L-2019-119, Quality Assurance Program Description for 10 CFR Part 52 Licenses FPL-2 Revision 5
| ML19164A110 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 06/11/2019 |
| From: | Franzone S Florida Power & Light Co |
| To: | Document Control Desk, Office of New Reactors |
| References | |
| L-2019-119 | |
| Download: ML19164A110 (174) | |
Text
{{#Wiki_filter:L-2019-119 10 CFR 50.55(f)(4)(i) June 11, 2019 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 Re: Florida Power & Light Company Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 Florida Power and Light Company Quality Assurance Program Description for 10 CFR Part 52 Licenses FPL-2 Revision 5
Reference:
- 1. FPL Letter L-2018-123 to NRC dated December 6, 2018, Florida Power and Light Company Quality Assurance Program Description for 10 CFR Part 52 Licenses FPL-2 Revision 4 (ADAMS Accession No. ML18344A463)
The purpose of this letter is to provide the Nuclear Regulatory Commission with Revision 5 of the Florida Power & Light Company (FPL) Quality Assurance Program Description for 10 CFR Part 52 Licenses (QAPD FPL-2; Enclosure 1). This QAPD was developed to accommodate combined license activities for Turkey Point Units 6 and 7 and any future nuclear power units pursued by FPL in accordance with 10 CFR 52. The changes made in this QAPD revision have been reviewed in accordance with 10 CFR 50.55(f)(4)(i) and 10 CFR 50.54(a)(3). These changes are not considered reductions of commitment in the program description since they implement company organization, administrative, editorial, completeness, and enhancement items. Accordingly, these changes did not require NRC approval prior to implementation. To facilitate your review of these changes, a 'track-changes markup' of QAPD FPL-2 Revision 4 (Reference 1) is provided as Enclosure 2. aoolf If you have any questions, or need additional information, please contact me at 561-691-2296. J:)oq1 {0/Lo Florida Power & Light Company 700 Universe Boulevard, Juno Beach, FL 33408
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Page 2 of 2 Sincerely, Steve Franzone Licensing Manager - New Nuclear Projects SMF/RFO : Florida Power and Light Company Quality Assurance Program Description for 10 CFR Part 52 Licenses FPL-2 (Revision 5) : Florida Power and Light Company Quality Assurance Program Description for 10 CFR Part 52 Licenses FPL-2 (Revision 4 track-changes markup) cc w/
Enclosures:
USNRC Regional Administrator, Region II USN RC PTN 6 & 7 Project Manager, AP1000 Licensing Branch 4, DNRUNRO USNRC Senior Resident Inspector, Turkey Point Nuclear Plant
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 1 of 85 Enclosure 1 Florida Power and Light Company Quality Assurance Program Description for 10 CFR Part 52 Licenses FPL-2 Revision 5
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 2 of 85 Florida Power and Light Company Quality Assurance Program Description for 10 CFR Part 52 Licenses FPL-2 FPL-2 Revision 5 Page 1 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 3 of85 FPL Quality Assurance Program De5,cription POLICY STATEMENT Florida Power and Light (FPL) shall design, procure, construct and operate nuclear plants in a manner that will ensure the health ant::I safety of. the public and workers. These activities shall be performed in compliance wfth the requirements ofthe Code of Federal Regulations (CFR), the applicable Nuclear Regulatory Commission (NRG) Facility Operating Licenses, and applicable laws and regulations of the state an~ local governments.
- The FPL New Nuclear Projects (NNP) Quality Assurance Program (QAP) is the Quality Assyrance Ptogram Description (QAPD) provided in this document and the associated implementing documents. Together they provide for control of FPL activities that affect the quality of safety-related nuclear plant structures, systems; and components .(SSCs) and include all planned and systematic activities necessary to provide adequate confidence thatsuch SSCs will perform satisfactorily in service. The QAPD may also be applied to cerlaih equipment and activities that are hot safety-related, but support safe plant operations, or where other NRC guidance establishes program requirements.
The QAPD is the top-level policy document that establlshes t_he manner in which quality is to be achieved, anc! presents FPL's overall philosophy regarding achievememt and assurance of quality. Implementing documents assign more detailed responsibilities and requirements and define the organizational interfaces involved 1n conducting activities within ~he scope 9f the QAP: Compliance with the QAPD and implementing documents is mandatory for personnel directly or indirectly associat. with implementation of the FPL NNP QAP. Signed: James . Robo NextEr nergy President and Chief Executive Officer FPL-2 Revision 5 Page2 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 4 of 85 FPL Quality As$uranco Program Do$crlption Approved Bf
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Director Nuclear Assurance & l\ssessment f;-as-,
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- Date***1 w.o. Mahar ForVice"Preeldent- New Nuclear Projects s-'~~9 1"'6ate **
- FPL-2 Revision 6 Page3ofaO May 20, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 5 of85 FPL Quality Assurance Program Description TABLE OF CONTENTS POLICY STATEMENT .................................................................................................................................. 2 PART I INTRODUCTION ....................................................................................................................... 8 SECTION 1 GENERAL .......................................................................................................................................8 PART II QAPD DETAILS ...................................................................................................................... 10 SECTION 1 ORGANIZATION ..........................................................................................................................10 Figure 1-1: NPP Construction and Startup Organization ..................................................................... 24 Figure 1-2: NextEra Energy Nuclear Fleet Corporate Operating Organization ................................... 25 Figure 1-3: NextEra Energy Nuclear Fleet Site Organization .............................................................. 26 SECTION 2 QUALITY ASSURANCE PROGRAM ......................................................................................27 2.1 Responsibilities ................................................................................................................. 28 2.2 Delegation of Work ............................................................................................................ 28 2.3 Site-specific Safety-Related Design Basis Activities ........................................................ 28 2.4 Periodic Review of the Quality Assurance Program ......................................................... 29 2.5 Issuance and Revision to Quality Assurance Program ..................................................... 29 2.6 Personnel Qualifications ................................................................................................... 29 2.7 NQA-1-1994 Commitment/ Exceptions ............................................................................ 30 SECTION 3 DESIGN CONTROL ....................................................................................................................32 3.1 Design Verification ............................................................................................................ 32 3.2 Design Records ................................................................................................................. 33 3.3 Computer Application and Digital Equipment Software .................................................... 33 3.4 Setpoint Control ................................................................................................................. 33 3.5 NQA-1-1994 Commitment .................................................................................................. 34 SECTION 4 PROCUREMENT DOCUMENT CONTROL.. ...........................................................................35 4.1 NQA-1-1994 Commitment/ Exceptions ............................................................................ 35 SECTION 5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS .......................................................... 37 5.1 Procedure Adherence ....................................................................................................... 37 5.2 Procedure Content ............................................................................................................ 37 5.3 NQA-1-1994 Commitment ................................................................................................ 37 SECTION 6 DOCUMENT CONTROL .............................................................................................................38 6.1 Review and Approval of Documents ................................................................................. 39 6.2 Changes to Documents .................................................................................................... 39 6.3 NQA-1-1994 Commitment ................................................................................................ 39 SECTION 7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES ..................... 40 7.1 Acceptance of Item or Service .......................................................................................... 40 7.2 NQA-1-1994 Commitment/ Exceptions ............................................................................ 41 SECTION 8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS .... 44 8.1 NQA-1-1994 Commitment ................................................................................................ 44 SECTION 9 CONTROL OF SPECIAL PROCESSES ..................................................................................45 9.1 NQA-1-1994 Commitment ................................................................................................ 45 FPL-2 Revision 5 Page 4 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 6 of85 FPL Quality Assurance Program Description TABLE OF CONTENTS (Continued) SECTION 10 INSPECTION ................................................................................................................................46 10.1 Inspection Program ........................................................................................................... 46 10.2 Inspector Qualification ...................................................................................................... 46 10.3 NQA-1-1994 Commitment/ Exceptions ............................................................................ 47 SECTION 11 TEST CONTROL ..........................................................................................................................48 11.1 NQA-1-1994 Commitment ................................................................................................ 48 11.2 NQA-1-1994 Commitment for Computer Program Testing ............................................. .48 SECTION 12 CONTROL OF MEASURING AND TEST EQUIPMENT ........................................................49 12.1 Installed Instrument and Control Devices ......................................................................... 49 12.2 NQA-1-1994 Commitment/ Exceptions ............................................................................ 49 SECTION 13 HANDLING, STORAGE, AND SHIPPING ...............................................................................50 13.1 Housekeeping ................................................................................................................... 50 13.2 NQA-1-1994 Commitment/ Exceptions ............................................................................ 51 SECTION 14 INSPECTION, TEST, AND OPERATING STATUS ................................................................ 53 14.1 NQA-1-1994 Commitment ................................................................................................ 53 SECTION 15 NONCONFORMING SERVICES, MATERIALS, PARTS, OR COMPONENTS ................ 54 15.1 Reporting Program ............................................................................................................ 54 15.2 NQA-1-1994 Commitment ................................................................................................ 54 SECTION 16 CORRECTIVE ACTION ..............................................................................................................55 16.1 Reporting Program ............................................................................................................ 55 16.2 NQA-1-1994 Commitment ................................................................................................ 55 SECTION 17 QUALITY ASSURANCE RECORDS ........................................................................................56 17.1 Record Retention .............................................................................................................. 56 17.2 Electronic Records ............................................................................................................ 56 17.3 NQA-1-1994 Commitment/ Exceptions ............................................................................ 56 SECTION 18 AUDITS ..........................................................................................................................................57 18.1 Performance of Audits ...................................................................................................... 57 18.2 Internal Audits ................................................................................................................... 58 18.3 NQA-1-1994 Commitment ................................................................................................ 59 PART Ill NONSAFETY-RELATED SSC QUALITY CONTROL. ....................................................... 60 SECTION 1 NON-SAFETY RELATED SSCs - SIGNIFICANT CONTRIBUTORS TO PLANT SAFETY ........... 60 SECTION 2 NON-SAFETY RELATED SSCs CREDITED FOR REGULATORY EVENTS ................................ 63 PART IV REGULATORY COMMITMENTS ....................................................................................... 64 REGULATORY GUIDES .....................................................................................................................................64 STANDARDS ........................................................................................................................................................66 FPL-2 Revision 5 Page 5 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 7 of85 FPL Quality Assurance Program Description TABLE OF CONTENTS (Continued) PART V ADDITIONAL QUALITY ASSURANCE AND ADMINISTRATIVE CONTROLS FOR THE PLANT OPERATIONAL PHASE ............................................................................................................... 67 SECTION 1 DEFINITIONS ...............................................................................................................................67 SECTION 2 REVIEW OF ACTIVITIES AFFECTING SAFE PLANT OPERATION ................................. 68 SECTION 3 OPERATIONAL PHASE PROCEDURES ................................................................................72 SECTION 4 CONTROL OF SYSTEMS AND EQUIPMENT IN THE OPERATIONAL PHASE ............. 79 SECTION 5 PLANT MAINTENANCE .............................................................................................................80 FPL-2 Revision 5 Page 6 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 8 of 85 FPL Quality Assurance Program Description This page intentionally left blank FPL-2 Revision 5 Page 7 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 9 of 85 FPL Quality Assurance Program Description PART I INTRODUCTION SECTION 1 GENERAL The Florida Power & Light Company (FPL) New Nuclear Projects (NNP) Quality Assurance Program Description (QAPD) is the top-level policy document that establishes the quality assurance policy and assigns major functional responsibilities for Combined Operating License (COL) construction, pre-operation and operations activities conducted by or for FPL. The QAPD describes the methods and establishes quality assurance (QA) and administrative control requirements that meet 10 CFR 50, Appendix B and 10 CFR 52. The QAPD is based on the requirements and recommendations of ASME NQA-1-1994, "Quality Assurance Requirements f~r Nuclear Facility Applications," Parts I, II and Ill, as specified in this document. New Nuclear Projects is responsible for development of the licensing actions needed in support of new nuclear site development. Responsibilities also include engineering oversight of contractors, site layout, staffing and program development, and operational readiness. The executive in charge of New Nuclear Projects reports directly to the Chief Nuclear Officer and is assisted by a support staff. Initially, New Nuclear Projects is responsible for construction planning and preparation. The responsibility for construction transitions to the executive for Site Construction at the start of construction activities when filled. New Nuclear Projects responsibilities include the establishment and execution of a contract or contracts for the engineering, procurement, construction, and startup activities of new nuclear plants. Organizational control and responsibility for newly constructed nuclear generating units transfers to the Chief Nuclear Officer following the completion of unit specific construction activities and prior to loading of fuel. As a new nuclear plant approaches startup, the site organization transitions from the development/ construction focused organization to the Operating Plant Site Organization. The VP New Nuclear Projects reports to the Executive VP Engineering, Construction, & Supply Chain. This reporting relationship allows the Chief Nuclear Officer and Nuclear Generation to remain focused on improving the performance of the operating fleet and minimize the distractions associated with the construction of new nuclear generating plants. This position will be filled in support of the start of construction activities for a new nuclear plant. This position is responsible for the control and oversight of all construction activities associated with a new nuclear unit. Reporting to this position will be the Licensing Director New Nuclear Projects and Project Director New Nuclear Projects. This position will transfer responsibilities for the constructed unit to the site executive reporting to the Chief Nuclear Officer at the completion of construction activities and prior to the loading of fuel in that unit. This position will retain responsibilities for other units under construction at a multi-unit site until construction activities for each unit are completed. This position is supported during these construction activities by other Nuclear organizations as needed. FPL-2 Revision 5 Page 8 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 10 of 85 FPL Quality Assurance Program Description PARTI INTRODUCTION (CONTINUED) The QAP is defined by the NRC-approved regulatory document that describes the QA elements (i.e. the QAPD), along with the associated implementing documents. Procedures and instructions that control NNP activities will be developed prior to commencement of those activities. Policies establish high-level responsibilities and authority for carrying out important administrative functions which are outside the scope of the QAPD. Procedures establish practices for certain activities which are common to all FPL organizations performing those activities so that the activity is controlled and carried out in a manner that meets QAPD requirements. Procedures specific to a site, organization, or group establish detailed implementation requirements and methods, and may be used to implement policies or be unique to particular functions or work activities. 1.1 Scope/ Applicability The QAPD applies to construction, pre-operation and operations activities affecting the quality and performance of safety-related structures, systems, and components, including, but not limited to: Designing Receiving Pre-Operational Activities (Including ITMC) Siting Storing Operating Procuring Constructing Maintaining Fabricating Erecting Repairing Cleaning Installing Modifying Handling Inspecting Refueling Shipping Testing Training Startup Decommissioning Safety-related SSCs, under the control of the QAPD, are identified by design documents. The technical aspects of these items are considered when determining program applicability, including, as appropriate, an item's design safety function. The QAPD may be applied to certain activities where regulations other than 10 CFR 50 and 10 CFR 52 establish QA requirements for activities within their scope. This QAPD was developed to address COL activities associated with Turkey Point Units 6 and 7 and any future nuclear power units pursued by Florida Power & Light Company in accordance with 10 CFR Part 52. This QAPD does not apply to any of the existing FPUNextEra Energy nuclear power plants. The policy of FPL is to assure a high degree of availability and reliability of the nuclear plants while ensuring the health and safety of its workers and the public. Towards this end, selected elements of the QAPD are also applied to certain equipment and activities that are not safety-related, but support safe, economic, and reliable plant operations, or where other NRC guidance establishes quality assurance requirements. Implementing documents establish program element applicability . . The definitions provided in ASME NQA-1-1994, Part I, Section 1.4, apply to select terms as used in this document. FPL-2 Revision 5 Page 9 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 11 of 85 FPL Quality Assurance Program Description PART II QAPD DETAILS SECTION 1 ORGANIZATION This section describes the FPL organizational structure, functional responsibilities, levels of authority and interfaces for establishing, executing, and verifying QAPD implementation. The organizational structure includes corporate and on-site functions for NNP including interface responsibilities for multiple organizations that perform quality-related functions. Implementing documents assign more specific responsibilities and duties, and define the organizational interfaces involved in conducting activities and duties within the scope of the QAPD. Management gives careful consideration to the timing, extent and effects of organizational structure changes. The FPL management senior position responsible for the Quality Assurance organization is responsible to size the Quality Assurance organization commensurate with the duties and responsibilities assigned. The FPL NNP organization is responsible for new nuclear plant licensing, engineering, procurement, construction, startup and operations development activities. There are several organizations within FPL which implement and support the QAPD. These organizations include, but are not limited to, the NNP organization, Corporate Services and Quality Assurance. Design, engineering and construction services are provided to the FPL New Nuclear Projects organization by two primary contractors in accordance with their own QAPDs. These two contractors are the A/E Firm and the NSSS vendor. No later than six months prior to fuel load of the unit, those positions which are identified for Operations will be staffed and have the appropriate authority required to perform operations activities. It is anticipated that even after fuel load, construction activities will be ongoing. Those positions required to support these activities will retain their applicable construction/preoperation responsibilities until it is deemed that they are no longer necessary. As the construction of systems (or portions thereof) is completed, control and authority (including oversight, configuration and operations) is transferred from the contractor to the FPL departments in the operations phase. During the transition, responsibilities will be clearly defined in instructions and procedures to ensure appropriate authority is maintained for each SSC. The following sections describe the reporting relationships, functional responsibilities and authorities for the organizations that implement and support the NNP QA Program. The NNP construction and startup organization and the FPL Fleet operating organization are shown in Figures 1-1, 1-2 and 1-3, respectively. FPL-2 Revision 5 Page 10 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 12 of 85 FPL Quality Assurance Program Description SECTION I ORGANIZATION (CONTINUED) 1.1 NNP Construction and Startup Organization 1.1.1 NextEra Energy President and Chief Executive Officer (CEO) This position is responsible for overall corporate policy and provides executive direction and guidance for the corporation as well as for the promulgation of corporate policy through the Company's senior management staff. The President and CEO is responsible for developing, implementing, and verifying execution of the FPL Quality Assurance Program. Responsibility for implementing the FPL Quality Assurance Program is delegated to the Chief Nuclear Officer and the authority for developing and verifying execution of the program is delegated to the Director Nuclear Assurance. 1.1.2 Executive Vice President - Engineering, Construction and Corporate Services This position reports to the CEO and is the project executive responsible for construction of the new nuclear plant. This position is the interface between the NNP project and the senior executive staff.
- 1.1.3 Vice President - New Nuclear Projects The Vice President - New Nuclear Projects, reports to the Executive Vice President -
Engineering, Construction and Corporate Services and is responsible for the overall safe and efficient licensing, engineering, construction and pre-operational test of the New Nuclear Projects, and for the implementation of quality assurance requirements in the areas specified by the QAPD. 1.1.4 President Nuclear Division This position reports to the CEO and has overall responsibility for the implementation of the QAP and for Nuclear Division activities including corporate responsibility for overall plant nuclear safety. The President is designated as the Company Officer responsible for assuring that defects and non-compliances are reported to the NRC as required by 10CFR21. 1.1.5 Vice President and Chief Nuclear Officer (CNO) This position reports to the President Nuclear Division and has overall responsibility for the implementation of the QAP and for Nuclear Division's activities including corporate responsibility for overall plant nuclear safety. This responsibility includes setting and implementing policies, objectives, and priorities to ensure activities are performed in accordance with QAP and other corporate requirements. FPL-2 Revision 5 Page 11 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 13 of 85 FPL Quality Assurance Program Description SECTION I ORGANIZATION (CONTINUED) 1.1.6 Licensing Director - New Nuclear Projects The Licensing Director - New Nuclear Projects reports to the Vice President - New Nuclear Projects and is responsible for the generation of the Combined Operating License (COL) application, and is responsible for the day-to-day oversight of the COL application contractor and assuring corrective action is taken for any quality concerns that are raised. This position is also responsible for the licensing actions associated with the New Nuclear Projects through the final licensing action associated with the new nuclear project. 1.1. 7 Project Director - New Nuclear Projects The Project Director - New Nuclear Projects, reports to the Vice President - New Nuclear Projects, is responsible for the construction and test of the new nuclear plant and is accountable for ensuring that company policy and procedures are properly implemented at the nuclear site. 1.1.8 Construction Director - New Nuclear Projects The Construction Director reports to the Project Director - New Nuclear Projects, and is responsible to interface with the NSSS supplier, the selected A/E, and the constructor. This position is responsible for the day to day oversight of the construction effort as the new nuclear plant is constructed, and for assuring corrective action is robust for any construction quality concerns that are raised by the Contractor or by FPL personnel. 1.1.9 Engineering Site Director - New Nuclear Projects The Engineering Site Director - Units 6 & 7 reports to the Project Director - New Nuclear Projects, and is responsible to interface with the NSSS supplier, and the selected NE. This position is responsible for the day to day oversight of the engineering effort as the new nuclear plant is designed and constructed, and for assuring that corrective action is robust for any engineering issues that are raised by the Contractor or by FPL personnel. 1.1.10 Quality Assurance Project Manager- New Nuclear Projects The New Nuclear Projects Quality Assurance Project Manager (QAPM) reports directly to the Director Nuclear Assurance, and is responsible for the development and verification of implementation of the QAPD described in this document. The QAPM is responsible for verifying compliance with regulatory requirements and procedures through audits and technical reviews; for monitoring organization processes to ensure conformance to commitments and licensing document requirements; for verifying that vendors who provide quality services, parts and materials to the new nuclear project are meeting the requirements of 10 CFR 50, Appendix B through NUPIC or FPL vendor audits. The QAPM has sufficient independence from other New Nuclear Projects priorities to bring forward issues affecting safety and quality and make judgments regarding quality in all areas necessary regarding FPL's nuclear development activities. The QAPM may make recommendations to the New Nuclear Projects management regarding improvement in the quality of work processes. If the QAPM disagrees with actions taken by the organization in this regard and is unable to obtain resolution, the QAPM shall inform the Director Nuclear Assurance. FPL-2 Revision 5 Page 12 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 14 of 85 FPL Quality Assurance Program Description SECTION I ORGANIZATION (CONTINUED) 1.1.11 Plant General Manager - New Nuclear Projects The Plant General Manager - New Nuclear Projects reports directly to the Vice President and CNO and is responsible for plant operation and administratively to the Vice President New Nuclear Projects during construction. This position is responsible for development of the site operating and support staff, and for operation of the new nuclear plant during the test phase. During construction, the Plant General Manager coordinates activities with the Vice President New Nuclear Projects to provide for equipment operation, maintenance and test including Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) In this position, as the plant moves into the operations phase, the Plant General Manager assures the safe, reliable, and efficient operation of the plant within the constraints of applicable regulatory requirements, combined operating license, and the QAP. Functional areas of responsibility also include chemistry activities, fuel handling (receipt, movement, and storage), health physics/radiological protection, operations and support, maintenance and production planning, and related procedures and programs. 1.1.12 Testing Director The Testing Director reports to the Project Director- NNP, and is responsible to coordinate the test program for the new nuclear plant. This position is responsible to develop the test program and to support the contractors and the operating staff through the plant test and startup phase. 1.1.13 Vice President - Integrated Supply Chain This position reports to the CEO through the Executive Vice President Engineering, Construction and Corporate Services and is responsible for procurement engineering; negotiating, generating, and issuing procurement documents for required items, coordinating contract activities and for services that support the operation, licensing, maintenance, modification, and inspection of FPL nuclear plants, as well as for materials and equipment to support the Nuclear Division staff. Responsibilities also include the review of procurement documents to ensure that technical and quality requirements are properly incorporated and for the performance of receipt inspection to verify that purchased items comply with procurement document requirements (other than at stations where receipt inspection is performed by the Quality Assurance Organization), and for the control of materials received at each FPL nuclear plant site in accordance with company policy and procedures. 1.1.14 Manager - Sourcing This position reports to the Vice President Integrated Supply Chain with direct interface with the VP-NNP. The position has functional areas of responsibility that include the authority for day-to-day material support activities at the site. Activities include contract coordination, procurement document control, and receipt and control of material. FPL-2 Revision 5 Page 13 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 15 of 85 FPL Quality Assurance Program Description SECTION I ORGANIZATION (CONTINUED) 1.1.15 Nuclear Steam Supply System (NSSS) Design Control Document (DCD) Holder The NSSS DCD Holder provides plant design and licensing of the plant on the FPL site. These engineering services for new nuclear generation include engineering and design necessary to support construction activities within the scope of the certified design. 1.1.16 A/E / Constructor The A/E Firm provides engineering services. These engineering services include site specific design activities necessary to support planning for preconstruction and construction of new nuclear generation. The Constructor provides construction services for the new plant. FPL-2 Revision 5 Page 14 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 16 of85 FPL Quality Assurance Program Description Section 1 ORGANIZATION (Continued) In establishing its organizational structure, NextEra Energy commits to compliance with NQA-1, 1994, Basic Requirement 1 and Supplement 1S-1. Management gives careful consideration to the timing, extent and effects of organizational structure changes. 1.2 Corporate Organization The following positions have the described corporate functional responsibilities. Some titles and reporting relationships may vary between corporate and some sites, but in all cases there is a designated position to carry out the defined responsibilities. 1.2.1 NextEra Energy Chairman and Chief Executive Officer (CEO) This position is responsible for overall corporate policy and provides executive direction and guidance for the corporation as well as promulgates corporate policy through the Company's senior management staff. Responsibility for implementing the Quality Assurance Program is delegated to the Chief Nuclear Officer and authority for developing and verifying execution of the program is delegated to the Director Nuclear Assurance & Assessment. 1.2.2 President Nuclear Division This position reports to the CEO and has overall responsibility for the implementation of the QAP and for Nuclear Division activities including corporate responsibility for overall plant nuclear safety. The President is designated as the Company Officer responsible for assuring that defects and non-compliances are reported to the NRC as required by 10CFR21. 1.2.3 Vice President & Chief Nuclear Officer (CNO) This position reports to the President Nuclear Division and has overall responsibility for the implementation of the QAP and for the Nuclear Division's activities including corporate responsibility for overall plant nuclear safety. This responsibility includes setting and implementing policies, objectives, and priorities to ensure activities are performed in accordance with QAP and other corporate requirements. FPL-2 Revision 5 Page 15 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 17 of 85 FPL Quality Assurance Program Description Section 1 ORGANIZATION (Continued) 1.2.4 Vice President Corporate Support This position reports to the CNO and is responsible for the following:
- Corporate Functional Area Managers (CFAMs)
- Performance Improvement '
- Security
- Fleet Training
- Licensing
- Interface with Nuclear Information Technology
- Continuous Improvement Program
- Fleet Projects (including capital projects, project control, project implementation, and ISFSI)
- Development and implementation of the programs associated with regulatory driven projects across the fleet.
- Outages
- Design Engineering
- Fleet Engineering Support 1.2.5 Sr. Director Nuclear Fleet Finance This position reports to the CNO and is responsible for the following:
- Nuclear fleet budgets
- Spending authorization
- Key performance indicators FPL-2 Revision 5 Page 16 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 18 of 85 FPL Quality Assurance Program Description Section 1 ORGANIZATION (Continued) 1.2.6 General Manager Fleet Engineering The General Manager Fleet Engineering reports to the Vice President Corporate Support and is responsible for:
- Fleet Engineering
- Probabilistic Safety Analysis
- Nuclear Fuels
- Engineering Programs
- Equipment Reliability
- Engineering Chiefs Organization The Engineering Site Directors report to this position.
1.2.7 Sr. Director Fleet Projects and Construction The Sr. Director Fleet Projects and Construction reports to the Vice President of Corporate Support and is responsible for the Engineering Construction Alliance interface including project controls implementation and engineering. 1.2.8 Director Fleet Design Engineering This position reports to the General Manager Fleet Engineering and is responsible for:
- Design Engineering
- Engineering Document Control
- Modifications and their Implementation
- Plant Design Configuration Control The Engineering Site Design Managers report to this position.
FPL-2 Revision 5 Page 17 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 19 of85 FPL Quality Assurance Program Description Section 1 ORGANIZATION (Continued) 1.2.9 Vice President Integrated Supply Chain (ISC) This position reports to the CEO through the Executive Vice President Engineering, Construction and ISC and is responsible through ISC directors for the following:
- Procurement Engineering
- Coordinating Contract Activities
- Negotiating, generating, and issuing procurement documents for required items and services supporting the operation, licensing, maintenance, modification, and inspection at the nuclear plants, and for materials and equipment to support the Nuclear Division staff
- Review of procurement documents to assure that technical and quality requirements are incorporated into the procurement documents that it authorizes
- Performance of receipt inspection to verify that purchased items comply with procurement document requirements (except at stations where receipt inspection is performed by the Nuclear Assurance Organization)
- Controlling materials received at each nuclear plant site in accordance with company policy and procedures 1.2.10 Senior Director IT Business Solutions This position reports to the NextEra Energy Vice President and CFO through the Vice President and CIO and is responsible for the following:
- Nuclear information technology such as computer-related hardware and software acquisition, deployment, maintenance, control and replacement; telecommunications
- Information I cyber security; and applicable training
- Interface with the organizational effectiveness manager
- Management of information technology
- Nuclear cyber security
- Computer-related hardware/software acquisition
- The functions are supported via staff at both corporate and site levels.
FPL-2 Revision 5 Page 18 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 20 of 85 FPL Quality Assurance Program Description Section 1 ORGANIZATION (Continued) 1.2.11 Vice President and Chief Information Officer This position reports to the NextEra Energy Vice Chairman and CFO. The CIO is responsible for:
- Nuclear Information Management (such as computer-related hardware and software acquisition, deployment, maintenance, control and replacement)
- Telecommunications
- Information/ Cyber Security
- Applicable Training The Vice President Information Technology reports to this position.
1.2.12 Director Nuclear Assurance & Assessment This position reports to and has direct access to the CNO for resolution of any areas in question. This position is responsible for the following:
- Activities that include establishing, maintaining, and interpreting quality assurance practices and policies (including this QATR)
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- Managing independent assessment (Quality Assurance {QA}) and establishing quality control practices and policies for quality verification activities
- Performance of receipt inspection, through the Nuclear Assurance Supervisor(s), to verify that purchased items comply with procurement documents at stations where receipt inspection is performed by the Nuclear Assurance organization
- Facilitating actions deemed necessary to prevent unsafe plant conditions or a significant violation of the QAP; including Stop Work authority at the sites and corporate offices
- Periodically apprising the CNO of the status of the quality assurance program at NextEra Energy facilities and immediately apprising senior management of significant problems affecting quality; and verifying implementation of solutions for significant conditions adverse to quality identified by Nuclear Assurance
- Establishing the requirements for assessor and inspector certification; and providing for supplier evaluation
- Conduct of supplier assessments or surveys; and verification that supplier quality assurance programs comply with NextEra Energy requirements FPL-2 Revision 5 Page 19 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 21 of 85 FPL Quality Assurance Program Description Section 1 ORGANIZATION (Continued) 1.2.13 Vice President - New Nuclear Projects The Vice President - New Nuclear Projects initially reports to the Chief Nuclear Officer and is responsible for:
- Project Administration
- Coordination and overall performance of the project
- Vendor Contract Compliance
- Quality
- Timeliness Error Free Performance The Vice President New Nuclear Projects transitions to reporting to the Executive Vice President Projects, Engineering, & Construction at the start of construction.
