ML17354A550
| ML17354A550 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie, Turkey Point  |
| Issue date: | 04/30/1997 |
| From: | Plunkett T FLORIDA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML17354A533 | List: |
| References | |
| FPLTQAR-1-76A, NUDOCS 9706250317 | |
| Download: ML17354A550 (272) | |
Text
QUALITYASSURANCE MANUAL Rev. 52 TABLE OF CONTENTS Date 04/30/97.
Pa e I or 2 TOPICAL QUALITYASSURANCE REPORT REV RELEASE DATE Title Page June 12, 1990 Abstract 4 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 April 30, 1997 Quality Assurance Program Policy June 3, 1996 0 Introduction Topical. Quality Requirements 14 June 3, 1996 TQR 1.0 Organization 30 March 28, 1997 TQR 2.0 Quality Assurance Program 15 October 16, 1996 TQR 3.0 Design Control 13 October 16, 1996 TQRR 4.0 4 Pmcurement Document Control October 16, 1996 TQR 5.0 instruction, Pmccttures gt Drawings 12 February 28, 1997 TQR 6.0 Document Control February 28, 1997 TQR 7.0 . Control of Purchased Items & Services February 28, 1997 TQR 8.0 Identification & Control of Material, Parts February 28, 1997
& Components TQR 9.0 Control of Special Processes 13 February 28, 1997 TQR 10.0 Inspection 12 Junc 3, 1996 TQR 11.0 Test Control February 28, 1997 TQR 12.0 Control of Measuring & Test Equipment 'ebruary 1, 1994 TQR 13.0 Handling, Storage & Shipping 10 February 28, 1997.
0 TQR 14.0 Inspection, Test & Operating Status Junc'3, 1996 970b2503i7 970bi2
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0 QUALITYA'SSURANCE MANUAL Rev. 52 TABLE OF CONTENTS Date 04/30/97 Pa e 2 or 2 TOPICAL QUALITYASSURANCE REPORT REV RELEASE
,NO DATE TQR 15.0 Nonconforming Materials, Parts or Components 12 February 28, 1997 TQR 16.0 Corrective Action .10 October 16, 1996 TQR 17.0 Quality Assurance Records October 16, 1996 TQR -18.0 Audits June 3, 1996 Appendices A - Organizations.A Figures Figure 1-1: Organization of Departments April 30, 1997 Affecting Quality Figure 1-2: Turkey Point Nuclear 12 March 28, 1997 Site Organization Figure 1-3: St. Lucie Nuclear March 28, 1997 Site Organization B - Qualification k Experience Requirements June 12, 1990 for Quality Assurance Personnel C - Baseline Document Matrix 15 October 16, 1996 D - Cancelled May 7, 1982 E - List of Corporate Quality Assurance 19 April 26, 1996 Procedures (QPs)
F - Topics to be Addressed, in Safety May 7, 1982 Analysis Reports GLOSSARY Glossary 23 October 16, 1996
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TOPICAL UALITYASSURANCE REPORT Rev. 10 0 APL QUALITYASSURANCE PROGRAM POLICY Date Pa e 06/03/96 1 or 1 NEED FOR POLICY To avoid undue risk to the health and safety of the public and~ompany employe~e it is necessary to design, construct, operate and modify nuclear powerv~tan with a high degree of functional integrity, quality and reliability.
STATEMENT OF POLICY It is the policy of Florida Power & Light ComDan ito+design, construct, operate and modify h
nuclear power plants of a quality level that ill m'eet or exceed government regulations and will merit public confidence by providing, electricity in.a~eliable<efficient and safe manner.
RESPONSIBILITY The Chairman of the Board.and Chief Execunve Officer of Florida Power A Light Company has delegated responsibili for~e ecution of thet 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 Director 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.
T. F. Plunkett
' President, Nuclear Division
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TOPICAL QUALITYASSURANCE REPORT Rev.
INTRODUCTION 14'ate 06/03/96 FPL Pa e 1 of 2 The Topical Quality Assurance Report (FPLTQAR 1-76A) contains the description of the Florida Power 2 Light Company (FPL) Quality Assurance Program relative to its nuclear power plants.
This report consists of three parts: The Introduction, whichide ineates the purpose-and summarizes the scope and applicability of the'Topical Qualitv Asses
(( ce Report. The second part, Topical Quality Requirements (TQRsi, which delmeate Quality Assurance Program requirements and summarizes the FPL approach t activities related to materials,,parts, components,.systems and services included in the Quasi Qssurance Program. The third part, Appendices, which provide supporting statements~taoulations, and technical analyses or deviations which are not, in themselves, the subject of~th~ereport.
.~O The corporate Quality Assurance>Manual (FPL-NQ Wq -100A) consists of the Topical Quality t Assurance Report and a Gloss+of commonly use terms. The Topical Quality Assurance Report delineates the gerie 'ccequirements and-responsibilities by which FPL implements the t(
corporate Quality AssuranceProgram~evisions and changes to this report are made in accordance (r ~
with a uality Instruction outlined in TQR'2.0.
~
In addition to t 'e-Quality Assurance Manual, Quality Instructions (QIs) are developed as required by each of the implementing plants and departments. Quality Instructions describe the measures to be used-to implement the quality requirements of the Quality Assurance Manual. The Quality Instructions describe actions and responsibilities to be performed within a department or organization and address the requirements of the appropriate Topical Quality Requirements.
The FPL Quality Assurance Program meets the requirements provided by the NRC Regulatory Guidance and Industry Standards as listed in'ppendix C of this Topical Quality Assurance Report.
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TOPICAL UALITYASSURANCE REPORT Rev. 14 INTRODUCTION 06/03/96 APL Date Pa e 2 of 2 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.
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.
irector Nuclear Assurance
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TOPICAL VALITYASSURANCE REPORT T R 1.0 Rev. 30 ORGANIZATION 03/28/97 FPL Date Pa e 1 of 20 1.1 GENERAL RE UIREMENTS The Florida Power & Light (FPL).organizational structure shall be defined such that the responsibilities for establishment.and implementation of~the Quality Assurance Program are clearly identified. The authority and duties~of individuals and organizations performing quality assurance and quality control functions shall be described, and shall illustrate the organizational independence and authority necessary to identify problems; to initiate; recommend, or provide solutions;iand to verify implementation of solutions.
6, In addition, the description shall illustrate that persons or groups responsible for verifying the correct performance of an activity'are independent of the person or groups responsible for performing the activity.
1.2 IMPL'EMENTATION
(~w The FPL Chairman of the Board and Chief Executive Officer is~ultimately responsible for flQX ~
the execution of: the Quality Assurance Program for FPL nuclear power plants. The authoiitygfor developing and verifying execution of the program is delegated to the President<Nuclear Division and 'the Director 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.
0 TOPICAL UALITYASSURANCE REPORT T R 10 Rev. 30 ORGANIZATION Date '03/28/97 Pa e 2 ot 20 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 Performance Assessment group. Quality Assurance Program changes reviewed by the QAPRC are reviewed and signed by the affected department heads.
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 activities affecting quality within each organization shall be established and delineated in organizational charts and written job or functional descriptions.
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'OPICAL UALITYASSURANCE REPORT T R'.0 Rev. 30 ORGA'NIZATION FPL Date Pa e 03/28/97 3 or 20 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 contractor.may directly adopt the,requirements<of the FPL Quality Assurance Manual. If the contractor implements the Quality Control function directly to the FPL Quality Assurance Manual requirements, the contractor's Quality Control Supervisor shall have the authority and freedom to administer the Quality Control program.
RESPONSIBILITIES The organization charts inrAppendi '~illustrate~the lines of authority and areas of
.FW) responsibility for each, of the organizations'that are involved in activities affecting quality.
Below are listed the%departments~and organizations that have quality assurance gQ g) responsibilities.~Organizational>responsibilities for implementation of the Quality Assurance Program, are described, in, the Topical Quality Requirements (TQRs).
1.3. 1+
- 0) Nuclear:Division 1.3.2 Su ort De artments 1.3;1.l Plant Vice Presidents 1.3.2.1 Corporate Records 1.3.1.2 Licensing and Special Programs 1.3.2.2 Environmental Services 1.3.1.3 Nuclear Engineering 1.3.2.3. Protection 8r, Control'Systems 1'.3.1.4 Nuclear Assurance 1.3.2.4 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 nuclear power plant design,. preoperational and start-up testing, operation, maintenance, refueling, and modification of the plant in aCcordance with written and approved procedures.
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TOPICAL UALITYASSURANCE REPORT TQR 1.0 Rev. 30 ORGANIZATION Date 03/28/97 Pa e 4 or 20 The President Nuclear Division has overall responsibility for the Nuclear Division's activities including corporate responsibility for overall plant nuclear safety.
Reporting to the President Nuclear Division are: the Vice President - Turkey Point Plant, Vice President - St. Lucie Plant, Director Nuclear Assurance, Vice President Nuclear Engineering, Manager of Licensing and Special Programs, and the Director 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.
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.
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TOPICAL VALITYASSURANCE'. REPORT T R 1.0 Rev. 30 ORGANIZATION Date 03/28/97 Pa e 5 ot 20'NRB.
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 performecLby,a team
.independent of the Quality Assurance Department~The results of this audit are presented to the Director, 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 forqthe operation, maintenance, and modification of their respective nuclear plant, as. well as the selection, development and direction of the:assigned.staff.
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Theyzwilt act as liaison between the plants and corporate"<headquarters, and are accountabie for ensuring that company 3)
,policies; and procedures~are properly implemented.and continued at the
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nuclear site, including procurement and control'of material. The, Plant Vice
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President has overall-responsibility for implementation of the Environmental
'Protection Plans. at their respective sites.
Other responsibilities of the site Vice President include. the following:
Nuclear Services o .Configuration management.
Nuclear Trainin Preparation of policy documents regarding nuclear training; 0 Support to secure the necessary resources to ensure that site personnel are adequately. trained; They must have adequate technical and job,related skills to provide safe and efficient operation while complying with NRC requirements.
0 TOPICAL UALlTYASSURANCE REPORT T R 1.0 Rev. 30 ORGANIZATION Date 03/28/97 Pa e 6 ot 20 Nuclear Securit o Coordinate, with the opposite plant site for overall development and implementation of the FPL Nuclear Security program.
Nuclear Business S stems o Coordinating contract activities.
o Reviewing contracts to assure that technical and quality requirements developed by others are incorporated. into the procurement documents which it authorizes.
o Ensuring that site-based information management programs are in compliance with FPL software QA commitments.
Business Systems Departments at PSL and PTN. are accountable for directing the identification, design, development, implementation, on-going maintenance, and control of all nuclear site specific data processing information management systems (excluding process applications), and identifying applicable site specific software in a Computer Software Index (CSI).
Nuclear Licensin o Maintenance of the operating license; o Interface with the NRC; o Resolution of NRC safety and regulatory issues; o Administering the Operating Experience and Feedback System.
Nuclear Materials Mana ement o Negotiation, generation, issuance of procurement documents. for required items and services supporting the operation, licensing, maintenance, notification, and inspection of FPL nuclear plants, and for materials and equipment to support Nuclear Division staff;
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'ev. 30 ORGANIZATION Date 03/28/97 Pa e 7 of 20 Reviewing procurement documents to assure that technical and quality requirements developed by others are incorporated into the, procurement documents which it authorizes The organization of Turkey Point Plant andSt>Lucie Plant is shown in Appendix The. Plant General Manager - PSL ang Plant GeneralIManager - PTN, through the h.
respective Plant Vice President, are responsible for the safe operation of the nuclear plant. The Plant General Managers have control'of the onsite resources necessary
. EW) for the safe operation'and'main'tenance regardless of organizational reporting.
~AN <>n The Plant Nuclear. Safety Committee (PNSC),at Turkey Point Plant and the Facility Review Group (FRY at the St. Lucie,Plant are comprised'f key plant management and staff personnel as described in the plant Technical Specifications.
The PNSC/FRG serves. the plant manager'in a technical advisory capacity for the
).
review of all safety-related procedures,and'activities that impact plant safety and the facility operating license.
1.3.1.2 Licensing and"Special Programs The Manager Licensing and'Special Programs is responsible for selected licensing support activities at the Juno Beach Office. This includes:
o Advising senior Nuclear Division management on a regular basis of important developments in licensing areas which could significantly.
affect. the Nuclear Division; o Coordinating with the Law Department for Nuclear Division licensing hearings and legal'ervices; OrtG292
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TOPICAL QUALITYASSURANCE REPORT T R 1.0 Rev. 30 ORGANIZATION 03/28/97 FPL Date Pa e 8 or 20 o Administering special programs, such as:
o Plant license renewal,.
o Environmental issues, o Self assessment, o INPO coordination, o Serving as FPL liaison in matters of high level waste disposal.
1.3.1.3 Nuclear Engineering The Vice President Nuclear Engineering is responsible for nuclear plant design and engineering support.
The Nuclear Engineering. organization is shown in Appendix A.
