ML19330B102
| ML19330B102 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek, Callaway  |
| Issue date: | 07/28/1980 |
| From: | Seiken S NUCLEAR POWER PLANT STANDARDS COMMITTEE |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8007300337 | |
| Download: ML19330B102 (24) | |
Text
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y SNUPPS Stenderdised Nuclear Unit Power Plant System s ches cherry need July 28, 1980 n.4,ui. m.,viend aceso SLNRC 80-33 FILE: 0542/0491.3 SUBJ: QA Programs for Design, Con-struction and Fire Protection:
Callaway and Wolf Creek Sites Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, D.C. 20555 Re: STN 50-482, STN 50-483, STN 50-486 Ref: a) Letter 3/20/80, Parr, NRC to Bryan, Union Electric Co.: Subj. as above b) Letter 3/20/80, Parr, NRC to Koester, Kansas Gas & Electric Co.:
Subj. as Above c) SLNRC 80-25 dtd. 5/27/80: Subj. as Above
Dear Mr. Denton:
The purpose of this letter is to respond to NRC questions concerning the Callaway and Wolf Creek site QA programs for design and construction for-warded to Union Electric and K:nsas Gas & Electric as Enclosure 1 to the Ref. a) and b) letters. Responses to Enclosure 2 questions specific to the QA programs for fire protection were previously forwarded to NRC via Ref. c).
Attachment A to this letter provides the Union Electric response to the reference NRC questions. The Kansas Gas & Electric response is forwarded as Attach 0ent B.
Both sets of responses were reviewed with NRC (Spraul) on July 15, 1980 and are understood to be responsive to NRC questions and comments. As a result of discussions with NRC, the subject QA Program document will be revised to incorporate commitments and agreements re-flected in the attached responses. A revised program document reflecting these commitments will be available within the next 90 days.
If further clarification should be required, please feel free to contact me'at (301) 869-8010 Very truly yours, Boc/
j SJS:dck:la20 Atta::hments: Responses to Enclosure 1 to NRC letters of 3/20/80 cc:
J. K. Bryan, UE G. L. Koester, KGE.
D. T. McPhee, KCPL 8007300 N
- E. ~ - l.
ATTACBMENT A UNION ELECTRIC REFEONSE TO ENCLOSURE 1 OF NRC MARCH 2C, 1980 REQUEST FOR ADDITION INFORMATION re UE ADDENDUM OF QA PROGRAM FOR DESIGN AND CONSTRUCTION 1.
NRC Comment The responsibilities of Daniel Inte: national Corporation are listed in the first paragraph on pege 17.0-2.
The list does not include quality control.
Identify the organization (s) responsible for quality control at the callaway Plant site.
UE Response t
Pages 17.0-1 & -2 are a general introduction to the Callaway Site Addendum.
As such no specific assignments or actions were described in these pages.
Specific QC responsibilities are described on pages 17B.1-7 and 8.
l 2.
NRC Comment The description of the QA program for the Callaway Plant refers to PSAR Section 17.1.
(See the first paragraph on page 17.1-1 for example.)
Since the SNUPPS submittal of December 20, 1979 includes the " Quality Assurance Program for j
Design and Construction," which updates PSAR Chapter 17, change i
references to PSAR Section 17.1 to reference the appropriate sections of this later QA program description.
j UE Response A forward will be added to the SNUPPS-Calladay Design and i
Construction QA Program (DEC QAP) which will indicate that where reference is made to the PSAR Chapter 17.1, it is un-derstood to mean the D&C QAP manual.
A similar clarification will be made in the Standard plant portion of the reference QA program for design and construction.
3.
NRC Comment There appears to be an inconsistency between the text and Figure 17.1-1 in that the last paragraph on page 17.1-2, the first paragraph on page 17.1-3, and elsewhere refer to "a site QA group leader" whereas Figure 17.1-1 shows a "Supv.
Engr. QA (Site). "
Please clarify.
I UE Response Nhen the Callaway Site QA Group was initially organized, the person responsible for guidance and authority over the group i
f O
I e
s t was designated "s'ite QA group leader".
