa e 2 or 26 REFERENCE INDUSTRY DRAFI'EV.
GOVERNMENT DOCUMENT DATED STANDARD ISSUED DATE 10 CFR PART 50, APPENDIX B 2/19/75 ANSI-N45.2 1971 10 CFR PART 50.55a ASME BkPV Code Specified in the Section III 2, SAR document of XI the respective plant Regulatory Guide 1.8 Rev. 1 9/75 ANSI-N18.1 1971 ANSI/ANS 3.1 1978 Regulatory Guide 1.28 6/7/72 ANSI-N45.2 1971 Regulatory Guide 1.30 8/11/72 ANSI-N45.2.4 1972 Regulatory Guide 1.33 Rev. 2 2/78 ANSI-N18.7 1976 Regulatory Guide 1.37 3/16/73 ANSI-N45.2.1 1973 Regulatory Guide 1.38 Rev. 2 5/77 ANSI-N45.2.2 1972 Regulatory Guide 1.39 Rev. 2 9/77 ANSI-N45.2.3 1973 Regulatory Guide 1.58 Rev. 1 9/80 ANSI-N45.2.6 1978 Regulatory Guide 1.64 Rev. 2 6/76 ANSI-N45.2.11 1974 Regulatory Guide 1.74 2/74 ANSI-N45.2.10 1973 Regulatory Guide 1.88 Rev. 2 10/76 ANSI-N45.2.9 1974 Regulatory Guide 1.94 Rev. 1 4/76 ANSI-N45.2.5 1974 Regulatory Guide 1.116 6/76 ANSI-N45.2.8 1975
""Regulatory Guide - ANSI-N45.2.13 1976 1.123 Rev. 1 7/77 Regulatory Guide 1.144 Rev. 1 9/80 ANSI-N45.2.12 1977 Regulatory Guide 1.146 8/80 ANSI-N45.2.23 1978
TOPICAL UALITFASSURANCE REPORT APPENDIX C Rev. 12 BASELINE DOCUMENT MATRIX Date 10 31 94 Pa e 3 of 26 Florida Power & Light Company position regarding conflicting guidance and exceptions:
T AR A endix C Clarification ANSI ANS 3.1 - 1978 PSL-2 Q
The Regulatory Guides and industry standards listed in Appendix C to the Topical Quality Assurance Report take precedence over any Regulatory Guide or industry standard which may be referenced in any one of these documents.
Re lato Guide 1.8 Rev. 1 ANSI N18.1-1971 ANSI ANS 3.1 PSL-2 ANSI N18.1 describes the training and'education requirements for plant staff positions and is endorsed by Reg. Guide~1.8iwith an exception. That exception is the requirements for
(
the Supervisor - Radiatibn Protection. ~SDN18.1 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 I 8 is also invoked by~Technical Specifications at our St .Lucieplant and a license amendment has been approvedIfor our Turkey Point plant to specify the Health Physics Supervisor qualifications addressed in Reg. Guide 1.8.
To avoid duplication of requirements, FPL will address Plant Staff Qualifications in only the Technical Specifications.
Re lato Guide 1.30 ANSI N45.2.4-1972
,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
~
are inherently contained in the applicable procedures.
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TOPICAL VArnVASSmuWCE aZPOm APPENDIX C Rev. 12 BASELINE DOCUMENT MATRIX nate 10 31 94 Pa e 4 of 26 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".
ANSI N45.2.4-1972, Paragraph 6.2.1 requires that "Items requiring calibration shall be tagged or labeled on completion indicating date'f calibration and identity of person that performed the calibration." In lieu of tagging or labeling equipment, FPL has chosen to control calibration of installed instrumentation and control equipment by main'taining records for each piece of equipment by instrument tag number (or equivalent) to show that established schedules and procedures for calibration have been followed.
Re lato Guide 1.33 Rev. 2 ANSI N18.7 - 1976 FPL's method of addressing Paragraphs 4.0, 5.2.2, 5.2.15 and 5.3 of ANSI 18.7 - 1976 as modified by Regulatory Guide 1.33, Rev. 2 is covered in Section 6 of each individual plant's Technical Specifications.
