ML19339A522

QA Program During Design & Const

ML19339A522
Person / Time
Site:	South Texas
Issue date:	10/31/1980
From:	BROWN & ROOT, INC. (SUBS. OF HALLIBURTON CO.)
To:
Shared Package
ML19339A516	List: ML19339A515 ML19339A518 ML19339A522 ML19339A524
References
NUDOCS 8011040183
Download: ML19339A522 (91)

Text

- .

(G .'T -

l i

ATTACHMENT 1 PART B BROWN & ROOT, INC.

QUALITY ASSURANCE PROGRAM DESCRIPTION DURING DESIGN AND CONSTRUCTION SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION OCTOBER 31, 1980 t

801)ogo/t&

i

'IABLE OF CONTENTS SECTION TITLE PAGE j 2

1.0 ORGANIZATION . . . . . . . ... ... . .. . . . . ..

Quality Assurance Program Responsibility . . 2 1.1 .. ....

1.2 Power Group Organization . .. .. . .. . . . . . . .. 3 Power Operations Department . 3 1.2.1 .. . . . . . . . . ..

4 1.2.2 Power Construction Department .. . . . . . . . ...

4 1.2.3 Power Engineering Department . .. .. . . . . . ..

4 1.2.4 Quality Assurance Department- . .... . . . . . . .

5 1.3 South Texas Project Organization . . . . . . . . . . . .

5 1.3.1 Project General Management . ... . . . . . .. ..

5 1.3.2 Project Site Organization . .... . . . . . .. . .

6 1.3.3 Project Engineering Organization . . . . . . . ...

6 1.3.4 Project Materials Management Organization . . . ...

Project Quality Assurance Organization . . . .. .. 6 1.34 8 1.4 QA Authority and Organizational Freedom .. . . . ...

9 2.0 QUALITY ASSURANCE PRr3 RAM . . . ... . . . . . . . ..

Brown & Root Quality Assurance Program Scope . . . . . . 9 2.1 Brown & Root Quality Assurance Program Description . 9 2.2 ..

2.2.1 Quality Assurance Program Documentation . . . . ... 9 2.2.2 Supplier and Subcontrauor Quality Assurance Program Requirements .. . . ... . . . . . . . .. 10 2.2.3 Personnel Indoctrination, Training, and Certification . . . . . . . .. .. . . . . . . . . . 10 2.2.4 Stop Work . . . . . . . . . . . . . . . . . . . .. . 11 2.2.5 Management Review . . . . . . . . . . . . . . . . . . 11 2.2.6 QA Program Revision . . . . . .. . . . . . . . . . . 11 3.0 DESIGN CONTROL . . . ... , . . .. . . . . . . . . . . 12 3.1 Design Control Requirements . . .. . . . . . . . . . . 12 3.2 Design Control Activities . . . ... .. . . . . . .. 13

- 3.2.1 Procedure Preparation . . . . .. . . . . . . . . .. 13 3.2.2 Standard, Guide, and Instruction Preparation . ... 14 3.2.3 Design Development Control . . .. . . . . . . . . . I '+

3.2.4 Design Input Control . . . . ... . . . . . . . . . 14 3.2.5 Design Verification . . . . . . . . . . . . . . . . . 14 3.2.6 Design Document Control . . . . . . . . . . . . . . . 15 3.2.7 Quality Assurance Review . . . . . . . . . . . . .. 17 3.2.8 Design Quality Engineering Review . . . . . . . . . . 17 3.2.9 Design Interface Control . . .. . . . . . . . . . 18 3.2.10 Design Change Control . .. . .. . . . . . . . . .. 18 3.2.11 _. Design Deficiencies . . . . . . . . . . . . . . . .. 20 3.2.12 Records Retention . . . . . . . . . . . . . . . . . . 20 l

l l B&R -i- OCTOBER 31, 1980 1

l

,- . , - , , . - .~: --

TABLE OF.C0h. .nTS

'(Continued)

SECTION TITLE .PAGE 20 4.0 PROCUREMENT DOCUMENT CONTROL . . . . .... . . . . ..

21 4.1 Procurement Document Processing ..... . . . . ...

21 4.1.1. Procurement of Engineered Equipment . .. . . .. ..

22

'4.1.2 Procurement of Bulk Materials . ... . . . . . ...

23

.4.1.3 Procurement of Subcontracts . ...... . . . . ..

23 4.2 Revisions . . . . . . .................

2h i 5.0 INSTRUCTIONS, PROCEDURES, AND DRAWINGS . .. . . . . . .

2h 5.1 Preparation . . . . . ................. 24 5.2 Reviews . . . . . . . .................

25 5.3 Fevisions . . . . . . .................

25 6.0 DOCUMENT CONTROL . . . .................

Document Control - Engineering . 25 6.1 .. . . . . . . . . ..

Document Control - Procurement . 25 6.2 . .. . . . . . . . . .

25 6.3 Document Control - Quality Assurance . . . . . . . . ..

26 6.4 Document Control - Construction .. . . . . . . . .. .

, 7.0 CONTROL OF PURCHASED MATERIALS, EQUIPMENT, AND SERVICES . . . . . .................

26 26 7.1 Evaluation and Selection of Suppliers . . . . . . . . .

I-7.2 Source Inspection . . ................. 27 Source Audits . . 28 7.3 . . .................

28 7.4 Receiving Inspection . .................

8.0 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS ................. 29 8.1 Receiving Inspection . ................. 29

! 8.2 Storage. . . . . . . . ................. 29 8.3 In-Process Control . . ................. 29 8.4 Suppliers and Subcontractors . . . . . . . . . . . . . . 29 9.0 CONTROL OF SP".CIAL PROCESSES . . . . . . . . . . . . . . 30 9.1 Nondestructive Examination (NDE) . . . . . . . . . . . . 30 Nondestructive Examination Procedures . . . . . . . . 30 9.1.1 9.1.2 Nondestructive Examination Personnel . . . . . . . . 30 Welding 31 9.2 . . . . . . . .................

9.2.1 Welding Procedure Specifications and 31 Procedure Qualifications . .. . . . . . . . . . . . ,

9.2.2 __ Welding and Welding Operators Performance 31 Qualifications . . .................

32 9.2.3 Control of Welding Materials .. . . . . . . . ...

Control of Welding Processes 32 9.2.4 . . . . . . . . . . . .

B&R -ii- OCTOBER 31, 1980

._. _ . . . -._.-..u... . . ..... ,,m_. i ,e - _ _ _ _ , - _ _ . _._ n, __

TABLE OF CONTENTS (Continued)

SECTION TITLE PAGE Repairs to Base Metal and Weld Metal 33 9.2.5 . . .. . ...

Heat Treatment . .. . ................. 33 9.3 9.4 Bending . . . . . .. .................

3^

Chemical Cleaning Control 33 9.5 .. . . . . .. . . ... ..

10.0 INSPECTION . . . . . . . . . . .... .. . .. . . . . 33 10.1 Inspection Personnel . . . . . . . . . . . . . . . . . .

34 10.2 Hold Points . . . . . .................

35 10.2.1 Suppliers . . . . . ................. 35 10.2.2 B&R Construction and Fabrication .... . . . .. . 35 10.3 Indirect Control of Inspections . . . . .. . . . .. . 35.

10.4 Inspection of Repaired Items . ... . . . . . . . . . . 35 11.0 TEST CONTROL . . . . . ................. 35 11.1 Test Procedures . . . ................. 36 11.2 Inspection of Tests . ................. 36 11.3 Documentation . .. . ................. 36 12.0 CONTROL OF MEASURING AND TEST EQUIPMENT . . . . . . . . 37 12.1 Calibration Standards ................. 37 12.2 Calibration of Measuring and Test Equipment . . . . . . 37 12.3 Damaged Equipment . . ................. 38 12.4 Inactive Equipment . . ................. 38 12.5 Nonconformances . . . ................. 38 12.6 Testing Laboratories . ................. 38 12.7 Issuance of Measuring . cad Test Equipment . . . . . . . . 38 13.0 HANDLING, STORAGE, AND SHIPPING . . . . . . . . . . . . 39 13.1 Shipping . . . . . . . ................. 39 13.2 Storage . . . . . . . ................. 39 13.3 Handling . . . . ... ................. 39 13.4 Preservation . . . . . ................. 40 13.5 Special Items . . . . ................. 40 14.0 INSPECTION, TEST, AND OPERATING STATUS . . . . . . . . . h0 14.1 Inspection at Supplier's Shop .. . . .. . . . . . . . h0 14.2 Receivine Inspection . ................. h0 ,

14.3 In-Process Cantrol . . . ................ hl l 14.4 Nonconformances ... ................. hl 14.5 Control of Status Indicators . . . . . . . . . . . . . . h1 14.6 Suppliers and Subcontractors . . .. ... . . . . . . . h1 B&R -iii- OCTOBER 31, 1980

. . - . . . - .. ,, . ~ . , , , , . -. - _.

_ , . _ , . . . . ,m.;

1 l

l i

I l

TABLE OF CONTENTS (Continued)

SECTION TITLE PAGE 15.0 NONCONFORMING MATERIALS, PARTS, OR COMPONENTS . ....

kl 15.1 Identification . . . . ................. hl Segregation h2 15.2 . . . . ....... . .. . .. . ... .

Approval for Issuance ................. h2 15.3 Disposition and Implementation . .... .. h2 15.4 . ... . .

15.5 Removal of Tags . . . .................

43 15.6 Nonconformance Trends ......-........... 43 Oh 15.7 Stop Work Order (SWO) .................

hh 16.0 CORRECTIVE ACTION . . .................

17.0 QUALITY ASSURANCE RECORDS ... . . .. .. . . . . . . h5 17.1 Processing of Quality Assurance Records . . . . . . . . h5 17.2 Storage . . . . . . . ................. h5 17.3 Filing . . . . . . . . ................. h5 17.4 Access Control . . . . . . . . . . . . . . . . . .. . . h5 17.5 Removal of Quality Assurance Records . . . . . . . . . . h5 17.6 Revision . . . . . . . ..... . .. . . . . . . . . . h6 17.7 Disposition . . . . . ................. h6 18.0 AUDITS . . . . . . . . ............ . . . . . 46 18.1 Qualification of Auditors . . . . ... . . . . . . . . h6 18.2 Planning and Scheduling Audits . . .. . . ..... . . 47 18.3 Implementation of Audits . ... . . .. . . . . . . . . h7 18.4 Audit Reports . . . . ................. hT 18.5 Audit Deficiencies . . ................. h8 a-B&R -iv- OCTOBER 31, 1980 w ._ . ._ - - - - . . - - .. .--, . .~ . . t

LIST OF TABLES NUMBER TITLE PAGE 11 Project Quality Assurance Department Functions . . . . .. h9 2 ANSI Standard and Regulatory Guide Compliance . .. . .. 52 3 STP Quality Assurance Procedures . .. . .. . . . . .. . 55 4 STP Engineering Procedures . . .... . .. . . . .. ..

50 5 STP Haterials Management Procedures . . . . . . . . . ..

60 6 STP Construction Procedures . . ... . .. . . . . . . .

61 l

EB&R -v- OCTOBER 31, 1980

.s . . . . _ . . . . . -

. , , . . . _ - _ _ _ - ._,,.s

LIST OF FIGURES NUMBER TITLE 1 Brown & Root Corporate Organization 2 Brown & Root Power _ Group Organization 3 Brown & Root Power Engineering Organization 4 Brown & Root Power Group Quality Assurance Organization 5 Brown & Root South Texas Project Organization 6 Brown & Root South Texas Project Site Organization 7 Brown & Root South Texas Project Engineering Organization 8 Brown & Root South Texas Project Materials Management Organization 9 Brown & Root South Texas Project Quality Assurance Organization P

1 i

l 1

c B&R -vi- OCTOBER- 31, 1980

, _ - - . . . ._.. ..,,.m._,. . .

_ :.---- - - ~ .._- ~ -

l BROWN & ROOT, INC.~

, QUALITY ASSURANCE PROGRAM DURING DESIGN AND CONSTRUCTION SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION Brawn & Root, Inc. (B&R) as the Engineer and Constructor of the South Temas Project Electric Generating Station Units 1 and 2 (STPEGS) has been delegated by Houston Lighting & Power Company (HL&P) the assignment of establishing and implementing a Quality Assurance Program for control of the B&R quality-related activities. Brown & Root has developed and implemented an overall Quality Assurance Program, as described herein, for controlling and documenting their quality-related activities during design, procurement and construction phases of the plant. These activities include, but are not necessarily limited to, design, procurement, handling, storage, fabrication, installation, erection, inspection, cleaning and testing operations. This program is for those systems which have an effect on nuclear safety in order to assure vital material, equipment, and components conform with the requirements of all applicable codes, standards, specifications, and procedures. This program meets the requirements of the " Quality Assurance Criteria for Nuclear Power Plants" contained in Appendix B to Title 10, Code of Federal Regulations, Part 50, Licensing of Production and Utilization Facilities.

l l

i l

I B&R OCTOBER 31, 1980

,. , - . , c,, . . . ,. -

l 1.0 ORGANIZATION  !

l 1.1 QUALITY ASSURANCE PROGRAM RESPONSIBILITY The President of Brown & Root, Inc. has assigned to the Group Vice President - Power Group the operating responsibility for fulfilling Brown & Root's contractual obligation for design and construction of the South Texas Project (STP). The Power Group reports to the President through the Senior Executive Vice President - Operations. The Brown & Root corporate organization is shown on Figure 1.

The President of brown & Root, Inc. has delegated, through the ,

Group Vice President - Power Group to the Quality Assurance l Managar - Power Group, the authority and responsibility for establishing and enforcing the Brown & Root Quality Assurance Program. This authority and responsibility is delegated and s documented in the form of the following policy statement issued by the_ President:

" Brown and Root is dedicated to furnishing high quality, reliable plants and services.

All work shall comply with ASME Codes, legal requirements, and industry standards as de-fined in our contracts.

"At my instruction, this Quality Assurance Program has been established to assist in achieving these objectives. The authority for administration of this Program within the Power Group is hereby assigned to the Quality Assurance Manager who reports to the Power Group - Group Vice President.

"It is the Quality Assurance Manager's responsibility to provide program leader-ship, to assure compliance with Program requirements, to coordinate resolutica of problems, and to assure proper imple-mentation of improvements. Questions regarding this policy should be directed to the Power Group - Group Vice President for resolution, and if major difficulties cannot be resolved in this way, they will be referred to my_ office for a final de-

_. cision.

"To be fully effective, this Program must be understood, accepted, and fully implemented by each employee holding responsibility within the Program. Therefore, all super-visors shall coordinate their operations to assure complete compliance.

B&R OCTOBER 31, 1980

_-. x

" Changes to this Quality Assurance Program will be issued periodically in order to reflect current industry Codes and Standards.

Suggested improvements should be submitted to the Quality Assurance Manager for evalua-tion and program change."

To implement this policy, the QA Manager - Power Group has established a QA Department, including a South Texas Project QA Organization, to administer the QA Program during the design, procurement, and construction activities of the Project.

1.2 POWER GROUP ORGANIZATION The Group Vice President - Power Group is delegated the overall responsibility within the B&R organization for the design and construction of nuclear power plants. As shown on Figure 2, the Power Group includes the following departments:

Power Operations, Power Construction, Power Engineering, and Quality Assurance. The management of each department reports directly and independently to the Group Vice President - Power Group. Figure 2 depicts the separation and independence of the QA Department from other departments within the;Powc1 Grsup.

1.2.1 Power Operations Department The Power Operations Department (as shown on Figure 2) provides Management Services and Project Management activities for Power Group projects. The Management Services activities include administering the functions associated with estimating, cost control, schedule, project reporting, and materials management. Project Management provides the management of projects for which B&R has contractual responsibility for engineering, procurement, and construction.

Project Management functions include the administration and coordination of project cost, schedules, scope, and client contact.

For the South Texas Project, whose B&R project scope includes i engineering, procurement, construction and quality assurance

! activities, a Vice President / Project General Manager is i

assigned overall B&R management responsibility for these activities except the quality assurance activities. This l

position reports directly to the Senior Vice President - Power Operations.

l B&R OCTOBER 31, 1980

. _ . _ . - .. , . - 2 -

= .._

.t

1. 2. 2 - Power Construction Department The Power Construction Department (as shown on Figure 2).

provides for the management and administration of.all construction activities. . Such activities include, but are not necessarily limited to, field engineering, erection, installation, maintenance and storage of equipment, and management of subcontractors.

1.2,3. Power Engineering Department The Power Engineering Department (as shown on Figare 3) provides power plant design, design-related activities, design analysis, field service, licensing, and technology.

development. The department responsibilities are' implemented-through engineering standards and procedures necessary to control and document design activities.

1.2.4 Quality Assurance Department Under the direction of the QA Manager - Power Group, the QA 4

Department is responsible for the implementation of the QA

' Program in accordance with B&R Corporate Policy; Nuclear Regulatory Commission (NRC) Regulation,-10CFR50, Appendix B; the Client's contractural Quality Assurance Plan; and the Quality Assurance Program identified to the NRC. The QA

Department (as shown on Figure 4) prepares, coordinates, and l

issues the Power Group QA program and procedures. Additionally,

.the QA Department assures compliance to procedures through periodic audits / surveillance of the B&R quality-related acti-vities.

i The QA Manager - Power Group has the following primary functions j and authority:

1. Preparing, reviewing, approving, and implementation of Power Group QA procedures necessary to enforce the QA Program.

2. Review of design, procurem.ent, and construction activities ,

l to verify and enforce ~ compliance to the QA Program.

3. Taplementing QA activities related to procurement, such as procurement document review, source surveillance inspections, and audits.

4

4. Implementing site QA functions related to construction activities.

1 B&R 0CTOBER 31, 1980

,+ye ,,, e - gy W 6w y gr .e e P $

• w - .D %% ' ~ - - ---w=,s w -e, e w w ,-w-r--wr+

, i l

5. Implementing stop work authority when necessary to  ;

enforce quality requirements.

6. Preparing and issuing periodic reports to B&R Management-

'and HL&P on the status and effectiveness of the QA

Program.

7. Conducting quality audits of Vendors, Engineering, i Procurement, Construction, and Project-Quality Assurance activities. These audits are conducted independent'of 4

project control through the .QA Audit Manager.