This designee was 1
later given the title of Supervising Engineer-QA.
Pro-cedurally either designation may be used as illustrated by Figure 17.1-2.
In order to clarify this, the words "Sup-ervising Engineer-QA" will be added before "(Site QA group leader)" on Page 17.1-2 (the first reference to this position).
4.
NRC Comment The last sentence of the first complete paragraph on page 17A.1-3 introduces the concept of the QA Department review-ing selected design documents.
Identify who (by position title) selects which design documents are reviewed by the QA Department and the bases of the selection.
The next paragraph and the first complete paragraph on page 17A.1-ll state that QA personnel either participate in the Integrated Design Review or audit it.
Identify who (again by position title) selects which Integrated Design Reviews.do not require QA personnel participation and the bases of the 6ecision.
Identify which organization reviews for quality assurance when QA personnel do not participate.
UE Response The QA Manager selects the design documents that must be reviewed by' the QA Department on the basis that he requires the original issue and all subsequent revisions of the design output documents (drawings and specifications) for all safety-related project design packages to be reviewed by the QA Department.
The QA Manager and the Project Manager jointly determine whether or not a project design package is safety-related before work commences, on.the design package.
The QA Manager determines the requirements for QA personnel parti-cipation in Integrated Design Reviews.
He requires QA personnel participation in all Integrated Design Reviews for all safety-related project design packages.
QA personnel participation is assured by the QA Manager's documented review of the Design Review List that identifies all safety-related project design packages that require an Integrated Design Review, and identifies the required participants for each review.
The appropriate paragraphs in the QA Program for Design & Construc-tion will be revised to reflect the above interpretation.
. 5.
NRC Comment Discuss the significance of changing " decisions" to
" problems" in part (d) on page 17B.1-5 and part th) on page 17B.1-8.
UE Response Changing the wording from " decisions" to " problems" was made by Daniel as part of a general upgrade of the QA program description.
The subject matter here is the need for consultation between the Project Manager, QC Maneger, and QA Manager and it is considered that the term " problem" has a broader connotation than " decision" and in fact the commitment to requiring consultation.in problems is con-sidered to include decisions.
6.
NRC Comment Discuss the significance of the change made on page 17B.1-22, under part 173.1.15 from:
" Documented approval is provided to Daniel prior to releasing any nonconforming item for installation or construction when it has been repaired or designated 'use as is'." to
" Documented approval of the nonconformance disposition is provided to Daniel for those items dispositioned ' repair' or 'use as is'."
UE Response This change was made with the intention of clarifying the program commitment.
Daniel cannot repair or "use as is" a nonconforming item until receiving documented approval from the A/E or the Utility.
The QA Program description was thus revised to clarify this requirement.
This additional clar-ification concerning repair or use of nonconforming items will be incorporated into the reference QA Program addendum.
7.
NRC Comment In Appendix A on page 17B.1-27, Daniel takes exception to two requirements in Section 5.4 of ANSI N45.2.5-1974.
When others have taken these same exceptions, we required additional controls as shown below:
C
. The construction manager or constructor will provide quality control measures on direct tension indicators based on applicable AISC documents, and as a minimum will perform the following:
a.
To verify the load indicating qualities of the load indicators, at least three load indicators from each keg shall be i
i verified in a calibration device similar to that required for wrench calibration.
If nut face washers are used between the indicators and the nuts, the indicators shall be tested with washers at the rate of three washers from each keg.
Each verification test shall show not less than the specified gap when bolt is tightened to the specified tension.
b.
Load i~ndicator washers shall be insta4 ed in accordance with the manufacturer's instructions.
When a load indicator is required under the nut a spseial nut face washer shall be fitted between the indicator and the nut.
c.
Bolted joints made with load indicators shall be inspected visually to ensure that all bolts have the load indicators properly' installed and to the proper gap.
At least 20 percent of the bolts in each connection but not less than two bolts shall be checked with a feeler gage to determine the bolts are properly tightened.
d.
