ML19323G825

QA Program for Facility

ML19323G825
Person / Time
Site:	Marble Hill
Issue date:	05/23/1980
From:	SARGENT & LUNDY, INC.
To:
Shared Package
ML19323G824	List: ML19323G823 ML19323G825
References
NUDOCS 8006090073
Download: ML19323G825 (37)

Text

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~h Al SA3GIMT & LUNDY CUALI""' ASSUPA!]C3 A1.1 oreanization organizational structuring and functional responsibility assignment are based on recognition of quality assurance as an 4--=-disciplinary function with quality-related activities being performed by individuals at all levels.

The authorities and responsibilities of persons implementing quality assurance activities are established, assigned, and documented in formal systems.

A The interfaces and lines of ccamunication between SSL, Public Service Indiana, and other Contractors are shown in Figure 1-4

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Qua ity Assurance organization.

The crganizational structure and functional responsibility assignments are such that:

(1) attainment of quality objectives

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is accomplished by individuals assigned responsibility for 2

specifying quality or performing work to procedures; (2)

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verification of conformance to established quality requirements I

is accomplished.by an individual who is independent of persons or groups responsible for the activity involved; and (3) personnel in key quality assurance functions have direct access to respcnsible management.

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re basic organizational structure of SSL is shown in Figure Al-1.

The Director of Engineering is responsible to the General Manager for all project design work performed by SSL.

The General Manager has overall responsibility for establishing and =aintaining an effective SSL Quality Assurance Program.

The General Manager is responsible for authorizing this Quality Assurance Program and any revisions.

A direct line of administrative control is established from the General Manager through the Director of Engineering to th'e Mechanical, Electrical,'and Structural Department Managers.

A direct line is established from the General Manager to the Head of the Quality Assurance Division.

The Mechanical, Electrical, and structural Departments, and Technical Services and Project Services Divisions provide the engineering services and other assistance to nuclear projects as requested.

These engineering discipline departments are responsible for the overall technical competence of work performed by SSL.

These departments are also respcnsible f or establishing SSL standagd methods and techniques for achieving technical objectives, when appropriate.

The responsibility for implementing S&L quality assurance is assigned to the management group consisting of the Director of Ingineering and the Manager of each engineering department (Mechanical, Electrical, and Structural).

The responsibility for accomplishing a quality design passes from the Mechanical Oepartnent Manager and Project Director through the Project Manager to Cepartment Project Engineers.

The Department Project A1-1 l

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Ingineers are assisted in the design effort by engineers assigned

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o then for the project and by speciali=ed staff divisions that sup ly the necessary expertise to ensure proper application of ceder, standards, government regulations, and current industry practices.

In project matters, the Department Project Engineers repert :c the Project Manager who is responsible for overall co=rdination and scheduling of the project.

The Project Manager repcr:s to the Project Director who represents SSL management on the project.

The respcnsibility and related authority for the organi=ation performing quality assurance functions are delegated to the Head cf the Quality Assurance Division.

The Head of the Quality Assurance Division provides technical Quality Assurance direction.

The Quality Assurance Division is organizationally free and independent of the SSL project organization and is so indicated in Figure Al-1.

2 The Quality Assurance Division is responsible for development of the Quality Assurance Program and for coordinating its

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i=plementation throughout SSL.

The Quality Assurance Division is responsible for monitoring compliance with the program and assessing its effectiveness, and recommending changes and corrective action, when appropriate.

The Quality Assurance Civision includes auditors who review,the performance of Sargent & ' undy project organizations for conformance to the precedures and practices established by the SSL Quality Assurance 1

Prcgram.

This division also includes Quality Assurance C0crdinators.

Figure Al-2 shows the SSL QA Division crgani=ation.

Tne 3SL CA Program provides tnat the Head of the Quality Assurance Division is responsible to the G&neral Manager for formulating end administering the Sargent & Lundy Quality Assurance Program.

He has appropriate and sufficient authority and crganizational freedom to identify quality problems, reconmend cr provide solutions and verify their implementation, and con:rol further prccessing of a nonconforming item, until the prcper disposition of the deficiency or unsatisfactory condition has ' een approved.

The Head of the Quality Assurance Division has the responsibility and authority to stop unsatisfactory work pending resciution of quality matters when in his judgment such action is necessary.

H s duties include:

a.

developing for the General Manager's authorization those SSL basic procedures necessary for i=plementation of this program, b.

reviewing detailed procedures and instructions by c:her responsible departments and divisions for conformance to the Quality Assurance Program and procedure requirements, A1-2

c.

recc=nending to responsible managemenu desirable changes in the Quality Assurance Program, J

d.

reviewing clients' special quality assurance require =ents and inco..porating.hese special requirements, e.

raining and indoctrination of all personnel perfor.ing activities covered by SSL's QA program, and f.

establishing and maintaining a QA records storage and retrieval system.

The Head of the Quality Assurance Division shall have a broad background and working knowledge of power plant design and engineering.

He shall have a familiarity with the operational activities within SSL.

He shall be capable of establishing 1

functional interfaces with both intracompany and intercompany organizations.

He shall have exhibited the managerial capability to achieve goals and objectives consistent with company policies.

He shall be familiar with NRC regulat:ory guides, ANSI standards, NRC general design criteria and regulations, and ASME codes.

Educational require =ents include as a minimum a baccalaureate degree in an engineering or equivalent technical or scientific 411.3

• ecipline.

It is desirable that the person be a Registered

'rofessional Zagineer. - Additionally, he is required to have a minimum of 8 years experience in Quality Assurance, nuclear power and management wi.h a minimum of 2 years in each.

The Quality Assurance cocrdinator is assigned on a project by the Head of the Quality Assurance Division.

He shall be responsible for:

a.

previding consultatica to project personnel relative to quality assurance requirements and procedures, b.

reviewing clienu unique quality assurance requirements, assisting in the implementatica cf quality assurance c.

requirements on a project, d.

appreving project QA procedures and instructions, interfacing with the Qualitf control coordinator on a e.

project, f.

interfacing with client en project quality assurance activi ies, a.d A1-3

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I g.

providing QA requirement input in S&L specifications for technical services provided by censultants.

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The Head, Quality control Division reports to the Director of Engineering.

The Quality Centrol Divisien organization is shown in Figure Al-3.

A Quality Centrol Coordinator is assigned to 411.2 a project by the Head, Quality Centrol Division to coordinate divisional activities en that project.

The division is responsible for reviewing SSL prepared p ccurement documents to ensure the inclusion of appropriate 411.14 quality assurance / quality control requirements.

The division has the added responsibility for providing a project with specialized services in metallurgy, nondestructive examination, materials selection, and welding.

The Head, Quality Control Division is responsible f or review and evaluation of bidder's proposals for conformance to procurement specification quality assurance / quality control requirements.

The Head, Quality control Division may be called upon to identify vendor quality control problems, reccmmend or initiate solutions, and verify their implementation.

In accordance with the requirements of an agreed to scope of activities, the Head, Quality control Division, will be called upcn to provide any or all of the folicwing services:

a.

surveillance of vendors; b.

review of special processes procedures such as nondestructive examinatien, heat treatment, bendi:Ig, welding, cleaning; c.

vendor inspection activities; -

d.

audit vendors for compliance to quality assurance programs; and e.

review vendor documentation.

These services will be done by qualified personnel in accordance with documented procedures and/or checklists.

The Quality Assurance Division will effect centrol over the Quality.Centrol Division's inspection functions of contractors 411.1 qualificaticns and irplementing procedures by reviewing and appreving by signature the Quality Control Division's procedures for Quality Assurance Program conformance and auditing the Quality Centrol Division's implementation of the procedures.

A1-4

Where perniens of engineering design work are delegated to subcentrac:crs, such as scil test borings, geology, cr hyd clogy, require =ents are establishef -hat these subcontrac:crs shall have s

a c.uality ase--= --d. --.-=

confor=in9 to ac. c. licable certions of 10 CFR 50 Appendix 3 and ANS: Standard N45.2.

Their programs and O. rccedures are reviewed bv Sar ent & Lundf for ce=cliance with these require =ents.

Scheduled audits are made by S&L to verify implementa:icn of suhcentrac:crs QA program and precedures and that they =eni:Or cc=pliance with their QA progra=.