1.2.14 Licensing Director - New Nuclear Projects The Licensing Director - New Nuclear Projects reports to the Vice President - New Nuclear Projects and is responsible for:
- Maintenance of the COL
- Day-to-day oversight of the COL application contractor and assuring corrective action is taken for any quality concerns that are raised
- Licensing actions associated with the New Nuclear Projects through the final licensing action associated with the new nuclear project FPL-2 Revision 5 Page 20 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 22 of 85 FPL Quality Assurance Program Description Section 1 ORGANIZATION {Continued) 1.3 Site Organization The following site management positions describe the typical site QAP functional responsibilities, which may be delegated to others as established in this document. The on-site operating organization includes one or more individuals knowledgeable in the following fields: nuclear power plant operation; nuclear power plant mechanical, electrical and electronic systems; nuclear engineering; chemistry and radiochemistry; radiation protection; and quality assurance. Some functions, such as operating experience, document control, or records management, may be aligned under different groups at different sites. Site procedures provide detailed organizational descriptions. 1.3.1 Site Directors I Plant General Managers (PGMs) These positions report to the CNO and are responsible for the safe operation of the nuclear plant. The Site Directors and PG Ms have control of the onsite resources necessary for the safe operation and maintenance regardless of organizational reporting. In this position, the Site Directors and PGMs assure the safe, reliable, and efficient operation of the plant within the constraints of applicable regulatory requirements, operating license, and the QAP. Functional areas of responsibility also include chemistry activities, environmental services, fuel handling (receipt, movement, and storage), radiation protection, operations and support, maintenance and work control, and related procedures and programs. The Onsite Review Group serves the Site Directors and PGMs in a technical capacity and provides review of plant safety and performance (see Appendix A). 1.3.1.a Licensing Manager This position reports to the Site Directors I Plant General Managers and is responsible for site regulatory interfaces. 1.3.1.b Training Site Manager This position reports to the Site Directors / PGMs and functionally interfaces with the Training Fleet Director (offsite) and is responsible for training. The Site Training Manager provides direction, control, and overall supervision of training personnel and training for all site personnel as required. Functional areas of responsibility include training support services, technical training, and operations training. This position is also responsible for NUREG-0737, Action Plan Item 1.8.1.2 technical review functions committed to regarding the oversight, implementation, and coordination of internal and external operating experience. 1.3.1.c Emergency Preparedness Manager This position reports to the Licensing Manager and functionally interfaces with the Manager of Emergency Preparedness (offsite) and is responsible for maintaining and implementing the emergency plan for the station. FPL-2 Revision 5 Page 21 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 23 of 85 FPL Quality Assurance Program Description Section 1 ORGANIZATION (Continued) The following positions report directly offsite, but functionally report to a site position: 1.3.2.a Engineering Site Director This position reports to the Vice President Corporate Support through the General Manager Fleet Engineering. The position has functional areas of responsibility that include authority for day-to-day engineering support activities, engineering administration, system engineering, system testing, and technical support. This position is also responsible for NUREG-0737, Action Plan Item I.B.1.2 technical review functions that St. Lucie Unit 2 and Seabrook Station are committed to and implement by system health monitoring, development of a quarterly system health report which provides system performance and status to senior management, and development and implementation of the Maintenance Rule Program. 1.3.2.b Project Site Manager This position reports to the Sr. Director Projects and Construction with direct interface with the Site Directors and PGMs and is responsible for installing plant modifications as a result of design changes and implementing other major projects. 1.3.2.c Nuclear Assurance Manager This position reports to the Director Nuclear Assurance & Assessment (offsite) and is responsible for site quality activities. Significant safety or quality issues requiring escalated action are directed through this position to senior management, as necessary. Functional responsibilities include conducting independent assessments of line and support activities; monitoring and assessing day-to-day station activities; stop work authority at the site; periodic reporting on the status and adequacy of the quality program; and providing quality verification and inspections. 1.3.2.d Design Engineering Site Manager This position reports functionally to the Vice President Corporate Support through the General Manager Fleet Engineering with direct interface with the Site Directors and PGMs and is responsible for compliance with the Design Control Program. FPL-2 Revision 5 Page 22 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 24 of 85 FPL Quality Assurance Program Description SECTION I ORGANIZATION (CONTINUED) 1.5 Authority . 1.5.1 Authority to Stop Work Quality assurance and inspection personnel have the authority, and the responsibility, to stop work in progress which is not being done in accordance with approved procedures or where safety or SSC integrity may be jeopardized. This extends to off-site work performed by suppliers that furnish safety-related materials and services to FPL. 1.5.2 Quality Assurance Organizational Independence For construction, independence shall be maintained between the organization or organizations performing the checking (quality assurance and control) functions and the organizations performing the functions. This provision is not applicable to design review/verification. 1.5.3 NQA-1-1994 Commitment In establishing its organizational structure, FPL commits to compliance with NQA-1-1994, Basic Requirement 1 and Supplement 1S-1. FPL-2 Revision 5 Page 23 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 25 of 85 FPL Quality Assurance Program Description SECTION I ORGANIZATION (CONTINUED) Figure 1-1: NPP Construction and Startup Organization NPP CONSTRUCTION AND STARTUP ORGANIZATION NextEra Energy Chairman CEO I Nex!Era Energy President coo I Executive VP Executive VP & CNO Engineering, Construction
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Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 28 of 85 FPL Quality Assurance Program Description SECTION 2 QUALITY ASSURANCE PROGRAM FPL has established the necessary measures and governing procedures to implement the QAP as described in the QAPD. FPL is committed to implementing the QAP for all aspects of work that are important to the safety of the nuclear plants as described and to the extent delineated in the QAPD. Further, FPL ensures through the systematic process described herein that its suppliers of safety-related equipment or services meet the applicable requirements of 10 CFR 50, Appendix B. Senior management is regularly apprised of the adequacy of implementation of the QAPD through the audit functions described in Part 11, Section 18. The objective of the QAPD is to assure that FPL's nuclear generating plants are designed, constructed, and operated in accordance with governing regulations and license requirements. The program is based on the requirements of ASME NQA-1-1994, "Quality Assurance Requirements for Nuclear Facility Applications," as further described in this document. The QAPD applies to those quality-related activities that involve the functions of safety-related structures, systems, and components (SSCs) associated with the design (excluding Design Certification activities), fabrication, construction, and testing of the SSCs of the facility and to the managerial and administrative controls to be used to assure safe operations. A list or system that identifies SSCs and activities to which this program applies is maintained at the appropriate facility. The Design Certification Document is used as the basis for this list. Cost and scheduling functions do not prevent proper implementation of the QAPD. As described in Part Ill of the QAPD, specific program controls are applied to nonsafety-related SSCs, for which 10 CFR 50, Appendix B, is not applicable, that are significant contributors to plant safety. The specific program controls consistent with applicable sections of the QAPD are applied to those items in a selected manner, targeted at those characteristics or critical attributes that render the SSC a significant contributor to plant safety. Delegated responsibilities may be performed under a supplier's or principal contractor's QAPD, provided that the supplier or principal contractor has been approved as a supplier in accordance with the QAPD. Periodic audits and assessments of supplier QA programs are performed to assure compliance with the supplier's or principal contractor's QAPD and implementing procedures. In addition, routine interfaces with supplier personnel provide added assurance that quality expectations are met. New nuclear plant construction will be the responsibility of FPL's NNP organization. Detailed engineering specifications and construction procedures will be developed to implement the QAPD and NSSS QA programs prior to commencement of construction activities. In general, the program requirements specified herein are detailed in implementing procedures that are either FPL implementing procedures, or supplier implementing procedures governed by a supplier quality assurance program. FPL-2 Revision 5 Page 27 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 29 of 85 FPL Quality Assurance Program Description SECTION 2 QUALITY ASSURANCE PROGRAM (CONTINUED) A grace period of 90 days may be applied to provisions that are required to be performed on a periodic basis, unless otherwise noted. Annual evaluations and audits that must be performed on a triennial basis are examples where the 90 day general period could be applied. The grace period does not allow the "clock" for a particular activity to be reset forward. The "clock" for an activity is reset backwards by performing the activity early. Audits schedules are based on the month in which the audit starts. 2.1 Responsibilities Personnel who work directly or indirectly for FPL are responsible for achieving acceptable quality in the work covered by the QAPD. This includes the activities delineated in Part I, Section 1.1. FPL personnel performing verification activities are responsible for verifying the achievement of acceptable quality. Activities governed by the QAPD are performed as directed by documented instructions, procedures, and drawings that are of a detail appropriate for the activity's complexity and effect on safety. Instructions, procedures and drawings specify quantitative or qualitative acceptance criteria as applicable or appropriate for the activity. Verification is performed against these criteria. Provisions are established to designate or identify the proper documents to be used for an activity, and to ascertain that such documents are being used. The Quality Assurance Project Manager is responsible for verification that processes and procedures comply with QAPD and other applicable requirements, that such processes or procedures are implemented, and that management appropriately ensures compliance. 2.2 Delegation of Work FPL retains and exercises the responsibility for the scope and implementation of an effective OAP. Positions identified in Part II, Section 1, of this QAPD may delegate all or part of the activities of planning, establishing, and implementing the program for which they are responsible to others, but retain the responsibility for the program's effectiveness. Decisions affecting safety are made at the level appropriate for their nature and effect, and with any necessary technical advice or review. 2.3 Site-specific Safety-Related Design Basis Activities Site-specific safety-related design basis activities are defined as those activities, including sampling, testing, data collection, and supporting engineering calculations and reports, that will be used to determine the bounding physical parameters of the site. Appropriate quality assurance measures are applied. FPL-2 Revision 5 Page 28 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 30 of 85 FPL Quality Assurance Program Description SECTION 2 QUALITY ASSURANCE PROGRAM (CONTINUED) 2.4 Periodic Review of the Quality Assurance Program Management of those organizations implementing the QA program, or portions thereof, assesses the adequacy of that part of the program for which it are responsible to ensure effective implementation at least once each year or at least once during the life of the activity, whichever is shorter. However, the required periodicity for the assessment of QA programs during the operations phase may be extended to once every two years. 2.5 Issuance and Revision to Quality Assurance Program Administrative control of the QAPD will be in accordance with 10 CFR 50.55(f) and 10 CFR 50.54(a). Changes to the QAPD are evaluated by the Quality Assurance Project Manager to ensure that such changes do not degrade previously approved quality assurance controls specified in the QAPD. This document shall be revised as appropriate to incorporate additional QA commitments that may be established during the Combined Operating License (COL) application development process. Revisions to the document will be reviewed, at a minimum, by the FPL Director Nuclear Assurance and approved by the Vice President - New Nuclear Projects. Regulations require that the Final Safety Analysis Report (FSAR) include, among other things, the managerial and administrative controls to be used to assure safe operation, including a discussion of how the applicable requirements of Appendix B will be satisfied. In order to comply with this requirement, the FSAR references the QAPD and, as a result, the requirements of 10 CFR 50.54(a) are satisfied by and apply to the QAPD. 2.6 Personnel Qualifications Personnel assigned to implement elements of the QAPD shall be capable of performing their assigned tasks. To this end, FPL establishes and maintains formal indoctrination and training programs for personnel performing, verifying, or managing activities within the scope of the QAPD to assure that suitable proficiency is achieved and maintained. Plant and support staff minimum qualification requirements are as delineated in the unit Technical Specifications. Other qualification requirements may be established but will not reduce those required by Technical Specifications. Sufficient managerial depth is provided to cover absences of incumbents. When required by code, regulation, or standard, specific qualification and selection of personnel is conducted in accordance with those requirements as established in applicable FPL procedures. Indoctrination includes the administrative and technical objectives, requirements of the applicable codes and standards, and the QAPD elements to be employed. Training for positions identified in 10 CFR 50.120 is accomplished according to programs accredited by the National Nuclear Accrediting Board of the National Academy of Nuclear Training that implement a systematic approach to training. Records of personnel training and qualification are maintained. FPL-2 Revision 5 Page 29 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 31 of 85 FPL Quality Assurance Program Description SECTION 2 QUALITY ASSURANCE PROGRAM (CONTINUED) The minimum qualifications of the Director - Nuclear Assurance and the New Nuclear Projects Quality Assurance Project Manager are that each holds an engineering or related science degree and a minimum of four years of related experience including two years of nuclear power plant experience, one year of supervisory or management experience, which one year of the experience is in performing quality verification activities. Special requirements shall include management and supervisory skills and experience or training in leadership, interpersonal communication, management responsibilities, motivation of personnel, problem analysis and decision making, and administrative policies and procedures. Individuals who do not possess these formal education and minimum experience requirements should not be eliminated automatically when other factors provide sufficient demonstration of their abilities. These other factors are evaluated on a case-by-case basis and approved and documented by senior management. The minimum qualifications of the individuals responsible for planning, implementing, and maintaining the programs for the QAPD are that each has a high school diploma or equivalent and has a minimum of one year of related experience. Individuals who do not possess these formal education and minimum experience requirements should not be eliminated automatically when other factors provide sufficient demonstration of their abilities. These other factors are evaluated on a case-by-case basis and approved and documented by senior management. 2.7 NQA-1-1994 Commitment I Exceptions In establishing qualification and training programs, FPL commits to compliance with NQA 1994, Basic Requirement 2 and Supplements 2S-1, 2S-2, 2S-3 and 2S-4, with the following clarifications and exceptions:
- NQA-1-1994, Supplement 2S-1 Supplement 2S-1 will include use of the guidance provided in Appendix 2A-1 in the same manner as if it were part of the Supplement. The following two alternatives may be applied to the implementation of this Supplement and Appendix:
* (1) In lieu of being certified as Level I, II, or Ill in accordance with NQA 1994, personnel that perform independent quality verification inspections, examinations, measurements, or tests of material, products, or activities may possess qualifications equal to or better than those required for performing the task being verified provided that the verification is within the skills of these personnel and/or is addressed by procedures. These individuals will not be responsible for the planning of quality verification inspections and tests (i.e.,
establishing hold points and acceptance criteria in procedures, and determining who will be responsible for performing the inspections), evaluating inspection training programs, nor certifying inspection personnel. FPL-2 Revision 5 Page 30 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 32 of 85 FPL Quality Assurance Program Description SECTION 2 QUALITY ASSURANCE PROGRAM (CONTINUED)
* (2) A qualified engineer may be used to plan inspections, evaluate the capabilities of an inspector, or evaluate the training program for inspectors.
For the purpose of these functions, a qualified engineer is one who has a baccalaureate in engineering in a discipline related to the inspection activity (such as electrical, mechanical, civil) and has a minimum of five years engineering work experience with at least two years of this experience related to nuclear facilities.
- NQA-1-1994, Supplement 2S-2 In lieu of Supplement 2S-2, for qualification of nondestructive examination personnel, FPL will follow the applicable standard cited in the version(s) of Section Ill and Section XI of the ASME Boiler and Pressure Vessel Code approved by the NRC for use at FPL sites.
- NQA-1-1994, Supplement 2S-3 The requirement that prospective Lead Auditors have participated in a minimum of five (5) audits in the previous three (3) years is replaced by the following, "The prospective lead auditor shall demonstrate his/her ability to properly implement the audit process, as implemented by FPL, to effectively lead an audit team, and to effectively organize and report results, including participation in at least one nuclear audit within the year preceding the date of qualification."
FPL-2 Revision 5 Page 31 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 33 of 85 FPL Quality Assurance Program Description SECTION 3 DESIGN CONTROL FPL has established and implements a process to control the design, design changes, and temporary modifications (e.g., temporary bypass lines, electrical jumpers and lifted wires, and temporary setpoints) for items that are subject to the provisions of the QAPD. The design process includes provisions to control design inputs, outputs, changes, interfaces, records, and organizational interfaces within FPL and with suppliers. These provisions assure that design inputs (such as design bases and the performance, regulatory, quality, and quality verification requirements) are correctly translated into design outputs (such as analyses, specifications, drawings, procedures, and instructions) so that the final design output can be related to the design input in sufficient detail to permit verification. Design change processes and the division of responsibilities for design-related activities are detailed in FPL and supplier procedures. The design control program includes interface controls necessary to control the development, verification, approval, release, status, distribution, and revision of design inputs and outputs. Design changes and disposition of nonconforming items as "use as is" or "repair" are reviewed and approved by the FPL design organization or by other organizations so authorized by FPL. Design documents are reviewed by individuals knowledgeable in QA to ensure the documents contain the necessary QA requirements. 3.1 Design Verification FPL design processes provide for design verification to ensure that items and activities subject to the provisions of the QAPD are suitable for their intended application, consistent with their effect on safety. Design changes are subjected to these controls, which include verification measures commensurate with those applied to original plant design. Design verifications are performed by competent individuals or groups other than those who performed the original design but who may be from the same organization. The verifier shall not have taken part in the selection of design inputs, the selection of design considerations, or the selection of a singular design approach, as applicable. This verification may be performed by the originator's supervisor provided the supervisor did not specify a singular design approach, rule out certain design considerations, and did not establish the design inputs used in the design, or if the supervisor is the only individual in the organization competent to perform the verification. If the verification is performed by the originator's supervisor, the justification of the need is documented and approved in advance by management. The extent of the design verification required is a function of the importance to safety of the item under consideration, the complexity of the design, the degree of standardization, the state-of-the-art, and the similarity with previously proven designs. This includes design inputs, design outputs, and design changes. Design verification procedures are established and implemented to assure that an appropriate verification method is used, the appropriate design parameters to be verified are chosen, the acceptance criteria are identified, and the verification is satisfactorily accomplished and documented. Verification methods may include, but are not limited to, design reviews, alternative calculations and qualification testing. Testing used to verify the acceptability of a specific design feature demonstrates acceptable performance under conditions that simulate the most adverse design conditions expected for item's intended use. FPL-2 Revision 5 Page 32 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 34 of 85 FPL Quality Assurance Program Description SECTION 3 DESIGN CONTROL (CONTINUED) FPL normally completes design verification activities before the design outputs are used by other organizations for design work, and before they are used to support other activities such as procurement, manufacture, or construction. When such timing cannot be achieved, the design verification is completed before relying on the item to perform its intended design or safety function. 3.2 Design Records FPL maintains records sufficient to provide evidence that the design was properly accomplished. These records include the final design output and any revisions thereto, as well as record of the important design steps (e.g., calculations, analyses and computer programs) and the sources of input that support the final output. Plant design drawings reflect the properly reviewed and approved configuration of the plant. 3.3 Computer Application and Digital Equipment Software The QAPD governs the development, procurement, testing, maintenance, and use of computer applications and digital equipment software when used in safety-related applications and designated nonsafety-related applications. FPL and suppliers are responsible for developing, approving, and issuing procedures, as necessary, to control the use of such computer applications and digital equipment software. The procedures require that the application software be assigned a proper quality classification and that the associated quality requirements be consistent with this classification. Each software application and revision thereto is documented and approved by authorized personnel. The QAPD is also applicable to the administrative functions associated with the maintenance and security of computer hardware where such functions are considered essential in order to comply with other QAPD requirements such as QA records. 3.4 Setpoint Control Instrument and equipment setpoints that could affect nuclear safety shall be controlled in accordance with written instructions. As a minimum, these written instructions shall: (a) Identify responsibilities and processes for reviewing, approving, and revising setpoints and setpoint changes originally supplied by the NSSS supplier, the A/E, and the plant's technical staff. (b) Ensure that setpoints and setpoint changes are consistent with design and accident analysis requirements and assumptions. (c) Provide for documentation of setpoints, including those determined operationally. (d) Provide for access to necessary setpoint information by personnel who write or revise plant procedures, operate or maintain plant equipment, develop or revise design documents, or develop or revise accident analyses. FPL-2 Revision 5 Page 33 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 35 of 85 FPL Quality Assurance Program Description SECTION 3 DESIGN CONTROL (CONTINUED) 3.5 NQA-1-1994 Commitment In establishing its program for design control and verification, FPL commits to compliance with NQA-1-1994, Basic Requirement 3, and Supplement 3S-1, the subsurface investigation requirements in Subpart 2.20, and the standards for computer software in Subpart 2.7. FPL-2 Revision 5 Page 34 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 36 of 85 FPL Quality Assurance Program Description SECTION 4 PROCUREMENT DOCUMENT CONTROL FPL has established the necessary measures and governing procedures to assure that purchased items and services are subject to appropriate quality and technical requirements. Procurement document changes shall be subject to the same degree of control as utilized in the preparation of the original documents. These controls include provisions such that: Where original technical or quality assurance requirements cannot be determined, an engineering evaluation is performed and documented by qualified staff to establish appropriate requirements and controls to assure that interfaces, interchangeability, safety, fit and function, as applicable, are not adversely affected and are not contrary to applicable regulatory requirements.
- Applicable technical, regulatory, administrative, quality and reporting requirements (such as specifications, codes, standards, tests, inspections, special processes, and 10 CFR
- 21) are invoked for procurement of items and services. 10 CFR 21 requirements concerning posting, evaluating, and reporting will be followed and imposed on suppliers when applicable. Applicable design bases and other requirements necessary to assure adequate quality shall be included or referenced in documents for procurement of items and services. To the extent necessary, procurement documents shall require that suppliers have a documented QA program that is determined to meet the applicable requirements of 10 CFR 50, Appendix B, as appropriate to the circumstances of procurements (or the supplier may work under FPL's approved QA program).
Reviews of procurement documents shall be performed by personnel who have access to pertinent information and who have an adequate understanding of the requirements and intent of the procurement documents. 4.1 NQA-1-1994 Commitment/ Exceptions In establishing controls for procurement, FPL commits to compliance with NQA-1-1994, Basic Requirement 4 and Supplement 4S-1, with the following clarifications and exceptions:
- NQA-1-1994, Supplement 4S-1 Section 2.3 of this Supplement 4S-1 includes a requirement that procurement documents require suppliers to have a documented QAP that implements NQA-1-1994, Part 1. In lieu of this requirement, FPL may require suppliers to have a documented supplier QAP that is determined to meet the applicable requirements of 10 CFR 50, Appendix B, as appropriate to the circumstances of the procurement.
With regard to service performed by a supplier, FPL procurement documents may allow the supplier to work under the FPL QAP, including implementing procedures, in lieu of the supplier having its own QAP. FPL-2 Revision 5 Page 35 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 37 of 85 FPL Quality Assurance Program Description SECTION 4 PROCUREMENT DOCUMENT CONTROL (CONTINUED) Section 3 of supplement 4S-1 requires procurement documents to be reviewed prior to bid or award of contract. The quality assurance review of procurement documents is satisfied through review of the applicable procurement specification, including the technical and quality procurement requirements, prior to bid or award of contract. Procurement document changes (e.g., scope, technical, or quality requirements) will also receive the quality assurance review. Procurement documents for Commercial Grade Items that will be procured by FPL for use as safety-related items shall contain technical and quality requirements such that the procured item can be appropriately dedicated. FPL-2 Revision 5 Page 36 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 38 of 85 FPL Quality Assurance Program Description SECTION 5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS FPL has established the necessary measures and governing procedures to ensure that activities affecting quality are prescribed by and performed in accordance with instructions, procedures or drawings of a type appropriate to the circumstances and which, where applicable, include quantitative or qualitative acceptance criteria to implement the QAPD. Such documents are prepared and controlled according to Part II, Section 6. In addition, means are provided to disseminate to the staff instructions of both general and continuing applicability, as well as those of short-term applicability. Provisions are included for reviewing, updating, and canceling such procedures. 5.1 Procedure Adherence FPL's policy is that procedures are followed, and the requirements for use of procedures have been established in administrative procedures. Where procedures cannot be followed as written, provisions are established for making changes in accordance with Part II, Section 6. Requirements are established to identify the manner in which procedures are to be implemented, including identification of those tasks that require: (1) the written procedure to be present and followed step-by-step while the task is being performed, (2) the user to have committed the procedure steps to memory, (3) verification of completion of significant steps, by initials or signatures or use of check-off lists. Procedures that are required to be present and referred to directly are those developed for extensive or complex jobs where reliance on memory cannot be trusted, tasks that are infrequently performed, and tasks where steps must be performed in a specified sequence. In cases of emergency, personnel are authorized to depart from approved procedures when necessary to prevent injury to personnel or damage to the plant. Such departures are recorded describing the prevailing conditions and reasons for the action taken. 5.2 Procedure Content The established measures address the applicable content of procedures as described in the introduction to Part II of NQA-1-1994. In addition, procedures governing tests, inspections, operational activities, and maintenance will include as applicable, initial conditions and prerequisites for the performance of the activity. 5.3 NQA-1-1994 Commitment In establishing procedural controls, FPL commits to compliance with NQA-1-1994, Basic Requirement 5. FPL-2 Revision 5 Page 37 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 39 of 85 FPL Quality Assurance Program Description SECTION 6 DOCUMENT CONTROL FPL has established the necessary measures and governing procedures to control the preparation of, issuance of, and changes to documents that specify quality requirements or prescribe how activities affecting quality, including organizational interfaces, are controlled to assure that correct documents are being employed. The control systems (including electronic systems used to make documents available) are documented and provide for the following: (a) identification of documents to be controlled and their specified distribution; (b) a method to identify the correct document (including revision) to be used and control of superseded documents; (c) identification of assignment of responsibility for preparing, reviewing, approving, and issuing documents; (d) review of documents for adequacy, completeness, and correctness prior to approval and issuance; (e) a method for providing feedback from users to continually improve procedures and work instructions; and (f) coordinating and controlling interface documents and procedures. The types of documents to be controlled include: (a) drawings such as design, construction, installation, and as-built drawings; (b) engineering calculations; (c) design specifications; (d) purchase orders and related documents; (e) vendor-supplied documents; (f) audit, surveillance, and quality verification/inspection procedures; (g) inspection and test reports; (h) instructions and procedures for activities covered by the QAPD including design, construction, installation, operating (including normal and emergency operations), maintenance, calibration, and routine testing; (i) technical specifications; and U) nonconformance reports and corrective action reports. During the operational phase, where temporary procedures are used, they shall include a designation of the period of time during which it is acceptable to use them. FPL-2 Revision 5 Page 38 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 40 of 85 FPL Quality Assurance Program Description SECTION 6 DOCUMENT CONTROL (CONTINUED) 6.1 Review and Approval of Documents Documents are reviewed for adequacy by qualified persons other than the preparer. During the construction phase, procedures for design, construction, and installation are also reviewed by the organization responsible for quality verification to ensure quality assurance measures have been appropriately applied. The documented review signifies concurrence. During the operations phase, documents affecting the configuration or operation of the station as described in the SAR are screened to identify those that require review by the I RC prior to implementation as described in Part V, Section 2.2. To ensure effective and accurate procedures during the operational phase, applicable procedures are reviewed, and updated as necessary, based on the following conditions:
- following any modification to a system;
- following an unusual incident, such as an accident, significant operator error, or equipment malfunction;
- when procedure discrepancies are found;
- prior to use if not used in the previous two years; or
- results of QA audits conducted in accordance with Part II, Section 18.1.
Prior to issuance or use, documents. including revisions thereto, are approved by the designated authority. A listing of all controlled documents identifying the current approved revision, or date, is maintained so personnel can readily determine the appropriate document for use. 6.2 Changes to Documents Changes to documents, other than those defined in implementing procedures as minor changes, are reviewed and approved by the same organizations that performed the original review and approval unless other organizations are specifically designated. The reviewing organization has access to pertinent background data or information upon which to base their approval. Where temporary procedure changes are necessary during the operations phase, changes that clearly do not change the intent of the approved procedure may be implemented provided they are approved by two members of the staff knowledgeable in the areas affected by the procedures. Minor changes to documents, such as inconsequential editorial corrections, do not require that the revised documents receive the same review and approval as the original documents. To avoid a possible omission of a required review, the type of minor changes that do not require such a review and approval and the persons who can authorize such a classification shall be clearly delineated in implementing procedures. 6.3 NQA-1-1994 Commitment In establishing provisions for document control, FPL commits to compliance with NQA-1-1994, Basic Requirement 6 and Supplement 6S-1. FPL-2 Revision 5 Page 39 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 41 of 85 FPL Quality Assurance Program Description SECTION 7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES FPL has established the necessary measures and governing procedures to control the procurement of items and services to assure conformance with specified requirements. Such control provides for the following as appropriate: source evaluation and selection, evaluation of objective evidence of quality furnished by the supplier, source inspection, audit, and examination of items or services. 7 .1 Acceptance of Item or Service FPL establishes and implements measures to assess the quality of purchased items and services, whether purchased directly or through contractors, at intervals and to a depth consistent with the item's or service's importance to safety, complexity, quantity, and the frequency of procurement. Verification actions include testing, as appropriate, during design, fabrication and construction activities. Verifications occur at the appropriate phases of the procurement process, including, as necessary, verification of activities of suppliers below the first tier. Measures to assure the quality of purchased items and services include the following, as applicable: Items are inspected, identified, and stored to protect against damage, deterioration, or misuse. Prospective suppliers of safety-related items and services are evaluated to assure that only qualified suppliers are used. Qualified suppliers are audited on a triennial basis. In addition, if a subsequent contract or a contract modification significantly enlarges the scope of, or changes the methods or controls for, activities performed by the same supplier, an audit of the modified requirements is conducted, thus starting a new triennial period. FPL may utilize audits conducted by outside organizations for supplier qualification provided that the scope and adequacy of the audits meet FPL requirements. Documented annual evaluations are performed for qualified suppliers to assure they continue to provide acceptable products and services. Industry programs, such as those applied by ASME, Nuclear Procurement Issues Committee (NUPIC), or other established utility groups, are used as input or the basis for supplier qualification whenever appropriate. The results of the reviews are promptly considered for effect on a supplier's continued qualification and adjustments made as necessary (including corrective actions, adjustments of supplier audit plans, and input to third party auditing entities, as warranted). In addition, results are reviewed periodically to determine if, as a whole, they constitute a significant condition adverse to quality requiring additional action. FPL-2 Revision 5 Page 40 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 42 of 85 FPL Quality Assurance Program Description SECTION 7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES (CONTINUED) Provisions are made for accepting purchased items and services, such as source verification, receipt inspection, pre- and post-installation tests, certificates of conformance, and document reviews (including Certified Material Test Report/Certificate). Acceptance actions/documents should be established by the Purchaser with appropriate input from the Supplier and be completed to ensure that procurement, inspection, and test requirements, as applicable, have been satisfied before relying on the item to perform its intended safety function.
- Controls are imposed for the selection, determination of suitability for intended use (critical characteristics), evaluation, receipt and acceptance of commercial-grade services or items to assure they will perform satisfactorily in service in safety-related applications.
- If there is insufficient evidence of implementation of a QA program, the initial evaluation is of the existence of a QA program addressing the scope of services to be provided. The initial audit is performed after the supplier has completed sufficient work to demonstrate that its organization is implementing a QA program.
7.2 NQA-1-1994 Commitment/ Exceptions In establishing procurement verification controls, FPL commits to compliance with NQA-1-1994, Basic Requirement 7 and Supplement ?S-1, with the following clarifications and exceptions:
- NQA-1-1994, Supplement ?S-1 FPL considers that other 10 CFR 50 licensees, Authorized Nuclear Inspection Agencies, National Institute of Standards and Technology, or other State and Federal agencies which may provide items or services to FPL plants are not required to be evaluated or audited.
The methodology for use of accreditation in lieu of commercial grade surveys for laboratory calibration and test services is defined in the Nuclear Energy Institute document NEI 14-05A, Revision 0, "Guidelines For The Use Of Accreditation In Lieu Of Commercial Grade Surveys For Procurement Of Laboratory Calibration And Test Services" and acknowledged by the NRC in RIS 2016-01 as acceptable for use by all holders of operating license under Title 1O of the Code of Federal Regulations (1 O CFR) Part 50. The use of this process was approved for licensees in NRC Safety Evaluation (ADAMS Accession Number ML16089A167) dated April 1, 2016 to Union Electric Company, Callaway Plant. Requirements for applying this methodology are defined in RIS 2016-01 and as identified in NEI 14-05A, commercial grade calibration or testing services may be procured from commercial laboratories based on the laboratory's accreditation to ISO/IEC-17025 by an Accreditation Body (AB) which is a signatory to the International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement (MRA) without performing commercial grade surveys. Additionally, the NRG provided provisional acceptance of ISO/IEC 17025 (2017 edition) applicable during the transition period set to FPL-2 Revision 5 Page 41 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 43 of 85 FPL Quality Assurance Program Description SECTION 7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES (CONTINUED) expire on November 30, 2020 to allow accredited laboratories to transition from the current 2005 edition as provided by ISO. The use of ISO/IEC 17025 (2017 edition) beyond the transition period requires NRG acceptance of the next revision to NEI 14-05A supporting this edition (ADAMS Accession Number ML19056A451 dated April 16, 2019 to Nuclear Energy Institute). The use of an accredited laboratory is acceptable provided all of the following are met: (1) A documented review of the supplier's accreditation is performed and includes a verification of the following: (a) The calibration or test laboratory holds accreditation by an accrediting body recognized by the ILAC MRA. The accreditation encompasses ISO/IEC-17025:2005, (or ISO/IEC-17025:2017),
"General Requirements for the Competence of Testing and Calibration Laboratories."
(b) For procurement of calibration services, the published scope of accreditation for the calibration laboratory covers the needed measurement parameters, ranges, and uncertainties. (c) For procurement of testing services, the published scope of accreditation for the test laboratory covers the needed testing services including test methodology and tolerances/uncertainty. (2) The purchase documents require that: (a) The service must be provided in accordance with their accredited ISO/IEC-17025:2005 (or ISO/IEC-17025:2017) program and scope of accreditation. (b) As found calibration data must be reported in the certificate of calibration when calibrated items are found to be out-of-tolerance (for calibration services only). (c) The equipment/standards used to perform the calibration must be identified in the certificate of calibration (for calibration services only). (d) The customer must be notified of any condition that adversely impacts the laboratory's ability to maintain the scope of accreditation. (e) Additional technical and quality requirements, as necessary, based upon a review of the procured scope of services, which may include, but are not necessarily limited to, tolerances, accuracies, ranges, and industry standards. FPL-2 Revision 5 Page 42 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page44 of85 FPL Quality Assurance Program Description SECTION 7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES (CONTINUED) (3) It is validated, at receipt inspection, that the laboratory's documentation certifies that: (a) The contracted calibration or test service has been performed in accordance with their ISO/IEC-17025:2005 (or ISO/IEC-17025:2017) program, and has been performed within their scope of accreditation, and (b) The purchase order's requirements are met. For Section 8.1, FPL considers documents that may be stored in approved electronic media under FPL or vendor control, not physically located on the plant site, but are accessible from the respective nuclear facility site as meeting the NQA-1 requirement for documents to be available at the site. Following completion of the construction period, sufficient as-built documentation will be turned over to FPL to support operations. The FPL records management system will provide for timely retrieval of necessary records. In lieu of the requirements of Section 10, Commercial Grade Items, controls for commercial grade items and services are established in FPL documents using 10 CFR 21 and the guidance of EPRI NP-5652 as discussed in Generic Letter 89-02 and Generic Letter 91-05.
- For commercial grade items, special quality verification requirements are established and described in FPL documents to provide the necessary assurance an item will perform satisfactorily in service. The FPL documents address determining the critical characteristics that ensure an item is suitable for its intended use, technical evaluation of the item, receipt requirements, and quality evaluation of the item.
- FPL will also use other appropriate approved regulatory means and controls to support FPL commercial grade dedication activities. One example of this is Electric Power Research Institute (EPRI) Topical Report TR-106439, "Guideline on Evaluation and Acceptance of Commercial Grade Digital Equipment for Nuclear Safety Applications," dated July 17, 1997. FPL will assume 10 CFR 21 reporting responsibility for all items that FPL dedicates as safety-related.