Direct tension indicators used with bolts that have been tightened to the full extent specified in Table 3 of AISC specification S314-5/75, " Structural Joints Using ASTM A325 or A490 Bolts," May 8, 1974, shall not be reused.
Section 5.4, second paragraph, Item 1 of the standard requires that " Bolts are the correct length as indicated by at least two threads extending beyond the nut."
This provision exceeds the requirements contained in present and past issues of the RCRBSJ Specification which requires
" full thread engagement."
This term is then defined:
" Full thread engagement is deemed to have been met when the end of the bolt is flush with the face of the nut."
The construction manager or constructor proposes the alternative to the requirement for "at least two threads extending
. i beyond the nut" by use of the industry practice of bolts flush with the face of the nut.
Provide a commitment to such controls or alternatives for our assessment.
UE Response The current version of Appendix A on Page 17B.1-27 has an inadvertent omission.
The following lines will be added to the end of the statement:
"As a result, the requirements for acceptance of tightened bolt assemblies is that "the length of the bolts shall be such that the point of the bolt will be flush with or outside of the face of the nut when com-pletely installed."
Daniel performs this type of work under the controls of Bechtel Specification 10466-C-122 (Q).
Section 11 of this, specification contains the pertinent information required by paragraphs a, b, e and d of the NRC comment.
This added clarification will be incorpo.ated into the reference QA Program addendum.
8.
NRC Comment The fire protection QA program for 'the Callaway Plant is not clear.
While providing a general commitment to selected portions of the overall QA program, part 17C then limits the commitments such that the general commitment appears meaningless, and the limiting commitments do not appear to be completely responsive to Mr. Vassallo's letter of August 29, 1977.
Please clarify.
(See Enclosure
. 2)
DE Response See response to Enclosure 2 to Mr. O.
D'. Parr's letter of March 20, 1980.
9.
NRC Comment Discuss how the QA program for non-Category I Seismic Systems provided in part 17C of the Callaway submittal meets the pertinent QA requirements of Appendix B to 10.CFR Part 50.
UE Response The Callaway QA program for non-Category I Seismic systems has been modified to more accurfcely reflect the scope and h
a
, substance of existing site activities.
A copy of this modi-fled program description is provided as an attachment with this letter.
The program as described in the enclosure is judged to com-ply with the pertinent and applicable criteria of Appendix B and address design and procurement controls; drawings, instruc-tions and procedures; control of purchased equipment and ma-terial; inspection; test controls; document control; special process control; identification of equipment and materials; non-conformance control; inspection and test statur.; correc-tive actions; records and audits.
These criteria have been and will continue to be invoked to the extent considered appropriate for the scope, complexity and importance of non-Category I seismic systems, i
_
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Attachment Union Elcctric Non-Category I S21smic Systems Quality Assurance Program The Quality Assurance Program for non-Category I Seismic Systems is developed sufficiently to assure that the re-quirements for design, procurement and installation are satisfied.
Design and procurement controls for seismic non-category I design are described in the SNUPPS Standard Non-Category I Seismic Program description for design and construction.
The QA program for non-Category I Seismic Systems is a graded program under the management control of the Union Electric QA organization.
1.
Design Control and Procurement Document Control Non-Category I seismic design activities are carried out by Bechtel on a standard plant basis.
The QA pro-gram applicable to the standard design and procurement document control effort is described in Table 17C.0-1 l
of the SNUPPS Standard Program Description.
l Design and procurement document controls for future design activities uuring the operating phase will include the following:
1 a) Measures to assure that quality standards are speci-fied in design documents and include applicable codes and standards and, further, that deviations and changes from these st andards are controlled.
Attachm:nt Page 2 b) Design reviews by personnel knowledgeable and independent of the design production process.
c) Measures to assure procurement documents adequate-ly state, and are reviewed for applicable technical and quality requirements, that the requirements are capable of being verified by inspection and/or test and that acceptance criteria are adequately stated.
d) Measures to assure design and procurement changes, including field changes, are subject to the same cont rols, reviews and approach applicable to the original document.