The minimum qualification requirements for the position of QA

Manager-Power Group is that.the appointed individual, at time of assignment to the position, must have six years experience

-in the field of quality assurance, preferably supervisory ~

experience'with design and-construction activities of a nuclear power plant. At least one year of'this six years experience must be nuclear power plant experience in the overall implementation of a quality assurance program. A l minimum of one year of this six years experience must be i' related technical or ac.demic training. A maximum of four years of this six years experience can be fulfilled by related technical or academic training.

1.3 SOUTH TEXAS PROJECT ORGANIZATION I 1.3.1 Project General Management

[ The Project L 1eral Management (see Figure 5) for the South l Texas "roject directs the overall B&R project activities,

except those areas of responsibility of the Project QA l Department. The Vice President / Project General Manager and j his staff are singularly responsible within the B&R j organization for overall project planning, coordination of the

efforts of Engineering, Material Management and Construction, identification and resolution of problems, monitoring job progress and cost performance, and contact with HL&P.

1.3.2 Project Site Organization l The Vice President / Project General Manager is represented, on 1 site, by the STP Deputy General Manager / Site Manager, who ,

directs the' overall B&R project site activities, except those 4 areas of responsibility of the Project QA Department. The project site organization is shown on Figure 6. The Assistant Engineering Manager - Site Design Engineering receives technical direction from the Engineering Project Manager, and project direction regarding administration, controls, and policy from the Deputy. General Manager / Site Manager.

i B&R OCTOBER 31, 1980 l

- 1

. _.._ _ _,...,_, _ ,_ , _ , _ _ , _ . , _ , _ . . _ , , ._, ; ,1 ;, ,, . .

-~ - l

- 1.3.3 ' Project Engineering Organization  !

The STP. Engineering- Project Manager provides: technical direction and coordination of the design. The' Engineering Project Manager reports to the Senior Vice President / Chief ~

Engineer - Power Engineering who provides technical' direction and guidance. In addition, the Engineering Project Manager reports to the Vice President / Project General Manager for project direction regarding administration, controls, and policy. Tre Project Engineering organization is shown on Figure 7.

Design 'fuality Engineers within the Engineering organization recommead engineering quality policy, ensure that adequate

! . procedures are developed, and review conformance to these procedures by Engineering personnel.

l.3.4 Project Materials Management Organization The STP Materials Management organization, interfacing with B&R Departments and HL&P's Purchasing, performs purchasing, subcontracting, expediting, material. control and warehousing activities. .The coordination and establishment of project procedures for these activities are the responsibilities of

. the Materials Manager. The Mate. rials' Manager report's to the Vice President / Project General Manager. The Materials Management organization is shown on Figure 8.

1.3.5 Project Quality Assurance Organization The d12 Quality Assurance organization is supervised by the

~

Project QA Manager (PQAM) who has been delegated sufficient -

authority to assure proper implementation of the QA Program, proper training of QA personnel, and proper documented evidence of the overall QA Program. The Project QA Manager reports directly to-the QA Manager - Power Group on QA matters and personnel administration matters. The Project QA Manager coordinates eith the Vice President / Project General Manager

regarding project administrative matters. The Project QA Manager receives programmatic direction and communications from the HL&P STP QA Manager. Reporting to.the Project QA Manager are the following department-managers

1. Quality Engineering

2. Quality Control i

3. Quality Systems i

B&R OCTOBER 31, 1980 4

.-~.4-.- ,#, .-- ,y . .,,, ,,..+s%3 m m re-. . = *p^ r - ,--,1.,.k' -7'~~~[.^.-

' b[. ';,. h \ ,* . JE. ---% , . , , . - - . - - - ,- ,-

~

l

.4. -Vendor Surveillance / Houston Coordination

5. Site Surveillance-

.The Quality Engineering function encompasses the major disciplines (i.e.,-Mechanical, NDE, Electrical, Instruments &. .

Controls, Civil, Structural, and certain specialized functions-such as coatings and insulation). Quality Engineers control quality assurance activities'related to their individual disciplines. The Quality Engineers work closely with the lead

~

discipline counterparts in Engineering and Construction to -

resolve in a timely fashion, problems that are identified ,

during construction to ascure that the'cause is determined and adequate corrective action is accomplished. The Quality Engineers perform reviews of engineering documents, purchase orders, and-nonconformance reports for assuring conformance to quality requirements, and prepare quality control inspection plans. The Quality Engineers participate'in planning QA activities-(procedures, plans, training, etc.) associated with specific construction activities. Finally, the Quality Engineers assure'that the QC inspectors are provided clear instructions and acceptance criteria.

Quality Control inspects construction activities puqsuant to inspection planning instructions prepared by Quality Engineering. Quality Systems coordinates the maintenance of '

- QA records, records turnover procedures, the QA training and certification program, and nonconformance trend analysis program. Vendor Surveillance / Houston Coordination assures that inspections and audits of vendor activities are performed, and serves as the interface between QA and Houston Engineering and Procurement activities. Site Surveillance performs surveillance over site activities at the direction of the Project QA-Manager and verifies the adequacy of the.

corrective actions taken in-response to this surveillance.

The STP Quality Assurance organization is shown on Figure 9.

A more detailed listing of the functions of each Quality Assurance organizational component is provided on Table 1.

The Project QA Manager has the following primary functions and authority:

1. Maintains an organization chart and job descriptions which define QA personnel duties and. responsibilities.

2. Prepares, approves, issues, and ensures the implementation of Project Procedures developed to control the activities of the QA organization.

l i

B&R OCTOBER 31, 1980 i

, ~: , , . - - , ,,-,..,,,,-,,--,,-,,-..,-v,. =-.,n<--. -: - - - , ,, z :,: n:u, : = -;-,n -,. . ..,

3. Provides for indoctrination and training of QA personnel.

4. Interfaces with' the QA Manager - Power Group and 'other B&R organizations on quality related Project matters.

5. Ensures receipt inspection of items; ensures that identification and control of items are maintained until turnover;. ensures special processes are controlled and accomplished by certified personnel and procedures; and ensures the calibration of measuring and test equipment.

6. Reviews and approves nonconformance reports and corrective action requests.

7. Maintains QA records in accordance with applicable proce-dures.

8. Implements stop work authority when necessary to enforce project quality requirements.

9. Reviews the status of the QA activities with he QA Manager - Power Group and the HL&P STP QA Manager.

10. Trends nonconformances and submits reports to HL&P, the QA Manager - Power Group, and other affected department management.

11. Submits project quality documents to the QA Manager -

Power Group for review by the Quality Assurance Management Review Board (QAMRB).

The minimum qualification requirements for the position of Project QA Manage: .s that the appointed individual, at time of assignment to the position, must have six years experience in the field of Quality Assurance, preferably supervisory experience with design and construction activities of a nuclear power plant. At least one year of this six years experience must be nuclear power plant experience in the overall implementation of a quality assurance program. A minimum of one year of this six years experience must be related technical or academic training. A maximum of four l years of this six years experience can be fulfilled by related technical or academic training.

1.4 QA AUTHORITY AND ORGANIZATIONAL FREEDOM foassuretheestablishme.'tandoperationoftheQuality Assurance Program, B&R personnel performing the QA functions have the freedom to identify quality problems and provide means for verifying solutions have been implemented. The QA B&R OCTOBER 31, 1980

:

a organizations have sufficient independence, authority and technical expertise to carry out the program in an efficient and effective manner. This is assured by the B&R QA Man gement reporting to management levels above and independent from the direct influences of the pressures of

' project production.

It is the respons;bility of each part of the B&R organization to implement activities delegated to it through the QA Program. The policies and procedures established and L implemented by the QA Department provide the authority and organizational freedom necest.ry for the assigned QA personnel to implement QA Program activities. Such activities include, but are not necessarily limited.to, the identification of quality problems; the initiation, recommendation, or provision for solutions; the verification of implementation of solutions; and the control of further processing or installation of nonconforming items until an approved disposition of the deficient or unsatisfactory condition _is

effected. Such activities further include the review and i

approval of quality-related procedures, training and certification of QA personnel, and auditing of quality t

activities.

2.0 QUALITY ASSURANCE PROGRAM 2.1 BROWN & ROOT QUALITY ASSURANCE PROGRAH SCOPE The Brown & Root STP QA Program complies with the requirements of ANSI N45.2 Standards and implementing Regulatory Guides identified on Table 2. The B&R STP QA Program applies to design, procurement, and construction activities affecting the quality of safety-related structures, systems, and components.

These safety-related items are identified on Tables 3.2.A-1 and 3.2.B-1 of the STP Final Safety Analysis Report.

2.2 BROWN & ROOT QUALITY ASSURANCE PROGRAM DESCRIPTION 2.2.1 Quality Assurance Program Documentation The written policies that implement the QA Program are contained in the QA Manual. The QA Manual is the key document for controlled implementation of the QA Progran. The QA Manual establishes the responsibilities and requirements for implementation of the QA Program and identifies the requirements for the procedures and instructions necessary to control QA Program implementation. The issuance and revision of the QA Manual is controlled by Quality Assurance.

Compliance to the requirements of the QA Manual is mandatory.

B&R - OCTOBER 31, 1980

. - - .=

I The mandatory requirements for implementation are communicated to the organization-by means of the' management statement-of policy as part of the QA Manual and related project documents, and to other organizations through special clauses in procurement and contract documents.

Project. procedures -and program documents issued by the cognizant organizations describe the methods and controls for implementing l the QA Program and QA Manual. requirements. Tables 3 through 6 provide a listing of the current implementing project procedures j and their relationship to the 18 criteria of 10CFR50, Appendix

' B.

The QA Program is approved by the Group Vice President - Power Group. The QA Manual is reviewed and approved by the QA Manager - Power Group. Project procedures and program documents ,

are reviewed by and approved by the cognizant managers responsible-for initiation of these documents.

2.2.2 Supplier and Subcontractor Quality Assurance Program Require-ments Section 4.0 of this program includes a description of the

• methods used to impose the applicable QA Program requirements on suppliers and subcontractors.

2.2.3 Personnel Indoctrination, Training, and Certification The QA Manual describes the requirements for indoctrination, training, and certification of all Power Group personnel who

~

perform qualf s-related activities. Each organization, as i required, wim levelop procedures, and/or instructions that

identify the material to be presented, methods of presentation,

4. schedules for conducting sessions, and the individuals to be

• trained. The indoctrination, training, and certification program is such that:

1. Personnel performing quality-related activities are instructed as to the purpose, scope, and implementation ,

of the quality-related procedures and instructions. This

training occurs prior to implementation of a new or revised procedure or instruction.

2. Personnel performing quality-related activities are trained and qualified, as required, in the principles and techniques of the activity being performed.

3. The scope, the objective, and the method of implementing the indoctrination and training program are documented.

i B&R OCTOBER 31, 1980

. . ._ . . _ _ - . . . . . . . . ~s . ,e _ _ . . . ,_._._1. _ _ C ..r " . _ - . --

4. Proficiency of personnel performing quality-rela.ed l activities is maintained by scheduled refresher training and reexamination, and/or recertification, where appropriate.

The Project.QA Manager developes, implements, and maintains an indoctrination, training, and certification program for all QA

~

personnel. This program meets the requirements of Regulatory Guide 1.58'as identified on Table 2.

2.2.4 Stop Work The QA Program provides QA personnel with stop-work authority during the design and construction phases. This authority is

delineated in written procedures and is applied to all work directly performed by B&R and/or Subcontractors.

2.2.5 Management Review The Quality Assurance Management Review Board, established by and under the direction of the Group Vice President - Power Group, consists of selected upper management such as the Senior Vice Presidents of Power Group, Power Operations, Power Construction, Power Enginee-ing, ar.d the QA Manager ,- Power Group. On a regular basis, members of the QAMRB meet to review reports of audits, corrective actions, monthly activities, and performance trends, as well as special problems which cannot be resolved at lower management levels.

At least once a year an audit of the QA Program is conducted by a special evaluation team independent of the project activities. The audit team is selected by.and reports to the QAMRB and is charged with the task of auditing QA Program activities performed on the project to verify compliance with the QA Program requirements.

2.2.6 QA Program Revision If programmatic change is required to those functions herein described, Brown & Root will provide prior to implementation a proposed amendment to this QA Program description to Houston Lighting & Power Company (HL&P) for its review and approval.

! Tables 3 through 6 of this program description provides a listing of those procedures currently in effect for control of the Quality Assurance, Engineering, Materials Management and Construction activities. New and revised procedures are prepared and approved in a manner commensurate with the

, schedule of quality-related activities on the Project.

Revised procedure lists, Tables 3 through 6, will be submitted to HL&P semi-annually.

B&R OCTOBER 31, 1980

_ . . _ . - . . . . -~ r, v -

J 3.0- DESIGN' CONTROL

.The Engineering Procedures Manual implements the' Quality Assurance Pregram as it applies to nuclear power plant design i

, , activities. Engineering Procedures, contained in the manual,- -

provide for the systematic application of design control  !

requirements such that the design is defined, controlled, and verified. Basic design control requirements for identification, preparation, review, document control, change control, and records are applied to the design of systems, structures, and components; and design control requirements are applied, on an item by item basis, as a function of importance to safety and

~

design complexity.

Design control is the responsiblity of the Engineering Project-Manager (EPM) who reports to the Vice President / Project General Manager for project direction and to the Senior Vice President-Power Engineering for technical direction. Design activities are controlled on a project basis. Design responsibilities are divided into specific _ discipline areas and the cognizant Discipline Project Engineer reports to the EPM for Project direction and to the EPM and his home Discipline Manager-t jointly for technical direction. The EPM is assisted by Assistant Engineering Project Managers (AEPM) who are individually responsible for system design, physical design, site engineering, and support activities.

3.1 DESIGN CONTROL REQUIREMENTS The following design control requirements are implemented to ensure that all design activities are conducted in a manner that is conducive to a quality power plant design:

1. A design control system is established to document the methods of accomplishing and controlling essential design activities.

2. Design documents such as calculations, diagrams, specifica-tions, and drawings are prepared and records developed such that the final design is traceable to its sources. j

3. Design activities,' documents, and interfaces are controlled

to assure that applicable input such as design bases, regulatory requirements, codes, and standards are incorpo-rated into the final design.

4. Design input requirements, including design criteria, are

! documented and their selection reviewed and approved.

! l l

B&R OCTOBER 31, 1980

.. . _ _ . _ . _ . _ . _ . . . .- . ~ ,, _ . , - m ._ -.m.~ . a. .._ ,,.-..=_.v.m--

l 1

5. Desiga documents include an indication as to their impor-tapee to safety and shall specify the quality characteris- l tics, including materials, parts, equipment and processes, l that are essential to func*. ions of structures, systems, l j

and components. Design documents also include, as appro-priate, acceptance criteria for inspections and tests. l

6. Design control measures are applied to items such as  !

reismic, stress, thermal, hydraulic, radiation, and accident analyses, as they apply to the development of design input or as they are used to analyze the design.

7. Safety related and/or Seismic Category 1 designs are verified for adequacy and accuracy through independent objective review of design documents by individuals competent in the subject activity. This verification may

+ include the use of alternate or simplified solution

^

methods or qualification testing, as appropriate.

8. Design changes, including engineering, vendor, and construc-tion originated changes, are controlled in a manner commensurate with the control imposed on the original design.

9. Document distribution is controlled such that all individuals-using a design document or its results and/or conclusions for further design work can be notified if the document is revised or canceled.

10. Design documentation includes evidence that design control requirements have been satisfied.

3.2 DESIGN CONTROL ACTIVITIES The following design control activities are conducted to ensure the engineering quality of all safety-related and/or Seismic Category I systems, structures, and components of a nuclear power plant.

3.2.1 Procedure Preparation Engineering Procedures are prepared to establish a design control system. These procedures address appropriate design control requirements and document the methods of accomplishing and controlling essential design activities. Such Engineering procedures are submitted to Quality Assurance for review.

l I

I B&R OCTOBER 31, 1980

- . -,. . . -~ . .,, - , , ,

3.2.2 Standard, Guide, and Instruction Preparation j Technical standards, guides, and instructions are prepared by Project Engineering Disciplines to establish appropriate i technical methods and requirements for design development.

These documents may include, but are not limited to, methods and requirements pertaining to items such as stress, thermal,  !

hydraulic, seismic, radiation, and accident analysis, material l c.qmpatibility, and accessibility for inservice inspection, maintenance, and repair. Technical standards, guides, and' instructions are considered to be design documents subject to all applicable design control requirements.

3.2.3 Design Development Control Design development is controlled by preparing design documents, including calculations, diagrams, specifications, and drawings, according to a well defined design process. The design process provides for developing the design in progressing detail, from conceptual design to final procurement documents and production drawings that are used to procure and erect structures, systems, and components.

3.2.4 Design Input Control Design input requirements are documented, and reviewed, to ensure that their effect on the final design is adequately considered. These requirements include, but are not limited to, design criteria, regulatory requirements, codes, standards, and requirements for testing, inspection, maintenance, handling, storage, and shipping. Assumptions are identified as "Prelimi-nary" to provide for tracking, and verification prior to records turnover.

3.2.5 Design Verification Nuclear power plant designs are verified for adequacy and accuracy through review of design documents by a technically qualified individual (s) other than the originator (s). Design verification may include techniques such as the use of alternate or simplified solution methods or qualification testing. The selection of verification technique and depth of review are based upon the complexity of the design, the importance of the design to safety, and the extent of any adverse conditions that influence design; but in any event design reviews ascertain that the design correctly and accurately represents design input and that the design method and assumptions are appropriate for the stated objective of the design. Safety related features of the power plant design'are verified, in accordance with the above paragraph, through independent objective review of B&R OCTOBER 31, 1980

m des'ign' documents by individuals or groups having no direct or immediate supervisory responsibility for developing the design under consideration. When the verification process is done by an individual _ review, such reviews will be conducted by persons whose primary assignment is the verification task. In particular, independent reviewers may not (1) be_the preparer (s) of the design, (2) have immediate supervisory responsibility for the individual (s) performing the design, (3) have specified a-singular design approach, (4) have ruled out certain design considerations, or (5) have established the design input for the particular design aspect being reviewed. Additionally, indeoendent objective reviewers must be adjudged to be technically l qualified by their Discipline Project Engineer, to have such

! qualification documented, and to provide documented evidence ,

regarding the extent and results of their review. All such i reviewers most receive specific training for this task and the

results of.their work is reviewed by Engineering Management. '

Design reviews are documenced on specific forms to provide objective evidence of their extent and results; and where i qualification testing is used as part of the review process, the tests are identified, documented, and performed in accordance

~

L.

with written procedures and instructions.