FPL-2 Revision 5 Page 43 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 45 of 85 FPL Quality Assurance Program Description SECTION 8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS FPL has established the necessary measures and governing procedures to identify and control items to prevent the use of incorrect or defective items. This includes controls for consumable materials and items with limited shelf life. The identification of items is maintained throughout fabrication, erection, installation and use so that the item can be traced to its documentation, consistent with the item's effect on safety. Identification locations and methods are selected so as not to affect the function or quality of the item. 8.1 NQA-1-1994 Commitment In establishing provisions for identification and control of items, FPL commits to compliance with NQA-1-1994, Basic Requirement 8 and Supplement 8S-1. FPL-2 Revision 5 Page44 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 46 of 85 FPL Quality Assurance Program Description SECTION 9 CONTROL OF SPECIAL PROCESSES FPL has established the necessary measures and governing procedures to assure that special processes that require interim process controls to assure quality, such as welding, heat treating, and nondestructive examination, are controlled. These provisions include assuring that special processes are accomplished by qualified personnel using qualified procedures and equipment. Personnel are qualified and special processes are performed in accordance with applicable codes, standards, specifications, criteria or other specially established requirements. Special processes are those where the results are highly dependent on the control of the process or the skill of the operator, or both, and for which the specified quality cannot be fully and readily determined by inspection or test of the final product. 9.1 NQA-1-1994 Commitment In establishing measures for the control of special processes, FPL commits to compliance with NQA-1-1994, Basic Requirement 9 and Supplement 9S-1. FPL-2 Revision 5 Page 45 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 47 of 85 FPL Quality Assurance Program Description SECTION 10 INSPECTION FPL has established the necessary measures and governing procedures to implement inspections that assure items, services, and activities affecting safety meet established requirements and conform to applicable documented specifications, instructions, procedures, and design documents. Inspection may also be applied to items, services, and activities affecting plant reliability and integrity. Types of inspections may include those verifications related to procurement, such as source, in-process, final, and receipt inspection, as well as construction, installation, and operations activities. Inspections are carried out by properly qualified persons independent of those who performed or directly supervised the work. Inspection results are documented. 10.1 Inspection Program The inspection program establishes inspections (including surveillance of processes), as necessary to verify quality: (1) at the source of supplied items or services, (2) in-process during fabrication at a supplier's facility or at a Company facility, (3) for final acceptance of fabricated and/or installed items during construction, (4) upon receipt of items for a facility, as well as (5) during maintenance, modification, in-service, and operating activities. The inspection program establishes requirements for planning inspections, such as the group or discipline responsible for performing the inspection, where inspection hold points are to be applied, determining applicable acceptance criteria, the frequency of inspection to be applied, and identification of special tools needed to perform the inspection. Inspection planning is performed by personnel qualified in the discipline related to the inspection and includes qualified inspectors or engineers. Inspection plans are based on, as a minimum, the importance of the item to the safety of the facility, the complexity of the item, technical requirements to be met, and design specifications. Where significant changes in inspection activities for the facilities are to occur, management responsible for the inspection programs evaluate the resource and planning requirements to ensure effective implementation of the inspection program. Inspection program documents establish requirements for performing the planned inspections, and documenting required inspection information such as rejection, acceptance, and re-inspection results, and the person(s) performing the inspection. Inspection results are documented by the inspector, reviewed by authorized personnel qualified to evaluate the technical adequacy of the inspection results, and controlled by instructions, procedures, and drawings. 10.2 Inspector Qualification FPL has established qualification programs for personnel performing quality inspections. The qualification program requirements are described in Part II, Section 2. These qualification programs are applied to individuals performing quality inspections regardless of the functional group where they are assigned. FPL-2 Revision 5 Page 46 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 48 of 85 FPL Quality Assurance Program Description SECTION 10 INSPECTION (CONTINUED) 10.3 NQA-1-1994 Commitment/ Exceptions In establishing inspection requirements, FPL commits to compliance with NQA-1-1994, Basic Requirement 10, Supplement 1OS-1 and Subpart 2.4, with the following clarification. In addition, FPL commits to compliance with the requirements of Subparts 2.5 and 2.8 for establishing appropriate inspection requirements.
- Subpart 2.4 commits FPL to IEEE 336-1985. IEEE 336-1985 refers to IEEE 498-1985. Both IEEE 336 -1985 and IEEE 498-1985 use the definition of "Safety Systems Equipment" from IEEE 603-1980. FPL commits to the definition of Safety Systems Equipment in IEEE 603- 1980, but does not commit to the balance of that standard. This definition is only applicable to equipment in the context of Subpart 2.4.
- An additional exception to Subpart 2.4 is addressed in Part II, Section 12 of the QAPD.
- Where inspections at the operating facility are performed by persons within the same organization (e.g., Maintenance group), FPL takes exception to the requirements of NQA-1-1994, Supplement 1OS-1, Section 3.1, the inspectors report to the quality control management while performing those inspections.
FPL-2 Revision 5 Page 47 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 49 of 85 FPL Quality Assurance Program Description SECTION 11 TEST CONTROL FPL has established the necessary measures and governing procedures to demonstrate that items subject to the provisions of the QAPD will perform satisfactorily in service, that the plant can be operated safely and as designed, and that the coordinated operation of the plant as a whole is satisfactory. These programs include criteria for determining when testing is required, such as proof tests before installation, pre-operational tests, post-maintenance tests, post-modification tests, in-service tests, and operational tests (such as surveillance tests required by Plant Technical Specifications), to demonstrate that performance of plant systems is in accordance with design. Programs also include provisions to establish and adjust test schedules, and to maintain status for periodic or recurring tests. Tests are performed according to applicable procedures that include, consistent with the effect on safety: (1) instructions and prerequisites to perform the test, (2) use of proper test equipment, (3) acceptance criteria, and (4) mandatory verification points as necessary to confirm satisfactory test completion. Test results are documented and evaluated by the organization performing the test and reviewed by a responsible authority to assure that the test requirements have been satisfied. If acceptance criteria are not met, re-testing is performed as needed to confirm acceptability following correction of the system or equipment deficiencies that caused the failure. The initial start-up test program is planned and scheduled to permit safe fuel loading and start-up; to increase power in safe increments; and to perform major testing at specified power levels. If tests require the variation of operating parameters outside of their normal range, the limits within which such variation is permitted will be prescribed. The scope of the testing demonstrates, insofar as practicable, that the plant is capable of withstanding the design transients and accidents. For new facility construction, the suitability of facility operating procedures is checked to the maximum extent possible during the pre-operational and initial start-up test programs. Tests are performed and results documented in accordance with applicable technical and regulatory requirements, including those described in the Technical Specifications and SAR. Test programs ensure appropriate retention of test data in accordance with the records requirements of the QAPD. Personnel that perform or evaluate tests are qualified in accordance with the requirements established in Part II, Section 2. 11.1 NQA-1-1994 Commitment In establishing provisions for testing, FPL commits to compliance with NQA-1-1994, Basic Requirement 11 and Supplement 11 S-1. 11.2 NQA-1-1994 Commitment for Computer Program Testing FPL establishes and implements provisions to assure that computer software used in applications affecting safety is prepared, documented, verified and tested, and used such that the expected output is obtained and configuration control maintained. To this end FPL commits to compliance with the requirements of NQA-1-1994, Supplement 11 S-2, and Subpart 2. 7 to establish the appropriate provisions. FPL-2 Revision 5 Page 48 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 50 of85 FPL Quality Assurance Program Description SECTION 12 CONTROL OF MEASURING AND TEST EQUIPMENT FPL has established the necessary measures and governing procedures to control the calibration, maintenance, and use of measuring and test equipment (M&TE) that provides information important to safe plant operation. The provisions of such procedures cover equipment such as indicating and actuating instruments and gages, tools, reference and transfer standards, and nondestructive examination equipment. The suppliers of commercial-grade calibration services are controlled as described in Part II, Section 7. 12.1 Installed Instrument and Control Devices For the operations phase of the facilities, FPL has established and implements procedures for the calibration and adjustment of instrument and control devices installed in the facility. The calibration and adjustment of these devices is accomplished through the facility maintenance programs to ensure the facility is operated within design and technical requirements. Appropriate documentation will be maintained for these devices to indicate the control status, when the next calibration is due, and identify any limitations on use of the device. 12.2 NQA-1-1994 Commitment/ Exceptions In establishing provisions for control of measuring and test equipment, FPL commits to compliance with NQA-1-1994, Basic Requirement 12 and Supplement 12S-1 with the following clarification and exception: The out of calibration conditions described in paragraph 3.2 of Supplement 12S-1 refers to when the M&TE is found out of the required accuracy limits (i.e., out of tolerance) during calibration. Measuring and test equipment are not required to be marked with the calibration status where it is impossible or impractical due to equipment size or configuration (such as the label will interfere with operation of the device) provided the required information is maintained in suitable documentation traceable to the device. This exception also applies to the calibration labeling requirement stated in NQA-1-1994, Subpart 2.4, Section 7.2.1 (ANSI/IEEE Std. 336-1985). FPL-2 Revision 5 Page 49 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 51 of 85 FPL Quality Assurance Program Description SECTION 13 HANDLING, STORAGE, AND SHIPPING FPL has established the necessary measures and governing procedures to control handling, storage, packaging, shipping, cleaning, and preservation of items to prevent inadvertent damage or loss, and to minimize deterioration. These provisions include specific procedures, when required to maintain acceptable quality of the items important to the safe operations of the plant. Items are appropriately marked and labeled during packaging, shipping, handling and storage to identify, maintain, and preserve the item's integrity and indicate the need for special controls. Special controls (such as containers, shock absorbers, accelerometers, inert gas atmospheres, specific moisture content levels and temperature levels) are provided when required to maintain acceptable quality. Special or additional handling, storage, shipping, cleaning and preservation requirements are identified and implemented as specified in procurement documents and applicable procedures. Where special requirements are specified, the items and containers (where used) are suitably marked. Special handling tools and equipment are used and controlled as necessary to ensure safe and adequate handling. Special handling tools and equipment are inspected and tested at specified time intervals and in accordance with procedures to verify that the tools and equipment are adequately maintained. Operators of special handling and lifting equipment are experienced or trained in the use the equipment. During the operational phase, FPL establishes and implements controls over hoisting, rigging and transport activities to the extent necessary to protect the integrity of the items involved, as well as potentially affected nearby structures and components. Where required, FPL complies with applicable hoisting, rigging and transportation regulations and codes. 13.1 Housekeeping Housekeeping practices are established to account for conditions or environments that could affect the quality of structures, systems and components within the plant. This includes control of cleanliness of facilities and materials, fire prevention and protection, disposal of combustible material and debris, control of access to work areas, protection of equipment, radioactive contamination control and storage of solid radioactive waste. Housekeeping practices help assure that only proper materials, equipment, processes and procedures are used and that the quality of items is not degraded. Necessary procedures or work instructions, such as for electrical bus and control center cleaning, cleaning of control consoles, and radioactive decontamination are developed and used. FPL-2 Revision 5 Page 50 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 52 of 85 FPL Quality Assurance Program Description SECTION 13 HANDLING, STORAGE, AND SHIPPING (CONTINUED) 13.2 NQA-1-1994 Commitment/ Exceptions In establishing provisions for handling, storage and shipping, FPL commits to compliance with NQA-1-1994, Basic Requirement 13 and Supplement 13S-1. FPL also commits, during the construction and pre-operational phase of the plant, to compliance with the requirements of NQA-1-1994, Subpart 2.1, Subpart 2.2, and Subpart 3.2, Appendix 2.1, with the following clarifications and exceptions: NQA-1-1994, Subpart 2.1 Subpart 2.1, Section 3.1 and 3.2 establish criteria for classifying items into cleanness classes and requirements for each class. Instead of using the cleanness level system of Subpart 2.1, FPL may establish cleanness requirements on a case-by-case basis, consistent with the other provisions of Subpart 2.1. FPL establishes appropriate cleanliness controls for work on safety-related equipment to minimize introduction of foreign material and maintain system/component cleanliness throughout maintenance or modification activities, including documented verification of absence of foreign material prior to system closure. NQA-1-1994, Subpart 2.2 Subpart 2.2, Section 2.2 establishes criteria for classifying items into protection levels. Instead of classifying items into protection levels during the operational phase, FPL may establish controls for the packaging, shipping, handling, and storage of such items on a case-by-case basis with due regard for the item's complexity, use, and sensitivity to damage. Prior to installation or use, the items are inspected and serviced as necessary to assure that no damage or deterioration exists which could affect their function. Subpart 2.2, Section 6.6, "Storage Records:" This section requires written records be prepared containing information on personnel access. As an alternative to this requirement, FPL documents establish controls for storage areas that describe those authorized to access areas and the requirements for recording access of personnel. However, these records of access are not considered quality records and will be retained in accordance with the administrative controls of the applicable plant. Subpart 2.2, Section 7.1 refers to Subpart 2.15 for requirements related to handling of items. The scope of Subpart 2.15 includes hoisting, rigging and transporting of items for the nuclear power plants during construction. FPL-2 Revision 5 Page 51 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 53 of 85 FPL Quality Assurance Program Description SECTION 13 HANDLING, STORAGE, AND SHIPPING (CONTINUED) NQA-1-1994, Subpart 2.3 Subpart 2.3, Section 2.3 requires the establishment of five zone designations for housekeeping cleanliness controls. Instead of the five-level zone designation, FPL bases its control over housekeeping activities on a consideration of what is necessary and appropriate for the activity involved. The controls are implemented through procedures or instructions which, in the case of maintenance or modification work, are developed on a case-by-case basis. Factors considered in developing the procedures and instructions include cleanliness control, personnel safety, fire prevention and protection, radiation control and security. The procedures and instructions make use of standard janitorial and work practices to the extent possible. NQA-1-1994, Subpart 3.2 Subpart 3.2, Appendix 2.1: Only Section 3 precautions are being committed to in accordance with RG 1.37. In addition, a suitable chloride stress-cracking inhibitor should be added to. the fresh water used to flush systems containing austenitic stainless steels. FPL-2 Revision 5 Page 52 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 54 of 85 FPL Quality Assurance Program Description SECTION 14 INSPECTION, TEST, AND OPERATING STATUS FPL has established the necessary measures and governing procedures to identify the inspection, test, and operating status of items and components subject to the provisions of the QAPD in order to maintain personnel and reactor safety and avoid inadvertent operation of equipment. Where necessary to preclude inadvertent bypassing of inspections or tests, or to preclude inadvertent operation, these measures require the inspection, test or operating status be verified before release, fabrication, receipt, installation, test or use. These measures also establish the necessary authorities and controls for the application and removal of status indicators or labels. In addition, temporary design changes (temporary modifications), such as temporary bypass lines, electrical jumpers and lifted wires, and temporary trip-point settings, are controlled by procedures that include requirements for appropriate installation and removal, independent/concurrent verifications and status tracking. Administrative procedures also describe the measures taken to control altering the sequence of required tests, inspections, and other operations. Review and approval for these actions is subject to the same control as taken during the original review and approval of tests, inspections, and other operations. 14.1 NQA-1-1994 Commitment In establishing measures for control of inspection, test and operating status, FPL commits to compliance with NQA-1-1994, Basic Requirement 14. FPL-2 Revision 5 Page 53 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 55 of85 FPL Quality Assurance Program Description SECTION 15 NONCONFORMING SERVICES, MATERIALS, PARTS, OR COMPONENTS FPL has established the necessary measures and governing procedures to control items, including services, that do not conform to specified requirements to prevent inadvertent installation or use. Controls provide for identification, documentation, evaluation, segregation when practical, and disposition of nonconforming items, and for notification to affected organizations. Controls are provided to address conditional release of nonconforming items for use on an at-risk basis prior to resolution and disposition of the nonconformance, including maintaining identification of the item and documenting the basis for such release. Conditional release of nonconforming items for installation requires the approval of the designated management. Nonconformances are corrected or resolved prior to depending on the item to perform its intended safety function. Nonconformances are evaluated for impact on operability of quality structures, systems, and components to assure that the final condition does not adversely affect safety, operation, or maintenance of the item or service. Nonconformances to design requirements dispositioned as repair or use-as-is are subject to design control measures commensurate with those applied to the original design. Nonconformance dispositions are reviewed for adequacy, analysis of quality trends, and reports provided to the designated management. Significant trends are reported to management in accordance with FPL procedures, regulatory requirements, and industry standards. 15.1 Reporting Program FPL has the necessary measures and governing procedures that implement a reporting program that conforms to the requirements of 10 CFR 52, 10 CFR 50.55 and 10 CFR 21 during design and construction and 10 CFR 21 during operations. 15.2 NQA-1-1994 Commitment In establishing measures for nonconforming materials, parts, or components, FPL commits to compliance with NQA-1-1994, Basic Requirement 15, and Supplement 15S-1. FPL-2 Revision 5 Page 54 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 56 of85 FPL Quality Assurance Program Description SECTION 16 CORRECTIVE ACTION FPL has established the necessary measures and governing procedures to promptly identify, control, document, classify and correct conditions adverse to quality. FPL procedures assure that corrective actions are documented and initiated following the determination of conditions adverse to quality in accordance with regulatory requirements and applicable quality standards. FPL procedures require personnel to identify known conditions adverse to quality. When complex issues arise where it cannot be readily determined if a condition adverse to quality exists, FPL documents establish the requirements for documentation and timely evaluation of the issue. Reports of conditions adverse to quality are analyzed to identify trends. Significant conditions adverse to quality and significant adverse trends are documented and reported to responsible management. In the case of a significant condition adverse to quality, the cause is determined and actions to preclude recurrence are taken. In the case of suppliers working on safety-related activities, or other similar situations, FPL may delegate specific responsibilities of the Corrective Action program but FPL maintains responsibility for the program's effectiveness. 16.1 Reporting Program FPL has the necessary measures and governing procedures that implement a reporting program that conforms to the requirements of 10 CFR 52, 10 CFR 50.55 and/or 10 CFR 21 during design and construction, and 10 CFR 21 during operations. 16.2 NQA-1-1994 Commitment In establishing provisions for corrective action, FPL commits to compliance with NQA-1-1994, Basic Requirement 16. FPL-2 Revision 5 Page 55 of 80 May 28, 2019
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Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 57 of 85 ' FPL Quality Assurance Program Description SECTION 17 QUALITY ASSURANCE RECORDS FPL has the necessary measures and governing procedures to ensure that sufficient records of items and activities affecting quality are developed, reviewed, approved, issued, used, and revised to reflect completed work. The provisions of such procedures establish the scope of the records retention program for FPL and include requirements for records administration, including receipt, preservation, retention, storage, safekeeping, retrieval, access controls, user privileges, and final disposition. 17.1 Record Retention Measures are established that ensure that sufficient records of completed items and activities affecting quality are appropriately stored. Records of activities for design, engineering, procurement, manufacturing, construction, inspection and test, installation, pre-operation, startup, operations, maintenance, modification, decommissioning, and audits and their retention times are defined in appropriate procedures. The records and retention times are based on Regulatory Position C.2 and Table 1, of Regulatory Guide 1.28, Revision 3 for design, construction, and initial start-up. Retention times for operations phase records are based on construction records that are similar in nature. 17.2 Electronic Records When using optical discs for electronic records storage and retrieval systems, FPL complies with the NRG guidance in Generic Letter 88-18, "Plant Record Storage on Optical Disks." FPL will manage the storage of QA Records in electronic media consistent with the intent of RIS 2000-18 and associated NIRMA Guidelines TG 11-1998, TG15-1998, TG16-1998, and TG21-1998. 17.3 NQA-1-1994 Commitment/ Exceptions In establishing provisions for records, FPL commits to compliance with NQA-1-1994, Basic Requirement 17 and Supplement 17S-1 as well as the applicable portions of 10 CFR 73 established via 10 CFR 73.55 (q) and 10 CFR 73. 70, with the following clarifications and exceptions:
- NQA-1-1994, Supplement 17S-1
- Supplement 17S-1, Section 4.2(b), requires records to be firmly attached in binders or placed in folders or envelopes for storage in steel file cabinets or on shelving in containers. For hard-copy records maintained by FPL, the records are suitably stored in steel file cabinets or on shelving in containers, except that methods other than binders, folders or envelopes may be used to organize the records for storage.
FPL-2 Revision 5 Page 56 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 58 of 85 FPL Quality Assurance Program Description SECTION 18 AUDITS FPL has established the necessary measures and governing procedures to implement audits to verify that activities covered by the QAPD are performed in conformance with the requirements established. The audit programs are themselves reviewed for effectiveness as a part of the overall audit process. 18.1 Performance of Audits Internal audits of selected aspects of licensing, design, construction phase and operating activities are performed with a frequency commensurate with safety significance and in a manner which assures that audits of safety-related activities are completed. During the early portions of NNP activities, audits will focus on areas including, but not limited to, procurement, and corrective action. Functional areas of an organization's QA program for auditing include, at a minimum, verification of compliance and effectiveness of implementation of internal rules, procedures (e.g., operating, design, procurement, maintenance, modification, refueling, surveillance, test, security, radiation control procedures, and the emergency plan), Technical Specifications, regulations and license conditions, programs for training, retraining, qualification and performance of operating staff, corrective actions, and observation of performance of operating, refueling, maintenance and modification activities, including associated record keeping. The audits are scheduled on a formal preplanned audit schedule. The audit system is reviewed periodically and revised as necessary to assure coverage commensurate with current and planned activities. Additional audits may be performed as deemed necessary by management. The scope of the audit is determined by the quality status and safety importance of the activities being performed. These audits are conducted by trained personnel not having direct responsibilities in the area being audited and in accordance with preplanned and approved audit plans or checklists, under the direction of a qualified lead auditor and the cognizance of the Quality Manager responsible for the day to day program as documented in Section 1. FPL is responsible for conducting periodic internal and external audits. Internal audits are conducted to determine the adequacy of programs and procedures (by representative sampling), and to determine if they are meaningful and comply with the overall QAPD. External audits determine the adequacy of supplier and contractor quality assurance programs. The results of each audit are reported in writing to the responsible Senior Executive responsible for the Quality Assurance program at the Site, or designee, as appropriate. Additional internal distribution is made to other concerned management levels in accordance with approved procedures. Management responds to all audit findings and initiates corrective action where indicated. Where corrective action measures are indicated, documented follow-up of applicable areas through inspections, review, re-audits, or other appropriate means is conducted to verify implementation of assigned corrective action. Audits of suppliers of safety-related components and/or services are conducted as described in Section 7 .1. FPL-2 Revision 5 Page 57 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 59 of 85 FPL Quality Assurance Program Description SECTION 18 AUDITS (CONTINUED) 18.2 Internal Audits Internal audits of organization and facility activities, conducted prior to placing the facility in operation, should be performed in such a manner as to assure that an audit of all applicable QA program elements is completed for each functional area at least once each year or at least once during the life of the activity, whichever is shorter. Internal audits of activities, conducted after placing the facility in operation, should be performed in such a manner as to assure that an audit of all applicable QA program elements is completed for each functional area within a period of two years. Internal audit frequencies of well established activities, conducted after placing the facility in operation, may be extended one year at a time beyond the above two-year interval based on the results of an annual evaluation of the applicable functional area and objective evidence that the functional area activities are being satisfactorily accomplished. The evaluation should include a detailed performance analysis of the functional area based upon applicable internal and external source data and due consideration of the impact of any functional area changes in responsibility, resources or management. However, the internal audit frequency interval should not exceed a maximum of four years. If an adverse trend is identified in the applicable functional area, the extension of the internal audit frequency interval should be rescinded and an audit scheduled as soon as practicable. During the operations phase, audits are performed at a frequency commensurate with the safety significance of the activities and in such a manner to assure audits of all applicable QA program elements are completed within a period of two years. These audits will include, as a minimum, activities in the following areas:
- 1. The conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions including administrative controls.
- 2. The performance, training, and qualifications of the facility staff.
- 3. The performance of activities required by the QAPD to meet the criteria of 10 CFR 50, Appendix B.
- 4. The Fire Protection Program and implementing procedures. A fire protection equipment and program implementation inspection and audit are conducted utilizing either a qualified off-site licensed fire protection engineer or an outside qualified fire protection consultant.
- 5. Other activities and documents considered appropriate by the Chief Nuclear Officer.
Audits may also be used to meet the periodic review requirements for Security, Emergency Preparedness, and Radiological Protection programs within the provisions of the applicable regulation. FPL-2 Revision 5 Page 58 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 60 of 85 FPL Quality Assurance Program Description SECTION 18 AUDITS (CONTINUED) Internal audits include verification of compliance and effectiveness of the administrative controls established for implementing the requirements of the QAPD; regulations and license provisions; provisions for training, retraining, qualification, and performance of personnel performing activities covered by the QAPD; corrective actions taken following abnormal occurrences; and, observation of the performance of construction, fabrication, operating, refueling, maintenance, and modification activities including associated record keeping. 18.3 NQA-1-1994 Commitment In establishing the independent audit program, FPL commits to compliance with NQA-1-1994, Basic Requirement 18 and Supplement 18S-1. FPL-2 Revision 5 Page 59 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 61 of85 FPL Quality Assurance Program Description PART Ill NONSAFETY-RELATED SSC QUALITY CONTROL SECTION 1 NON-SAFETY RELATED SSCs -SIGNIFICANT CONTRIBUTORS TO PLANT SAFETY Specific program controls are applied to nonsafety-related SSCs, for which 10 CFR 50, Appendix B is not applicable, that are significant contributors to plant safety. The specific program controls consistent with applicable sections of the QAPD are applied to those items in a selected manner, targeted at those characteristics or critical attributes that render the SSC a significant contributor to plant safety. The following clarify the applicability of the QA Program to the nonsafety-related SSCs and related activities, including the identification of exceptions to the QA Program described in Part II, Sections 1 through 18 taken for nonsafety-related SSCs. 1.1 Organization The verification activities described in this part may be performed by the FPL line organization. The QA organization described in Part II is not required to perform these functions. 1.2 QA Program FPL QA requirements for nonsafety-related SSCs are established in the QAPD and appropriate procedures. Suppliers of these SSCs or related services describe the quality controls applied in appropriate procedures. A new or separate QA program is not required. 1.3 Design Control FPL has design control measures to ensure that the contractually established design requirements are included in the design. These measures ensure that applicable design inputs are included or correctly translated into the design documents, and deviations from those requirements are controlled. Design verification is provided through the normal supervisory review of the designer's work. 1.4 Procurement Document Control Procurement documents for items and services obtained by or for FPL include or reference documents describing applicable design bases, design requirements, and other requirements necessary to ensure component performance. The procurement documents are controlled to address deviations from the specified requirements. FPL-2 Revision 5 Page 60 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 62 of 85 FPL Quality Assurance Program Description SECTION 1 NON-SAFETY RELATED SSCs -SIGNIFICANT CONTRIBUTORS TO PLANT SAFETY (CONTINUED) 1.5 Instructions, Procedures, and Drawings FPL provides documents such as, but not limited to, written instructions, plant procedures, drawings, vendor technical manuals, and special instructions in work orders, to direct the performance of activities affecting quality. The method of instruction employed provides an appropriate degree of guidance to the personnel performing the activity to achieve acceptable functional performance of the SSC. 1.6 Document Control FPL controls the issuance and change of documents that specify quality requirements or prescribe activities affecting quality to ensure that correct documents are used. These controls include review and approval of documents, identification of the appropriate revision for use, and measures to preclude the use of superseded or obsolete documents. 1.7 Control of Purchased Items and Services FPL employs measures, such as inspection of items or documents upon receipt or acceptance testing, to ensure that all purchased items and services conform to appropriate procurement documents. 1.8 Identification and Control of Purchased Items FPL employs measures where necessary, to identify purchased items and preserve their functional performance capability. Storage controls take into account appropriate environmental, maintenance, or shelf life restrictions for the items. 1.9 Control of Special Processes FPL employs process and procedure controls for special processes, including welding, heat treating, and nondestructive testing. These controls are based on applicable codes, standards, specifications, criteria, or other special requirements for the special process. 1.10 Inspection FPL uses documented instructions to ensure necessary inspections are performed to verify conformance of an item or activity to specified requirements or to verify that activities are satisfactorily accomplished. These inspections are performed by knowledgeable personnel who may be in the same line organization as those performing the activity being inspected. FPL-2 Revision 5 Page 61 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 63 of 85 FPL Quality Assurance Program Description SECTION 1 NON-SAFETY RELATED SSCs -SIGNIFICANT CONTRIBUTORS TO PLANT SAFETY (CONTINUED) 1.11 Test Control FPL employs measures to identify required testing that demonstrates that equipment conforms to design requirements. These tests are performed in accordance with test instructions or procedures. The test results are recorded, and authorized individuals evaluate the results to ensure that test requirements are met. 1.12 Control of Measuring and Test Equipment (M&TE) FPL employs measures to control M&TE use, and calibration and adjustment at specific intervals or prior to use. 1.13 Handling, Storage, and Shipping FPL employs measures to control the handling, storage, cleaning, packaging, shipping, and preservation of items to prevent damage or loss and to minimize deterioration. These measures include appropriate marking or labels, and identification of any special storage or handling requirements. 1.14 Inspection, Test, and Operating Status FPL employs measures to identify items that have satisfactorily passed required tests and inspections and to indicate the status of inspection, test, and operability as appropriate. 1.15 Control of Nonconforming Items FPL employs measures to identify and control items that do not conform to specified requirements to prevent their inadvertent installation or use. 1.16 Corrective Action FPL employs measures to ensure that failures, malfunctions, deficiencies, deviations, defective components, and nonconformances are properly identified, reported, and corrected. 1.17 Records FPL employs measures to ensure records are prepared and maintained to furnish evidence that the above requirements for design, procurement, document control, inspection, and test activities have been met. FPL-2 Revision 5 Page 62 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 64 of85 FPL Quality Assurance Program Description SECTION 1 NON-SAFETY RELATED SSCs - SIGNIFICANT CONTRIBUTORS TO PLANT SAFETY (CONTINUED) 1.18 Audits FPL employs measures for line management to periodically review and document the adequacy of the process, including taking any necessary corrective action. Audits independent of line management are not required. Line management is responsible for determining whether reviews conducted by line management or audits conducted by any organization independent of line management are appropriate. If performed, audits are conducted and documented to verify compliance with design and procurement documents, instructions, procedures, drawings, and inspection and test activities. Where the measures of this part (Part Ill) are implemented by the same programs, processes, or procedures as the comparable activities of Part II, the audits performed under the provisions of Part II may be used to satisfy the review requirements of this Section (Part Ill, Section 1.18). SECTION 2 NON-SAFETY RELATED SSCs CREDITED FOR REGULATORY EVENTS The following criteria apply to fire protection (10 CFR 50.48), anticipated transients without scram (ATWS) (10 CFR 50.62), the station blackout (SBO) (10 CFR 50.63) SSCs that are not safety-related;
- FPL implements quality requirements for the fire protection system in accordance with Regulatory Position 1.7, "Quality Assurance," in Regulatory Guide 1.189, "Fire Protection for Operating Nuclear Power Plants."
- FPL implements the quality requirements for ATWS equipment in accordance with Generic Letter 85-06, "Quality Assurance Guidance for A TWS Equipment That Is Not Safety Related."
- FPL implements quality requirements for SBO equipment in accordance with Regulatory Position 3.5, "Quality Assurance and Specific Guidance for SBO Equipment That Is Not Safety Related," and Appendix A, "Quality Assurance Guidance for Nonsafety Systems and Equipment," in Regulatory Guide 1.155, "Station Blackout."