2.
Instruction, Procedures and Drawings Design, installation, inspection, maintenance and modification of seismic non-category I systems are accomplished in accordance with documented instructions, procedures, and drawings.
3.
Control of Purchased Material, Equipment, and Services Receipt inspection or installation inspection assures that material and equipment for saismic non-category I systems conform to procurement documents.
e
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Attachment Page 3 4.
Inspection Documented inspections and/or process monitoring oper-ations are performed in accordance with procedures or checklists by individuals other than those who per-formed the activities being inspectec.
The adequacy and implementati6n of the inspection effort shal l be monitored through audit / surveillance.
Installation, maintenance or modifications to non-Seismic Category I systems governed by this program are subject ts inspection to assure conformance to design and installation requirements.
5.
Test and Test Control Tests required by design or procurement documents to be performed onsite are conducted in accordance with rrocedures or checklists to verify conformance with design and system performance rcquirements. These tests results shall be documented and evaluated.
6.
Inspection and Test Status Measures are established to provide for the identifi-cation of test and inspection status for applicable portions of non-Category I seismic systems, components e
Attachment Page 4 and structures.
Designation of operation status is considered non-applicable to these items.
7.
Document Control Measures are established to control the issuance of documents such as instruction, drawings and proce-dures, including changes thereto.
8.
Identification and Control of Materials, Parts and Components Measures are established for the control of material, parts and components sufficient to prevent use of in-correct, indeterminate or defective items.
Identifi-cation of such materials, parts and components is maintained on a bulk basis.
9.
Control of Special Processes Measures are established tc assure that special pro-cesses, including welding, are controlled and per-formed by qualified procedures.
Unique traceability of specific welder and weld procedures to individual welds is considered unnecessary.
e
Attachment Page 5
- 10. Control of Measuring and Test E_quipment Measures are established to assure tools, gages, in-struments and other measuring and testing devices used in quality-related activities are controlled, calibrated and adjusted at specified intervals to maintain accuracy within specified limits.
- 11. Non-Conforming Items Items that do not conform to specific requirements shall be identified during inspection and/or tests.
Nonconforming items identified shall be documented, properly controlled and d ispositioned, and otherwise processed according to procedures.
Nonconforming ma-terial will be tagged and/or segregated to prevent inadvertent use.
- 12. Corrective Action Procedures provide that failures, deficiencies, devia-tions, defective items and noconformances which affect seismic non-category I components are promptly iden-tified, reported, evaluated, ar.d corrected.
The eval-uation considers the cause of the condition and action to preclude recurrence.
e
Attachment Page 6
- 13. Records Records are maintained in accordance with ANSI N45.2.9 to show the applicable program criteria commitments are being satisfied for activities affecting the seismic non-category I program.
- 14. Audits Audits are performed to verify compliance with the Seismic non-Category I requirements, including proce-dures, inspections, and testing activities.
Audits are conducted by QA personnel in accordance with written procedures or checklists.
Audit results are documented and reviewed by supervisory personnel responsible for correcting deficiencies re-vealed by the audit.
Follow-up actions are taken by responsible management to correct deficiencies identi-fled during the audit.
i i
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ATTACHMENT B KANSAS GAS AND ELECTRIC COMPANY RESPONSE TO ENCLOSURE 1 OF NRC MARCH 20, 1980 REQUEST FOR ADDITIONAL INFORMATION re WOLF CREEK ADDENDUM QUALITY ASSURANCE PROGRAM DESIGN AND CONSTRUCTION Question:
1.
Reinstate or justify the deletion of "The committee shall prepare a response to the citation and initiate appropriate corrective action or verify that proper corrective act3on has already taken place" from the fourth paragraph in 17.1.1.1.3 (page 17.1-7).
Response
The wording deleted implied that the " Committee" prepares responses to citations.
It is impractical for a committee to prepare (write) documents.
The work of drafting the response is assigned to an individual.
The Chairman reviews and transmits the response, the entire Committee reviews the response.