, 3.2.6 Design Document Control The design of a structure, component, or system is conveyed by one or more of the following documents which are prepared, reviewed, approved, and distributed according to Project procedures:

1. System Design Descriptions i

2. Technical Reference Documents

3. Purchase Specifications

)

4. Construction Specifications

5. ASME Design Specifications

6. Calculations 4

7. Drawings 3.2.6.1 System Design Descriptions ihebasisforthedesignofeachsystemiscontainedina System Design Description (SDD). An SDD identifies the system's design criteria including design inputs and their-sources; applicable Code,' standard, and regulatory requirements; operation

~

i 6

B&R OCTOBER 31, 1980

, . . . . ..e, - , . -  %-.-,-,...e4-- . gm y ~%..4'*eC'*. 1 E N* /.1 # M.L"_' .'~. ~._ , _ . ---,b. - , - -,.si,h-_3-,--.-w-,

l l

4-parameters and environmental conditions; structural loadings, mechanica1' loadings,'and electrical requirements; and safety, quality assurance, material, fabrication, and construction j requirements.

h

- When the design of a system is initially developed, the basic design requirements.are published in an SDD that is unique'to the system. As the design is finalized, the' design basis is reflected in calculations, Specifications, Technical Reference 1

Documents, and drawings. The status of each of these documents

- is tracked by the cognizant Froject Engineering Discipline in.

accordance with applicable.?roject Engineering Procedures, and as these design documents reach completion, the SDD is revised to reflect the as-designed configuration.

l 4

3.2.6.2 Technical Reference Documents =

The design of a system, as conveyed by an SDD, may be supported by one or nore Technical Reference Documents (TRD), which may cover more than one system. A TRD is not an SDD, but~it may l contain design criteria. In such cases, these design criteria will augment or supplement.the design criteria contained in an SDD(s). Technical Reference Documents may include, but are not limited to, the following: design criteria (other than those contained in SDDs); standard attachments to Purchase Specifications; reports including Design Reports, Stress Reports, test reports, etc.; lists (e.g., valve lists, line lists, etc.); B&R Standards; special instructions; and, Design l

Specifications.

3.2.6.3 Purchase Specifications Purchase Specifications are prepared to purchase engineered equipment and/or services. Purchase Specifications are prepared according to a standard format; however, bulk material and I some minor catalog items may be purchased by a Bulk Material i . Specification.

i 3.2.6.4 Construction Specifications ,

When necessary, Construction Specifications are prepared by i Engineering to provide requirements for the construction of l 1 specific items. Construction specifications may be in a l format similar to a Purchase Specification or issued as a Technical Reference Document.

3.2.6.5 SME Design Specifications ASME Design Specifications are prepared with sufficient detail

-to provide a complete basis for design in accordance with the ASME B&PV~ Code. ASME Design Specifications include, as a minimum:

i B&R -

16- OCTOBER 31, 1980 i 1

i u...e= ,. e ae** **'"9 .****e -e. e""

W 2 = -- -*m..--.m. -* ,u%.u.=..an,,=r% -

.e5 . egg *= - e e ..

~

~1 i

1. The functions of items including any. dimensions upon which functional performance depends.

2. Design requirements, including mechanical and operating loads.

3. Environmental conditions,Lincluding radiation conditions.

4. Code classification of items. .

5. Definition of boundaries, inclu' ding dimensional locations, forces, moments, and structural requirements.

6. Material requirements, where applicable.

t

7. Reference to other documents where' operating requirements are defined when the operability of a component is required.

2-

8. Applicable Code by year and addenda.

3.2.6.6 Calculations i Manual and/or computerized calculations are prepared as a basis for system designs.

3.2.6.7 Drawings Drawings are prepared, according to a standard format, to i- convey design, purchase, fabrication, and/or construction requirements.

3.2.7 Quality Assurance Review Quality Assurance reviews and approves procurement specifications prior to issue to ensure that design characteristics can be

! controlled, inspected, and/or tested and that appropriate inspection and test criteria are identified. In addition, the i review also ensures that the design document reflects sufficient t acceptance criteria to allow verification that quality assurance activities have been satisfactorily accomplished.

1 3.2.8 Design Quality Engineering Review 4

Design Quality Engineering reviews and approves certain design documents, including specifications, drawings, System Design 1 l

Descriptions, and Technical Reference Documents, to ensure that'all applicable design control requirements have been satisfied. As a minimum, these reviews ensure that the document has been prepared, reviewed, and approved in accordance with the applicable procedures; that all review comments have been 1

B&R OCTOBER' 31, 1980

- . , . - . , , . . , ., - , n n - -- m.. _; =, -- : - -. . .- ,

I l

received, resolved, and incorporated into the document; and that all documentation, which is required to provide ev!.dence that the applicable design control requirements have been satisfied, has been properly prepared and filed. Drawings are reviewed on a randomly selected basis subsequent to their issuance. Design Quality Engineering reports to the Engineering Project Manager and is not a part of the Quality Assurance Department.

3.2.9 Design Interface Control Internal design interfaces are controlled thraugh review and approval of design documents by individuals and groups whose design activities are contingent upon the design reflected in the documents. Design interface reviews consider pertinent interface paraceters, including, configuration, dimensions, process, performance, loads, materials, inspection, testing, operation, safety, and fabrication. These reviews are documented on specific forms to provide objective evidence of their extent and results. In addition, design interfaces are further controlled by ensuring that approved design interface documents are distributed to the reviewing organizations and other individuals and groups using the documents in support of their design activities.

Interface with the NSSS supplier design is controlled through HL&P by identification and review of documents that define NSSS design inte._;ees with the balance of the plant. Interface with supplier / vendor designs is controlled through the purchasing documents and, in some cases, through the use of written Interface Agreements. Design requirements are identified in the purchase specification.

3.2.10 Design Change Control Changes originating from Engineering, suppliers, Construction, HL&P, or resulting from the nonconformance system are controlled from their initiation through their approval and distribution to ensure that~their effects are properly considered and implemented.

Cha ges originating from within Engineering can result from design reviews, unsolicited comments, Engineering Design Deficiencies or from other sources such as interfacing designs.

Requests for changes from vendors are submitted on a Supplier Deviation Request (SDR). Requests for changes from Construction are submitted on a Field Change Request (FCR) or may result from a Nonconformance Report (NCR). NCRs that are dispositioned use-as-is or repair-and such disposition represents a departure from a design document,. require a change to a design document OCTOBER 31, 1980 B&R I

> l j

through the system described below prior to approving the NCR. l Requests for_ changes originating from HL&P may be transmitted via (1) a numbered letter, which is tracked on an open item list, or (2) a Field Change Request (FCR). In addition, the need for design changes may also originate from the resciution of Audit Deficiency Reports or Corrective Action Requests.

Designchanges,regardlessoft$eirpointoforigin,aremade

- through the Design Change Notice (DCN) System. This system includes a special DCN form to ensure that the primary design document is properly identified, the source of the change is listed, in the justification for making the change is described, the effect of the change on the design basis is considered, the technical rationale necessary to ensure the engineering quality of the change is documented, the need to revise other design documents is identified, the need for changes to licensing documents is considered, and that ALARA review of the change has been completed, if necessary. The form also includes adequate space for the necessary review and approval signatures.

Proposed design changes are verified through review and approval of design documents by either the same individuals or groups responsible for verifying the original design or designated alternates. Quality Assurance reviews proposed design changes that affect the. quality related aspects of Purchase and Construction Specifications as they are defined by inspection,

testing, Code, standard, special process, and/or regulatory requirements. In addition, proposed design changes originating at the construction site either from an FCR or NCR are reviewed by a Change Review Board, either at the Site or in Houston.

j This board consists, as a minimum of representatives from each of the affected Project Engineering Disciplines, Design Quality Engineering, and Engineering Project Management. The Change Review Board does not actually conduct reviews, but instead ensures that interfacing discipline reviews have been conducted, and if necessary, takes management action where interface problems cannot be resolved at the discipline level.

When change requests originate from the construction site, the Assistant Engineering Manager-Site Design Engineering may

-approve the change through the DCN System. To ensure that the expertise necessary for the control of design changes is available at the construction site, Engineering maintains a staff of technically qualified Project Site Engineers. These engineers are members of an Engineering Discipline in Houston.

Additionally, the DCN sistem provides the capability, under controlled conditions, for construction to proceed pending approval of the design change by Houston Engineering. In these cases, provisions are made for the construction to be

tagged to ensure that it is accessible for repair / rework l

B&R . OCTOBER 31, 1980

, s T

should the change be disapproved or for final inspection should the change be approved. Once appraved, design changes are distributed to all individuals and groups using the original design in support of their activities.

With respect to field activites, the design change system provides for a "real time" maintenance of the as-built configura-tion. The design documents are revised prior to releasing

' construction to proceed with the change. Construction and inspection personnel are notified of the change prceptly through a computerized tracking system. When construction of an item has been completed, part of the final inspection process will include the verification that the as-built configura-tion conforms to the design. As-built verification inspection plans will be prepared by Quality Engineering and reviewed by-Engineering. These plans will then be used for final inspection ,

and will be included in the records.

3.2.11 Design Deficiencies Design deficiencies identified in design documents subsequent' to their having been design verified are documented, tracked, and closed out using a form titled Engineering Design Deficiencies (EDD). EDD's may also be used to identify, track and closeout deviations from procedural requirements. EDD's may be written by an individual in the Engineering Department who identified such a deficiency. Procedures allow an individual to appeal Power the closeout of an EDD to the Senior Vice President Enginering. Significant EDD's and adverse trends detected as a result of EDD activity are reviewed with the Engineering Project Management at the time of detection.

3.2.12 Records Retention Design documents and changes thereto are filed and maintained to ensure that a complete record of design development is established and accessible. These records include information necessary to justify the design and provide evidence that design' control requirements have been satisfied.

4.0 PROCUREMENT DOCUMENT CONTROL l Brown & Root departments that are responsible for the preparation, or participation in the preparation of Inquiry Packages, Material Requisitions, Purchase Orders and Subcontracts establish procedures to delineate the sequence of activities necessary to prepare, review, approve, issue, and control these documents.

l

' The procedures governing these procurement activities also identify the quality requirements, item identification, documentation tracevoility, technical and commercial requirements OCTOBER 31, 1980 B&R l

l . ;- :. . g _ _. .- .. _-

3 _

that are to be' imposed'upon Suppliers and Subcontractors.

These procedures are reviewed by, and as applicable, approved

.by Quality Assurance to ensure that the procedures comply with quality requirements. The written procedures regarding the procurement activities ensure that:

1. QA requirements of 10 CFR 50 Appendix B and.those applicable ANSI.N45.2 Standards and implementing Regulatory Guides are identified in the procurement document.

2. QA requirements are inspectable and controllable, and acceptance and rejection criteria are defined.

3. Procurement documents contain or reference applicable i

design basis technical requiremants including applicable l

regulatory requirements, drawings, specifications, codes, F standards, test and inspection requirements, identification requirements, special process instructions, packaging and P shipping instructions.

4. Procurement documents identify the documentation (e.g.

dre. wings; specifications; procedures; inspection and fabrication plans; inspection and test records; personnel and procedure qualifications; material, chemical and physical test results) to be prepared, maintained, and submitted, to the purchaser for review and/or approval.

5. Procurement documents identify those records which require retention, control and maintenance.

6. Procurement documents provide for KL&P and B&R right of access to supplier's facilities and records for' source inspection and auditing.

7. Procurement documents include requirements for invoking appropriate quality and regulatory requirements in subtier supplier procurement documents.

4.1 PROCUREMENT DOCUMENT PROCESSING 1 4.1.1 Procurement of Engineered Equipment Engineering is responsible for the initiation, development, preparation, and verification of specifications for engineered equipment as defined in Section 3.0 The specification is reviewed and initially approved by Engineering and Quality Assurance. The specification is then sent to Houston Lighting

& Power.(HL&P) for review and approval. After HL&P approval

^

of the specification and return to Engineering, it'is submitted as part of an inquiry package to Purchasing which adds other sections to the package that relate to the commercial aspects.

B&R OCTOBER 31, 1980 l l

l

. . . - - . . - - . . . , , ~ . , . , - , - ,, .n., .nn. .,. . , n., .re .,m.,nR- ~ ., , - - . . . -

. - - - - . - _ ~ - --- - -.

.q l

- -Purchasing then transmits the completed inquiry package as a Request for Quotation to the prospective bidders.

J Bids are returned through Purchasing to Engineering and to l Quality Assurance. Engineering provides the technical evaluation 4

of the submitted bids, and Quality Assurance provides a quality evaluation. Purchasing performs a commercial evaluation of-each bid. Engineering then'combinec the technical evaluation with the quality and commercial evaluations submitted by Quality Assurance and Purchasing, and prepares a combined bid recommendation for submittal to HL&P.

After receiving HL&P approval to proceed with the recommended

' procurement action, Engineering prepares, reviews, approves i and forwards a Material Requisition to Quality Engineering for review and approval. After Quality Engineering approval the i Material Requisition is returned to Engineering who forwards the completed requisition to Purchasing. Purchasing then prepares the Purchase Order. The final procurement package, -

including the Purchase Order, drawings, specifications, proce-dures, etc., that comprise the total package to be forwarded to the supplier.is transmitted to HL&P for approval.

The Purchase Order and any other pertinent commercial / purchasing data is maintained by Purchasing as purchasing records for i filing and retrieval purposes. This, and all other documents, including Inquiry Packages, Quotations, and Material Requisitions, which pertain to the Purchase Order is organized and filed in systematic sequence and become the documented and retrievable

' support of the B&R transaction. The QA Record file for these procurement documents is maintained jointly by HL&P and B&R.

4.1.2 Procurement of Bulk Materials

! Engineering is responsible for the initiation, development, preparation, and verification of specification for safety-related bulk materials as defined in Section 3.0 The specifica-

tion is reviewed and initially approved by Engineering and Quality Assurance. The Specification is then sent to Houston Lighting & Power (HL&P) for review and approval. After HL&P l

approval of the specification and return to Engineering it is  ;

submitted as part of an inquiry package by Engineering to-

' -Purchasing which adds other sections to the package that ,

relate to the commerical aspects. Purchasing then transmits  !

the completed inquiry package as a Request for Quotation to 4

- the prospective bidders.

Bids are returned through Purchasing to Engineering and to Quality Assurance. Engineering provides the technical evaluation of the submitted bids, and Quality Assurance provides a quality A

l B&R OCTOBER 31, 1980

l V

evaluation. Purchasing performs a commercial evaluation of each bid. Purchasing then combines the technical evaluation f with the quality and commercial evaluations submitted by Quality Assurance and Engineering, and prepares a combined bid )

recommendation for submittal to HL&P. l I After receiving HL&P approval to proceed with the recommended procurement action, Engineering prepares, reviews, approves and forwards a Material Requisition to Quality Engineering for review and approval. After Quality Engineering approval, the Material Requisition is returned to Engineering for forwarding  :

to Purchasing. Purchasing then preparesLthe Purchase Order.  !

The final Purchase Order package that comprises the total package to be forwarded to the supplier is transmitted to HL&P for approval.

The Purchase Order and any other pertinent commercial / purchasing data is maintained by Purchasing as purchasing records for filing and retrieval purposes. This, and all other documents including Inquiry Packages, Quotations, and Material Requisi- l tions, which pertain to the Purchase Order is organized and i - filed in systematic sequence and become the documented and retrievable support of the B&R transaction. The principle difference between bulk material purchases and engineered l

! equipment purchases is that the bulk material items are purchased to manufacturer's specifications consistent with the desired qtslity, engineering standards, or Code requirements in lieu of B&R Engineering developed specifications.

4.1.3 Procurement Of Subcontracts Subcontracts are categorized as either Engineering or Field Subcontracts. Engineering Subcontracts are utilized to procure services to a defined scope of work contained in an Engineering Specificaton. This may include specifications and materials

on equipment to be furnished under the subcon,-act. Field Subcontracts are utilized to obtain services in accordance with a specification prepared by Construction or Quality i

Assurance. The procedures and procurement documents associated with procurement of Engineering Subcontracts tre similar to  ;

those utilized for the purchase of Engineered Equipment. The i associated procurement documents will receive the appropriate Engineering and Quality Assurance reviews as described in Section 4.1.1.  ;

4.2 REVISIONS Revisions to Engineering Specifications shall be reviewed and approved as described in Section 3.0. Revisions to Purchase l Orders / Subcontracts shall be the same as the original as described in subsections 4.1.1 and 4.1.3.

1 B&R OCTOBER 31, 1980

. , - m.,- , , _ , , _ - . - , - - , . , , , - . . , - . - - ,,--,m,,-4 -,w , - , ---r-.,%e v..---gw,,,.-

- , = or ~ - ,-c., ,.m, #,.,,,--.-r-,

5.0 INSTRUCTIONS, PROCEDURES _AND DRAWINGS Engineering, Materials Management, Construction, and Quality ,

Assurance ensure through planning techniques that activities  !

affecting quality are set forth by written instructions, procedures, and drawings, 1nd are accomplished in accordance with these instructions, procedures, and drawings. Instructions, procedures, and drawings shall include appropriate quantitative (dimensions, tolerances, design limits, etc.) and qualitative (tests, samples, comparative workmanship, etc.) criteria for determining that important activities affecting quality have been satisfactorily completed. Instructions, procedures, and drawings are developed to ensure that applicable documents are made available in a manner commensurate with the schedule of quality related activities on the Project.

5.1 PREPARATION e

The responsibility for the origination and maintenance of procedures'and instructions is assigned to the organization or department responsible for implementing the activity. Engineering i prepares procedures to control engineering activities affecting product quality and for preparing procurement and construction specifications containing definitive qualitative and quantitative

acceptance criteria by which it can be determined whether an i important activity has been satisfactorily accomplished.

Materials Management prepares procedures to control procurement activities. Construction prepares procedures to control the construction activities being performed at the Project site.