FPL-2 Revision 5 Page 63 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 65 of85 FPL Quality Assurance Program Description PART IV REGULATORY COMMITMENTS NRC REGULATORY GUIDES AND QUALITY ASSURANCE STANDARDS This section identifies the NRC Regulatory Guides and the other quality assurance standards which have been selected to supplement and support the FPL QAPD. See FSAR Chapter 1 for the FPL evaluation of conformance with the guidance in NRC Regulatory Guides in effect six months prior to the submittal date of the application. REGULATORY GUIDES Regulatory Guide 1.8, Rev. 3, May 2000, Qualification and Training of Personnel for Nuclear Power Plants Regulatory Guide 1.8 provides guidance that is acceptable to the NRC staff regarding qualifications and training for nuclear power plant personnel. FPL identifies conformance and exceptions for the applicable regulatory position guidance provided in this regulatory guide in FSAR Chapter 1. Regulatory Guide 1.26, Revision 4, March 2007 - Quality Group Classifications and Standards for Water-, Steam-, and Radioactive-Waste-Containing Components of Nuclear Power Plants Regulatory Guide 1.26 defines classification of systems and components. FPL identifies conformance and exceptions for the applicable regulatory position guidance provided in this regulatory guide in FSAR Chapter 1. Regulatory Guide 1.28, Rev. 3, August 1985, Quality Assurance Program Requirements (Design and Construction) Regulatory Guide 1.28 describes a method acceptable to the NRC staff for complying with the provisions of Appendix B with regard to establishing and implementing the requisite quality assurance program for the design and construction of nuclear power plants. FPL identifies conformance and exceptions for the applicable regulatory position guidance provided in this regulatory guide in FSAR Chapter 1. Regulatory Guide 1.29, Revision 4, March 2007 - Seismic Design Classification Regulatory Guide 1.29 defines systems required to withstand a safe shutdown earthquake (SSE). FPL identifies conformance and exceptions for the applicable regulatory position guidance provided in this regulatory guide in FSAR Chapter 1. FPL-2 Revision 5 Page 64 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 66 of 85 FPL Quality Assurance Program Description NRC REGULATORY GUIDES AND QUALITY ASSURANCE STANDARDS (CONTINUED) Regulatory Guide 1.33, Revision 2, February 1978, Quality Assurance Program Requirements (Operations) Regulatory Guide 1.33 describes a method acceptable to the NRC staff for complying with the Commission's regulations with regard to overall quality assurance program requirements for the operation phase of nuclear power plants. FPL identifies conformance and exceptions for the applicable regulatory position guidance provided in this regulatory guide in FSAR Chapter 1. Regulatory Guide 1.37, Revision 1, March 2007 - Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants Regulatory Guide 1.37 provides guidance on specifying water quality and precautions related to the use of alkaline cleaning solutions and chelating agents. FPL identifies conformance and exceptions for the applicable regulatory position guidance provided in this regulatory guide in FSAR Chapter 1. Regulatory Guide 1.54, Revision 1, July 2000 - Service Level I, II, and Ill Protective Coatings Applied to Nuclear Power Plants Regulatory Guide 1.54 provide guidance for the application of protective coatings within nuclear power plants to protect surfaces from corrosion, contamination from radionuclides, and for wear protection. FPL identifies conformance and exceptions for the applicable regulatory position guidance provided in this regulatory guide in FSAR Chapter 1. For plants with an NFPA 805 fire protection licensing bases, NextEra Energy commits to implement Regulatory Guide 1.205, December 2009, Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants, which endorses in part, NEI 04-02, Revision 2, Nuclear Energy Institute Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48( c). The implementation of these documents is described in the station specific Technical Specifications and License Conditions and station specific NRC approved Safety Evaluation Reports. FPL-2 Revision 5 Page 65 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 67 of85 FPL Quality Assurance Program Description NRC REGULATORY GUIDES AND QUALITY ASSURANCE STANDARDS (CONTINUED) STANDARDS ASME NQA-1-1994 Edition - Quality Assurance Requirements for Nuclear Facility Applications FPL commits to NQA-1-1994, Parts I, II, and Ill, as described in the foregoing sections of this document. Nuclear Information and Records Management Association, Inc. (NIRMA) Technical Guides {TGs) FPL commits to NIRMA TGs as described in Part II, Section 17. FPL-2 Revision 5 Page 66 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 68 of 85 FPL Quality Assurance Program Description PART V ADDITIONAL QUALITY ASSURANCE AND ADMINISTRATIVE CONTROLS FOR THE PLANT OPERATIONAL PHASE FPL includes the requirements of Part V to establish the necessary measures and governing procedures for the operations phase of the plant. SECTION 1 DEFINITIONS FPL uses the definitions of terms as provided in Section 4 of the Introduction of NQA-1-1994 in interpreting the requirements of NQA-1-1994 and the other standards to which the QAPD commits. In addition, definitions are provided for the following terms not covered in NQA-1-1994: administrative controls: rules, orders, instructions, procedures, policies, practices and designations of authority and responsibility experiments: performance of plant operations carried out under controlled conditions in order to establish characteristics or values not previously known independent review: review completed by personnel not having direct responsibility for the work function under review regardless of whether they operate as a part of an organizational unit or as individual staff members (see review) nuclear power plant: any plant using a nuclear reactor to produce electric power, process steam or space heating on-site operating organization: on-site personnel concerned with the operation, maintenance and certain technical services operating activities: work functions associated with normal operation and maintenance of the plant, and technical services routinely assigned to the on-site operating organization operational phase: that period of time during which the principal activity is associated with normal operation of the plant. This phase of plant life is considered to begin formally with commencement of initial fuel loading, and ends with plant decommissioning review: a deliberately critical examination, including observation of plant operation, evaluation of assessment results, procedures, certain contemplated actions, and after-the-fact investigations of abnormal conditions supervision: direction of personnel activities or monitoring of plant functions by an individual responsible and accountable for the activities they direct or monitor surveillance testing: periodic testing to verify that safety related structures, systems, and components continue to function or are in a state of readiness to perform their functions system: an integral part of nuclear power plant comprising components which may be operated or used as a separate entity to perform a specific function FPL-2 Revision 5 Page 67 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 69 of85 FPL Quality Assurance Program Description SECTION 2 REVIEW OF ACTIVITIES AFFECTING SAFE PLANT OPERATION 2.1 Onsite Operating Organization Review The FPL onsite organization employs reviews, both periodic and as situations demand, to evaluate plant operations and plan future activities. The important elements of the reviews are documented and subjects of potential concern for the independent review described below are brought to the attention of the Plant Manager. The reviews are part of the normal duties of plant supervisory personnel in order to provide timely and continuing monitoring of operating activities in order to assist the Plant Manager in keeping abreast of general plant conditions and to verify that day-to-day operations are conducted safely in accordance with the established administrative controls. The Plant Manager ensures the timely referral of the applicable matters discussed in the reviews to appropriate management and independent reviewers. 2.2 Independent Review Activities occurring during the operational phase shall be independently reviewed on a periodic basis. The independent review program shall be functional prior to initial core loading. The independent review function performs the following:
- a. Reviews proposed changes to the facility as described in the safety analysis report (SAR). The Independent Review Committee (IRC) also verifies that changes do not adversely affect safety and if a technical specification change or NRC review is required.
- b. Reviews proposed tests and experiments not described in the SAR prior to implementation. Verifies the determination of whether changes to proposed tests and experiments not described in the SAR require a technical specification change or license amendment.
- c. Reviews proposed technical specification changes and license amendments relating to nuclear safety prior to NRC submittal and implementation, except in those cases where the change is identical to a previously approved change.
- d. Reviews violations, deviations, and events that are required to be reported to the NRC. This review includes the results of investigations and recommendations resulting from such investigations to prevent or reduce the probability of recurrence of the event.
- e. Reviews any matter related to nuclear safety that is requested by the Site Director/
PGM
- f. Reviews corrective actions for significant conditions adverse to quality.
- g. Reviews internal audit reports.
- h. Reviews the adequacy of the internal audit program every 24 months.
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Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 70 of 85 FPL Quality Assurance Program Description SECTION 2 REVIEW OF ACTIVITIES AFFECTING SAFE PLANT OPERATION (CONTINUED) Independent Review Committee
- 1. An independent review committee is assigned independent review responsibilities.
- 2. The independent review committee reports to the Site Director/ PGM.
- 3. The independent review committee is composed of no less than 5 persons and no more than a minority of members are from the on-site operating organization.
For example, at least 3 of the 5 members must be from off-site if there are 5 members on the committee. A minimum of the chairman or alternative chairman and 2 members must be present for all meetings.
- 4. During the period of initial operation, meetings are conducted no less frequently than once per calendar quarter. Afterwards meetings are conduced no less than twice a year.
- 5. Results of the meeting are documented and recorded.
- 6. Consultants and contractors are used for the review of complex problems beyond the expertise of the off site/on site independent review committee.
- 7. Persons on the independent review committee are qualified as follows:
- a. Supervisor or Chairman of the Independent Review Committee
- Education: baccalaureate in engineering or related science
- Minimum experience: 6 years combined managerial and technical support
- b. Independent Review Committee Members Education: Baccalaureate in engineering or related science for those Independent review personnel who are required to review problems in:
- nuclear power plant operations,
- nuclear engineering,
- chemistry and radiochemistry,
- metallurgy,
- nondestructive testing,
- instrumentation and control,
- radiological safety,
- mechanical engineering, and electrical engineering.
FPL-2 Revision 5 Page 69 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 7.1 of 85 FPL Quality Assurance Program Description SECTION 2 REVIEW OF ACTIVITIES AFFECTING SAFE PLANT OPERATION (CONTINUED) High school diploma for those independent review personnel who are required to review problems in administrative control and quality assurance practices, training, and emergency plans and related procedures and equipment. Minimum experience: 5 years experience in their own area of responsibility (nuclear power plant operations, nuclear engineering, chemistry and radiochemistry, metallurgy, nondestructive testing, instrumentation and control, radiological safety, mechanical engineering, and electrical engineering, administrative control and quality assurance practices, training, and emergency plans and related procedures and equipment). An independent biennial assessment includes an examination of selected procedures to verify that the procedure review and revision controls of Section B.14 are effectively implemented. Results of independent assessments are reported in an understandable form and in a timely fashion to a level of management having the authority to effect corrective action. Nuclear Assurance conducts timely follow-up action, including re-assessment of deficient areas, as necessary, to establish adequacy of corrective actions. Independent assessment results are documented and reviewed by Nuclear Assessment management and by management having responsibility for the area assessed. In addition, Nuclear Assurance activities are periodically assessed for effectiveness. Results are documented and reported to responsible management. Nuclear Assurance provides for assessment of work carried out under the requirements of the OAP that is delegated to other (non-NextEra Energy) entities. Independent Assessments are performed on a fixed frequency. Independent Assessments of the topics in Table 1 are *audited at least biennially. A 90-day grace period may be applied to these non-regulatory topics in executing this periodicity. When the grace period is applied, the next due date for the activity is based upon the original scheduled date. However, in all cases the periodicity shall not exceed two years plus 90 days. Certain activities, as identified in Table 2, receive independent assessments at frequencies established by related NRC rules. A grace period shall not be applied to these regulatory topics unless permitted by the NRC rule. FPL-2 Revision 5 Page 70 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 72 of 85 FPL Quality Assurance Program Description SECTION 2 REVIEW OF ACTIVITIES AFFECTING SAFE PLANT OPERATION (CONTINUED) Table 1 Topics Subject to Independent Assessment with QATR Defined Frequency
. , *T:ppic 1 '
', / ,.,
a ,Y *,: :. .. , ' , Chemistry, Effluents & Environmental Monitoring Engineering Maintenance/ Work Management Nuclear Assurance Operations Performance Improvement Procurement & Nuclear Materials Management QA Programs Radiological Protection & Radwaste Training Table 2 Topics Subject to Independent Assessment with Regulatory Defined Frequency
. *~' .:
Cyber Security Emergency Planning Fire Protection Fitness For Duty and Access Authorization Independent Spent Fuel Storage Security
- 1. Topic titles in these tables may vary; however, all program elements (i.e. applicable regulatory requirements and all 10 CFR 50 Appendix B criteria) will be covered as identified in implementing procedures.
FPL-2 Revision 5 Page 71 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 73 of 85 FPL Quality Assurance Program Description SECTION 3 OPERATIONAL PHASE PROCEDURES The following is a description of the various types of procedures used by FPL to govern the design, operation, and maintenance of its nuclear generating plants. FPL follows the guidance of Appendix A to Regulatory Guide 1.33 in identifying the types of activities that should have procedures or instructions to control the activity. Each procedure shall be sufficiently detailed for a qualified individual to perform the required function without direct supervision, but need not provide a complete description of the system or plant process. 3.1 Format and Content Procedure format and content may vary from one location to the other. However, procedures include the following elements as appropriate to the purpose or task to be described:
- Title/Status Each procedure is given a title descriptive of the work or subject it addresses, and includes a revision number and/or date and an approval status.
- Purpose/Statement of Applicability/Scope The purpose for which the procedure is intended is clearly stated (if not clear from the title). The systems, structures, components, processes or conditions to which the procedure applies are also clearly described.
- References Applicable references, including reference to appropriate Technical Specifications, are required. References are included within the body of the procedure when the sequence of steps requires other tasks to be performed (according to the reference) prior to or concurrent with a particular step.
- Prerequisites/Initial Conditions Prerequisites/initial conditions identify those independent actions or procedures that must be accomplished and plant conditions which must exist prior to performing the procedure. A prerequisite applicable to only a specific portion of a procedure is so identified.
- Precautions Precautions alert the user to those important measures to be used to protect equipment and personnel, including the public, or to avoid an abnormal or emergency situation during performance of the procedure. Cautionary notes applicable to specific steps are included in the main body of the procedure and are identified as such.
- Limitations and Actions Limitations on the parameters being controlled and appropriate corrective measures to return the parameter to the normal control band are specified.
FPL-2 Revision 5 Page 72 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 74 of 85 FPL Quality Assurance Program Description SECTION 3 OPERATIONAL PHASE PROCEDURES (CONTINUED)
- Main Body The main body of the procedure contains the step-by-step instructions in the degree of detail necessary for performing the required function or task.
- Acceptance Criteria The acceptance criteria provide the quantitative or qualitative criteria against which the success or failure (as of a test-type activity) of the step or action would be judged.
- Checklists Complex procedures utilize checklists which may be included as part of the procedure or appended to it.
3.2 Procedure Types Administrative Control Procedures These include administrative procedures, directives, policies, standards, and similar documents that control the programmatic aspects of facility activities. These administrative documents ensure that the requirements of regulatory and license commitments are implemented. Several levels of administrative controls are applied ranging from those affecting the entire Company to those prepared at the implementing group level. These documents establish responsibilities, interfaces, and standard methods (rules of practice) for implementing programs. In addition to the administrative controls described throughout this QAPD, instructions governing the following activities are provided:
- Operating Orders/Procedures Instructions of general and continuing applicability to the conduct of business to the plant staff are provided. Examples where these are applied include, but are not limited to, job turnover and relief, designation of confines of control room, definition of duties of operators and others, transmittal of operating data to management, filing of charts, limitations on access to certain areas and equipment, shipping and receiving instructions.
Provisions are made for periodic review and updating of these documents, where appropriate.
- Special Orders Management instructions, which have short-term applicability and require dissemination, are issued to encompass special operations, housekeeping, data taking, publications and their distribution, plotting process parameters, personnel actions, or other similar matters.
Provisions are made for periodic review, updating, and cancellation of these documents, where appropriate. FPL-2 Revision 5 Page 73 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 75 of 85 FPL Quality Assurance Program Description SECTION 3 OPERATIONAL PHASE PROCEDURES (CONTINUED)
- Plant Security and Visitor Control Procedures or instructions are developed to supplement features and physical barriers designed to control access to the plant and, as appropriate, to vital areas within the plant.
Information concerning specific design features and administrative provisions of the plant security program is confidential and thus accorded limited distribution. The security and visitor.control procedures consider, for example, physical provisions, such as: fences and lighting; lock controls for doors, gates and compartments containing sensitive equipment; and provisions for traffic and access control. Administrative provisions, such as: visitor sign-in and sign-out procedures; escorts and badges for visitors; emphasis on inspection, observation and challenging of strangers by operating crews; and a program of pre-employment screening for potential employees are also considered.
- Temporary Procedures Temporary procedures may be used to direct operations during testing, refueling, maintenance, and modifications to provide guidance in unusual situations not within the scope of the normal procedures. These procedures ensure orderly and uniform operations for short periods when the plant, a system, or a component of a system is performing in a manner not covered by existing detailed procedures or has been modified or extended in such a manner that portions of existing procedures do not apply.
Temporary Procedures include designation of the period of time during which they may be used and are subject to the procedure review process as applicable. Engineering Procedures These documents provide instructions for the preparation of engineering documents, engineering analysis, and implementation of engineering programs. This includes activities such as designs; calculations; fabrication, equipment, construction, and installation specifications; drawings; analysis and topical reports; and testing plans or procedures. They include appropriate references to industry codes and standards, design inputs, and technical requirements. Installation Procedures These documents provide instructions for the installation of components generally related to new construction and certain modification activities. They include appropriate reference to industry standards, installation specifications, design drawings, and supplier and technical manuals for the performance of activities. These documents include provisions, such as hold or witness points, for conducting and recording results of required inspections or tests. These documents may include applicable inspection and test instructions subject to the requirements for test and inspection procedures below. FPL-2 Revision 5 Page 74 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 76 of 85 FPL Quality Assurance Program Description SECTION 3 OPERATIONAL PHASE PROCEDURES (CONTINUED) System Procedures These documents contain instructions for energizing, filling, venting, draining, starting up, shutting down, changing modes of operation, and other instructions appropriate for operations of systems related to the safety of the plant. Actions to correct off-normal conditions are invoked following an operator observation or an annunciator alarm indicating a condition which, if not corrected, could degenerate into a condition requiring action under an emergency procedure. Separate procedures may be developed for correcting off-normal conditions for those events where system complexity may lead to operator uncertainty. Appropriate procedures will also be developed for the fire protection program. Start-up Procedures These documents contain instructions for starting the reactor from cold or hot conditions and establishing power operation. This includes documented determination that prerequisites have been met, including confirmation that necessary instruments are operable and properly set; valves are properly aligned, necessary system procedures, tests and calibrations have been completed; and required approvals have been obtained. Shutdown Procedures These documents contain guidance for operations during controlled shutdown and following reactor trips, including instructions for establishing or maintaining hot shutdown/standby or cold shutdown conditions, as applicable. The major steps involved in shutting down the plant are specified, including instructions for such actions as monitoring and controlling reactivity, load reduction and cooldown rates, sequence for activating or deactivating equipment, requirements for prompt analysis for causes of reactor trips or abnormal conditions requiring unplanned controlled shutdowns, and provisions for decay heat removal. Power Operation and Load Changing Procedures These documents contain instructions for steady-state power operation and load changing. These type documents include, as examples, provisions for use of control rods, chemical shim, coolant flow control, or any other system available for short-term or long-term control of reactivity, making deliberate load changes, responding to unanticipated load changes, and adjusting operating parameters. Process Monitoring Procedures These documents contain instructions for monitoring performance of plant systems to assure that core thermal margins and coolant quality are maintained in acceptable status at all times, that integrity of fission product barriers is maintained, and that engineered safety features and emergency equipment are in a state of readiness to keep the plant in a safe condition if needed. Maximum and minimum limits for process parameters are appropriately identified. Operating procedures address the appropriate nature and frequency of this monitoring. FPL-2 Revision 5 Page 75 of 80 May 28, 2019
. ~
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 77 of 85 FPL Quality Assurance Program Description SECTION 3 OPERATIONAL PHASE PROCEDURES (CONTINUED) Fuel Handling Procedures These documents contain instructions for core alterations, accountability of fuel and partial or complete refueling operations that include, for example, continuous monitoring of neutron flux throughout core loading, periodic data recording, audible annunciation of abnormal flux increases, and evaluation of core neutron multiplication to verify safety of loading increments. Procedures are also provided for receipt and inspection of new fuel, and for fuel movements in the spent fuel storage areas. Fuel handling procedures include prerequisites to verify the status of systems required for fuel handling and movement; inspection of replacement fuel and control rods; designation of proper tools, proper conditions for spent fuel movement, proper conditions for fuel cask loading and movement; and status of interlocks, reactor trip circuits and mode switches. These procedures provide requirements for refueling, including proper sequence, orientation and seating of fuel and components, rules for minimum operable instrumentation, actions for response to fuel damage, verification of shutdown margin, communications between the control room and the fuel handling station, independent verification of fuel and component locations, criteria for stopping fuel movements, and documentation of final fuel and component serial numbers (or other unique identifiers) and locations. Maintenance Procedures These documents contain instructions in sufficient detail to permit maintenance work to be performed correctly and safely, and include provisions, such as hold or witness points, for conducting and recording results of required inspections or tests. These documents may include applicable inspection or test instructions subject to the requirements for test and inspection procedures below. Appropriate referencing to other procedures, standards, specifications, or supplier manuals is provided. When not provided through other documents, instructions for equipment removal and return to service, and applicable radiation protection measures (such as protective clothing and radiation monitoring) will be included. Additional maintenance procedure requirements are addressed in NQA-1-1994, Subpart 2.18, Section 2.2, Procedures. Radiation Control Procedures These documents contain instructions for implementation of the radiation control program requirements necessary to meet regulatory commitments, including acquisition of data and use of equipment to perform necessary radiation surveys, measurements and evaluations for the assessment and control of radiation hazards. These procedures provide requirements for monitoring both external and internal exposures of employees, utilizing accepted techniques; routine radiation surveys of work areas; effluent and environmental monitoring in the vicinity of the plant; radiation monitoring of maintenance and special work activities, and for maintaining records demonstrating the adequacy of measures taken to control radiation exposures to employees and others. FPL-2 Revision 5 Page 76 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 78 of 85 FPL Quality Assurance Program Description SECTION 3 OPERATIONAL PHASE PROCEDURES (CONTINUED) Calibration and Test Procedures These documents contain instructions for periodic calibration and testing of instrumentation and control systems, and for periodic calibration of measuring and test equipment used in activities affecting the quality of these systems. These documents provide for meeting surveillance requirements and for assuring measurement accuracy adequate to keep safety-related parameters within operational and safety limits. Chemical and Radiochemical Control Procedures These documents contain instructions for chemical and radiochemical control activities and include: the nature and frequency of sampling and analyses; instructions for maintaining coolant quality within prescribed limits; and limitations on concentrations of agents that could cause corrosive attack, foul heat transfer surfaces, or become sources of radiation hazards due to activation. These documents also provide for the control, treatment and management of radioactive wastes, and control of radioactive calibration sources. Emergency Operating Procedures These documents contain instructions for response to potential emergencies so that a trained operator will know in advance the expected course of events that will identify an emergency and the immediate actions that are taken in response. Format and content of emergency procedures are based on NU REG and Owner's Group(s) guidance that identify potential emergency conditions and require such procedures to include, as appropriate, a title, symptoms to aid in identification of the nature of the emergency, automatic actions to be expected from protective systems, immediate operator actions for operation of controls or confirmation of automatic actions, and subsequent operator actions to return the reactor to a normal condition or provide for a safe extended shutdown period under abnormal or emergency conditions. Emergency Plan Implementing Procedures These documents contain instructions for activating the Emergency Response Organization and facilities, protective action levels, organizing emergency response actions, establishing necessary communications with local, state and federal agencies, and for periodically testing the procedures, communications and alarm systems to assure they function properly. Format and content of such procedures are such that requirements of each facility's NRC approved Emergency Plan are met. FPL-2 Revision 5 Page 77 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 79 of 85 FPL Quality Assurance Program Description SECTION 3 OPERATIONAL PHASE PROCEDURES (CONTINUED) Test and Inspection Procedures These documents provide the necessary measures to assure quality is achieved and maintained for the nuclear facilities. The instructions for tests and inspections may be included within other procedures, such as installation and maintenance procedures, but will contain the objectives, acceptance criteria, prerequisites for performing the test or inspection, limiting conditions, and appropriate instructions for performing the test or inspection, as applicable. These procedures also specify any special equipment or calibrations required to conduct the test or inspection and provide for appropriate documentation and evaluation by responsible authority to assure test or inspection requirements have been satisfied. Where necessary, hold or witness points are identified within the procedures and require appropriate approval for the work to continue beyond the designated point. These procedures provide for recording the date, identification of those performing the test or inspection, as-found condition, corrective actions performed (if any), and as-left condition, as appropriate for the subject test or inspection. FPL-2 Revision 5 Page 78 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 80 of 85 FPL Quality Assurance Program Description SECTION 4 CONTROL OF SYSTEMS AND EQUIPMENT IN THE OPERATIONAL PHASE Permission to release systems and equipment for maintenance or modification is controlled by designated operating personnel and documented. Measures, such as installation of tags or locks and releasing stored energy, are used to ensure personnel and equipment safety. When entry into a closed system is required, FPL has established control measures to prevent entry of extraneous material and to assure that foreign material is removed before the system is reclosed. Administrative procedures require the designated operating personnel to verify that the system or equipment can be released and determine the length of time it may be out of service. In making this determination, attention is given to the potentially degraded degree of protection where one subsystem of a redundant safety system is not available for service. Conditions to be considered in preparing equipment for maintenance include, for example: shutdown margin; method of emergency core cooling; establishment of a path for decay heat removal; temperature and pressure of the system; valves between work and hazardous material; venting, draining and flushing; entry into closed vessels; hazardous atmospheres; handling hazardous materials; and electrical hazards. When systems or equipment are ready to be returned to service, designated operating personnel control placing the items in service and document its functional acceptability. Attention is given to restoration of normal conditions, such as removal of jumpers or signals used in maintenance or testing, or actions such as returning valves, breakers or switches to proper start-up or operating positions from "test" or "manual" positions. Where necessary, the equipment placed into service receives additional surveillance during the run-in period. Independent verifications, where appropriate, are used to ensure that the necessary measures have been implemented correctly. The minimum requirements and standards for using independent verification are established in company documents. FPL-2 Revision 5 Page 79 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 81 of 85 FPL Quality Assurance Program Description SECTION 5 PLANT MAINTENANCE FPL establishes controls for the maintenance or modification of items and equipment subject to this QAPD to ensure quality at least equivalent to that specified in original design bases and requirements, such that safety-related structures, systems and components are maintained in a manner that assures their ability to perform their intended safety function(s). Maintenance activities (both corrective and preventive) are scheduled and planned so as not to unnecessarily compromise the safety of the plant. In establishing controls for plant maintenance, FPL commits to compliance with NQA-1-1994, Subpart 2.18, with the following clarifications:
- Where Subpart 2.18 refers to the requirements of ANS-3.2, it shall be interpreted to mean the applicable standards and requirements established within the QAPD
- Section 2.3 requires cleanliness during maintenance to be in accordance with Subpart 2.1. The commitment to Subpart 2.1 is described in the QAPD, Part II, Section 13.2.
FPL-2 Revision 5 Page 80 of 80 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 82 of 85 C) Organization Chart
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 83 of 85 NPP CONSTRUCTION AND STARTUP ORGANIZATION NextEra Energy Chairman CEO NextEra Energy President coo Executive VP Executive VP & CNO Engineering, Construction
& Corporate Services I
Director Nuclear Assurance Vice President Integrated Supply Chain I Vice President New Nuclear Projects QA Project Manager New Nuclear Projects 1-------------- 1 Plant General Manager-Sourcing
~ Manager New Nuclear Projects Licensing Director Project Director New Nuclear New Nuclear Projects Projects Engineering Site Construction Director Testing Director Director New Nuclear Projects New Nuclear Projects
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 84 of 85 ORGANIZATION RELATIONSHIPS OF KEY MANAGEMENT & FUNCTIONAL GROUPS (CORPORA TE) CHAIRMAN CHIEF EXECUTIVE OFFICER (CEO) EXECUTIVE EXECUTIVE VICE VICE PRESIDENT PRESIDENT ENGINEERING, PRESIDENT NUCLEAR DIVISION & CONSTRUCTION & ISC CFO VICE PRESIDENT NUCLEAR DIVISION & CHIEF NUCLEAR OFFICER (CNO)" VICE PRESIDENT CIC I VICE PRESIDENT INTEGRATED SUPPLY SENIOR DIRECTOR VICE PRESIDENT VICE PRESIDENT DIRECTOR CHAIN FINANCE, NEW NUCLEAR CORPORATE NUCLEAR ASSURANCE NUCLEAR FLEET SUPPORT & ASSESSMENT SENIOR DIRECTOR IT BUSINESS SOLUTIONS I SENIOR DIRECTOR GENERAL MANAGER GENERAL MANAGER PROJECTS& CFAMS FLEET ENGINEERING CONSTRUCTION IT TECHNOLOGY DIRECTOR BUSINESS DIRECTOR FLEET DESIGN ENGINEERING ( OFF-SITE (1) )
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --------------------------------------r----
C ON-SITE (1) ) SITE DIRECTORS/ PLANT GENERAL SITE SITE DESIGN SITE INFORMATION MANAGERS ENGINEERING ENGINEERING NUCLEAR ASSURANCE TECHNOLOGY DIRECTORS MANAGERS MANAGERS LEADER
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 1 Page 85 of 85 ORGANIZATION RELATIONSHIPS OF KEY MANAGEMENT & FUNCTIONAL GROUPS (SITE)
. *-*-*-*-*-*1 . *-*-*-*-*-*1 . *-*-*-*-*-*1 SITE I ENGINEERING I SECURITY
- I NUCLEAR
- DIRECTORS/ PGM . SITE I SITE I SITE I I ASSURANCE I I DIRECTORS . MANAGER I I DESIGN MANAGER .