The preceding clarification will be incor-porated into the reference QA Program addendum.
Question:
2.
Since the QA program for the operations phase is descr'ibed in the FSAR for Wolf Creek, delete the last sentence from 17.1.1.7 (page 17.1-8) which states: "The Plant Staff will be assisted by at least one quality assurance engineer staticaed at the plant".
Response
Section 17.1.1.7 will be revised to delete the last sentence.
Question:
3.
The description of the QA program for the Wolf Creek Generating Station refers to PSAR Section 17.1.
(See the third paragraph on page 17.1-17 for example.)
Since the SNUPPS submittal of December 20, 1979 includes the " Quality Assurance Program for Design and Construction", which updates PSAR Chapter 17, change references to PSAR Se: tion 17.1 to reference the appropriate sections of this later QA program description.
Response
An introduction will be added to the Wolf Creek QUALITY ASSURANCE PROGRAM for DESIGN and CONSTRUCTION which will indicate that where reference is made to PSAR Chapter 17.1 it is, understood to mean the QUALITY ASSURANCE PROGRAM for
2.
DESIGN and CONSTRUCTION.
A similar clarification will be made in the Standard plant portion of the QA program for design and construction.
Question:
4.
The fourth paragaph on page 17.1-17 and the first and fifth paragraphs on page 17B-9 refer to Table 3.2-1 of the Standard Plant PSAR for the identification of safety-related items.
However, page 17.1-10 of the Wolf Creek portion of the December 29, 1979 submittal also refers to Section 3.8.4 of the Wolf Creek portion (or addendum) of the PSAP..
It appears that the three aforementioned paragraphs should also refer to Section 3.8.4.
Please clarify.
Response
The fourth paragraph on page 17.1-17 and the first and fifth paragraphs on page 17B-9 will be revised to reference both Table 3.2-1 of the Standard Plant PSAR and Section 3.8.4 of the Wolf Creek addendum to the PSAR.
Question:
5.
Reinstate or justify the deletion of " inspection trip reports" from the records to be furnished by Bechtel and Westinghouse as per the last paragraph on page 17.1-56.
Response
The " approval of supplier QA programs and shop inspection reports" are retained and controlled by the Lead AE anl NSSS vendor es QA 3ecords in accordance with ANSI N45.2.9 requirements.
These records are not required at the construction jobsite since adequate means presently exist to inform the site that vendor i
QA programs have been approved and required inspections satis-factorily performed.
Specifically, the Supplier Print Control Register issued to the jobsites identifies the approval status of all supplier QA program manuals.
Satisfactory inspection completion is indicated by Lead AE inspecti9n sign off of the Certificate of Conformance or, in the case of the NSSS vendor, by sign off of the Quality Release form.
The use of the supplier Print Control Register to identify manual aoproval status will be reflected in a revision to the refertice QA Program addendum.
3.
Question:
6.
Item (i) at the top of page 17B-4 indicates that the Daniel Regional QA Manager is responsible to review and concur with the QA program of selected suppliers, while item (j) at the middle of page 17B-8 indicates that the Daniel Quality Control Manager is responsible to review the QA/QC programs of suppliers.
Clarify that the QC Manager's review of QA programs of suppliers not selected for review and concurrence of the Regional QA Manager includes the concurrence responsibility.
Response
Item (i) at the top of page 17B-4 describes responsibilities of the Project QA Manager not the Regional QA Manager.
Items (e) and (j) on page 17B-8 indicate that the Quality Con-trol Manager is responsible for qualifying suppliers and sub-contractors including review of their QA programs.
The Quality Control Manager makes the determination of qualification.
On a selected basis the Project QA Manager provides an overview of the Quality Control Manager's function by also reviewing and concurring (or not concurring) with the suppliers QA program.
Question:
7.
Explain the deletion of procedures for controlling special processes from part 17B.1.1.2 responsibilities of Technical Services.
Response
i This deletion was the result of a typing error.
The text under 17B.1.1.2.a will be revised to correct this error.
1 Question:
8.