Quality Assurance prepares QA procedures, QC procedures, nondestructive examination (NDE) procedures, and QA personnel I training procedures to control the Project QA activities and to ensure control and compliance with quality requirements by i organizations responsible for quality activities. Procedures integrating quality / inspection requirements and other construction

or procurement activities may be used. When such procedures are required, procedures are developed defining the preparation, i review, approval and issuance of integrated procedures. Reviews and approvals of intearated procedures and revisions thereto are performed by the departments responsible for implementing i- the activities defined in the integrated procedure.

5.2 REVIEWS Instruction, procedures, and drawing documents are reviewed l and approved as described in other sections of this program.

Reviews are made for technical content, appropriate quantitative

and qualitative acceptance criteria, Code .nd regulatory

requirements, clarity, and conflict with other documents approved for the Project.

B&R OCTOBER 31, 1980

_ - . . - -.. ... ~

i 5.3 REVISIONS Revisions are prepared, reviewed, and approved in the same '

manner as the origf.nal document.

6.0 DOCUMENT CONTROL Documents .used for the design, procurement, and construction

of quality-related items are distributed and controlled in accordance with approved Project Procedures.

t

6.1 DOCUMENT CONTROL - ENGINEERING Design documents, such as. Specifications, System Design Descrip-tions, Technical Reference Documents, Drawings, and Engineering Procedures that area the responsibility of the Engineering Department are distributed within the Engineering Department and to'other organizations by the Engineering Document Control Center (EDCC). Distribution of design documents and revisions are made in accordance with a Master Distribution Schedule established for the Project and augmented by Project Procedures.

i The recipient of a design document signs an acknowledgement 2

form and returns it to the EDCC to verify receipt of the document or document package. Upon receipt of a design document revision, the recipient destroys the superseded document unless the document is required for reference. In this case, the superseded document is marked " void" by the responsible i group or individual. When the retention of the superseded document is no longer required it shall be destroyed. A comprehensive document status list is published at least every two months by the EDCC. The revision status summary provides

an up-dated listing of the controlled documents, their revision

! number, and status. If discrepancies are noted by a document holder, the holder notifies the EDCC to resolve the situation.

6.2 DOCUMENT CONTROL - PROCUREMENT Procurement documents are controlled as described in Section i 4.0 of this program.

f l 6.3 DOCUMENT CONTROL - QUALITY ASSURANCE i

' Quality Assurance originated documents such as procedures, instructions, and manuals that are controlled under the direction f of the Project QA Manager. Distribution and control of QA documents is through the Quality Systems group. Distribution of QA documents and revisions are made in accordance with a log that lists those individuals to whom controlled QA Documents I

i r

l i

B&RLi OCTOBER 31, 1980 i

i have been assigned. Upon receipt of the QA document or revision, the recipient signs the acknowledgement form and returns it to the Quality Systems to verify receipt of the document. The superseded QA document pages are either destroyed or stamped void or superseded by the recipient. A list of revisions is issued periodically by the Quality Systems to the document holders for review against the document in their possession.

If discrepancies are noted by the document holder, the holder

! notifies Quality Systems to resolve the situation. When a QA document is recalled, a memo is sent to all document holders requesting return of the document. Followup action is taken to ensure that all recalled documents have been returned.

6.4 DOCUMENT CONTROL - CONSTRUCTION Document control is maintained at the project site by a Document Control Center (DCC). The DCC supervisor reports within the Site Manager's organization. The primary responsibilities of the DCC include the receipt, reproduction, distribution, storage, and retrieval of project document or design documents generated at the site or received at the site through DCC.

Distribution of drawings, specifications and certain other types of design documents or letters, is accomplished through use of a distribution system. A distribution routing is generated which is the instrument used by the DCC to disribute the document copies to the copy-holder files. This involves DCC maintenance of field satellite drawings and other files.

The DCC distribution personnel are responsible for delivery and retrieval of drawings and documents to the field locations as directed by the distribution routing. Once the distribution and recovery of superseded document copies are completed, the distribution routing is returned to the DCC system to show the completed distribution and recovery transactions.

7.0 CONTROL OF PURCHASED MATERIALS, EQUIPMENT, AND SERVICES 7.1 EVALUATION AND SELECTION OF SUPPLIERS The control of purchased items begins with the evaluation and selection of Suppliers. The selection of Suppliers is based on their capability to provide items or services in accordance with the requirements of the Purchase Order or Subcontract, which reflect the regulatory and quality requirements. The Inquiry Packages contain a request for the bidders to submit their QA Manual and to complete a QA Vendor Questionnaire for evaluation by Quality Assurance.

Upon receipt of a bidder's quotation package, Purchasing /

Subcontracts send the QA Vendor Questionnaire and any bidder QA exceptions to Quality Engineering and the QA Manual to the B&R n. OCTOBER 31, 1980

l l

1 Audit Section. They review the questionnaire, the QA Manual l and any bidder QA exceptions and document the results as delineated in the prescribed QA Procedures. This review ensures that the bidder's quality assurance program meets the '

. applicable quality and regulatory requirements. Results of the evaluation are sent to the Purchasing / Subcontracts and:

Engineering Departments.

Engineering provides a technical evaluation of the submitted bids, Purchasing / Subcontracts performs a commercial evaluation of the submitted bids. Engineering then combines the technical evaluation with the quality and commerical e'raluations submitted by Quality. Engineering and Purchasing / Subcontracts, and prepares a combined bid recommendation for submittal to HL&P.

After all quotations have been tabulated and evaluated by Engineering, Purchasing / Subcontracts, and QA, a pre-award audit at the bidder's facility is conductt$ by Quality Assurance.

Following receipt of a satisfactory quality assurance program evaluation and pre-award audit, and the necessary procurement document reviews, Engineering prepares a recommendation for HL&P approval.

7.2 SOURCE INSPECTION 1

After a Purchase Order has been issued to a selected Supplier, Vendor Surveillance performs the source inspection activities.

The degree of. source inspection at the Supplier's facility is based upon the relative importance, complexity, and quality of j

the item being purchased.

Vendor Surveillance prepares an inspection package on each 1

Supplier consisting of Purchase Orders, drawings, specific-ations, a Vendor Surveillance Plan and special requirements to identify what reviews and inspections are required to be performed. The Vendor Surveillance Plan is prepared by Quality Engineering, with input from other departments as required, to denote the inspection requirements, acceptance criteria, and inspection frequency for initial, in-process, and final shop inspections. From this information, a Vendor Surveillance Schedule is prepared by QA for scheduling inspection trips.

Vendor Surveillance assigns a trained and certified inspector 2

to perform the inspection, when an initial, in-process, or final inspection hold point has been reached. The inspector documents the acceptance or rejection of each inspection hold

. _ point.

4 Prior to shipment, the inspector reviews the required documenta-tion such as Material Test Reports, NDE Reports, and radiographs

_at the Supplier's facility to ensure the documentation is BGR ,

OCTOBER 31, 1980

. . _ _ . _ . . . - - - _ - . . - , _ - . . _ . , . . . . . _ , . . . - . . . , . _ , , . . . - ~ . . . . _ . _ .

t acceptable and complies with the Purchase Order or Subcontract.

If all documentation and test requirements have been met by.

the Supplier and found acceptable, the inspectors release the item for shipment.

4 Final inspection or hold point inspections at the vendor's facility may be waived under one of the following conditions:

i

1. The item is' relatively simple and standard in design, manufacture, and tests; adaptable to standard or automated inspections and/or tests of the item or statistical sacples of the item to verify quality characteristics

after delivery; and when receipt inspection does not require operations which could adversely affect the integrity, functionability or cleanliness of the item.

2. When sufficient quality history is available to provide an adequate confidence. level that the item will meet its intended purpose.

All waivers are documented and approved by the Project QA Manager.

1 Any deviations or discrepancies noticed by the inspector is discussed with the supplier's QA/QC Manager before leaving the +

facility. An attempt is made by the inspector to obtain a proposed resolution from the supplier at this time. If the resolution is not acceptable, the inspector initiates a noncon-formance report in accordance with Section 15.0 of this program.

I 7.3 SOURCE AUDIYS Audits are performed by the QA Audit Section during the course i of manufacturing activities at a supplier's facilities, in accordance with Section 18.0 of this program.

7.4 RECEIVING INSPECTION

$ Procedures are established to delineate the method of receiving

! inspection for purchased safety-related items. Upon receipt of procured safety-related items, the item (s) are inspected to determine the condition of the item, to confirm that identifica- ,

tion and traceability requirements have been met, and to l confirm that the required documentation as specified in the  ;

i Purchase Order is attached or previously has teen received.

Accepted item (s) are received, inspected, identified, and

' released for controlled storage and subsequent use. . Discrepant items are tagged, documented as nonconformances and handled in accordance with Section 15.0 of this program.

B&R OCTOBER 31, 1980

_ . _ _ . _, _ . _ _ ._~._ ,_-.._ . . _ . . , _ _ _ - - _ . . . . . _ - , . .

8.0 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS Project Procedures are established and implemented to provide methods for the identification of items, methods for ensuring traceability of items to documentation, and methods for physically marking such items. Identification markings (serial numbers, symbols, code numbers, tags, etc.) of items are legible and applied so that the function of the item is unaffected. When required by code or regulation, if the material is cut to make more than one piece, the markings are transferred before cutting.

8.1 RECEIVING INSPECTION Certified personnel are responsible for verifying that received items are idantified as required by the Purchase Order. Items found improperly identified are placed in a hold status segregated from the acceptable items, identified and handled in accordance with Section 14.0 of this program. Items found properly identified are documented and processed in accordance with Section 14.0 of this program and transferred to a storage area.

The documentation required by the Purchase Order is also reviewed to ensure the identification numbers on the item (s) received correspond to the identification data on the documenta-tion.

8.2 STORAGE While the items are in storage, methods are established by responsible Construction personnel to ensure correct identifica-tion of the items before releasing them for erection or instal-lation. Storage requirements are described in Section 13.0 of this program.

8.3 IN-PROCESS CONTROL QC Inspectors verify that ; oper identification of field installed items as required has been maintained throughout i erection or installation. If discrepancies are noted, the item is identified, a hold tag applied, and handled in accordance with Section 15.0 of ths program.

8.4 SUPPLIERS AND SUBCONTRACTORS l Suppliers and Subcontractors are required to establish procedures for the identification and control of items (including partially fabricated su') assemblies) so that all segments of the fabrication and manufacturing process can be verified, traced, and checked for compliance with the Purchase Order or Subcontract. Checks l

B&R OCTOBER 31, 1980 I

W ~ ~ - m- e q- ,m y ,

and reviews are performed by Vendor Surveillance to ensure that the identification markings correspond at all stages from initial receipt of the order, throughout fabrication to shipment to the site.

9.0 CONTROL OF SPECIAL PROCESSES The performance and control of special processes are delineated in B&R specifications and procedures prepared by Engineering, Quality Assurance, and Construction, and reviewed and approved by Quality Engineering. These procedures provide a method for procedural and personnel qualifications used to perform special processes and for the performance of special processes under environmentally controlled conditions. Quality Engineering ensures that special processes are performed in accordance with applicable Project Procedures, Code and regulatory require-ments.

Suppliers and Subcontractors are required by B&R to establish procedures for the control of special processes at their facilities. Quality Engineering and Engineering review and approve their procedures before implementation to ensure the procedures satisfy the applicable Code and regulatory requirements and the QA Program.

9.1 NONDESTRUCTIVE EXAMINATION (NDE) 9.1.1 Nondestructive Examination Procedures Nondestructive examinations are performed using NDE procedares approved by a B&R NDE Level III. Before their use, the procedures are qualified and documented by the NDE Level III to ensure compliance with the Code and regulatory requirements. These procedures define the NDE methods required to be qualified, responsibilities for preparation of the NDE procedures, minimum content of the procedure, equipment to be used, test specimens required, essential variables that require procedure requalifica-tion, and documentation and witnessing requirements.

9.1.2 Nondestructive Examination Personnel Training and certification of NDE personnel is in accordance with the Quality Assurance personnel training procedures which meet the requirements of the American Society for Nondestructive Testing Practice SNT-TC-1A, 1975. The Quality Assurance personnel training procedures provide a program which defines responsibilities, certification, recertification, qualification, examination, training, and experience requirements; minimum grades for qualification examination; and specific documentation and physical requirements.

B&R OCTOBER 31, 1980

The NDE Level III is responsible for the certification and recertification of all B&R NDE personnel and for the maintenance of all documentation related to their qualification, certifica-tion, and experience.

9.2 WELDING 9.2.1 Welding Procedure Specifications and Procedure Qualifications Materials Engineering establishes specifications defining the administrative and functional controls to be exercised when establishing welding procedure specifications. These administra-tive and functional controls define, as a minimum:

1. The programmatic requirements necessary to control the accomplishment of activities, including prerequisites and subsequent issuance of welding procedure specifications.

2. The responsibilities and qualifications of personnel involved with qualifying welding procedure specifications.

3. The requirements and controls of weld and base metals used during qualification of velding procedure specifica-tions.

4. The documentation required for back-up support of the welding procedure qualification report.

5. The interface requirements between Materials Engineering and QA to be in effect during the welding procedure specification qualification process.

Welding procedure specifications are qualified in accordance with the Code or standard referenced in the appropriate engineer-ing specification for safety-related items. Welding procedure specifications are qualified under the direction of Materials Engineering and approved by Quality Engineering before their use in production.

9.2.2 Welders and Welding Operators Performance Qualifications Personnel selected to perform welding functions are qualified in accordance with the requirements of the Code or standard referenced in the appropriate engineering specification for safety-related items. Performance tests used to qualify welders and welding operators are administrated by the Project Welding Engineers and surveillance performed by QC Inspectors.

A file of welders, welding operators, and their qualification is maintained by the Site DCC or QA vault.

BS .. OCTOBER 31, 1980

Each qualified welder or welding operator is assigned a weld symbol for use in identifying their welds, and such symbols are controlled by the use of a log maintained by the Project Welding Engineer. These synbols are not reassigned to another welder or welding operator during the life of the project.

9.2.3 Control of Welding Materials The Project Welding Engineer prepares requisitions for the purchase of welding materials such as electrodes, fluxes, and gases. These requisitions, which contain all the quality control requirements as well as appropriate procurement specifica-tions, are reviewed and approved by the Project Welding Engineer and Quality Engineering before transmitting them to Purchasing for procurement.

Upon receipt of welding materials, Quality Con ~ trol inspects the material in accordance with Section 7.0 of this program to ensure compliance to the procurement documents. If the material is acceptable, it is transferred to a controlled welding materials warehouse. Materials for safety-related work is clearly identified until the material has been consumed.

Issuance of welding materials to crafts is the responsibility of the Project Welding Engineer. Welding materials, when issued to the craftsman, are maintained in containers or handled to avoid contamination.

9.2.4 Control of Welding Processes Welding is controlled through Construction procedures that implement the requirements of specifications established by Materials Engineering. The procedures define a sequence of operations necessary for the welding of items. These specifica-tions also identify the special process to be used, the methods used for establishing hold points, and any documentation requiremente.

The Project Welding Engineer prepares Weld Data Cards (WDC) for safety-related ASME welds. After the WDC is prepared, it is reviewed by Quality Engineering to ensure required inspection hold points are included and reference is made to the applicable isometric, welding procedure specification, and field weld number. During production welding, the applicable WDC remains in the immediate area, and when a designated hold point is reached, further operation is not started until satisfactory verification of QC inspection has been established as evidenced by sign-off of the QC inspector. After welding is completed,  ;

the WDC is transferred to the Project Welding Engineer for final review and approval. All documentation accumulated on each weld is attached to the WDC for review purposes. Following approval by the Project Engineer, the WDC is reviewed and approved by Quality Engineering; and the total documentation package is then forwarded to the QA Vault for permanent storage.

I

-B&R OCTOBER 31, 1980

9.2.5 Repairs to Base Metal and Weld Metal Repair and examination of base and weld metal are made in accordance with written procedures prepared by the Project Welding Engineer using qualified welding and NDE procedures, and certified inspectors and welders. The methods of reinspection of base metal repair are in accordance with written repair and

NDE procedures. The methods of reinspection of weld metal repair are at least the same as the.one performed on the original weld.

9.3 HEAT TREATMENT When post weld heat treatment is required, it is performed to the applicable welding procedure specification and to the specified post-weld heat treatment procedures. Preheat and interpass temperature controls is in accordance with the l applicable welding procedure specification. These procedures are approved by Quality Engineering before their use.

9.4 BENDING Procedures are established and qualified for the bending process. Engineering reviews and approves the bending procedures prior to their use. The bending procedure qualification tests and procedure requirements require the following:

1. Number and location of test specimens;

2. Strain calculations;

3. Testing on simulated similar items to be bent;

4. Impact testing, when required;

5. Minimum thickness required; and

6. Cross-sectional diameters, ovality and shape tolerances.

9.5 CHEMICAL CLEANING CONTROL Chemical cleaning is requi..ed to be performed in accordar.ra with written procedures prepared by Construction and rev awed and approved by Quality Engineering. Cleaning activities are performed by trained personnel and monitored by certified Quality Control inspectors.  !

1 10.0 INSPECTION Planned, written procedures for in-process and final examinations and inspections are prepared by Quality Engineering to ensure conformance with documented instructions, procedures, and l l

1 l

B&R OCTOBER 31, 1980 l l

l

. . , _ . .. ~. _ _ _ . . - .

drawings. These procedures, when necessary, provide step-by-step instructions. To ensure that the procedures are carried out and results are documented, detailed inspection reports, drawings, and/or checklists are made a part of the procedures for use by inspecting personnel.

Inspection procedures, instructions, and checklists contain, as applicable, the following prerequisities:

1. Identification of characteristics to be inspected;

2. Identification of the individuals responsible for performing the inspection operation;

3. Acceptance and rejection criteria;

4. A description of the method of inspection including equipment to be used;

5. Verification of completion and certification of inspection;

6. A record of the results of the inspection operation, and

7. Mandatory hold points.

Suppliers and Subcontractors are required to establish procedures for in process and final examinations, tests and inspections at their facilities. These procedures comply with the applicable quality and regulatory requirements.

10.1 INSPECTION PERSONNEL QC Inspectors are trained c for certified in accordance with Quality Assurance personnet training procedures. The respon-sibilities of the shop and field inspectors includes visual and physical inspection of the work or items; verification of documentation; identifying Quality Assurance and Quality Control problems; recommending, proposing, or initiating action leading to a resolution of any recognized problem; and verifying the corrective action taken is acceptable.