A1.2 Quality Assura.ce Prec~am A Quality Assurance Progra= has been established in accordance with the require =ents of 10 CFR 50 Appendix 3, which enec= passes responsi-bilities, effort, equip =ent, procedures, and =anagement necessary to provide the means to =een the S&L quality cbjectives.

The S&L Quality Assurance Progra=, as represented herein complies with Nuclear Regulatery Cc- 'ssien Regulatien 10 CFR 50 Appendix 3,

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Quality Assurance Criteria for Nuclear Power Plants.

S&L is ccm-

=itted to meeting and i=ple=enning these requirements:

Regula: cry Guide 1.28 - Quality. Assurance Program Requirements (Design and Construction).

ANS: N45.2 - Quality Assurance Requirements for Nuclear 411.7 Pcwer Plants.

f Gray 3cck, WASE 1233, Rev. 1 - Guidance en Quality

, Assurance Require =ents During Design and Precurement Phase of Nuclear Pcwer Plants.

NEC Regulatory Gaide 1.64 - Quali:V. Assurance Requirements for Nuclear Power Plants.

ANS: N45.2.11 - Quality Assurance Requirements for the Design of Nuclea Pcwer Plants.

Quality Assurance Ar icles,Section III, Divisions 1.and 2, Nuclear P:wer Plant Cc=penents, Boiler and Pressure Vessel Ccies.

Regulatcry Gtide 1.58 - Qualification of Nuclear Pcwer 411.24 Plant Inspecticn, Examination and Testing Personnel.

The positiens responsible for defining the QA Progra= cen ent and changes there : are:

(1)

General Manag'er and (2) Head, Quality Assurance Division.

The =anage=ent levels responsible for the final review and apprcval of the ^A Program are both the General Manager and the Head, Quality Assurance Civision.

The CA Progra provides precedures for its docu= anted revision.

The precedures which establish the authority and =anner by which the 2-.,...

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deter =ination of the need for revisions, b.

the nethod of proposing the revisions, and c.

the nethod of evaluating and approving revisions.

3 e safety-related structures, syste=s, and components being controlled by S&I.'s QA Progra= are indicated in Table 1-3 in Section 1 in this chapter of the PSAR.

S e Progras and its i=plementing procedures are made available to all 411.6 responsible project personnel through controlled distribution of the Quality Assurance m ual. The Program is controlled by formal docu=ent control systems applied to work for which S&L is responsible. Procedures are established wherein recipients of the manual are required to acknowledge its receipt.

Quality Assurance Procedures, Quality Control Procedures and Departmental 411.23 Standards provide for training and indoctrination of personnel performing inspection, testing,

==4 nation, auditing and/or design functions.

The results of such training and indoctrination are documented, filed and auditable.

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Retraining, including racertification as applicable, will be performed as

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required to naistain proficiency.

The quality-related design and procurement activities initiated prior to sub=ission of the PSAA were:

a.

5555 Specification b.

NSSS Award c.

Meteorological Program Specification d.

Meteorological Program Award e.

Essential Service Water Strainer Specification f.

Sa'fety Category I Shop Fabricated Tank Specification g.

Boring Program Specification h.

3ering Program Award 1.

Soring Program j.

Contain=ent Liner Specification k.

Rainfohcing Steel Specification 1.

Concrete Specification

. General Geotechnical and Eydrologic Investigation n.

1:lti= ate Heat Sink Design o.

All safety-related design criteria p.

? SAP. preparation Al-6

l The S&L QA progra=, SL-3028, and i=ple=enting procedures were in effect for the above sark, except the 555S specification, =eteorological program specification and award, and boring pregram specification and award. These were under the control of a =anage=ent authorized QA Program and procedures in effect at that cine which included standard approved =ethods for audi:s and follow-up.

S&L quality-related activities are documented in procedures, standards, and instructions as well as a QA Program.

S&L policies, goals, and objectives require through its QA Program the application of those quality system elements necessary to the fesign of structures, systems, and components and any additional censulting services previded by S&L to meet the requirements of S&L, Public Service Indiana, and applicable codes, standards, and regulatory agencies.

Such structure, system, and component design and services will be performed in accordance wi:h the ? ogram which satisfies the require =ents of 10 CFR 50, Appendix 3.

The S&L QA Program and implementing procedures specify methods 1

to be used in ce= plying with applicable criteria and are mandatory for all nuclear safety-related work.

See Table Al-1 for a listing of QA and QC procedures that describe the implementation of applicable 10 CFR 50, Appendix B, criteria.

The activities in safety-related work are audited periodically to verify that they have been performed in accordance with the Progra= and associated i

j procedures.

Disputes arising from a difference of opinion between Quality Assurance and personnel of other Departments shall be resolved by the General Manager.

All S&L personnel engaged in safety-related work receive for=al training in the application cf those procedures to their work. The program provides for indoctrination and training of persennel performing activities affecting i

quality as se 'ssary to provide assurance that appropriate proficiency is achieved and =uintained. This training is accomplished in accordance with l

appropriate procedures and lessen plans approved by the Head of the Quality Assurance Divisien.

l The qualification requirements for the position responsible for assuring effective implementation of the QA ? ogram are stated under Ortanizatien.

At least once each year a report is prepared assessing the status, adequacy and effectivity cf the QA Program. This report will be prepared by the Head, QA Division at the direction of the General Manager. The basis for this report is provided by the findings and assessments made during audits. This is supplemented with the findings of a sanagement audit of the QA Division.

Personnel perfor=ing audits have no direct responsibility for the activity which they are reviewing.

As a minimu=, this report addresses the following three major objectives:

l to assess compliance with and effectiveness of the a.

program and its i=plementation, b.

to assess the adequacy and status of implementing procedures, and to assess confer:ance of this program wi:h current l

c.

l regula:1ces and guidelines.

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Appropriate corrective action is taken en the results of this review.

Design Control The design of structures, systems, and ce=ponents is directly controlled l

within the various S&L design organizations. The control processes are docu=ented by procedures and instructions which establish the responsibilities and interf aces of each organizational unit that has an assigned design respon-sibility.

Included are measures to assure the following:

a.

Design criteria, for structures, system and components, identify the applicable design bases, regulatory require-ments, codes and standards. The correctness of the trans-lation of the design criteria into specifications, drawings, procedures and instructions is part of the desigo review performed in accordance with specified QA proceduJes (see Table Al-1).

b.

Appropriate quality requirements and standards are specified and included in design documents by those assigned responsibility for these items.

c.

Deviations from quality requirements and standards sud design changes (including field-initiated design char.ges) are controlled to the same level as was applied to tae original design. The review and approval of such deviations is accomplished by the same groups that performed the original review and approval unless another equivalent responsible design group is designated by S&L management.

A1.3.1 Design of Purchased Eculpment The design documentation for purchased equipment, components, and services nor= ally consists of equipment, component, and services procurement specifications which specify general requirements including materials, processes workmanship, and tests; layout drawings which show the outline and interf ace requirements; and specific data sheets of project infor=ation which define the requirements of the equipment, ecmponent, or services. The project engineer is responsible for the preparation of the design instructions, specifications, and drawings, and assurance that they conform to the requirements of the project data sheets, system design control documents, design criteria, and applicable codes, standards, and regulations. The initial issues of purchase specifications are reviewed by the Contract Division and the Quality Control Division prior to supplier bidding. Changes to those documents are controlled in the same nanner.

The specification outlines the engineering documents (such as drawings, procedures, calculations, qualification data, test data and quality verification documents) which =ust be submitted by the vendor for review and comment.

411.26 Any subsequent changes to the vendor docu=ents are for= ally revieved and their acceptance documented.

"Off the shelf" commercial or previously approved =aterials, parts, and 411.3 equipment that are essential to the safety-related functions of structures, systems and co=ponents are reviewed by the appropriate engineering division for suitability of application. Reviews of these ite=s may include any or all of the following: historical perfor=ance data and records, valid industry standards and specifications, prototype testing prograss and design reviews.

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4 A1.3.2 Stru: cure. System, and Co=ponen Desian

• esign criteria which contain design bases and other data for the specific project are issued to the client and to the responsible casign groups.