Discuss the significance of changing "decisiens" to " problems" in part (d) at mid page 17B-5 and part (g) at mid page 17B-8.
Response
The change from " decisions" to " problems" was made as part of a general upgrade of the QA Trogram description.
The need for consultation between the Project Manager, QC Manager and QA Manager is recognized, therefore, the term " problem" was used because of its b:oader connotation.
The commitment requiring consultation on problems includes consultations on decisions.
b o
1 t-4.
Question:
3 9.
Explain the significance of deleting" certification of the j
assigned construction" from the responsibilities of the Daniel 4
Quality Control Manager" at the bottom of page 17B-7.
Response
The prime QC function is to examine, test and inspect the construction effort against the acceptance criteria provided by the design engineer and to document the results of those 1
QC activities.
The term " certification" is considered to be superfluous and not germane to the QC function and this was deleted.
Actual certification of compliance to the approved design is accomplished in the turnover process from the con-structor to the owner.
Question:
i 10.
Explain the significance of the change to the second paragraph of 17B.1.2 from " Prior to issuance, all procedures and instructions are forwarded to KG&E for review and final approval", to " Prior to issuance, procedures are forwarded to KG&E for review and final approval".
I
Response
l Instructions are subtier documents approved by Daniel QA.
These documents will be periodically axamined by KGE in the course of QA audit and surveillance but are not considered sufficiently important to require prior KGE approval.
Question:
11.
Dele
- justify the addition of " inadvertent" to the second sent on page 17B-18 which states " Identification and con-trol n sures shall be provided to prevent the inadvertent use or installation of incorrect or defective material, parts and components".
Response
The addition of the word " inadvertent" is intended to provide the owner with the opportunity to consider proceeding with i
installation of incorrect or incomplete materials and equip-ment items in instances where such installation or further pro-cessing will not preclude or inhibit later completion or correction of.the items in question._ Further processing and/or installation of such items shall be subject to written and approved Utility Management controls.
This activity will be under the control of the KGE QA manager and shall be so stated in the reference QA Program addendum.
I e
5.
Question:
12.
The fire protection QA program for the Wolf Creek Generating i
Station is not clear.
While providing a general commitment to selected portions of the overall QA program (the reference to j
" Chapter 17.0 of this PSAR Addendum" should be changed to reflect the SNUPPS submittal of December 20, 1979 as in item 4 above),
part 17C then limits the commitments such that the general commitment appears meaningless, and the limiting commitments do not appear to be completely responsive to Mr Vassallo's letter of August 29, 1977.
Please clarify.
Response
See response to enclosure 2 of Mr O D Parr's letter of March 20, 1980.
i 1
Question:
13.
Discuss how the QA program for non-Category I Seismic Systems provided in part 17C of the Wolf Creek submittal meets the pertinent QA requirements of Appendix B to 10CFR Part 50.
nesponse:
The Wolf Creek QA program for non-Category I Seismic systems has been modified to more accurately reflect the scope and substance of existing site activities.
A copy of this modi-4 fied program description is provided as an attachment with this letter.
The program as described in the enclosure is judged to com-ply with the pertinent and applicable criteria of Appendix B l
and address design and procurement controls; drawings, instruc-tions and procedures; control of purchased equipment and ma-i terial; inspection; test controls; document control; special process control; identification of equipment and materials; non-conformance control; inspection and test status; correc-tive actions; records and audits.
Thase criteria have been 4
i and will continue to be invoked to the extent considered appropriate for the scope, complexity and importance of non-Category I seismic systems.
e m.
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Enclosure KGE Non-Category I Saismic Systems Quality Assurance Program The Quality Assurance Program for non-Category I Seismic Syste s is developed sufficiently to assure that the re-quirements for design, procurement and installation are satisfied.
Design and procurement controls for seismic non-category I design are described in the SNUPPS Standard Non-Category I Seismic Program description for design and construction.
The QA program for non-Category I Seismic Systems is a graded program under the management control of the KGE QA organization.
1 l
1.