To ensure independence of the inspection group from the group performing the activity, QC inspectors report to the QC Manager who reports to the Project QA Manager. Vendor Surveillance inspectors report to the Vendor Surveillance / Houston Coordination Manager who reports to the Project QA Manager so that their independence from the group performing the activity is ensured.

R&R OCTOBER 31, 1980

l l

l l

l 10.2 HOLD POINTS i

i 10.2.1 Suppliers i

Before the start of any manufacturing or fabrication process at a supplier facility, Quality Engineering will determine if in-process shop inspection is necessary. This determination is based on the complexity of the process and the past performance history of the supplier. If it is determined that in-process

-inspection is necessary, Quality Engineering with the cooperation of the supplier establishes hold points beyond which the manufacturing or febrication will not proceed without a shop inspection by Vendor Surveillance. Waiver of such hold points is made by the Project QA Manager.

10.2.2 B&R Construction and Fabrication Before the start of a B&R construction activity or fabrication process at the project site, Qaality Engineering will review the process and determine if in process inspection is necessary.

This determination will be based on the complexity of the activity or process, the engineering specifications, quality and regulatory requirescats, and history of project or industry related problems for the specific activity. If it is determined in-process inspection is necessary, Quality Engineering establishes hold points with Construction beyond which point that activity or process will not proceed without a QC inspection.

10.3 INDIRECT CONTROL OF INSPECTIONS If physical inspections of items or processes are impossible or disadvantageous, a documented system of indirect control by monitoring processing methods, equipment and personnel functions is provided. Both physical inspection and process monitoring is provided when control is inadequate without both.

10.4 INSPECTION OF REPAIRED ITEMS Inspections that are performed on repairs, modifications, and replacements are performed as required in written approved procedures.

11.0 TEST CONTROL Test control procedures are established by Engineering for design opersbility/ qualification, by Construction for testing of special processes, and by suppliers and subcontractors for  ;

product integrity tests. The responsible organizations also j establish and implement procedures that when followed, demoa-- I strates the item will perform satisfactorily in service and l B&R OCTOBER 31, 1980

a meet the requirements of the Design Specifications. These procedures' are reviewed by Quality Assurance to ensure compliance with quality or regula$ory requirements before implementation.

11.1 TEST PROCEDURES Testing is performed in accordance with written test procedures that incorporate or reference the performance or qualification test requirements included in the Design Specifications or other procurement docuaents.

-Test procedures also specify the necessity for the following test prerequisites:

1. Calibrated instrumentation;

2. Adequate and appropriate equipmett;

3. Trained, qualified and certified personnel;

4. Preperation, condition, and completeness of the test item to be tested; 5 Suitable and controlled environmental conditions;

6. Mandatory inspection hold points for witness;

7. Provisions-for data collection and storage;

8. Acceptance and rejection criteria, and

9. Methods for documenting or recording test data results.

As an alternate, the required tests may be specified by reference to proper Codes, standards, and approved procedures which state criteria, acceptance levels, required examinations, and certification requirements.

11.2 INSPECTION OF TESTS In-process and final inspection of testing activities at the site are in accordance with Section 10.0 of this program to ensure that adequate controls are established.

11.3 DOCUMENTATION a.

A'l test results are documented by the organization that performed the tests. The test results are evaluated by the organization requesting and/or performing the tests to ensure the completed tests have met the requirements established in the test procedures and design specifications.

B&R .e. OCTOBER 31, 1980 a

J I

12.0 CONTROL OF MEASURING AND TEST EQUIPMENT Procedures provide for methods to calibrate and identify  ;

Measuring and Test Equipment (M&TE), to notify Quality Control i and Construction of the status of M&TE, and to recall suspected l or damaged M&TE. Testing Laboratories and Subcontractors used for calibration of M&TE establish a system for the calibration of M&TE which complies with quality and regulatory requirements.

Quality Engineering reviews Testing Laboratories / Subcontractors' system to ensure it is a satisfactory program.

12.1 CAL {BRATION STANDARDS Measuring and test equipment required to be calibrated are calibrated against measurement standards having known relationship to national standards where such exist. Where required by National standards or other standards, reference standards are mair tained and used in an environment having the necessary temperature, humidity, and/or contamination controls, and are supported by certificates attesting to the date, and accuracy (conditions where applicable) under which.the results were furnished. If no reference standards exist for a particular piece of M&TE, the basis of calibration is in accordance with the Manufacturer's recommendation.

Calibration standards are not required for standard off-the-shelf measuring equipment which is not likely to change or drift during usage. Such devices are rulers, scales, and tape measures which need only to be inspected for evidence of -

damage or deterioration before usage.

12.2 CALIBRATION OF MEASURING AND TEST EQUIPMENT As described in procedures, all measuring and test equipment are calibrated and properly adjusted at specified periods or use intervals so accuracy is maintained within specified limits. Before calibration, all M&TE is assigned and permanently identified with a serial number in an area of the instrument that will not damage the instrument or interfere with its use.

M&TE is calibrated by trained personnel under the surveillance of the Site Surveillance Group to ensure proper calibration procedures are available and used in the calibration process.

The calibration of all M&TE is documented; quality Engineering reviews these reports on a random basis.

A- M&TE Master Index is maintained. The index identifies the calibration status, interval, item identification, and any condition affecting measurement control. The index is periodi-cally reviewed by Quality Engineering to ensure they are complete and that they reflect the current status of all the referenced standards and M&TE.

B&R OCTOBER 31, 1980 l

l All M&TE which are calibrated is labeled with a calibration label. The label will state calibration date, the calibrator, and the next calibration due date. This will complement the records maintained on each piece of M&TE and will readily aid the user in determining if a piece of equipment is within its 3 next calibration due date. y 12.3 DAMAGED EQUIPMENT Measuring and test equipment found damaged in service or

' improperly maintained is identified and segregated from the calibrated M&TE and its calibration sticker removed. After the M&TE has been repaired and accuracy verified, a new calibra-tion sticker is affixed on the M&TE and the ites placed back in service.

i 12.4 INACTIVE EQUIPMENT Measuring and test equipment that is inactive because of temporary or permanent termination of a construction activity, is identified by affixing an inactive sticker to the equipment or segregating it from the active calibrated equipment.

12.5 NONCONFORMANCES When nonconformances are noted and the M&TE is used for final acceptance testing while out of calibration, a nonconformance report in accordance with Section 15.0 of this program is prepared. An evaluation is conducted to determine.the validity i

of previous inspections subsequent to the calibration check.

l The corrective action is reviewed, and when deemed necessary, the item is reinspected using properly calibrated equipment.

12.6 TESTING LABORATORIES-If B&R elects to use standard testing laboratories to perform calibration services, they are approved before award of contract in accordance with Section 7.0 of this program. Certification ,

traceable to nar.ional standards (where such exist) are provided for all calibrations performed and transmitted to B&R for record storage ar.d filing.

12.7 ISSUANCE OF MEASURING AND TEST EQUIPMENT Before the issuance of M&TE, the facility attendant checks equipment and logs out the equipment. Upon return of the issued equipment, the attendant notes the return and condition of the equipment. ,

5 B&R OCTOBER 31, 1980

._ ._. , .- , . _ _ _ _ _ _ _ . - . _ ._ _ . .._._ _. . _ ...._ _ _ _ , ~ . _ _ . _ - _. - _ _ - -.

l i

13.0 HANDLING, STORAGE, AND SHIPPING Detailed procedures have been developed and implemented to ensure that handling, storage, shipping, and preservation of items are performed in accordance with approved instructions, procedures, quality and regulatory requirements. The implementa-tion of the procedures are performed by personnel who are trained and aware of the requirements of the procedures.

These procedures are reviewed and approved by Quality Assurance before their implementation. Engineering alt,o reviews and approves the procedures for engineered items.

I 13.1 SHIPPING Engineering specifications and Purchase Orders provide adequate instructions for marking and labeling items and their shipping containers. Marking is adequate to identify, maintain, and preserve the shipment, including the indication of the presence of special environments or the need for special controls such as handling. All safety-related items are suitably protected during shipment to prevent damage or deterioration of the item from environmental conditions.

13.2 STORAGE After receiving inspection has been performed, as outlined in Section 7.0 of this program, items are stored in appropriate areas as determined by Engineering specifications and Manufac-4 turer's recommendations. Storage levels are comparable to

, levels required for packaging and shipping. Storage facilities have controlled access to the extent required to prevent unauthorized personnel from obtaining items. Maintenance, care, and protection of items are delineated in Construction or Material Management Procedures or as specified in the Manufacturer's instruction to prevent damage, deterioration, or loss by environmental conditions. The withdrawal of items from storage is controlled by procedures to confirm that correct items are being released.

13.3 HANDLING Items transferred to or removed from storage are handled by ,

Construction personnel in accordance with procedures. When i specified, critical, heavy, and major items are handled in accordance with the Manufacturer's instructions. Special handling tools and equipment are provided and controlled as necessary to ensure safe and adequate handling.

I B&R OCTOBER 31, 1980

. - - - - - .. - .-. ~ , -

(

13.4 PRESERVATION ,

l Items subject to deterioration and damage from exposure to 'l air, moisture, or other environmental conditions while in l storage are kept preserved in accordance with the Manufacturer's instructions and applicable B&R specifications and procedures.

13.5 SPECIAL ITEMS When necessary for items such as critical, sensitive, perishable or high value articles, specific procedures are written for the handling, storage, packaging, shipping, and preservation of these items. These procedures include requirements for special coverings, special protective environments, specific moisture content levels, and temperature levels. These special items are specified in engineering documents.

14.0 INSPECTION, TEST, AND OPERATING STATUS Responsible departments establish and implement procedures to identify the inspection, test, and operating status of processes and items. These procedures define areas requiring controls, describe tags, stamps, labels, cards, and checklists provided to accomplish the intent of this section, and provide for the development of other means of status identification during the 4

design, procurement, and construction phases. The authority and approvals required for originating or removing status a

indicators are also described in the applicable procedures.

4 14.1 INSPECTION AT SUPPLIER'S SHOP Upon the approval and issuance of a procurement document, an j Engineering specification and other related documents, the status of inspection and test activities at the Suppler's Facility is controlled by Vendor Surveillance through the use of the Vendor Surveillance Plan and Vendor Surveillance Report, Inspector's stamps, and other status indicators noted in procedures applicable to the source inspection activity.

14.2 RECEIVING INSPECTION Upon the receipt of safety-related items from the Supplier, receiving inspection is performed in accordance with Section ,

7.0 of this program and applictble procedures specifying the use of tags, stickers or other indicators applicable to the receipt inspection activity, e.

B&R OCTOBER 31, 1980

I 1

14.3 IN-PROCESS CONTROL The processing, fabrication, installation, or testing of materials and equipment by Construction in accordance with Project documents and Construction Procedures is reviewed, monitored, and inspected by QC Inspectors. The QC Inspectors I use defined indicators as specified by Project procedures to note the status of the construction activities.

14.4 NONCONFORMANCES S

Nonconformances shall be indicated on Nonconformance Reports as explained in Section 15.0 of this program. Tags, stickers

-or other indicators are also used to identify the status of nonconforming items and their resolution.

14.5 CONTROL OF STATUS INDICATORS The control, issuance, use, and removal of status indicators is the responsibility of the organization originating the status indicator.

I 14.6 SUPPLIERS AND SUBCONTRACTORS Suppliers and Subcontractors are required to establish and implement a program to identify the examination and process status of the purchased material or equipment.

15.0 NONCONFORMING MATERIALS, PARTS OR COMPONENTS Quality Assurance has established written procedures describing the controls used for the identification, documentation, segregation and disposition / resolution of nonconformances.

These procedures identify individuals who are delegated the responsibility and authority to approve the disposition of a nonconformance report and establish methods of analyzing nonconformance reports for quality trends. Nonconformances are deficiencies in characteristics, documentation or procedures which render the quality of an item unacceptable or indeterminate.

The documentation used by B&R for nonconformances identifies I the material or item, describes the nonconformance, describes the disposition or resolution and includes approval signatures for the dispo Ation.

15.1 IDENTIFICATION It is the responsibility of all B&R employees to report any I nonconformance to B&R Quality Assurance. Upon identification d' of a nonconformance as defined, a Nonconformance Report (NCR) is issued by Quality Assurance.

B&R OCTOBER 31, 1980

1 l

l 1

The Nonconformance Report is completed stating the nonconformance insofar as violation, events and/or physical conditions pertaining to the nonconformance. Supporting documentation is referenced or attached to the report if the documentation aids in under-

- standing the nature of the nonconformance.

15.2 SEGREGATION Nonconforming items are tagged to note the nonconforming condition. If the item cannot be easily tagged, documentation traceable to that item is used to denote-its nonconforming condition. Where practical, nonconforming materials, parts or i components are segregated from acceptable items while in a hold status to prevent their inadvertent use.

15.3 APPROVAL FOR ISSUANCE Nonconformance Reports, after being prepared, are reviewed by j Quality Engineering to ensure completeness and accuracy of the information stated. Any misunderstandings are resolved by Quality Engineering conferring with individuals reporting the nonconformance. If satisfactory, the nonconformance report is approved.

i 15.4 DISPOSITION AND IMPLEMENTATION If nonconforming items or conditions identified during construc-tion activities can be reworked to original design configuration or brought into compliance through a " standard repair procedure",

the NCR is dispositioned by the Lead QC Inspector and the Construction General Foreman. Once the disposition is complete, the QC Inspector removes the hold tags and work may proceed.

NCR's falling into this category are forwarded to Quality Engineering for review, written approval, and record retention.

Since no design evaluation is required, it is not necessary.to include these NCR's in the Material Review Board process.

i NCR's requiring design evaluation (i.e. those NCR's indentified as " repair" or "use-as-is") are forwarded by Quality Engineering to the Materials Review Board (MRB). The MRB is an on-site

< committee' responsible for providing dispositions to all NCR's i requiring design evaluation. Concurrence by both the Engineering and Quality Engineering representatives is required for disposi- ,

tion of an NCR. When the MRB review has been completed, the signed NCR, with disposition noted is provided to HL&P Quality Assurance for review of disposition to ensure concurrence that QA pt- -- uirements.have been implemented. During the const phase only, if a disposition cannot be readily obta aeu, one Site Manager may request of the Project QA Manager a temporary waiver to allow controlled use of a i

nonconforming item.

! l 1

s B&R OCTOBER 31, 1980

_ _ _ - . -. _ _ . ~ . . _ . __ .. , _ _ . . . . _ , . _ _ _ _

The implementation of disposition of nonconformances is assigned to:

1. Brown & Root Construction, when the nonconformance pertains to fabrication, erection, or construction activities performed by B&R or EER's subcontractors / vendors; or

2. Brown & Root Quality Assurance when the nonconformance pertains to quality assurance / control activities performed by BER or B&R's subcontractors / vendors; or

3. Brown & Root Engineering when the nonconformance pertains to design activities and/or engineered materials procured by B&R; or

4. Houston Lighting & Power when the nonconformance pertains to activities and/or materials procured by the NSSS Vendor.

Items dispositioned " repair" are repaired in accordance with approved procedures and re-inspected by at least the same methods that found the nonconformance. Items dispositioned

" scrap" are tagged and are segregated to prevent their inadvertent use prior to their disposal.

15.5 REMOVAL OF TAGS Upon final close-out, all tags indicating the nonconforming status of the material or item are removed by Quality Assurance.

15.6 NONCONFORMANCE TRENDS Trend analysis is a systematic review of nonconformance experience to prevent future nonconformance by identifying and eliminating underlying causes of past incidents.

The trend analysis program serves as a reliable method for collecting data, an effective means of reporting the data, and a vehicle for instituting corrective action when adverse trends are identified. Quality Systems identifies the methods

to be used,to collect data, the ways to categorize and monitor deficient conditions by the use of quality indicators, data normalization and graphic representation, and the methods of reporting this information to management.

Trend analysis procedures define the list if docaments that will be trended. Examples of documents included in the list are: Nonconformance Reports; Corrective Action Requests; Audit Deficiency Reports; Engineering Design Deficiencies; and Vendor-Related Reports identifying nonconformances.

B&R OCTOBER 31, 1980

- - _ . . . ~ . _ . . . . _ . - . _ , ,..-.. . - .<= ,, ..J

l The results of the trend analysis are reported to Quality Engineering for their review of suspect areas to determine whether the incidents that make up a trend have a common cause. If a common cause is identified, Quality Engineering will issue a Corrective Action Request for recurrence control.

Once a corrective action is undertaken,. Quality Engineering follows up and assures that the corrective action is satisfactory and properly implemented.

15.7 STOP WORK ORDER (SWO)

The identification of a nonconforming condition may warrant a the Project QA Manager to stop work on a particular operation until proper disposition of the deficiency has been approved.

Characteristics that warrant a Stop Work Order (SWO) are established in applicable project procedures. If stop work action is warranted, the affected organization is verbally notified by the Project QA Manager. A Stop Work Order documenting the reason work was stopped is initiated and issued to the affected organization. Authorization to resume work affected by a SWO is given by the Project QA Manager when responses, corrective actions, recurrence controls and other. requirements have been satisfactorily responded to and have been determined to be acceptable.

16.0 CORRECTIVE ACTION Procedures ensure that conditions adverse to quality are

, promptly identified, corrected, and action taken to prevent recurence. These procedures also include a system for identifying and reporting significant deficiencies to HL&P and for instituting corrective action.

Nonconforming materials or items are identified and documented on Nonconformance Reports, as described in Section 15.0 of this program. If corrective action is required, as deemed necessary by Quality Engineering after their review of an NCR, a Corrective Action Request (CAR) is initiated. CAR's may also be issued to identify for correction, significant or repetitive conditions adverse to quality. .

l The CAR's have specified time limits for taking responsive action and may constrain or hold work on specific tasks. A failure to respond within the time limits may result in issuance 4

of a Stop Work Order. After a CAR is issued, Quality Engineering determines when corrective action has been taken, and whether it was effective in preventing recurrence of the problem. A Stop Work Order may be issued if it is found that the corrective action has been ineffective.

t l

I t

B&R OCTOBER 31, 1980 j l

i

__. . . - ~ -. . . . _ , _ _-

,_.-.-,,,s _. _ - .