- a. Nuclear Engineering Nuclear Engineering includes personnel located at both nuclear sites and at the 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 Program, and Nuclear Engineering is responsible for approval of the design output.
Delegated activities are performed in accordance with an FPL approved Quality Assurance Program and the contractor is responsible for approval of design output. Nuclear Engineering is responsible for defining the scope of delegated activities and the responsibilities of the contractor.
Prior to the release of design outputs by contractor organizations, Nuclear Engineering ensures that the contractor is technically qualified to perform the design-related activity.
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TOPICAL'ALITYASSVIU NCE:REPORT TQR 1.0 Rev. 30 ORGANIZATION Date 03/28/97 Pa e 9 of 20 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~ower plant projects..during construction and operation to assure~efficient, economical and reliable power plant design, conformancetwith engineering schedules and budgets and compliance with regulatory requirements.
Nuclear Engineering fs<responsible for:
h o power plant design related>aspects of the FPL Quality Assuran'ce Program. throughout,all phases of. plant life;
<.Vr$andgmaintenance o development of the design control program rX
<<governing design-related activities performed by Nuclear Engineering
> and for-provi'ding technical support:to the Quality Assurance fr Departm~enti 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; o 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; etq0292
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TOPICAL UALITYASSUIVWCE REPORT T R 1.0 Rev. 30 ORGANIZATION 03/28/97 FPL Date Pa e 10 or 20 Aspects of the above activities are performed by the Juno Beach Engineering organization as determined by the Vice President Nuclear Engineering.
- b. Nuclear Fuel I The Manager Nuclear Fuel is responsible for nuclear fuel engineering (
and procurement activities including the following:
o assuring that technical and quality requirements (including inputs from other-FPL departments) are incorporated in fuel contracts and letters of authorization; o administering and managing contracts for nuclear fuel and related services to assure'hat. technical and quality obligations are met, and serving as FPL liaison in all matters of nuclear fuel and fuel-related contracts; o administering and managing spent fuel disposal contracts with Department of Energy and serving as FPL liaison in matters of nuclear fuel; o all fuel related design, analyses, reviews, and technical assistance necessary to ensure the safe, reliable, and economic operation of the nuclear plants; o the development and/or review of fuel and nuclear physics design; o implementing and maintaining the FPL. corporate nuclear material accountability program as outlined in the, FPL Special Nuclear Material Control Manual; o providing support to the Quality Assurance Department for their auditing of nuclear fuel design and fuel assembly manufacturing; J
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TOPXCAX VAX3HVASSUXV NCE REPORT T R 1;0 Rev. 30 ORGANIZATION FPL Date Pa e 03/28/97 11 or 20 o performing audits and coordinating accountability reporting on all nuclear fuel.
- c. Component Support and Inspections hh, The Manager Component Suppor~tand Inspections is responsible for providing support to the plants as>follows:
o providing technical support of activities associated with component r.
non-destructive
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reliability, materials evaluations; inspections, corrosion protection, examination, and ASME Section XI implementation/problem. resolution for nuclear plant components;
. $ M~S. >W) o providing~specifi~ccomponent expertise, metallurgical support, and non-destructive examination and inspections;
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.ogestablishing i' the,FPL Welding Program to meet the requirements of
(
the Quality)Assurance Program and applicable codes and standards;
~~) o developing, maintaining, and: controlling the procedures and instructions to implement the FPL Welding. Program; and o originating and qualifying welding procedure specifications; and
- d. Reliability and Risk Assessment The Supervisor-of Reliability and Risk Assessment is responsible for providing support to the plants as follows:
o prepare and maintain Probabilistic Safety..Assessment (PSA) for each plant; o perform Risk Assessments in support of Maintenance activities; o perform Risk Assessments. in support of the NRC Maintenance Rule.
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TOPICAL UALITYASSURANCE REPORT TQR 1.0 Rev. 30 ORGANIZATION Date 03/28/97 Pa e 12 of 20 1.3.1.4 Nuclear Assurance The Director Nuclear Assurance is responsible for the selection, technical direction, administrative control (e.g. performance appraisal, salary review, hire/fire, position assignment) staffing, training and development of personnel required for supervisory and operating continuity of the Quality Assurance Department, Nuclear Safety Speakout, and the CNRB Subcommittee. The Director Nuclear Assurance serves as the CNRB Chairman. The Director Nuclear Assurance also initiates QA Program policy changes when necessary.
In addition, the Director 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 Director Nuclear Assurance and the Company Nuclear Review Board (CNRB).
The Nuclear Assurance organization is shown in Appendix A.
- a. Nuclear Safety Speakout 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.
- b. Quality Assurance Department The Quality Assurance Department is responsible for administering the FPL Quality Assurance Program. This includes developing and verifying implementation of corporate policies, plans, requirements, and procedures affecting quality. The Quality Assurance Department retains responsibility for delegated portions of the Quality Assurance Program
II TOPICAL. UALITYASSURANCE REPORT T R 1.0 Rev. 30, ORGANIZATION Date 03/28/97 Pa e 13 or 20 by performing initial evaluation and subsequent periodic audits of the contractors'uality Assurance Programs. The Quality Assurance Program responsibility further extends-to the performance of..audits within the Company to assure management that .the established requirements and procedures are being implemented, and that the Program complies with the basehnesdocument requirements.
The organizational freedom of the Quality Assurance function is accomplished m rt through. the corporate structure, illustrated in Appendix A, which. provides independence from 'those departments responsible for design; procurement, engineering,, construction and operation. With zA, quality assurance as'its sole function thefQuality Assurance Department, both on-site and'off:site, is completely free from the cost and scheduling pressures
( of design, procurement, construction and operation. The Quality Assurance Department has the freedom and authority to: a) identify quality problems;,b) initiate, recommend or provide corrective action; c) verify implementation of the corrective action;. and d) recommend the stoppage-of. work or operations adverse to quality, when necessary; The QA Supervisor Performance Assessment, QA Supervisor Procurement Quality,'Site Quality Manager - St. Lucie,.and Site Quality Manager - Turkey Point report administratively and functionally to the
.Director 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.
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TOPXCAI VALITYASSURANCE REPORT TQR 1.0 Rev. 30 ORGANIZATION FPL Date Pa e 03/28/97 14 Of 20
- 1) Performance Assessment The QA Supervisor Performance Assessment 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 Performance Assessment activities include the following:
o develop and maintain the corporate Quality Assurance Manual, including the administration of the Quality Assurance Program Review Committee (QAPRC);
o develop and implement a Quality Assurance indoctrination program for FPL personnel; o prepare reports on Quality Assurance Program activities for review by the CNRB; o plan, coordinate and implement a comprehensive system of periodic internal audits with support from the other Quality Assurance groups, when necessary; o perform periodic activity audits of FPL procurement and associated documents and changes to these documents to assure that the necessary quality requirements are imposed; o provide NDE Level IIIservices including technical direction and monitoring of NDE'ctivities performed by Quality Control at the plant sites (PTN and PSL).
- 2) Procurement Quality The QA Supervisor Procurement Quality directs and administers the Procurement Quality program in support of both nuclear plants.
Procurement Quality activities include the following:
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TOPICAL UALITYASSURANCE, REPORT TQR 1.0 Rev. 30 ORGANIZATION 03/28/97 FPL Date
.Pa e 15 of 20 o perform appropriate surveillance of hardware during manufacture; o develop and implement a program for auditing afaupplier c'8 XQ Quality Assurance/Quality Controt,itrograms including Architect Engineer/Nuclear Steam<Supply 'System, Suppliers; assist other FPLpdepartments WC' in the:identification of quality problems associatedwith procurement and storage; initiate, recommend, or~provide solution; and verify implementation of f'olutions; o maintain the Quality. Assurance Department list of approved suppliers; Forqpurchased C) items and,services, the responsibility of this group extends
((
through receipt of shipment or performance: of contract.
Q
- 3) Site Quality Assurance Turkey Point Nuclear (PTN) and St. Lucie (PSL)
Quality Assurance activities at the plant sites (PTN'nd 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 quality assurance. policies,.plans,, requirements, and procedures at the plant site; o perform audits, assessments and other observations as specified'n procedures and instructions to verify compliance with Quality Assurance Program commitments;
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TOPICAL UALITYASSURANCE REPORT TQR 1.0 Rev. 30 ORGANIZATION Date 03/28/97 Pa e 16 or 20 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 recommend stoppage of work or operations adverse to quality at the plant site in accordance with the appropriate'nstructions; o review and comment 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 Analysis Report, and the applicable Technical Specifications; o perform audits of the architect engineer and Nuclear Steam Supply Syst'm suppliers both on-site and off-site, in conjunction with the Procurement Quality group.
The interface with the Procurement Quality group ends with the receipt of a shipment of nuclear safety-related equipment at the plant site. The Quality Assurance program for the shipment is then within the purview of the Site Quality Assurance group.
The Quality Manager - Turkey'Point and Quality Manager - St. Lucie are additionally responsible for the establishment and implementation of quality control aspects of the Quality Assurance Program at the plant site. Reporting directly to the Site Quality Manager 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
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TOPICAL UALXTTASSURANCE'. REPORT .
TQR 1.0 Rev. 30 ORGANIZATION FPL Date Pa e 03/28/97
- 17. or 20 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 responsibihties include:
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
nacceptance 1.3.1'.5 Nuciesr Busiue'ss.Services+
of the installed items; The. Director Business"Services is responsible for Nuclear Division business and.financial planning and analysis and nuclear.,plant support in the areas of document control and QA records management, division-'based and staff computer systems, security, emergency preparedness, and radiological services.
Nuclear Business Services is, shown in. Appendix A.
- Accountabilities related to division-based and staff computer systems encompass:
o directing the identification, design, development, implementation, on-going maintenance, and control of division-based information management systems; o identifying applicable division-based software in a Computer Software Index (CSI);
o Coordinating and directing computer hardware and telecommunication planning and control; Oise292
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TOPICAL UALITYASSURANCE REPORT TQR 1.0 Rev. 30 ORGANIZATION Date 03/28/97 Pa e 18 of 20 o ensuring that the information management programs are in compliance with FPL software QA commitments.
1.3.2 Su ort De artments Providing support activities for the Nuclear Division are Corporate Records, Environmental Affairs, Protection 8r. Control Systems, and Information
'Management. The reporting relationship of each department is described in the following sections and is shown in Appendix A.
1.3.2:1 Corporate Records The Supervisor Corporate Records is responsible for:
o 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 serving as the Records Official.
1.3.2.1.a The Records Official, reporting to the General Counsel and Secretary is responsible for:
o ensuring the Quality Assurance records program activities are managed in accordance with applicable recordkeeping requirements; locating acceptable record storage areas when requested; 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.
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TOPICAL QUALITYASSURA'NCE'EPORT T R 10
'ev. 30 ORGANIZATION FPL Date Pa e 03/28/97
.19 ot 20 1.3.2.2 Environmental Services Environmental Services is responsible for obtaining the federal an'd state environmental permits required for PPL=Xacilities and ~erations.
Environmental Services is also -responsibleufor providing technical support.
on environmental regulatory requirements, including regulatory, development, enforcement actions, compliance with<environmental requirements and environmental assessments and clean-ups at all company facilities,.as well as technical. support and/or/advice on non-.radiological .environmental monitoring, (federal f~4 'v>>'
and state) programs at the nuclear power plant sites.
The Site Vice President has overall. responsibility for implementation of the Environmental X)
Protection. Plans (EPPs) at nuclear power plant. sites.
T&he Environm~ental Services Department through its functional areas is responsible for providing technical support and/or advice on non-.radiological environmental monitoring programs and oversight.of other requirements related to.the Environmental Protection. Plans. The Department provides review of proposed changes to the Environmental Protection Plans, review of plant changes, tests or experiments and review of other plant activities which may be subject to environmental regulations to ensure their compliance.
The Department provides information as necessary to the CNRB Chairman on environmental matters for which requirements are included in Environmental Protection Plans.
1.3.2.3 Protection & Control Systems The Director of Protection:& Control Systems reports to the Vice President of Power Delivery.
0 TOPICAL QUALITYASSUIWACE REPORT T R 10 Rev. 30 ORGANIZATION Date 03/28/97 Pa e 20 of 20 Protection &'Control Systems is responsible for:
o test, calibration and maintenance of certain high voltage electrical protective relays for safety-related systems of. the nuclear plant; o final wiring connection checks; o preoperational check-out and test of system protection devices; o providing inspection of equipment under their cognizance; o providing certain setpoint and checkpoint values for protective devices.
1.3.2.4 Information Management The Corporate Information Management organization is shown in Appendix A.
Information Managemen't is responsible for ensuring the integrity of the operating environment and the applications used by the Nuclear Division.
The Director of IT Operations and the Director of Business Systems report to the Vice President of Information Management.
1.3.2.4.a The Director of IT Operations is responsible for:
o the installation and maintenance of operating system software and the operation of computer hardware for FPL's corporate computer system; o executing software production release and change control activities.
1.3.2.4.b The Director of Business Systems is responsible for administering physical databases and providing on-going technical support.
