ML19341C484

Forwards Updated Description of Operational QA Program,Which Supersedes 781229 Submittal Re Administrative Changes & Changes for Applicability to Regulatory Documents

ML19341C484
Person / Time
Site:	Fort Calhoun
Issue date:	02/24/1981
From:	William Jones OMAHA PUBLIC POWER DISTRICT
To:	Clark R Office of Nuclear Reactor Regulation
References
NUDOCS 8103030622
Download: ML19341C484 (37)

Text

r Y

Omaha Public Power District 1623 HARNEY e OMAHA. NEORASMA 68102 e TELEPHONE S36 4000 AREA CODE 402 February 24, 1981 .+

,e 'h g Director of Nuclear Reactor Regulation /lP p 'h ATTN: Mr. Robert A. Clark, Chief 2 ca 2 Operating Reactors Branch No. 3 8-~ O -.

U. S. Nuclear Regulatory Commission 4g Washington, D. C. 20555 'O d t,

Reference:

Docket No. 50-285 h "

Fort Calhoun Station Unit No.1 Operational QA Program Gentlemen:

An updated operational Quality Assurance (QA) Program for Fort Calhoun Station Unit No. I was submitted by Omaha Public Power District letter dated December 29, 1978. The QA Program for Operations has been modified to reflect the latest NRC requirements pertaining to the inclu-sion of diesel generator fael oil in the QA Program.

Enclosed are forty (40) copies of the updated description of the operational QA Program for Fort Calhoun Station Unit No.1. This sub-mittal supersedes our submittal dated December 29, 1978. A single line in the margin designates changes from the previous submittal. The changes constitute administrative changes and changes for applicability to regulatory documents.

Since ely,

) te W. C Jones Divi on Manager Prod tion Operations WCJ/KJM:jmm Enclosures l cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.

Washington, D.C. 20036 8103030h b [

\

l l

I 17.0 QUALITY ASSURANCE DURING TIIE OPERATIONS PHASE l

This document describes the Omaha Public Power District's (OPPD) Quality Assurance Program for the operation of Fort Calhoun Station Unit. No. 1. The program is based on the criteria of Appendix B to 10CFR Part 50, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants";

General Design Criterion 3, Appendix A to 10CFR Part 50, " Fire Protection";

Appendix E to 10CFR Part 71, " Quality Assurance Criteria for Shipping Pack-ages for Radioactive Material;" and the guidance provided in: American National Standard, ANSI N45.2, " Quality Assurance Program Requirements for Nuclear Power Plants," and its associated daughter standards; officially promulgated Regulatory Guides and Standards associated with WASil 1283, WASH 1309, and WASil 1284; and Appendix A to Branch Technical Position 9.5-1,

" Guidelines for Fire Protection for Nuclear Power Plants." The program will be applied to: Critical Quality Elements (CQE) defined as those structures, l systems, components, or items whose satisfactory performance is required to prevent or mit.igate the consequences of postulated accidents that could cause undue risk to the health and safety of the public; those fire protec-tion systems and equipment used or installed in all areas housing safety-related equipment, and other areas where an unsuppressed fire could poten-tially damage safety-related structures, systems or et.inponents ; those acti-vities af fecting the components of radioactive material packaging for trans-port which are significant to safety; and Limited Critical Quality Elements (Limited CQE) defined as those structures, systems, components er items whose satisfactory performance is required to prevent or mitigate the f ail-ure of those structures, systems, components or items identified as CQE.

17.1 Organization OPPD's organization for carrying out an effective operations phase Quality Assurance Program is shown in Figure 17.1. The Division Manager - Environ-mental and Regulatory Affairs is the upper %rel off-site management posi-tion which has direct management responsibila y for formulation, implementa-tion, and assessment of the effectiveness of the Quality Assurance Program.

The Division Manager -

Production Operations is the upper level off-site management position which has direct management responsibility for plar.t operations and for formulation, implementation, and assessment of the effec-tiveness of the Fire Protection Program and the Packaging of Radioactive Material. for Transport. Those positions in Figure 17.1 that have responsi-bility for Fire Protection Program implementation are indicated by an aste-risk (*) and those positions that have responsibility f.r Radioactive Mater-ial Packaging implementation are indicated by a (#). The Division Manager -

Engineering is the upper 1cvel off-site management position which has direct responsibility for designation of those structures, systems, components or items classified as Critical Quality Elements (CQE's) or Limited Critical Quality Elements (Limited CQE's), and covered by the Quality Assurance Pro-gram, and for designation of the fire protection systems, equipment, and i

zones covered by the Fire Protection Program. The Division Manager - Mater-ial Management is the upper level off-site management position which has direct management responsibility for farmulation and implementation of the Nuclear Purchasing Procedures.

< v 0

l' l

17.1.1 Manager - Fort Calhoun Station The Manager -

Fort Calhoun Station shall have direct responsibility for the safe operation of the nuclear power facility. In all matters pertaining to the nuclear facility, the Manager - Fort Calhoun Station shall report to and be directly responsible to the Section Manager - Operations.

17.7.2 Plant Review Committee (PRC) l A committee composed of plant staff members designated as the Plant Review Committee (PRC) shall act in an advisory capacity to the Manager - Fort Cal- l houn Station. The responsibilities and authority of the Plant Review Com-mittee are delineated in Section 5.5.1 of Fort Calhoun Station Unit No. 1 Technical Specifications, Appendix A to Operating License No. DPR-40.

17.1.3 Safety Audit and Review Committee (SARC)

Another committee composed primtrily of off-site, highly qualified and experienced District management personnel and consultants, designated as the Safety Audit and Review Committee (SARC), shall function to provide the independent review and audit of activities as designated in Sections 5.5.2 and 5.5.3 of Fort Calhoun Station Unit No. 1 Technical Specifications, Ap- l pendix A to Operating License No. DPR-40. The SARC reports to and advises the Assistant General Manager on reviews and audits of the designated acti- l vities.

17.1.4 Manager - Quality Assurance The Manager -

Quality Assurance is responsible for the development and implementation of the Quality Assurance Program for design, construction, and operation. This responsibility extends into all project and operations activities including engineering, design, procurement and construction. Ile reports on all technical and administrative matters to the Division Manager

- Environmental and Regulatory Affairs. This reporting arrangement pro-vides isolation of construction and operational costs and scheduling in-fluences from activities performed by the Manager - Quality Assurance. He has the duty and anthority to identify quality-related problems; to initi-ate, recommend, or provide solutions; and to verify the implementation and effectiveness of corrective action taken. He has authority to "Stop Work" on design, procurement, fabrication, installation, or packaging of safety-related structures, systems, or components, fire protection systems and equipment, and shipping packages for radioactive material. His principle duties and responsibilities include the following:

(1) Manages the OPPD Quality Assurance Program.

(2) Supervises and coordinates an independent audit, review, and update of OPPD quality activities to assure compliance with, and effecciveness of, the Quality Assurance Program.

(3) Training and indoctrination of OPPD personnel in Quality Assurance activities.

1 l

l 1

i o

9 .

(4) Prepares Quality Assurance procedures, instructions, and reports. Preparation and maintenance of OPPD's QA Manual.

(5) Reviews draft standards submitted by various standards agen-cies for review. Coordinates response by District for QA-related draf t standards.

(6) Acta as an internal consultant on Quality Assurance and nu-clear safety related matters.

(7) Maintains liaison with the NRC and vendors on quality matters.

(8) Maintains a file of quality-related codes and standards for the construction and operation of nuclear power plants.

(9) Reviews design data and changes, operating procedures, and test reports for quality requirements.

(10) Serves as a member of various committees including the Safety Audit and Review Committee.

(11) Maintains OPPD's list of qualified vendors and suppliers.

Add and removes names from this list as necessary to pre-serve quality standards within the corporation.

(12) Verifies that the Quality Assurance related requirements of the Fire Protection Program, approved by the NRC, are satisfied.

The qualification requirements of the Manager - Quality Assurance are:

(1) A college degree or equivalent in engineering. Registration as a professional engineer in the state of Nebraska is desir-able. Advanced degree in management or work in quality-related discipline is desirable.

(2) Eight (8) or more years in a supervisory or management posi-tion related to the operation, maintenance, testing, and construction of nuclear power plants, including quality assurance.

(3) Basic understanding of regulations, standards, and guides '

relating to quality assurance.

(4) Thorough administrative and supervisory skills and technical know' ;c of quality assurance requirements for nuclear power l ' int (5) A degree of initiative, sound judgment and maturity. )

Man. .e the ability to make sound decisions and defend them to L, , management.

?

I l

t

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

__ - = _.

9 y (6) The ability to work closely and in harmony with others. The ability to coordinate several complex operations simultane-ously.

(7) An excellent degree of emotional stability is a major re-quirement of this position.

(8) Must possess skill as a manager and a very high degree of personal integrity.

The Manager - Quality Assurance has assisting him in the execution of his duties and responsibilities a QA Engineering Staff as necessary, including:

(1) The Corporate QA Engineer - has primary responsibility for OPPD Quality Assurance activities during design and procure-ment.

(2) The Construction QA Engineer - has primary responsibility for all Quality Assurance activities at the construction site.

(3) The Operations QA Engineer - has primary responsibility for Quality Assurance activities at an operating nuclear power plant.

The Corporate QA Engineer's duties and responsibilities are:

(1) Plans, schedules, and conducts audits of procurement (in-cluding fuel) and design activities to determine compliance with and effectiveness of the District's QA Program.