17.0 -QUALITY ASSURANCE RECORDS Brown & Root has established a record management program in which storage, control, retention, and accessiblity of QA records are listed; origination and retention responsibilites are defined; and retention times are listed. Procedures have also been established which outline the specific identification system and categories to facilitate interface with the identifica-tion used by the Nuclear Steam Supply System (NSSS) and other suppliers.

17.1 PROCESSING OF QUALITY ASSURANCE RECORDS All QA records are reviewed.for conformance to requirements, legibility, completeness, and traceability to the item or-activity being documented.

17.2 STORAGE Quality Assurance records retained at the Houston offices or at the Site are stored in central files within Engineering, Procurement, or Quality Assurance. Duplicate QA record storage

' facilities are maintained in separate and remote locations.

The QA records storage facility at the Site is constructed and located to protect the contents from possible destruction by causes such ac fire, floods, tornadoes, insects, rodents, and from possible deP.erioration by a combination of extreme variations 4 in temperatures and humidity conditions and may be used in lieu of duplicate storage.

17.3 FILING QA records are filed in such a manner as to provide timely retrieval. An index system is established to identify QA records, where records are stored, and the location of the records within the storage area.

17.4 ACCESS CONTROL The cognizant managers maintain a list of personnel who have been authorized admittance to the respective record storage areas. Personnel not on the list may be admitted to the storage areas with approval from the cognizant managers only.

l 17.5 REMOVAL OF QUALITY ASSURANCE RECORDS Records may be examined within the storage area. Methods are established to control the removal and return of QA records from the storage facility. These methods reflect the following:

B&R OCTOBER 31, 1980

er

1. Approval by the cognizant Manager for removal of each

. record.

2. Logging of the record to be removed and the date of removal.

3. Individual obtaining the record and date to be returned.

4. Follow-up to assure timely return of the records.

17.6 REVISION Quality Assurance records may be supplemented or revised.

These supplements or revisions are originated, processed, and distributed in the same manner as the original records.

17.7 DISPOSITION QA records are retained at the prescribed location by the

< assigned organization according to procedures, until the records are required by HL&P.

18.0 AUDITS A system for both internal and external audits is established in QA procedures approved by the QA Manager - Power Group and implemented by the Q.A. Audit Manager. These procedures specify requirements for training and qualifying auditors, planning and scheduling audits, implementing an audit, pre-paring a formal audit report, and resolving any audit findings.

Internal audits include all B&R activities and external audits include the activities of Suppliers and Subcontractors.

A system of management audits shall also be established to audit the activities of Quality Assurance and to verify compliance with, and effective implementation of, all aspects of a QA Program.

18.1 QUALIFICATIONS OF AUDITORS Personnel performing audits are trained and qualified in accordance with the Quality Assurance personnel training procedures. Personnel qualified to perform audits are independent of any direct responsibility for the activities being audited.

At least one audit team member must be experienced or trained in the discipline being audited.

B&R OCTOBER 31, 1980

18.2 PLANNING AND SCHEDULING AUDITS

. Audit functions are prescheduled'and documented by the.QA Audit Manager. The frequency of audits is based on the safety l importance and status of activities being performed. Each .

l element of the complete QA program, including site' activities, is audited at least annually.

Supplemental. audits are performed, as required, when significant changes are made in functional areas of the QA Program, when there are repetitive nonconforming conditions, or when it is necessary to verify implementation of required corrective

action. These audits are requested by either the Project QA Manager or tne QA Manager-Power Group.

18.3 IMPLEMENTATION OF AUDITS Audited organizations receive written notification before a scheduled audit in order to establish proper interface.

Personnel performing the audit prepare an audit checklist consisting of questions extracted from applicable specifications, codes, plans and/or procedures to which the audited organization is committed. The audit checklist is reviewed and approved by the QA Audit Manager or his identified designee. On the date of the audit, a preaudit meeting is conducted with the management of the audited organization to discuss the audit sequence and to establish channels of communications. After the preaudit meeting, the audit is conducted and results recorded on the

, audit checklist. At the conclusion of the audit, a post-audit meeting is held to discuss the audit findings with management personnel of the audited organization. Corrective action responsibilities are assigned, and response times are established.

18.4 AUDIT REPORTS After the audit is completed, a formal audit report is pre-pared by the audit team leader and forwarded to the QA Audit Manager or his identified designee for approval. This report contains, as a minimum, an analysis of observations /recommenda- i tions, the indentification of individuals contacted during the audit, the scope of the audit, and any Audit Deficiency Reports l I (ADR). l The audit report is issued within 30 days after the audit and sent by formal letter to the audited organization, HL&P, the i ~ Project QA Manager, the QA Manager - Power Group, and the QAMRB members.

l i

B&R OCTOBER 31, 1980 1

._ _ . . _ ._- _ . _ ~ , _ .. _ _ _ . , , . . _ , . . _ . __._ - __ .-. ,. _ _.

I 18.5 AUDIT DEFICIENCIES All deficiencies noted by an auditor are noted on the audit checklist and formally documented on an ADR. The audited organization documents the corrective action taken or to be taken, including action to prevent recurrence of the defi-ciency on the ADR, and returns the ADR to the QA Audit Manager.

The QA Audit Manager or his identified designee reviews the corrective action taken to ensure it will resolve the deficiency.

If the corrective action is found to be satisfactory, the ADR is closed unless verification is required. Follow up action is perfonmed by verification of corrective action when necessary.

Audit deificencies that cannot be resolved at the Project level shall be referred to the:next meeting of the QAMRB for resolution.

B&R OCTOBER 31, 1980

y'(

f TABLE 1 PROJECT QUALITY ASSURANCE DEPARTMENT FUNCTIONS Quality Engineering

1. Reviews Purchase Orders for compliance with QA requirements.

2. Reviews selected design documents for compliance with QA requirements.

3. Reviews and approves nonconformance reports.

4. Reviews design change notices and field change requests for compliance with QA requirements.

5. Prepares quality control inspection plans in conjunction with Construction Engineering.

6. Reviews and approves quality-related construction record packages.

7. Resolves QC technical problema.

8. Reviews and approves quality / construction procedures.

9. Prescribes training programs for QA personnel qualification and certificaticn.

Quclity Control

1. Inspects construction activities as directed by Quality Engineering in their inspection planning instructions.

2. Assures certified QC inspectors are utilized.

3. Coordinates and reports construction inspection results.

4. Prepares nonconformance reports as required.

5. Assures inspection equipment is properly qualified and calibrated.

6. Performs nondestructive examination on site for B&R activities.

B&R OCTOBER 31, 1980

l l

~

l l

TABLE 1 PROJECT QUALITY ASSURANCE DEPARTMENT FUNCTIONS (Continued)

Quality Systems

1. Prepares and maintains the Project QA Manual.

2. Coordinates preparation of QA procedures.

3. Coordinates B&R QA Records turnover.

4. Maintain site QA records.

5. Coordinates draft responses to Site NRC Inspection Reports.

6. Coordinates responses to HL&P and B&R site audits.

7. Prepares monthly QA operations reports and quarterly QA nonconformance trend analysis reports.

8. Coordinates QA training and certification program.

Vendor Surveillance / Houston Coordination

1. Performs vendor inspections as required by Quality Engineering in their inspection planning instructions.

2. Assures certified Vendor Surveillance inspectors are utilized.

3. Coordinates and reports vendor inspection results.

4. Prepares nonconformance reports as required.

5. Coordinates corporate audits and corrective actions.

6. Coordinates QA activities related to Engineering and Procurement activities.

7. Coordinates responses to HL&P and B&R audits other than site audits.

B&R OCTOBER 31, 1980

, . - . , . . . , . , ~ , . . . ,, - -

.u ,

4 TABLE 1 PROJECT QUALITY ASSURANCE DEPARTMENT FUNCTIONS (Continued)

Site Surveillance

1. Assures qualified personnel are utilized.

2. Schedules and conducts surveillance programs on site activities.

3. Assures adequacy of corrective action resulting from their surveillance activities.

4. Reports results of surveillance activities to the Project QA Manager.

1 1

B&R' OCTOBER 31, 1980

1 TABLE 2 ANSI STANDARD AND REGULATORY GUIDE COMPLIANCE The B&R STP Quality Assurance Program complies with the following ANSI Standards and implementing Regulatory Guides except as noted:

STANDARD TITLE ANSI N.45.2-1971 Quality Assurance Program Require-R.G. 1.28(Rev.0,6/72) ments for Nuclear Facilities ANSI N.45.2.1-1973 Cleaning of Fluid Systems and Asso-R.G. 1.37(Rev.0,3/73) ciated Components During Construc-tion Phase of Nuclear Power Plants ANSI N.45.2.2-1972 Package, Shipping, Receiving, Storage R.G. 1.38(Rev.0,3/73) and Handling of Items for Nuclear Power Plants ANSI N.45.2.3-1973 Houskeeping During the Construction R.G. 1.39(Rev.0,3/73) Phase of Nuclear Power Plants ANSI N.45.2.4-1972 Installation, Inspection and Testing R.G. 1.30(Rev.0,8/72) Requirements for Instrumentation and Electric Equipment During the Con-struction of Nuclear Power Generating Stations ANSI N.45.2.5-1974 Supplementary Quality Assurance Require-(see Notes 1 and 2) ments for Installation, Inspection and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants ANSI N.45.2.6-1973 Qualifications of-Inspection, Examination R.G 1.58(Rev.0,8/73) and Testing Persennel for the Construc-tion Phase of Nuclear Power Plants ANSI N.45.2.8 Supplementary Quality Assurance Require-(Draft 3, Rev.3, 4/74) ments for Installation, Inspection and Testing of Mechanical Equipment and Sys-tems for the Construction Phase of Nuclear Power Plants ANSI N.45.2.9-1974 Requirements for Collection, Storage '

R.G. 1.88(Rev.0,8/74) and Maintenance of Quality Assurance Records for Nuclear Power Plants ANSI N.45.2.10-1973 Quality Assurance Terms and Definitions  :

R.G. 1.74(Rev.0,2/74) l B&R OCTOBER 31, 1980 i

i

d TABLE 2

' ANSI STANDARD AND REGULATORY GUIDE COMPLIANCE (Continued)

STANDARD TITLE ANSI N.45.2.11-1974 Quality Assurance Requirements for the R.G. 1.64(Rev.2,6/76) Design of Nuclear Power Plants ANSI N.45.2.12 .

Requirements for Auditing of Qu lity (Draft 3, Rev.4, 2/74) Assurance Programs for Nuclear Power (see Note 3) Plants ANSI N.45.2.13 Quality Assurance' Requirements for (Draft 2, Rev.4, 4/74) Control of Procurement of Items and-Services for Nuclear Power Plants ANSI 17.101.4-1972 Quality Assurance Requirements for R.G. 1.54(Rev.0,6/73) Coatings Applied to Water Cooled Nuclear Power Plant Exception Notes

1. ' ANSI N.45.2.5-1974, Section 4.8, states " Pumped concrete must be sampled from the pump line discharge". In lieu of this statement,

.in process strength samples of pumped concrete are taken at the delivery point. Correlation tests of air content, slump, and temperature are performed to verify these plastic properties of the concrete at the placement point in accordance with the following frequency requirements:

A. A minimum of 2 correlation tests are performed for each pumped placement exceeding 200 cu. yds.

B. Otherwise, a minimum of 2 correlation tests per week are performed when any individual pumped placement during a week requires delivery of more than one truckload of concrete.

C. During a week when a pumped placement exceeding 200 cu. yds.

is made, the correlation tests performed on that placement will satisfy the weekly requirement for performing two correlation tests as specified in Item B above.

When any of the specified limits and tolerances on loss of air content, slump, or temperature are exceeded at the placement point, correlation tests between the delivery point and placement point 1 will be accomplished for each 100 cu. yds. of concrete placed as

.B&R OCTOBER 31, 1980

-- = _ - -

(

L i

TABLE 2  ;

ANSI STANDARD AND REGULATORY GUIDE COMPLIANCE {

(Continued) long as limits and tolerances are exceeded. If two consecutive tests are out of tolerence, corrective action will be implemented to assure that subsequent loads awaiting discharge int- +he pump are within tolerances for the placement. This will be .scom-plished by adjusting the plastic property requirements of the concrete at the pump intake.

" Correlation Tests", " Delivery Point", and " Placement Point" are as defined in ANSI N.45.2.5-1978, Section 1.4.

2. Samples and frequency for cadweld testing is in accordance with ACI-359/ASME Section III, Division 2, issued for trial use and comment in 1973, including addenda 1 through 6, (see Sections 3.8.1.6.3 and 3.8.3.6.3 of the STP Final Safety Analysis Report).

3. If a work activity and contract is for a two-month period or less, an audit is not necessary when a facility preaward audit has been conducted.

B&R OCTOBER 31, 1980 y . . . . .

,. , . - . . . ~

TABLE 3 STP QUALITY ASSURANCE PROCEDURES Procedure 10CFR50, App. B Number Title Criteria QAP-1.1 QA Organization I QAP-2.1 QA Personnel Development II QAP-2.2 QA Training II QAP-2.3 Site QA Personnel Examination II and Certification QAP-2.4 Audit Personnel Certification II, XVIII QAP-2.5 Vendor Surveillance Personnel. II, VII Examination and Certification QAP-3.1 Engineering Quality Assurance III QAP-3.2 $7. eld Design Changes III QAP-4.2 Houston Purchasing Activities IV QAP-4.3 Field Purchasing Activities 'IV QAP-5.1 Subcontract Quality Control Services IV, VII

QAP-5.3 Surveillance of Pittsburgh Testing VII Laboratory QAP-5.4 Structural Integrity Test VII QAP-5.5 Mechanical Subcontract Surveillance VII Activities QAP-5.6 Post-Tensioning VII QAP-5.11 Site Geotechnical Surveillance VII QAP-6.1 Procedure Development V, VI QAP-6.2 QA Manuals, Procedures and Instructions V, VI Control

, B&R OCTOBER 31, 1980

TABLE 3 STP QUALITY ASSURANCE PROCEDURES (Continued) l Procedure 10CFR50, App. B Number Title Criteria  ;

QAP-6.3 QA Forms Control VI QAP-6.4  ;QA Document Review V, VI QAP-7.1 ' Vendor Surveillance Organization' I, VII QAP-7.2 Vendor Surveillance and Houston Coordin- VII ation Activities QAP-10.1 Inprocess Inspection and As-Built X' Verification Planning QAP-15.1 Nonconformance Control XV QAP-15.2 Stop Work II, XV QAP-15.3 Potentially Reportable Deficiencies XV QAP-15.4 Trend Analysis XV QAP-15.5 Field Inspection Reports X, XV QAP-16.1 Corrective Action Requests XVI QAP-17.1 Records Control XVII QAP-18.1 Audit Program XVIII QAP-18.2 Site Surveillance XVIII NDEP-1.1 NDE Procedure and Jastruction IX Qualification NDEP-2.1 Radiographic Examination IX NDEP-3.1 Visual Examination IX k

B&R OCTOBER 31, 1980 L . . . _ _. - , .. . ._ . ._ ._. _ _ . - -- _ . . , ,

' TABLE 3 STP QUALITY ASSURANCE PROCEDURES (Continued)

Procedure 10CFR50, App. B Number Title Criteria NDEP-4.1 Liquid Penetrant Examination IX NDEP-5.1 Magnetic Particle Examination IX NDEP-6.1 Ultrasonic Examination IX NDEP-7.2 Gas and Bubble Formation Leak Testing IX 4

e j

i 1

I i

i 1

i B&R OCTOBER 31, 1980

TABLE 4 STP ENGINEERING PROCEDURES Procedure 10CFR50, App. B Number Title Criteria GR-001 STP Engineering Procedures Manual V, VI GR-002 Project Organization I GR-003 Design Quality Program LII GR-004 Certification of ASME Documents III DC-C' Preparation and Control of Project V Procedures DC-002 Drawing Control III, V DC-004 Foreign Document Processing III, VI DC-005 Preparation and Control of Engineering III, IV, VII Specifications DC-007 Preparation and Control of System III Design Descriptions DC-008 Calculations III DC-009 File and File Storage XVII DC-010 Codification III, VIII, XVII DC-011 Document Distribution VI DC-012 SAR Change Control III DC-013 Change Not.ce Control III DC-014 Document Review Comment Process III DC-015 Design Verification III DC-016 ALARA Review III DC-017 Computer Program Documentation III DC-019 Technical Reference Control III

~~

DC-020 Records Turnover III, VI, XVII DC-021 Engineering Design Deficiencies III, XV, XVI  ;

5 DC-022 Nonconformance Reports III, XV, XVI, i B&R OCTOBER 31, 1980 i

~ '=

~ < . ~. -

p -y a n . .~,

TABLE 4 STP ENGINEERING PROCEDURES (Continued)

Procedure. 10CFR50, App. E Number Title Criteria DC-023 Field Change Requests 'III DC-024 Supplier Deviation Requests III, IV, VII DC-025 . Studies and Reports III DC-027 Special Tasks III DC-028 Design Chenge Control III DC-029 Change Review Board .III AD-002 Qualifying Suggested Bidders' IV, VII Engineering Capability and Experience AD-003 Preparation of Inquiry Packages for IV, VII Engineered Equipment AD-004 Bid Evaluation of Engineered Equipment IV, VII AD-007 Preparation of Material Requisitions IV,VII PM-006 Personnel Indoctrination and Training II PM-008 Computer Program Use III J

4 B&R OCTOBER 31, 1980

... .-. . - . .. . . = . . . . . - , . ,, .. -- -. .. - --

. TABLE 5  ;

STP MATERIALS MANAGEMENT PROCEDURES Procedure .