Syste: design-controlli=g documents are then prepared by the responsible

roject engineers. The system design-controlling docu=ents provide the basis for detailed structure, system, and component design and typically include the syste: design criteria, piping and instrument diagrams, functional descriptions and control diagrams, instru=ent engineering diagrams, and i

instrument data sheets.

The design effort for plant thermal, stress, radiation and hydraulic 411.1?

analyses; co=patibility of materials; accessibility for inservice inspection,

=aintenance, and repair; and specifyi=g criteria for inspection and tests are carried out by the responsible design organizations and are subjected to tha design reviews and controls in accordance with design and quality assurance procedures den appropriate, acceptance / rejection criteria are included in design documents.

Verification of checking of design activities and design documents is accomplished by performing design reviews, or the use of alternate or simplified calculational methods, or by conducting a suitable test program.

kten a test program is used to verify the adequacy of a design feature, it includes suitable qualification testing of a prototype unit under conditions extending to the =ost adverse design conditions. The extent of tha verification is to be consistant vich the importance of the design activity to plant safety, co=plexity of design, degree of standardization, state of the art and s4-4*arity with previously proven design.

Departmental standards and quality assurance procedures provide guidance 411 9 for pe g design verification. They are performed by qualified personnel independent of the preparer, and the reviewer is not the preparer's i==ediate supetviser except as permitted in Regulatory Guide 1.64 These standards provide for the 'ssignments of review personnel, including personnel frc= interfacing depart =ents, establish the considerations to be used in H

reviewing the systen or structure and define the responsibility and authority of the reviewers, includin6 chair authority to reject design.

k* hen a reviewer's co==ents are satisractorily resolved, the document is signed and becomes a reccrd of design verification and is subject to audit.

The appropriate engineerizig division responsible for the review assures that:

411.25 a.

design characteristics can be controlled, inspected and 411,11 tested, and b.

inspecti:n and test criteria are identified.

411 14 In addition to the design reviews, stated above, made prior to the issue of design documents, an independent design review is made of the engineering work for systers er co=plete structures, after the design documents have been adequate y developed and PSI has had an opportunity to review them for adherence to requirenents. The independent design review covers the project scope-of-work d : =ent, the system design-controlling documents, and the design criteria. The doc==ents are reviewed against requirements of the PSAR and j

any applicable ameninents with the responsible project design engineers providng necessary design information as required for the review. Responsibility to initiate and to follow through on any required changes is assigned to applicable pr:je:: personnel.

Al-9

A1,3,3 Centinuine Desien Evaluation Necessary changes resulting from evaluation cf problems with other plants which are generic and affect quality and which may be applicable to the project are identified, documented, reviewed, and resolved by S&L.

Folicwing the decision to apply a prcject design change originating frcm this actica, the responsible project engineer (s) make the necessary design document changes where applicable, to solve the design problem.

Revisions to the design documents as well as field changes are subjected to review and approval precedures commensurate with these applied to the original design.

A1.3.4 Desien Interfaces The project manager assigned.to the project is responsible fcr the total project coordination wich SSL.

The project engineers are directly responsible for the preparation of the engineering design a.nd the documentation issued for the project.

The interrelationship between the principal design organizations within SSL associated with the project is indicated in Figure Interactions between S&L and outside organi=ations such as PSI 411.14' and Westinghouse, which provide designs, specification, data and/or technical directicn are defined as external interfaces.

The identification of ex'ternal interfaces.is described in documents such as scope of work, procuremer_t specifications, and general quality assurance procedures.

Procedur'es are es ablished for the review, approval, release, 411.9 distribution, and revision of SSL design documents among par.icipating design organizations (see Table Al-1

).

These precedures include provisions for the following:

a.

reviewing documents for accuracy and technical adequacy prior to release;

b. ' approving doc:ments by authorized personnel; distributing documents to th'eir intended points cf c.

use; d.

determining that the correct revision of these documents is being used;

' A1-10

e.

providing ststdard systems for identification of documents and a centrol system to clearly. indicate

_ heir applicability, accountability, and status; s

f.

establishing retention periods for documents and a mechanism for their transmittal to the client, if required; g.

filing of documents in an orderly manner in a ille rocm, or area that provides controlled access ans' prouec-J.on against fire, flood, vermin, and decay; and h.

subjec ing changes to dccuments to the same degree of centrol as the original.

In addition to -Je documents which centrol system design, a series of project procurement and standard specifications establish the requirements for structure and component design which satisfy the system requirements.

These project procurement and standard specifications identify applicable codes, standards, regulacions, and otheir requirements to be utilized to assure ccmpliance with 57.c criteria, quality levels, and specific reg.irements which SSL or the client imposes to meet acceptable gc als.

Subsequen: changes to the documents for che project are subjected to review and approval procedures commensurate with

.hese applied to che orig' al issue.

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Caficiencies and nonconformance in SSL work detected during the design verification process or by other means are centrolled and corrected in accordance with procedures.

The SSL QA Program is supplemented by detailed proceduras covering requirements for distrir

' ion of design documents, drawings, etc.

Later issues of specific docun. ants er drawings follow the same distribution as the original.

Status lists are prepared, distributed, and reviewed per documented procedures to prevent inadvertent use of obsolete documents.

A1.3.5 Control, Collection, and stcrace of Documents The SSL QA Program includes implementing procedures for control, collecticn, storage, and maintenance of documents, and changes thereto in a systematic manner as follows:

a.

Quality Assurance Manual control; b.

control of regulations, guides, codes, and standards; c.

project distribution list and project file index; d.

identification and retention of quality assurance records; e.

storage, handling, and retrieval of QA records; and f.

control of revisicns to design documents.

A1,3,;

Desien Chanca Centrol The design change centrol procedure requires documentaticn of the change, approval by the responsible project engineer, and finally a design verification review.

The responsible project engineer is charged with the responsibility for defining all other design documents affected by the change, and for resolving and coordinating changes with other project engineers whose design is af f ected.

Design changes affecting interface conditions between PSI and the major equipment suppliers are identified, acconplished, reviewed by the Project Manager with PSI, checked,

, and documented in accordance with established procedures (see Table Al-1

).

Design changes identified by field organizations are generally the resul: of unexpected construction or-operating ccnditions.

Tne field organization generates a document which identifies the conditions and may propose a method of correction.

SSL is responsible f or documenting safety-related design changes.

When a proposed design or a method of correcting a design problem does net comply with apprcved design basis documents, it is the res-ponsibility of S&L to provide a solution to the problem in accord with project procedures.

A1-11

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Precure ent Document Centrol Procedures are established and documented to provide assurance that applicable regulatory requirements, design bases, and other requirenents which are necessary to assure adequate quality are included or referenced in the SSL-originated documents for procurenent of equipment, components, and services.

Applicable procedures require that the following information and recuirenents are included in procurement documents, as appropriate:

a.

basic technical requirements - drawings, specifications, codes, and standards, with applicable revision data; test and inspection requirements; and special instructions and requirements, such as for designing, fabricating, cleaning, packaging, handling, shipping, and normal or extended storage in the field; b.

vendor quality assurance program - identification of quality requirements, including ref erence to 10 CFR 50, Appendix B, and ANSI N45.2 to be developed and implemented by the vendor and his subcontractors; c.

documentation _equirements - vendor will prepare and maintain the identification of dccuments and records.

He shall submit, or make available for review and/or ccmment, drawings, specifications, as applicable, procedures, procurement documents, inspection and test records, personnel and procedure qualifications, chemical and physical property test results for materials, and certificates of _ccmpliance; d.

records con *.rol - identification of QA records to be retained, centrolled, maintained or delivered to the construction site prior to use er component installation; e.

scarce surveillance and audit - provisions for access 411.16 to vendor's and his subcontractors' facilities and records for scurce surveillance and/or audit by purchaser or authorized representative; f.

Icwer-tier proc'urements - extension by contractor of applicable requirements to 1ower-tier contractors and venders, including access by purchaser or his designated representative, to facilities, procedures, and records; g.

noncenformances - provisions for the vender to sub=i:

l ncnconformances, discrepancies, deviations or l

conditions adverse to quality, together with his A1-12

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l recommended disposition ("use - as isa, rework or repair) for S&L review and acceptance.