4i 0
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TOPICAL UALITYASSUI4LNCE RRX'ORT ' R 2.0 Rev. 15 QUALITYASSURANCE PROGRAM 10/16/96 EPL Date Pa e 1 or 8 2.1 GENERAL RE UIREMENTS Florida Power k, Light Company has established a Quality Assurance Program which complies with the criteria of f 10 CFR 50 Appendix B and meets the requirements of Regulatory Guides and Industry Standards referenced inhAppendix C of this report. The Topical Quality Requirements and attached Policy/Statement, together with Quality Instructions document the Program and the F L policy with regard to Quality Assurance.
This Program shall be instituted fo~each plant site in a. schedule consistent with accomplishing the required activity-and shall be carried out throughout the life of FPL nuclear plants.
.Wo 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 J
Report for eac nuclear ubn? A'dditionally, the requirements of the FPL Quality Assurance Program> shall op~ply to all FPL, contractor, or consultant organizations performing<activities affecting the quality of safety related structures, systems, and components of FPL nuclear power plants. Portions of the FPL Quality Assurance s
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 i'ndoctrination 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.
il TOPICAL QUALITYASSUIVLNCE REPORT T R 2.0 Rev. 15 QUALITYASSURANCE PROGRAM Date 10/16/96 APL Pa e 2'r 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 Policy Statement of the President of the Nuclear Division, the goal of the FPL Quality Assurance Program is to maintain quality levels in an effective and efficient manner, and'to assure'the high degree of functional integrity and reliability of nuclear safety related structures, systems, and components. To meet this goal, the following objectives of the FPL Quality Assurance Program have been defined:
- 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; Apprise management of unresolved problems and trends which could. have a significant effect on nuclear power plant safety; and Prevent schedule delays and high cost due to poor quality.
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Iles TOPICAL VALI'SSUIUXCEREPORT T R 2.0 Rev. 15 QUALITYASSURANCE PROGRAM Date 10/16/96 Pa e 5 or 8 However, FPL shall retain overall responsibilities 'for the Quality Assurance Progr'am. Procurement documents shall define the scope of delegated activities, as well as Quality Assurance Program requirements-that shall govern-these activities.
The Quality Assurance Departmen shall review and approve the Quality Assurance Program governing~contracted activities prior to award of contract nature. In all cases, final t'~'s" except for. activities for which the<output is approval 0
shall. occur of a conceptual and/or prototype at a point in the process to ensure that the output complies~with the requirements of the FPL approved Quality Assurance Program. ~+he obiect of this review shall be to verify that the program is in compliance ith the applicable requirements of Appendix B, IOCFR50, and ANSI N45~2s. Audits shall bdconducted periodically to verify the acceptable t( o implementation of the contractor's FPL approved Quality Assurance Program governing delegated activities. The Quality Assurance Department is responsible for conducting these audits. The initial review and periodic audits shall be performed by qualified Quality Assurance Department personhel, 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.
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TOPICAL OVALI'IY ASSURANCE REPORT TQR 2.0 Rev. 15 QUALITYASSURANCE PROGRAM Date 10/16/96 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 refiect 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 Director Nuclear Assurance and the Supervisor Performance Assessment 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;
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TOPICAL UAXXIY ASSUR& NCE REPORT TQR 2.0 Rev. 15 QUALITYASSURANCE PROGRAM 10/16/96 FPL Date Pa e 7 of 8 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~ay include such items-as the status of audits, a summary
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of audit~findings,jthe status of development projects, and descriptions of policy matters or problems requiring management attention; The CNRB shall review the status of tlie Quality Assurance Program on a semiannual basis.~The review will include assessment of the Program r~x .A goals, objectives, Periodic
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and accom lishments; audits ofethe QualiWyAssurance Department and Program shall be conducted>by>an independent audit group under the direction of the Director Nuclear Assurance. This audit group shall employ FPL audit
.procedures
%~g and:shall distribute the audit report to the Director Nuclear Assurance, (t A andito,the CNRB for review of findings and corrective action.
uditor certifications 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 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;
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TOPICAL VALHVASSURANCE REPORT TQR 3.0 Rev. 13 DESIGN CONTROL Date 10/16/96 APL Pa e 1 ot 10 3.1 GENERAL RE UIREMENTS A Quality Assurance Program shall be established for design-related activides-. The design control program shall ensure that the design is defined, controlled and verified; that applicable design inputs are specified and corre~ct~ltranstated into design output documents; that design interfaces are identified and controlled; that design adequacy is verified by persons other than those @ho designed the item; and that design changes, including field changes, are governed by~control measures commensurate with those applied to the original design.
na Design records'shall be developed to provide evidence that the design process and design verification, were performed in accordance with the requirements of FPL's Quality Assurance Program.
Design records shall include design output documents and the, important steps in the design effort. The intent of this documentation is to allow a technically qualified person
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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 and databases designating safety related and quality related items and any revisions thereto shall be controlled in accordance with the FPL QA Program'equirements.
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'OPICAL VALITYASSURANCE'R%X'ORT TQR 3.0 Rev. 13 DESIGN CONTROL Date 10/16/96 Pa e 2 of 10 3.2 IMPLEMENTATION The controlling document for the identification of safety related items shall be the FSAR.
Where the FSAR is not definitive for a specified plant, Nuclear Engineering shall develop-and maintain documents/databases identifying those items which are safety related (e.g.,
plant equipment database, drawings, etc). These documents/databases shall clearly
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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/Modification 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'n design output documents such as specifications, drawings, and other documents defining 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.
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TOPICAL VALlHYASSK94LNCE REPORT T R 3.0 Rev. 13 DESIGN CONTROL Date 10/1'6/96 Pa e 3 or 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 forward the approved PC/M:o.the applicable PJant-Vice President. Internal plant coordination and review o . design control documents shall be controlled by approved instructions.
3.2.1 Design Process The design organization shall soeci 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 veritscKti'on that design output documents satisfy design input requirements. esignymethods; materials, parts, equipment and processes, including those, associated with commercial grade items that are essential to the function of"thehitem<shall be-se ected, reviewed and approved for suitability of
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ap lication~by the design organization.
U Design inputs shall be identified, documented, reviewed and approved by the design organization. They shall be specified to the level of detail necessary to permit the design activity to be carried out in a correct manner, and to provide a consistent basis for making design-related decisions, performing design verification
'nd evaluating design;changes. Changes to approved design inputs, including the reason for the changes, shall be approved, documente'd and controlled by the design organization.
The design organization shall identify aspects of manufacture, construction, inspection and testing critical to achieving the function of the item. Quality standards and quality requirements shall be specified on design output documents.
Changes from approved quality- requirements specified in design output, including the reason for the changes, shall be approved, documented and controlled by the design organization.
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TOPICAL UALITYASSUIVRNCE R1H'ORT TQR 3.0 Rev. 13 DESIGN CONTROL Date 10/16/96 Pae 8 or 10 3.3 RESPONSIBILITIES 3.3.1 The Vice President Nuclear Engineering is responsible for:
l
- 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 if the 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);
- f. Providing Nuclear Engineering approval of design documents;
- g. Updating design documents and drawings according to applicable
.procedures;
- h. Coordinating the NRC interface for 10 CFR 50.59 reports.
3.3.2 The Plant Vice President is responsible for:
Reviewing, tracking the status of, and maintaining a,file on proposed PC/Ms; 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; reviewing completed PC/Ms, after implementation for compliance with governing procedures, including a review of all endorsements, sign-offs, completion of required acceptance testing/inspection, and any necessary changes to operating practices and procedures;
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TOPICAL UALlHYASSURANCE REPORT TQR 3.0 Rcv. 13 DESIGN CONTROL 10/16/96 FPL Date Pa c 10 or 10 3.3.5 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; Reviewing proposed design changes which involve an Unreviewed,Safety Question or a change in Technical Specifications or License.
3.3.6 Each direct report to the President, Nuclear Division and Department Heads of organizations supporting the Nuclear Division shall be responsible for:
- a. identification of computer programs/software used to accomplish activities affecting quality; establishment of departmental instructions which prescribe the methods and techniques used to meet the QA program requirements for control of s
computer programs/software.
3.3.7 Director Information Technology (IT) Operations is responsible for evaluating all
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Operations determines applications may be affected, then IT Operations is
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responsible for notifying user departments.
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TOPICAL QUART ASSURANCE REPORT TQR 4.0 Rev. 9 PROCUREMENT DOCUMENT CONTROL 10/16/96 EPL Date Pa e 3 or 5 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'a elated structures, systems, and components are subject to technical or quality requirements equivalent to, or better than, those used for the original equi ment.
Changes to procurement documents, whether initiated by FPL or their representative, are subjected to the!same degree of control as that utilized in the 4.2.3 e~
.preparation of the original~document.
Selection of)procurement Sources It shall be verified that the procurement document has been reviewed and approved, and that the supplier has been approved prior to issuing the purchase AJ order for safety related materials or services. Verbal'urchase orders shall be made in accordance with TQAR Appendix C exceptions to ANSI N45.2.13.
Supplier approval is not necessary if the important characteristics of the item, can be verified by inspection or test.
The overall procurement requirements, including those related to planning, bid evaluation, and review and concurrence of suppliers Quality Assurance. programs, are described in Quality Instructions.
4.3 RESPONSIBILITIES 4.3.1 Direct reports of the President, Nuclear Division, and Department Heads of organizations supporting the Nuclear Division originating a procurement requisition shall be responsible for:
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.TOPICAL UALI'ITASSURANCE MH'ORT TQR 4;0 Rev. 9 PROCUREMENT DOCUMENT CONTROL Date 10/16/96 Pa e 4 ot 5
- 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.
4.3.2 The Vice President Nuclear Engineering is responsible for:
- a. Performing technical. evaluations to verify and/or establish technical and quality requirements for permanent and-temporary power plant items and services;
- b. Reviewing technical and quality requirements contained in 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; Evaluating the interchangeability of items that are not identical to what is
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currently installed.
4.3.3 The Director 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);
Identifying surveillance witness and/or'hold points at the supplier's facility for safety related procurement when supplier QA program is relied upon and programmatic deficiencies dictate; Performing supplier surveillance.
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TOPICAL QUALITYASSURANCEt'REtPORT TQR 5.0 INSTRUCTIONS, PROCEtDUREtS Rev. 12 AND DRAWINGS Date 02/28/97'a e 1 of 3 5.1 GENERAL RE UIREMENTS Activities affecting quality, of nuclear. safety-related structures, systems, and components shall be prescribed'y documented instructions, procedures, or, drawings of a type appropriate to the circumstances and shall be accomplished>in accordance with these instructions, procedures, or drawings. These documents shall include appropriate quantitative criteria such as dimensions, tolerances, and operating limits, and qualitative criteria such as comparative workmanship samples,~to assure that the quality assurance activity has been satisfactorily,accomplishedt
- 5. 2 IMPLHMENTATfON 5.2.1 Quality Assurance Program'Documents The FPL QualitynAssurancefManual described in TQR 2;O.contains the Topical Quality, Assurance Report which complies with the criteria of 10'FR 50,
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B,.@Quality Instructions provide direction for activities affecting quality.
fs'ppendix The>Quality Assurance Department reviews and comments on Quality Instructions (t written by other departments. Comments concerning compliance with corporate A. )~.
MQuality 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 operati'ons, 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
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TOPICAL UALITYASSURANCE REPORT T R 5.0 INSTRUCTIONS, PROCEDURES Rev. '12 AND DRAWINGS 02/28/97 FPL Date Pa e 2 of 3 operating procedures,,off-normal and emergency procedures, test procedures, and calibration procedures. Also included are maintenance and repair procedures for
-subcontracted maintenance and repair activities which are outside the normal scope of plant craft capability. 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.
l 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 J
with the appropriate criteria of 10 CFR 50, Appendix B.
il TOPICAL UALITYASSURANCE< REPORT T R 5.0 INSTRUCTIONS, PROCEDURE<S Rev. 12 AND DRAWINGS Date 02/28/97 Pa e 3 ot 3 5.2.3 Drawings The design organization is responsible for review and approval of drawings. For delegated design activities, the Nuclear Engineering, Department may ~aprove
)
changes to drawings. The technical control of diawings, 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.
5.2.4 Acceptance Criteria c,&
Quality Instructions shall require that instructions, procedures, and drawings
'I affecting quality include adequate quantitative and qualitative acceptance criteria, as appropriate, for determining satisfactory work performance and quality compliance. These acceptance criteria requirements apply to important activities
. such as design, operations, test control, inspection, and plant modifications.
5.3 RE<SPONSIBILITII<< l 5.3.1,Each direct report to the President Nuclear Division and Department Heads of organizations supporting the Nuclear Division is responsible for:
Establishment of a documented system for the preparation, review, approval and revision of procedures. This system shall comply with regulatory requirements, the applicable Plant Technical Specifications and Topical Quality Requirements.
5.3.2 The Director Nuclear Assurance is responsible for:
- a. Review and concurrence of procedures affecting quality in accordance with Paragraph 5.2.
