ML20009E953
| ML20009E953 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 07/22/1981 |
| From: | WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | |
| Shared Package | |
| ML20009E947 | List: |
| References | |
| NUDOCS 8107280565 | |
| Download: ML20009E953 (100) | |
Text
_ _ _.
f WNP - 1/4 PSAR CHAPTER 17 OUALITY ASSURANCE The Washington Public Power Supply System will implement an overall Quality Assurance Program (QA Program) for the design, procurement, construction and operation of the Supply System's Nuclear Project Nos. 1/4 (WNP-1/4) in accordance with the requirements of Appendix "B" of 10CFR50. As the applicant, the Supply System is responsible for t,he plants and will take,
appropriate actions to assure that they are designed, procured, constructed and operated in accordance with sound engineering principles and practices.
Systems, components and structures that are safety-related, in the context of 10CFRE0 will be designed, specified, fabricated, installed, tested and operated in accordance with applicable regulatory requirements, codes, standards, specifications and procedures. The objective of the Supply System is to iglement a QA Program that is responsive to the requirements of NRC l
Regulations,10CFR50, Appendix 8, " Quality Assurance Criteria for Nuclear Power Plants" by assuring that quality related efforts are performed in a controlled mannar and are documented to provide objective evidence of cogliance.
17.1 QUALITY ASSURANCE DURING DESIGN AND CONSTRUCTION Washington Puolic Power Supply System 17.1.1 Oroanization This Section describes the organizational relationships within the Supply i
System and assigns the authorities and responsibilities for the administration and implementation of the Quality Assurince Program. Assigned authorities and responsibilities demonstrate the organizational freedom of Quality Assurance.
This organizational freedom is accomplished through Corperate and Project structures which provide independence from Supply System organizations responsible for " construction".
At the Corporate level, the Director and staff of Quality Assurance, and at the Project (jobsite) Level the Project QA Manager and staff, are completely free from responsibility of cost and scheduling during " construction". The Director of Quality Assurance and the Project QA Manager have the freedom and authority to identify quality related problems, initiate corrective actions (including stop work) and recommend or provide solutions and to verify the 1mplementation of corrective actions.
Each nuclear power plant Project is administered by a Project Program Trector. The Program Director is directly accountable to the Managing Director and is responsible for the safe, successful and timely completion of construction, startup, and initial power generation of the projects. The Program Director accomplishes the Project responsibilities by managing and directing the Engineering Organization (the AE), which is performing design; the Construction Management Organization, which manages the installation 8107280565 810722 PDR ADOCK 05000460 A
~
I
WNP - 1/4 PSAR subcontractors on the project; and Project Supply System perscnnel. The Engineering Organization (the AE) and the Construction Management Organization may be a different or the same entity.
The organizations of the Supply System and Supply System Quality Assurance are presented in Figures 17.1-1 and 17.1-2 and 17.1-3.
The functional responsibilities for the implementation of the Supply System Quality Assurance Program are assigned as follows:
Corporate The Managing. Director of the Supply System has the ultimate responsibility for the Quality Assurance Program. The Managing Director shall assure that the program is implemented and maintained by assigning the appropriate auths.rity and responsibility to the Quality Assurance Director at the Corporate Level and to the Program Director at the Project Level.
The Deputy Managing Director is the chief operating officer and has delegated authority to implement policies of the Managing Director. The Deputy Managing Director is accountable to the Managing Director and is responsible for:
i a) coordinating and integrating the activities of Supply System organizations l
b) acting for the Managing Director as required.
i The Director of Nuclear Safety reports to the Managing Director and is responsible for formal contacts between the Supply System and the Nuclear Regulatory Comission (NRC) of nuclear safety issues pertaining to licensing.
The Project Licensing Manager reports to the Nuclear Safety Directorate through the Manager, Licensing and is responsible for the following:
a) coordinating and maintaining a working interface between the Supply System and the NRC b) managing, coordinating and participating in the preparation of all required license applications and supporting documentation c) maintaining a working knowledge of all pertinent regulations d) assuring review of and providing technical inputs to Safety Analysis Reports e) assuring reviewing of regulatory guides for applicability to the projects.
The Director of Administration reports to the Managing Director and is responsible to provide Records Management Services and software processing and control services to the Home Office and to the Project.
l 2
l
WNP - 1/4 PSAR The Director of Contracts and Material Management reports to the Managing Director and is responsible for the procurement control of materials and samb at for the Supply System and provides support to the Program Directors in areas or pi@t procurement, procurement contracts, and traterials control.