. I . MANAGER I
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ENGINEERING MAINTENANCE - SITE - CHEMISTRY MANAGER SITE DIRECTOR
- MANAGER-PROGRAMS ENGINEERING
- SITE SAFETY WORK MANAGER -SYSTEMS r--
HEALTH MANAGEMENT SITE - MANAGER MANAGER TRAINING RADIATION SITE PROTECTION MANAGER MANAGER ~ OPERATIONS Licensing Manager f--- SITE DIRECTOR I I Emergency OPERATIONS ASST. Preparedness (1) Seabrook does not have Shift Technical Advisors-this position combined with Shift Manager I SRO MANAGER* LINE Manager (2) Meets position of Operations Supervisor
--Organizational titles are generic-specific site organizational titles may differ--
I .-* -*-. -*-* I IT
- 1*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*:
SHIFT BUSINESS I MANAGER I SOLUTIONS I (2) I Denotes direct reporting relationship to corporate organization, [ _. -~~~E~. - . _; but physically located at sites I I
. I SHIFT L*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*-*
TECHNICAL ADVISORS (1)
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 1 of 87 Enclosure 2 Florida Power and Light Company Quality Assurance Program Description for 10 CFR Part 52 Licenses FPL-2 Revision 4 Track-Changes Markup
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 2 of 87 0 FPL. Florida Power and Light Company Quality Assurance Program Description for 10 CFR Part 52 Licenses FPL-2 FPL-2 Revision 4Q Page 1 of 86 April 2Q, 2QHlJldl'f 13 2QHlMay 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 3 of 87 FPL Quality Assurance Program Description POLICY STATEMENT Florida Power and Light (FPL) shall design, procure, construct and operate nuclear plants in a manner that will ensure the health and safety of the public and workers. These activities shall be performed in compliance with the requirements of the Code of Federal Regulations (CFR), the applicable Nuclear Regulatory Commission (NRC) Facility Operating Licenses, and applicable laws and regulations of the state and local governments. The FPL New Nuclear Projects (NNP) Quality Assurance Program (QAP) is the Quality Assurance Program Description (QAPD) provided in this document and the associated implementing documents. Together they provide for control of FPL activities that affect the quality of safety-related nuclear plant structures, systems, and components (SSCs) and include all planned and systematic activities necessary to provide adequate confidence that such SSCs will perform satisfactorily in service. The QAPD may also be applied to certain equipment and activities that are not safety-related, but support safe plant operations, or where other NRC guidance establishes program requirements. The QAPD is the top-level policy document that establishes the manner in which quality is to be achieved, and presents FPL's overall philosophy regarding achievement and assurance of quality. Implementing documents assign more detailed responsibilities and requirements and define the organizational interfaces involved in conducting activities within the scope of the QAP. Compliance with the QAPD and implementing documents is mandatory for personnel directly or indirectly associated with implementation of the FPL NNP QAP. Signed: James L. Robo NextEra Energy President and Chief Executive Officer FPL-2 Revision 4.§. Page 2 of 86AJJril 2G, 2QHlJlily 13 2G18/\aril 1, 2Q1 Q May 28,2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 4 of 87 FPL Quality Assurance Program Description Approved By: F. A. Banks Director Nuclear Assurance & Assessment Date W. D. Maher For Vice President - New Nuclear Projects Date D. Moul Vice President and Chief Nuclear Officer Date Mano Nazar President Nuclear Division Date FPL-2 Revision 4.§. Page 3 of 86/\pril ::l!J, ;:igrnJul*,* 1.i. ;:igrn/1.pril 1 2!J19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 5 of 87 FPL Quality Assurance Program Description TABLE OF CONTENTS POLICY STATEMENT ............................................................................................................................ 2 PART I INTRODUCTION .................................................................................................................. 8 SECTION 1 GENERAL .......................................................................................................................................8 PARTII QAPD DETAILS ................................................................................................................. 10 SECTION 1 ORGANIZATION ..........................................................................................................................10 Figure 1-1: NPP Construction and Startup Organization .................................................................. 26 Figure 1-2: NextEra Energy Nuclear Fleet Corporate Operating Organization ................................. 26 Figure 1-3: NextEra Energy Nuclear Fleet Site Organization ........................................................... 30 SECTION 2 QUALITY ASSURANCE PROGRAM .......................................................................................30 2.1 Responsibilities ............................................................................................................. 33 2.2 Delegation of Work ....................................................................................................... 33 2.3 Site-specific Safety-Related Design Basis Activities ...................................................... 33 2.4 Periodic Review of the Quality Assurance Program ....................................................... 34 2.5 Issuance and Revision to Quality Assurance Program .................................................. 34 2.6 Personnel Qualifications ............................................................................................... 34 2.7 NQA-1-1994 Commitment/ Exceptions ........................................................................ 35 SECTION 3 DESIGN CONTROL ....................................................................................................................37 3.1 Design Verification ........................................................................................................ 37 3.2 Design Records ............................................................................................................ 38 3.3 Computer Application and Digital Equipment Software .................................................. 38 3.4 Setpoint Control ............................................................................................................ 38 3.5 NQA-1-1994 Commitment .............................................................................................. 39 SECTION 4 PROCUREMENT DOCUMENT CONTROL.. ...........................................................................40 4.1 NQA-1-1994 Commitment/ Exceptions ........................................................................ 40 SECTION 5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS ..........................................................42 5.1 Procedure Adherence ................................................................................................... 42 5.2 Procedure Content ....................................................................................................... 42 5.3 NQA-1-1994 Commitment ............................................................................................ 42 SECTION 6 DOCUMENT CONTROL. ............................................................................................................43 6.1 Review and Approval of Documents ............................................................................. 44 6.2 Changes to Documents ................................................................................................ 44 6.3 NQA-1-1994 Commitment ............................................................................................ 44 SECTION 7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES .....................45 7.1 Acceptance of Item or Service ...................................................................................... 45 7.2 NQA-1-1994 Commitment/ Exceptions ........................................................................ 46 SECTION 8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS .... 50 8.1 NQA-1-1994 Commitment ............................................................................................ 50 SECTION 9 CONTROL OF SPECIAL PROCESSES ..................................................................................51 9.1 NQA-1-1994 Commitment ............................................................................................ 51 FPL-2 Revision 4.§ Page 4 of 86April 2Q, 2Q1!!J1,11y 1a, 2Q1!!Jl.eril 1, 2Q1Q May 28,2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 6 of87 FPL Quality Assurance Program Description TABLE OF CONTENTS (Continued) SECTION 10 INSPECTION ................................................................................................................................52 10.1 Inspection Program ...................................................................................................... 52 10.2 Inspector Qualification .................................................................................................. 52 10.3 NQA-1-1994 Commitment/ Exceptions ........................................................................ 53 SECTION 11 TEST CONTROL ..........................................................................................................................54 11.1 NQA-1-1994Commitment ............................................................................................ 54 11.2 NQA-1-1994 Commitment for Computer Program Testing ............................................ 54 SECTION 12 CONTROL OF MEASURING AND TEST EQUIPMENT........................................................55 12.1 Installed Instrument and Control Devices ...................................................................... 55 12.2 NQA-1-1994 Commitment/ Exceptions ........................................................................ 55 SECTION 13 HANDLING, STORAGE, AND SHIPPING ...............................................................................56 13.1 Housekeeping .............................................................................................................. 56 13.2 NQA-1-1994 Commitment/ Exceptions ........................................................................ 57 SECTION 14 INSPECTION, TEST, AND OPERATING STATUS ................................................................59 14.1 NQA-1-1994 Commitment ............................................................................................ 59 SECTION 15 NONCONFORMING SERVICES, MATERIALS, PARTS, OR COMPONENTS ................ 60
- 15. 1 Reporting Program ....................................................................................................... 60 15.2 NQA-1-1994 Commitment ............................................................................................ 60 SECTION 16 CORRECTIVE ACTION ..............................................................................................................61 16.1 Reporting Program ....................................................................................................... 61 16.2 NQA-1-1994 Commitment ............................................................................................ 61 SECTION 17 QUALITY ASSURANCE RECORDS ........................................................................................62 17.1 Record Retention ......................................................................................................... 62 17.2 Electronic Records ....................................................................................................... 62 17.3 NQA-1-1994 Commitment I Exceptions ........................................................................ 62 SECTION 18 AUDITS ..........................................................................................................................................63 18.1 Performance of Audits .................................................................................................. 63 18.2 Internal Audits .............................................................................................................. 64 18.3 NQA-1-1994 Commitment ............................................................................................ 65 PART Ill NONSAFETY-RELATED SSC QUALITY CONTROL ..................................................... 66 SECTION 1 NON-SAFETY RELATED SSCs - SIGNIFICANT CONTRIBUTORS TO PLANT SAFETY ........... 66 SECTION 2 NON-SAFETY RELATED SSCs CREDITED FOR REGULATORY EVENTS ................................ 69 PART IV REGULATORY COMMITMENTS ................................................................................... 70 REGULATORY GUIDES .....................................................................................................................................70 STANDARDS ........................................................................................................................................................72 FPL-2 Revision 4.§ Page 5 of 86April 2Q, 2Q18July 13. 2Q18A13ril 1. 2Q19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 7 of 87 FPL Quality Assurance Program Description TABLE OF CONTENTS (Continued) PART V ADDITIONAL QUALITY ASSURANCE AND ADMINISTRATIVE CONTROLS FOR THE PLANT OPERATIONAL PHASE ........................................................................................................... 73 SECTION 1 DEFINITIONS ...............................................................................................................................73 SECTION 2 REVIEW OF ACTIVITIES AFFECTING SAFE PLANT OPERATION ................................. 74 SECTION 3 OPERATIONAL PHASE PROCEDURES ................................................................................78 SECTION 4 CONTROL OF SYSTEMS AND EQUIPMENT IN THE OPERATIONAL PHASE ............. 85 SECTION 5 PLANT MAINTENANCE .............................................................................................................86 FPL-2 Revision 4.§. Page 6 of 86/\l)Fil 2Q, 2grnJt1ly 13, 2Q18A1,ril 1, 2Q19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 8 of 87 FPL Quality Assurance Program Description This page intentionally left blank FPL-2 Revision 4.§. Page 7 of 86ApFil 2Q, 2Q18Jllly 13, 2Q18.0.eFil 1 2Q19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 9 of 87 FPL Quality Assurance Program Description PART I INTRODUCTION SECTION 1 GENERAL The Florida Power & Light Company (FPL) New Nuclear Projects (NNP) Quality Assurance Program Description (QAPD) is the top-level policy document that establishes the quality assurance policy and assigns major functional responsibilities for Combined Operating License (COL) construction, pre-operation and operations activities conducted by or for FPL. The QAPD describes the methods and establishes quality assurance (QA) and administrative control requirements that meet 10 CFR 50, Appendix B and 10 CFR 52. The QAPD is based on the requirements and recommendations of ASME NQA-1-1994, "Quality Assurance Requirements for Nuclear Facility Applications," Parts I, II and Ill, as specified in this document. New Nuclear Projects is responsible for development of the licensing actions needed in support of new nuclear site development. Responsibilities also include engineering oversight of contractors, site layout, staffing and program development, and operational readiness. The executive in charge of New Nuclear Projects reports directly to the Chief Nuclear Officer and is assisted by a support staff. Initially, New Nuclear Projects is responsible for construction planning and preparation. The responsibility for construction transitions to the executive for Site Construction at the start of construction activities when filled. New Nuclear Projects responsibilities include the establishment and execution of a contract or contracts for the engineering, procurement, construction, and startup activities of new nuclear plants. Organizational control and responsibility for newly constructed nuclear generating units transfers to the Chief Nuclear Officer following the completion of unit specific construction activities and prior to loading of fuel. As a new nuclear plant approaches startup, the site organization transitions from the development/ construction focused organization to the Operating Plant Site Organization. The VP New Nuclear Projects reports to the Executive VP Engineering, Construction, & Supply ~Chain. This reporting relationship allows the Chief Nuclear Officer and Nuclear Generation to remain focused on improving the performance of the operating fleet and minimize the distractions associated with the construction of new nuclear generating plants. This position will be filled in support of the start of construction activities for a new nuclear plant. This position is responsible for the control and oversight of all construction activities associated with a new nuclear unit. Reporting to this position will be the Licensing Director New Nuclear Projects and Project Director New Nuclear Projects. This position will transfer responsibilities for the constructed unit to the site executive reporting to the Chief Nuclear Officer at the completion of construction activities and prior to the loading of fuel in that unit. This position will retain responsibilities for other units under construction at a multi-unit site until construction activities for each unit are completed. This position is supported during these construction activities by other Nuclear organizations as needed. FPL-2 Revision 4~ Page 8 of 86 April 2Q, 2Q18July 13, 2Q18May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 10 of 87 FPL Quality Assurance Program Description PARTI INTRODUCTION (CONTINUED) The QAP is defined by the NRG-approved regulatory document that describes the QA elements (i.e. the QAPD), along with the associated implementing documents. Procedures and instructions that control NNP activities will be developed prior to commencement of those activities. Policies establish high-level responsibilities and authority for carrying out important administrative functions which are outside the scope of the QAPD. Procedures establish practices for certain activities which are common to all FPL organizations performing those activities so that the activity is controlled and carried out in a manner that meets QAPD requirements. Procedures specific to a site, organization, or group establish detailed implementation requirements and methods, and may be used to implement policies or be unique to particular functions or work activities. 1.1 Scope / Applicability The QAPD applies to construction, pre-operation and operations activities affecting the quality and performance of safety-related structures, systems, and components, including, but not limited to: Designing Receiving Pre-Operational Activities (Including ITAAC) Siting Storing Operating Procuring Constructing Maintaining Fabricating Erecting Repairing Cleaning Installing Modifying Handling Inspecting Refueling Shipping Testing Training Startup Decommissioning Safety-related SSCs, under the control of the QAPD, are identified by design documents. The technical aspects of these items are considered when determining program applicability, including, as appropriate, an item's design safety function. The QAPD may be applied to certain activities where regulations other than 10 CFR 50 and 10 CFR 52 establish QA requirements for activities within their scope. This QAPD was developed to address COL activities associated with Turkey Point Units 6 and 7 and any future nuclear power units pursued by Florida Power & Light Company in accordance with 10 CFR Part 52. This QAPD does not apply to any of the existing FPUNextEra Energy nuclear power plants. The policy of FPL is to assure a high degree of availability and reliability of the nuclear plants while ensuring the health and safety of its workers and the public. Towards this end, selected elements of the QAPD are also applied to certain equipment and activities that are not safety-related, but support safe, economic, and reliable plant operations, or where other NRC guidance establishes quality assurance requirements. Implementing documents establish program element applicability. The definitions provided in ASME NQA-1-1994, Part I, Section 1.4, apply to select terms as used in this document. FPL-2 Revision 4.§. Page 9 of 86Af)ril 2G, 2G1 Bdllly 13, 2G18Af)Fil 1. 2G1Q May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 11 of 87 FPL Quality Assurance Program Description PART II QAPD DETAILS SECTION 1 ORGANIZATION This section describes the FPL organizational structure. functional responsibilities. levels of authority and interfaces for establishing, executing, and verifying QAPD implementation. The organizational structure includes corporate and on-site functions for NNP including interface responsibilities for multiple organizations that perform quality-related functions. Implementing documents assign more specific responsibilities and duties. and define the organizational interfaces involved in conducting activities and duties within the scope of the QAPD. Management gives careful consideration to the timing, extent and effects of organizational structure changes. The FPL management senior position responsible for the Quality Assurance organization is responsible to size the Quality Assurance organization commensurate with the duties and responsibilities assigned. The FPL NNP organization is responsible for new nuclear plant licensing, engineering, procurement. construction. startup and operations development activities. There are several organizations within FPL which implement and support the QAPD. These organizations include. but are not limited to. the NNP organization. Corporate Services and Quality Assurance. Design, engineering and construction services are provided to the FPL New Nuclear Projects organization by two primary contractors in accordance with their own QAPDs. These two contractors are the NE Firm and the NSSS vendor. No later than six months prior to fuel load of the unit. those positions which are identified for Operations will be staffed and have the appropriate authority required to perform operations activities. It is anticipated that even after fuel load. construction activities will be ongoing. Those positions required to support these activities will retain their applicable construction/preoperation responsibilities until it is deemed that they are no longer necessary. As the construction of systems (or portions thereof) is completed, control and authority (including oversight, configuration and operations) is transferred from the contractor to the FPL departments in the operations phase. During the transition. responsibilities will be clearly defined in instructions and procedures to ensure appropriate authority is maintained for each SSC. The following sections describe the reporting relationships. functional responsibilities and authorities for the organizations that implement and support the NNP QA Program. The NNP construction and startup organization and the FPL Fleet operating organization are shown in Figures 1-1. 1-2 and 1-3. respectively. FPL-2 Revision 4~ Page 10 of 86<\pril 2Q, 2Q1Bdlll'l 1a. 2Q1B/\pril 1 2919 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 12 of 87 FPL Quality Assurance Program Description SECTION I ORGANIZATION (CONTINUED) 1.1 NNP Construction and Startup Organization 1.1.1 NextEra Energy President and Chief Executive Officer (CEO)
- I Formatted: Left I This 12osition is res12onsible for overall cor12orate 12olicy and 12rovides executive direction and guidance for the cor12oration as well as for the 12romulgation of cor12orate 12olicy through the Com12any's senior management staff. The President and CEO is res12onsible for develo12ing,
- Formatted: Left )
im12lementing, and verifying execution of the FPL Quality Assurance Program. Res12onsibility for im12lementing the FPL Quality Assurance Program is delegated to the Chief Nuclear Officer and the authority for develo12ing and verifying execution of the 12rogram is delegated to the Director Nuclear Assurance. 1.1.2 Executive Vice President - Engineering, Construction and Cor12orate Services This 12osition re12orts to the CEO and is the 12roject executive res12onsible for construction of the
- Formatted: Left I new nuclear 12lant. This 12osition is the interface between the NNP 12roject and the senior executive staff.
1.1.3 Vice President- New Nuclear Projects The Vice President - New Nuclear Projects, re12orts to the Executive Vice President -
- Formatted: Left I Engineering, Construction and Cor12orate Services and is res12onsible for the overall safe and efficient licensing, engineering, construction and 12re-012erational test of the New Nuclear Projects, and for the im12lementation of quali!Y assurance requirements in the areas s12ecified by the QAPD.
1.1.4 Exesutive Vise President Nuclear Division ancl Chief Nuslear Offiser (Cf>IO) This 12osition re12orts to the CEO and has overall res12onsibili!Y for the im12lementation of the
- Formatted: Left I QAP and for Nuclear Division activities including cor12orate res12onsibility for overall 12lant nuclear safety. +his resi:1ensieilitv inslucles settin§ ancl iFfl(:11ementin§ i:1elisies, eejestives, ancl i:1rierilies le ensure aslivities are i:1erferFflecl in asserclanse will=l QAP ancl ell=ler ser1:1erate re§uirements. +l=le Cf>IO The President is designated as the Com12any Officer res12onsible for assuring that defects and non-com12liances are re12orted to the NRC as required by 10CFR21.
1.1.5 Vice President and Chief Nuclear Officer (CNO) This 12osition re12orts to the President Nuclear Division and has overall res12onsibility for the implementation of the QAP and for Nuclear Division's activities including cor12orate res12onsibili!Y for overall 12lant nuclear safety. This res12onsibili!Y includes setting and im12lementing 12olicies,
- Formatted: Body Text 2, Pattern: Clear, Tab stops: 0.26",
List tab I objectives, and 12riorities to ensure activities are performed in accordance with QAP and other coroorate reauirements. Formatted: Font: Bold I FPL-2 Revision 4.§. Page 11 of86A13ril 2Q, 2Q18d~ly 13, 2Q18Aaril 1, 2Q1Q May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 13 of 87 FPL Quality Assurance Program Description SECTION I ORGANIZATION {CONTINUED) 1.1.Be Licensing Director - New Nuclear Projects Formatted: Left The Licensing Director - New Nuclear Projects reports to the Vice President- New Nuclear Projects and is responsible for the generation of the Combined Operating License (COL) application. and is responsible for the day-to-day oversight of the COL application contractor and assuring corrective action is taken for any quality concerns that are raised. This position is also responsible for the licensing actions associated with the New Nuclear Projects through the final licensing action associated with the new nuclear project. 1.1.?e Project Director - New Nuclear Projects Formatted: Left The Project Director - New Nuclear Projects. reports to the Vice President- New Nuclear Projects. is responsible for the construction and test of the new nuclear plant and is accountable for ensuring that company policy and procedures are properly implemented at the nuclear site. 1.1.8+ Construction Director - New Nuclear Projects Formatted: Left The Construction Director reports to the Project Director - New Nuclear Projects. and is responsible to interface with the NSSS supplier. the selected NE. and the constructor. This position is responsible for the day to day oversight of the construction effort as the new nuclear plant is constructed. and for assuring corrective action is robust for any construction quality concerns that are raised by the Contractor or by FPL personnel. 1.1.~ Formatted: Font color: Auto Formatted: Left The En ineerin Site Director - Units 6 & 7 -re arts to the Pro*ect Director - New Nuclear Formatted: Font color: Auto Projects. and is responsible to interface with the NSSS supplier. and the selected NE. This Formatted: Font color: Auto position is responsible for the day to day oversight of the engineering effort as the new nuclear plant is designed and constructed. and for assuring that corrective action is robust for any Formatted: Font color: Auto engineering issues that are raised by the Contractor or by FPL personnel. Formatted: Left Formatted: Font color: Auto 1.1.100 Quality Assurance Project Manager- New Nuclear Projects Formatted: Font color: Auto Formatted: Left The New Nuclear Projects Quality Assurance Project Manager (QAPM) reports directly to the Director Nuclear Assurance. and is responsible for the development and verification of Formatted: Left implementation of the QAPD described in this document. The QAPM is responsible for verifying compliance with regulatory requirements and procedures through audits and technical reviews: for monitoring organization processes to ensure conformance to commitments and licensing document requirements: for verifying that vendors who provide quality services. parts and materials to the new nuclear project are meeting the requirements of 10 CFR 50. Appendix B through NUPIC or FPL vendor audits. The QAPM has sufficient independence from other New Nuclear Projects priorities to bring forward issues affecting safety and quality and make judgments regarding quality in all areas necessary regarding FPL"s nuclear development activities. The QAPM may make recommendations to the New Nuclear Projects management regarding improvement in the quality of work processes. If the QAPM disagrees with actions taken by the organization in this regard and is unable to obtain resolution. the QAPM shall inform the Director Nuclear Assurance. FPL-2 Revision 4§. Page 12 of 86April 29, wrnJl,ll'{ 1.J 29rn.'\pril 1 2919 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 14 of87 FPL Quality Assurance Program Description SECTION I ORGANIZATION {CONTINUED) 1.1.1 rn Plant General Manager - New Nuclear Projects
- Formatted: Left I The Plant General Manager New Nuclear Projects reports directly to the Site Vise President Units e & ?Vice President and CNO and is responsible for plant operation and administratively to the Vice President New Nuclear Projects during construction. This position is responsible for
- Formatted: Left I development of the site operating and support staff. and for operation of the new nuclear plant during the test phase. During construction. the Plant General Manager coordinates activities with the Vice President New Nuclear Projects to provide for equipment operation. maintenance and test including Inspections, Tests. Analyses. and Acceptance Criteria {ITAGAC,)
In this position. as the plant moves into the operations phase. the Plant General Manager assures the safe. reliable, and efficient operation of the plant within the constraints of applicable regulatory requirements. combined operating license. and the QAP. Functional areas of responsibility also include chemistry activities. fuel handling (receipt. movement. and storage). health physics/radiological protection. operations and support. maintenance and production planning, and related procedures and programs. 1.1.124 Testing Director The Testing Director reports to the Project Director - NNP. and is responsible to coordinate the
- Formatted: Left I test program for the new nuclear plant. This position is responsible to develop the test program and to support the contractors and the operating staff through the plant test and startup phase.
1.1.132 Vice President - Integrated Supply Chain This position reports to the CEO through the Executive Vice President Engineering. Construction and Corporate Services and is responsible for procurement engineering: negotiating, generating. and issuing procurement documents for required items, coordinating contract activities and for services that support the operation. licensing. maintenance. modification. and inspection of FPL nuclear plants. as well as for materials and equipment to support the Nuclear Division staff. Responsibilities also include the review of procurement documents to ensure that technical and quality requirements are properly incorporated and for the performance of receipt inspection to verify that purchased items comply with procurement document requirements (other than at stations where receipt inspection is performed by the Quality Assurance Organization). and for the control of materials received at each FPL nuclear plant site in accordance with company policy and procedures. 1.1.1 ~ Manager - Sourcing This position reports to the Vice President Integrated Supply Chain with direct interface with the
- Formatted: Left J VP-NNP. The position has functional areas of responsibility that include the authority for day-to-day material support activities at the site. Activities include contract coordination. procurement document control, and receipt and control of material.
FPL-2 Revision 4.§. Page 13 of 86/\13ril 2ll, 2ll18Ji;ly 1a 2Q18/\pril 1 2Q19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 15 of 87 FPL Quality Assurance Program Description SECTION I ORGANIZATION {CONTINUED) 1.1.154 Nuclear Steam Supply System (NSSS) Design Control Document (DCD) Holder +--- Formatted: Left I The NSSS DCD Holder provides plant design and licensing of the plant on the FPL site. These engineering services for new nuclear generation include engineering and design necessary to support construction activities within the scope of the certified design. 1.1.15e A/E / Constructor - Formatted: left I The NE Firm provides engineering services. These engineering services include site specific design activities necessary to support planning for preconstruction and construction of new. nuclear generation. The Constructor provides construction services for the new plant. This sestien sessribes the organizational stnicture, functional responsibilities, levels ef authority and interfaces for establishing, mcesuting, and verifying QAP implementation. The erganizatienal stnicture insluses serperate funstiens and onsite functions at each plant ans contains organization charts sepisting tt:le organizational relationships fer key management and functional greups beth serperate and en site. Implementing desuments assign mere specific responsibilities and duties, ans define the erganizatienal interfaces involves in conducting activities and duties within tt:le ssepe ef this QAPD. The Ct:lief Nuclear Officer has overall responsibility for implementation of tt:ie quality pregram. The authority to accomplish quality assurance functions is delegates to the staff as necessary to fulfill the identified responsibilities. Personnel executing perfermanse activities and tt:lose perferming verification activities are functionally independent to tt:ie segree sommensmate with the activity's relative importance to safety. The mett:los ans extent of verification is commensurate with importance of the activity to plant safety and reliability. The organization executing independent assessment activities maintains independence from tt:le organization(s) performing the activity being assessed. Management positions are establishes both offsite ans onsite for carrying out the indepensent assessment functions. lndivisuals filling these positions: Have sufficient authority ans organizational freesom to implement tt:leir assigned responsibilities, including authority to obtain assess to records and personnel as needed to perform assessments. Report to a sufficiently t:ligh management level te ensure that cost ans sst:ledule considerations do not unduly influence sesision making. Have effective lines of communication with persons in other senior management positions. Have ne unrelated suties or responsibilities that would preclude full attention to assigned responsibilities. Responsible indivisuals or organizations may delegate any or all of their responsibility. 1Nhen worl< is selegated to personnel or organizations outside of f Pb the responsibility fer tt:le pregram effectiveness and the work is retained by fPL, ans the selegation shall FPL-2 Revision 4§. Page 14 of 86/\pril 2Q, 2Q1SJuly 1 a, 2Q1 BAaril 1. 2Q19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 16 of 87 FPL Quality Assurance Program Description be iEleRtifieEI aREI ElesoribeEI suol:! tl:!at: Tl:!e orgaRizatioRal elemeRts respoRsible for tl:!e work are iEleRlifieEI. MaRagemeRt ooRtrols aREI liRes of oommuRioatioR are establisl:!eEI. RespoRsibility for aR appropriate QAP aREI eiaeRt of maRagemeRt oversigl:!t is establisl:!eEI. PerformaRoe of ElelegateEI 1.vork is formally evallcla!eEI by FPL. FPL-2 Revision 4.§ Page 15 of 861\13ril 2G, 2GrnJ~ly 13. 2Q1 BAaril 1. 2Q19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 17 of 87 FPL Quality Assurance Program Description Section 1 ORGANIZATION (Continued) In establishing its organizational structure, NextEra Energy commits to compliance with NQA-1, 1994, Basic Requirement 1 and Supplement 1S-1. Management gives careful consideration to the timing, extent and effects of organizational structure changes. 1.g.4 Corporate Organization The following positions have the described corporate functional responsibilities. Some titles and reporting relationships may vary between corporate and some sites, but in all cases there is a designated position to carry out the defined responsibilities. 1.4_g.1 NextEra Energy Chairman and Chief Executive Officer (CEO) This position is responsible for overall corporate policy and provides executive direction and guidance for the corporation as well as promulgates corporate policy through the Company's senior management staff. Responsibility for implementing the Quality Assurance Program is delegated to the Chief Nuclear Officer and authority for developing and verifying execution of the program is delegated to the Director Nuclear Assurance & Assessment. 1.2.2 President Nuclear Division This position reports to the CEO and has overall responsibility for the implementation of the QAP and for Nuclear Division activities including corporate responsibility for overall plant nuclear safety. The President is designated as the Company Officer responsible for assuring that defects and non-compliances are reported to the NRC as required by 10CFR21. 1.4_g.2~ Vice President & Chief Nuclear Officer (CNO) This position reports to the Chairman and CEOPresident Nuclear Division and has overall responsibility for the implementation of the QAP and for the Nuclear Division's activities including corporate responsibility for overall plant nuclear safety. This responsibility includes setting and implementing policies, objectives, and priorities to ensure activities are performed in accordance with QAP and other corporate requirements. he CNO is designated as the Company Offiser responsible for ensuring that defests and non somplianses are reported to the f>JRC as required by 10CFR21.
- - - { Formatted: Body Text 2 FPL-2 Revision 4.§. Page 16 of 86A13ril 29, 2918d1c1lv 13, 2918Aaril 1, 2919 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 18 of 87 FPL Quality Assurance Program Description Section 1 ORGANIZATION (Continued) 1.4_?_.J1 Vice President Corporate Support This position reports to the CNO and is responsible for the following:
- Corporate Functional Area Managers (CFAMs)
- Performance Improvement
- Security
- Fleet Training
- Licensing
- Interface with Nuclear Information Technology
- Continuous Improvement Program
- Fleet Projects (including capital projects, project control, project implementation, and ISFSI)
- Development and implementation of the programs associated with regulatory driven projects across the fleet.
- Outages
- Design Engineering
- Fleet Engineering Support 1.4.?...§4 Vice President Sr. Director Nuclear Fleet Finance This position reports to the CNO and is responsible for the following:
- Nuclear fleet budgets
- Spending authorization I
- Key performance indicators I
. I I
1.1.a Vice President Projects Design and Execution This position re13orts to the Vice President of Cor13orate Su1313ort, and for im13lementation of QATR related res13onsibilities, has the Director of Projects and Construction and the Fleet Director of Design Engineering. This 13osition is res13onsible for:
- Fleet Projects Ca13ital Projects Project Control Project lmf)lementation Regulatory
- Oversight and Execution of Design Engineering
- Engineering Document Control
- Modifications and their lm13lementation
- Plant Design Configuration Control FPL-2 Revision 4.§. Page 17 of 86/1.~ril 2Q, 2GrnJ~ly 1a, 2G1S/\aril 1, 2G19 May 28,2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 19 of 87 FPL Quality Assurance Program Description Section 1 ORGANIZATION (Continued) 1 ..f.4.B~ General Manager Fleet Engineering The General Manager Fleet Engineering reports to the Vice Presidentf_.':'~~c,~~-~!:!::__ _ _ _.------- Formatted: Highlight ServisesCorporate Support and is responsible for:
- Fleet Engineering
- Probabilistic Safety Analysis
- Nuclear Fuels
- Engineering Programs
- Equipment Reliability
=--Engineering Chiefs Organization
+-- Formatted: NonTial, No bullets or numbering The Engineering Site Directors report to this position.
1.2. 7e4-,7. .fu,_Director Fleet Projects and Construction The .fu,_Director Fleet Projects and Construction reports to the Vice President Projests Design anEI Exem1tien of Corporate Support and is responsible for the Engineering Construction Alliance interface including project controls implementation and engineering. fleet Projests +--- Formatted: NonTial, Left, No bullets or numbering, Tab Capital Prejests stops: Not at 0.75" Projest Centre! Projest anEI Implementation 1.4,g2.8+ Director Fleet Design Engineering This position reports to the Vise PresiElent Prejests Design anEI Exes1,1tienGeneral ManasgerManager Fleet EngineringEngineering and is responsible for:
- Design Engineering
- Engineering Document Control
- Modifications and their Implementation
- Plant Design Configuration Control The Engineering Site Design Managers report to this position.
FPL-2 Revision 4.§. Page 18 of 86.'\J,Jril 2Q, 2Q18J1a1ly 13. 2Q18AllFil 1, 2Q19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 20 of 87 FPL Quality Assurance Program Description Section 1 ORGANIZATION (Continued) 1.4..,92.9g Vice President Integrated Supply Chain ((SC) This position reports to the CEO through the Executive Vice President Engineering, Construction and ISC and is responsible through ISC directors for the following:
- Procurement Engineering
- Coordinating Contract Activities
- Negotiating, generating, and issuing procurement documents for required items and services supporting the operation, licensing, maintenance, modification, and inspection at the nuclear plants, and for materials and equipment to support the Nuclear Division staff
- Review of procurement documents to assure that technical and quality requirements are incorporated into the procurement documents that it authorizes
- Performance of receipt inspection to verify that purchased items comply with procurement document requirements (except at stations where receipt inspection is performed by the Nuclear Assurance Organization)
- Controlling materials received at each nuclear plant site in accordance with company policy and procedures 1.-h-W2.109 Senior Director IT Business SolutionsVise PresiEleRt IRfoFFRatioR Testrnology Formatted: Tab stops: 0.75", Left This position reports to the NextEra Energy Vice President and CFO through the Vice President and CIO and is responsible for the following:
- Nuclear information technology such as computer-related hardware and software acquisition, deployment, maintenance, control and replacement; telecommunications
- Information/ cyber security; and applicable training
- IRterfase with the Vise PresiEleRt for OrgaRizatioRal EffestiveRess aRd LeamiRg for syber semffity
- Interface with the organizational effectiveness manager
- Management of information technology
- Nuclear cyber security
- Computer-related hardware/software acquisition
- The functions are supported via staff at both corporate and site levels.
FPL-2 Revision 4§ Page 19 of 8SAJJFil 2Q, 2Q1ijJl-Jly 13 2QrnAeFil 1 2919 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 21 of 87 FPL Quality Assurance Program Description Section 1 ORGANIZATION (Continued) 1.4--,442.110 Vice President and Chief Information Officer This position reports to the NextEra Energy Vice Chairman and CFO. The CIO is responsible for:
- Nuclear Information Management (such as computer-related hardware and software acquisition, deployment, maintenance, control and replacement)
- Telecommunications
- Information / Cyber Security
- Applicable Training The Vice President Information Management Technology reports to this position.
1.~2.124 Director Nuclear Assurance & Assessment This position reports to and has direct access to the CNO for resolution of any areas in question. This position is responsible for the following:
- Activities that include establishing, maintaining, and interpreting quality assurance practices and policies (including this QATR)
- Managing independent assessment (Quality Assurance {QA}) and establishing quality control practices and policies for quality verification activities
- Performance of receipt inspection, through the Nuclear Assurance Supervisor(s), to verify that purchased items comply with procurement documents at stations where receipt inspection is performed by the Nuclear Assurance organization
- Facilitating actions deemed necessary to prevent unsafe plant conditions or a significant violation of the QAP; including Stop Work authority at the sites and corporate offices
- Periodically apprising the CNO of the status of the quality assurance program at NextEra Energy facilities and immediately apprising senior management of significant problems affecting quality; and verifying implementation of solutions for significant conditions adverse to quality identified by Nuclear Assurance
- Establishing the requirements for assessor and inspector certification; and providing for supplier evaluation
- Conduct of supplier assessments or surveys; and verification that supplier quality assurance programs comply with NextEra Energy requirements FPL-2 Revision 4.§. Page 20 of 86April ::w, 2Q18July 13, 2Q1B/\aril 1, 2Q19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 22 of 87 FPL Quality Assurance Program Description Section 1 ORGANIZATION (Continued) 1..:k4-J2.132, Vice President - New Nuclear Projects The Vice President - New Nuclear Projects initially reports to the Chief Nuclear Officer and is responsible for:
- Project Administration
- Coordination and overall performance of the project
- Vendor Contract Compliance
- Quality
- Timeliness
- Error Free Performance The Vice President New Nuclear Projects transitions to reporting to the Executive Vice President Projects, Engineering, & Construction at the start of construction.