10CFR50, App. B Number Title Criteria MM-HMC-01 Houston Material Control LIV, VII MM-SP-03 Site Purchasing IV MM-SW-08 Site Warehouse VII, XIII MM-SMC-20 Site Material Control IV, VII PP-005 Engineered Equipment Procurement IV PP-006 Bulk Material Purchasing IV PP-007 Engineered Equipment Change Orders IV PP-008 Bulk Material Change Orders IV PP-021 Engineered Subcontracts IV PP-022 Field Subcontracts IV PP-023 Engineered Subcontract Purchasing IV PP-024 Field Subcontract Purchasing IV PP-025 Engineered Subcontract Change Orders IV PP-026 Field Subcontract Change Orders IV i

GCP-6 Field Sponsored Subcontracts IV (Under $100,000)

GCP-9 Bid Comparison, Recommendation IV and Draft of Field Subcontracts GCP-23 Field Sponsored Subcontracts IV (Over $100,000)

! CCP-25 Field Sponsored Subcontract IV Change Order GCP-27 Bidder Evaluation IV GCP-28 Preparation of Field Requisitions IV l

'i B&R OCTOBER 31, 1980 l

TABLE 6 jI STP CONSTRUCTION' PROCEDURES Procedure 10CFR50, App. B

_Ngjber Title Criteria CCP-1 Construction Surveys X CCP-2 Structural Backfill X CCP-9 ECW Pond Embankment Earthwork X CCP-10 Rigging X CCP-14 Vibroflotation X

CCP-15 Fabrication of Miscellaneous and X Structural Steel CCP-20 ECW Pipe Excavation and Backfill X CCP-21 ECW Pond Concrete Paving for Erosion X Protection CCP-22 ECP Soil Cement Erosion Protection X CCP-23 Installation of Safety-Related Concrete X Bolts CCP-25 Quality / Construction Concrete X Procedure CPP-1 Qualification of Coating Application II, IX Personnel-Service Level I Steel CPP-2 Coating Service Level I Steel IX CPP-5 Coating Service Level II Steel and IX Concrete CPP-6 Coating Service Level I Concrete IX DCP-1 Document Control Centers General V, VI Procedure ECP-2 Meggering X ECP-6 Electrical Installations X ECP-9 Cable / Raceway Installation and X

_. Documentation GCP-1 Preparation and Control of Quality / V Construction Procedures B&R OCTOBER 31, 1980 m . - .

. _ , , - ~ . _ _ , , , .. , _ _ . . , , s7 , , . ., . _ _

I TABLE 6 STP CONSTRUCTION PROCEDURES (C:ntinund)

Procedure 10CFR50, App. B Number Title Criteria GCP-4 Housekeeping II GCP-13 Indoctrination & Training II GCP Field Change Request III GCP-22 Receiving an( Receving Inspection VII, XIII GCP-30 Turnovers XI, XIV, XVII, GCP-32 Temporary Waiver Request XV GCP-34 Permanent Item Transfer VIII GCP-35 Storage and Maintenance XIII GCP-36 Field Change Notice III GOP-15 Field Work Authorization X GOP-16 Clearance Control XI, XIV GOP-17 Boundary Tags XI, XIV GOP-23 Control of Field Sketches V GOP-24 Processing Foreign Documents VI GOP-34 Document Subdistribution Control VI ICP-1 Receiving, Functional Check, Storage XIII, XIV and Handling of Instrumentation ICP-2 Calibration of Electronic Distance XII Meters ICP-3 General Calibration Procedure XII ICP-5 Fabrication and Installation of X Instruments and Instrument Sensing Lines MCP-1 Trenching and Backfill X MCP-2 Fabrication and Installation of X Safety Related Piping Systems B&R OCTOBER 31, 1980 1 _. . . . . _ . _ . - _ . - . - - . -. -.- -- - .- -: -

nm. _ , _

TABLE 6 STP CONSTRUCTION PROCEDURES I

(C:ntinued)

Procedure 10CFR50, App. B i Number ' Title Criteria MCP-3 Safety-Related Mechanical Equipment X Installation.  ;

MCP-5 Handling and Tagging of Piping Valves VIII, X, XIII MCP-6 Pressure Testing for Piping Subsystems X, XI and/or Components MCP-7 Field Fabrication and Installation X of Pipe Hangers and Supplementary Steel Supports MCP-9 Bolt Torquing for Mechanical Equipment X and Piping MCP-10 Setting the Reactor Vessel X MCP-13 Mechsnical Fabrication and Instal- X lation MOP-3 Review and Documentation of Isometric V Drawings and Support Drawings M0P-4 Drafting and Processing Piping V Isometrics MOP-6 Traveler Package V MECP-1 Qualification of Welders and Welding II, IX Operators MECP-2 Field Fabrication and Erection of IX Structural Steel HECP-4 Field Fabrication and Welding of IX Piping Systems and Components -

Nuclear MECP-5 Post Weld Heat Treatment IX MECP-8 Control of Welding Material IX MECP-9 .- Field Welding and Inspection of IX Instrument lines B&R OCTOBER 31, 1980

TABLE 6- I

- STP CONSTRUCTION PROCEDURES I (C:ntinued)

Procedure- '10CFR50, App. B l Number Title Criteria MECP-12 Stud Welding IX WECP-2 Oxygen Indicators IX WECP-4 Field Welding of Aluminum Bronze Pipe IX

WECP-5 Instructions for Weld Documentation IX WES-001 Materia'as Engineering Specification IX WES-ll Electronic Alignment, Performance IX Verification, and Maintena .' af Automatic Welding Systems WES-12 Main Coolant Loop Pipe Welding IX WES-13 Insurance and Control of Purge Dams IX WES-14 Procedure for Requesting NDE IX B&R OCTOBER 31, 1980 l

?

BROWN & ROOT Wm_J$# ._

'. FIGURE 1 - CORPORATE ORGANIZATION THE HALLIBURTON CuerANY I

BROWN & ROOT,INC.

BOARD OF DIRECTORS I

PRESIDENT AND CHIEF EXECUTIVE OFFICER 1

1 OPE R ATIONS SR. E XECUTIVE

! VICE PRESIDE NT a

I I ,,.-E.

MARINE SERVCES ADMINISTRATION EMECUTIVE VICE PRESIDENT E M E CUTIVE VICE PRESIDENT CORPORATE CENTRAL E ASTE RN .' .dMsSPMERE WESTERN MEMISPMERE g7g SUSSIDIARIES LEGAL DEPARTMENT DEVELOPMENT g e ENGINEERsNG DIV. GROUP m m GROUP SECRETARY MA NAGE ME N T SR. VICE PRESIDENT g,g.* SR.VeCE PRESsDENT VsCE PRESIDENT VICE PRESIDENT yggg yngsgDENT SR VICE PRESOENT ANO GE N CD'JNSE L VICE PRES )ENT A8.O CMiF8 FNGtNFFR MANUF ACTURING MARINE ENGINEERING MARINE EQUIPMENT 80WER GROUP GROUP mumm -

IU & PROJECT GEN MGMT Muum m MANAGEMENT W 7 S ROUP SR VICE PRESIDENT

' VICE PRESIDENT GROUP VICE PRESIDENT (See Figure 2)-

MARINE IND*> STALES & EMPLOVE E Rf L ATeONS HE AVY CONST. GROUP Mumm Im POLICY VtCE '3f 5 FNT I

}

i

l BROWN & ROOT E N POWER GROUP FIGURE 2 - POWER GROUP ORGANIZATION

'. . . .. . .WR?. .v.'FF.PRf,Sj pf,N,{ , ,, ,,

POWE R GROUP SENIOR VICE PRESIDENT I I I I POWER GROUP FINANCIAL & PE RSONNEL SERVICES MID-VALLEY, INC' ADMINISTRMION MANAGER OUALITY ASSURANCE PRESIDENT MANAGER M AN AGE R (See F ogure 4)

POWE R OPE R ATIONS POWER CONSTRUCTION ' ' SENIOR VICE PRESIDENT SENIOR VICE PRESIDENT AND CHlEF ENG E (See Figure 3) l I I I S UTH TE AS O ECT PRO MANAGEMENT CONSTRUCTION CONSTRUCTION VICE PRE'8tDENT VICE PRESIDENT AND GENER AL M ANAGER (See Figure 5)

I I I I PROJECT CONTROLS ESTl'AATING CONST RUCTION MAINTENANCE MANAGER MANAGER CHIEF ENGINEER MANAGER I I CONTRACT / PROPOSALS M ATE RIALS MAN AGEMENT MANAGER MANAGER

~

PrqC SECT GENER AI.

M AN AGE RS

s t

BROWN & ROOT AT m- -a FIGURE 3 - POWER ENGINEERING ORGANIZATION

• POWER ENGINEERING SENIOR VICE MESIDENT AND CHIEF ENGINEER I

I I ENGINEE RING EN ' " VICE PRESIOENT E PRES EC i

i I mmmmm ENG N NG EN NEER N R ECT GR.

mem E NGINEE RING STAF F N M ANAGE R MANAGER t

(See Figure 7)

TRANSMIS$10N NUCLE AR LICENSING " mum MAN AGER OF PROKCTS - AND DISTRIB JTION CONSULTING SE RVICE "

""' MANAGER MANAGER MANAGER ELECTR Kl SYSTEM TECHNICAL FOREIGN PROKCTS ""'"

AN ALYTICAL SE RVICE mumme PLANNING ammmum SERVICES MANAGER M ANAGE R MANAGE R I

REFERENCE REFERENCE CivlL/5'RUCTUR AL - PROPOSAL DESIGN

" MMAGER i

mundu

^ PO INSTRUMENTATION &

CONTROL MANAGE R ELECTRICAL

"'"" M ANAGE R

, MATE RIAL CONT ROL

• "'"" M ANAGE R d

BROWN & ROOT

%~h'h FIGURE 4 - POWER GROUP QUALITY ASSURANCE ORGANIZATION

\

POWER GROUP OUALITY ASSURANCE MANAGER I I l COMMANCHE PEAK QA AUDITS ASST. OA MANAGER '

.l OUALITY ASSURANCE MANAGER

" HOUSTON

' M ANAGER MANAGER (See Figure 9) l

, FOSSIL

{

QA MANAGER

.i VENDOR ummum SURVEILLANCE MANAGER l

4 M ENGINEERING MANAGER l

BROWN & ROOT "Y 3 FIGURE 5 SOUTH TEXAS PROJECT ORGANIZATION SOUTH TEXAS PROJECT VICE PRESIDENT AND

' GENER AL M ANAGER E

r DEPUTY GEN. MGR* PROJECT AND SITE MANAGEMENT MANAGER STAFF (See Figurs 6) l I ENGINEERING MATERIALS HOUSTON WELDING PROGRAMS PROJECT MANAGEMENT CONTROLS MANAGER MANAGER MANAGER MANAGER i (See Figure 7) (See Figure 8)

mw .ww~.v v_-_____ . _ _ . ~ . . _ _ _ . . . _

l BROWN & ROOT L&3 1

' FIGURE 6 - SOUTH TEXAS PROJECT SITE ORGANIZATION DEPUTY GENER AL 9

MANAGER ANO S:TE MANAGER a.

I I I I

/ PROJECT

~i ASSISTANT ADMINISTRATION DESIGN ENGRG.

ASSISTANT ASSISTANT CONTROLS CONSTRUCTION ^ * "*

• MANAGER CONSTRUCTION PROJECT MGR.

',,l ' MANAGER MANAGED J

1 Il STAFF

" ENGINEER GENERAL SUPERINTENDENT l I I

PERSONNEL SERVICES DISCIPLINES: AREA MAN AGERS ADMIN. SE RVICES CIVIL INDUSTRIAL ENGR. MATERI AL MANAGEMENT MECHANICAL HVAC MANAGER SUBCONTRACTS ADMIN.

ELECTJINSTR. TURNOVER I

I WELDING CONSTRUCTION ENGRG.

I' EQUIPJEXCAV.

j I'

I i

?

i 4

4

M'MTV 77.%W~ .7 ;fs v --

,r,87EWsPT'Fup.W 7, - - .r i w yw w w 4, r**M"whmw. r., w ur .mrwer ,rm,,,, ,g.,_ _ _ . _

BROWN & ROOT

' FIGURE 7- SOUTH TEXAS PROJECT ENGINEERING ORGANIZATION l E NGsNEE RING PROA CT MANAGER e

i E NGReE E RING E NGINE E RING CONTROL

, ADestNISTR ATION 9

i 1 I I SYSTEM 40U4P DE9CN SPECIAL SERVICES

, A337. teeGAG toGR.

PMY9 CAL DE9GN AS$Y.ENGRG MGR 97E DESIGN EasGRG AS$7 ENGRG. IsGR A557 ENGAG 4AGR.

DE $Nm 4 OuAt it y E " CIVtL/STRUCTUR AL

- 5%metamG ARE A DE9GN PNVR' PAL DE90N A55UnameCE E NGaset E RWG DOCUMENT A TION Sv5 TEM DESIGN A55UsI ANCtf " SE mymCES MECHANICAL /MV AC SPECIAL PROBLEMS "usu MODEL DESaGM - STRE55 ANALYSIS ENGeseE E mmG ST AFF mus MA TE RIALS COseTROL ENGRG SERVICES C E LECTReCAL I "' museu

" C L humuu m

$T T T'* hems NUCLE AR laces #SmG

- - ARCHITECTURAL E E ECTRICAL - PIPE MNG SUPPORTS CONTROL SUPPORTS

- " MWWW NG DESIM PiemG N TS uma ME Avv Ctvil J w DE9GN NUCLEAR ANALYSIS MATE RI ALS ENGmEE RsNG

BROWN & ROOT

• IL M FIGURE 8 - - SOUTH TEXAS PROJECT

! blTERI ALS MANAGEMENT MATERIALS MANAGEMENT ORGANIZATION MANAGER 1

SITE HOUSTON ASSISTANT ASSISTANT

^ '^ ^"# MATERIALS MANAGER SITE GENERAL HOUSTON CHIEF PURCHASING SUBCONTRACTS SU8 CONTRACTS WAREHOUSE - MANAGER MANAGER MANAGER MANAGER f

i 1

SITE HOUSTON SITE PURCHASING MATERIAL CONTROL MATERIALS CONTROL MANAGER MANAGER MANAGER 4

SITE TR AF FIC i '

) Humum EXPEDITING BE M M M I SUPPORT GROUP i M M EERI M MANAGER i

MANAGER

BROWN & ROOT

(

l E M_ -

FIGURE 9 -SOUTH TEXAS PROJECT HL&P POWER GROUP OUALITY ASSURANCE OUALITY ASSURANCE MANAGER - STP MANAGER l

L

~

l ,

m OA PROGRAMMATIC Esunimusum m e mmeeenug DIRE CTION a E

' s E SOUTH TEXAS PROJECT s

OUALITY ASSURANCE MANAGER e

a

! 5 1

• OA PERSONNEL SERVICES

• ADMINISTRATION MANAGER i

VENDOR OUALITY SYSTEMS SU RVEILLANCE/ mm mg SITE SURVEILLANCE 4 gg OUALITY ENGINEERING gag OUALITY CONTROL sum COORDIN ATION MANAGER MANAGER

=

MANAGER MANAGER MANAGER RECORDS CONTROL INTERNAL

"^ M SURVEl NCE M g E NDE OUALITY ENGRG* REI SUPERVISOR SURVEILLANCE SUPERINTENDENT MAMGER MECHANICAL NDE OC HOUSTON OA gg OUALITY SERVICES , PTL SU8 CONTRACT

" ' SUPERVISOR SURVELLLANCE OUALITY ENGRG. SUPERINTENDENT COORDINATOR PLANNING / OA TRAINING M&TE

, ,a ELECTRICAllt & C ,, CIVILfSTRUCTURAL , ,

SURVEfLLANCE OUALITY ENGRG. SUPERINTENDENT SCHEDULING COO R DIN ATO R R

CIVIL / STRUCTURAL E'LECTRICAL/l & C OC mE Em MECH. SUBCONTR ACT

, , BUDGETS / ADMIN.

OUALITY ENGRG. SURVEILLANCE SUPERINTENDENT i

^

{' M PR R MENT m COATINGS & INSUR OC SUPERINTENDENT OUALITY ENGRG.

HECE IVING, mm OUALITY ENGRG. um STOR AGE, MAINT.

DINATOR OC SUPERINTENDENT .

d

w_. - .~ -

ATTACHMENT.2' RESPdNSES TO NRC QUESTIONS ON

' STP QUALITY ASSURANCE PROGRAM DESCRIPTION i

.Q-la) . Submit into- th'e docket of the South Texas Project; (STP) Houston l

Lighting & Power (HL&P) and Brown & Root's (B&R) improved QA program controls ' discussed in the HL&P July 18, 1980 response to the Order.to Show Cause dated April 30, 1980 and at the open l

-public meeting August 19, 1980 as a revision to the QA program

description presented in Chapter 17 of the STP Preliminary Safety Analysis Report. Your response should clearly indicate that the previously docketed QA program description is superceded by the new submittal.

A-la)! Part A of Attachment'l is the revised QA Program Description for Houston Lighting & Power and Part.B of Attachment 1 is the I

revised Brown and Rocc Quality Assurance Program Description.

These revised QA program descriptions supersede the previously

~ docketed QA program descriptions presented in Chapter 17 of the I STP PSAR.

Q-lb) Provide a commitment in your revised QA-program description to notify NRC of changes to the docketed QA program description, for review and acceptance, prior to implementation except for organizational changes which are to be reported within 30 days after announcement. (Note-editorial changes or personnel reassignments of a non-substantive nature do not require NRC notification.)

l A-lb) Refer to section 2.11 of the HL&P QA Program Description.

l l Q-2) Provide in your response to it:- I above the additional informa-

[

tion requested below which was previously addressed at the public l

meeting of August 19, 1980.

I g

Q-2a) Describe, both in descriptive form-and through organizational ~

charts.HL&P and B&R' organization structures relative to the STP

]' ,

with particular emphasis on the QA organizations and their W interaction'between HL&P and B&R personnel.

I A-2a) This information is presented in section 1.0 of the HL&P and B&R h- QA Program Descriptions.

)

Q-2b) As outlined in your response to the Order to Show Cause, dated

/* July 28, 1980, the HL&P organization establishes Quality h Assurance Supervisors in each of.the_ major disciplines such as k

civil, structural, and electrical instrumentation. How will each

! of these HL&P Supervisors provide programmatic direction to B&R on matters'related to his discipline? Is it planned to have a j

F direct interface with B&R Quality Engineering of the same

~

discipline?

A-2b) The Quality Assurance Supervisors have a direct interface with B&R-Quality Engineering of the same discipline. They provide 4 programmatic direction to Brown & Root through implementation h

I - -.._#. e se ,.--n.o- , . . . - . . . *

• e-review (as defined in the introduction to the HL&P Quality Assurance Program Description), reviewing and approving procedures applicable to the respective discipline, and indentifying and resolving-deficiencies. This activity involves a virtually continuous interface between the HL&P QA Supervisors and B&R Quality Engineering.