~
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TOPICAL VALITYASSURANCE. REPORT T R 6.0 Rev. 1'1 DOCUMENT CONTROL Date 02/28/97 Pt=gL Pa e 1 ot 3 6.1 GENERAL RE UIREMENTS The distribution of documents such as instructions, procedures, drawings, and software which provide guidance; specifications, or requirements affecting the quality of. nuclear L/
.safety related structures; systemsan,d .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 Q) to controlled, documents. shall~be so identified and shall be reviewed and approved by the same organization that performed the original review and approval unless otherwise specifieddi'n4the implementing procedures. in:addition, procedures shall
~~ ))
preclude the possibility of use of outdated documents.
6.2 'IMPLEMENTATION 6.2.'1 Quality Instructions shall delineate the control measures thatprovide for:
Q p) 6.2;1.-1 Identification of individuals or organizations responsible for preparing, reviewing, approving, and issuing documents and revisions thereto; 6.2.1.2 Identifying the, proper documents to be, used in performing the activity; 6;2.1.3 Coordination and control of interface documents; 6.2.1.4 Ascertaining.that proper documents are being used; 6.2.1.5 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: .
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TOPICAL VALITYASSURANCE REPORT T R 6.0 Rev. 11 DOCUMENT CONTROL Date 02/28/97 Pa e 2 or 3'.
design specifications;
- b. design, manufacturing, construction, and installation drawings;
- c. quality program manuals, procedures, and instructions.
- d. inspection, manufacturing, and test procedures and instructions;
- e. plant operating and maintenance procedures;
- f. plant Safety Analysis Reports and related design criteria documents.
The requirem'ents for control of procurement documents are contained in TQR4.0, Procurement Document 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 to drawings shall be approved prior to release by the. drawing custodian.
Approval shall be 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.
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TOPICAL QUALITYASSURANCE REPORT TQR 6.0-Rev. 11 DOCUMENT CONTROL Date 02/28/97 Pa e 3 of 3 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 ~heJatest applicable revision, or by a document receipting. / system.
6.3 RESPONSISILITIES 6.3.1 Direct reports to the President, Nuclea~rDivision, and Department Heads of
.organizations supporting the.Nuclear<Division shall"be responsible for:
- a. the development, maintenance and control of those documents identified'n Section 6.'2"tssued".by them as controlled. documents;
.b. the adequacy of.thetr instructions, including the instructions for control of the-documents and changes thereto to preclude the possibility of use.of outdated or inappropriate documents.
Each~ecipient:of controlled document is responsible for ensuring that the 6.3:2 (CA" app~oriate a
latest. revision is being used..
6.3,3 The Vice President, Nuclear Engineering, is responsible for assuring that the kA .
Architect-Engineer, Nuclear Steam Supply'System vendor, and other contractors,
~
as a minimum:
.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; provide that all revisions required as a result of FPL comments,
]
nonconformances, .or engineering work are incorporated into revised documents.
6.3.4. 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.
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TOPICAL UALrrVASSURANCE REPORT T R 7.0 Rev. 9 CONTROL OF PURCHASED ITEMS' SERVICES Date 02/28/97 Pa e 1 of 4 7.1 GENERAL RE UIRE<MENTS 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 documented. evidence of, source selection, verification act vities and examination of items'r services to,assure compliance with the procurement>document. The effectiveness of the control of quality"by contractors and subcontractors shall be assessed at intervals consistent with the importance,.complexity, and quality of the product or service, 7.'2'MPLEMENTATION 7.2.1 Evaluation of Supplie~rs, g Procurement source evaluation and"selection 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 6
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 of 10 CFR 50, A'ppendix 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'f supplier approval shall be based on such factors as prior performance, historical quality performance data, source surveys or audits, and evaluation of the supplier's, Quality Assurance, Program. The basis shall be consistent with the importance, complexity, and quality required for the items or services involved.
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TOPICAL UALITYASSURANCE RE<PORT T R 7.0 Rev. 9 CONTROL OF PURCHASED ITEMS & SERVICI<<
FPL l Date Pa e 02/28/97 2 <<r 4 7.2.2 Verification Activities Quality Instructions shall define the requirements for verification activities such as surveillance, inspection, or audit to assure conformance o~f- rocured items and .
services to i'dentified requirements. These verification activities shall be performed in accordance with written procedures, procurement documents and their references, which specify the documentation required and the characteristic or process to be witnessed, inspected, verified, or accepted. FPL verification activities shall be accomplished by qualified personnel to verify that the supplier complies with quality requirements, and depending on the importance/complexity, shall be performed on those items where verification of procurement requirements cannot be determined upon receipt.
7.2.3 Receiving Inspection Quality 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:
- a. Measures for verifying that the shipment is complete, properly identified, undamaged, and corresponds with the purchase order documentation;
- b. Measures for inspection of the item and review of supporting documentation (e.g., mill test reports, NDE reports). as required by the purchase documents;
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TOPICAL QUALITYASSURANCE RE<PORT TQR 7.0 Rev. 9 CONTROL OF PURCHASED ITEMS a SERVICES Date 02/28/97 Pa e 3 of 4
- 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.
Measures to ascertain..that inspectionwre'cords or Certificates. of Conformance are available prior, to.release; Measures verifying completion of Commercial e
Grade Item. dedication requirements.
7.2.4 'Supplier Furnished'ecords'ecords required to~be furnished by tlie supplier .shall be specified in the
.procurement document. Certifications:or, documentation verifying conformance provided by the supplier shall identify the specific procurement requirements met (either by. reference to the purchase order or by referenced. requirements therein).
Such-certification shall identify any procurement requirements which have not f~~3 been met and provide a description of those nonconformances dispositioned
'accept as is" or "repair".
7.3 RE<SPONSIBILITIES 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;
- b. The. performance of the acceptance methods selected, when assigned, to them.
7.3.2 The Vice President Nuclear Engineering-is responsible for
- a. 'Requesting that Nuclear, Assurance perform a supplier evaluation;
- b. Determining the methods of acceptance for items and services.
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TOPICAL QUALITYASSURANCE REPORT T R 7.0 Rev. 9 CONTROL OF PURCHASED ITEMS A SERVICES Date 02/28/97 Pa e 4 or 4 7.3.3 The Director Nuclear Assurance is responsible for:
- a. Assuring that evaluations of suppliers are performed and the results documented in accordance with approved Quality Instructions; Determining the methods of source verification; Performing receipt inspections in accordance with approved Quality Instructions; 7.3.4 The Site Vice President is responsible for:
- a. 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.
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TOPICAL VALITYASSVRANCE REPORT T R 8.0 Rev. 4 IDENTIFICATIONAND CONTROL OF MATERIALS, PARTS Date 02/28/97 AND COMPONENTS Pa e I Ot 3 8.1 GENERAL RE VIREMENTS 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 identificati'on of~the item shall be maintained by heat number, part number,.serial number, assigned~traceability 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 prevents the use of non-inspected, incorrect or defective materials, parts, and components. I 8,2 IMPLEMENTATION (o
Quality Instructions shall establish the~<responsibilities and requirements for the identification, and co'ntrol of materials, parts and components. The procedures and instructions used by all
.O.. 2 organizations shall'ssure that identification and control is .
f~
maintained:throughout fabrication, receipt, handling, storage, installation and use of items.
This shall include welding material traceability to the point, of consumption. Provisions include:
g
- a. MPhysical 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 parts-or their container; Post-installation identification of items that cannot feasibly be physically marked shall be traceable by record verification; Items requiring identification, but whose identification was lost during storage, shall be segregated and'documented as nonconforming and dispositioned in accordance with established procedures;
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TOPICAL UALITYASSURANCE REPORT TQR 8.0 Rev. 4 IDENTIFICATIONAND CONTROL OF MATERIALS, PARTS Date 02/28/97 AND COMPONENTS Pa e 2 of 3 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
'to 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 me'thod 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; 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.
0 TOPICAL QUALlTYASSURANCE REPORT TQR 8.0 IDENTIFICATIONAND CONTROL Rev.ate OF MATERIAL'S, PARTS 02/28/97 AND COMPONENTS Pa e 3 ot 3
.8.3 RESPONSIBILITIES 8.3.1 The Site Vice President 'has overall'.responsibility for:
- a. Assuring that an identification and control csystem is developed, and
.implemented for items to be utilized within the plant;
- b. Receiving, controlling;and ensurin~~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 V
by, applicable procedures>or~asQrequested in accordance with applicable
.purchase orders, s ecifications orgcommercial grade dedication packages; e.
/(
Incorporating'applicable pre-installation and/or post-installation inspections, tests, and<QC hold, pointsy(including Commercial Grade Item Dedication requirements) into applicable work control. documents.
8.3;2 6
The-Vice President Nuclear Engineering has overall responsibility for: I
- a. Determining and-specifying end use applications for items.
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TOPICAL VALrrVASSURANCE RKPORT T R 9.0 Rev. '13 CONTROL OF SPE<CIAL PRO CE<SSE<S Date 02/28/97 Pa e 1 of 5.
9.1 GENE<RAL RE UIRE<ME<NTS Measures shall be established to assure that special processes such, as welding,. heat treating, and nondestructive examination items, are controlled and accomplished by qualified personnel using qualified'rocedures and equipment in accordance with applicable codes, standards, specifications, criteria~and other. special requirements.
9.2 IMPLE<ME<NTATION Special process requirements. shall be included in design outputs -and changes thereto.
'Special process. procedures shalllbe developed, reviewed, approved and controlled, and' special process personnel and equipment shall be. qualified.
9.'2.1 Identification.of% ecial Processes Specialrprocesses k4 2) are"those processes which must be qualified and controlled Xw~.. (Wc where quality. is highly~dependent on close control of process variables or operator
(~X skills,:and'objective verification (inspection, examination or testing) of end quality is'difficult.
j Special processes identified by applicable codes and standards shall be controlled, qualified, and implemented in accordance with those codes and standards.
Examples of special processes include (but are not limited to) welding, heat treating, and nondestructive examination. Others, (e.g., flushing, protective coating, plating applications and nuclear cleaning) should be reviewed to determine ifthey are special processes.
9.2.2 Procedure uglification 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.
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TOPICAL QUALITYASSURANCE REPORT TQR 9.0 Rev. 13 CONTROL OF SPECIAL PRO CE<SSES FPL Date Pa e 02/28/97 2 of 5 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 Supgll'ystem vendor,~z .
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 for a qualified person to perform the technique and achieve the desired results; A
- 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; Qualified prior to, or during initial use.
Special process procedures and'revisions thereto which specify, acceptance criteria (other than those identified'in the ASME code) shall have the concurrence of the acceptance criteria by Nuclear Engineering prior to issuance and use.
9.2.3 Personnel uglification and Certification Procedures or instructions shall specify personnel qualification and certification requirements. Personnel responsible for the performance and verification of special processes shall be trained, tested, and certified as required by applicable specifications, codes and standards. Requirements for the period of certification, retesting, and recertification of personnel shall also be specified. Contractors-shall
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'OPICAL QUALITYASSURANCE< REPORT T R 9.0 Rev. 13 CONTROL OF SPECIAL PRO CESSEindividuals or groups other than those who performed the activity being inspected. Examinaaions, measurements and tests of materials or products processed shall be performedifor each work operation, where necessary, to assure conformance to established requirements. Ifdirect inspection
./~~ ~
of processed materials or products is impossible or disadvantageous, indirect control by h.
surveillance or monitoring shall be provided. Mandatorytinspection, witness, or hold points beyond which work shall not proceed w'ithout the consent of FPL or a designated representative shall be indicated. in the appropriat 4/3)documents.
10.2 IMPLEMENTATION 10.2.1 Inspection Program A'.~A For plant operations, maintenance, or modification activities, a.program for on-site inspecuon of activities affecting quality shall be established. 'This program shall Qij ensure thorperformance 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.
OGOa&2
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TOPICAL QUALITYASSURANCE REPORT TQR 10.0 Rev. 12 INSPECTION Date 06/03/96 Pa e 2 ot' Protection & 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 the requirements and responsibilities for'the performance of inspections.
10.2.2 Inspection Plans and Schedules Documented inspection plans may be either a separate document or an integral part of work instruction documents. The plans shall be based on design specifications, procurement. documents, drawings, other specifications or previous experience, as appropriate. 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. If sampling is permitted, the sampling procedure shall'e based on nationally recognized standard practices.
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TOPICAL QUALITYASSUIUkNCE REPORT T R 10.0 Rev. 12 INSPECTION Date 06/03/96 Pa e. 3 of 6 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 accordancerwith appropriate codes, standards and/or company training programs. These qualifications and certifications shall:be.
documented.'rior to performing inspections, inspection personnel shall have access to the drawings, procedures, specifications ot'odtewdocumented criteria necessary for
.performance of the inspections 10.2.4 Inspection, Procedures ~
Required inspection~surveillance or, monitoring activities shall be performed and documented according to written, approved instructions or procedures.