1A-442.1~ Licensing Director - New Nuclear Projects The Licensing Director - New Nuclear Projects reports to the Vice President - New Nuclear Projects and is responsible for:
- Maintenance of the COL
- Day-to-day oversight of the COL application contractor and assuring corrective action is taken for any quality concerns that are raised
- Licensing actions associated with the New Nuclear Projects through the final licensing action associated with the new nuclear project FPL-2 Revision 4.§. Page 21 of 86ApFil 2Q, 2GrnJuly 1:l. 2Q18AllFil 1. 2Q19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 23 of 87 FPL Quality Assurance Program Description Section 1 ORGANIZATION (Continued) 1.~4 Site Organization The following site management positions describe the typical site QAP functional responsibilities, which may be delegated to others as established in this document. The on-site operating organization includes one or more individuals knowledgeable in the following fields: nuclear power plant operation; nuclear power plant mechanical, electrical and electronic systems; nuclear engineering; chemistry and radiochemistry; radiation protection; and quality assurance. Some functions, such as operating experience, document control, or records management, may be aligned under different groups at different sites. Site procedures provide detailed organizational descriptions. 1.4.1 Regional 1/ioe Presidents (RVPs) North and South These positions report to the C~IO and are responsil:lle for the operation, maintenanoe, lioensing, training, and emergenoy planning. In this position, the RI/Ps aot as a liaison l:let>.veen the plants and oorporate and is aooountal:lle for ensuring that the oompany polioy and prooedures are properly implemented and oontinued at the nuolear site. 1.~4.1.,a Site Directors LaRti Plant General Managers (PGMs) These positions report to the RVP-5--CNO and are responsible for the safe operation of the nuclear plant. The Site Directors and PGMs have control of the onsite resources necessary for the safe operation and maintenance regardless of organizational reporting. In this position, the Site Directors and PGMs assure the safe, reliable, and efficient operation of the plant within the constraints of applicable regulatory requirements, operating license, and the QAP. Functional areas of responsibility also include chemistry activities, environmental services, fuel handling (receipt, movement, and storage), radiation protection, operations and support, maintenance and work control, and related procedures and programs. The Onsite Review Group serves the Site Directors and PGMs in a technical capacity and provides review of plant safety and performance (see Appendix A). 1.4~.1.ge Licensing Manager This position reports to the RVl2&-Site Directors / Plant General Managers GNG and is responsible for site regulatory interfaces. 1.43.1.bd Training Site Manager This position reports to the Site Directors I PGMs and functionally interfaces with the Training Fleet Director (offsite) and is responsible for training. The Site Training Manager provides direction, control, and overall supervision of training personnel and training for all site personnel as required. Functional areas of responsibility include training support services, technical training, and operations training. 1.4~.1.o Performanoe Improvement SupervisorThis position reports to the Training Manager and is responsil:lle for administration of the oorreotive aotion and self assessment programs. FPL-2 Revision 4~ Page 22 of 86,11,pFil 2Q, 2Q1 gJllly 1:i 2Q1 g,l\aril 1, 2G1 g May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 24 of 87 FPL Quality Assurance Program Description This position is also responsible for NUREG-0737, Action Plan Item 1.8.1.2 technical review functions that St. b~aie Unit 2 and Seabrool< Station are committed to regarding the oversight, implementation, and coordination of internal and external operating experience. 1.4,~.1.ec Emergency Preparedness Manager This position reports to the Licensing Manager and functionally interfaces with the Manager of Emergency Preparedness (offsite) and is responsible for maintaining and implementing the emergency plan for the station. FPL-2 Revision 4.§. Page 23 of 86April 29, 2Q18J~ly 13, 2Q18Aaril 1, 2Q1Q May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 25 of 87 FPL Quality Assurance Program Description Section 1 ORGANIZATION (Continued) 1.4 .1.El TFainin§ Site Mana§eF This position Feports to the Site DiFeetoFS / PGMs anEl funetionally interfaees with the Tminin§ fleet DiFeotoF (offsite) anEl is Fesponsible feF tFainin§. The Site TFainin§ Mana§eF pmviEles EliFeotion, oontml, anEl ovemll s1c1peFVision of tminin§ peFSonnel anEl tminin§ feF all site peFSonnel as Feq!JiFeEl. f1c1notional aFOas of Fesponsibility inol1c1Ele IFainin§ s1c1pport seFVioes, teohnieal tminin§, anEl opeFations tFainin§. The following positions report directly offsite, but functionally report to a site position: 1.~4.2.a Engineering Site Director This position reports to the Vice President Corporate Support through the General Manager Fleet Engineering. The position has functional areas of responsibility that include authority for day-to-day engineering support activities, engineering administration, system engineering, system testing, and technical support. This position is also responsible for NUREG-0737, Action Plan Item I.B.1.2 technical review functions that St. Lucie Unit 2 and Seabrook Station are committed to and implement by system health monitoring, development of a quarterly system health report which provides system performance and status to senior management, and development and implementation of the Maintenance Rule Program. 1.4~.2.b Project Site Manager This position reports to the Vioe PFesiElent Pmjeots anEl Desi§n thFO!J§h theSr. Director Projects and Construction with direct interface with the Site Directors and PGMs and is responsible for installing plant modifications as a result of design changes and implementing other major projects. 1.4~.2.c Nuclear Assurance S1c1peFViS0FManager This position reports to the Director Nuclear Assurance & Assessment (offsite) and is responsible for site quality activities. Significant safety or quality issues requiring escalated action are directed through this position to senior management, as necessary. Functional responsibilities include conducting independent assessments of line and support activities; monitoring and assessing day-to-day station activities; stop work authority at the site; periodic reporting on the status and adequacy of the quality program; and providing quality verification and inspections. 1.~.2.d Design Engineering Site Manager~ This position reports functionally to the Vice President Corporate Support through the En§ineeFiR§ DiFeetoF anEl Vise PFOsiElent of Pmjeets anEl Desi§n Exee1c1tion General Manager Fleet Engineering with direct interface with the Site Directors and PGMs and is responsible for compliance with the Design Control Program. FPL-2 Revision 4.§. Page 24 of 86A13Fil 29, 291 Bdlclly 13, 291 B/\pril 1. 2919 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 26 of 87 FPL Quality Assurance Program Description SECTION I ORGANIZATION (CONTINUED) 1.5 Authority 1.5.1 Authority to Stop Work Quality assurance and inspection personnel have the authority, and the responsibility, to stop work in progress which is not being done in accordance with approved procedures or where safety or SSC integrity may be jeopardized. This extends to off-site work performed by suppliers that furnish safety-related materials and services to FPL. 1.5.2 Quality Assurance Organizational Independence For construction, independence shall be maintained between the organization or organizations performing the checking (quality assurance and control) functions and the organizations performing the functions. This provision is not applicable to design review/verification. 1.5.3 NQA-1-1994 Commitment In establishing its organizational structure, FPL commits to compliance with NQA-1-1994, Basic Requirement 1 and Supplement 1S-1. FPL-2 Revision 4§. Page 25 of 86Af3Fil 2Q, 2Q1 gJyly 1J 2Q1 gAeril 1, 2Q19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 27 of 87 FPL Quality Assurance Program Description SECTION I ORGANIZATION (CONTINUED) Fiaure 1 1: NPP Construotion anEI Startup Oraanization Field Code Changed NPP CONSTRUCTION AND STARTUP ORGANIZATION NextEra Energy President CEO Executive VP Executive VP & CNO Engineering, Construction Nuclear Division & Corporate Services Director Nuclear Assurance Vice President Integrated Supply Chain Vice President QA Project New Nuclear Projects Manager r------------ ------------, I
---------, ProJectDirector New Nuclear Projects Engineering Director NewNuctear Projects Figure 1-1: NPP Construction and Startup Organization FPL-2 Revision 4.§. Page 26 of 8BA13ril 2Q, 2Q1BJ.ily 1:3. 2Q18Aaril 1. 2Q19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 28 of 87 FPL Quality Assurance Program Description NPP CONSTRUCTION AND STARTUP ORGANIZATION Formatted: Normal, Left, Space After: 0 pt NextEra Enerw Chairman CEO NexlEra Energy Preside111 coo Executive VP Executive VP & CNO Engineering. Cooslructicn
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1 Plant G<rleral Manager NewNudearProj-Uoonsbig Diloc1or ProjectDlrecl<lr NewNudear Now Nuclear Proj- Projects Engineering Site Construction Director Testing Diredor Di!edor NO\Y Nudea, Projects NewNudear Projects FPL-2 Revision 4.§. Page 27 of 86A13ril 2Q, 2grnJllly 13, 2QrnAaril 1, 2Q19 May 28, 2019
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Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 30 of 87 FPL Quality Assurance Program Description Figure 1-2: NextEra Energy Nuclear Fleet Corporate Operating Organization Formatted: Centered 00.00 I Formatted: Widow/Orphan control, Adjust space between Latin and Asian text, Adjust space between Asian text and numbers, Tab stops: Not at 1" FPL-2 Revision 4.§. Page 29 of 86Araril 2Q, 2Q1Bd1a1ly 13. 2Q18Aaril 1, 2Q19 May 28, 2019
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Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 33 of 87 FPL Quality Assurance Program Description SECTION 2 QUALITY ASSURANCE PROGRAM +------{ Formatted: Nonnal, Left FPL has established the necessary measures and governing procedures to implement the OAP as described in the QAPD. FPL is committed to implementing the QAP for all aspects of work that are important to the safety of the nuclear plants as described and to the extent delineated in the QAPD. Further, FPL ensures through the systematic process described herein that its suppliers of safety-related equipment or services meet the applicable requirements of 10 CFR 50, Appendix B. Senior management is regularly apprised of the adequacy of implementation of the QAPD through the audit functions described in Part II, Section 18. The objective of the QAPD is to assure that FPL's nuclear generating plants are designed, constructed, and operated in accordance with governing regulations and license requirements. The program is based on the requirements of ASME NQA-1-1994, "Quality Assurance Requirements for Nuclear Facility Applications," as further described in this document. The QAPD applies to those quality-related activities that involve the functions of safety-related structures, systems, and components (SSCs) associated with the design (excluding Design Certification activities), fabrication, construction, and testing of the SSCs of the facility and to the managerial and administrative controls to be used to assure safe operations. A list or system that identifies SSCs and activities to which this program applies is maintained at the appropriate facility. The Design Certification Document is used as the basis for this list. Cost and scheduling functions do not prevent proper implementation of the QAPD. As described in Part Ill of the QAPD, specific program controls are applied to nonsafety-related SSCs, for which 10 CFR 50, Appendix B, is not applicable, that are significant contributors to plant safety. The specific program controls consistent with applicable sections of the QAPD are applied to those items in a selected manner, targeted at those characteristics or critical attributes that render the SSC a significant contributor to plant safety. Delegated responsibilities may be performed under a supplier's or principal contractor's OAPD, provided that the supplier or principal contractor has been approved as a supplier in accordance with the QAPD. Periodic audits and assessments of supplier QA programs are performed to assure compliance with the supplier's or principal contractor's QAPD and implementing procedures. In addition, routine interfaces with supplier personnel provide added assurance that quality expectations are met. New nuclear plant construction will be the responsibility of FPL's NNP organization. Detailed engineering specifications and construction procedures will be developed to implement the QAPD and NSSS QA programs prior to commencement of construction activities. In general, the program requirements specified herein are detailed in implementing procedures that are either FPL implementing procedures, or supplier implementing procedures governed by a supplier quality assurance program. FPL-2 Revision 4.§. Page 32 of 86A13Fil 2Q, 2grnJuly rn. 2Q18Aeril 1, 2Q1 g May 28,2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 34 of 87 FPL Quality Assurance Program Description SECTION 2 QUALITY ASSURANCE PROGRAM (CONTINUED) A grace period of 90 days may be applied to provisions that are required to be performed on a periodic basis, unless otherwise noted. Annual evaluations and audits that must be performed on a triennial basis are examples where the 90 day general period could be applied. The grace period does not allow the "clock" for a particular activity to be reset forward. The "clock" for an activity is reset backwards by performing the activity early. Audits schedules are based on the month in which the audit starts. 2.1 Responsibilities Personnel who work directly or indirectly for FPL are responsible for achieving acceptable quality in the work covered by the QAPD. This includes the activities delineated in Part I, Section 1.1. FPL personnel performing verification activities are responsible for verifying the achievement of acceptable quality. Activities governed by the QAPD are performed as directed by documented instructions, procedures, and drawings that are of a detail appropriate for the activity's complexity and effect on safety. Instructions, procedures and drawings specify quantitative or qualitative acceptance criteria as applicable or appropriate for the activity. Verification is performed against these criteria. Provisions are established to designate or identify the proper documents to be used for an activity, and to ascertain that such documents are being used. The Quality Assurance Project Manager is responsible for verification that processes and procedures comply with QAPD and other applicable requirements, that such processes or procedures are implemented, and that management appropriately ensures compliance. 2.2 Delegation of Work FPL retains and exercises the responsibility for the scope and implementation of an effective QAP. Positions identified in Part II, Section 1, of this QAPD may delegate all or part of the activities of planning, establishing, and implementing the program for which they are responsible to others, but retain the responsibility for the program's effectiveness. Decisions affecting safety are made at the level appropriate for their nature and effect, and with any necessary technical advice or review. 2.3 Site-specific Safety-Related Design Basis Activities Site-specific safety-related design basis activities are defined as those activities, including sampling, testing, data collection, and supporting engineering calculations and reports, that will be used to determine the bounding physical parameters of the site. Appropriate quality assurance measures are applied. FPL-2 Revision 4.§. Page 33 of 86A~ril 29, 291Bdllly 13, 2918Aaril 1, 2919 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 35 of 87 FPL Quality Assurance Program Description SECTION 2 QUALITY ASSURANCE PROGRAM (CONTINUED) 2.4 Periodic Review of the Quality Assurance Program Management of those organizations implementing the QA program, or portions thereof, assesses the adequacy of that part of the program for which it are responsible to ensure effective implementation at least once each year or at least once during the life of the activity, whichever is shorter. However, the required periodicity for the assessment of QA programs during the operations phase may be extended to once every two years. 2.5 Issuance and Revision to Quality Assurance Program Administrative control of the QAPD will be in accordance with 10 CFR 50.55(f) and 10 CFR 50.54(a). Changes to the QAPD are evaluated by the Quality Assurance Project Manager to ensure that such changes do not degrade previously approved quality assurance controls specified in the QAPD. This document shall be revised as appropriate to incorporate additional QA commitments that may be established during the Combined Operating License (COL) application development process. Revisions to the document will be reviewed, at a minimum, by the FPL Director Nuclear Assurance and approved by the Vice President- New Nuclear Projects. Regulations require that the Final Safety Analysis Report (FSAR) include, among other things, the managerial and administrative controls to be used to assure safe operation, including a discussion of how the applicable requirements of Appendix B will be satisfied. In order to comply with this requirement, the FSAR references the QAPD and, as a result, the requirements of 10 CFR 50.54(a) are satisfied by and apply to the QAPD. 2.6 Personnel Qualifications Personnel assigned to implement elements of the QAPD shall be capable of performing their assigned tasks. To this end, FPL establishes and maintains formal indoctrination and training programs for personnel performing, verifying, or managing activities within the scope of the QAPD to assure that suitable proficiency is achieved and maintained. Plant and support staff minimum qualification requirements are as delineated in the unit Technical Specifications. Other qualification requirements may be established but will not reduce those required by Technical Specifications. Sufficient managerial depth is provided to cover absences of incumbents. When required by code, regulation, or standard, specific qualification and selection of personnel is conducted in accordance with those requirements as established in applicable FPL procedures. Indoctrination includes the administrative and technical objectives, requirements of the applicable codes and standards, and the QAPD elements to be employed. Training for positions identified in 10 CFR 50.120 is accomplished according to programs accredited by the. National Nuclear Accrediting Board of the National Academy of Nuclear Training that implement a systematic approach to training. Records of personnel training and qualification are maintained. FPL-2 Revision 4.§. Page 34 of 86/\pril 2Q, 2Q1 8J~ly 13, 2Q18A13ril 1, 2Q19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 36 of 87 FPL Quality Assurance Program Description SECTION 2 QUALITY ASSURANCE PROGRAM (CONTINUED) The minimum qualifications of the Director- Nuclear Assurance and the New Nuclear Projects Quality Assurance Project Manager are that each holds an engineering or related science degree and a minimum of four years of related experience including two years of nuclear power plant experience, one year of supervisory or management experience, which one year of the experience is in performing quality verification activities. Special requirements shall include management and supervisory skills and experience or training in leadership, interpersonal communication, management responsibilities, motivation of personnel, problem analysis and decision making, and administrative policies and procedures. Individuals who do not possess these formal education and minimum experience requirements should not be eliminated automatically when other factors provide sufficient demonstration of their abilities. These other factors are evaluated on a case-by-case basis and approved and documented by senior management. The minimum qualifications of the individuals responsible for planning, implementing, and maintaining the programs for the QAPD are that each has a high school diploma or equivalent and has a minimum of one year of related experience. Individuals who do not possess these formal education and minimum experience requirements should not be eliminated automatically when other factors provide sufficient demonstration of their abilities. These other factors are evaluated on a case-by-case basis and approved and documented by senior management.
- 2. 7 NQA-1-1994 Commitment/ Exceptions In establishing qualification and training programs, FPL commits to compliance with NQA 1994, Basic Requirement 2 and Supplements 2S-1, 2S-2, 2S-3 and 2S-4, with the following clarifications and exceptions:
NQA-1-1994, Supplement2S-1 Supplement 2S-1 will include use of the guidance provided in Appendix 2A-1 in the same manner as if it were part of the Supplement. The following two alternatives may be applied to the implementation of this Supplement and Appendix:
* (1) In lieu of being certified as Level I, II, or Ill in accordance with NQA 1994, personnel that perform independent quality verification inspections, examinations, measurements, or tests of material, products, or activities may possess qualifications equal to or better than those required for performing the task being verified provided that the verification is within the skills of these personnel and/or is addressed by procedures. These individuals will not be responsible for the planning of quality verification inspections and tests (i.e.,
establishing hold points and acceptance criteria in procedures, and determining who will be responsible for performing the inspections), evaluating inspection training programs, nor certifying inspection personnel. FPL-2 Revision 4.§. Page 35 of 86/\13ril 29, 291 BJ~ly 1J, 291 BAaril 1, 291 Q May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 37 of 87 FPL Quality Assurance Program Description SECTION 2 QUALITY ASSURANCE PROGRAM (CONTINUED)
* (2) A qualified engineer may be used to plan inspections, evaluate the capabilities of an inspector, or evaluate the training program for inspectors.
For the purpose of these functions, a qualified engineer is one who has a baccalaureate in engineering in a discipline related to the inspection activity (such as electrical, mechanical, civil) and has a minimum of five years engineering work experience with at least two years of this experience related to nuclear facilities. NQA-1-1994, Supplement 2S-2 In lieu of Supplement 2S-2, for qualification of nondestructive examination personnel, FPL will follow the applicable standard cited in the version(s) of Section Ill and Section XI of the ASME Boiler and Pressure Vessel Code approved by the NRC for use at FPL sites. NQA-1-1994, Supplement 2S-3 The requirement that prospective Lead Auditors have participated in a minimum of five (5) audits in the previous three (3) years is replaced by the following, "The prospective lead auditor shall demonstrate his/her ability to properly implement the audit process, as implemented by FPL, to effectively lead an audit team, and to effectively organize and report results, including participation in at least one nuclear audit within the year preceding the date of qualification." FPL-2 Revision 4.§ Page 36 of 86Araril 2G, 2Q18Jllly 13 2G18Aaril 1 2919 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 38 of 87 FPL Quality Assurance Program Description SECTION 3 DESIGN CONTROL FPL has established and implements a process to control the design, design changes, and temporary modifications (e.g., temporary bypass lines, electrical jumpers and lifted wires, and temporary setpoints) for items that are subject to the provisions of the QAPD. The design process includes provisions to control design inputs, outputs, changes, interfaces, records, and organizational interfaces within FPL and with suppliers. These provisions assure that design inputs (such as design bases and the performance, regulatory, quality, and quality verification requirements) are correctly translated into design outputs (such as analyses, specifications, drawings, procedures, and instructions) so that the final design output can be related to the design input in sufficient detail to permit verification. Design change processes and the division of responsibilities for design-related activities are detailed in FPL and supplier procedures. The design control program includes interface controls necessary to control the development, verification, approval, release, status, distribution, and revision of design inputs and outputs. Design changes and disposition of nonconforming items as "use as is" or "repair are reviewed and approved by the FPL design organization or by other organizations so authorized by FPL. Design documents are reviewed by individuals knowledgeable in QA to ensure the documents contain the necessary QA requirements. 3.1 Design Verification FPL design processes provide for design verification to ensure that items and activities subject to the provisions of the QAPD are suitable for their intended application, consistent with their effect on safety. Design changes are subjected to these controls, which include verification measures commensurate with those applied to original plant design. Design verifications are performed by competent individuals or groups other than those who performed the original design but who may be from the same organization. The verifier shall not have taken part in the selection of design inputs, the selection of design considerations, or the selection of a singular design approach, as applicable. This verification may be performed by the originator's supervisor provided the supervisor did not specify a singular design approach, rule out certain design considerations, and did not establish the design inputs used in the design, or if the supervisor is the only individual in the organization competent to perform the verification. If the verification is performed by the originator's supervisor, the justification of the need is documented and approved in advance by management. The extent of the design verification required is a function of the importance to safety of the item under consideration, the complexity of the design, the degree of standardization, the state-of-the-a rt, and the similarity with previously proven designs. This includes design inputs, design outputs, and design changes. Design verification procedures are established and implemented to assure that an appropriate verification method is used, the appropriate design parameters to be verified are chosen, the acceptance criteria are identified, and the verification is satisfactorily accomplished and documented. Verification methods may include, but are not limited to, design reviews, alternative calculations and qualification testing. Testing used to verify the acceptability of a specific design feature demonstrates acceptable performance under conditions that simulate the most adverse design conditions expected for item's intended use. FPL-2 Revision 4.§. Page 37 of86/\pril2G, :wrnd.ily 13, 2G18Aaril 1, 2G19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 39 of 87 FPL Quality Assurance Program Description SECTION 3 DESIGN CONTROL (CONTINUED) FPL normally completes design verification activities before the design outputs are used by other organizations for design work, and before they are used to support other activities such as procurement, manufacture, or construction. When such timing cannot be achieved, the design verification is completed before relying on the item to perform its intended design or safety function. 3.2 Design Records FPL maintains records sufficient to provide evidence that the design was properly accomplished. These records include the final design output and any revisions thereto, as well as record of the important design steps (e.g., calculations, analyses and computer programs) and the sources of input that support the final output. Plant design drawings reflect the properly reviewed and approved configuration of the plant. 3.3 Computer Application and Digital Equipment Software The QAPD governs the development, procurement, testing, maintenance, and use of computer applications and digital equipment software when used in safety-related applications and designated nonsafety-related applications. FPL and suppliers are responsible for developing, approving, and issuing procedures, as necessary, to control the use of such computer applications and digital equipment software. The procedures require that the application software be assigned a proper quality classification and that the associated quality requirements be consistent with this classification. Each software application and revision thereto is documented and approved by authorized personnel. The QAPD is also applicable to the administrative functions associated with the maintenance and security of computer hardware where such functions are considered essential in order to comply with other QAPD requirements such as QA records. 3.4 Setpoint Control Instrument and equipment setpoints that could affect nuclear safety shall be controlled in accordance with written instructions. As a minimum, these written instructions shall: (a) Identify responsibilities and processes for reviewing, approving, and revising setpoints and setpoint changes originally supplied by the NSSS supplier, the NE, and the plant's technical staff. (b) Ensure that setpoints and setpoint changes are consistent with design and accident analysis requirements and assumptions. (c) Provide for documentation of setpoints, including those determined operationally. (d) Provide for access to necessary setpoint information by personnel who write or revise plant procedures, operate or maintain plant equipment, develop or revise design documents, or develop or revise accident analyses. FPL-2 Revision 4.§. Page 38 of 86/\!)Fil 2Q, 2Q1 §J~ly 1<l, 2Q1 §April 1 2919 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 40 of 87 FPL Quality Assurance Program Description SECTION 3 DESIGN CONTROL (CONTINUED) 3.5 NQA-1-1994 Commitment In establishing its program for design control and verification, FPL commits to compliance with NQA-1-1994, Basic Requirement 3, and Supplement 3S-1, the subsurface investigation requirements in Subpart 2.20, and the standards for computer software in Subpart 2.7. FPL-2 Revision 4.§ Page 39 of 86A13ril 2G, 2G18July 1:;i, 2Q1 g,11.sril 1, 2Q19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 41 of 87 FPL Quality Assurance Program Description SECTION 4 PROCUREMENT DOCUMENT CONTROL FPL has established the necessary measures and governing procedures to assure that purchased items and services are subject to appropriate quality and technical requirements. Procurement document changes shall be subject to the same degree of control as utilized in the preparation of the original documents. These controls include provisions such that: Where original technical or quality assurance requirements cannot be determined, an engineering evaluation is performed and documented by qualified staff to establish appropriate requirements and controls to assure that interfaces, interchangeability, safety, fit and function, as applicable, are not adversely affected and are not contrary to applicable regulatory requirements. Applicable technical, regulatory, administrative, quality and reporting requirements (such as specifications, codes, standards, tests, inspections, special processes, and 10 CFR
- 21) are invoked for procurement of items and services. 10 CFR 21 requirements concerning posting, evaluating, and reporting will be followed and imposed on suppliers when applicable. Applicable design bases and other requirements necessary to assure adequate quality shall be included or referenced in documents for procurement of items and services. To the extent necessary, procurement documents shall require that suppliers have a documented QA program that is determined to meet the applicable requirements of 10 CFR 50, Appendix B, as appropriate to the circumstances of procurements (or the supplier may work under FPL's approved QA program).
Reviews of procurement documents shall be performed by personnel who have access to pertinent information and who have an adequate understanding of the requirements and intent of the procurement documents. 4.1 NQA-1-1994 Commitment I Exceptions In establishing controls for procurement, FPL commits to compliance with NQA-1-1994, Basic Requirement 4 and Supplement 4S-1, with the following clarifications and exceptions:
- NQA-1-1994, Supplement 4S-1 Section 2.3 of this Supplement 4S-1 includes a requirement that procurement documents require suppliers to have a documented QAP that implements NQA-1-1994, Part 1. In lieu of this requirement, FPL may require suppliers to have a documented supplier QAP that is determined to meet the applicable requirements of 10 CFR 50, Appendix B, as appropriate to the circumstances of the procurement.
- With regard to service performed by a supplier, FPL procurement documents may allow the supplier to work under the FPL QAP, including implementing procedures, in lieu of the supplier having its own QAP.
FPL-2 Revision 4.§. Page 40 of 86/\13ril 2Q, 2Q18J1a1ly 13. 2Q18Aaril 1, 2Q19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 42 of 87 FPL Quality Assurance Program Description SECTION 4 PROCUREMENT DOCUMENT CONTROL (CONTINUED) Section 3 of supplement 4S-1 requires procurement documents to be reviewed prior to bid or award of contract. The quality assurance review of procurement documents is satisfied through review of the applicable procurement specification, including the technical and quality procurement requirements, prior to bid or award of contract. Procurement document changes (e.g., scope, technical, or quality requirements) will also receive the quality assurance review. Procurement documents for Commercial Grade Items that will be procured by FPL for use as safety-related items shall contain technical and quality requirements such that the procured item can be appropriately dedicated. FPL-2 Revision 4.§. Page 41 of 86/\JJril 2Q, 2Q1 Bde1ly 13, 2Q1BAaril 1. 2Q19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 43 of 87 FPL Quality Assurance Program Description SECTION 5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS FPL has established the necessary measures and governing procedures to ensure that activities affecting quality are prescribed by and performed in accordance with instructions, procedures or drawings of a type appropriate to the circumstances and which, where applicable, include quantitative or qualitative acceptance criteria to implement the QAPD. Such documents are prepared and controlled according to Part II, Section 6. In addition, means are provided to disseminate to the staff instructions of both general and continuing applicability, as well as those of short-term applicability. Provisions are included for reviewing, updating, and canceling such procedures. 5.1 Procedure Adherence FPL's policy is that procedures are followed, and the requirements for use of procedures have been established in administrative procedures. Where procedures cannot be followed as written, provisions are established for making changes in accordance with Part II, Section 6. Requirements are established to identify the manner in which procedures are to be implemented, including identification of those tasks that require: (1) the written procedure to be present and followed step-by-step while the task is being performed, (2) the user to have committed the procedure steps to memory, (3) verification of completion of significant steps, by initials or signatures or use of check-off lists. Procedures that are required to be present and referred to directly are those developed for extensive or complex jobs where reliance on memory cannot be trusted, tasks that are infrequently performed, and tasks where steps must be performed in a specified sequence. In cases of emergency, personnel are authorized to depart from approved procedures when necessary to prevent injury to personnel or damage to the plant. Such departures are recorded describing the prevailing conditions and reasons for the action taken. 5.2 Procedure Content The established measures address the applicable content of procedures as described in the introduction to Part II of NQA-1-1994. In addition, procedures governing tests, inspections, operational activities, and maintenance will include as applicable, initial conditions and prerequisites for the performance of the activity. 5.3 NQA-1-1994 Commitment In establishing procedural controls, FPL commits to compliance with NQA-1-1994, Basic Requirement 5.
- FPL-2 Revision 4.§. Page 42 of 86A13ril 2G, 2G1 §Ji;ly 1:l, 2G1 §Aaril 1. 2G19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 44 of 87 FPL Quality Assurance Program Description SECTION 6 DOCUMENT CONTROL FPL has established the necessary measures and governing procedures to control the preparation of, issuance of, and changes to documents that specify quality requirements or prescribe how activities affecting quality, including organizational interfaces, are controlled to assure that correct documents are being employed. The control systems (including electronic systems used to make documents available) are documented and provide for the following: (a) identification of documents to be controlled and their specified distribution; (b) a method to identify the correct document (including revision) to be used and control of superseded documents; (c) identification of assignment of responsibility for preparing, reviewing, approving, and issuing documents; (d) review of documents for adequacy, completeness, and correctness prior to approval and issuance; (e) a method for providing feedback from users to continually improve procedures and work instructions; and (f) coordinating and controlling interface documents and procedures. The types of documents to be controlled include: (a) drawings such as design, construction, installation, and as-built drawings; (b) engineering calculations; (c) design specifications; (d) purchase orders and related documents; (e) vendor-supplied documents; (f) audit, surveillance, and quality verification/inspection procedures; (g) inspection and test reports; (h) instructions and procedures for activities covered by the QAPD including design, construction, installation, operating (including normal and emergency operations), maintenance, calibration, and routine testing; (i) technical specifications; and G) nonconformance reports and corrective action reports. During the operational phase, where temporary procedures are used, they shall include a designation of the period of time during which it is acceptable to use them. FPL-2 Revision 4.§. Page 43 of 86April 2Q, 2GrnJ~lv 1.i, 2GrnApril 1 2Q19 May 28,2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 45 of 87 FPL Quality Assurance Program Description SECTION 6 DOCUMENT CONTROL (CONTINUED) 6.1 Review and Approval of Documents Documents are reviewed for adequacy by qualified persons other than the preparer. During the construction phase, procedures for design, construction, and installation are also reviewed by the organization responsible for quality verification to ensure quality assurance measures have been appropriately applied. The documented review signifies concurrence. During the operations phase, documents affecting the configuration or operation of the station as described in the SAR are screened to identify those that require review by the IRC prior to implementation as described in Part V, Section 2.2. To ensure effective and accurate procedures during the operational phase, applicable procedures are reviewed, and updated as necessary, based on the following conditions:
- following any modification to a system;
- following an unusual incident, such as an accident, significant operator error, or equipment malfunction;
- when procedure discrepancies are found;
- prior to use if not used in the previous two years; or
- results of QA audits conducted in accordance with Part II, Section 18.1.
Prior to issuance or use, documents including revisions thereto, are approved by the designated authority. A listing of all controlled documents identifying the current approved revision, or date, is maintained so personnel can readily determine the appropriate document for use. 6.2 Changes to Documents Changes to documents, other than those defined in implementing procedures as minor changes, are reviewed and approved by the same organizations that performed the original review and approval unless other organizations are specifically designated. The reviewing organization has access to pertinent background data or information upon which to base their approval. Where temporary procedure changes are necessary during the operations phase, changes that clearly do not change the intent of the approved procedure may be implemented provided they are approved by two members of the staff knowledgeable in the areas affected by the procedures. Minor changes to documents, such as inconsequential editorial corrections, do not require that the revised documents receive the same review and approval as the original documents. To avoid a possible omission of a required review, the type of minor changes that do not require such a review and approval and the persons who can authorize such a classification shall be clearly delineated in implementing procedures. 6.3 NQA-1-1994 Commitment In establishing provisions for document control, FPL commits to compliance with NQA-1-1994, Basic Requirement 6 and Supplement 6S-1. FPL-2 Revision 4.§. Page 44 of 86April 29, 2Q18dllly 13, 2Q18Asril 1 2919 May 28,2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 46 of 87 FPL Quality Assurance Program Description SECTION 7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES FPL has established the necessary measures and governing procedures to control the procurement of items and services to assure conformance with specified requirements. Such control provides for the following as appropriate: source evaluation and selection, evaluation of objective evidence of quality furnished by the supplier, source inspection, audit, and examination of items or services. 7.1 Acceptance of Item or Service FPL establishes and implements measures to assess the quality of purchased items and services, whether purchased directly or through contractors, at intervals and to a depth consistent with the item's or service's importance to safety, complexity, quantity, and the frequency of procurement. Verification actions include testing, as appropriate, during design, fabrication and construction activities. Verifications occur at the appropriate phases of the procurement process, including, as necessary, verification of activities of suppliers below the first tier. Measures to assure the quality of purchased items and services include the following, as applicable: Items are inspected, identified, and stored to protect against damage, deterioration, or misuse. Prospective suppliers of safety-related items and services are evaluated to assure that only qualified suppliers are used. Qualified suppliers are audited on a triennial basis. In addition, if a subsequent contract or a contract modification significantly enlarges the scope of, or changes the methods or controls for, activities performed by the same supplier, an audit of the modified requirements is conducted, thus starting a new triennial period. FPL may utilize audits conducted by outside organizations for supplier qualification provided that the scope and adequacy of the audits meet FPL requirements. Documented annual evaluations are performed for qualified suppliers to assure they continue to provide acceptable products and services. Industry programs, such as those applied by ASME, Nuclear Procurement Issues Committee (NUPIC), or other established utility groups, are used as input or the basis for supplier qualification whenever appropriate. The results of the reviews are promptly considered for effect on a supplier's continued qualification and adjustments made as necessary (including corrective actions, adjustments of supplier audit plans, and input to third party auditing entities, as warranted). In addition, results are reviewed periodically to determine if, as a whole, they constitute a significant condition adverse to quality requiring additional action. FPL-2 Revision 4.§. Page 45 of 86A13ril 2G, 2Q1Bdllly 13, 2Q1Bl\sril 1, 2Q19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 47 of 87 FPL Quality Assurance Program Description SECTION 7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES (CONTINUED) Provisions are made for accepting purchased items and services, such as source verification, receipt inspection, pre- and post-installation tests, certificates of conformance, and document reviews (including Certified Material Test Report/Certificate). Acceptance actions/documents should be established by the Purchaser with appropriate input from the Supplier and be completed to ensure that procurement, inspection, and test requirements, as applicable, have been satisfied before relying on the item to perform its intended safety function. Controls are imposed for the selection, determination of suitability for intended use (critical characteristics), evaluation, receipt and acceptance of commercial-grade services or items to assure they will perform satisfactorily in service in safety-related applications. If there is insufficient evidence of implementation of a QA program, the initial evaluation is of the existence of a QA program addressing the scope of services to be provided. The initial audit is performed after the supplier has completed sufficient work to demonstrate that its organization is implementing a QA program. 7 .2 NQA-1-1994 Commitment/ Exceptions In establishing procurement verification controls, FPL commits to compliance with NQA-1-1994, Basic Requirement 7 and Supplement ?S-1, with the following clarifications and exceptions:
- NQA-1-1994, Supplement ?S-1 FPL considers that other 10 CFR 50 licensees, Authorized Nuclear Inspection Agencies, National Institute of Standards and Technology, or other State and Federal agencies which may provide items or services to FPL plants are not required to be evaluated or audited.
The methodology for use of accreditation in lieu of commercial grade surveys for laboratory calibration and test services is defined in the Nuclear Energy Institute document NEI 14-05A Revision O "Guidelines For The Use Of Accreditation In Lieu Of Commercial Grade Surveys For Procurement Of Laboratory Calibration And Test Services" and acknowledged by the NRC in RIS 2016-01 as acceptable for use by all holders of operating license under Title 10 of the Code of Federal Regulations (10 CFR) Part 50. The use of this rocess was a roved for licensees in NRC Safety Evaluation (ADAMS Accession Number ML16089A167) dated April 1, 2016 to Union Electric Company, Callaway Plant. Requirements for applying this methodology are defined in RIS 2016-01 and as identified in NEI 14-05A, commercial grade calibration or testing services may be procured from commercial laboratories based on the laboratory's accreditation to ISO/IEC-17025 by an Accreditation Body (AB) which is a signatory to the International Laboratory Accreditation Cooperation {ILAC) Mutual Recognition Arrangement (MRA) without performing commercial grade surveys Additional! , the NRC rovided rovisional Formatted: Font: 11 pt acceptance of ISO/IEC 17025 (2017 edition) applicable during the transition period set to FPL-2 Revision 4.§. Page 46 of 86i\13ril 20, 2Q1BJ1cJly 13, 2Q1BAaril 1 2019 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 48 of 87 FPL Quality Assurance Program Description SECTION 7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES (CONTINUED) expire on November 30, 2020 to allow accredited laboratories to transition from the current 2005 edition as provided by ISO. The use of ISO/IEC 17025 (2017 edition) beyond the transition period requires NRC acceptance of the next revision to NE! 14-05A supporting this edition (ADAMS Accession Number ML19056A451 dated April 16, 2019 to Nuclear Energy Institute). The use of an accredited laboratory is acceptable .orovided all of the followina are met: Formatted: Font: 12 pt
~
Formatted: Font: 11 pt Wl=leR f,HJFel=lasiR!! eeFRFReFeial §FaEle ealil3FatieR seFViees fFeFR a ealil3FalieR Formatted: Font color: Auto lal3eFatery, prem1mmeRI seuFGe evalualieR aREl seleelieR FReasums Reed net 13e peFfeFmed pFe 1Jided eael=! ef tl=!e fellewiR!! eenditiens aFe met* Formatted: Not Expanded by/ Condensed by (1) A documented review of the sui;;mlier's accreditation is i;ierformed and includes a verification of the following: (a) The calibration or test laborato[Y holds accreditation by an accrediting body recognized by the ILAC MRA. The accreditation encomi;iasses ISO/IEC-17025:2005, (or ISO/IEC-17025:2017),
"General Reguirements for the Comi;ietence of Testing and Calibration Laboratories."