(2) Maintains a list of qualified vendors and services to nuclear power plants operating and under construction. Conducts necessary audits of vendors and suppliers and reviews their QA Manuals and programs in making this determination.

, (3) Coordinates source inspection and witnessing of test of components and equipment for nuclear power plants as re-quired.

(4) Maintains file of applicable QA codes and standards for construction and operation of nuclear and fossil power plants, including their ordering and distribution. Furnishes interpretation of same on request.

(5) Prepares needed QA Procedures and changes to QA Manual.

Controls distribution of QA Manual.

(6) Assists in conducting QA reviews of procedures, tests, test results, DCR's and other documents requiring QA review.'

(7) Maintains District's QA files, including QA training records and qualification files.

1 l

_4 t

r

4 1

The Construction QA Engineer's duties and responsibilities are:

(1) Plans, schedules, and conducts audits of construction acti-vities to determine compliance with and ef fectiveness of the District's QA Program.

(2) Assists in conducting QA reviews of procedures, tests, test results, field changes, and other documents requiring QA review during construction.

(3) Provides training for and qualifies OPPD civil, mechanical, and electrical QA inspectors for the construction effort.

(4) Maintains liaison between Contractor and Architect-Engineer QA and QC personnel.

(5) Monitors accumulation, active files storage, and transfer of QA records to the QA records vault.

(6) Interprets codes and standards involving construction activities.

(7) Identification, reporting, and followup action on construc-tion deficient items requiring corrective action.

(8) Acts as on-the-scene advisor to the construction management personnel on matters of quality.

(9) Assists 1- monitoring and auditing of the testing program.

The Operations QA Engineer and his staff of QA inspectors are stationed at the Fort Calhoun Station and are involved only in QA activities. The Opera-tions QA Engineer's duties and responsibilities are:

(1) Plans, schedules, and conducts audits of operating plant activities to determine compliance with and effectiveness of the District's QA Program.

(2) Maintains permanent QA records vault and other QA files at an operational nuclear power plant.

(3) Advises Stores Clerk on Quality Assurance requirements relating to the maintenance, storage, and inspection of spares for the operating plant.

(4) Reviews CQE, Limited CQE, fire protection, and radioactive l material packaging, work requests, maintenance work orders,

, requests for quotations, purchase orders, work and installa-l tion packets and other documentation for inclusion of neces- l l sary quality related data , adding same as necessary, to en-sure complete documentation for an operating plant.

1 1

(5) Witnesses inspection of incoming material, as required. to ensure quality and documentation.

(6) Acts as on-the-scene advisor to the Manager - Fort Calhoun Station on matters and questions related to QA activities.

(7) Assists the Manager -

Quality Assurance in the training of Station and other District personnel in matters relating to QA activities.

(8) Assists in monitoring and auditing of the quality assurance related portions of the testing program including testing of fire protection systems and the qualifications of test personnel.

(9) Assures the effective implementation of the Fire Protection Program on site by planned inspections and scheduled audits.

He will report the results of these inspections or audits to the Manager - Quality Assurance who will assure and verify that the results are promptly reported to cognizant management personnel.

17.1.5 QC Staff The QC Staff is responsible for quality control actions as specified in Plant Standing Orders. The QC Staff reports to the Supervisor - Maintenance, l Fort Calhoun Station.

17.1.6 Division Manager - Material Management The prime QA responsibility of the Division Manager - Material Management is to provide uniform procedures to be used by other District personnel when procuring Critical Quality Elements for Fort Calhoun Station Unit No.

1. Other specific duties as prescribed by the Nuclear Purchasing Procedures include:

(1) maintenance of procurement records; and (2) direction of corrective action by suppliers for deficiencies in his documentary evidence of quality, shipping damage, or count discrepancies.

17.1.7 Section Manager - Generating Station Engineering The Section Manager - Generating Station Engineering, under the Division Manager - Engineering, has primary responsibility for maintenance of as-built data; performance and review of detailed design for the nuclear power plant; development and review of procurement specifications; classification of safety-related structures, systems and components; and the modifications associated with the Fire Protection Plan.

)

1

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

i 17.1.8 Section Manager - Technical Services The Section Manager - Technical Services, under the Division Manager - Pro-duction Operations, has primary responsibility for control of technical support for the nuclear power plant staff, including nuclear material man-agement, radiological and chemical control, plant modifications, environ-mental sciences, and packaging of Icw specific act'vity radioactive material for transport.

4 17.2 QA Program 17.2.1 Corporate Policy OPPD's corporate policy is to construct and operate nuclear power plants with due regard for public and plant safety as prescribed by various regu-latory requirements. Since there is a close correlation between safety and plant quality, OPPD has as its goal the establishment of a program for quality achievement and assurance in nuclear power station desip, construc-tion and operation which assures that the above policy is met. The OPPD QA Manual is the document which states OPPD's corporate qu r.tity policies, goals, and objectives, and defines responsibilities.

OPPD assures transmittal of these quality policies to all concerned by controlled distribution of the QA Manual and changes thereto to all levels of management associated with the OPPD QA Program. In addition, specific QA Procedures are authorized and promulgated, further defining detailed objec-tives for attaining and maintaining high quality in the design, construc-tion, and operation of its nuclear power plants.

OPPD's Quality Assurance Program has the full support r,f upper management.

The As 1stant General Manager authorizes issuance of the QA Manual and all 4

revisions thereto, which defines the general requirements and specifies the responsibilities for implementing OPPD's Quality Assurance Program. Imple-mentation of the general requiresents documented in the QA Manual is facili-tated by specific requirements and procedures documented in the Purchasing Manual, Quality Assurance Procedures, Generating Station Engineering Procc-dures Manual, and the Fort Calhoun Station Operating Manual.

! The Critical Quality Element and Limited Critical Quality Element struc-tures, systems, and components controlled by the QA Program are classified to an extent consistent with their importance to safety and are identified in the Generating Station Engineering CQE Evaluation of Fort Calhoun Nuclear Station. Limited Critical Quality Elements include consumables such as gas-kets, packing, lubricants, and diesel generator fuel oil among many other off-the-shelf items. With regard to fire protection, the QA Program is ap-

.plicable to the fire pumps, main loop firemain piping, fire walls, penetra-tion fire seals, automatic initiated detector systems, automatic initiated independent fire suppression systems, and all piping, valves, sprinklers, and nozzles associated with automatically initiated water fire protection systems. The actual fire areas, room numbers, and protected systems are as described in the Fire Protection Program Review for Fort Calhoun Unit 1 l dated December 31,.1976. The pertinent sections of the QA Program shall be applied to the Fire Protection' Program to an extent consistent with their importance to safety. Therefore, Sections 17.6, 17.8, 17.9, 17.12 and 17.13 are not applicable.

l

[

The QA Program shall apply to the procurement and use of packaging for the transport of radioactive material. This shall include receptacles, wrap-pers, and their contents excluding fissile material and other radioactive material, but including absorbent material, spacing structures, thermal insulation, radiation shielding, devices for cooling and for absorbing mechanical shock, external fittings, neutron moderators, nonfissile neutron absorbers, and other supplementary equipment which have safety significance.

The programs all assure that the package design, fabrication, assembly, testing, maintenance, modification, and repair conform to the approved design of each individual package and that the handling, storing, cleaning, inspecting, assembling and shipping meet tha requirements of 10CFR Part 71 and Department of Transportation Regulations.

Any disputes which cannot be resolved to the satisfaction of either the Manager -

Quality Assurance or the Division Manager -

Environmental and Regulatory Affairs will be brought before the Assistant General Manager.

In addition, periodic training sessions are held to promulgate and explain policies, goals, and objectives including changes thereto. Needed changes to the OPPD QA Program have been identified by means of:

a. planning, performing and reporting audits

b. continning review of NRC Regulatory Guides and ANSI N45.2 standards

c. participation in the Edison Electric Institute Task Force on Qua1ity Assurance

d. response to NRC questions and identified deficiencies Changes to the Fort Calhoun Station Unit No. 1 QA Program are accomplished by isruing technical supplements to the QA Program. These changes are not incarporated into the FSAR.

17.2.2 QA Manual The Preface of the OPPD QA Manual states:

"The QA Manual shall be implemented and applied to nuclear power stations being designed, constructed and operated by OPPD. This QA Manual establishes the OPPD Quality Assurance Program and sets forth the Quality Policies for OPPD. Compliance with this QA l Manual as well as QA Procedures developed therefrom are mandatory.

Management shall give full support to maintaining an effective quality program. Compliance with applicable requirements of the QA Manual shall be made a condition of contract for supporting Companies."

l The OPPD QA Manual requires that OPPD organizations and Companies under con-l tract to supply technical services or products for the plant comply with the following requirements:

l l 1

1 I

l

t

a. The authority and duties of individuals and groups performing qua-f lity assurance functions are clearly established and delineated in l writing. They have sufficient authority and organizational free-dom to:

(1) identify quality problems (2)- initiate, recommend, or provide solutions for conditions ad-l verse to quality (3) verify implementation

b. An individual or group assigned responsibility for QA functions,

, such as auditing or otherwise verifying that an activity has been

correctly performed, is independent of the individual or group

directly responsible for performing the specific activity.

, Copies of the QA Manual are issued in a controlled manner. A mailing list is maintained by QA showing recipients of the QA Manual. Personnel signify the receipt of their copy of the QA Manual by signing and returning a re-ceipt card to the Manager - Quality Assurance. Recommended changes to this manual are solicited and all such recommendations are given due considera-

! tion by the Manager - Quality Assurance. Necessary revisions are prepared, l reviewed for adequacy, approved and issued in a controlled manner similar to the QA Manual. These revisions are also controlled by means of a receipt i card.