- a. /Ins 'ection procedures, instructions or checklists shall contain the
)
fo owing:
o Identification of characteristics to.be inspected; o Identification of the individual,ox.groups responsible for performing the inspection; o Acceptance criteria or reference to the acceptance criteria; o A description of the method of'inspection; o Verification of completion.and.certification of inspection.
Inspection records shall identify:
o Inspector or data recorder; o Method or type of observations;,
o Test or inspection results; orsoaetz,
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. TOPICAL QUALITYASSURANCE REPORT T R10.0 .
Rev. 12 INSPECTION 06/03/96 FPL Date Pa e 4 of 6 o Statement of acceptability; o Date of observation; o Deficiencies and nonconformances, and the action taken in connection with these deficient conditions, either by inclusion or by reference to other documents;
- c. Inspection procedures shall be reviewed by Nuclear Assurance personnel to determine the need fox an independent inspection and the degree and method if such an inspection is required, and to assure the. identification of inspection personnel and the method of documentation of inspection'esults; 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; Modification, repair, replacement or rework items shall be inspected in accordance with original inspection requirements or acceptable alternatives.
10.2.5 Inspection, Witnes's, 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'nd.signed-off by the responsible personnel before work can proceed.
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TOPICAL UALITYASSURANCE REPORT T R 10.0 Rev. 12 INSPECTION 06/03/96 FPL Date Pa e 5 of 6 FPL procurement documents shall indicate FPL witness or hold points applicable
-prior to 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 RESPONSIBILITIES.
10.3.1 Direct Reports of the President, Nuclear Division, and'epartment Heads of organizations supporting the Nucleary)ivision that perform inspection activities
,are responsible for:
- a. Implementation of a program- for inspection activities; b.
. ((2) .
Ensuring that this program verifies compliance with applicable portions of Technical Specifications, SA'R requirements, procurement documents, other, operatinggicensef requirements and the QA Manual; c.
f('.X$. "
Ensuring coordination with!QC for incorporation of QC inspection and hold,'points into procedures and work documents;
- d. censuring that inspections, are not inadvertently omitted or bypassed;.
e.
<D).
Ensuring that personnel assigned to perform inspections .are appropriately
. qualified and certified;,
- f. 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 inspection results.
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TOPICAL QUALHTASSURANCE REPORT T R 10.0 Rev. 12 INSPECTION Date 06/03/96 Pa e 6 of 6 10.3.2 The Director Nuclear Assurance is responsible for:
- a. Implementation of a program for inspection antLsurveillance 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; Reviewing inspection procedures to determine the need for an independent inspection and the degree and method ifsuch an inspection is required, and to ensure the identification of inspection personnel and the method of documentation of inspection results.
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TOPICAL QUALITYASSURANCE REPORT T-R 11.0 Rev. 6 TEST CONTROL Date 02/28/97 Pa e 1 or 4 11.1 GENERAL RE UIREMENTS A test program-shall be established to assure that testing required to demonstrate that structures, systems and components will perform satisfactorily in service is identified,
,accomplished, and documented in accordance with writteniprocedures. The test program shall include, as
. EA.M appropriate, proof. tests prior to installation, pre-operational tests, start-up
.tests, operational tests, and retest following repairsmeplacements or modifications.
11.2 IMPLEMENTATION 11.2.1 Test Program Testing requirements'shall.be'identified in the'engineering/design documents, SAR
.%M~~ Fn) or, procurement documents; as appropriate. Retest documents, Z(
procedures,
'following repair~eplacemen~ts, o modifications shall be performed in. accordance with the"original design and.test requirements or acceptable alternatives. Retest
(~ "o ..
shall.beperformed when the original test results are invalidated: A schedule shall
()~Ax be prov'ded and maintained to provide assurance'that all tests are performed and properly evaluated on a timely basis.
Quality Instructions shall be written which deliheate the methods and responsibilities for'cheduling, 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.
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TOPICAL QUALITYASSURANCE REPORT T R 11.0 Rev. 6 TEST CONTROL Date 02/28/97 Pa e 2 of 4 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 <e...
applicable design 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:
- a. Instructions for. the testing method used (including precautions, limitations, and restoration of normal conditions upon test completion);
- b. Required test equipment hand instrumentation;
- c. Test. requirements and acceptance criteria;
- d. Hold, witness, inspection and data collection points;
- e. 'est 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;
- f. Methods for documenting or recording test data and results; 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.
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TOPICAL QUALITYASSURANCE REPORT TQR 11.0 Rev. 6 TEST CONTROL Date 02/28/97 Pa e 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. having,appro~ri'ate qualifications... The acceptance status of the test-shall be. documented~Deficiencies noted. during the evaluation, shall be documented and.disposition provided in accordance with TQR
(
15.0 and approved Quality Instructions.
The evaluation of the test~esultsmay be delegated to other organizations; however, FPL shall retai'n the responsibility for the evaluation. The evaluating organization shall be required to use qualified personnel, evaluate the data against
. CM~+ <~)
predetermined criteria,'.and document the results of the evaluation and acceptance status of the test.
11.3 RESPONSIBILITIES 11'.3.1 The~SiteiVice 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 Director Nuclear Assurance is responsible for:
- a. Assuring that test, procedures specify necessary quality requirements such as witness and hold pointsand.adequate data sheets.
11.3.3 The Director Protection:& Control Systems is responsible for:
- a. Assuring the 'identification, scheduling,,control, performance, and
',documentation of tests perforined by Protection & Control Systems;
- b. Submitting test procedures to the Plant General Manager for review;
- c. Coordinating test schedules with the Plant General Manager.
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TOPICAL QUALITYASSURM iCE RE<PORT TQR 11.0 Rev. 6 TEST CONTROL Date 02/28/97 Pa e 4 ot 4 11.3.4 The Vice President Nuclear Engineering is responsible for:
- a. Specifying the need for pre-installation and post-installation 'testing of items within the purview of Nuclear Engineering;
- b. Writing test procedures as requested;
- c. Evaluating-test results as requested.
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TOPICAL QUALITYASSURANCE REPORT TQR 12.0 Rev. 5 CONTROL'F MEASURING Date, 02/01/94 FPL 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 department maintaining calibrated instruments to provide for
.the calibration and control of such'instruments.
12.2 PLEMENTATT 12.2.1 Calibration and Control of'Measuring and Test Equipment Procedures shall be written to delineate the. methods and responsibilities for the control',
maintenance, and.calibration'of measuring and test equipment '(M&TE) and.installed plant instrumentation and control equipment... M&TE,control procedures or calibration program documents shall coniain the following: -.'-,,
a A,complete listing of-.METE and installed plant instrumentation and control
..equipment to be controlled; b; ", i, The frequency, of calibration. of listed MEcTE 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 MATE;
- d. A method to uniquely. identify controlled M&TE t(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 M&TE and installed plant instrumentation and control equipment.
0 TOPICAL QUALITYASSURANCE REPORT TQR 12.0 Rev. 5 CONTROL OF MEASURING Date 02/01/94 AND TEST EQUIPMENT 2 of 4 M&TE shall be calibrated in environments which will not adversely affect their accuracy.
When inaccuracy due to environmental effects cannot be avoided, compensating corrections shall be determined and applied in accordance with the manufacturer technical instructions.
M&TE and reference standards shall be suitably marked so that the calibration status can be determined.
FPL may delegate the control and/or calibration of M&TE to other organizations. FPL, however, retains ultimate responsibility for control and calibration, and the contractor shall meet the requirements of this TQR or an acceptable alternative program as required by the procurement document for the contracted services.
12.2.2 Calibration Procedure M&TE, 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 M&TEor 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.
0 TOPICAL QUALITYA'SSURA'NCE REPORT TQR 12.0 Rev. 5 CONTROL OF MEASURING Date 02/01/94 FPL AND TEST. EQUIPMENT 3 of 4 12.2.3 Calibration Standards M8cTE shall be calibrated using reference standards whose calibration has a known, documented,-valid relationship to nationally recognized standards or accepted values of natural physical constants. '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'dequate for the programmatic requirements of the equipment being calibrated.
MEcTE shall be calibrated against. working standards having an accuracy of at least four
.times'the required accuracy, of the equipment being calibrated. 'When this is not practical, working standards shall, have..an accuracy that assures that the MEcTE being calibrated will be within required accuracy tolerances and that the basis of acceptance is documented and authorized. by designated responsible management.
The meaning'of this paragraph may be diagrammed as follows:
~ wmzNATIONALINSTITUTE OF STANDARDS AND TECHNOLOGY (NIST)
"greater than" tolerance PRIMARY STANDARD (ifapplicable)
"greater than" tolerance SECONDARY STANDARD (ifapplicable)
"greater than" tolerance WORKING STANDARD.
"1:4 ratio" tolerance (except as noted above)
M8cTE (installed instruments and measuring and test equipment used for inspection, maintenance, etc.)
The accuracies of M8cTE and reference standards shall be-chosen such that the equipment being calibrated can be calibrated and maintained'within the required tolerances.
Cl TOPICAL QUALITYASSURANCE REPORT TQR 12.0 Rev. 5 CONTROL OF MEASURING Date 02/01/94 FPL 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. M&TE andTeference standards, when found out of tolerance, shall be so identified and removed from service, tagged to indicate its status and segregated from M&TEin service, pending 4
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.
12.3 RE, P N, IBILITIES 12.3.1 Direct reports of the President, Nuclear Division, and Department Heads of organizations supporting the Nuclear Division shall be responsibile for:
a.. 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.
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TOPICAL UALITYASSURANCE REPORT T R 130 HANDLING,STORAGE, SHIPPING Rcv. 10 CLEANNESS CONTROL, AND HOUSEKEEPING Date 02/28/97 Pa e 1 <<t 3 13.1 GE<NERAL RE UIREMENTS Written instructions or procedures shall be established and implemented for the cleaning, shipping, storage, preservation, packaging, and handling of specified items.
These instructions and procedures shall delineate measures which prevent degrading an J/
item through damage or deterioration. When necessary for particular products, special protective environments such as inert gas atmosphere, specific moisture content levels, and temperature levels shall be specified and.provided.
Housekeeping procedures and instructions shall require cleanness to be maintained at a level consistent with the. work performed to pievent the entry of foreign material into safety related systems.>> Control of personn'el, tools, equipment and supplies shall be 0 established with approved procedures or instructions when the safety function of a 4
system, component or item may be jeopardized and also while the reactor system is opened for. inspection, maintenance or repair. Documented cleanness inspections shall be performed prior to system closure.
13.2 IMPLE<ME<NTATION 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.
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TOPICAL UALITYASSURANCE REPORT T R 130 HANDLING, STORAGE, SHIPPING Rev. 10 CLEANNESS CONTROL, AND HOUSEKEEPING Date 02/28/97 Pa e 2 or 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, st~ed, and shipped~-=
accordance with written procedures, where necessary, to implement the design document and purchase order requirements. These procedures shall assure that cleaning, handling, storing, packaging, shipping, and preserving materials, components and systems will preclude damage, loss, or deterioration by environmental conditions, such as temperature or humidity.
Site 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.
TOPICAL UALlTYASSURANCE REPORT TQR 13.0 HANDLING,STORAGE, SHIPPING Rev. 10 CLEANNESS CONTROL, AND HOUSEKEEPING FPL Date Pa e 02/28/97 3 ot 3 13.3 RESP ONSIBILITIE<S 13.3.1 The Site Vice President has overall responsibility for ensuring that handling, storage, shipping, cleanness and housekeeping requirements are identified .and c
implemented.
13.3.2 The Vice President Nuclear Engineering is responsible for:
- a. Identifying special handling and storage requirements for site-fabricated items in applicable design output documents/work instructions;
~
Identifying cleaning and'cleanness verification methods in appropriate specifications, drawings or procedures.
13.3.3 The Director Nuclear Assurance is responsible for:
- a. Verifying proper handling, storage, and shipping activities at supplier facilities;
- b. Verification of housekeeping, handling, storage, shipping and cleanness of items through inspections, surveillances, examinations or tests at the plant site.
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TOPICAL. QUALITY'ASSURANCE,REPORT T R 14.0 Rev. 11 INSPECTION, TEST AND OPERATING STATUS FPL Date Pa e 06/03/96 1 of 2 14.0 GENERAL RE UIREMENTS Measures shall be established to indicate by use of.markings~spch as stamps, tags 4<. A.
labels, routing cards or other suitable means, the status of~inspections and tests performed on material, equipments, or systems. These~easures 17~ M shall. provide for the identification of items which have satisfactorily passed required inspections and tests.
Measures shall also be established for indicating th'e operating status of structures, systems and components to-prevent inadverterit~operations.