(b) For i;irocurement of calibration services, the i;iublished scoi;ie of accreditation for the calibration laborato[Y covers the needed measurement i;iarameters, ranges, and uncertainties. (c) For i;irocurement of testing services, the i;iublished scoi;ie of accreditation for the test laborato[Y covers the needed testing services including test methodology and tolerances/uncertainty. (2) The i;iurchase documents reguire that: (a) The service must be i;irovided in accordance with their accredited ISO/IEC-17025:2005 (or ISO/IEC-17025:2017) i;irogram and scoi;ie of accreditation. (bl As found calibration data must be rei;iorted in the certificate of calibration when calibrated items are found to be out-of-tolerance (for calibration services only). (c) The eguii;iment/standards used to i;ierform the calibration must be identified in the certificate of calibration (for calibration services QDJy}_, (d) The customer must be notified of any condition that adversely imi;iacts the laborato[Y's ability to maintain the scoi;ie of accreditation. (e) Additional technical and guality reguirements. as necessa[Y, FPL-2 Revision 4§. Page 47 of 86AFJril 29, 29rndllly rn. 29rn.l\aril 1, 2919 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 49 of 87 FPL Quality Assurance Program Description based upon a review of the procured scope of services. which may include. but are not necessarily limited to. tolerances. accuracies, ranges, and industry standards. SECTION 7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES (CONTINUED) (3) It is validated, at receipt inspection, that the laboratory's documentation certifies that: a The contracted calibration or test service has been erformed in Formatted: Font: Not Italic, Font color: Auto accordance with their IS0/IEC~T7025:2005 (or ISO/IEC- Formatted: Body Text, Indent: Left: 1.5", Hanging: 0.31", 17025:2017) ro ram and has been erformed within their Right: 0.25", Numbered + Level: 1 + Numbering Style: a, b, scope of accreditation, and c, ... + Start at: 1 + Alignment: Left + Aligned at: 0.32" + Indent at: 0.57", Pattern: Clear, Tab stops: 1.5", Left + Not at 1" Formatted: Font: Not Italic, Font color: Auto Tl=ie purshase dosuments impose any additional teshnieal and administrative Formatted: Font: Not Italic requirements, as nesessary, to somply with the f PL 0/\ program and teshnisal provisions. At a minimum, the purshase dosument shall require that the salibration sertifisatetreport inslude identifisation of the laboratory equipment.lstandard (Q) The purchase dosuments require reporting as found salibration data when salibrated items are found to be out of toleranse. (0) A dosumented review of the supplier's assreditation *.viii be performed and will inslude a verifisation of the fellowing:
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assreditation by any one of the fellowing assrediting bodies, whish are recognized by the International Laboratory Assreditation Cooperation (lbAC} Ml,ltual Resognition Arrangement (MRI\): National Voluntary Laboratory Assreditation Program (NVbAP), administered by the National Institute of atandards & Teshnology; American Assosiation for Laboratory Assreditation (A2bA};
/\CLASS Assreditation Services ~I\CbASS);
International Assreditation aervise (I/I.a); LaboratoF)' Assreditation Bureau (L /1. B); Other ~JRC approved laboratory assrediting body.
- The assreditation ensompasses Mla/lSOtlEC 17025. "General Requirements fer the Competense of Testing and Calibration Laboratories."
- The published ssope of acsreditation fer the salibration laboratory savers the nesessary measurement parameters, range, and unsertainties.
For Section 8.1, FPL considers documents that may be stored in approved FPL-2 Revision 4.§ Page 48 of 86A13ril 2Q, 2Q1 Bdllly 13, 2Q18Aaril 1, 2Q1 Q May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 50 of 87 FPL Quality Assurance Program Description electronic media under FPL or vendor control, not physically located on the plant site, but are accessible from the respective nuclear facility site as meeting the NQA-1 requirement for documents to be available at the site. Following completion of the construction period, sufficient as-built documentation will be turned over to FPL to support operations. The FPL records management system will provide for timely retrieval of necessary records. In lieu of the requirements of Section 10, Commercial Grade Items, controls for commercial grade items and services are established in FPL documents using 10 CFR 21 and the guidance of EPRI NP-5652 as discussed in Generic Letter 89-02 and Generic Letter 91-05.
- For commercial grade items, special quality verification requirements are established and described in FPL documents to provide the necessary assurance an item will perform satisfactorily in service. The FPL documents address determining the critical characteristics that ensure an item is suitable for its intended use, technical evaluation of the item, receipt requirements, and quality evaluation of the item.
FPL will also use other appropriate approved regulatory means and controls to support FPL commercial grade dedication activities. One example of this is Electric Power Research Institute (EPRI) Topical Report TR-106439, "Guideline on Evaluation and Acceptance of Commercial Grade Digital Equipment for Nuclear Safety Applications," dated July 17, 1997. FPL will assume 10 CFR 21 reporting responsibility for all items that FPL dedicates as safety-related. FPL-2 Revision 4.§. Page 49 of 86A13Fil 2Q, 2Q1Bdllly 13. 2Q1BAaril 1. 2Q19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 51 of 87 FPL Quality Assurance Program Description SECTION 8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS FPL has established the necessary measures and governing procedures to identify and control items to prevent the use of incorrect or defective items. This includes controls for consumable materials and items with limited shelf life. The identification of items is maintained throughout fabrication, erection, installation and use so that the item can be traced to its documentation, consistent with the item's effect on safety. Identification locations and methods are selected so as not to affect the function or quality of the item. 8.1 NQA-1-1994 Commitment In establishing provisions for identification and control of items, FPL commits to compliance with NQA-1-1994, Basic Requirement 8 and Supplement 8S-1. FPL-2 Revision 4.§. Page 50 of 86/'.pril 2Q, 2Q1 Bd1c1ly 1d, 2Q18Aaril 1, 2Q1Q May 28,2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 52 of 87 FPL Quality Assurance Program Description SECTION 9 CONTROL OF SPECIAL PROCESSES FPL has established the necessary measures and governing procedures to assure that special processes that require interim process controls to assure quality, such as welding, heat treating, and nondestructive examination, are controlled. These provisions include assuring that special processes are accomplished by qualified personnel using qualified procedures and equipment. Personnel are qualified and special processes are performed in accordance with applicable codes, standards, specifications, criteria or other specially established requirements. Special processes are those where the results are highly dependent on the control of the process or the skill of the operator, or both, and for which the specified quality cannot be fully and readily determined by inspection or test of the final product. 9.1 NQA-1-1994 Commitment In establishing measures for the control of special processes, FPL commits to compliance with NQA-1-1994, Basic Requirement 9 and Supplement 9S-1. FPL-2 Revision 4§ Page 51 of 86/\13ril 2Q, 2QrnJ~ly 13, 2Q1BApril 1, 2Q19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 53 of 87 FPL Quality Assurance Program Description SECTION 10 INSPECTION FPL has established the necessary measures and governing procedures to implement inspections that assure items, services, and activities affecting safety meet established requirements and conform to applicable documented specifications, instructions, procedures, and design documents. Inspection may also be applied to items, services, and activities affecting plant reliability and integrity. Types of inspections may include those verifications related to procurement, such as source, in-process, final, and receipt inspection, as well as construction, installation, and operations activities. Inspections are carried out by properly qualified persons independent of those who performed or directly supervised the work. Inspection results are documented. 10.1 Inspection Program The inspection program establishes inspections (including surveillance of processes), as necessary to verify quality: (1) at the source of supplied items or services, (2) in-process during fabrication at a supplier's facility or at a Company facility, (3) for final acceptance of fabricated and/or installed items during construction, (4) upon receipt of items for a facility, as well as (5) during maintenance, modification, in-service, and operating activities. The inspection program establishes requirements for planning inspections, such as the group or discipline responsible for performing the inspection, where inspection hold points are to be applied, determining applicable acceptance criteria, the frequency of inspection to be applied, and identification of special tools needed to perform the inspection. Inspection planning is performed by personnel qualified in the discipline related to the inspection and includes qualified inspectors or engineers. Inspection plans are based on, as a minimum, the importance of the item to the safety of the facility, the complexity of the item, technical requirements to be met, and design specifications. Where significant changes in inspection activities for the facilities are to occur, management responsible for the inspection programs evaluate the resource and planning requirements to ensure effective implementation of the inspection program. Inspection program documents establish requirements for performing the planned inspections, and documenting required inspection information such as rejection, acceptance, and re-inspection results, and the person(s) performing the inspection. Inspection results are documented by the inspector, reviewed by authorized personnel qualified to evaluate the technical adequacy of the inspection results, and controlled by instructions, procedures, and drawings. 10.2 Inspector Qualification FPL has established qualification programs for personnel performing quality inspections. The qualification program requirements are described in Part II, Section 2. These qualification programs are applied to individuals performing quality inspections regardless of the functional group where they are assigned. FPL-2 Revision 4§. Page 52 of 86i\13ril 2Q, 2Q1 gJ~ly 13, 2Q1 §April 1, 2Q19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 54 of 87 FPL Quality Assurance Program Description SECTION 10 INSPECTION (CONTINUED) 10.3 NQA-1-1994 Commitment/ Exceptions In establishing inspection requirements, FPL commits to compliance with NQA-1-1994, Basic Requirement 10, Supplement 1OS-1 and Subpart 2.4, with the following clarification. In addition, FPL commits to compliance with the requirements of Subparts 2.5 and 2.8 for establishing appropriate inspection requirements.
- Subpart 2.4 commits FPL to IEEE 336-1985. IEEE 336-1985 refers to IEEE 498-1985. Both IEEE 336 -1985 and IEEE 498-1985 use the definition of "Safety Systems Equipment" from IEEE 603-1980. FPL commits to the definition of Safety Systems Equipment in IEEE 603- 1980, but does not commit to the balance of that standard. This definition is only applicable to equipment in the context of Subpart 2.4.
- An additional exception to Subpart 2.4 is addressed in Part II, Section 12 of the QAPD.
- Where inspections at the operating facility are performed by persons within the same organization (e.g., Maintenance group), FPL takes exception to the requirements of NQA-1-1994, Supplement 10S-1, Section 3.1, the inspectors report to the quality control management while performing those inspections.
FPL-2 Revision 4!2 Page 53 of 86April 2Q, 2Q18J1,1iy 1:.i 2Q18April 1, 2Q19 May 28,2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 55 of 87 FPL Quality Assurance Program Description SECTION 11 TEST CONTROL FPL has established the necessary measures and governing procedures to demonstrate that items subject to the provisions of the QAPD will perform satisfactorily in service, that the plant can be 'operated safely and as designed, and that the coordinated operation of the plant as a whole is satisfactory. These programs include criteria for determining when testing is required, such as proof tests before installation, pre-operational tests, post-maintenance tests, post-modification tests, in-service tests, and operational tests (such as surveillance tests required by Plant Technical Specifications), to demonstrate that performance of plant systems is in accordance with design. Programs also include provisions to establish and adjust test schedules, and to maintain status for periodic or recurring tests. Tests are performed according to applicable procedures that include, consistent with the effect on safety: (1) instructions and prerequisites to perform the test, (2) use of proper test equipment, (3) acceptance criteria, and (4) mandatory verification points as necessary to confirm satisfactory test completion. Test results are documented and evaluated by the organization performing the test and reviewed by a responsible authority to assure that the test requirements have been satisfied. If acceptance criteria are not met, re-testing is performed as needed to confirm acceptability following correction of the system or equipment deficiencies that caused the failure. The initial start-up test program is planned and scheduled to permit safe fuel loading and start-up; to increase power in safe increments; and to perform major testing at specified power levels. If tests require the variation of operating parameters outside of their normal range, the limits within which such variation is permitted will be prescribed. The scope of the testing demonstrates, insofar as practicable, that the plant is capable of withstanding the design transients and accidents. For new facility construction, the suitability of facility operating procedures is checked to the maximum extent possible during the pre-operational and initial start-up test programs. Tests are performed and results documented in accordance with applicable technical and regulatory requirements, including those described in the Technical Specifications and SAR. Test programs ensure appropriate retention of test data in accordance with the records requirements of the QAPD. Personnel that perform or evaluate tests are qualified in accordance with the requirements established in Part II, Section 2. 11.1 NQA-1-1994 Commitment In establishing provisions for testing, FPL commits to compliance with NQA-1-1994, Basic Requirement 11 and Supplement 11S-1. 11.2 NQA-1-1994 Commitment for Computer Program Testing FPL establishes and implements provisions to assure that computer software used in applications affecting safety is prepared, documented, verified and tested, and used such that the expected output is obtained and configuration control maintained. To this end FPL commits to compliance with the requirements of NQA-1-1994, Supplement 11 S-2, and Subpart 2.7 to establish the appropriate provisions. FPL-2 Revision 4.§. Page 54 of 86.0.pril 2Q, 2Q1§July 13, 2Q18Aaril 1, 2Q19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 56 of 87 FPL Quality Assurance Program Description SECTION 12 CONTROL OF MEASURING AND TEST EQUIPMENT FPL has established the necessary measures and governing procedures to control the calibration, maintenance, and use of measuring and test equipment (M&TE) that provides information important to safe plant operation. The provisions of such procedures cover equipment such as indicating and actuating instruments and gages, tools, reference and transfer standards, and nondestructive examination equipment. The suppliers of commercial-grade calibration services are controlled as described in Part II, Section 7. 12.1 Installed Instrument and Control Devices For the operations phase of the facilities, FPL has established and implements procedures for the calibration and adjustment of instrument and control devices installed in the facility. The calibration and adjustment of these devices is accomplished through the facility maintenance programs to ensure the facility is operated within design and technical requirements. Appropriate documentation will be maintained for these devices to indicate the control status, when the next calibration is due, and identify any limitations on use of the device. 12.2 NQA-1-1994 Commitment/ Exceptions In establishing provisions for control of measuring and test equipment, FPL commits to compliance with NQA-1-1994, Basic Requirement 12 and Supplement 12S-1 with the following clarification and exception: The out of calibration conditions described in paragraph 3.2 of Supplement 12S-1 refers to when the M&TE is found out of the required accuracy limits (i.e., out of tolerance) during calibration. Measuring and test equipment are not required to be marked with the calibration status where it is impossible or impractical due to equipment size or configuration (such as the label will interfere with operation of the device) provided the required information is maintained in suitable documentation traceable to the device. This exception also applies to the calibration labeling requirement stated in NQA-1-1994, Subpart 2.4, Section 7.2.1 (ANSI/IEEE Std. 336-1985). FPL-2 Revision 4.§. Page 55 of 86/1.pril 29, 2918Jl!ly 1a, 2918A13Fil 1. 291 g May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 57 of 87 FPL Quality Assurance Program Description SECTION 13 HANDLING, STORAGE, AND SHIPPING FPL has established the necessary measures and governing procedures to control handling, storage, packaging, shipping, cleaning, and preservation of items to prevent inadvertent damage or loss, and to minimize deterioration. These provisions include specific procedures, when required to maintain acceptable quality of the items important to the safe operations of the plant. Items are appropriately marked and labeled during packaging, shipping, handling and storage to identify, maintain, and preserve the item's integrity and indicate the need for special controls. Special controls (such as containers, shock absorbers, accelerometers, inert gas atmospheres, specific moisture content levels and temperature levels) are provided when required to maintain acceptable quality. Special or additional handling, storage, shipping, cleaning and preservation requirements are identified and implemented as specified in procurement documents and applicable procedures. Where special requirements are specified, the items and containers (where used) are suitably marked. Special handling tools and equipment are used and controlled as necessary to ensure safe and adequate handling. Special handling tools and equipment are inspected and tested at specified time intervals and in accordance with procedures to verify that the tools and equipment are adequately maintained. Operators of special handling and lifting equipment are experienced or trained in the use the equipment. During the operational phase, FPL establishes and implements controls over hoisting, rigging and transport activities to the extent necessary to protect the integrity of the items involved, as well as potentially affected nearby structures and components. Where required, FPL complies with applicable hoisting, rigging and transportation regulations and
- codes.
13.1 Housekeeping Housekeeping practices are established to account for conditions or environments that could affect the quality of structures, systems and components within the plant. This includes control of cleanliness of facilities and materials, fire prevention and protection, disposal of combustible material and debris, control of access to work areas, protection of equipment, radioactive contamination control and storage of solid radioactive waste. Housekeeping practices help assure that only proper materials, equipment, processes and procedures are used and that the quality of items is not degraded. Necessary procedures or work instructions, such as for electrical bus and control center cleaning, cleaning of control consoles, and radioactive decontamination are developed and used. FPL-2 Revision 4~ Page 56 of 86/\flril 2Q, 2Grndllly 13, 2Q18Aaril 1, 2Q19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 58 of 87 FPL Quality Assurance Program Description SECTION 13 HANDLING, STORAGE, AND SHIPPING (CONTINUED) 13.2 NQA-1-1994 Commitment/ Exceptions In establishing provisions for handling, storage and shipping, FPL commits to compliance with NQA-1-1994, Basic Requirement 13 and Supplement 13S-1. FPL also commits, during the construction and pre-operational phase of the plant, to compliance with the requirements of NQA-1-1994, Subpart 2.1, Subpart 2.2, and Subpart 3.2, Appendix 2.1, with the following clarifications and exceptions: NQA-1-1994, Subpart 2.1 Subpart 2.1, Section 3.1 and 3.2 establish criteria for classifying items into cleanness classes and requirements for each class. Instead of using the cleanness level system of Subpart 2.1, FPL may establish cleanness requirements on a case-by-case basis, consistent with the other provisions of Subpart 2.1. FPL establishes appropriate cleanliness controls for work on safety-related equipment to minimize introduction of foreign material and maintain system/component cleanliness throughout maintenance or modification activities, including documented verification of absence of foreign material prior to system closure. NQA-1-1994, Subpart2.2 Subpart 2.2, Section 2.2 establishes criteria for classifying items into protection levels. Instead of classifying items into protection levels during the operational phase, FPL may establish controls for the packaging, shipping, handling, and storage of such items on a case-by-case basis with due regard for the item's complexity, use, and sensitivity to damage. Prior to installation or use, the items are inspected and serviced as necessary to assure that no damage or deterioration exists which could affect their function. Subpart 2.2, Section 6.6, "Storage Records:" This section requires written records be prepared containing information on personnel access. As an alternative to this requirement, FPL documents establish controls for storage areas that describe those authorized to access areas and the requirements for recording access of personnel. However, these records of access are not considered quality records and will be retained in accordance with the administrative controls of the applicable plant. Subpart 2.2, Section 7.1 refers to Subpart 2.15 for requirements related to handling of items. The scope of Subpart 2.15 includes hoisting, rigging and transporting of items for the nuclear power plants during construction. FPL-2 Revision 4§. Page 57 of 86A13ril 2Q, 2Q1BJ1c1ly 1:3, 2Q1B/\aril 1, 2Q19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 59 of 87 FPL Quality Assurance Program Description SECTION 13 HANDLING, STORAGE, AND SHIPPING (CONTINUED) NQA-1-1994, Subpart 2.3 Subpart 2.3, Section 2.3 requires the establishment of five zone designations for housekeeping cleanliness controls. Instead of the five-level zone designation, FPL bases its control over housekeeping activities on a consideration of what is necessary and appropriate for the activity involved. The controls are implemented through procedures or instructions which, in the case of maintenance or modification work, are developed on a case-by-case basis. Factors considered in developing the procedures and instructions include cleanliness control, personnel safety, fire prevention and protection, radiation control and security. The procedures and instructions make use of standard janitorial and work practices to the extent possible. NQA-1-1994, Subpart 3.2 Subpart 3.2, Appendix 2.1: Only Section 3 precautions are being committed to in accordance with RG 1.37. In addition, a suitable chloride stress-cracking inhibitor should be added to the fresh water used to flush systems containing austenitic stainless steels. FPL-2 Revision 4.§. Page 58 of 86A~ril 2Q, 2Q18Jt1ly 13, 2Q18A13ril 1, 2Q19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 60 of 87 FPL Quality Assurance Program Description SECTION 14 INSPECTION, TEST, AND OPERATING STATUS FPL has established the necessary measures and governing procedures to identify the inspection, test, and operating status of items and components subject to the provisions of the QAPD in order to maintain personnel and reactor safety and avoid inadvertent operation of equipment. Where necessary to preclude inadvertent bypassing of inspections or tests, or to preclude inadvertent operation, these measures require the inspection, test or operating status be verified before release, fabrication, receipt, installation, test or use. These measures also establish the necessary authorities and controls for the application and removal of status indicators or labels. In addition, temporary design changes (temporary modifications), such as temporary bypass lines, electrical jumpers and lifted wires, and temporary trip-point settings, are controlled by procedures that include requirements for appropriate installation and removal, independent/concurrent verifications and status tracking. Administrative procedures also describe the measures taken to control altering the sequence of required tests, inspections, and other operations. Review and approval for these actions is subject to the same control as taken during the original review and approval of tests, inspections, and other operations. 14.1 NQA-1-1994 Commitment In establishing measures for control of inspection, test and operating status, FPL commits to compliance with NQA-1-1994, Basic Requirement 14. FPL-2 Revision 4.§. Page 59 of 861\13Fil 29, 2Q18Jllly 13, 2Q18Aaril 1 2919 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 61 of 87 FPL Quality Assurance Program Description SECTION 15 NONCONFORMING SERVICES, MATERIALS, PARTS, OR COMPONENTS FPL has established the necessary measures and governing procedures to control items, including services, that do not conform to specified requirements to prevent inadvertent installation or use. Controls provide for identification, documentation, evaluation, segregation when practical, and disposition of nonconforming items, and for notification to affected organizations. Controls are provided to address conditional release of nonconforming items for use on an at-risk basis prior to resolution and disposition of the nonconformance, including maintaining identification of the item and documenting the basis for such release. Conditional release of nonconforming items for installation requires the approval of the designated management. Nonconformances are corrected or resolved prior to depending on the item to perform its intended safety function. Nonconformances are evaluated for impact on operability of quality structures, systems, and components to assure that the final condition does not adversely affect safety, operation, or maintenance of the item or service. Nonconformances to design requirements dispositioned as repair or use-as-is are subject to design control measures commensurate with those applied to the original design. Nonconformance dispositions are reviewed for adequacy, analysis of quality trends, and reports provided to the designated management. Significant trends are reported to management in accordance with FPL procedures, regulatory requirements, and industry standards. 15.1 Reporting Program FPL has the necessary measures and governing procedures that implement a reporting program that conforms to the requirements of 10 CFR 52, 10 CFR 50.55 and 10 CFR 21 during design and construction and 10 CFR 21 during operations. 15.2 NQA-1-1994 Commitment In establishing measures for nonconforming materials, parts, or components, FPL commits to compliance with NQA-1-1994, Basic Requirement 15, and Supplement 15S-1. FPL-2 Revision 4§. Page 60 of 86AflFil 2G, 2Q1 §dllly 13, 2Q1 §/1,aril 1, 2Q19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 62 of 87 FPL Quality Assurance Program Description SECTION 16 CORRECTIVE ACTION FPL has established the necessary measures and governing procedures to promptly identify, control, document, classify and correct conditions adverse to quality. FPL procedures assure that corrective actions are documented and initiated following the determination of conditions adverse to quality in accordance with regulatory requirements and applicable quality standards. FPL procedures require personnel to identify known conditions adverse to quality. When complex issues arise where it cannot be readily determined if a condition adverse to quality exists, FPL documents establish the requirements for documentation and timely evaluation of the issue. Reports of conditions adverse to quality are analyzed to identify trends. Significant conditions adverse to quality and significant adverse trends are documented and reported to responsible management. In the case of a significant condition adverse to quality, the cause is determined and actions to preclude recurrence are taken. In the case of suppliers working on safety-related activities, or other similar situations, FPL may delegate specific responsibilities of the Corrective Action program but FPL maintains responsibility for the program's effectiveness. 16.1 Reporting Program FPL has the necessary measures and governing procedures that implement a reporting program that conforms to the requirements of 10 CFR 52, 10 CFR 50.55 and/or 10 CFR 21 during design and construction, and 10 CFR 21 during operations. 16.2
- NQA-1-1994 Commitment In establishing provisions for corrective action, FPL commits to compliance with NQA-1-1994, Basic Requirement 16.
FPL-2 Revision 4.§. Page 61 of 86 1\J:)Fil 20, 2018JlJly 13, 2018April 1, 2019 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 63 of 87 FPL Quality Assurance Program Description SECTION 17 QUALITY ASSURANCE RECORDS FPL has the necessary measures and governing procedures to ensure that sufficient records of items and activities affecting quality are developed, reviewed, approved, issued, used, and revised to reflect completed work. The provisions of such procedures establish the scope of the records retention program for FPL and include requirements for records administration, including receipt, preservation, retention, storage, safekeeping, retrieval, access controls, user privileges, and final disposition. 17.1 Record Retention Measures are established that ensure that sufficient records of completed items and activities affecting quality are appropriately stored. Records of activities for design, engineering, procurement, manufacturing, construction, inspection and test, installation, pre-operation, startup, operations, maintenance, modification, decommissioning, and audits and their retention times are defined in appropriate procedures. The records and retention times are based on Regulatory Position C.2 and Table 1, of Regulatory Guide 1.28, Revision 3 for design, construction, and initial start-up. Retention times for operations phase records are based on construction records that are similar in nature. 17.2 Electronic Records When using optical discs for electronic records storage and retrieval systems, FPL complies with the NRC guidance in Generic Letter 88-18, "Plant Record Storage on Optical Disks." FPL will manage the storage of QA Records in electronic media consistent with the intent of RIS 2000-18 and associated NIRMA Guidelines TG 11-1998, TG15-1998, TG16-1998, and TG21-1998. 17.3 NQA-1-1994 Commitment/ Exceptions In establishing provisions for records, FPL commits to compliance with NQA-1-1994, Basic Requirement 17 and Supplement 17S-1 as well as the applicable portions of 10 CFR 73 established via 10 CFR 73.55 (q) and 1 O CFR 73.70, with the following clarifications and exceptions:
- NQA-1-1994, Supplement 17S-1
- Supplement 17S-1, Section 4.2(b), requires records to be finmly attached in binders or placed in folders or envelopes for storage in steel file cabinets or on shelving in containers. For hard-copy records maintained by FPL, the records are suitably stored in steel file cabinets or on shelving in containers, except that methods other than binders, folders or envelopes may be used to organize the records for storage.
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Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 64 of 87 FPL Quality Assurance Program Description SECTION 18 AUDITS FPL has established the necessary measures and governing procedures to implement audits to verify that activities covered by the QAPD are performed in conformance with the requirements established. The audit programs are themselves reviewed for effectiveness as a part of the overall audit process. 18.1 Performance of Audits Internal audits of selected aspects of licensing, design, construction phase arid operating activities are performed with a frequency commensurate with safety significance and in a manner which assures that audits of safety-related activities are completed. During the early portions of NNP activities, audits will focus on areas including, but not limited to, procurement, and corrective action. Functional areas of an organization's QA program for auditing include, at a minimum, verification of compliance and effectiveness of implementation of internal rules, procedures (e.g., operating, design, procurement, maintenance, modification, refueling, surveillance, test, security, radiation control procedures, and the emergency plan), Technical Specifications, regulations and license conditions, programs for training, retraining, qualification and performance of operating staff, corrective actions, and observation of performance of operating, refueling, maintenance and modification activities, including associated record keeping. The audits are scheduled on a formal preplanned audit schedule. The audit system is reviewed periodically and revised as necessary to assure coverage commensurate with current and planned activities. Additional audits may be performed as deemed necessary by management. The scope of the audit is determined by the quality status and safety importance of the activities being performed. These audits are conducted by trained personnel not having direct responsibilities in the area being audited and in accordance with preplanned and approved audit plans or checklists, under the direction of a qualified lead auditor and the cognizance of the Quality Manager responsible for the day to day program as documented in Section 1. FPL is responsible for conducting periodic internal and external audits. Internal audits are conducted to determine the adequacy of programs and procedures (by representative sampling), and to determine if they are meaningful and comply with the overall QAPD. External audits determine the adequacy of supplier and contractor quality assurance programs. The results of each audit are reported in writing to the responsible Senior Executive responsible for the Quality Assurance program at the Site, or designee, as appropriate. Additional internal distribution is made to other concerned management levels in accordance with approved procedures. Management responds to all audit findings and initiates corrective action where indicated. Where corrective action measures are indicated, documented follow-up of applicable areas through inspections, review, re-audits, or other appropriate means is conducted to verify implementation of assigned corrective action. Audits of suppliers of safety-related components and/or services are conducted as described in Section 7.1. FPL-2 Revision 4~ Page 63 of 86/1.pril 2'l, 2Q18d1c1ly 1:3. 2Q18A13ril 1, 2G19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 65 of 87 FPL Quality Assurance Program Description SECTION 18 AUDITS (CONTINUED) 18.2 Internal Audits Internal audits of organization and facility activities, conducted prior to placing the facility in operation, should be performed in such a manner as to assure that an audit of all applicable QA program elements is completed for each functional area at least once each year or at least once during the life of the activity, whichever is shorter. Internal audits of activities, conducted after placing the facility in operation, should be performed in such a manner as to assure that an audit of all applicable QA program elements is completed for each functional area within a period of two years. Internal audit frequencies of well established activities, conducted after placing the facility in operation, may be extended one year at a time beyond the above two-year interval based on the results of an annual evaluation of the applicable functional area and objective evidence that the functional area activities are being satisfactorily accomplished. The evaluation should include a detailed performance analysis of the functional area based upon applicable internal and external source data and due consideration of the impact of any functional area changes in responsibility, resources or management. However, the internal audit frequency interval should not exceed a maximum of four years. If an adverse trend is identified in the applicable functional area, the extension of the internal audit frequency interval should be rescinded and an audit scheduled as soon as practicable. During the operations phase, audits are performed at a frequency commensurate with the safety significance of the activities and in such a manner to assure audits of all applicable QA program elements are completed within a period of two years. These audits will include, as a minimum, activities in the following areas:
- 1. The conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions including administrative controls.
- 2. The performance, training, and qualifications of the facility staff.
- 3. The performance of activities required by the QAPD to meet the criteria of 10 CFR 50, Appendix B.
- 4. The Fire Protection Program and implementing procedures. A fire protection equipment and program implementation inspection and audit are conducted utilizing either a qualified off-site licensed fire protection engineer or an outside qualified fire protection consultant.
- 5. Other activities and documents considered appropriate by the Chief Nuclear Officer.