The QA Program requires that design documents, such as drawings, and procurement specifications are to be prepared, reviewed, approved, and issued by the appropriate departments in accordance with specific QA procedures prior to their release for procurement of equipment or services (see Table n-1

).

The procedures provide for appropriate sequencing of steps and for dccumentation of preparation, review, and approval acticns.

These procedures also require that all quality-related references in the procurement document are current, correct, and complete.

The following reviews of procurement specifications are required to be accomplished and documented:

a.

review by the responsible specification preparer for editing, form, standards, and uniformity; b.

review by an engineer (independent of the Specification Division) for accuracy and technical adequacy, for correct translation of design bases and t.pplicable regulatory requirements, and for conformance with the approved design input; c.

review for compatibility by an engineer of each interfacing discipline, if interfaces exist; d.

review by the assigned Quality control coordinator for inclusion of appropriate quality requirements for vendors to have and implement a documented QA Program for purchased materials, equipment and services;

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e.

review by PSI; f.

review by the appropriate design and drafting divisions, as required; and g.

review by the assigned Quality Assurance coordinator of the procurement documents for services of consultants retained by S&L for inclusien of l

appropriate QA Program requirements.

l Af ter initial approval of procurement documents, all quality-related changes are subject to the same level of control as utilized in the preparation of the original documents.

The vendor is evaluated prior to purchase order award, to assure that the vendor can meet both technical and quality assurance requirenents of the procurement specification, in accordance with specific QA procedures (see Table Al-1

).

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A1-13

If spare er replacement parts are purchased, such purchase will be based on either an existing approved specification or a new specification, prepared, reviewed, and approved in accordance with CA precedures.

n.5 Instructions, Procedures, and 0;awines As referenced in A1.3 activities affecting quality are prescribed by documented policies, procedures, instructions, drawings, or specifications of a type appropriate to the circumstances.

The activities are prescribed in such documents as effice procedures, project instructions, design criteria, and drawings.

Specific responsibiltiy for.the preparation, review, approval, release, applications, and maintenance of these dccuments is assigned to the appropriate Department Manager or Project Director.

The documents include appropriate quantitative or qualitative criteria for determining that important activities have been satisfactorily accomplished.

Where necessary for quality, design instructions, procedures, and drawings will indicate the required sequential order of a ctivities.

Quantitative criteria, such as standard practices fcr dimensicning, identifica:icn and selection of tolerances, and qualitative criteria, such as comparative workmanship samples and visual standards, are specified in the appropriate documents as criteria for determining quality compliance.

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Applicable govern =ent and industry standards developed by NRC, ASTM, ASMI, ANSI, and IEEE and other recognized criteria, will be specified where applicable.

These codes, standards, etc.,

inecrpcrate both qualitative and quantitative acceptance criteria and will be thoroughly identified and referenced in design criteria, analyses, specifications, and other engineering dccu=ents.

4 A1.6 Document control Procedures and cractices are established and documented to centrol the issuance of design documents, instructions, l

preceferes, and drawings, including changes thereto, which prescribe activities affecting quality (see Table Al-1

).

Quality Assurance Program and implementing procedures include measures which prcvide assurance that documents, including changes, are reviewed for adequacy and approved for release by authcrized personnel and are distributed'to and used at the 1cca:icn where the prescribed activity is performed.

The groups and/-

4-M viduals responsible for these activities are identified.

A1-14

l A1.6.1 De.:: ent centrol Measures dnese participating in an activity are made aware of and use proper and current instructions, procedures, drawines, specifications, and engineering requirements for performing the activity.

Participating organizations have documented procedures for control cf these documents and changes thereto, to preclude the possibility of use of outdated or inappropriate documents.

Master lists are distributed on a monthly basis so that recipients can verify that they are working with current issue of drawings and specifications.

Master lists of other activities i

will be provided on a timely basis.

Documen control measures provide for:

a.

reviewing documents and their revisions for adequacy prior to their release by authorized personnel; b.

identifying individuals or organizations and their i

authority who are responsible for preparing, reviewing, approving, and issuing documents and revisions thereto; c.

identifying and maintaining current the proper documents and their status, e.g.,

"prelinina.f,"

approved for construction," " approved for procure-a ment," etc., as appropriate; d.

coordinating and controlling interface documents; e.

assuring availability of documents at the onset of work for which they are needed; f.

establishing current and updated document distribution lists; and j

i g.

cbsoleting, recalling, or in some manner identifying documents not intended for current use.

i A1.6.2 Occume;3_Eevision Control Changes to documents are reviewed and approved with a degree of control commensurate with the original document, by the same organizations that performed the original review and approval unless other qualified organizations are specifically designated by SCL management.

Reviewers have access to pertinent background nfermaticn upon which to ' case the review, and have been determined by SCL management to have an adequate understanding of the requirements and intent of the original document.

SCL OA Prcgra= and implementing procedures require that approved changes be reviewed for applicability to related instructions, precedures, drawines, and other appropriate docunents, and that s

those affected documents be changed through controls consistent A1-15

with the original issue.

In addition, all approved changes are required Oc be docu=ented and traceable as well as inplemented by s

all crganizations ir.vcived.

K1.6.3 Centrcl Inclenentine ;ccuments Policies, precedures, instructions manuals, and other planning documents, as a minimum, are included in controls applied to the SSL system documentation.

The key quality-related document types and the group responsible for review, approval and issuance of dccuments and changes thereto, are as follows:

Quality Assurance a.

quality assurance records and instructions b.

quality assurance dccument centrol procedures c.

design review and centrol quality assurance procedures d.

design document control quality assurance precedures e.

design records control quality assurance procedures f.

design change centrol quality assurance procedures 7

g.

safety classification and identification quality assurance procedures for structures, systems, and ccmponents h.

design audit and corrective. action procedures i.

vender evaluatien and qualification quality assurance precedures j.

outside censultant evaluation and qualification procedur es.

Cuali-v centrol 1

a.

procedures for vendor surveillance i

b.

procedures for vendor quality documents control l

c.

procedures for pre-award and post awtIa addits of vendors i

d.

procedures for review of vendor test and inspection documentation e.

procedures for training of auditors

~

I A1-16

f.

precedures for pcs:-award evaluation of vendor's quality control procedures g.

procedures for certification of NDS personnel h.

precad"-ae for review of vendor's quality assurance precram 1.

procedures for evaluation of bidder's proposals.

_E_neine eri ne a.

safety classification b.

design calculations c.

design criteria 6.

design drawings e.

procurement specifications and documents f.

status reports g.

standard design documents

(

Suelear safecutrds and Licensine a.

PSAR b.

FSAR c.

shielding calculations.

11.7 gen rel of Pu chased Material, Eculement, and _Ser._ rices The SSL CA Prceram and implementing procedures specify measures to assure that pur=hased items and services are clearly and adequately specified in procurement specifications and are supplied by venders and outside consultants who are capable of prcducing items and services, whether purchased directly or throuch subcon : actors, which conform to the procurement document r equirements.

These procedures include provisiens for vendor evaluation and selection, review of procurement requirements, and surveillance of the vendor's facility.

A;.7 ;

Evaluation _ and Selection of Prostective Bidders Ivaluatica and recommendation of precurement sources are performed by SSL engineering, contract, quality control and qual y assurance person'nel.

~

A1-17 1

I The evaluaticns ccver review of capabilities and facilities fcr technical, v.anufacturing, financial, and quality performance, and

_..-_._.a_e...____.-.._..c.,

a s a,_ y _- _ e-

_' _= _ a_.

<_w s

a.

historical perferrance data, especially in product quality and delivery; b.

review and cc==ent en vendor / consultant quality assurance manual; c.

source serveys and/or audits, to verify vendor /censultant imple=entation of his quality assurance program; and d.

source qualification programs.

The quality assurance system cf eotential vendors and consultants is investigated := determine ecmpliance with the applicable criteria of 10CFR 50, Appendix B and ANSI N45.2.

This investigation is accomplished prior to or subsequent to the solicitation of bids.

Ecwever, it must be accomplished prior to an award by S&L or submittal of the recccmendation letter to PSI, as applicable.

Proposals from bidders are reviewed bv. S&L in accordance with approved QA procedures.