ANSI N18.7-1976, Section 4.3, requires that personnel performing the independent review and audit be specified in number and technical discipline. This standard is invoked by the Technical Specifications (Appendix A of the Facility Operating Licenses) which have been approved for the FPL nuclear plants at St. Lucie and Turkey Point. Specifically this
'function is performed by the Company Nuclear Review Board (CNRB) identified in Section 6.5,2 of the Technical Specifications, To avoid duplication of requirements, FPL will address the personnel and functions of this independent review and audit only in the Technical Specifications.
0 TOPICAL VALI'.ITASSURANCE REPORT APPENDIX C Rev. 12 BASELINE DOCUMENT MATRIX Date 10 31 94 Pa e 5 of 26 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 devel'oped 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>i Section 4 of each plant's Technical Specifications.
FPL's method of addressing" Paragraph
~n of ANSI N18.7-1976, as modified by 5<2.'9 Regulatory Guide X, ~~~. X) 1.333'e~v. 2%s covered in 10 CFR 73 and each plant's Security Plan,
)
and as such is not included~in the Quality-Assurance Program.
Chemical cleani~ng is ot presently controlled as a special process per se; however, the requirements o'f 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 addi-
TOPICAL UALITYASSURANCE REPORT APPENDIX C Rev. 12 BASELINE DOCUMENT MATRIX Date 10 31 94 FPL P 6 of 26 tion, 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 r
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 r
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.
Re lato Guide 1.37 ANSI N45.2.1-1973 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.
0 TOPICAL UAXJIYASSUIUXCE REPORT APPENDIX C Rev. 12 BASELINE DOCUMENT MATRIX nate 10 31 94 Pa 7 or 26 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 etting.
ANSI N45.2.1-1973, Paragraphs 7.2.2, 7.2.3, and 7;3~address specific cleaning methods (Alkaline, Chelate, Acid) and make recommenaations associated with several types of
~ A.
cleaning methods. FPL's QA manua 'does not pecifically delineate these paragraphs.
However, the procedure developedper Paragraph 2.2 of~ANSI N45.2.1 will ensure that any
. (~M <'<2) specific cleaning method chosen will be properly considered and controlled.
Re lato (n
Guide 1.38-R'ev; 2 ANSI N45.2'.2 - 1972 FPL will meet t 'requirements of Reg. Guide 1.38, Rev. 2, Position 2C, D and E for safety related applications during preoperational and operational activities. Restrictions imposed for-tapes to be color contrasting will only be applied to the extent that these colors are dissimilar or otherwise distinguishable. This does not preclude using other tapes when precautions are taken to ensure these tapes do not come in contact with austenitic stainless steel or nickel alloy materials, 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.
These requirements do not apply:-to components in storage which would require removal of such tapes and barriers to effect installation.
TOPICAL UAu'ITASSURANCE REPORT APPENDIX C Rev. 12 BASELINE DOCUMENT MATRIX Date 10 31 94 P e 8 or 26 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 envfronmental 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 r
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.
FPL considers this to be a more effective approach since the quantity of spare and
... -.replacement material, parts and corqponents governed by this standard will be afforded protection commensurate with the recommendations of Section 2.7 of this standard.
TOPICAL UALITFASSXHUXCE REPORT APPENDIX C Rev. 12 BASELINE DOCUMENT MATRIX Date 10 31 94 Pae 9 of'6 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 Pr. V or ship material governed by this standard. Suppliers of materi/a>are required by purchase order to provide adequate packaging and shipping p otection. Isolated cases of material packaging or shipping are treated on a case-by-c e/basis and receive protection L
comparable to that required by the manufacturer of'that material. Loading, rigging and handling precautions identified in Sectio .3 are applied to material unloaded by FPL from a transport vehicle.
ANSI N45.2.2-1972 Section 5.'2 Wa.
requires that specific attributes of material and components
.Ak received by FPL be inspected. For plants with operating licenses FPL verifies kiQ) conformance to procurement documents during receipt inspections. Any of these attributes identtTted in these A
ocurement documents are verified during this inspection.
ANSI N45F2.2- 972 Section 5.2, paragraph 5.2.1, requires certain preliminary inspections
%4 J.