Design Control and Procurement Document Control Non-Category I seismic design activities are carried out by Bechtel on a standard plant basis.
The QA pro-gram applicable to the standard design and procurement document control effort is described in Table 17C.0-1 of the SNUPPS Standard Program Description.
Design and procurement document controls for future design activities during the operating phase will include the following:
a) Measures to assure that quality standards are speci-fied in design documents and include applicable codes and standards and, further, that deviations and changes from these standards are controlled.
I e
Enclosure Page 2 b) Design reviews by personnel knowledgeable and independent of the design production process.
c) Measures to assure procurement documents adequate-ly state, and are reviewed for applicable technical and quality requirements, that the requirements are capable of being verified by inspection and/or test and that acceptance criteria are adequately stated.
d) Measures to assure design and procurement changes, including field changes, are subject to the same controls, reviews and approach applicable to the original document.
2.
Instruction, Procedures and Orawings Design, installation, inspection, maintenance and modification of seismic non-category I systems are accomplished in accordance with documented instructions, procedures, and drawings.
3.
Control of Purchased Material, Equipment, and Services Receipt inspection or installation inspection assures that material and equipment for seismic non-category I systems conform to procurement documents.
D e
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Enclosuro Page 3 4.
Inspection Documented inspections and/or process monitoring oper-ations are performed in accordance with procedures or checklists by individuals other than those who per-formed the activities being inspected.
The adequacy and implementation of the inspection effort shall be monitored through audit / surveillance.
Installation, maintenance or modifications to non-Seismic Category I systems governed by this program are subject to inspection to assure conformance to design and installation requirements.
5.
Test and Test Control Tests required by design or procurement documents to be performed onsite are conducted in accordance with procedures or checklists to verify conformance with design and system performance requirements. These tests results shall be documented and evaluated.
6.
Inspection and Test Status Measures are estabitshed to provide for the identifi-cation of test and inspection status for applicable portions of non-Category I seismic systems, components 1
s e
Enclosure Page 4 and structures.
Designation of operation status is considered non-applicable to these items.
7.
Document Control Measures are established to control the issuance of documents such as instruction, drawings and proce-dures, including changes thereto.
8.
Identification and Contrgl of Materials, Parts and Components Measures are established for the control of material, parts and components sufficient to prevent use of in-correct, indeterminate or defective items.
Ident ifi-cation of such materials, parts and components is maintained on a bulk basis.
9.
Control of Special Processes Measures are established to assure that special pro-cesses, including welding, are controlled and per-fomed by qualified procedures.
Unique traceability of specific welder and weld procedures to individual welds is considered unnecessary.
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Enclosure Page 5
- 10. C_ontrol of Measuring and Test Equipment Measures are established to assure tools, gages, in-struments and other measuring and testing devices used in quality-related activities are controlled, calibrated and adjusted at specified intervals to maintain accuracy within specified limits.
- 11. Non-Conforming Items Items that do not conform to specific requirements shall be identified during inspection and/or tests.
Nonconforming items identified shall be documented, properly controlled and dispcsitioned, and otherwise processed according to procedures.
Nonconforming ma-terial will be tagged and/or segregated to prevent inadvertent use.
- 12. Corrective Action Procedures provide that failures, deficiencies, devia-tions, defective items and noconformances which affect seismic non-category I components are promptly iden-tified, reported, evaluated, and corrected.
The eval-uation considers the cause of the condition and action to preclude recurrence.
9
Enclosure Pag? 6
- 13. Records Records are maintained in accordance with ANSI N45.2.9 to show the applicable program criteria commitments are being satisfied for activities affecting the seismic non-category I program.
- 14. Audits i
Audits are performed to verify compliance with the Seismic non-Category I requirements, including proce-dures, inspections, and testing activities.
Audits are conducted by QA personnel in accordance with written procedures or checklists.
Audit results are documented and reviewed by supervisory personnel responsible for correcting deficiencies re-vealed by the audit.
Follow-up actions are taken by responsible management to correct deficiencies identi-fled during the audit.