14.2 IMPLEMENTATION 14.2'.1 General A suitable system for identif'ying the-inspection, test, and operating status of materials, b'.~J equipment>>,system's>>and components shall be established. Each A.
system shall'be implemented'and maintained in accordance, with written Quality fP ~y Instructions~The Architect/Engineer or Contractors shall develop and implement procedures to comply with contractual responsibilities, and
~< 2) applicable codes, standards, specifications, and criteria governing the status identification of procurement items being. tested, installed, or fabricated. The Architect/Engineer (where, applicable), suppliers and contractors shall be required to maintain a system for identifying the. inspection, test and processing status of materials, parts, and components. Elements of this system require that suppliers and contractors:have a controlled manufacturing and.test operation in order to preclude the inadvertent bypassing, of processing, inspections or test, and to provide a positive identification of component status throughout all phases of manufacturing, testing, and inspecting, by means of tagging, routing cards, stamping, manufacturing or test reports, labeling or other appropriate methods. Methods to verify adequacy of the controls-shall be established and implemented; as appropriate.
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TOPICAL QUALXTYASSURANCE REPORT T R 14.0 Rev. 11 INSPECTION, TEST AND OPERATING STATUS EPL Date Pa e 06/03/96 2 of 2 14.2.2 Status Identification and Control Quality Instructions shall describe control of the application and removal of markings such as stamps, tags, labels, routing cards,~d other suitable. means to indicate the status of non-operational, nonconforming, or malfunctioning nuclear safety related structures, systems and components to prevent inadvertent operation, and to prevent omission of inspections, tests, or other critical operations. These procedures and instructions shall delineate the requirements, methods and responsibilities for indicating the status of the affected items.
These procedures willclearly delineate the individuals or groups responsible for application and removal of status indicators. These procedures shall require independent verifications, where appropriate.to ensure that necessary measures have been implemented.
RESPONSIBILITIES 14.3.1 Direct 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 inspections, test and operating status.
14.3.3 The Director Nuclear Assurance is responsible for assuring that requirements
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are implemented per written instructions and procedures.
Ii TOPICAL UALITYASSURANCE RE<PORT T R 150 Rev. 12 NONCONFORMING MATERIALS, PARTS OR COMPONENTS Date 02/28/97 Pa e 1 or 5 15.1 GE<NE<RAL RE UIREMENTS Measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation. 'these measures shall include, as appropriate, procedures, for, identification, documentation, segregation, disposition and notification to affected organizations. Nonconforming items shall be reviewed and accepted, rejected, repaired'r reworked in accordance with documented procedures.
r; 15.2 IMPLEMENTATION 15.2.1 Program Quality Instructions shall define the responsibilities and methods for identifying, documenting, segregating and providing disposition for nonconforming items.
Throughout plant life, FPL.may delegate any portion of the identification and control of nonconforming items and services to an Architect/Engineer (A/E),
constructor, NSSS vendor or other contractor. In any case, FPL retains the responsibility for assuring that requirements are met, and shall assure that the
~;contractor's actions conform to requirements set by FPL.
15.2.2 Documenting and Controlling Nonconformances All nonconformances 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 disposition is properly provided.
Where physical segregation is not practical, suitable .tags, marking or documentation shall be used to assure control.
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TOPICAL UALITYASSURANCE REPORT T R150 Rev. 12 NONCONFORMING MATERIALS, PARTS OR COMPONENTS Date 02/28/97 Pate 2 or 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 traceabil~it between processing methods a'nd 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.
15.2.4 Evaluation and Disposition Nuclear Engineering, or other delegated organizations, as specified by procedure, shall evaluate nonconformances and provide disposition for 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.
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TOPICAL QUALITYASSURANCE REPORT TQR 15.0 Rev. 12 NON COi DEFORMING MATERIALS, PARTS OR COMPONENTS Date 02/28/97 Pa e 3 or 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 with a disposition of "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 items to FPL.
I The determination of the need and the advisability of releasing nonconforming '(
items shall be initiated by the=Site-Vice President, and approved by Nuclear Engineering. The following factors may be appropriate considerations in making this determination:
- a. Effect, on the orderly progress of work if items are released; I
- b. -
Safety of personnel; ~
c,, Suitability of items in "as-is" condition, i.e., probability of eventual ~.
satisfactory resolution of the nonconformance without repair, rework, or replacement;
- d. Accessibility of items after release;
- e. Cost of removal and repair of replacement should 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.
0 TOPICAL UALITYASSURANCE REPORT TQR 15.0 Rev. 12 NONCONFORMING MATERIALS, PARTS OR COMPONENTS Date 02/28/97 Pa e 4 of 5 15.3 RESPONSIBILITIES 15.3.1 Direct reports of the President, Nuclear Division, and Department Heads of organizations supporting the Nuclear Division are responggle 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 o'rganizations;
- d. tracking and control of open nonconforming items within the scope of their departmental responsibilities;
- e. providing disposition and verifying the resolution of nonconforming items
~
within the scope of their departmental responsibilities;
- f. periodically assessing quality trends related to nonconformances.
15.3.2 The Site Vice President is responsible for:
- a. supplier notification and follow-up of nonconformances requiring supplier corrective actions.
- b. initiation of release of nonconforming material for use.
15.3.3 The Director 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.
il TOPICAL QVALITYASSURANCE< REPORT T R150 Rev. 12 NONCONFORMING MATERIALS, PA'RTS OR COMPONE<NTS Date 02/28/97 Pa e 5 of 5 15.3.4 The Vice President Nuclear Engineering is responsible for:
- a. the review, evaluation,.and-disposition of nonconformances submitted by other departments; approval of release of nonconforming ite'ms; supplier notification and follow-up,of nonconformances requiring supplier corrective actions.
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TOPICAL UALITYASSURANCE REPORT TQR 16.0 Rev. 10 CORRECTIVE ACTION 10/16/96 FPL Date Pa e 2 of 4 "Routine Corrective Action" applies to conditions which do not require immediate corrective action. Routine corrective action is assured through the distribution and disposition associated with -inspection reports-,
surveillance reports, nonconformance reports, and audit reports; and the investigation analysis and action associated with reportable 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 closeout 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'nspections, tests, or operations.
If corrective action is inadequate or not timely, the follow-up.organization shall request corrective action from management, as delineated in procedures. The President Nuclear Division is the final authority in the event that agreement is not reached at lower levels regarding stop work requests or other corrective action.
Where corrective action. is required of contractor personnel, FPL shall define in procedures and contracts the corrective action interface between FPL and the contractor. FPL shall require the A/E, NSSS vendor, constructor and other suppliers of safety related materials and services to have a documented corrective action system.
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'OPICAL VALITYASSVItANCE REPORT TQR 16;0 Rev. 10 CORRECTIVE ACTION FPL Date Pa e 3 10/16/96 Of 4 16;2.'2 Recurrence- Control It is the responsibility of the organization which identifies the significant condition adverse to quality to verify that corrective action~description not only corrects the immediate condition,. but also precludes the condition from recurring. The organization(s) that provide(s) the corrective action disposition and implementation is responsible.to assure that the coirective action taken ndt only corrects. the immediate condition, but also recludesirecurrence.
16.2.3 Incidents and Reportable.E ents A
eporting documented x~~
Operating repoitablMevents and reports .of incidents shall be investigated, (Cz.
as~to cause and corrective action, and reported to the NRC in accordancei with the applicable plant Technical Specifications and Federal Regulation . Re ortable>events and.reports of incidents. that are safety rel'ated or-that result
((
(( it in;damage shall be (CNRB) for review.
forwarded to the Company-Nuclear Review Board Conditions adverse to quality. are reported to operating plant management through: distribution of QA audit. reports, QC inspection reports, J
corrective action requests, and the investigation and reporting of reportable events in accordance with plant Technical Specifications.
16.3, RESPONSIBILITIES 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.
16.3.2 Direct reports of the President Nuclear Division and Department Heads of organizations supporting the Nuclear Division. are responsible for:
- a. Assuring that timely. corrective action within their respective organization;
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, TOPICAL UALIIVASSURANCE REPORT TQR 17.0 Rev. 5 QUALITYASSURANCE RECORDS 10/16/96 FPL Date Pa e 1 tsr 5 17.1 GENERAL RE UIREMENTS Sufficient records shall be maintained to furnish documentedwvidence of the quality of 4
safety related structures,,systems, and components, and~of activities affecting their quality. The records shall include, as appropriate,'data such as qualifications of personnel, procedures, and equipment; and other documentation such as inspection or test acceptance criteria, and the action taken in connection withdeficiencies noted during inspection.
The records required to furnish documentary-evidence of quality, herein called quality assurance records, shall be identifiable and.retrieva le. These records shall be maintained 4~w .cv) in facilities that provide a suitable
'V environment to minimize deterioration or damage and to prevent loss.
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The requirements and responsibilities for quality assurance record control, transmiuai, retention~and~ maintenance shall be established and documented. These record requirements shall be consistent with applicable design, manufacturing, and installation codes and standards, and with procurement document requirements.
17e2 IMPLEMENTATION 17.2.1 Records Identification and Classification 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.
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TOPICAL UALITYASSURANCE REPORT TQR 17.0 Rev. 5 QUALITYASSURANCE RECORDS Date 10/16/96 Pa e 2 or 5 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. Retention times shall be established for each record series and provided to the Records Official.
17.2.2 Completeness and Control I
Quality assurance records submitted for retention shall be legible, completely filled out, and adequately identifiable and retrievable for each item.
Quality Instructions shall include methods for handling corrections and supplements,to existing QA records.
17.2.3 Retrieval Records shall be filed in an approved record storage area or facility using a documented system to provide retrievability. Documented methods for control and accountability of records removed from the record storage area shall be instituted.
17.2.4 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 record storage area or facility ~
shall be given for special processed records (e.g. radiographs, magnetic media, and microfilm, etc.).
TOPICAL VALITYASSURANCE'EPORT T R 17.0 Rev. 5 QUALITYASSURANCE RECORDS Date 10/16/96 Pa e 3 or 5 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 QA Supervisor Performance, Assessment, a.Risk Management Representative>and the 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 record storage facilities and the adequacy
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of additional record storage~facilities prior to the, construction. of a new
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facility or the conversion-of existin~structures.
When tempora~ystorage of records,.(such as for processing, revi w, or use) is an.organization's'procedures, the records shall be stored in a QARSET 'equire@'by approved container. 'The maximum allowable time limit.for temporary storage. is 24~onths.
'The. requirements of the Topical Quality Assurance Report, Appendix C shall be utilized in. the evaluation of potential permanent and, temporary record storage facilities.
17.3 RESPONSIBILITIES 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. the technical content and accuracy of the records they generate;
,b. transmitting records and indexing information, to the appropriate record
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storage facility or requesting approved storage locations from QARSET;
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TOPICAL UALI'IVASSURANCE'REPORT TQR 17.0 Rev. 5 QUALITYASSURANCE RECORDS Date 10/16/96 Pa e 4 ot 5 C. establishing and approving a list of quality assurance records generated
)
by the organization and their retention times and assuring that these quality 4
assurance records are identified in the appropriate quality-assurance record-index; the storage and retrieval of quality assurance records prior to transmittal to permanent record storage facilities; performing periodic surveys to ensure that their record control system is adequate; transmitting a copy of the records retention schedule to the Records Official for all records maintained by their organization.
17.3.2 The Records Official is responsible for:
- a. ensuring the quality assurance records program activities are managed in accordance with applicable recordkeeping requirements;
- b. reviewing and retaining copies of record retention schedules received from originating departments; locating acceptable record storage areas when requested; I
leading the evaluation of specially designated QARSET approved record
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storage facilities, maintaining records of this evaluation, and establishing schedules to assure that re-evaluations are performed every two,(2) years.
17.3.3 The Plant Vice President is responsible for:
- a. the storage, retrieval, and control of quality assurance records at the site.
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17.3.4 The Corporate Records Supervisor is responsible for:
- a. storage, retrieval, and control of records and documents stored at the Corporate Records Center and Documentary Files.
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TOPICAL UAKJHY ASSURANCE MH'ORT TQR 17.0 Rev. 5 QUALITYASSURANCE RECORDS 10/16/96 FPL Date Pa e 5 of 5 17.3;5 The Quality Assurance Record Storage Evaluation Team (QARSET) is responsible for:
a..evaluating the acceptability of storage locations for quality msurance records;
- b. ensuring that evaluations of recor storage locations. are perfohned every two years.
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TOPICAL QUALITYASSURANCE T R180 REPORT'UDITS Rev. 9 Date 06/03/96 Pa e 1, of 5 IS.I GENERAL RE UIREMENTS A comprehensive system of planned and periodic audits shall be'carried out to verify compliance with all aspects of the quality assurance program>and to determine Qe .
effectiveness of the program. The audits shall be performed in~accordance with the written procedures or checklists by appropriately trained personnei not having direct responsibilities in the areas. being audited. Audin results shaH .be documented and reviewed by management having responsibility in the area audited. Follow-up action, including reaudit of deficient areas, shall be taken; here necessary.
18;2 IMPLEMENTATION A'omprehensive program of audits is camed outhby'the Quality Assurance Department during the design, procuremen+t, construction, and..operations, phase of nuclear power
'..4 2) plants. These audits are erformed towerify that all safety related'ctivities associated with nuclear power plants are carried':out in accordance w'ith.the requirements of the FPL QA Program,. and that the implementation is effective.