Revisions are dated and identified with formal revision numbers as they are

, issued and contain a list of effective pages so that individuals in the field have '.he capability of determining if their QA Manual is complete and up to date.

17.2.3 QA Procedures OPPD assures that the various QA Program Procedures are derived from QA policies, goals, and objectives by means of a review of these procedures, both prior to issuance and during audits of the activity prescribed by the procedure. Procedure review is accomplished in accordance with QAP #3, Document. Review Procedure. Audits are conducted in accordance with QAP #17, 7

Audit Planning, Performance, and Reporting.

17.2.4 Training and Indoctrination i

. Personnel responsible for performing quality-affecting activities are in-j structed as to the purpose, scope, and implementation of the quality-related manuals, instruction, and procedures by participation in the OPPD " Quality Assurance Training Program," the Fort Calhoun Station " Indoctrination Pro-gram and Training Program," the Chemical and Radiation Protection Training

Program, and the on-the-job training provided by each activity.

I I

i 1

l

• l l <

l 1

l The QA Manual specifies that personnel performing quality-affecting acti-vitics are required to possess documented evidence that they are trained and l

qualified in the principles and techniques of the actiaity being performed.

Quality Assurance Procedures providing for training and qualification in the principles and techniques of the activity being performed are as follows:

(1) QAP #10, Nondestructive Evaluation (NDE) Personnel Admini-stration (2) QAP #18, Auditor Training and Qualification (3) QAP #19, QA Indoctrination and Training of Personnel (4) QAP #8, Qualification of Construction Inspectors Fort Calhoun Starion standing orders specify the training and qualification requirements for :pe ra to rs , maintenance personnel and chemistry and radia-tion protection personnel. The QA auditing and surveillance programs pro-vide assurance that the personnel are trained in the activity concerned prior to the event. The Fort Calhoun Station Training Manual specifies the training and qualification requirements for Security and Fire Brigade per-sonnel. Standing Orders specify the qualification and certification of maintenance Quality Control personnel.

The scope, the objective, and the method of implementing the various indoc-trination and training programs are prescribed in writing and records are maintained to verify the progress and success of the programs. This docu-mentation is audited and the programs receive periodic review.. within the applicable divisions to verify their adequaty.

The indoctrination and training programs d; scribed above assure that the proficiency of personnel perfo rming quality-af fecting activities is main-tained by specifying retraining, re-examining, and/or recertifying in ac-cordance with the specified require,wnts.

The indoctrination and training programs provide for documenting the train-ing sessions, describing the content, th: date held, the attendees, and the results of any examinations conducted inherent therewith.

17.3 Design Control The OPPD Quality Assurance Program provides for several levels of design control for modification of or additions to an operating nuclear power plant. OPPD design activities meet applicable NRC Regulatory Guide require-ments for all safety-related activities including Regulatory Guide 1.64,

" Quality Assurance Requirements for the Design of Nuclear Power Plants." QA audits assure that OPPD's design control measures provide a clear definition of design interfaces, review and approval of initial design, including changes or revisions, and that those performing design review activities are independent of those originating the design. The verification of engineering and design adequacy of the contractors' design documents will be performed in accordance with the contractor's approved Quality Assurance Program and Procedures and by OPPD through review by either Generating Station Engineering (GSE) or Technical Services, and the Plant Review Committee.

]

4

• 4 Procedures for OPPD design development and review are contained within the QA Manual, Station Operating Manual, GSE Procedures Manual, and the Plant Modification Procedure. The GSE and Technical Services design activities are controlled through GSE Procedures Manual. Administrative instructions l for initiating, controlling and documenting modification of station equip-ment and facilities is provided through Plant. Standing Orders. GSE Proce-

dures describe the various , relationships of the design development and veri-i fication organizations within the design prccess.

., The Manager - Fort Calhoun Station is responsible for reviewing and approv-

! ing design prior to implementation at Fort Calhoun Station Unit No. 1.

. Utilization of the Plant Review Committee is governed by the Station Operat-1 ing Manual and Plant Standing Orders for their review functim l If an unreviewed safety question is involved, the design is further reviewed by the Safety Audit and Review Committee as specified in the SARC Charter

prior to submittal to the NRC for approval.

GSE Procedures require a r. Independent review of desigi documents. GSE Procedures assure that design characteristics can be controlled, inspeti.d,-

and tested. Independent design review and verification activities are re-

quired by the QA Manual to be performed under the authority of the designer j organization's QA Program by appropriately qualified engineers for engineer-ing calculations, specifications, and design drawings for sa fety-rela ted j items.

The QA Manual states:

"The selected documents shall be reviewed to determine that they contain, as appropriate:

} '

a. Applicable design bases, technical requirements, regulatory requirements, component and material identification, drawings specifications, codes and industry standards, tests and in~

spection requirements, and special process instructions for such activities as fabrication, cleaning, erection, packaging, handling, shipping, storage, and inspection;

b. Requirements that ident.ify the documentation to be prepared, maintained, submitted, and made available to the purchaser j for review and comment, such as drawings, specifications, procedures, inspection and test records, personnel and pro-

, cedure qualifications, and chemical and physical test re-i suits on materials;

c. Requirements for the retention, control, and maintenance af i documents and quality assurance act.ivities records."  ;

GSE Procedures' describe how reviews and verifications are conducted through the use of a design verification checklist. This procedure complies with Section 6 (Design Verification) of ANSI N45.2.11, " Quality Assurance Re-quirements for the Design of Nuclear Power Plants."

i  !

t 1 I

-- . - - , .- , .__.--~--~m ,-# -.

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

The QA Manual requires:

" Design adequacy shall be verified by systematic evaluation of the ele-ments of the design with respect to requirements for design, safety, function, and quality. Verification may be accomplished by performing design reviews, by the use of alternate or simplified calculational methods, or by conducting a suitable test program. The verifying pro-cess shall be performed by individuals or groups other than those who performed the original design, but who may be from the same organiza-tion. The verifications shall be legible and be in a form suitable for reproduction, ftling, and retrieving."

Detailed design or design changes involving Critical Quality Elements (CQE's) that are performed by 6enerating Station Engineerir. t (GSE) are performed in accordance with the GSE Procedures Manual. GSE Procedures state that technical calculations and safety analyses must be provided by the design engineer and describe how safety analyses and technical calcula-tions are processed. GSE Procedures provide design controls for compati-bility of materials and accessibility for inservice inspection, maintenance, and repair.

Materials, parts, equipment and processes essential to Critical Quality Elements, the Fire Protection Program, and packaging for shipment of radio-active material are required to be selected and reviewed for suitability of application. The methods of assurance of suitability are required to in-clude independent design verification by individuals or groups competent in the applicable field of design and related nuclear power plant requirements.

The methods of selection and review are required to provide for (as applic-able): reactor physics, stress, thermal, hydraulic and accident analysas; compatibility of materials; as low as practicable radiation levels; accessi-bility for inservice inspection, maintenance and repair; test requirements and delineation of acct -* ance criteria for inspections and tests.

Measures shall be established by the Section Manager - Generating Station Engineering, Section Manager - Technical Services, and Manager - Fort Cal-houn Station to assure that the applicabic guidelines of Regulatory Guide 1.120 or approved alternatives are included in design and procurement docu-ments prepared by their personnel and that deviations therefrom are control-led. Field changes and design deviations will be subject to the same level of controls, reviews, and approvals that were applicable to the original document. Quality standards will be specified in the design documents such as appropriate fire protection codes and standards. Deviations or changes from these standards will be individually approved. New designs and plant modifications, inc!vding fire protection systems, will be reviewed by quali-fied personnel to assure inclusion of appropriate fire protection require-ments. These reviews will include items such as:

a. Reviews to verify adequacy of wiring isolation

b. Reviews to verify appropriate requirements for room isolation

c. Reviews to verify appropriate material is used l Design control measures for packaging for transport of radioactive material shall be applied to items such as: criticality physics, radiation shield-ing, stress, thermal, hydraulic, and accident analyses; compatibility of materials; features to facilitate decontamination; and delineation of accep-tance criteria for inspections and tests. Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design. Changes in the conditions specified in the package approval require Commission approval.

All materials, parts, and equipment for CQE structures, systems, and compon-ents are procured in accordance with the Nuclear Purchasing Procedures regardless of commercial or previous approval stattm. The Nt.clea r Purchas-ing Procedures require an engineering and quality review of all procurement documents for CQE items.

Requests for design changes are originated in accordance with, and processed through, a review chain described in Plant Standing Orders. l GSE Procedures require that all CQE design changes be processed through the design engineer and that an independent reviewer reviews the changes. All aspects of the process a re documented and retained in the mas file per GSE Procedures.

Design documents are then transmitted to the ::tation for review and approval in accordance with Plant Standing Orders. These standing orders delineate l the p la nn i r.g , control, and documentation of station modifications at the Station. Errors and deficiencies in the design process are normally de-tected during the design verification performed in accordance with GSE Procedures, and the design reviews of the Plant Review Committee or the Safety Audit and Review Committee. The rejected design is returned to the designer for redesign with their documented comments.

QA audits are another mechanism by which errors and deficiencies in the design process are documented and corrected. An audit of OPPD design acti-vities is performed annually and as ordered by the Manager - Quality Assur-ance or the Safety Audit and Review Committee. Audits are performed utiliz-ing ANSI N45.2.ll criteria and are conducted as needed to ensure compliance.