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 UAIZIYASSURANCE REPORT APPENDIX C Rev. 12 BASELINE DOCUMENT MATRIX Date 10 31 94 Pa e 10 of 26
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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 assure'd 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.
TOPICAL UALFXYASSUI~CE REPORT APPENDIX C Rev. 12 BASELINE DOCUMENT MATRIX Date 10 31 94 Pa e 11 of 26 Re lato Guide 139 Rev. 2 ANSI N45.2.3-1973 For FPL's operating nuclear plants, alternative methods are followed V to achieve equivalent slav objectives for the below listed sections of ANSI N45.23-' 3:
The zone designations of Section 2.1 of N45.2.3 and the requirements associated with each (X.r" zone are not consistent with the FPL Housekeejing 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~reventrthe entry of foreign material into safety related
%%A are Documented cleanliness'inspections performed immediately prior to system systems.
(( A.
closure. Control'of';personnel, tools, equipment, and supplies is established with approved
(( qh" procedures whemthe safety function of a system, component, or item may be jeopardized and also wlrile<the reactor system is opened for inspection, maintenance, or repair.
Re lato Guide 1.58 Revision 1 ANSI N45.2.6-1978 ANSI N45.2.6-1978, Paragraphs 1.1, 3.1, 3.2.2(a) and 4 (Table-1) identify requirements which apply to personnel who perform inspections, tests or nondestructive examinations or who participate in the approval of procedures, the handling of data or test results, or the control of reports and records.
FPL proposes an alternative to capability requirements for those who participate in: (1) the approval of procedures, (2) the handling of data or test results and (3) the control of reports and records, FPL accomplishes this by having personnel determined to be qualified and competent by management through consideration of education, training, and experience.
TOPICAL UAXJIYASSURANCE REPORT APPENDIX C Rev. 12 BASELINE DOCUMENT MATRIX Date 10 31 94 Pa e 12 of 26 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.
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 preoperationhl and operational inspections,
- -.examinations and tests shall be supeprised or directed by personnel qualified to Position C,1 of Regulatory Guide 1.58, Revision 1.
TOPICAL UALI'IYASSURANCE REPORT APPENDIX C Rev. 12 BASELINE DOCUMENT MATRIX Date 10 31 94 Pa e 13 of 26 F PL 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.alLnew certifications issued for personnel shall meet the education and experience<requirements or shall document objective evidence demonstrating that the individual~deed 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, Paragraphs.3 is that an initial and periodic review (not to exceed two years) of personnel shan~determine the capabilities in his qualified area. If during. this N~~ ((/) ..
review/or at any atheist>me, it is determined that the individuai's capabilities are not in accordance with the specified requirements, that individual shall be
.j removed from that/activi~ty until the required capability has been demonstrated. In
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addition, duringithisireview a determination shall be made that an individual has been actively involved<in the inspection process in his qualified area.
Re lato Guide 1.64 Rev. 2 ANSI N45.2.11-1974 v
FPL's exception to Regulatory Guide position C.2 is as follows:
Design verification shall be performed by technically qualified individual(s) or group(s) other than those who performed the design. The original designers and verifiers may both be from the design organization. Design verification by. the designer's immediate supervisor shall be limited to those instances when 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
TOPICAL VALLEY'ASSUIUXCEREPORT APPENDIX C Rev. 12 BASELINE DOCUMENT MATRIX Date 10 31 94 Pa e 14 or 26 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 subs'equent (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.
Re lato Guide 1.68 11 73 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". To avoid duplication of requirements, FPL will address Regulatory Guide 1.68 in the FSAR.
Re lato Guide 1.74 ANSI N45.2.10 - 1973 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.
TOPICAL UALIHTASSXBU,NCE REPORT APPENDIX C Rev. 12 BASELINE DOCUMENT MATRIX Date 10 31 94 Pa 15 of 26 FPL has developed a glossary of terms and their definitions as part of the Quality Assurance Manual which is being used throughout its nuclea construction and operating plant activities.
The following definitions are currently listedqin our glossary and are alternatives or clarifications to those listed in the ANSI Standardiand Regulatory Guide:
Assembly A combination of subassemblies or components or both, fitted togethe to form a kab e unit.