18.2.1 Personne 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 qualified 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 Instructions provide requirements for written audit. plans and'schedules.
The audits are planned and scheduled on the basis of the following:
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TOPICAL QUALITYASSURANCE REPORT TQR 18.0 Rev. 9 AUDITS Date 06/03/96 Pa e 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; 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 I
evaluations; (
Audits shall be regularly scheduled for. on-going activities; Regularly scheduled audits shall be supplemented, as required to cover unforeseen events or changes in requirements.
The scope of audit activities shall include, as a minimum:
- a. The determination of site features which affect plant safety (e.g., core sampling, site preparation, and meteorology);
The preparation, review, approval, and control of:the SAR, designs, specifications, procurement documents, instructions, procedures, and drawings;
il 0
Ii
'OPICAL QUALITYASSURANCE REPORT T R180 Rev. 9 AUDITS 06/03/96 FPL Date
,Pa e 3 of '5 c; Evaluation of bids;
- d. Indoctrination and training programs; e.. Receiving and plant inspections;
. f. Operation, maintenance/repair and modification;
- g. The implementation of operating and test procedures;.
- h. All criteria in Appendix B to 10'C 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 activ'ities. Procurement'documents shall reauire that FPL suppliers and contractors
'in turn perform audi~ts~o their'sub-tier-suppliers.and contractors.
18.2.3 Conduct oftAudits Quality'Instructions shall delineate requirements for the conduct of audits. These instructions shall require. that:
- a. Audits be conducted by trained;and qualified personnel; Personnel conducting audits shall not have direct responsibility in the area audited; C. Checklists or instructions shall be used to ensure depth and continuity. of audits; Objective evidence shall be examined for compliance with quality assurance program requirements.. This shall include examination: of instructions and activities to assure that documented objective evidence. is meaningful and in compliance with the overall Quality Assurance Program;
II 0
0
TOPICAL QUALITYASSURANCE REPORT T R 180 Rev. 9 AUDITS Date 06/03/96 Pa e 4 of 5
- 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.
18.2.5 Follow-up Responsible management of the audited organization shall take action to correct the deficiencies identified in the audit report and provide a written response within thirty calendar days after receipt of the report. This response shall include action taken and/or planned to correct deficiencies and to prevent recurrence of the deficiencies, and commitment dates for actions not yet complete. The mechanism for evaluation and follow-up of corrective action is described in TQR 16.0. The status of correction of deficiencies shall be followed until the corrective actions have been accomplished and 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 This status report summarizes the results of QA Department audit 'CNRB).
activities for the period, keeps all CNRB members apprised of current conditions and program effectiveness, and when necessary, directs management attention to trends and problems. 'ignificant
0 II
TOPICAL QUALITYASSUIVkNCE REPORT T R 180 Rev. 9 AUDITS 06/03/96 FPL Date Pa e 5 oi 5 18.3 RESPONSIBILITIES 18.3.1 Direct reports to the President, Nuclear Division, and Department Heads of organizations supporting the nuclear division shall be res onsible for:
- 1. Taking action to correct. deficiencies. identified, in audiVreports;
- 2. Providing a written response within thirty, (30),calendar days of receipt the audit report.
a.
/~
18.3.2 The. Director Nuclear Assurance is responsible Scheduling audits on a regular basis;
'ta~j for the following:
- b. Selecting the audit. team and theeead~Auditor;
.%~~> <<A c.
'v Reviewing each audit report for accuracy, completeness, proper format and d'.
distribution; Q
Designating a,quahfied replacement Lead Auditor (in writing) if the audit
<( 0, team. leader transfers from the respective QA group or is otherwise unable
(~.> .
to continue the assigned audit;
- e. e'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.
4l e
CN JlAHAN Ot TNCOOARO .
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CIOtt CSCCVIIIE OFHCE A tACSKCNT tAKSKNNT CCNKAALCOVkSCL FLOaDA foWCA AND HVCLEAR CSWSION I UCNT SCCAtfAAT COMPANY NVCIEAA REVIEW SCARC SKE IVIVRC 11 VICE tAt Vol kf OF tACC I OF I HIFORMANCM HAHACKNCHT VICC PRCSIOKNT OOICCIOR VICE PRESIDENT VICE PRCSeckf CIRKCTOR NUCLEAR NUCIEAA SUINCSS ST. LVCC NANT TURKEY Potff PLANT HUCLCAR ASSVAAHCC tkcwccako SERF+CO SEC ROVAt 11 OF tACC I Ot I SPCCIRCSNC HANACCA 0 Ao ANKATIDM ot tfsta sff t IIAHACKA PLANT StklACKS OAOAIOTATION TUAKKYPOINT OI FIO. f4 CHCIHttako VICt tAtSOCNT IMIKLI.S OA OVPKAVNOA tASSCSIUCNT C A PORN AHC C NANACKA POWER DCUVCAY NAHACCA tAIStokf SERVICES MJCLCARUCCNSPIO V IIANAOKR ANDSPCCIAL tAOCAAN I CoktOHCMT SVtPOAT MAN ACE A I VIS SECTION OVAUTY ASSV RANCE COMPUTER SKAIVCCO SCC IVSURE 11 PAOOAAN RtlhCW Cokkffftc OF PAOC I OF I OUttAVISOA HANAOCR'/ WSHNII PIANNINO Of.LVCIC/ AI OA OUPCRVISOA I ttRIOANANCC tROCVA tllCkf OVAUTY ckcolcca>>o +
f HANAOCR OVAUfYNANAOCR HUCIE*R TVAKtYtfkkf/
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OVAUTYCONTROL DISCVUNE SottRVNOAO CICCF CNCOIECRS OV PCRVI SON NVClt AA SAFETY It t SNOUT TOPICAL QUAUTY ASSURANCE REPORT REVISION 25 WPCAVOCA CkAO ORGANIZATIONOF DEPARTMENTS AFFECTING QUALITY 04/30/97 FIGURE 1-1 APPENDIX A PAGE1 OF 2 NUCLEAR DIVISION
0
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CHAIRMANOF THE BOARD CISEF EXECUTIVE OFFICER PAESeENT FLORIDA POWER A LICHf GENERAL CODNSEL ANO SECRETAAY VICE PAESI DENT INFORMATION MANAGEMENT DNECTOA ENVIRONMENTAL SEAYICES MANACEA DSECTOR BVQNESS SYSTEMS COAPORAT E AECOAOS SUPERVISOR ISAECTOA VT OPERATIONS DSECTOA PROTECTION A CONTROL SYSTEMS DSIECTOA PLAICSNC A CONTROL TOPICAL QUALITYASSURANCE REPORT REVISION 25 ORGANIZATION OF DEPARTMENTS AFFECTING QUALITY 04/30/97 FIGURE 1-1 APPENDIX A PAGE 2 OF 2 NUCLEAR DIVISION
il 0
VICE PRESIDENT TURKEY POINT PLANT'LANT
~ GENERAL RESOURCES MANAGER'ATERIALS UCEN SING MANAGEMENT BUSINESS SYSTEMS PTN ENGINEERING MANAGER MANAGER'T MANAGER'LANT MANAGER'RAIMNG ECON CAL SUPPORT)
CHANGE CONTROL MANAGER OPERATIONS SUPPORT SUPERVISOR'ERVICES SUPERVISOR ENCTIEERTIO VPERVISOR'REACTOR ENCNE FIRE SAFETY SECURIlY ERNGI'STAsI'AND SUPERVISOR LmLI2ATION PLANT ENGINEERING SITE MANAGER SUPERINTENDENT ADMINISTRATIVE CONTROL OPERATIONS SUPERVISOR
&n MANAGER MANAGER'
'aC SYSTEMS ENGINEERING MAINTENANCE MANAGER OPERATIONS >
SUPERVISOR'+
SUPERVISOR'. ~
SUPERVISOR'ANAGER MECHAMGAL SUPERVISOR'ORK gMAINTENANCE SUPERVISOR <
NUCLEAR PLANT '
HEALTH PHYSCS CHEMISTRY ~GCSTRY TECHNCAL SUPERVISOR SUPERVISOR MAINTENANCE SUPERVISOR MAINTENANCEQ SUPPORT'UPERVISOR PRCUECTS SUPERVISOR
'Indicates position with accountabilities in Technical Specifications.
TOPICAL aUALITYASSURANCEREPORT
~ Although Operations Support Engineering (OSE) personnel may report to the REVISIOII 12 site Engineering Manager, the Plant General Manager shall have direct and unfettered control over those activities necessary for safe operation and TURKEY POINT PLANT maintenance of the plant. osr18/97 SITE ORGANIZATION FIGURE 1-2 C>
O
~ The Health Physics Supervisor shall have direct aocess to the Plant General M Manager for matters relating to the radiological health and safety of employees APPENDIX A PAGE 1 OF 1 N and the public.
0 0
P
VICE PRESI CENT ST. LUCIS PLANT RESOURCES UCENSING STEAM GENERATOR MATEILALS BUSINESS SYSTEMS PSL ENGINEERING MANAGER'ERVICES PtANT GENERAL MANAGER'UMAN MANAGER p Q MANAGER'EPLACEMENTMANAGER MANAGER MANAGER I) MANAGER'NrORMATION opERATloNs soppoRT ENCNEERNO SVPEAVSOR'REACIOR ENGPIEERt4OI'STAA)
SERVICES SUPERVISOR C3~
" PIANT ENGINEERING P
PROTECTION SERVICES SUPERVISOR SECURITY SUPERVISOR r/ MANAGER AOMIN!STRATIVE LANG SUPERVISOR URUTATION SUPERVISOR SYSTEMS ENGINEERING MANAGER 0 0 MANAGER'PERATIONS WORK CONTROL MANAGER'PERAllONS SUPERVISOR'HEMISTRY SUPERVISOR'aC MAINTENANCE SUPERVISOR'EECIRICAL MAINTENANCE SUPERVISOR'AINTENANCE PROCE CURES SUPERVISOR ROTATING EQUIPMENT SUPERVISOR'MECHANI GAL)
VALVESa WELOING
~
SUPERVISOR'ECHAISCAl TOPICAL Q ALITYASSURANCEREPORT
'indicates posibon with accountabilities in Technical Specifications. ST. LUCIE PLANT, UNIT 1 tt: 2 SITE ORGANIZATION , 03/2ar97 HQIE FIGURE 14 O Although Operations Support Engineering (OSE) pe'rsorinel may report to the Site Engineering Manager, Ci APPENDIX A PAGE1OF1 M the Plant General Manager shall have direct and unfettered control over those OSE resources I4 necessary for safe operation and maintenance of the plint.
0 TOPICAL QUALITY ASSURANCE. REPORT APPEND1X B Rev. 5 QUALIFICATIONAND EXPERIENCE REQUIREMENTS FOR FPL QUALITY Date gi ASSURANCE PERSONNEL FPL Page 1 of XIXEEd Q uality, Managers, (JB/PTN/PSL)
.:Mi.
Shall satisfy the following set of,requirements:
Graduate of a four year~accredited engineering or science college or university, plus seven years. of industrial experience, including, five (5) years in positions of leadership, such as lead engineer," pandect engineer, audit team leader,'tc/At least two (2) years of this Gve (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 ymasters deg(ee in engineering or business management is considayd equivalent to two (2) years of general'industry.
experience.
The education and.etqtedenee requirements should not be treated as absolute when similar triitung or. an outstanding tecord willprovide reasonable assurance that a petson can perform the tequited tasks.
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TOPICAL VALI'XVASSURANCE RRZ'ORT APPENDIX C Rev. 15 BASELINE DOCUMENT MATRIX Date 10/16/96 Pa e 2 ot 24 REFERENCE INDUSTRY DRAFT REV.
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 BAPV Code Specified in the Section III 4 SAR document of XI the respective plant Regulatory Guide 1.8 Rev. 1 9/75 ANSI-N18. 1 1971 ANSUANS 3.1 1978 Regulatory Guide 1.28 6/7/72 ANSI-N45.2 1971 egulatory Guide 1.30 8/11/72 ANSI-N45.2.4 1972 egulatory 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 egulatory Guide 1.123 Rev. 1 7/77 ANSI-N45.2.13 1976 egulatory Guide 1.144 Rev. 1 9/80 ANSI-N45.2.12 1977 Regulatory Guide 1.146 8/80 ANSI-N45.2.23 1978
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ik TOPICAL QUALIIVASSUI~CE REPORT APPENDIX C Rev. 15 BASEL'INE DOCUMENT MATRIX, Date 10/16/96 Pa e 7 of 24 Re ulato Guide 1.38 Rev. 2/ANSI N45.2.2 - '1972 FPL will meet the requirements:of'Reg. Guide 1.38, Rev. 2~position 2C,.D and E&r-safety related applications during preoperational.and operational actiyitIes.'estrictions 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 withraustenitic stainless. steel or nickel alloy materials.