The evaluation of prcposals includes review for ability of the bidder to meet QA Prcyram requirements in precurement specifications.

The preposal evaluaticn is sent to PSI for their use in award of purchase crder.

An audi: may be reco== ended by S&L to PSI to be performed prior to award of purchase order to evaluate current implementation of the vender QA program.

Preaward =eetings with vendors to resclve any questiens are held pricr to any recc==endation for purchase.

t

~

Fcr curside technical service consultants, acceptable bidders are placed en the General Bidders List after evaluation as described above.

Bidders may be selected on the basis of specific service required or after propcsal evaluations.

After purchase crder award by S&L, an audit of the cutside consultant is performed for

_.. _ e...e.n.. a._ _acn.

un,_____,.

e.

AL.. 2 Surveillance of Vendors Succlyina Materials and Ecuic=ent The S&L Quality Ccatrol Divisicn shall perform surveillance /audi s in the facilities ef.. the contracter, subcontractor, vendor, and supplier engaged in fabricating and furnishing materials, parts, or cc=penents for the project when requested by PSI.

The surveillances/ audits are performed by qualified personnel in accordance with documented precedures.

Measures are established c ascertain that procurement sy __ _' _' _' _ _= __' -. _e

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e_

. _ _ _ ~.. _ _

n_._I$

i s

a.

detailed quali:y centrol precedures for the' work for velding, heat treat =ent, radiography, magnetic particle testing, e:.;

b.

special precess precedures; c.

re:::: ended cus:c=er inspection poin: program; C.

d.

appropriate dccu=entation as required by applicable codes, standards, and regulating criteria; e.

radiographic fi1= and report; f.

no: ices of ncnconformances and deviations; and j

~

g.

applicable procedures, codes, and standards for tests.

Surveillance when performed by S&L will include such activities as preparatien of inspection point programs, vendor procedure

+::

review, surveillance of in-process manufacturing and testing activities, and an inspection prior to release for shipment.

These measures are established ec evaluate the effectiveness of centrol of quality by venders.

When surveillances of venders other than NSSS supplier are perfor=ed by S&L, they will be centrolled by the inspection point regrams apprc7ed by PSI.

I e

e b

i Al *9

t A1.7.3 Documentation Occumentation to be submitted by vendors is specified in the pro-curement specification.

The following measures are conducted by S&L perscnnel, when requested by PSI:

~~

a.

review of vendor documentation during in-process, testing and final inspection stages; b.

review of the documentation which is to be shipped to the construction site.

This documentation con-sists of items such as:

material test reports, 4

inspection and test reports, raciographs, and applicable code data reports.

A1.7.4 Inscection Point Procram for Vendors Supplving Materials and Eculpment The frequency and extent of the surveillanees are censistent with the i=portance to safety, complexity, and quantity of the item er service being furnished.

The measures to evaluate the effective-ness of the control of vendor quality are described in A1.7.2.

The surveillances when performed will be in accordance with an inspecticn point program, prepared by the vendor and approved by PSI.

The Inspection Point Programs include manufacturing and test-ing activities to be witnessed, Quality Assurance / Quality Control activities to be confirmed by surveillance, and the review of the required documentation.

w b

d."4w e

+--

AL.8 Identification and Centrol of Materials. Parts, and Cenecnents S&L dces nc have any direct activities which require a quality assurance program for identification and control of materials, parts, and cc=penents.

Requirements are established in precurement specifications for a system of identification and centrol of =aterials, parts, and components so that where required, traceability frc= precurement, thrcugh installation, to end use, is assured and the use of incorrect or defective items is avoided.

The identification and centrol of materials, parts, and cc=ponents is primarily the function of the various fabricators and the constructor.

S&L perfor=s audits and surveillance when requested by PSI of these activities in the facilities of other contracecrs, sub-contracters, venders, and suppliers engaged in the project.

These audits and surveillances are by qualified,,=rsennel.

Their work is assigned, performed, reported, and reviewed in accordance with documented procedures.

Surveillance during manufacturing will provide a detailed m

cbservatien of the identification program administered by each vendor.

The effectiveness of the written procedures in maintaining identification control will be assigned by the audit function.

~

9 Centrol of Scecial Processes S&L d es nc: have any direct activities which rec.uire a c.uality assurance pregram for control of special processes.

Control of special precesses is the function of the various fabricaters and the constructor.

However, S&L provides surveillance when requested by PSI of special processes in the facilities of cen-

acters, subcontractors, venders, and suppliers engaged in f abricating and furnishing equipment and systems for the project.

These are by qualified S&L personnel.

Their work is assigned, perfor=ed, reported, and reviewed in accordance with documented procedures.

Require =ents are established in procurement specifications tc assure that special processes such as welding, heat treating, cleaning, and nondestructive examination are performed under adequate c---- 's and that precedures governing these processes are estar _is.w.ed in accorcance wi,h applicable ccdes and i

specifica:icns.

Surveillances per=i: di-rect cbservation of i

special prccesses, thereby checkinw adherence to the vender p ccedures.

Included during these surveillances will be 1

verifica:icn of the qualifications of personnel performing special precesses.

Records cf procedure, personnel, and equipment qualifica: ion required :: be maintained will be reviewed fer suitable methods fcr s: crape and retrievability.

Reccrds of special processes perferred in ec pliance with app cved precedures and with l

Al-21 L

= -.

qua ifief perscnnel will be reviewed for maintenance of suitable

~

me:heds fcr s:Orage and retrievability.

c.10 Ins 7ecticn Sa' does not have any direct activities which require a quality

r ;snce prcgram for inspection.

Ecwever, S&L will provide, wher

.equested by PS2, scheduled surveillance of inspection activities in the facilities of contractors, subcontractors, venders, and suppliers engaged in fabricating and furnishing systems and equip =ent for the project, as set forth in Section

=

n addition, S&L, when requested, will conduct scheduled audits of Westinghouse and their subcontractors and of suppliers of Er balance of plant safety-related equipment.

These audits will verify the application of approved procedures for inspections and acceptability of the equipment.

7

~

Surveillances and audits on inspection functions will be reported to PSI for review and for verification that hold points

[

identifiac by the inspection point program have been-witnessed.

A1.11 Test Centrol S&L dces not have any direct activities which require a quality

(

assurance progrs= for control of tests.

Pre-operational test cen:rol is the responsibility of the varicus vendors and the ccnstructor.

Start-up test control is the responsibility of the r

Owner.

However, as the designer of many of the systems in the sta icn, S&L dces identify and specify test requirements for certain systems and ccmponents.

S&L's QA procedures for the prepara:icn, review, and approval of procurement specifications prevides fer the inclusion of acceptance limits in the written es: precedures submitted by vendors.

S&L reviews the test precedures previded by vendors to assure that requirements and acceptance limits specified in S&L's design documents have been incorporated.

S&L provides technical input and review for test precedures written by Public Service Indiana.

S&L previdas surveillance when requested by PS: of testing by centracecrs, suncentractors, vendors, and suppliers who fabrica:e and furnish equipment and systems for the project.

Surveillances are by qualified S&L personnel.

Werk is assigned, performed, reper:ed, and reviewed in accordance with documented procedures.

Surveillance by SLL cn vender tests incl $ des verification of' cc=pliance te precedural requirements including the generaticn of the required dccu=entation.

Checks are made of cc=pletion of i

pre-requisite ccnditions, such as test conditions, tes' equipmen:, calibra icn sestus and data accumulation.

j l

)

Tes: accuracy and ce=pleteness will be reviewed by cbservatien of selec:sf tes perfcrmance by Public Service Indiana and S&L.

Al-22

i 1

1 l

Results Of tests will be evaluated by S&L to confirm the vender's acceptability of the tests.

AL.12 Centrol of Measurine and Test Equi = ment S&L dces nce hate any direct activities which require a quality assurance program for identification and centro.1 cf measuring and tes: equipment.

Control of measuring and test equipment is the i

responsibility of the organizations performing inspection and tests.

Ecwever, S&L provides for surveillance, when requested by PSI, of activities in the facilities of other contractors, subcontractors, vendors, and suppliers engaged in fabricating and furnishing materials, parts, and components for the project.

Surveillances are by qualified personnel.