Audit A documented activity performed in accordance with written
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p ocedures 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 UALITTASSXHhLNCE REPORT APPENDIX C Rev.
BASELINE DOCUMENT MATRIX Date 10 31 94 P e 16 of 26 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 Purchase requisitions, purchase orders, drawings, contracts, specifications or instructions used to define requirements for purchase.
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.
TOPICAL VALI'SSUIUXCEREPORT APPENDIX C
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Rev. 12 BASELINE DOCUMENT MATRIX Date 10 31 94 Pa e 17 of 26 Quality Control Those quality assurance actions related to the physical characteristics or material, structure component or system, which provide a means to controlsthe quality of the material, structure, component or system to predetermined requirements.
~V Storage That period following the release of an item for shipment until turnover for start-up preo erational testing. This would include inplace sto age.
V System Aril intent par aof a nuclear power plant comprised of
~
electrical, electronic, or mechanical components (or
%dj combinations thereof) that may be operated fC 'g to perfoon~a specific function.
as a separate entity Testing Performance of those steps necessary to determine that systems or components function in accordance with predetermined specifications.
"Re uirements" Clarification for Glossa
~RE UIRHMRNT, 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.
TOPICAL VALIASSURANCE REPORT APPENDIX C Rev. 12 BASELINE DOCUMENT MATRIX w Date 10 31 94 PRI Pa e 18 of 26 Re lato Guide 1.88 Rev. '2 ANSI N45.2.9-1974 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 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 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 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 (Q'ARSET) shall be responsible for determining methods utilized to assure that QA Records are adequately stored and protected.
The QARSET shall consist of the following: the Quality Manager - Juno Beach, the Loss
- --.Prevention Engineer, and the Nuclear Records Official, who shall be responsible for maintaining records of evaluations and establishing schedules to assure that reevaluations.
are performed every two (2) years. Ifnecessary, the QARSET may delegate appropriate designees to serve as team members.
TOPICAL VALIASSURANCE REPORT APPENDIX C Rev. '12 BASELINE DOCUMENT MATRIX 10 31 94 FPL Date Pa e 19 of 26 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.evaluati'ons 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 NFP~A No. 232 owithout additional provisions.
- 2. 2-hour rated fire resistant file room as defined in NFPA No. 232- 1980 if the following additional. rovisio~nare-provided:
- a. Early warning fire detection and automatic fire suppression shall be provided, with electronic supervision at a constantly monitored central station.
b.
2J Records shall be stored in fully enclosed metal cabinets. Records shall not be permitted on open steel shelving. No storage of 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, eating and drinking shall be prohibited throughout the records storage facility.
- e. Ventilation, temperature, and humidity control equipment shall be provided with approved fire dampers where they penetrate fire barriers.
TOPICAL VALI'SSUIUXCE REPORT APPENDIX C Rev. 12 BASELINE DOCUMENT MATRIX nate 10 31 94 Pa e 20 of 26
- 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:
The maintenance of duplicate QA Records stored in separate locations which are not subject to the same destructive force at the same time.
- 2. The use of QARSET approved factory built record protection 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.
(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.'orced-air (7) circulation with filter system.
(8) Adequate fire detection and/or suppression system. \
- ,;(~) No pipes other than, those providing fire protection to the storage facility are to be located within the facility.
TOPICAL VALI'SSXHHNCEREPORT APPENDIX C Rev. 12 BASELINE DOCUMENT MATRIX Date 10 31 94 P e 21 or 26 Re lato Guide 1.116 ANSI N45.2.8-1975 ANSI N45.2.8-1975, Paragraph 2.3 requires that Measuring and+est Equipment (M&TE) used for inspection be identified on the Inspection Repo~aPL may, as an option, employ a M8rTE issue log which provides traceability between M&TE and the applicable inspections.
ANSI N45.2.8-1975, Paragraph 4.6 addresse care of items to the extent that temporary use of equipment or facilities to whic the st'anda d applies that are to become part of the
~~" o completed project may be desirable; The following clariGcation applies~to the above statement. For FPL plants in the construction phase
. ((
to the point of, plant operation license) temporary use of equipment f(
and facilities may be required according to need and/or situation. In this case, authorizafion 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.