Vapor burner material (other than. metal) shall be colored.to contrast with or be otherwise distinguishable:from.safety rethted systems to+prevent undisclosed. entry into the system.
o These requirements do,not'apply to components in storage which would require removal. of. such jf tapes and barriers.tb effect installation)
ANSI N45.2.2-1972 Section 2.7 requires that items governed. by this standard be classified into
'i~~)
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:
- l. 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.
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TOPICAL VALITYASSURANCE REPORT APPENDIX C Rev. 15 BASELINE DOCUMENT MATRIX 10/16/96 FPL Date Pa e 10 or 24 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.
Re ulatorv Guide 1.39 Rev. 2/ANSI N45.2.3-1973 For FPL's operating nuclear plants, alternative methods are followed to achieve equivalent objectives for the below listed sections of ANSI N45.2.3-1973:
The zone designations of Section 2.1 of N45.2.3 and the requirements associated with each zone are not consistent with the FPL Housekeeping requirements at our operating nuclear units.
In lieu of the zone designation,. cleanliness is maintained at a level consistent with the work being performed, so as to prevent. the entry of foreign material into safety related systems.
Documented cleanliness inspections are performed immediately. prior to system closure. Control of personnel, tools, equipment, and supplies is established with approved procedures when the safety function of a system, component, or item.may be jeopardized and also while the reactor system is opened for inspection, maintenance, or repair.
Re ulatorv 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 ply to personnel who perform inspections, tests or nondestructive examinations or who articipate in the approval of procedures, the handling of data or test results, or the control of reports and records.
0 0
41
TOPICAL UALIHTASSURANCE REX'ORT APPENDIX C Rev. 15 BASELINE DOCUMENT MATRIX Date 10/16/96 EPL Pa e 11 ot 24 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-toke.qualified and competent
.. C%
by management through consideration of education, training, and,experience.
The Florida Power k, 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 f~
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.
n For leak testing conducted as part of'the preoperational and operational testing programs, FPL considers that the qualification requirements oflRegulatory Guide 1.8 (ANSI N18.1-1971) and ANSI N45.2.6-f978! Paragraph 3!0 to be an acceptable alternative to SNT-TC-IA-f975 requirements for leWtesttng, except forleak testing defined in and performed under the ASMF
(
Code, where in such;cases, the appropriate section of the Code shall govern.
For preoperational and operational inspection, examination and testing by Quality Control Inspectors, FPL considers that Position C.l of Regulatory Guide 1.58, Revision 1 and ANSI N45.2.6-1978, Paragraph 3.0 are acceptable requirements for training and.qualification, except for inspections, tests and examinations defined in and performed under the ASME Code, where in such cases, the appropriate section of 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 G'uide 1.8 are sufficient for the type and scope of activities performed and that qualifications to ANSI N45.2.6-1978 is unnecessary and redundant. These preoperational and operational inspections, examinations and tests shall be supervised or directed by personnel qualified to Position C.l of Regulatory Guide 1.58, Revision l.
0 0'
TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev. 15 BASELINE DOCUMENT MATRIX FPL Date Pa e 10/16/96 12 or 24 FPL shall comply with Position C.10 of Regulatory Guide 1.58, Revision 1, effective with Revision 4 of the Topical Quality Assurance Report, in that all new certifications issued for personnel shall meet the education and experience requirements or shall document objective-evidence demonstrating that the individual indeed does have comparable or equivalent competence to that which would be gained from having the required education and experience.
FPL's position on ANSI N45.2.6-1978, Paragraph 2.3 is that an initial and periodic review (not to exceed two years) of personnel shall determine the capabilities in his qualified area. If during this review, or-at any other time, it is determined that the individual's capabilities are not in accordance with the specified requirements, that individual shall be removed from that activity until the required capability has been demonstrated. In addition, during this review a etermination shall be made that an individual has been actively involved in the inspection process in his qualified area.
Reeulator Guide 1.64. Rev. 2/ANSI N45.2.11-1974 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 dependently verified). Justification for verification by the designer's immediate supervisor hould be documented along with the extent of the supervisor's involvement in the design.
ik TOPICAL VALHYASSVRANCE REPORT APPENDIX C Rev. 15 BASELINE DOCUMENT.MATRIX FPL Date Pa e 10/16/96 13 or 24 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 aMn'dnstructions are included in FPL's Quality Assurance Program documentation. The Quality Assurance Department eve)nates all of this documentation in reviews performed during~its development. and revision.
Accordingly, FPL, does not require subsequent (' 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.
O~
~Q, Regulatory Guide 1.68"~lt/73) entitled upreoperational'and Initial Start-up Test programs for Water Cooled
.t,(
ower+Reactors" is~addressed in Section 14.2.1'.of the St. Lucie Unit 2 FSAR
(
which states in part,~yThe start-up test program is developed using the recommendations of Regulatory Guide .<
1.68". 'To avoid duplication of requirements,.FPL will address Regulatory, J
Guide '1.68'in",the FSAR.
Reeulato 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.
0 TOPICAL UALITYASSURANCE REPORT APPENDIX C Rev. 15 BASELINE DOCUMENT MATRIX Date 10/16/96 Pa e '14 of 24 FPL has developed a glossary of terms and their definitions as part of the Quality Assurance Manual which is being used throughout its nuclear construction and operating-plant activities-.
The following .definitions are currently listed in our glossary and are. alternatives or clarifications to those listed in the ANSI Standard and Regulatory Guide:
Assembly A combination of subassemblies or components or both, fitted together to form a workable unit.
A documented activity performed in accordance with written procedures or checklists to verify, by examination and evaluation of objective evidence, that applicable elements of the quality assurance program have been developed, documented and effectively implemented'in accordance with specified requirements.
An-audit does not include surveillance or inspection for the purpose of process control or product acceptance.
Guidelines .Particular provisions which are considered good practice but which are not mandatory in programs intended to comply with Standards.
The term "should" denotes a guideline; the term "shall" denotes a requirement; and the word "may" denotes permission, neither a requirement nor a recommendation.
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TOPICAL QUALI'IVASSURANCE REPORT APPENDIX C Rev. 15 BASELINE DOCUMENT MATRIX FPL Date Pa e 10/16/96 16 or 24 Quality Control Those quality assurance actions related to the physical characteristics or material, structure, component-or system, which-a means to control the quality of the material, structure, 'rovide component or system to predetermined requirements.
Storage That period following the release of an item for shipment until turnover for start-up preoperational testing. This would include inplace storage.
System An integral part of a nuclear power plant comprised of electrical, electronic, or mechanical components (or combinations thereof) that may,be operated as a separate entity to perform a specific function.
Testing Performance of those steps necessary,to determine that systems or components function in accordance with predetermined'pecifications.
"Re uirements" Clarification for Glossa
~EII IIEMBNT: 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.
0 TOPICAL UALI'ITASSURANCE iREPORT, APPENDIX C Rev. 15 BASELINE DOCUMENT MATRIX Date 10/16/96 Pa e 17 .or 24 Re ulato 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 FPL provides the following definitions as an alternative to the above.
/~V'tandard.
Lifetime Records: Records which are required by the.NRC facility operating license, the NRC construction permit, applicable parts of OCFR; the FSAR, or other NRC commitments to be retained for the life of the plant.
.Cow Non-permanent Records:
x~4 Record's~which are required by the NRC the NRC construction permit, applicable parts of 10CFR, facility operating license, the FSAR, or other NRC commitments to be retained for periods.of, time less than-the life of the plant.
ANSI N45.2.9-19+4)requirements for Section 5.6, "Facility", are clarified'y 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 (QARSET) shall be responsible for determining methods utilized to assure that QA Records are adequately stored and protected.
The QARSET shall consist of the following: .the QA Supervisor Performance Assessment, a
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Risk Management Representative and the 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.
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TOPICAL VADE ASSURANCE REPORT APPENDIX C Rev. 15 BASELINE DOCUMENT MATRIX FPL Date Pa e 10/16/96 21 ot 24 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 cheoked 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) requiresithat 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.initiall'laced 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 of following controls are.provi'ded in'.th~eFPL
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issuance Quality a written. purchase order. The Assurance Manual to assure that the intent
(( Cq of ANSI N45.2:13 isisatisfied fo~Confirming Purchase Orders".
~Q Prior to~verbally placing the order, it must be verified that the intended supplier is on (1) y~j the FPL'uality 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.
Section 8.2 of ANSI N45.2.13 identifies those nonconformances which shall be submitted to the Purchaser. Florida Power 8c Light's.(FPL) position regarding the nonconformances to be reported is as follows. Suppliers (including A/E's and Contractors) shall submit all nonconformances which consist of one or more of the following:
- 1) Technical or material requirements are violated.
- 2) Requirement in. supplier documents which have, been approved by the Purchaser
.is violated.
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TOPICAL UALHT.ASSURANCE REPORT APPENDIX C Rev. 15 BASELINE DOCUMENT MATRIX FPL nate Pa e 10/16/96 23 of 24 In the case of suppliers, an annual evaluation of quality performance history shall be performed to determine reaudit requirements. Reaudit requirements for>uppliers shall be based-on the Cg quality performance, and the complexity and criticalit -of>thegequipment 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 0.
confirm the audit scope, present the audit plan, introduce auditors, meet counterparts, discuss audit sequence and plans for%the postaudith conference, and establish channels of communication." FPL will not requyie the re-audit conference for audits of limited scope and of specific site activities conducted by
~J the Construction and Operations Groups.
conference is omiued because the.day-to-day contact of the auditors and plant management, This
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the awareness on. the cartof piant'management that these audits are conducted without pre-audit conferences, andithe limited scope of the audits meet the intent of a pre-audit conference.
ANSI Standard N45.2.12-1977, Paragraph 4.5.1 states in part "The audited organization shall provide a follow-up report stating the corrective action taken and'the date corrective action was completed". The FPL QA Program requires the QA Department to followup on all action taken by the audited department. This is documented on the corrective action followup form by the QA Department and closed by the QA Department instead of the audited department. This assures that all actions taken by the audited department are verified by the QA'Department and that the QA Department concurs with the resolution. We feel that it is appropriate for this to be documented by the QA Department instead of the audited department.
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TOPICAL QUALITYASSURANCE'RRZ'ORT APPENDIX C Rev. 15 BASELINE DOCUMENT MATRIX FPL Date Pa e 10/16/96 24 or 24 Plannin Clarification ANSI N45.2.4-1972, Paragraph 2.1; ANSI N45.2.6-1973, Paragraph 2.1; ANSI N45.2.13-1976, Paragraph 7.2; ANSI N18.7-1976/ANS 3-2, Paragraph 5.2.7.1; ANSI r
N45.2.8-1975, Paragraph 2.1 and Paragraph 2.2 include plans and/or planning as required.
The terms plan and/or planning are included in FPL's acti'vities as indicated in the following clarification:
Planning is considered to be a management process or analytical tool used as an aid to help develop identification and/or development of program requirements, implementation activities, assignments and staffing, inspections, surveillances and audits, controls and other activities to assure completeness of the requirements. Planning, as such, is not always documented nor addressed as an end item and is considered to be an integral "process" within the developed item.
Plans which are considered to be end type or output type documents have the term "plan" in the title,.such as ISI Master Plan, Audit Plan, Start-up Plan, and others, which as such will reflect directly the requirement of these standards in the appropriate documents.
Plans which are not considered to be end type or output type documents do not'have the word plan in the title. However, certain procedures, instructions, flow charts, schedules and checklists may be considered to be plans reflecting planned actions which especially require step-by-step accomplishments. In these cases, the term plan may not appear in the title but considered to be a plan only in the indirect sense and identified as a procedure or other document. FPL considers the above practice to be in compliance with the "plan" requirements of these standards.
0 TOPICAL QUALITY,ASSURANCE REPORT. APPENDIX D R~. N/A GRAY, GREEN,. AND ORANGE BOOK Owe Mgy 7 $ 98/
MATRIXTO QA PROCEDURES Page g of APPENDIX D f(
"GRAY, GREEN,-AND ORANGE BOOK MATRIXTO'QA PROCKOURES Oi CV E
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TOPICAL QUALITYASSURANCE REPORT APPENDIX E Rev. 19 LIST OF CORPORATE QUALITY ASSURANCE PROCEDURES Date 04/26/96-Pace 1 nf 1 This Appendix has beeneleted in its entirety.
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TOPICAL QUALITYASSURANCE REPORT APPEND1X F C
Rev.
TOPICS TO BE ADDRESSED IN Dete May 7, 1982 SAFETY ANALYSIS REPORTS page 1 at 1 The FPL Topical Quality Assurance Report is-the statement of Florida Power Sc 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 identi6cation of the involvement of principal contractors such as the AtchitectjEngineer, Nuclear Steam Supply System vendor, or Constructor. Me.contractor involvement in, the Program willbe descxibed in the plant. Safety Analysis. Report. In addition,.other detailed<aspects of the Quality Assurance Program vary &om plant-to-plant or with plant site. These aspects will also be described in the plant X
The requirements of the FPL Quality Assurance Program shall'pply.to the nuclear safety "Vp'AR.
"i related structiites, systems and components as defined in,the applicable plant SAR.
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