Design activities include design initiation, design bases preparation, design specifications preparation, and design output document preparation and control. Audits are performed using audit checklist (s) prepared by the audit team and approved by the Team Leader prior to commencing the audit.

Upon completion of each audit, a formal audit report is prepared. The audit report contains any deficiencies or nonconformances found during the audit, and recommended actions to be taken. If necessary, a re-audit of the area is performed to verify the corrective action taken. Audits are also sche-duled and documented to verify compliance with the Fire Protection Progra:n, including design and procurement documents, instruments, procedures :.d drawings, and inspection and test activities.

The OPPD QA Program requires that. OPPD's manufacturers' and contractors' design activities meet applicable NRC Regulatory Guide requirements for all safety-related activities including Regulatory Guide 1.64, " Quality Assur-ance Requirements for the Design of Nuclear Power Plants." The OPPD QA Program requires verification that all applicable NRC Regulatory Guide requirements have been incorporated in all activities affecting quality design review, audit, and surveillance of manufacturers and contractors.

This will assure that design input (applicable regulatory requirements and design bases as specified in the license application for safety-related structures, systems, and components) for Fort Calhoun Station Unit No. I are correctly translated into Design Output Documents (specifications, drawings, procedures, and instructions). QA audits will assure that OPPD's manufac-turers' or contractors' design control measures provide a clear definition of design interfaces, review and approval of initial design, including changes or revisions, and that those performing design review activities are independent of those originating the design.

The design activities of contractors for safety-related structures, systems, or components are required to comply with the design development and control requirements of ANSI N45.2.11. The design activities of manufacturers of packaging for transport of radioactive material are required to comply with the applicable regulatory requirements and the approved package design, as specified in the license. This compliance is audited by OPPD Quality Assur-ance. OPPD will perform audits of OPPD's and contractors' design activities in accordance with QAP No. 2, " Audit Plans."

17.4 Procurement Document Control Appropriate requirements have been established by the OPPD Quality Assurance Program to assure that procurement documentation is controlled and accur-ately reflects applicable regulatory requirements, design bases, and other appropriate requirements, such as industry codes and standards. Procurement documents and specificatiens require that bidders or suppliers submit for review by OPPD written quality assurance programs consistent with the impor-tance and complexity of the materials, equipment, or service procured. Such quality assurance programs shall be consistent with pertinent provisions of Appendix B to 10CFR, Part 50, or Appendix E to 10CFR Part 71, as appropri-ate. OPPD satisfies these requirements as follows:

(1) Review of procurement documentation for CQE-listed materials, equipment, and services will be performed in accordance with Nuclear Purchasing Procedures (NP?) No. I and No. 2, which require OPPD Engineering and QA to review all CQE procurement documents and document their review on the procurement docu-ment.

(2) Procurement documents for fire protection and radioactive taterial packaging materials, equipment, and services will receive the proper review, concurrence, documentation by qualified personnel for adequacy of fire protection and quality requirements. This review will determine that fire protection requirements and quality requirements are cor-rectly stated, inspectable and controllable; that there are adequate acceptance and rejection criteria; and that the procurement document has been properly prepared, reviewed, and approved.

.. 1 1

(3) Procurement documents for Limit.ed CQE items shall be reviewed to assure that the item is materially compatible with the i

environment in which it will be used and that applicable 3

documentation is specified.

(4) Planned, periodic, and documented audits will be performed by l responsible OPPD personael to provide assurance that the 4

. procurement activities of OPPD are being carried out in accordance with approved procedures. These audits will be

conducted as described _in Section 17.18.

I Appendix C to the Nuclear Purchasing Procedures requires that quality data be included in or appended to the Procurement Document or engir eering data

, attachments, as appropriate. The quality data prescribes as necessary:

i l

(1) Quality requirements including use of procedures or instruc-tions (2) Requirements for a Supplier Quality Program and documentation

, (3) Requirements for documentary evidence of quality to be fur-nished by the Supplier (e.g., test results, certification that specific requirements have been met, or traceability to

the source) 1 (4) Access requirements for QA surveillance, inspection, and 3 audits at the Supplier's work site The following is inserted as a special condition on all sealed bid contracts for CQE items

J

" Quality Assurance 4

"The Contractor shall submit his Quality Assurance Manual or

complete details of his Quality Assurance Program for review and approval by the District. The program proposal shall meet the intent of the latest effective provisions of 10CFR. Part 50, Ap-i pendix B, " Quality Assurance Criteria for Nuclear Power Plants",

as well as all the requirements of ANSI N45.2 and/or Fection III of the ASME Boiler and Pressure Vessel Code.

i "The Manual or program shall include sufficient organizational de-scription to indicate the independence of the Quality Assurance Group and establish the -authority and organizational freedom to identify and evaluate deficiencies and ensure that corrective actions are taken. Responsibilities and qualifications of . key 4 personnel shall also be shown.

"Further, the program shall make provisions for the District

[ and/or the Engineer to conduct periodic audits of the Contractor's Quality Assurance Program as well as that of his subcontractors.

The Contractor shall be responsive to requests for corrective l actions by the Di: strict and/or the Engineer regarding implementa-l l

l I

Lion of, or deficiencies in, his program or those of his subcon-tractors. The Contractor shall cooperate in scheduling of audits or tests, and shall supply with his proposal a schedule of sug-gested witnesses and/or holdpoints for OPPD and/or Engineer's inspection personnel.

"In addition, unpriced copies of all first tier subcontracts and purchase orders shall be provided to facilitate proper organiza-tion of audits.

"The program shall also make provision for establishing the res-ponsibility of the Contractor for the quality of the work per-formed by his subcontractors and for review and approval of sub-contractors' Quality Control programs to the same standards re-quired of the Contractor.

"In addition, the program shall provide that all records attesting to the quality of materials and equipment., such as material certi-fications, test reports, procedures and qualifications, process records, and radiographs shall be submitted to the District for permanent retention. All such records shall be available for review during shop audits and shall be forwarded prior to or concurrent with material or equipment shipments to which they are related."

The OPPD QA Manual requires that modifications to a Purchase Order or any document forming a part of the order shall be prepared, reviewed, and ap-proved as for new Procurement Documents.

Nuclear Purchasing Procedures No. I and No. 2 assure that procurement docu-ments for spares or replacement parts are subject to controls meeting all requirements of WASH 1283, Revision 1. The procurement process for spares and replacement parts for Fort Calhoun Station Unit No. 1 (FC1), as required by the OPPD QA Manual and further delineated in the OPPD Nuclear Purchasing Procedures, is more controlled than the original procurement process. The procurement process for FC1 occurred from 1967 to 1970; the 10CFR, Part 50, Appendix B, QA requirements were not invoked until 1971.

l l

l 17.5 Instructions, Procedures, and Drawings l Appropriate requirements have been established in the OPPD Quality Assurance Program to assure that quality-related activities for plant operations are prescribed by documented instructions, procedures, or drawings; be accomp-lished in accordance with such documents, and are approved only when accep-Lance criteria are met. The responsibility for the development of the instructions, procedures, or drawings is delegated to the organization responsible for the activity (normally the Manager - Fort Calhoun Station);

however, the leveloped instructions, procedures, and drawings are subject to OPPD QA audit. The Quality Assurance Manual contains the specific require--

ments pertaining to the instructions, procedures, and drawings associatra with activities affecting plant quality.

The QA Department audits measures established to assure that approved changes are promptly included where applicable into instructions, proce-dures, and drawings associated with the change. The OPPD QA Program assures that changes are reviewed for their effect on present instructions, proce-dures , and/or drawings.

The OPPD QA Program requires that procedures include a description of the sequence of activities or operation for fabrication, processing, assembly, inspection and test. Instructions shall indicate the operations or proces-ses to be performed, type of characteristics to be measured or observed, the methods of examination, the applicable acceptance criteria and documentation requirements. The QA Program also requires establishment of those inspec-tions, tests, and holdpoints from raw material through fabrication, process-ing, and assembly, at which time conformance of parts, components, and subsystems to requirements will be verified. Holdpoints identify those inspection points which will be rendered impossible to inspect by subsequent operations, and must be certified complete before start of the next opera-tion by use of checklists and certifications. Each checklist or certifica-tion shall include the date of completion of the operation or test and the signature of the operator or inspector.

The Operations QA Engineer will review such documentation to assure it adequately reflects all applicable quality requirements. In review activi-ties the Operations QA Enginet r will assure that instructions, procedures, and drawings contain appropria te quantitative (such as dimensions, toler-ances, and samples) acceptanct criteria for determining that important activities have been satisfactority accomplished.

Inspections, tests, administrative controls, fire drills, and training that govern the Fire Protection Program will be prescribed by documented instruc-tions, procedures, or drawings and will be accomplished in accordance with these documents. Instructions and procedures for design, installation, inspection, test, maintenance, modification and administrative controls will be reviewed in accordance with the Plant Administrative Procedures to assure the proper inclusion of fire protection requirements.

Through its auditing procedures, as described in Section 17.18, OPPD will determine that quality activities are accomplished in accordance with those approved instructions, procedures, and drawings.

1 1

17.6 Document Control GPPD has established requirements to assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel. These requirements provide that contractors include, in their internal p rograms , measu r( s to assure that changes to documents will be reviewed and approved by the same organization that performed the original review and approval. OPPD will verify implementation of these requirements through audits. This OPPD QA Program requires that changes to documents that have been reviewed and approved by OPPD organizations will be reviewed and approved by the same OPPD organizations that performed the original review and approval. These requirements also provide that the documents are distributed to and used at the location where the prescribed activity is performed. The scope of these requirements apply to OPPD as well as to contractors and subcontractors.