Re lato Guide 1.123 Rev. 1 ANSI N45.2.13-1976 I
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 purchased. For commercial grade items, FPL'has. determined that certain aspects of the individual requirements ofANSI N45.2.13 need not apply. Commercial. grade items are those (1) not subject to design or speciGcation requirements that are unique to facilities or activities licensed by
TOPICAL UALI'IYASSUIUXCE REPORT APPENDIX C Rev. 12 BASELINE DOCUMENT MATRIX Date 10 31 94 Pa e 22 of 26 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.
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, 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 issuance of a written purchase order. The following controls are provided in the FPL Quality Assurance Manual to assure that the intent of ANSI N45.2.13 is satisfied for "Confirming Purchase Orders".
Prior to verbally placing the order, it must be verified that the intended supplier is on the FPL Quality Assurance, Approved Supplier List.
(2) The verbally placed order must be promptly followed-up (confirmed) with a written procurement document which, is subject to all reviews and approvals required for safety related purchases.
TOPICAL VALIASSUIhLNCE REPORT APPENDIX C Rev. 12 BASELINE DOCUMENT MATRIX Date 10 31 94 Pa e 23 of 26 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 gc QX to be reported is as follows. Suppliers (including A/E's an 'Contractors) shall submit all nonconformances which consist of one or more of thegollowing:
- 1) Technical or material requirements are'violated.
- 2) Requirement in supplie documents which have been approved by the Purchaser is violated.
Nonconformances~which would-affect he quality of the item in regard to 3)
~~~ ((as function of safety related features~ In cases where the supplier cannot make this determinAaion, they shalhbe submitted to the Purchaser for evaluation.
This policy assures thatall nonconformances affecting safety related functions will be
()s reviewed and approved by FPL In all cases, the supplier's documentation on nonconformances is available for FPL's review.
Re lato Guide 1.144 Rev. 1 ANSI N45.2.12-1977 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' 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."
'IQPICAL UALITV'SSURANCEREPORT APPENDIX C Rev. 12 BASELINE DOCUMENT MATRIX Date 10 31 94
' 24 of 26 e
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
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0
TOPICAL VALIASStHbLNCE REPORT APPENDIX C Rev. 12 BASELINE DOCUMENT MATRIX Date 10 31 94 Pa e 25 of 26 on all action taken by the audited department. This is documented on the corrective action followup form by the QA Department and closed by th 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 QAWepartment concurs with the resolution. We feel that it is appropriate fo this to be documented by the QA Department instead of the audited department.
Plannin Clarification ANSI N45.2.4-1972, Paragraph 2.1;<
0 SI N45.2.6-1973, Paragraph 2.1; ANSI N45.2.13-1976, Paragraph 7.2; ANSI 18.7-1976/ANS 3-2, Paragraph 5.2.7.1; ANSI W</) .
N45.2.8-1975, Parag aph-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 p 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.-
TOPICAL UALFIYASSUIUACE REPORT APPENDIX C Rev. 12 BASELINE DOCUMENT MAmIX 10 31 94 FPl Date Pa e 26 or 26 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 oz other document. FPL considers the above practice to be in compliance with the "plan" requirements of these standards.
TOPICAL QUALITY ASSURANCE-REPORT APPENDIX D N/A GRAY, GREEN, AND ORANGE BOOK May 7, 1982 APL MATRIX TO QA PROCEDURES Page 1 of APPENDIX D "GRAY, GREEN, AND ORANGE BOOK MATRIXTO QA PROCEDURES AN LLED IN ENTIRETY Ol CO L'
~ r'f TOPICAL QUALITYASSURANCE REPORT APPENDIX E Rev.
LIST OF CORPORATE QUALITY pa~a 02/01/94 ASSURANCE PROCEDURES Page of This Appendix has,been deleted in its.etttiret+
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TOPICAL QUALITY ASSURANCE REPORT APPENDIX F Rev.
TOPICS TO BE ADDRESSED IN Date May 7, 1982 FPL SAFETY ANALYSIS REPORTS Page 1 'of 1 The FPL Topical Quality Assurance Report is the statement of Florida Power & 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 willbe 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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