The Technical Director is directly accountable to the Managing Director and has responsibility to assure the provision of technical Engineering support to the Project from a Centralized Engineering organization. The Technical Director has overall responsibility for assuring:
a) the technical adequacy of the design of Supply System plants b) provision of technical direction to selected Design Subcontractors c) ensuring the transfer of design experience among projects The Director, Quality Assurance reports and is accountable to the Managing Director and is responsible for administration of the Quality Assurance Manuals for the Supply System. These responsibilities include:
(a) interpretation of Code and Quality, Assurance Manual requirements (b) definition, approval, revision and distribution of the Supply System Quality Assurance Manuals to ensure that the manual adequhcely describes requirements (c) approval of all Corporate quality affecting implementing procedures and
(
instructions (d) determining the adequacy and effectiveness of program implementation (e) apprising the Managing Director of the effectiveness of the QA Program by periodic reporting of quality activities, trends, and problems, through implementation of corrective action systems I
(f) exercising the authority vested in, the Quality Assurance organization to cause the acceptance or rejection of materials and components based on conformance verification to engineering requirements and the requirements of the Code (g) assuring that QA policies and programs provide Project QA Managers the l
freedom to inform the Director, Quality Assurance of significant l
conditions affecting quality (h) exercising authority to stop nonconforming work of any Supply System subcontractor or supplier organization and notification of the ANI, of the work stoppage L
9
/
WNP - 1/4 PSAR (1) assuring the adequacy, clarity and appropriateness of the Supply System Quality Assurance oriented communications and comitments directed to Suppliers, and the Authorized Inspection Agency (j) assuring that significant conditions affecting quality, which are identified. by Project Quality Assurance and which are addressed to the QA Directorate for resolution, are adequately investigated and/or corrected The Director, Quality Assurance is supported by the following departments:
Manacer, Vendor Surveillance and Audits The Manager, Vendor Surveillance and Audits reports to the Director, QA and is resonsible for assuring.~
(a) QA audits of internal Supply System organizations and external organizations, except for 'inagement Audits (b) Quality Assurance surveillance of off-site Suppliers and activities (c) audits, surveillances and/or surveys of Suppliers of items, materials, or services who do not have ASME Certification (d) developing audit and surveillance schedules and selecting qualified personnel to perform the activities in this function (e) review and approval of off, site Supply System administrated vendor's/ supplier's Quality Assurance programs (f) overview of AE administrated off-site contractors (g) qualification and certification of Audit personnel (h) performance of pre-award surveys / evaluations of vendors / suppliers, maintaining and distributing an updated listing of those approved (1) participation in and provide overview of audits of the AE and NSSS vendors (j) overview of off-site inspection contract for fuel and spare parts surveillance and acceptance (k) exercising Stop Work Authority Manacer, OA Enoineerina and Systems The Manager, QA Engineering and Systems reports to the Director, QA and is responsible for:
(a) distribution and control of the Quality Assurance Manual, the Corporate ASME Manual and revisions thereto
'l
WNP - 1/4 PSAR (b) assuring that Code requirements are properly interpreted and included in the QA Program requirements (c) interfacing with the ANI, Authorized Inspection Agency and the Enforcement Authority (d) exercising Stop Work Authority (e) identifying, reporting or processing nonconformances (f) assuring that a written agreement with an Authorized Inspection Agency is obtained to provide for ANI Sdrvices (g) assuring that Level III.TDE personnel involved in examination activities are certified in accordance with ASNT and/cr the Code (h) assuring that appropriate Certificates of Authorization are obtained, reviewed, and available at the location of the work (i) assucing the appror :.te certification of Supply System personnel who perform quality-af*-
- ng activities (j) performing surveillance of Home Office engineering organization The Manacer, Ooerational OA and Services, reports to the Director, Quality issurance, and is responsiole for monitoring and performing surveillances of
- .ctivities performed under the responsibility of Home Office Supply System organizations. Subsequent to the issuance of Operating License, the Manager, Operational QA and Services is also responsible for monitoring and performing surveillances of activities performed under the responsibility of Plant Managers and Startup Managers. Some of the specific responsibilities of the Manager, Operational.QA and Services, include:
(a) development, maintenance and distribution of the Operations QA Program (b) establishment of an independent QA surveillance program over Home Office activities performed by Supply System organizations (other than Engineering Division) and vendors (c) providing Operational Quality Assurance input to the training and indoctrination program ~for personnel performing activities that affect safety-related functions of plant items (d) interfacing between the plants and other Supply System organizations to establish coordinated Quality Assurance support (e) reporting plant-related quality problems to appropriate mant.gement levels to expedite corrective action (f) providing assistance to other Supply System organizations in QA matters f.