OPPD employs within its own internal organization a control system that utilizes numbering of documents requiring control, predetermined distri-bution lists, and review and approval procedures. Controlled documents associated with Fort Calhoun Station Unit No. I have been controlled by document change transmittal letters instructing the recipient to remove and destroy obsolete or superseded pages. OPPD requires:

(1) maintenance of a distribution list (2) use of receipt cards / letters (which indicate that superseded pages/ documents are destroyed or marked " superseded")

The Quality Assurance Program requires that design engineering and procure-ment documentation, except for fire protection equipment, which consists of specifications, drawings, FSAR material, instruction, procedures, reports, and changes thereto, and manufacturing and construction documents and re-cords required for traceability, evidence of quality, and substantiation of the as-built configuration, be controlled.

Instructions, procedures, specifications, drawings, and procurement docu-ments are controlled in accordance with the QA Manual Section 9, GSE Proce-dures, and Plant Standing Orders.  !

A " Table of Contents" or "Index" system is used by OPPD departments to identify the current revision number of instructions, procedures, and pro-curement documents. As a new revision or addition is made, a new " Table of Contents" or "Index" is promulgated. The controlled copies are distributed to predetermintd, responsible personnel, and a distribution list is main-tained. Suptrseded documents are returned to the originator or destroyed as directed in .he transmittal letter. I Since Fort Calhoun Station Unit No. I was constructed prior to present requirements, the file of specifications and drawings is not complete. OPPD l has a continuing program of updating its specificati:,ns and dr.: wings filee. 1 A master index is in preparation and is controlled in accordance with GSE j Procedures.

i I

1 1

l l

Procedures in the QA Manual identify these individuals or groups responsibic for reviewing, approving, and issuing documents and revisions thereto.

Where deemed necessary, OPPD will require that periodic document summary lists be submitted by an organization to verify the use of the proper docu-ment or change.

The ef fectiveness of document control methods is evaluated through audits.

17.7 Control of Purchased Material, Equipment, and Services Measures utilized by OPPD to control purchased material, equipment, and services for an operating plant consist of individual committee reviews, audits, and inspections. These measures are described in the OPPD Quality Assurance Manual and the Purchasing Manual.

Potential manufacturers or contractors who are to be considered by OPPD or its prime contractors for the supply of items will normally be evaluated in advance of placing them on the Approved Suppliers List. OPPD's evaluation of potential vendors is performed by QA in accordance with Quality Assurance Procedure (QAP) No. 5. The evaluation involves the review of available historical data on manufacturers' or contractors' performance and capa-bility; review of their quality assurance programs; or results of previous sh,p surveys and audits. Quality assurance program descriptions are re-quiced to be submitted with bids for CQE-listed items. The manufacturer or c ontractor to supply the material, equipment, or services will be selected from the Approved Suppliers List. If required, a pre-award survey at the supplier's facility will be conducted before award of contract.

Documented, objective evidence such as certifications, chemical and physical analyses, inspection reports, test results, personnel and process qualifi-cation results, code stanpings and nondestructive test reports are required to be evaluated by OPP 9 and suppliers or contractors. This verification will assure conformance to design requirements, drawings, specifications, cNes , standards, regulatory requirements and other applicable criteria.

these documents become a part of the quality verification records to be retained as a QA record in accordance with Sect. ion 17.17.

Source inspection, when deemed necessary, is required by the applicable procurement document. The purchasing organization shall require that hold-points he determined as necessary for this activity. Manufacturers are required to give suf ficient notice of approaching holdpoints to allow sche-duling of personnel.

Both in process and final source inspections cover review of the quality verification documentation. An inspection document is used to establish the inspection sequence and for recording inspection results. This document also becomes part of the quality verification records. Provision is made for repo rt.in g deviations and nonconformances, if any; for recommending disposition and corrective action; for reinspection, if required; and for release for shipment, if appropriate. OPPD or its contractor may elect to participate in selected source inspections.

1 l

. i l

The OPPD QA Program requires that procurement documents specify that manu-facturers or contractors provide the quality verification documentation at the plant prior to the scheduled time of installation or use of the subject material and equipment. During the review and approval of procurement documents, OPPD will check to assure that the above requirement is included.

Audits will assure that the Contractor is implementing a records management

system. Installation or use of delivered components will not occur until receipt of objective evidence of the quality verification package.

r l Receiving inspection of purchased products will be accomplished by Stores and QA personnel in accordance wt.a Plant Standing Orders. These procedures l 4 require that shipments dativered to the stat. ion be checked by the Stores Clerk for shipping damage, agreement of actual count with the purchase order and packing slip, and agreement of the individual item identification I with the purchase order and packing slip.

l Limited CQE items are verified upon receipt that the item rece'.ved is actu-l 5 ally the item that was ordered.

Standing Orders require that one or more receiving inspection packets be l 4 prepared by the QA Engineer (Ope rat. ions) for each purchase order requiring delivery of material to the Station. A receiving inspection packet includes a preprinted packet cover, a copy of the purchase order or Requisition on Purchasing, a material inspection packet, and a document retention checklist.

Special instructions may be included in the packet for complex inspection

requirements and tests to be performed at the plant or the supplier's work site as determined from the purchase order. Drawings and/or specification documents are included - as appropriate. The inspector (s) perform (s) the l l receiving inspection in accordance with the above instructions and/or specifications.

The QA Program requires that all inspection records or certificates of con-formance attesting to the quality of materials and equipment be submitted to the District for permanent. retention. All such records shall be available for review during shop audits and shall be forwarded prior to or concurrent.

with material or equipment shipments to which they are related. In addition,

) prior to acceptance of all material, the QA Engineer (Operations) shall be ,

4 notified to verify that necessary documentation has been received. The documentation is maintained within the Receiving Inspection Packet."

Products intended for use as Critical Quality Elements are inspected upon I receipt in accordance with Plant Standing Orders, which require a " Rejected l Material" tag to be af fixed to rejected material, and the material segre-gated in the receiving area to prevent inadvertent use. Accepted material is identified, and' there are records traceable to the material indicating I

acceptance. Furthermore, materials classified as Critical Quality Elements are cont. rolled in accordance with ANSI N45.2.2 and 10 CFR 50, Appendix B.

1 4 17.8 Identification and Control of Materials, Parts, and Ccmponents Appropriate requirements have been established by the OPPD Quality Assurance Program to assure continuous and accurate identification and control of I materials, parts, and components so that the use of incorrect or defective j material, parts, or components is prevented.

i i

l ew--- m-,m,.

For an operating nuclear power plant, sp M ric procedures to comply with this requirement. are contained in the Quality Assurance Manual and the Plant Operating Manual. All material received at the Storeroom for use as Criti-cal Quality Elements or as packaging for radioactive material for transport are identified to prevent the use of incorrect or defective material. The identification of the item is maintained by an appropriate code, letter, or number so that the identity of the material is maintained. Items shipped to the plant are normally identified by nameplate or other identification marking on the item. In those instances when it is not practical to provide identification markings on the individual items, identification information will be provided in shipping paperwork that is transmitted with each ship-ment.

Limited CQE raaterial is identified such that verification of the identity of the item to be used is assured prior to installation or use and that confor-mance documentation is available.

Materials classified as Critical Quality Elements are controlled in accor-dance with ANSI N45.2.2 and 10 CFR 50, Appendix B.

Material classified as Critical Quality Elements or packaging for radio-active material for transport is released from the Storeroom by the Stores Cle<k only upon receipt of two copies of an authorized and signed "Requisi-tion on General Stores," OPPD Form 45.5203.

The " Requisition on General Stores" is initiated by designated District personnel. It designates each individual item requested, including size, tchedule, pressure rating, etc., and the system on which the material is used. Two lines are left blank between each item on the " Requisition" to assure space for the material identification data.

The " Requisition on General Stores" for Critical Quality Elements shall not l contain noncritical material. This precludes the issuance of noncritical items on the same requisition for Critical Quality Element material.

Each " Requisition on General Stores" for Critical Qualit.y Element ruterial is stamped with the Critical Quality Element stamp. Each "Requisit ion" for packaging fo r radioactive material for transport will be stamped with a l

" Radioactive Material Packaging" stamp. When available, the material iden-tification number, material heat number, or code number or letter is noted on the " Requisition."

The traceability of materia i.s is maintained through the use of Plant Stand-ing Orders. The receiving inspection packet contains all of the documenta-tion needed for the traceability of the item. Those documents which are not included are referenced as to their location. The method of identification to be applied to purchased materials is specified as part. of the purchase document. Cc, des and standards referenced in the purchase document have incorporated the appropriate marking method, such that. the fit, function, or quality of the item is not affected. Codes and standards referenced in-clude:

(1) ASTM - American Society for Testing and Materials (2) ASME - Americ.a Society of Mechanical Engineers l

l

The correct identification of materials is verified and documented prior to l release. I Contractors are required to utilize procedures which establish and document a system or method of identifying the material (e.g., physical marking, tagging, labeling, color code). This system shall clearly indicate whether materials are acceptable or unacceptable for further use, as required by the quality program. Material traceability is provided as specifically required by applicable codes; otherwise, material identification, either on the item or on records traceable to the item, will be used, as appropriate. Where identification marking of an item is employed, the marking will be clear, understandable, and legibic, and applied in such a manner as not. to affect the function of the item. The identification and control measures provide for relating the item of production (batch, lot, components, part) at any stage, f rom materials receipt through fabrication, shipment, and installa-tion to an applicable drawing, specification, or other technical document.