Audits may also be used to meet the periodic review requirements for Security, Emergency Preparedness, and Radiological Protection programs within the provisions of the applicable regulation. FPL-2 Revision 4§. Page 64 of 86/\13Fil 2G, 2G1 BJ1c1ly 1a, 2G18/1.pril 1, 2G1 G May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 66 of 87 FPL Quality Assurance Program Description SECTION 18 AUDITS (CONTINUED) Internal audits include verification of compliance and effectiveness of the administrative controls established for implementing the requirements of the QAPD; regulations and license provisions; provisions for training, retraining, qualification, and performance of personnel performing activities covered by the QAPD; corrective actions taken following abnormal occurrences; and, observation of the performance of construction, fabrication, operating, refueling, maintenance, and modification activities including associated record keeping. 18.3 NQA-1-1994 Commitment In establishing the independent audit program, FPL commits to compliance with NQA-1-1994, Basic Requirement 18 and Supplement 18S-1. FPL-2 Revision 4.§. Page 65 of 86A13Fil 29, 2918July 1a, 2918AaFil 1, 2919 May 28,2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 67 of87 FPL Quality Assurance Program Description PART Ill NONSAFETY-RELATED SSC QUALITY CONTROL SECTION 1 NON-SAFETY RELATED SSCs - SIGNIFICANT CONTRIBUTORS TO PLANT SAFETY Specific program controls are applied to nonsafety-related SSCs, for which 10 CFR 50, Appendix B is not applicable, that are significant contributors to plant safety. The specific program controls consistent with applicable sections of the QAPD are applied to those items in a selected manner, targeted at those characteristics or critical attributes that render the SSC a significant contributor to plant safety. The following clarify the applicability of the QA Program to the nonsafety-related SSCs and related activities, including the identification of exceptions to the QA Program described in Part II, Sections 1 through 18 taken for nonsafety-related SSCs. 1.1 Organization The verification activities described in this part may be performed by the FPL line organization. The QA organization described in Part II is not required to perform these functions. 1.2 QA Program FPL QA requirements for nonsafety-related SSCs are established in the QAPD and appropriate procedures. Suppliers of these SSCs or related services describe the quality controls applied in appropriate procedures. A new or separate QA program is not required. 1.3 Design Control FPL has design control measures to ensure that the contractually established design requirements are included in the design. These measures ensure that applicable design inputs are included or correctly translated into the design documents, and deviations from those requirements are controlled. Design verification is provided through the normal supervisory review of the designer's work. 1.4 Procurement Document Control Procurement documents for items and services obtained by or for FPL include or reference documents describing applicable design bases, design requirements, and other requirements necessary to ensure component performance. The procurement documents are controlled to address deviations from the specified requirements. FPL-2 Revision 4.§. Page 66 of 86A13ril 20, 2018Ji,Jly 1:l, 20181\aril 1, 2019 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 68 of 87 FPL Quality Assurance Program Description SECTION 1 NON-SAFETY RELATED SSCs - SIGNIFICANT CONTRIBUTORS TO PLANT SAFETY (CONTINUED) 1.5 Instructions, Procedures, and Drawings FPL provides documents such as, but not limited to, written instructions, plant procedures, drawings, vendor technical manuals, and special instructions in work orders, to direct the performance of activities affecting quality. The method of instruction employed provides an appropriate degree of guidance to the personnel performing the activity to achieve acceptable functional performance of the SSC. 1.6 Document Control FPL controls the issuance and change of documents that specify quality requirements or prescribe activities affecting quality to ensure that correct documents are used. These controls include review and approval of documents, identification of the appropriate revision for use, and measures to preclude the use of superseded or obsolete documents. 1.7 Control of Purchased Items and Services FPL employs measures, such as inspection of items or documents upon receipt or acceptance testing, to ensure that all purchased items and services conform to appropriate procurement documents. 1.8 Identification and Control of Purchased Items FPL employs measures where necessary, to identify purchased items and preserve their functional performance capability. Storage controls take into account appropriate environmental, maintenance, or shelf life restrictions for the items. 1.9 Control of Special Processes FPL employs process and procedure controls for special processes, including welding, heat treating, and nondestructive testing. These controls are based on applicable codes, standards, specifications, criteria, or other special requirements for the special process. 1.10 Inspection FPL uses documented instructions to ensure necessary inspections are performed to verify conformance of an item or activity to specified requirements or to verify that activities are satisfactorily accomplished. These inspections are performed by knowledgeable personnel who may be in the same line organization as those performing the activity being inspected. FPL-2 Revision 4.§. Page 67 of 86April 2Q, 2Q18Jt1ly 1a, 2Q1 BAaril 1, 2Q1 Q May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 69 of 87 FPL Quality Assurance Program Description SECTION 1 NON-SAFETY RELATED SSCs - SIGNIFICANT CONTRIBUTORS TO PLANT SAFETY (CONTINUED) 1.11 Test Control FPL employs measures to identify required testing that demonstrates that equipment conforms to design requirements. These tests are performed in accordance with test instructions or procedures. The test results are recorded, and authorized individuals evaluate the results to ensure that test requirements are met. 1.12 Control of Measuring and Test Equipment (M&TE) FPL employs measures to control M&TE use, and calibration and adjustment at specific intervals or prior to use. 1.13 Handling, Storage, and Shipping FPL employs measures to control the handling, storage, cleaning, packaging, shipping, and preservation of items to prevent damage or loss and to minimize deterioration. These measures include appropriate marking or labels, and identification of any special storage or handling requirements. 1.14 Inspection, Test, and Operating Status FPL employs measures to identify items that have satisfactorily passed required tests and inspections and to indicate the status of inspection, test, and operability as appropriate. 1.15 Control of Nonconforming Items FPL employs measures to identify and control items that do not conform to specified requirements to prevent their inadvertent installation or use. 1.16 Corrective Action FPL employs measures to ensure that failures, malfunctions, deficiencies, deviations, defective components, and nonconformances are properly identified, reported, and corrected. 1.17 Records FPL employs measures to ensure records are prepared and maintained to furnish evidence that the above requirements for design, procurement, document control, inspection, and test activities have been met. FPL-2 Revision 4.§. Page 68 of 86/\.iril 2Q, 2Q1BJ1c1ly 13, 2Q1 B/\aril 1, 2Q1 Q May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 70 of 87 FPL Quality Assurance Program Description SECTION 1 NON-SAFETY RELATED SSCs - SIGNIFICANT CONTRIBUTORS TO PLANT SAFETY (CONTINUED) 1.18 Audits FPL employs measures for line management to periodically review and document the adequacy of the process, including taking any necessary corrective action. Audits independent of line management are not required. Line management is responsible for determining whether reviews conducted by line management or audits conducted by any organization independent of line management are appropriate. If performed, audits are conducted and documented to verify compliance with design and procurement documents, instructions, procedures, drawings, and inspection and test activities. Where the measures of this part (Part Ill) are implemented by the same programs, processes, or procedures as the comparable activities of Part II, the audits performed under the provisions of Part II may be used to satisfy the review requirements of this Section (Part 111, Section 1.18). SECTION 2 NON-SAFETY RELATED SSCs CREDITED FOR REGULATORY EVENTS The following criteria apply to fire protection (10 CFR 50.48), anticipated transients without scram (ATWS) (10 CFR 50.62), the station blackout (SBO) (10 CFR 50.63) SSCs that are not safety-related;
- FPL implements quality requirements for the fire protection system in accordance with Regulatory Position 1.7, "Quality Assurance," in Regulatory Guide 1.189, "Fire Protection for Operating Nuclear Power Plants."
- FPL implements the quality requirements for ATWS equipment in accordance with Generic Letter 85-06, "Quality Assurance Guidance for ATWS Equipment That Is Not Safety Related."
- FPL implements quality requirements for SBO equipment in accordance with Regulatory Position 3.5, "Quality Assurance and Specific Guidance for SBO Equipment That Is Not Safety Related," and Appendix A, "Quality Assurance Guidance for Nonsafety Systems and Equipment," in Regulatory Guide 1.155, "Station Blackout."
FPL-2 Revision 4§. Page 69 of 86Ar,ril 2G, 2G18July 1 a, 2G18Aeril 1. 2G1Q May 28,2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 71 of 87 FPL Quality Assurance Program Description PART IV REGULATORY COMMITMENTS NRC REGULATORY GUIDES AND QUALITY ASSURANCE STANDARDS This section identifies the NRG Regulatory Guides and the other quality assurance standards which have been selected to supplement and support the FPL QAPD. See FSAR Chapter 1 for the FPL evaluation of conformance with the guidance in NRG Regulatory Guides in effect six months prior to the submittal date of the application. REGULATORY GUIDES Regulatory Guide 1.8, Rev. 3, May 2000, Qualification and Training of Personnel for Nuclear Power Plants Regulatory Guide 1.8 provides guidance that is acceptable to the NRG staff regarding qualifications and training for nuclear power plant personnel. FPL identifies conformance and exceptions for the applicable regulatory position guidance provided in this regulatory guide in FSAR Chapter 1. Regulatory Guide 1.26, Revision 4, March 2007 - Quality Group Classifications and Standards for Water-, Steam-, and Radioactive-Waste-Containing Components of Nuclear Power Plants Regulatory Guide 1.26 defines classification of systems and components. FPL identifies conformance and exceptions for the applicable regulatory position guidance provided in this regulatory guide in FSAR Chapter 1. Regulatory Guide 1.28, Rev. 3, August 1985, Quality Assurance Program Requirements (Design and Construction) Regulatory Guide 1.28 describes a method acceptable to the NRG staff for complying with the provisions of Appendix B with regard to establishing and implementing the requisite quality assurance program for the design and construction of nuclear power plants. FPL identifies conformance and exceptions for the applicable regulatory position guidance provided in this regulatory guide in FSAR Chapter 1. Regulatory Guide 1.29, Revision 4, March 2007 - Seismic Design Classification Regulatory Guide 1.29 defines systems required to withstand a safe shutdown earthquake (SSE). FPL identifies conformance and exceptions for the applicable regulatory position guidance provided in this regulatory guide in FSAR Chapter 1. FPL-2 Revision 4.§. Page 70 of 86Af)Fil 2G, 2G18Jlll',' 13, 2G18Aaril 1. 2G19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 72 of 87 FPL Quality Assurance Program Description NRC REGULATORY GUIDES AND QUALITY ASSURANCE STANDARDS (CONTINUED) Regulatory Guide 1.33, Revision 2, February 1978, Quality Assurance Program Requirements (Operations) Regulatory Guide 1.33 describes a method acceptable to the NRC staff for complying with the Commission's regulations with regard to overall quality assurance program requirements for the operation phase of nuclear power plants. FPL identifies conformance and exceptions for the applicable regulatory position guidance provided in this regulatory guide in FSAR Chapter 1. Regulatory Guide 1.37, Revision 1, March 2007 - Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants Regulatory Guide 1.37 provides guidance on specifying water quality and precautions related to the use of alkaline cleaning solutions and chelating agents. FPL identifies conformance and exceptions for the applicable regulatory position guidance provided in this regulatory guide in FSAR Chapter 1. Regulatory Guide 1.54, Revision 1, July 2000 - Service Level I, II, and Ill Protective Coatings Applied to Nuclear Power Plants Regulatory Guide 1.54 provide guidance for the application of protective coatings within nuclear power plants to protect surfaces from corrosion, contamination from radionuclides, and for wear protection. FPL identifies conformance and exceptions for the applicable regulatory position guidance provided in this regulatory guide in FSAR Chapter 1. For plants with an NFPA 805 fire protection licensing bases, NextEra Energy commits to implement Regulatory Guide 1.205, December 2009, Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants, which endorses in part, NEI 04-02, Revision 2, Nuclear Energy Institute Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c). The implementation of these documents is described in the station specific Technical Specifications and License Conditions and station specific NRC approved Safety Evaluation Reports. FPL-2 Revision 4~ Page 71 of 86Af:)Fil 2G, 2Q1§Ji,jly 13, 2G1 Maril 1, 2G19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 73 of 87 FPL Quality Assurance Program Description NRC REGULATORY GUIDES AND QUALITY ASSURANCE STANDARDS (CONTINUED) STANDARDS ASME NQA-1-1994 Edition - Quality Assurance Requirements for Nuclear Facility Applications FPL commits to NQA-1-1994, Parts I, II, and Ill, as described in the foregoing sections of this document. Nuclear Information and Records Management Association, Inc. (NIRMAl Technical Guides (TGs) FPL commits to NIRMA TGs as described in Part II, Section 17. FPL-2 Revision 4.§. Page 72 of 86,'1,pril 2Q, 2Q18Jldly 1:3, 2Q18/l,pril 1, 2Q19 May 28,2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 74 of 87 FPL Quality Assurance Program Description PART V ADDITIONAL QUALITY ASSURANCE AND ADMINISTRATIVE CONTROLS FOR THE PLANT OPERATIONAL PHASE FPL includes the requirements of Part V to establish the necessary measures and governing procedures for the operations phase of the plant. SECTION 1 DEFINITIONS FPL uses the definitions of terms as provided in Section 4 of the Introduction of NQA-1-1994 in interpreting the requirements of NQA-1-1994 and the other standards to which the QAPD commits. In addition, definitions are provided for the following terms not covered in NQA-1-1994: administrative controls: rules, orders, instructions, procedures, policies, practices and designations of authority and responsibility experiments: performance of plant operations carried out under controlled conditions in order to establish characteristics or values not previously known independent review: review completed by personnel not having direct responsibility for the work function under review regardless of whether they operate as a part of an organizational unit or as individual staff members (see review) nuclear power plant: any plant using a nuclear reactor to produce electric power, process steam or space heating on-site operating organization: on-site personnel concerned with the operation, maintenance and certain technical services operating activities: work functions associated with normal operation and maintenance of the plant, and technical services routinely assigned to the on-site operating organization operational phase: that period of time during which the principal activity is associated with normal operation of the plant. This phase of plant life is considered to begin formally with commencement of initial fuel loading, and ends with plant decommissioning review: a deliberately critical examination, including observation of plant operation, evaluation of assessment results, procedures, certain contemplated actions, and after-the-fact investigations of abnormal conditions supervision: direction of personnel activities or monitoring of plant functions by an individual responsible and accountable for the activities they direct or monitor surveillance testing: periodic testing to verify that safety related structures, systems, and components continue to function or are in a state of readiness to perform their functions system: an integral part of nuclear power plant comprising components which may be operated or used as a separate entity to perform a specific function FPL-2 Revision 4.§_ Page 73 of 86A13fil 20, 201 Bdlclly 1a. 2Q1 Maril 1, 2Q1 Q May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 75 of 87 FPL Quality Assurance Program Description SECTION 2 REVIEW OF ACTIVITIES AFFECTING SAFE PLANT OPERATION 2.1 Onsite Operating Organization Review The FPL onsite organization employs reviews, both periodic and as situations demand, to evaluate plant operations and plan future activities. The important elements of the reviews are documented and subjects of potential concern for the independent review described below are brought to the attention of the Plant Manager. The reviews are part of the normal duties of plant supervisory personnel in order to provide timely and continuing monitoring of operating activities in order to assist the Plant Manager in keeping abreast of general plant conditions and to verify that day-to-day operations are conducted safely in accordance with the established administrative controls. The Plant Manager ensures the timely referral of the applicable matters discussed in the reviews to appropriate management and independent reviewers. 2.2 Independent Review Activities occurring during the operational phase shall be independently reviewed on a periodic basis. The independent review program shall be functional prior to initial core loading. The independent review function performs the following:
- a. Reviews proposed changes to the facility as described in the safety analysis report (SAR). The Independent Review Committee (IRC) also verifies that changes do not adversely affect safety and if a technical specification change or NRC review is required.
- b. Reviews proposed tests and experiments not described in the SAR prior to implementation. Verifies the determination of whether changes to proposed tests and experiments not described in the SAR require a technical specification change or license amendment.
- c. Reviews proposed technical specification changes and license amendments relating to nuclear safety prior to NRC submittal and implementation, except in those cases where the change is identical to a previously approved change.
- d. Reviews violations, deviations, and events that are required to be reported to the NRC. This review includes the results of investigations and recommendations resulting from such investigations to prevent or reduce the probability of recurrence of the event.
- e. Reviews any matter related to nuclear safety that is requested by the Site Director I PGM Site Vice Prnsident
- f. Reviews corrective actions for significant conditions adverse to quality.
- g. Reviews internal audit reports.
- h. Reviews the adequacy of the internal audit program every 24 months.
FPL-2 Revision 4§. Page 74 of 86/\13ril 20, 201BJ1cJly 13, 2918/\aril 1, 2019 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 76 of 87 FPL Quality Assurance Program Description SECTION 2 REVIEW OF ACTIVITIES AFFECTING SAFE PLANT OPERATION (CONTINUED) Independent Review Committee
- 1. An independent review committee is assigned independent review responsibilities.
- 2. The independent review committee reports to the Site Director I PGM. _Site Vise PresiseRt.
- 3. The independent review committee is composed of no less than 5 persons and no more than a minority of members are from the on-site operating organization.
For example, at least 3 of the 5 members must be from off-site if there are 5 members on the committee. A minimum of the chairman or alternative chairman and 2 members must be present for all meetings.
- 4. During the period of initial operation, meetings are conducted no less frequently than
.once per calendar quarter. Afterwards meetings are conduced no less than twice a year.
- 5. Results of the meeting are documented and recorded.
- 6. Consultants and contractors are used for the review of complex problems beyond the expertise of the off site/on site independent review committee.
- 7. Persons on the independent review committee are qualified as follows:
- a. Supervisor or Chairman of the Independent Review Committee
- Education: baccalaureate in engineering or related science
- Minimum experience: 6 years combined managerial and technical support
- b. Independent Review Committee Members Education: Baccalaureate in engineering or related science for those Independent review personnel who are required to review problems in:
- nuclear power plant operations,
- nuclear engineering,
- chemistry and radiochemistry,
- metallurgy,
- nondestructive testing,
- instrumentation and control,
- radiological safety,
- mechanical engineering, and electrical engineering.
FPL-2 Revision 4.§. Page 75 of 86A13ril 2Q, 2Q1 BJuly 13, 2Q18/\pril 1 2Q1 Q May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 77 of 87 FPL Quality Assurance Program Description SECTION 2 REVIEW OF ACTIVITIES AFFECTING SAFE PLANT OPERATION (CONTINUED) High school diploma for those independent review personnel who are required to review problems in administrative control and quality assurance practices, training, and emergency plans and related procedures and equipment. Minimum experience: 5 years experience in their own area of responsibility (nuclear power plant operations, nuclear engineering, chemistry and radiochemistry, metallurgy, nondestructive testing, instrumentation and control, radiological safety, mechanical engineering, and electrical engineering, administrative control and quality assurance practices, training, and emergency plans and related procedures and equipment). An independent biennial assessment includes an examination of selected procedures to verify that the procedure review and revision controls of Section B.14 are effectively implemented. Results of independent assessments are reported in an understandable form and in a timely fashion to a level of management having the authority to effect corrective action. Nuclear Assurance conducts timely follow-up action, including re-assessment of deficient areas, as necessary, to establish adequacy of corrective actions. Independent assessment results are documented and reviewed by Nuclear Assessment management and by management having responsibility for the area assessed. In addition, Nuclear Assurance activities are periodically assessed for effectiveness. Results are documented and reported to responsible management. Nuclear Assurance provides for assessment of work carried out under the requirements of the QAP that is delegated to other (non-NextEra Energy) entities. Independent Assessments are performed on a fixed frequency. Independent Assessments of the topics in Table 1 are audited at least biennially. A 90-day grace period may be applied to these non-regulatory topics in executing this periodicity. When the grace period is applied, the next due date for the activity is based upon the original scheduled date. However, in all cases the periodicity shall not exceed two years plus 90 days. Certain activities, as identified in Table 2, receive independent assessments at frequencies established by related NRC rules. A grace period shall not be applied to these regulatory topics unless permitted by the NRC rule. FPL-2 Revision 432 Page 76 of 861\pril 2Q, 2grnJt1ly 1a, 2Grnl'.aril 1, 2Q1 g May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 78 of 87 FPL Quality Assurance Program Description SECTION 2 REVIEW OF ACTIVITIES AFFECTING SAFE PLANT OPERATION (CONTINUED) Table 1 Topics Subjectto Independent Assessment with QA TR Defined Frequency Topic1 Chemistry, Effluents & Environmental Monitoring Engineering Maintenance / Work Management Nuclear Assurance Operations Performance Improvement Procurement & Nuclear Materials Management QA Programs Radiological Protection & Radwaste Training Table 2 Topics Subject to Independent Assessment with Regulatory Defined Frequency
-*** TQpic1 *"**. '"
Cyber Security Emergency Planning Fire Protection Fitness For Duty and Access Authorization Independent Spent Fuel Storage Security
- 1. Topic titles in these tables may vary; however, all program elements (i.e. applicable regulatory requirements and all 10 CFR 50 Appendix B criteria) will be covered as identified in implementing procedures.
FPL-2 Revision 4.§. Page 77 of 86/\pril 2Q, 2Q18July 1:l, 2Q18Aeril 1. 2Q19 May 28, 2019
l Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 79 of 87 FPL Quality Assurance Program Description SECTION 3 OPERATIONAL PHASE PROCEDURES The following is a description of the various types of procedures used by FPL to govern the design, operation, and maintenance of its nuclear generating plants. FPL follows the guidance of Appendix A to Regulatory Guide 1.33 in identifying the types of activities that should have procedures or instructions to control the activity. Each procedure shall be sufficiently detailed for a qualified individual to perform the required function without direct supervision, but need not provide a complete description of the system or plant process. 3.1 Format and Content Procedure format and content may vary from one location to the other. However, procedures include the following elements as appropriate to the purpose or task to be described:
- Title/Status Each procedure is given a title descriptive of the work or subject it addresses, and includes a revision number and/or date and an approval status.
- Purpose/Statement of Applicability/Scope The purpose for which the procedure is intended is clearly stated (if not clear from the title). The systems, structures, components, processes or conditions to which the procedure applies are also clearly described.
- References Applicable references, including reference to appropriate Technical Specifications, are required. References are included within the body of the procedure when the sequence of steps requires other tasks to be performed (according to the reference) prior to or concurrent with a particular step.
- Prerequisites/Initial Conditions Prerequisites/initial conditions identify those independent actions or procedures that must be accomplished and plant conditions which must exist prior to performing the procedure. A prerequisite applicable to only a specific portion of a procedure is so identified.
- Precautions Precautions alert the user to those important measures to be used to protect equipment and personnel, including the public, or to avoid an abnormal or emergency situation during performance of the procedure. Cautionary notes applicable to specific steps are included in the main body of the procedure and are identified as such.
- Limitations and Actions Limitations on the parameters being controlled and appropriate corrective measures to return the parameter to the normal control band are specified.
FPL-2 Revision 4Q Page 78 of 86/\F'Fil 20, 201 BJ~ly 1a, 20181'.aFil 1, 201 g May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 80 of 87 FPL Quality Assurance Program Description SECTION 3 OPERATIONAL PHASE PROCEDURES (CONTINUED)
- Main Body The main body of the procedure contains the step-by-step instructions in the degree of detail necessary for performing the required function or task.
- Acceptance Criteria The acceptance criteria provide the quantitative or qualitative criteria against which the success or failure (as of a test-type activity) of the step or action would be judged.
- Checklists Complex procedures utilize checklists which may be included as part of the procedure or appended to it.
3.2 Procedure Types Administrative Control Procedures These include administrative procedures, directives, policies, standards, and similar documents that control the programmatic aspects of facility activities. These administrative documents ensure that the requirements of regulatory and license commitments are implemented. Several levels of administrative controls are applied ranging from those affecting the entire Company to those prepared at the implementing group level. These documents establish responsibilities, interfaces, and standard methods (rules of practice) for implementing programs. In addition to the administrative controls described throughout this QAPD, instructions governing the following activities are provided:
- Operating Orders/Procedures Instructions of general and continuing applicability to the conduct of business to the plant staff are provided. Examples where these are applied include, but are not limited to, job turnover and relief, designation of confines of control room, definition of duties of operators and others, transmittal of operating data to management, filing of charts, limitations on access to certain areas and equipment, shipping and receiving instructions.
Provisions are made for periodic review and updating of these documents, where appropriate.
- Special Orders Management instructions, which have short-term applicability and require dissemination, are issued to encompass special operations, housekeeping, data taking, publications and their distribution, plotting process parameters, personnel actions, or other similar matters.
Provisions are made for periodic review, updating, and cancellation of these documents, where appropriate. I . FPL-2 Revision 4.§. Page 79 of 86ApFil 2Q, 2QH!dbJl't' 13 2QH!ApFil 1 2Q19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 81 of 87 FPL Quality Assurance Program Description SECTION 3 OPERATIONAL PHASE PROCEDURES (CONTINUED)
- Plant Security and Visitor Control Procedures or instructions are developed to supplement features and physical barriers designed to control access to the plant and, as appropriate, to vital areas within the plant.
Information concerning specific design features and administrative provisions of the plant security program is confidential and thus accorded limited distribution. The security and visitor control procedures consider, for example, physical provisions, such as: fences and lighting; lock controls for doors, gates and compartments containing sensitive equipment; and provisions for traffic and access control. Administrative provisions, such as: visitor sign-in and sign-out procedures; escorts and badges for visitors; emphasis on inspection, observation and challenging of strangers by operating crews; and a program of pre-employment screening for potential employees are also considered.
- Temporary Procedures Temporary procedures may be used to direct operations during testing, refueling, maintenance, and modifications to provide guidance in unusual situations not within the scope of the normal procedures. These procedures ensure orderly and uniform operations for short periods when the plant, a system, or a component of a system is performing in a manner not covered by existing detailed procedures or has been modified or extended in such a manner that portions of existing procedures do not apply.
Temporary Procedures include designation of the period of time during which they may be used and are subject to the procedure review process as applicable. Engineering Procedures These documents provide instructions for the preparation of engineering documents, engineering analysis, and implementation of engineering programs. This includes activities such as designs; calculations; fabrication, equipment, construction, and installation specifications; drawings; analysis and topical reports; and testing plans or procedures. They include appropriate references to industry codes and standards, design inputs, and technical requirements. Installation Procedures These documents provide instructions for the installation of components generally related to new construction and certain modification activities. They include appropriate reference to industry standards, installation specifications, design drawings, and supplier and technical manuals for the performance of activities. These documents include provisions, such as hold or witness points, for conducting and recording results of required inspections or tests. These documents may include applicable inspection and test instructions subject to the requirements for test and inspection procedures below. FPL-2 Revision 4§. Page 80 of 86/\pril 2Q, 2Q18dt1ly 13, 2Q181',pril 1, 2Q1Q May 28,2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 82 of 87 FPL Quality Assurance Program Description SECTION 3 OPERATIONAL PHASE PROCEDURES (CONTINUED) System Procedures These documents contain instructions for energizing, filling, venting, draining, starting up, shutting down, changing modes of operation, and other instructions appropriate for operations of systems related to the safety of the plant. Actions to correct off-normal conditions are invoked following an operator observation or an annunciator alarm indicating a condition which, if not corrected, could degenerate into a condition requiring action under an emergency procedure. Separate procedures may be developed for correcting off-normal conditions for those events where system complexity may lead to operator uncertainty. Appropriate procedures will also be developed for the fire protection program. Start-up Procedures These documents contain instructions for starting the reactor from cold or hot conditions and establishing power operation. This includes documented determination that prerequisites have been met, including confirmation that necessary instruments are operable and properly set; valves are properly aligned, necessary system procedures, tests and calibrations have been completed; and required approvals have been obtained. Shutdown Procedures These documents contain guidance for operations during controlled shutdown and following reactor trips, including instructions for establishing or maintaining hot shutdown/standby or cold shutdown conditions, as applicable. The major steps involved in shutting down the plant are specified, including instructions for such actions as monitoring and controlling reactivity, load reduction and cooldown rates, sequence for activating or deactivating equipment, requirements for prompt analysis for causes of reactor trips or abnormal conditions requiring unplanned controlled shutdowns, and provisions for decay heat removal. Power Operation and Load Changing Procedures These documents contain instructions for steady-state power operation and load changing. These type documents include, as examples, provisions for use of control rods, chemical shim, coolant flow control, or any other system available for short-term or long-term control of reactivity, making deliberate load changes, responding to unanticipated load changes, and adjusting operating parameters. Process Monitoring Procedures These documents contain instructions for monitoring performance of plant systems to assure that core thermal margins and coolant quality are maintained in acceptable status at all times, that integrity of fission product barriers is maintained, and that engineered safety features and emergency equipment are in a state of readiness to keep the plant in a safe condition if needed. Maximum and minimum limits for process parameters are appropriately identified. Operating procedures address the appropriate nature and frequency of this monitoring. FPL-2 Revision 4.§. Page 81 of 86,1\~ril 2Q, 2Q1 §Jllly 13, 2Q1 §/\aril 1, 2Q19 May 28, 2019 ____J
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 83 of 87 FPL Quality Assurance Program Description SECTION 3 OPERATIONAL PHASE PROCEDURES (CONTINUED) Fuel Handling Procedures These documents contain instructions for core alterations, accountability of fuel and partial or complete refueling operations that include, for example, continuous monitoring of neutron flux throughout core loading, periodic data recording, audible annunciation of abnormal flux increases, and evaluation of core neutron multiplication to verify safety of loading increments. Procedures are also provided for receipt and inspection of new fuel, and for fuel movements in the spent fuel storage areas. Fuel handling procedures include prerequisites to verify the status of systems required for fuel handling and movement; inspection of replacement fuel and control rods; designation of proper tools, proper conditions for spent fuel movement, proper conditions for fuel cask loading and movement; and status of interlocks, reactor trip circuits and mode switches. These procedures provide requirements for refueling, including proper sequence, orientation and seating of fuel and components, rules for minimum operable instrumentation, actions for response to fuel damage, verification of shutdown margin, communications between the control room and the fuel handling station, independent verification of fuel and component locations, criteria for stopping fuel movements, and documentation of final fuel and component serial numbers (or other unique identifiers) and locations. Maintenance Procedures These documents contain instructions in sufficient detail to permit maintenance work to be performed correctly and safely, and include provisions, such as hold or witness points, for conducting and recording results of required inspections or tests. These documents may include applicable inspection or test instructions subject to the requirements for test and inspection procedures below. Appropriate referencing to other procedures, standards, specifications, or supplier manuals is provided. When not provided through other documents, instructions for equipment removal and return to service, and applicable radiation protection measures (such as protective clothing and radiation monitoring) will be included. Additional maintenance procedure requirements are addressed in NQA-1-1994, Subpart 2.18, Section 2.2, Procedures. Radiation Control Procedures These documents contain instructions for implementation of the radiation control program requirements necessary to meet regulatory commitments, including acquisition of data and use of equipment to perform necessary radiation surveys, measurements and evaluations for the assessment and control of radiation hazards. These procedures provide requirements for monitoring both external and internal exposures of employees, utilizing accepted techniques; routine radiation surveys of work areas; effluent and environmental monitoring in the vicinity of the plant; radiation monitoring of maintenance and special work activities, and for maintaining records demonstrating the adequacy of measures taken to control radiation exposures to employees and others. FPL-2 Revision 4§. Page 82 of 86.'\pril 2Q, 2Q1 BJuly 1:J 2Q18Aoril 1 2Q1Q May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 84 of 87 FPL Quality Assurance Program Description SECTION 3 OPERATIONAL PHASE PROCEDURES (CONTINUED) Calibration and Test Procedures These documents contain instructions for periodic calibration and testing of instrumentation and control systems, and for periodic calibration of measuring and test equipment used in activities affecting the quality of these systems. These documents provide for meeting surveillance requirements and for assuring measurement accuracy adequate to keep safety-related parameters within operational and safety limits. Chemical and Radiochemical Control Procedures These documents contain instructions for chemical and radiochemical control activities and include: the nature and frequency of sampling and analyses; instructions for maintaining coolant quality within prescribed limits; and limitations on concentrations of agents that could cause corrosive attack, foul heat transfer surfaces, or become sources of radiation hazards due to activation. These documents also provide for the control, treatment and management of radioactive wastes, and control of radioactive calibration sources. Emergency Operating Procedures These documents contain instructions for response to potential emergencies so that a trained operator will know in advance the expected course of events that will identify an emergency and the immediate actions that are taken in response. Format and content of emergency procedures are based on NUREG and Owner's Group(s) guidance that identify potential emergency conditions and require such procedures to include, as appropriate, a title, symptoms to aid in identification of the nature of the emergency, automatic actions to be expected from protective systems, immediate operator actions for operation of controls or confirmation of automatic actions, and subsequent operator actions to return the reactor to a normal condition or provide for a safe extended shutdown period under abnormal or emergency conditions. Emergency Plan Implementing Procedures These documents contain instructions for activating the Emergency Response Organization and facilities, protective action levels, organizing emergency response actions, establishing necessary communications with local, state and federal agencies, and for periodically testing the procedures, communications and alarm systems to assure they function properly. Format and content of such procedures are such that requirements of each facility's NRC approved Emergency Plan are met. FPL-2 Revision 4.§. Page 83 of 86/\13ril 29, 291§Jllly 1.i, 291§/\aril 1, 2919 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 85 of 87 FPL Quality Assurance Program Description SECTION 3 OPERATIONAL PHASE PROCEDURES (CONTINUED) Test and Inspection Procedures These documents provide the necessary measures to assure quality is achieved and maintained for the nuclear facilities. The instructions for tests and inspections may be included within other procedures, such as installation and maintenance procedures, but will contain the objectives, acceptance criteria, prerequisites for performing the test or inspection, limiting conditions, and appropriate instructions for performing the test or inspection, as applicable. These procedures also specify any special equipment or calibrations required to conduct the test or inspection and provide for appropriate documentation and evaluation by responsible authority to assure test or inspection requirements have been satisfied. Where necessary, hold or witness points are identified within the procedures and require appropriate approval for the work to continue beyond the designated point. These procedures provide for recording the date, identification of those performing the test or inspection, as-found condition, corrective actions performed (if any), and as-left condition, as appropriate for the subject test or inspection. FPL-2 Revision 4~ Page 84 of 86.0.pril 2G, 2Q1§d~ly 1a, 2Q1§/\pril 1 2Q19 May 28, 2019
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 86 of 87 FPL Quality Assurance Program Description SECTION 4 CONTROL OF SYSTEMS AND EQUIPMENT IN THE OPERATIONAL PHASE Permission to release systems and equipment for maintenance or modification is controlled by designated operating personnel and documented. Measures, such as installation of tags or locks and releasing stored energy, are used to ensure personnel and equipment safety. When entry into a closed system is required, FPL has established control measures to prevent entry of extraneous material and to assure that foreign material is removed before the system is reclosed. Administrative procedures require the designated operating personnel to verify that the system or equipment can be released and determine the length of time it may be out of service. In making this determination, attention is given to the potentially degraded degree of protection where one subsystem of a redundant safety system is not available for service. Conditions to be considered in preparing equipment for maintenance include, for example: shutdown margin; method of emergency core cooling; establishment of a path for decay heat removal; temperature and pressure of the system; valves between work and hazardous material; venting, draining and flushing; entry into closed vessels; hazardous atmospheres; handling hazardous materials; and electrical hazards. When systems or equipment are ready to be returned to service, designated operating personnel control placing the items in service and document its functional acceptability. Attention is given to restoration of normal conditions, such as removal of jumpers or signals used in maintenance or testing, or actions such as returning valves, breakers or switches to proper start-up or operating positions from "test" or "manual" positions. Where necessary, the equipment placed into service receives additional surveillance during the run-in period. Independent verifications, where appropriate, are used to ensure that the necessary measures have been implemented correctly. The minimum requirements and standards for using independent verification are established in company documents. FPL-2 Revision 4~ Page 85 of 86At,iril 29, 291 gJlJI¥ 1J, 291 gApril 1 2919 May 28,2019 ______J
Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2019-119 Enclosure 2 Page 87 of 87 FPL Quality Assurance Program Description SECTION 5 PLANT MAINTENANCE FPL establishes controls for the maintenance or modification of items and equipment subject to this QAPD to ensure quality at least equivalent to that specified in original design bases and requirements, such that safety-related structures, systems and components are maintained in a manner that assures their ability to perform their intended safety function(s). Maintenance activities (both corrective and preventive) are scheduled and planned so as not to unnecessarily compromise the safety of the plant. In establishing controls for plant maintenance, FPL commits to compliance with NQA-1-1994, Subpart 2.18, with the following clarifications:
- Where Subpart 2.18 refers to the requirements of ANS-3.2, it shall be interpreted to mean the applicable standards and requirements established within the QAPD
- Section 2.3 requires cleanliness during maintenance to be in accordance with Subpart 2.1. The commitment to Subpart 2.1 is described in the QAPD, Part II, Section 13.2.
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