Q-2c) Describe the extent to which QA individuals in HL&P and B&R participate in design and construction daily staff meetings to (a) keep abreast of daily work assignments, (b) assure adequate QA attention and controls are applied to quality affecting activities, and (c) assure adequate QA/QC staffing is available to accommodate daily work assignments and assist in resolving problem areas.

A-2c) Quality Control Superintendents and/or Inspectors attend weekly planning and scheduling meetings, in addition to other planning meetings, for their respective disciplines. During these meetings work schedules are confirmed, permitting Quality Control to assign the required number of qualified persontel to ensure adequate attention and controls are applied to activities affecting quality. An example of these meetings is the preplacement and post placement meetings held in association with safety-related concrete placements.

Brown & Root Quality Engineering meets with design and construction staff personnel at periodically scheduled meetings to determine quality requirements for scheduled activities and to assist in the resolution of problems. Additionally, Quality Engineering interfaces with HL&P QA and B&R design and construction personnel to assure adequate attention to activities affecting q,ality.

HL&P Discipline QA and Quality Systems personnel monitor B&R Construction and published meeting schedules to plan HL&P QA/QC

' participation.

4 Q-2d) Describe your QA program for transferring responsiblities and

' control of quality-related activities from the principal contractors to HL&P during the phase out of design and construction activities.

f A-2d) HL&P and Brown & Root Project Quality Assurance are in the process of establishing and documenting a program for

{ transferring responsibilities and controls for quality-related y

I activities from B&R to HL&P during phaseout of

{ design / construction and during preoperational testing and plant I turnover. This program will be implemented prior to h

~

preoperational testing. Refer to section 2.10 of the revised f HL&P QA Program.

e tr h.

p I-h

Q-2e) In your response to the Order to Show Cause, you state that HL&P is attempting to improve the attitude of the QA/QC personnel through insistence on adherence to procedures, emphasis on the

-independence of the QA/QC function, and improved supervisory support for the QC inspectors. Describe in greater detail how the development and maintenance of the proper QA/QC attitude will be monitored. What management steps are contemplated should departure in expected performance be identified?

A-2e) Brown & Root Construction / Quality Assurance holds periodic meetings in which Construction and Quality Assurance. personnel express their concerns. These meetings are chaired jointly by the Project QA Manager and the Construction General Superintendent. There have been two such meetings and more will be scheduled as required. From these meeti,gs, management has a better understanding of the real problems and can take measures for correction. The B&R Quality Assurance Management Review Board, which meets periodically with HL&P management participation, reviews Quality Assurance activities, including attitudinal and other matters, and provides management direction in the implementation of the Quality Assurance program.

If disagreements arise in the field between QC and Construction-personnel, they will be elevated to the next level of management for resolution. This method of problem solving has been delineated to the B&R Quality Assurance and Construction personnel as described in the " South Texas Project Qtiality Assurance Program" provided as Exhibit 19 to HL&P Response to the Order to Show Cause (July 28, 1980).

HL&P is monitoring the development and maintenance of QA/QC attitudes by reviewing the training programs, talking to QA/QC personnel to keep abreast of their current attitudes and performing implementation reviews to evaluate their effectiveness. HL&P management is in close contact with B&R management to prevent poor QA/QC attitudes. Howe.ver, should departure from expected performance occur, HL&P management will take action based on the specific cause-of that departure by such measures as requiring changes in structure, personnel or training

! programs.

l Q-2f) Provide a matrix of recommendations proposed by Bechtel and MAC and HL&P's evaluation of each recommendation. In those cases where the recommendations were not accepted, the basis for the rejection should be described.

A-2f) See attached copy of letter ST-HL-AE-548.

Q-2g) (1) Describe the extent HL&P will implement Bechtel's recommendations relative to (a) competitive salary ranges

! for QAEs and (b) ratios of staffing levels for QAEs and QCEs i both at HL&P and B&R.

N 1

[ . - . - .-. .-

(2)' ' Provide a comparision of'new staffing and qualification plans for HL&P and B&R relative to the prior situation and-describe your criteria _fov: determining when supplementary personnel from MAC are nc. longer necessary.

~

A-2g) (1)(a) . Management Analysis Company is preparing a report which will present recommendations to HL&P regarding Quality Assurance' activities. The recommendations will address job descriptions and titles, personnel qualifications and salary ranges.

- -(1)(b) HL&P projected staffing levels of Quality Assurance personnel will exceed the ratio suggested.by the Bechtel review.

Brown & Root does not. establish a ratio in their staffing for QAEs and QCEs. The policy has been "hite qualified people to perform the task in question". At the present time B&R has a staff located at the site of,over 240 people which includes 23 Quality Engineers (QAEs) and '132 Inspectors (QCEs).

(2) As indicated in response to Show Cause, (p 1-18, Sec. D)

[ approximately 25 full time professional personnel were in HL&P_ Project Quality Assurance'as of the end of April, 1980.

At that time the need for an' additional twenty personnel was identified and recruiting these personnel began. Since then, a more refined assessment of staffing requirements has been made in light of changes to the QA pror am in response-to the Show Cause Order. This staffing assea: ment was-summarized in a submittal to NRC (letter ST-EO-AE-451', G.W.

Oprea, Jr. to K. Seyfrit, dated 9/24/80, copy attached).

As permanent replacements are recruited and management is-confident in their ability to properly perform their duties, MAC personnel will be phased out or shifted to other assignments. Consideration will be given to certifications,-

previous experience, observed ability to perform on the South Texas Project, and level of quality assurance activity r required'to support the project in the individuals assigned l position.

The most significant change made to the B&R QA organization was in the Quality Engineering-function for the project.

.i The Brown & Root Quality Engineering staff previously was-

~

l l

located in the Houston Offices and comprised of only 3 g

Quality Engineers supporting the South Texas Project. This

group was moved to the site in June, 1980, and joined the' 6

" Quality Control Engineers at the site. This was supplemented with 5 Engineers from Management Analysis l

Company (MAC). The current Quality Engineering staff at the jobsite is'23. Brown & Root has instituted an-aggressive g

' recruiting program in order to replace the MAC personnel by

?-

t h-t

'V 4  ;

+ , . . .e.. ,, . _ . .

14 -

-1 4.

l t i b'

l the' fall of 1981. 'MAC personne1'will be released only when

-l qualified personnel have been hired by Brown & Root and have i become fully-functional in their job assignment.

Q-2h) Your response to the Order to Show Cause contains many-commitments in_a number of quality assurance and construction-areas with completion of these commitments over a time span.

Describe in detail your system to track and ensure completion of required commitments before recommending restart of work in a

.particular area.

I A-2h) .HL&P Managementi has produced a master list recording the status of actions to complete all commitments. These action items are ,

coordinated with the NRC Resident Reactor Inspector on a daily ,

basis. . Each of these actions is. assigned to an individual for completion by a particular due date. . Priorities are assigned ~to meet NRC's schedule for review and close-out of the id tvidual, items. . The Executive Vice-President and the Manager, . Houston I

, Operations, on a weekly basis, review the status of actions to

assure completion of these comnitments.

Q-21)- You state in the response to the Order to Show Cause that key HL&P personnel are being retrained in basic priniciples_of quality assurance. Indicate whether this is intended to be a continuing program, also identify who is responsible for' administering, controling, and evaluating this training.

A-21) The Quality Assurance indoctrination program was administered to key individuals _and will be applied to new personnel. The program is administered and controlled by the Houston Quality Assurance Manager in Houston and by the Supervisor, Quality Systems at the STP site. The effectiveness of this program is determined through the result of Quality Assurance audits. Refer to section 2.6 of the HL&P. revised Quality Assurance Program Description.-

Q-2j) (1)' In regard to qualification of personnel, describe the criteria for determining when upgraded qualifications are achieved for personnel both within HL&P and B&R. Will proficiency tests be'given to personnel performing-activities affecting quality and acceptance criteria developed to determine when an individual is qualified? How i i

and by whom are proficiency tests prepared? Will certificates of qualification clearly delineate the specific l functions the individual is qualified to perform and will:

t they include the criteria used to qualify the individual in each function?

(2) What has been done to verify that personnel, presently on the job, are fully qualified for their positions?

(3) What is being done to upgrade radiograph ir.terpretations i capability?

t

+

L e

- .~ .- - ,

A-2j) (1) HL&P Discipline QA personnel are required to be certified to perform implementation reviews. This certification is an upgrading of the qualifications required in the past for performing surveillance in that proficiency examinations on general QA requirements,' specific procedures and technical competence are required. The exams are prepared by Quality Systems personnel for precedural and general QA requirements and by Discipline QA Supervision for technical knowledge.

Certifications state the qualification requirements and specific areas of certification such as civil, electrical and mechanical.

Brown & Root Quality Assurance personnel who desire to obtain additional certifications (upgrading) are required to have:

1. Sufficient education and work-time experience verified in writing;

2. Satisfied the required reading list;

3. Attended formal classroom training (as required by the discipline Quality Control Superintendent or Level III Quality Engineer).

4. Proficiency testing under the direction of the Level III Quality Engineer.

Under Brown & Root QA procedures persons may be initially certified (or upgraded) by demonstrating proficiency and by having the required education and work-time experience in accordance with ANSI N.45.2.6. NDE personnel will conform to the requirements of SNT-TC-1.A , 1975, which requires proficiency testing in all cases. Other personnel may certify (or upgrade) by formal classroom training and proficiency testing in cases where sufficient verified education and/or work-time experience is not present. Again these requirements conform to ANSI N.45.2.6.

Proficiency tests are prepared by the instructor under the direction of Level III Quality Engineering or by the Level III Quality Engineer himself. In all cases tests are

' reviewed and aporoved by the L3 vel III Quality Engineer.

I Specific functions are delineated in written Brown & Root l

procedures. Certification forms specify education level, I

classroom training, applicable work-time experience, and I

proficiency test scores.

l (2) MAC, HL&P and B&R QA management have performed evaluations of each key supervisory position and where additional expertise is required it is being provided through additional training.

t I

h

(

- ' - - - - ' - - - '- , ,a y 4 A . -, 4 . p p.. p, , - , w c= = _,

Qualification for present B&R QA personnel has been established by:

1. Written verification of Work-Time Experience and Education Level,

2. Training administered as required by the discipline superintendent and/or the Level III Quality Engineer, and i

3. Proficiency testing.

l (3) Radiographers are certified according to SNT-TC-1.A, 1975.

They receive formal training in site procedures (required reading) and classroom training as required by the Discipline Superintendent and NDE Level III Quality Engineer.

Upgrading of skill is presently performed by participation in the refresher training program and the weekly training sessions held by the NDE Quality Control Superintendent.

Additional training may be done at the request of the NDE Quality Control Superintendent and/or the NDE Level III Quality Engineer.

Q-2K) In regard to upgrading quality assurance actions, you state you are writing construction procedures in a format which makes them easier to implement and that already you have revised concrete and welding procedures.

(1) Will personnel who are to implement the revised procedures have input to the changes? (The lack of input into the June 1978 procedure revisions apparently caused concern among QC Inspectors).

(2) What are your plans with regard to training personnel on these procedures? (QC personnel were concerned when 1978 procedure revisions were hastily implemented without sufficient training).

A-2k) (1) See Section 5.1 of the h&R QA Program Description.

(2) See Section 2.2.3 of the B&R QA Program Description.

Q-21) In your response to the Order to Show Cause, you state that inspectors initiate nonconformance reports as apprcpriate only during " planned inspections". Does this preclude an inspector from writing such reports in advance of planned inspection milestones, during surveillance inspections, or when proceeding through the plant? Describe your controls in this area in full i detail.

1 I

hl

)

b _ _ _ _ _ _ _ _ _ . . .. _

A-21) The revised B&R procedure for reporting nonconforming conditions applies to all Project activities involving the procurement, installation, construction, inspection, testing or operation of materials, parts, components and their associated design documents.

The procedure makes clear that each employee on the Project is responsible for bringing to the attention of Quality Assurance any questions regarding materials, items or processes which may not conform to specified requirements of design documents.

s This procedure provides a system for the reporting of nonconform-ances at any time whether or not found during planned inspections.

Q-2m) In your response to the Order to Show Cause you state that following initiation of a nonconformance report, an inspector must obtain acknowledgement by signature of the Construction Foreman or General Foreman. State your procedures for covering inspector action when such acknowledgement is refused or cannot be obtained? Describe your controls in this area in full detail.

A-2m) Should QC be unable to obtain an acknowledgement signature on a nonconformance report (NCR) from the Construction Foreman or General Foreman, the Project QA Manager is informed, who, if necessary, will resolve the matter at a higher level. Regardless of receiving acknowledgement by Construction of an NCR, the NCR will be processed by Quality Assurance in accordance with procedures.

Q-2n) Describe the extent to which authorized individuals, within the HL&P and B&R engineering and QA organizations, responsible for determining acceptable dispositions and closeouts of nonconformances are preselected and identified on official documents and state whether the document is used in the nonconformance process.

A-2n) Dispositions of NCRs are provided by the Material Review Board.

4 The Material Review Board (MRB) consists primarily of a Project Site Engineer (PSE), a Quality Engineer (QE) and representatives from Construction and Project General Management. The chairman of the MRB is the Quality Engineer. As applicable, the MRB may request attendance and/or inputs from the Authorized Nuclear Inspector (ANI), Purchasing, Material Control or Westinghouse NSSS representatives. The PSE and the QE are responsible for all 6 final decisions in MRB matters, however, the concurrence of HL&P f

is required on all MRB dispositions prior to initiation of work.

j The MRB is responsible for conducting meetings to review, disposition and approve all NCRs except those dispositioned

) " Rework" or " Standard Repair" by the Lead Inspector. Formal meetings are not required in all cases as long as the chairman

'y obtains the approval of all applicable MRB members.

ll i  !

.. .,.g.-...~

-- = - --

Acceptability of rework / repair of items is verified by reinspecting the item as originally inspected or by a method at least equal to the original inspection method. Verification for ASME Code items by the ANI is performed concurrently with B&R QA verification.

HL&P Discipline Quality Assurance concurrence is required on all Material Review Board dispositions.

Q-2o) In your response to the Order to Show Causa; you state that where appropriate hold tags or other work constraints wf11 be applied.

The term "where appropriate" does not provide us witn a sufficient understanding of the degree to which nonconforming items will be segregated and tagged to control further processing or installation. Describe in full /etail HL&P and B&R Controls in this area.

A-2o) In the Quality Assurance procedure for the control of nonconform-ing items, the term "where appropriate" is not used. Instead, the term "whenever practical" is used. Practicality is determined by the accessibility, numbers of items (i.e. bulk orders), etc. 'he B&R nonconformance procedure states that whenever practical, nonconformance items are identified with hold tags to prevent further processing until dispositioned by the

( Material Review Board. Nonconforming items are segregated, whenever practical, from those which are acceptable to prevent inadvertant use or installation. When physical segregation is not possible due to bulk, size or weight, hold tags and roping

( off the immediate area is an acceptable substitute for

}

segregation. If physical conditions limit the application of hold tags a statement to that effect is entered in the ' Remarks' section of the nonconformance report.

Q-2p) Describe in full detail, your controls which will assure that corrective actions are completed in a reasonable time frame.

p A-2p) Procedures have been developed and implemented by B&R which will assure that corrective actions are completed in a reasonable time frame. Quality Engineering assigns a " completion due date" to each Corrective Action Request (CAR). The CAR has specific tire y

limits for taking responsive action and may " constrain" or " hold"

1. work on specific tasks or by specific crews until resolved.

Failure to respond satisfactorily within the specified time will result in a "Stop Work" order at the direction of the cognizant g

QE Supervisor. Corrective action is verified by QA/QC when notified by the action designee. Follow-up review and

~

reverification is performed and documented by QA/QC within 30 days to assure the effectiveness of the corrective action. If ineffective, a Stop Work may be initiated at the discretion of the cognizant QE Supervisor.

Q-2q) For quality affecting activities, describe the criteria for determining (a) what inspections are to be performed, (b) the accuracy requirements of measuring and test equipment.

tv h

t e

L - --- -- - +.-. . . ,. .w- 2 _

.e

~A-2q) Refer to section 2.10 of the B&R Quality Assurance Program Description.

Q-2r) Describe HL&P's and B&R's QA involvement in the documented evaluation of inspection and test results to assure they are complete and accurate.

A-2r) B&R QC documents inspection and test results.- B&R Quality.

Engineering reviews final record packages to ensure that all inspection and test results are documented, complete and acceptable. Reviews of records of each activity are included in the implementation review performed by HL&P Discipline QA.

Q-2s) Describe who within HL&P and B&R is responsible for the calibration of measuring and. test equipment including NDT devices and describe the QA orginization involvement in this area. Also state that person or persons qualification.

A-2s) The calibration of measuring and test equipment is performed by the B&R calibration facility. B&R Quality Assurance Site Surveillance is responsible for assuring that the system for the control of measuring and test equipment is implemented and in conformance to established procedures. Refer to section 12 of the B&R QA Program Description.

HL&P Discipline Quality Assurance performs ie91ementation review of the B&R overall program to assure that B&R Construction and Quality Assurance Site Surveillance are maintaining proper control of measuring and test equipment (Refer to section 12 of the HL&P Quality Assurance Program Description). Qualification

requirements for the personnel performing the calibration are:

i i

Calibration Facility Supervisor - Graduate of a four year accredited engineering or science college or university with 2 years of experience in the field of instruments; high school graduate with four years of related experience in the field of instruments.

Calibration Specialist - Two years of accredited college, university or technical school and one year related experience in the field of instruments; high school graduate with two years of related experience in the field of instruments.

Calibration Technican - High school graduate or hold a high school equivalent certificate, read, write and communicate in English; two years experience in testing of calibrated tools or measuring and test egoipment in power plants, heavy industrial or military facilities.

.Each person is trained and certified as being quclified to I perform the assigned work.

t s

e h

b v

(

.. _ . _ _ . m. .

1 r

I Q-2t) Describe your controls for documenting and maintaining as-built conditions on drawings and specifications. Describe the extent as-bi!- drawings and specifications identify nonconformances I dispr.t; oned as " accept as is".

A-2t) Refer to the B&R Quality Assurance Program Description,-Section 3.2.10.

Q-3) In your submittal of the revised QA program description, provide a means for locating your responses to the above specific r requests.

A-3) Specific answers are provided above or answers are provided in the revised QA program descriptions and a reference is indicated.

==

1 Ii

+.,,S_ ,-m *- =

V _