OPPD requires its suppliers to establish and implement a program for in-specting, marking, identifying and documenting material prior to use or storage. This program must be documented.

IIoldpoints are required where inspections must be made and certified com-plete before start of the next operation. Inspection of materials include the following:

(1) Verification that identification and markings are in accor-dance with applicable codes, standards, specifications, drawings, and purchase orders.

(2) Visual examination of materials and components for physical damage or contamination.

(3) Examination of quality verification records to assure that the material received was manufactured, tested and inspected prior to shipment in accordance with applicable requirements.

(4) Actual inspection, as required, of workmanship, configuration and other characteristics.

These inspections shall be documented by reports and controlled through internal auditing. OPPD will perform surveillance of vendor facilitics to assure implementation of the program.

OPPD will require that. contractors establish specific measures to assure compliance with approved procedures for identification and control of ma-terials, parts, and components, including coatings and partially fabricated assemblies. OPPD will verify conformance by four methods:

(i) Review and approval of contractors' quality assurance programs, including procedures.

(2) Review and approval of Product Control Procedures contained in OPPD's Plant Operating Manual.

(3) Surveillance of selected manufacturing, fabrication, con-struction and installation activities by quality assurance personnel.

(4) Auditing:

(a) of contractors for sat isfactory performance of committed quality actions; and (b) of Stores activities for adherence to quality require-ments.

17.9 Control of Special Processes OPPD requires for its operating nuclear power plants that written procedures and controls be prepared to assure that special processes, including weld-ing, heat treating, special coating applications, and nondestructive testing are accomplished by qualified personnel using qualified procedures in accor-dance with applicable codes, standards, specifications, criteria, and other special requirements. These procedures shall describe the operations to be performed, the sequence of operations, the characteristics involved (e.g.,

flow temperature, fitup, finish, hardness, and dimensions), the limits of these characteristics, process controls, measuring and testing equipment to be utilized, and documentation requirements.

Examination, tests, and inspections shall be conducted to verify conformance to the specified requirements.

Written procedures will also be required to cover training, examination, qualification, certification, and verification of personnel as well as the maintenance of all required personnel records.

Compliance with these procedures is required for plant maintenance per-sonnel, contractors, and vendors. Procedures for control of special pro-cesses are subject to review and approval by OPPD on an individual basis.

OPPD will assure conformance with these requirements by:

(1) Review of procedures by the Plant Review Committee and Opera-tions QA Engineer for inclusion of special processes requir-ing control; definition of requirements for training, quali-fication and certification; conformance to applicable codes, standards, drawings, specifications, or other criteria.

(2) Audits to verify the adequacy of selected plant and vendor shop activities and the effectiveness of the special process procedures being implemented.

Special Process Control activities performed by OPPD parsonnel are presently being performed in accordance with Plant Standing Orders. l

'O

! 17.10 Inspection l OPPD will establish with its personnel and . contractors a division of res-ponsibility which will determine the services, structures, systems,.com-

{ ponents, and materials for which each is respon.ible. The organization j

having the responsibility for maintenance or repair of such items shall also have the primary responsibility to assure that adequate inspection is ac-l complished. OPPD Q4 however, retains the responsibility and authority for s

review, approval, and surveillance or audit of the inspection procedures utilized by plant maintenance personnel or contractors.

OPPD QA or Maintenance QC personnel will be responsible for the inspection l of all work performed by OPFD maintenance personnel on nuclear safety re-1ated structures, systems, or components, and on radioactive material pack-

! aging. Fort Calhoun Quality Control personnel or other personnel who are independent of the individuals performing the activity being inspected and who are qualified in the design and installation requirements for fire i protection will inspect activities affecting fire protection to verify conformance with documented installation drawings and test procedures for f accomplishing the activities, j

j The review and approval of a contractor's inspection program and procedures

will be accomplished as an integral part of OPPD's review of the organi-zation's Quality Assurance / Quality Control programs.

The Operations QA ,

Engineer and the plant QC personnel will use the following criteria in evaluating inspection methods proposed by plant maintenance personnel or

! organizations under contract to OPPD: 1 (1) Inspection procedures for functional groups such as pro-l curement, project engineering, construction, and shop in-spectors, must be described including measures to identify  !

l inspection and test status.

) (2) Duties and responsibilities of personnel performing quality  ;

activities must be clearly established.

i l (3) Qualifications of personnel performing quality activities

] must be commensurate with their duties and responsibilities.

(4) Documentation methods for inspection activities of each group must be established (e.g., inspection forms, reports).

l

} (5) Documentation control systems for identification and dis-

! tributing inspection documents must be defined.  !

~f (6) Review and approval procedures for inspection documentation must be provided.

(7) Surveillance methods must be established to assure proper implementation of inspection procedures.

. .-.r.fwy-f...m.-, ys y p- ..-c .m_,, w - ,.-r- . . , . , _ . , m------,_.e -

m, 3, y-,

(8) Planning of inspection sequence activities by plant main-tenance personnel or the contractors shall include the type of characteristics to be measured, the methods of examina-tion, and the criteria. OPPD will approve inspection hold-points in the sequence.

The flanager -

Fort Calhoun Station shall assure that the periodic inspec-tions made by his staff members include:

(1) Periodic inspections of fire protection systems, breathing equipment, emergency lighting, and communication equipment to assure the acceptable conditions of these items.

(2) Periodic inspections of materials subject to degradation such as fire stops, seals, and fire retardant coatings to assure that such items have not been damaged or deteriorated.

Inspection planning shall be utilized to assure conformance to procedures, drawings, specifications, codes, standards, and other documented instruc-tions. Inspections shall not be performed by those individuals who per-formed the activity being inspected. Sufficient inspections shall be con-ducted to verify conformance particularly in areas rendered inaccessible by further processing. Process monitoring may be utilized in lieu of inspec-tion in those cases where inspection is impossible, disadvantageous, or destructive. When required for adequate control, a combination of inspec-tion and process monitoring shall be employed. Holdpoints shall verify (by review of inspection reports, visits to supplier shops, and plant surveil-lance) that inspections are being performed and documented by personnel in conformance with approved procedures.

The provisions which assure inspections are performed with the necessary drawings and specifications are covered in Plant Standing Orders. l

?!odifications are inspected in accordance with Fort Calhoun Administrative Procedures Standing Orders. A plan of inspection and monitoring is devel- l oped and incorporated in Planning Documents of work segments, including designation of mandatory holdpoints. The inspection and monitoring plan is designed to verify conformance of work and products with the Planning Docu-meats, applicable Design Documents, and specific quality standards and re-quirements. The plan provides for inspection and monitoring during critical stages in the progression of work and for inspection at the conclusion of each work segment.

Repairs and replacements are inspected in process or during receiving in-spection in accordance with Fort Calhoun Administrative Procedure Standing Orders. Any holdpoints for inspection or witnessing is specified under the QA or QC Requirements section of the maintenance order.

OPPD inspectors are qualified and maintain their qualification by partici-pation in the training and indoctrination delineated in Section 17.2.4. l OPPD QA/QC and maintenance personnel performing nondestructive examination are trained and qualified in accordance with QAP #10, "NDE Personnel Admini-stration." Consultant and Cont ra cto r inspectors performing inspection duties for OPPD are require <1 to provide documentary evidence that they are qualified and that the certifications are current in accordance with ANSI N45.2.6.

( . .

27.11 Test Control l The OPPD Quality Assurance Program requires that plant personnel, contrac-  ;

tors, and suppliers designate appropriate tests to be performed at specific l stages of manufacturing, fabrication, construction, and operation. Conduct l of tests will be governed by written procedures which will incorporate i requirements and acceptance limits to assure that the structures, systems, and components tested will perform satisfactorily in service. Tests will be conducted in accordance with these procedures and will be properly docu-mented. Written test procedures fo r radioactive material packaging shall incorporate the requirements and acceptance limits contained in the package approval.

OPPD shall ascure that all necessary tests are conducted by contractors performing maintenance or repair service for an operating plant. Such testing will be performed in accordance with quality assurance and engineer-ing test limits contained in applicable design documents. Test requirements and acceptance criteria are provided by the organization responsible for the specification of the item under test, unless otherwise designated. The entire test program will cover all required testing including, as appropri-ate, performance testing of production equipment, calibration testing of instruments, hydrostatic testing of pressure boundary components and sur-veillance testing.

Provisions to assure that modifications, repairs, and replacements are tested in accordance with the original design and testing requirements or acceptance alternatives are contained in (1) GSE Manual for preparation of test procedures as a part of the design package; (2) Standing Order for execution of modifications at the plant; (3) Standing Order for tests of repairs or replacements; (4) huclear Purchasing Procedure No. 2 for tests to be conducted by the supplier; and (5) Standing Orders for surveillance tests. Documentation of tests conducted is included in the completed design package, with the completed maintenance order by special procedure, or included in the receiving inspection packet.

Following construction, modification, repair or replacement, sufficient testing will be performed to demonstrate that fire protection systems, emergency lighting and communication equipment will perform satisfactorily in service and that design criteria are met. Written test procedures for installation tests will be prepared by the responsible engineering group and will incorporate the requirements and acceptance limits contained in appli-cable design documents.

Present test control activities are being performed in accordance with Plant Standing Orders.

I Test procedures as a minimum shall include:

l (1) Requirements that prerequisites for the test have been met.