Their work is assigned, performed, reported, and reviewed in accordance with documented procedures.

Surveillance activity includes checks to assure that inspecticn 411.17 cperaticas will be performed with appropriate measuring and tes equipment, currently adjusted and calibrated against nationally recognized standards.

Where no national standards for equipment calibration exist, the documentation for the basis of the calibra:icns will be audited.

Requirements are established in procurement specifications for centrcl of measuring and test equipment.

S&L reviews vendors tr0cedures and centrol of measuring and test ecuipment to insure 411 17 requirements specified in S&L specifications have been incorpcrated.

Kl.13 Handling, Storace, and Shippine S&L does net have any direct activities which require a quality assurance program for handling, storage, and shipping.

Handling, storage, and shipping is the responsibility of the varicus venders and storage at the site is the responsibility of the constructor as regards storage.

Ecwever, S&L prevides when requested by PSI surveillance of these activities for PSI in the facilities of centractors, subcontractors, vendors, and suppliers engaged in fabricating and furnishing materials, parts, and ccmponents for the project.

Surveillances are by qualified persennel.

Werk is assigned, performed, reported, and reviewed in accorfance with documented procedures.

During vender surveillance and final acceptance inspection at

=anufac: ring plants, handling, stcrage and shipping practices will be meni:Ored for conformance with approved precedures.

Shipments will not be released until satisfactory preparation has been cenpleted.

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Ecwever, S&. will provide surveillance when requested by PSI to determine tha: the MSSS supplier and other venders have implenanted their quality assurance program for identification and test.

Surveillances are performed by qualified personnel.

Werk is assigned, cerformed, reecrted and reviewed in accordance a.

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. A1.15 Ncncenfc =ine Materials, Parts, or cc=renents

[

S&. dcas no have any direct activities which require a quality assurance p cgran for noncenfo =ing materials, parts, or cc=ponents.

This item is the responsibility of fabricators, 5

canufacturers, vendors, and the constructor.

"cwever, require =enus are established in crocurenent

~

I specifica:icns that vendors shall furnish documentation of anv.

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. ye ew vendo.- e-cc ar..s '

ca.* ol o' ncncenfc = ing ra erials, parts or ccmponents at vendor facilities during surveil".ances, audits, when requested by 752.

y Sargent & Lundy reviews documented instances of nonconforming parts and cc penents where such nonconfo=ance affects the d e s i e.n, and prevides PSI with a written evaluation cf such e f f e cts.

Sargent & Lundy reccmmends resolutiens of

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y Sargen undy reviews, and makes recccmendations to PSI, for acceptance cf ncnce for=ances, discrepanc<es, cevtat<ons or cc.di:icns adverse te quality, requiric2g a "use-as-is" or a

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The S&L 3...anual includes i=plementing procedures for

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werk.

aisc prevides a means for taking action to preclude 4 _: 1 _, *. ~. c.n. d.' d o n s adv.e.-s e.

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.._.._ ' =.. a = _ -. '.. '. =..v. e..". a.. _' ~ _= _', '.'.' e c *...4 r. a l, a..d.:._-".c... =.1 Cepar ne..:s re".iew records of deficiencies and nonconfermances in

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o...s_4ae set,._ ces a,.e.

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a.a.....,e_.'ences a. cre _ _=. _'...,' a n t s.

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4

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ensure that design improvements based on operating erperience may be inccrporated into SSL's work.

The cbjective of such reviews is to identify quality problems of a generic nature.

Action is taken, as appropria *, to correct identified deficiencies and noncenformances and to preclude repetition.

The QA Program assigns to the Project Manager the responsibility for correcting and controlling deficiencies and noncenformances in SCL work that are detected in audits, in the design verifi ation process, or by other means.

The Project Manager eriorms this duty in accordance with specific procedures.

r The specific procedure for identifying and correcting deficiencies and nonconformances requires anyone who detects a deficiency or nonconformance to file a corrective Action Repcrt.

The procedure defines the means for review of this report by appropriate levels of management, and assigns responsibilities for the varicus actions to be taken once the report has been

=

filed.

4

=

l If the deficiency er nonconformance is determined to be a significant condition adverse to quality, the appropriate repartment Manager identifies tne cause and takes appropriate correceive action to preclude its repetition.

When found by SCL, 1

f. -

significant safety-related design nonconformances which meet the j.

ri eria of 10CFR50.55 (e) are reported to PSI without delay.

ne Head, Quality Assurance Division, monitors repcrts of deficiencies and nonconformances and classifies them, in order to help the Department Managers determine where and what kind of corrective actions may be needed.

He reports the occurrence of si nificant conditions adverse to quality ec. the appropriate Cepartmen: Mana=ers, and the General Manager.

The Project Engineer is responsible for verifying that any reper:ed deficiency or nonconformance has been corrected.

Effectiveness of the corrective action is verified by follow-up audits.

A1.17

- Quality Assusce _Pecds

.u.17.1 Fecords Maintenange F.equireme'nts are established in the QualiOy Assurance Program and implenenting procedures for generation, collection, compilation, storace, and retrieval of documentation necessary to provide i

records of quality in the design activities and initiation of procurement related to the Marble Hill Nuclear Generating Station.

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M A1-25

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guides, standards, PSAR, etc.); and the project design documents t... : 2 2...

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standard specifications).

The records are provided with a number and sufficien: infor=ation to permit identification of the reccrd with the item (s) or activi y te which it applies.

A1.17.2 Retrievabilibv Procedures require that sufficient records be prepared as work is perfor=ed to provide assurance of the quality of the activities erformed, and that such records be consistent with acclicable V

coces, stancarc.s an s=.ec : cations.

.. e ua itv. recor,s are to o

be identified and filed in a timely and orderly manner to allow for access and ra rievability, and they also are to be usable and are to be carefully handled to maintain usability and preserve the original quality of the records to the maximum extent.

A1.17.3 Storace Facilities Requirements are also included for transmittal, retention, and maintenance Of records upon ccmpletion of S&L work on the cro"ect, and for provision of crecer erotective s:crage for all 1.

qua

y assurance recercs.

Recerc.s are storec at

& u.

in a

.cncrete bicek facility that provides controlled access and proteculen against fire, ficed, condensation, vernin and decav..

^"-'--c A1.18 A ccepren.ensive system or p.lannec and per. ocic auc1:s of an:-----

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-an safety-related items is utilized by S&L to verify all aspects of the S&L Quality Assurance Program and assess its effectiveness.

Organi=atiens subject to audit directly by S&L include the

.#c ' ' wi..:.

1 a.

S&L predJect grcups and divisions.

1 b.

Technical services censultants performing activities a::ectin c.ua la.t v.

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n addi:icn :

the abcve internal audits., S&L will perform when

-., auc..1:s en vencers as :cl.,cws:

rec.cestef hv.

a.

Westinghcuse crganizations, groups or individuals a,.nc,uc ng suppcrt divisions), as we.3.

as se.,ected

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555 Succlier and Subcentracecrs r. 8.

i; Westinghcuse and its subcontracecrs will be audited by S&L when

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quality assurance manuals, to provide.an evaluation of the effectiveness of their QA Procram.

This will be cer an 1

esta=: snec senecule durine varicus stages of c.esien,

-..c a

1ca.,.-..cn.

The audi:ine will include evaluation of work areas, activities, precesses a.I.d ite=s in process as well as review of documents and recerfs.

PS

's CA personnel may acccmpany the S&L audit team whenever practical to assist in the audits.

_rcr=al audi: reports will be prepared by S&L and will be trans=itted to PSI for follow up.

Audit responses will be closed cu: to the satisfaction of PSI.

AL.18.2 Vendcrs t.

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cender=ance to their procurement document recuirements and for cc pliance with their quality assurance manuals and manufacturing pr:cedures, af:er award of contract and during fabrication, as requested by PSI.

In addition, vendor's records will be audited

_cr ::=pliance with procurement documents, applicable codes and cre"ect requirements, during in-process surveillance and prior to

,c._.e s...-..e....

... e

__._,-._ _ _ 3._. 2 _:_. =_ _ _-. s w.d.'.' b e __ - =_ c, a _ e d. bv. S&L.

""e aud.'* _ecer.s will be transmitted to the vendors responsible management by S&L fer resclu ien.

Audit responses will be closed out to the satisfactic-Of S&L and PSI.

.u.13.3 5 L and Technical Services Consultants

_3annec. anc periccic aucits witn.4n S&u. anc or outssce tecynica_3 r_

servi:es censultants are carried out by the Quality Assurance Civisien as recuired by the Cuality Assurance Manual.

The

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c verify that the policies, precedures, and instructions necessarv. for implementation of the QA Pr:gri: are established in a.-timely manner; I

b.

te determine the degree of compliance with the

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a_ _. - _...._ _,., a,$

r te Essess the effectiveness of the program and its

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The QA Program requires that each element of the Quality Assurance Program be audited at least once a year on each project, in accordance with an audit schedule, based on activities performed.

The required audits cover evaluation of written quality system procedures and practices, and the effectiveness of their implementation, by monitoring work areas and activities and by review of pertinent documents and their handling.

Audit reports are reviewed and approved by the Head, QA Divisian, and distributed to the persons directly responsible for the areas or functions audited; the Division Heads respcnsible for those areas or functions audited; the Managers of the Mechanical, Electrical, and Structural Departments; the Project Director; the Project Manager; the Director of Engineering; and the General Manager.

A divisional report, prepared once a year, assesses the status, adequacy, quality trends and effectivity of th:e Quality Program, as described in A1.2.

~4ritten procedures are provided for audit planning, execution, evaluation of results, and reporting.

The audit plan is in the form of a checklist, and indicates the audit scope, the elements to be audited, the applicable documents and requirements, and the q..; -

-'diting team.

The audit plan is reviewed and approved prior to its use.

It may be altered during an audit, if necessary to achieve the audit's objectives.

Such changes must be documented and beccme part of the audit record.

Audits are conducted by S&L perscnnel who have no direct responsibility in the areas they audit.

Auditors are required to possess the educational and experience qualifications for auditing which are specified in the procedures for auditor qualification.

A written report is required for each audit.

The report includes, as a minimum:

a.

a statement of the audit scope;

~

b.

identification of the auditors and audi team leader; c.

identification of persons and/or areas audited; d.

details of nonconfermances, including identification of the individual (s) responsible for the area or function where each nonconformance was noted; e.

reques: to respcnsible personnel for response on corrective action within a stated peried; A1-28

f.

a.. evaluation statement regarding the effectiveness i

cf the pregram elements that were audited if apprcpriate; and g.

reccmmendations for improvement of the pregram if apprcpriate.

Folicwup, inclufing reaudits, of deficient areas and nonconformances is required in accordance with written instructions.

Nonconforming areas are reaudited as necessary to assure that effective ccrrective action has been taken by the responsible management.

3 f r.

M l

(

A1-29 l

l

l TABLE Al-1 S&L CA PROGRAM PROCEDURES WHICH DESCRIBE 7'*C' ?'drNTATION OF 10 CFR 50, APPENDIX 3, C RITERI_ A__

PROCEDURE CRITERIA GC-NUM3ER TITLE COVERED 1.1 Identification of Safety Related Items III 3.1 Preparation, Approval and Authori=ation II, V of the S&L QA Manual (SL-3028.XX) and Revisions, Additions and Deletions Thereto 3.2 3.3 Preparation, Review and Approval of I

Position Descriptions 3.4 Training and Indoctrination of I

Management Personnel 3.5 Instruction for Non-Management Personnel I

3.6 Identification, Review and Approval of I

S&L Orga. ization Structure 3.7 Preparation and Maintenance of a Project I

Organizational Structure 3.8 Praparation, and Approval of the I,

III Project Scope of Work 3.9 Review of Client QA Program Requirements II, III 3.10 Preparation, Review and Approval of III, V Projec: Instructions 3.12 Preparation and Review of Employee I,

II Ixperience Records 4.1 Preparation, Review and Approv.al of III, IV, Procurement Specifications VII, XVII 4.2 Preparation, Review and Approval of S&L

III, V, VI Drawings and Revisions Thereto 4.3 Preparation, Review and Approval of III Design Calculations t

Al-30

TABLE Al-1 (Cont'd)

PROCEDURE CRITERIA G C '.".'. .3 ER TITLE COVERED 4.4 Preparation, Review and Approval of III, VI Design Reports 4.5 Preparation, Review and Approval of III, VI Standard Design Documents 4.6 4.7 Preparatien of Safety Analysis Reports I thru (PSAR and FSAR)

XVIII-4.8 Review of Foreign Design Documents III, IV, VII 4.9 Preparation and Maintenance of Project III Status Reports 4.10 Preparation, Review, and Approval of III Design Criteria 4.11 Preparation of Corrective Action Reports XVI, XVII for Design Activities 4.12 Nuclear Feedback III 4.13 Independent Design Review III 4.14 4.15 Issuing and Withdrawing a Stbp Work Order XVI 5.1 Qualification of Vendors for General IV, VII Bidders Lists 5.2 Bid Evaluation and Reconmendation IV, VII 5.3 Post Award Evaluation of Vendor's

VII, Quality Documents XVIII 6.1 Distribution and Control of the S&L QA II, VI Manual (SL-3028.XX) and Revisions, Additions and Deletions Thereto 6.2 Al-ll

TABLE Al-1 (Cont'd)

PRIIIICT!*

CRITERIA

~ ~-:!":GIR TITLE COVERED 6.3 Control of Regulations, Guides, Codes and III, VI Standards 6.4 Project Distribution List and Project III, VI File Index s,3 6.6 Identification and Retention of QA XVII Safety-Related Records 6.7 Storage, Handling and Retrieval of XVII Quality Assurance Records

=.. _

6.8 Control of Revisions to Design Documents III, VI r-s,9 7.1 Internal Audit Planning, Perfor: nance XVIII and Reporting a

7.2 Auditor Qualification Training XVIII 7.3 Audits by S&L Management, of the XVIII Guality Assurance Division PR CI";URI CRITERIA

"., IP-:!'CGIR TITLE COVERED 2.3 Training Program for Audit Personnel XII, XVIII 7.1 Int.rnal Procedure for Document Control VI 3.2 Preaward Audits of Vendors VII, XVIII 3.3 Pcst-award Audits of Vendors VII, XVIII 1

5.4 Review of Vendor Test and Inspection VII, X

ocumen:

12.1 Post-Award Evaluation of Vendor's VII, X Ouality Control Procedures Al-32

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PUBLIC SERVICE

=*

INDIANA S. W. Shielos Vice Prendent - EW Symsn April 28, 1980 Mr. Harold R. Denton, Director Docket Nos.:

STN 50-546 Office of Nuclear Reactor Regulation STN 50-547

~Z U. S. Nuclear Regulatory Commission Construction Permit Nos.:

i Washington, D. C.

20555 CPPR-170 CPPR-171

.=

Marble Hill Nuclear Generating Station Units 1 and 2

Dear Mr. Denton:

As requested by Mr. L. S. Rubinstein in his letter of April 1,1980 Public Service Company of Indiana, Inc. (PSI) hereby subnits twenty (20) copies of the consolidated description of the Marble Hill Quality Assurance Progran. Responses to your requests for additional

=

infor=ation are incorporated in this description. Provided in the margin of this report are sidebar markings, identifying revised portions of the Quality Assurance Program. A single sidebar in the j

right hand =argin indicates the test opposite is a change from the Quality Assurance Program description provided in Chapter 17 of the Marble THil ?SAR. A double sidebar in the right hand =argin denotes new material addressed in the February 28, 1980 report, the March 6, 1980 letter to you, or responses to requests for additional information.

=

This consolidated report supercedes all other Quality Assurance Program descriptions and *.-ill serve as the PSI description of the Marble Hill Construction Quality Assurance Program.

=

If you have any questions, please feel free to contact =e.