1 Test prerequisites may include, but are not limited to, the j following:

(a) . calibrated instrumentation ,

4 (b) adequate and appropriate equipment ,

(c) trained, qualified and, as appropriate, licensed or i certified personnel i

i (d) preparation, condition, and completeness of item to be tes t.ed (e) suitable and, if required, controlled environmental con-g ditions 6

1. l 1

(f) mandatory inspection holdpoints, where applicable, for  ;

i witness by OPPD, contractor, or authorized inspector j j- -(g) provisions for data collection and storage J (h) acceptance and rejection criteria [

l (i) n.e thods of documenting or recording test data results  !

< (2) Designation of specific test methods to adequately assess appropriate parameters.

(3) Designation of measuring and test equipment to be used.

(4) Specific environmental considerations.

l

(5) Measurer, to prevent damage to the item or system under test.

I i (6) Safety considerations.

l -

i (7) Documentation requirements.

Test results shall be evaluated to verify as applicable: ,

4 i (1) Proper functioning of the system, structure, or component. ,

j (2) Conformance to design specifications.

! (3) Compliance with stated test requirements.

(4) That test results are within allowable limits.

i (5) That recording and documentation is complete and accurate.

l ,

p. l l

L 4 I

Audits by OPPD QA, vendor surveillance, and witness of specific tests will serve to assure the functional adequacy of, and verify compliance with, the testing program.

17.12 Control of Measuring and Test Equipment The OPPD Quality Assurance Program requires that organizations performing quality activities involving measuring and test equipment have written procedures to govern these actions. OPPD requires that the standards used for calibration and accuracy verification of measuring and test equipment be traceable to the U. S. Bureau of Standards or other appropriate sources. In addition, only properly calibrated measuring and test equipment shall be used. A calibration frequency and method system shall be established to which the tools, instruments, gauges, and other devices shall conform.

Records of calibrations shall be maintained and the calibration equipment appropriately marked to indicate the date and acceptance of the calibration.

Calibration activities being performed by OPPD personnel are in acccrdance with Standing Orders. If a standards error exceeds the guaranteed accuracy, l then the standard shall be replaced. Calibration standards, when not limi-ted by the " state-of-the-art," will have an uncertainty (error) requirement of no more than 1/10th of the uncertainty of the equipment being calibrated.

When inspecticn and testing equipment is found to be out of calibration due to use or damage, or when out of limits at recalibration, all items inspec-ted, tested, or measured with that equipment since the latest valid calibra-tion shall be considered as being potentially unacceptable. Resolution of these cases shall be determined on a case basis by treating them as a non-conformance.

OPPD QA shall monitor calibration activity, including evidence of calibra-tion status and the use of calibrated equipment. In addition, OPPD QA will perform periodic audits to ensure that approved calibration control proce-dures are being implemented.

17.13 Handling, Storage, and Shipping OPPD's QA Program requi es .bac instructions or guidance for plant handling, n-eservation, storaen, na ccatrol of products are prepared and approved prior to' arrival e r ce s . ducts at the plant. These procedures will spe-cify, as required, ( bat , ial environmental facilities, such as inert gas, umidity control, 'r tempet ature controlled storage area are established prior to the receipt of the prodects. Contractors performing maintenance or repair services for an operating plant shall provide procedures for the handling of products to prevent damage or deterioration. The procedures will be reviewed and approved by OPPD.

l l

To assure existence of the requirements for procedures in the procurement I documents, OPPD QA will verify the inclusion during its review prior to I authorization for document issuance. OPPD personnel shall procure, receive, store and handle CQE and radioactive material packaging products, material, and components in accordance with the Purchasing Manual and Plant Standing Orders.

OPPD QA will perform periodic surveillance and audits of affected OPPD l organizatioes and contractors to assure that specified and approved pro-cedures are being properly implemented.

17.14 Inspection, Test, and Operating Status OPPD's QA Program requires that procedures be established to identify the inspection, test, and operating status of radioactive material packaging and safety-related structures, systems, and components. Identification of the inspection, test, and operating status of structures, systems, and compon-ents is provided through use of Fort Calhoun Administrative Procedures, and the Surveillance Test Program. Schedules and methods for periodic testing of fire protection systems and components will be developed and documented by the Manager - Fort Calhoun Station. Fire protection equipment, emergency lighting, and communication equipment will be tested periodically to assure that the equipment will properly function and continue to meet the design criteria. Test results will be documented, evaluated, and their accept-ability determined by plant Quality Control personnel.

The application and removal of inspection and welding stamps and status inoicators are procedurally controlled, and nonconforming, inoperative, or malfunctioning structures, systems, or components are identified through the use of Quality Assurance Procedures and Plant Standing Orders.

There is no provision for formally bypassing required inspections, tests, and other critical operations at the operating plant. System completeness and acceptance at the end of a maintenance or repair phase are determined by:

(1) reviewing for adequacy, completeness, and conformance to quality assurance requirements for each system or component being accepted; (2) performing curveillance and monitoring of the test actisities associated with the approved test program; (3) reviewing the test records to verify that test results comply with QA requirements.

The suppliers' and contractors' inspection and test status of items are re-quired to be maintained through the use of status indicators such as physi-cal location, tags, markings, shop travelers, stamps, or inspection records.

These measures provide for assuring that only items that have received the required inspections and tests are used in manufacturing and are released for shipment. The procedures for control of status indicators, including the authority for application and removal of tags, markings, labels or stamps will be documented in approved manufacturing or quality assurance l procedures. Performance of this function will be audited by OPPD QA to assure that effective measures are being taken.

i

?

17.15 Nonconforming Materials,-Parts, or Comoonents The OPPD Quality Assurance Program requires that measures be taken and docu-

- mented by OPPD Stores and by Plant and QA personnel to control the identi-

- fication, documentation, segregation, and disposition of nonconforming ma-terial, parts, or. components. The implementing instructions which fulfill these requirements are contained in Plant Standing Orders and Quality Assu-i rance Procedures. The QA Manual identifies those individuals or groups delegated the responsibility and authority for the disposition and approval of nonconforming items. Nonconforming items are controlled and identified in accordance with written procedures to prevent inadvertent use or instal-lation. Control measures include tagging or marking and segregation when feasible. Nonconforming products are maintained in quarantine whenever possible. Control measures are maintained until the item has been removed from the plant site or corrective work has been completed and accepted.

Plant Standing Orders set forth requirements for controlling and correcting l nonene. forming items at Fort Caldun Station Unit No. 1. These procedures cover:

(1) Initiation of the documentation for material rejected at re-ceiving inspection or in plant activities including the af-fixing of a Rejected Material tag to the nonconforming item.

The nonconformance report identifies the nonconforming item and describes the nonconformance.

(2) Assignment of disposition and/or corrective action respon-sibilities, including the inspection requirements and signa-j ture approval of the disposition.

(3) Control of correction work planning and acceptance.

i Nonconformance reports are analyzed during audits of the nonconformity con-trol system to detect adverse quality trends. These reports go to manage-ment for review and assessment.

1 The OPPD Quality Assurance Program requires that measures be taken and docu-mented by contractors and suopliers to control the identification, documen-i tation, segregation, and disposition of nonconforming material, parts, or components. These measures will prevent inadvertent use or installation-of i

defective components and are subject to review and approval by OPPD Written procedures w?'1 be required for investigation of the nonconforming item, decisions on its disposition, and preparation of adequate reports. Proce-dures will also control further processing, fabrication, delivery, or in-sta11ation of items for which disposition is pending. All reports document-l ing actions taken en nonconforming items will be made available to OPPD i for evaluation. Departures from design specifications and drawing require-ments that are dispositioned "use as-is" and " repair" will formally be re-ported to affected organizations and OPPD management. OPPD will audit contractors to assure compliance with this requirement.

y g 4*,t re - - - * - 3 ,,w... --e, -r-,--. -,+ - -

a The effectiveness of nonconformance control procedures will be assured by: l (1) Contractor quality assurance and manufacturing, fabrication, or construction personnel being involved in processing non- l conforming reports. )

l (2) OPID participation in dispositions and approvals.

(3) Document review at final inspection or shipping release and 4

at receiving inspection by OPPD.

(4) Surveillance by OPPD's and contractors' quality assurance

personnel.

(5) Audits performed by the contractors, suppliers, and OPPD QA.

. 17.16 Corrective Action i OPPD requires measures for an operating nuclear power plant to assure that conditions adverse to quality _ are promptly identified, reported, and cor-rected. Responsibility for performing corrective action will be assigned to

OPPD personnel and all contractors and suppliers so that each will be alert to those conditions adverse to quality within his own area of responsi-

bility. In the case of significant conditions adverse to quality which are reportable to the NRC under the provisions of 10CFR, Section 50.55(c),

measures shall be taken to assure that the cause of the condition is de-I termined and corrective action is implemented to preciude repetition.

Corrective action procedures will require thorough investigation and docu-

- mentation of significant conditions adverse to quality. The cause and corrective action will be reported in writing to the appropriate levels of management. The corrective action to be applied will be subject to review and approval by OPPD QA. Corrective action followup and closeout procedures

will provide that corrective action commitments are implemented in a syste-matic and timely manner and are effective.

The instructions for implementing these requirements are contained in QAP No. 5, " Supplier Qualification," and Plant Standing Orders. l The effectiveness of the suppliers' or contractors' corrective action pro-gram will be assessed during audits by the supplier, the contractor, and by OPPD. Stop work authority shall be exercised as required.

i The effectiveness of OPPD's corrective action program will be assessed during audits by QA and 'he SARC.

17.17 Quality Assurance Records y

OPPD's Quality Assurance Program requires that OPPD and its contractors have a quality records system which will provide documentary evidence of the performance of activities affecting quality. The requirements include that:

(1) Records are to be maintained that show evidence of perfor-mance of activities af fecting quality. Typical records to be

maintained include quality assurance programs and plans, de-sign data and studies, design review reports, specification procurement documents, procedures, inspection and test re-

, ports, material certifications, personnel certifications, test reports, . audit reports, reports of nonconformances and i corrective actions, as-built drawings , operating logs, cali-t bration history, maintenance data, and failure and incident reports.

(2) Inspection and test records, as a minimum, will identify the date of .the inspection or test, the inspector or data re-corder, the type of observation, the results, the accepta-bility, and the action taken in connection with any noncon-

. formances noted.

(3) Records shall be protected against deterioration and damage.

l (4) Criteria shall be established for determining the classifica-tion of the record as well as the length of the retention period.

(5) A method of identification and indexing of records for ease of retrievability shall be established.

r (6) Responsibility for recordkeeping during design, fabrication, construction, preoperational testing, and commercial opera-tion shall be documented.

.l (7) Method of transfer of records between organizations and ulti-mate transfer to OPPD shall be established.

All requirements and responsibilities for the handling, storage, and reten-j tion of records which furnish documentary evidence of quality are prescribed by QAP #7, " Storage and Retention of QA Records"; GSE Procedure A-9, "Fil- '

ing"; and Fort Calhoun Station Standing Orders. The records are accumulated l and handled in a controlled manner in accordance with these written instruc-I tions. An audit system is established to assure that the record transmit-tals, retention, and maintenance are effective and consistent with appli-cable codes, standards, and procurement documents.

t 17.18 Audits The OPPD QA Program requires that planned and periodic audits be performed to verify compliance with all aspects of the Quality Assurance Program and

! to determine the effectiveness of the program. OPPD QA will perform such audits on OPPD internal activities, contractors, suppliers, and others as necessary to provide an objective evaluation of the effectiveness of their programs; to determine that their programs are in compliance with estab-lished requirements, methods, and procedures; and to verify implementation of recommended corrective action. The Operations QA Engineer is responsible for assuring the effective implementation of the Fire Protection Program on-site by inspections and audits.

i i

The internal audit cycle for-Fort Calhoun Station Unit No. 1 is promulgated by QA Procedure #16 and is based on the safety importance of the activities being performed. An internal and external audit schedule is distributed and updated quarterly to ensure coverage of status changes. If, in the opinion of the Manager - Quality Assurance, a given area requires added emphasis, the frequency of audits is increased until the situation is clarified.

The OPPD audits, both internal and external, will be conducted primarily by members of the Quality Assurance staff in accordance with QA Procedure #2,

" Audit Plans"; QAP #17, " Audit Planning, Pe r fo rma nce , and Reporting"; QAP

1. 5, " Supplier Qualification"; and QAP #15, " Adverse Condition Reporting and Correction." Consultants will be utilized by OPPD on audits as required.

OPPD specifies that the auditing system used by OPPD, its contractors, and suppliers:

(1) utilizes an audit planning document which defines the organi-zations and activities to be audited and the frequency of audits; (2) requires auditors to be familiar with the type of activities to be audited and have no direct responsibilities in the type of activities to be audited; (3) provides auditing checklists or other objective guidelines to identify those activities which affect quality; (4) requires examination of the essential characteristics of the quality activity examined; (5) requires an audit report to be prepared and that it notes the extent of examination and deficiencies found.

QAP #17, " Audit Planning, Performance, and Reporting"; QAP #18, " Auditor Training and Qualification"; and QAP #19, " Quality Assurance Indoctrination and Training of Personnel", provide the means which assure that audits are performed in a thorough and professional manner. OPPD audits determine the existence of a system and the deficiencies of that system, and the actual practice of the system. Audit checklists are used to ensure that audits include the objective evaluation of work areas, activities, processes and items and the review of documents and records.

OPPD QAP #17 requires that upon completion of each audit, a formal report shall be prepared following the guidance of ANSI N45.2.12. The audit report shall contain any deficiencies or nonconformances found during the audit, and recommended actions to be taken. Audit reports are distributed as follows:

Standard Distribution:

i (1) Applicable Assistant General Manager (2) Applicable Division Manager l (3) Applicable Section Manager {

(4) Applicable Department Manager j

r: a l

t I (5) Applicable Supervisor

( (6) Manager - Quality Assurance (7) Applicable QA Engineer (8) Partipating Auditors Special Distribution:

Depending upon the nature of discrepancies noted, or the areas audited, the following are added to the distribution list as re-quired:

(1) Division Manager - Material Management (2) Contract and Specifications Engineer (3) Supervisor of General Stores (4) Maintenance Engineer (5) Applicable Contractor (6) SARC Secretary for promulgation to SARC Members

- QA Form #2 of QAP #15 is used to identify and monitor corrective actions arising from QA audits conducted in accordance with any of the QA proce-dures. This form is used by QA personnel (or by non-QA personnel conducting QA audits) to document quality assurance related deficiencies and their cor-rective action. Items 1 through 7 of QA Form #2 are completed by the person identifying.the deficiency. The form is addressed to the Action Addressee.

The Original, Audit File, and Action Addressee's copies, are sent to the l Action Addressee for his endorsement of action to be taken, assign investi-gator (if required), and expected completion date (if known). The Followup Copy is retained by the auditor originating the deficiency report and a copy is made and sent to the QA Engineer - Cortarate.

The Action Addressee will keep the Action Addressee's Copy, state corrective action to be taken, and forward the Original and the Audit File Copy to the l appropriate QA Engineer. The QA Engineer will send the Audit File Copy to i

the Manager - Quality Assurance for filing. The Original and Followup copies are kept by the QA Engineer for followup and corrective action. After re-ceiving the deficiency report with the stated corrective action, the QA Engineer reviews the forms for concurrence. If he does not concur with the corrective action to be taken, he will return the fo rms to the Action Ad-dressee for further action. Final concurrence will be decided between the QA Engineer and the Action Addressee. After concurrence by the QA Engineer, he will provide followup on the item until it is complete. When the defi-ciency is corrected, the QA Engineer updates the Original Copy to agree with the Followup Copy and sends the Original to the Manager - Quality Assurance.

The Manager - Quality Assurance will update the Audit File Copy from the Original and file both copies, thus closing out the deficiency.

J A quarterly report of deficiencies that have occurred, including the status of all resolved deficiency reports, is prepared and distributed by the QA

, Engineer (Corporate). This report is routed to the senior management of the major OPPD organizations participating in the QA program.

l l

\

i l

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

e ..

I The QA Engineer '(Operations) is responsible for followup activities at Fort Calhoun Station Unit No. 1. He works closely with the Manager - Fort Cal-houn Station and Plant Staff in this regard, notifying the Manager - Quality-Assurance as each deficiency is corrected. The QA Engineer (Corporate) maintains followup on design, procurement, and supplier activities.

J i

The Manager - Quality Assurance maintains a consolidated status summary of all deficiencies.

6 J

, I f

I i

i 1

)

O h

1 r

l l

t

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

o o

T NLR AAE Ngf g 0 m

L TRG Cg S AS SEA I , .,

, I RE IhN S ," f VFER N S E ER SEA SGM V' I

I.,"

g RONO E ET OIYCR TTNE TET Y O A P GS D ' CI LAC JLR tA E.

U p S l lRE RAUi AUF T cSG SOSN US cst S.

N AE AI O

C R

EL SA E E Y E E A

Nr T. RS RYC TYCR YCR OR ETN ATNE T NO

%E GIA RIA E. AT I

i" DTI NNAA ALR OLRT

?AUI ILRI AUD NCALF NAU 1USG USU OR ISV I

UF GA E

uQS f

US A

0QSN C AE CSA A

IN R IVE D

E C

N A

S E ES NYCR Y CR R OT'I E TNO N IIAE AT U I TLRN ILR AUE C S O

AAUI Rl SG USP I EOSN CSS S T P AE AN T NLR O I A AAE A TRG T SEA Y I N*l I S

SEA t T SGi A I N h R L

V O E 1 T A 0 I S W R R U L H T R S.

Of O O 7 NRAS 0 S0 TS Q OECE L A II FI P 1 IGIC F VT V l TANI A T I RA IHR $

EECR C

SMEE HV C S ER PE UP SN U N R E TS SO S A R O

E U I

L G T

\j

_ ~ C 1

• # A h R O F NS N NRON E OCIO IGTI P I

SACT l D NUA 0 IVnDR iOE RL OA P

P ID RP SC PO I R i

IVN 0 0

RH EC PE F UT i

• # * # S A

F S YL NRN R MN TOF F OEO E UO RF I

IGI TAT GTOI ARHT l 1 ILTA ANT A

CNA NOLA UOS T EAR AFAT QC SME 1 f CS S S P

• E O I T

I E

RC SL EI ON IB SA TI N

l IVE RT l

IS LN O

E!i PI IBF IS LA SE Stt NR O

PT S SN

- EE

- EK RM 1

RR F OE NI _

TL

_ SC OH _

IS _

_ T _

CE .

_ EV -

G. G R& N T T

NLR ,' .R I t

G N O NO OTI RC AAE O' . R . R '. N I SLCI

_ T RG S."E I.E C'EICR IGTIE AI T IVCTC PA 0

_ SEA EI TAATE [

NN ISEG V"NI I,^ CnRAN RIAE EMI T P:GO RD IA SGI A

I D

fG h

E SuETI E

f E NSG N

U VAR SCFP S R

_ G E

• a

-