S

erely, G

/

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du

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S. W. Shields TDC/cg cc:

V. Stallo a

J. G. Keppler E. R. Schweibinz, P. E; 8MD3 J. J. Earrisen 1000 East Main S reet. P!ainfield, Indiana 46168 317. 839.9611

=

d ECW TO USE TEE " DESCRIPTION" 0F THE PSI MARBLE HILL PROJECT CUALITY ASSURANCE PROGRAM This document co= bines cot:=1t=ents made, relative to Quality Assurance, !.n the Marble Hill Project Prelimbry Safety Analysis Report; PSI's response to the NRC Confir=ing Order of August 15, 1979; the March 6, 1980, PSI g

letter to Mr. Denton of'the NRC, relative to Quality Assurance; responses to 22 specific questions raised by the NRC in March,1980, relative to the letter to Mr. Denton; and 15 additional questions raised by the NRC in April, ig 1980.

PSI has intended to address each NRC request in this combined connit=ents document.

Portions of the Quality Assurance Program Description which

=

were revised frem the PSAR are indicated with a single vertical change bar in the margin. Additions of new material requested by the NRC are

{

indicated with double vertical change bars.

Because some of the =aterial which was requested to be included would have been redundant if included exactly as submitted in the Confir=ing Crder

~~

response, this material was reworded, relocated, or combined with =aterial fren the PSAR to provide better structure and' clarity.

i ma a -.'

DUPLICATE DOCUMENT Entire document previously entered into system under:

hO

[

ANO o

No. of pages: _

[jN The SASSAFRAS AUDUBON SOCIETY T

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6. );

of LAWRENCE - GREENE - MONROE - BROWN -

I b! 4 MORGAN & OWEN COUNTIES 3

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INDIANA

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April 7,1980 L

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ws Mr. Victor Stello, Jr.

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Dimetor, office of Inspection and En'orcement y6 h U.S. Nuclear Regulatory Cn-insion Washington, D.C. 20555 h

M

Dear Mr. Stello:

Sassafras indubon received notice tod.ay of the forthec=i=g meeti=g of the NRC with PSI, April 11, lo80 in Bethesda, Maryland, on PSI's Revised Quality Assurance Progran for Marble F417 -

Teu a:e =st listed as a participa=t in the meeting, but si=ce you chaired the meeting at Madison, Tn#4ana on this subject, and will be involved d.n the reco=sendation to the C.

1. =si:ners as to vbether safety-related construction should resume at Marble

"#'7, we th ug=t it best to add:ess our co= timing concerns to you.

ne of the =ajor cuesti.ons SAS seeks answers to concerning Marble M411 (see.*.,tatement p ese=ted to you at Madison, Tn44 = on March 25,1980) were anivered at the meeting at Fadisen. Eth regard Question I, "Can Marble Hill be repaired sufficient 17?", we hooe that the NP.C will support an independent assessme=t of the quality of construction a:d the degree to which it can be satisfactorily repaired, which has been sought by Save-the ~ alley.

he qcestion of whether PSI v471 be recuired to have N Certification, not just an "i=eri= let-er", prior to resQion of construction at Fafels Will, was =ade more cc= fusing at the meeti=g on March 25, Fadison, Tndia by the co=ments of Mr. S.W.

5:ields, Tice-President, Electric Syste=s, PSI. Does PSI still intend to assume over-all respo:sibility for Farble '34'7 ? If the ASME Code is law in the State of Inr '=

v' " ot FSI bzve to be certified? Ntrtech's assessme=t, pages 79-88 of the proceedi=gs of the Subce 'ttee Eea-ings on Const-.2ction Pmble=s at Maio'e ~34'7 : Nuclear Recula-tc.. Co 'esion Oversitht, Eeve=ber 27 and 28,1979, states that it is ex remely in-po-ta=t T a a.11 syste=s and co=ponents in that plant be built in accordance with the M Code a=d be code sta= ped in orcer for PSI to qualify for insurance at Marble F'".

This is =:t tre time to accept another prc=issory note fron PE.

Sassafras ;- r-+cs co=ti=ues to be disturbed by the fact that ricstantial progress has I

been =ade in the construction of Marble '33" (even though not " safety-: elated") yet FSI does not bzve a fally developed and fc=ctional Material Management Progran. This see=s ime=cusable and a =at'er of =isplaced priorities.

PE, vben gaestioned by the EEC at the March 25 meeti=g as to when PSI personnel would repla:s M1C perso=nel, :eplied that they expected it to take one to three years. As we ce=e=ed on Farch 25th, this is far too i=defini,e considering thatsafety-related verk stgage was brought on at least in part by serious understaffing as well as la.ek l

cf.- ' ar exnerience. PAC perso=e1 scarcely seems the answer to the extent p1rnnec a: p:e se=.

d y +6 W5S~2io 187

.c Gi 65

?S 's =-='ysis and conclusions :egarding their fixed-price con ractural agree-

=E

en s Ad d act address the substantive problems associated with then in the past E

• • • as s"^ a:e u= acceptable

'de assune that construction schedules and natters EE vhich canse delays in schedules w ll be part of the April 11 Agenda on PSI's "f

i

?.evised ;1/;C Program.

EE

==

After -h reeting of PSI with the IE on April lith, we would appreciate a reply

~E=

5=.

to our cuestions of March 25th and of this date, as well as a s --=v of the 2

=

a=swers of PSI.o the questions asked by the E in OA Questions Concer=ing gE the Medele 247' Docketed QA Prorran.

=-

=3 Tne over-r*Fing concern of our Society conti=ues to be the need for Marble Pill?

EEE "he evidence in44 cMes it is not needed. To igno:e this fact. hen =any aspects 355 of Marble 24'1 's construction is being questioned cannot be justified.

EEE

.=

==

To -s sinee:ely, Esi Es 23

.ohn A. ~'

. s1 cent EE5 f.oute 1, Box 375 EEE 1:ashvil2s, I= diana 47448 EE t=

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.F( ~$4Dfff[d SASSAFRAS Al'Dl'llON SOCIls'lY

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Y. %

of LA RENCE. Gl(EENE..\\10Ni(OE - Ill(OWN -

Y-

-/ %,

N MORGAN & OWEN CO!!NTIES

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, !.6-r N S t i7 N

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TO: Mr. Victor Stello, Jr., Director, Office of e--

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• Inspection and Enf >rcer4=+

n.:elear ?.e.,-

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t-b ulatory Co m i nion OP.C). D M M

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Mr. Jares G. Keppler, Direcitor, P.egion III l

'h)..*,

Mr. Cordell C. Winia=s, Construction Proj-l-l T

T4 eet Section Chief, P.egion III N?..

Questions and Co ments of the Sassafras Audubon Society presented at a Public Meeting held at Madison, Indiana, March 25, 1980, on the P.e-sponse of Public Service Indiana, Inc. (PSI) to the HP.0 " Order Con-firming Suspension of Construction" at Marble Hill, August 15, 1979 i

'he para =ount question concernirg Marble Hin is not whether safety-related construc-tien should be resumed, but whether all construction should be stopped. Should the public be subjected to the dangers inherent in the operation of a nuclear plant, in-cluding the storage of the plant's highly toxic wastes o._n-site, jf_ its po.er is not needed?

J-PSI has an overcapacity of :nore than 50% at peak power demand with Gibson 5 expected to come on line in 1933 PSI has over-estimated growth in de=and for electrical err-crg in its service area for =any years, and is urrailling to recognice :

1) that the expected population growth and general econo =ic activity in its area is likely to re=ain lov' below the Nation's average, aM

2) that the increasing cost of electrical energy will spur grea+ar energ con-servation, with the potential of energy conservation cutting energy use 30-40% by the year 2000, and

3) that ine: easing availability of natural gas in the next several decades win co=pete with and reduce dependency on electric power.

' The disastrous economics of nuchar plants adds another dimension to the question of whether Marble Hm should be built. The costs of constructing a nuclear plant has been increasing an:really at = ore than 3X the rate of general inflation, partly because of changes in design and adoption of standards to reduce the level of hacards in plant ope ration.

PSI should be requi:ed by the NP.0, prior to consideration of resumption of const: action, to idents.fy and docu=ent all safety-related =aterials and syste=s which will have to be changed, additi rQ'9^.ashvc 9

pheed to comply with post"-

~

WN" the DOS study of the Bymn 7

should also be applied to erators on-site have to be DUPLICATE DOCUMENT PSI has =ade no realistic esti= ate o Entire document previously but cost estimates of nuclear plants entered into system under:

lic service ec==issions place the co g

g does not include the costs of decont ANO n

No. of pages:

w l

[(%52/OAO K

.-