WNP - 1/4 PSAR (g) periodic review of reports of surveillances, audits, and plant-related non-conformances to identify any quality trends which may constitute a need for corrective action in order to preclude repetition of nonconformances, and for notifying the responsible Supply System organizations the significant results of such reviews for accomplishment of corrective action (h) reviewing Home Office procurement documents, procedures, and instructions for assuring inclusion of appropriate quality requirements (i) exercising Stop Work Authority Projects a.
The Program Director is responsible and accountable to the Managing Director for the safe, successful completion, startup and initial power generation of WNP-1/4 within approved schedules and budgets. The WNP-1/4 Program Director directs overall engineering, program management, construction, operations and quality assurance. Specific quality related activities are:
b.
Engineering 1)
Review and approve prepurchased equipment and construction specifications (hereinafter also called equipment and construction specifications or procurement documents)* and significant changes thereto, to assure that Supply System regulatory, code, and standard requirements are included and met, and that they are technically adequate. This review and approval shall be at the system or structure levels which deal with basic concepts of overall plant design and at the component level for critical components. Field initiated changes will be reviewed and approved if the changes represent a change in design. Field changes which implement constructability but do not affect the basic design will generally not be reviewed and approved by the Supply System.
Included in the responsibility is the completion of a Comment / Resolution Form for initial release of a specification and a documented approval sheet for subsequent changes.
Prepurchased equipment specifications and construction specifications are differentiated as follows:
Prepurchased equipment:
Specification wherein the Supply System purchases equipment or material directly from a manufacturer or supplier and includes all activities through delivery to the site.
Construction: Specification wherein the Supply System purchases site construction activities through a contractor. The specification may include a requirement for the contractor to purchase plant equipment or materials for its installation, or may only require installation of prepurchased equipment, or both, s
-c
,, _ + -.
WNP - 1/4 i
PSAR Significant changes are defined as those changes which affect the basic design. Non-significant changes are those which implement or enhance constructability but do not change the basic design.
2)
Reviews acplicable drawings for information to assure that they are technically adequate and that apprcpriate quality centrol provisiens have been included.
3)
Approves and/or determines the disposition of ncnconforming 4tems or material fcund during site activities as members of the Ncnconformance Review Scard (see Subsecticn 17.4);
4)
Provides personnel to Supply System Quality Assurance to assist in vendor surveillance activities and to perform surveillance and audits of site centractors' and AE's home office activities, as requested.
c.
Prearam Manacement
~
1)
Review and approve equipment and construction specificaticr.s, and changes thereto, to assure that the contractual requirements delineated in the bidding documents and the general and special conditiens sections provide Supply System with the requirements necessary to administer the contract effectively; 2)
Administers the contracts to assure that activities affecting quality are performed in accordance with the requirements specified in the procurement documents, and that when nonconformances are identified, approved corrective action is implemented in a timely and e'ffective manner.
3)
Responsible for quality of the werk, implementation of schedules and cost centrol techniques as well as implementation of the policies and overall objectives of the Supply System.
d.
Licensing
- 1)
Review and approve equipment and construction specifications, and significant changes thereto, to assure that PSAR/FSAR commitments and regulatory requirements are included and met.
e.
Plant Ooerations 1)
Responsible for the review and approval of specifications, and significant changes thereto, for the cperability and maintainability of the equipment, systems and structures; 7
_b
Provides personnel to Supply System Quality Assurance to assist in vendor surveillance activities and to perform other surveillance and audit functions, as requested, f.
Construction Manacement 1)
Responsible for construction contract administration to assure that activities affecting quality are performed in accordance with the requirements specified in the contract documents, and that when nonconformances are identified, steps are taken to stop the nonconforming activity and to assure that resolution is implemented in a timely and effective manner.
2)
Assists in verifying acceptability of contract change orders, g.
Quality Assurance 1)
The Manager, Quality Assurance & Safety reports to the Program Director and is responsible for enforcing implementation of the Supply System's Corporate Health & Safety Programs under the OSHA /WISHA act of 1970 and the Supply System's Quality Assurance Programs for design, engineering, procurement, fabrication, installation, construction, testing, operation and maintenance of the WNP-1/4 Project. The Manager of Quality Assurance & Safety provides assistance to the Program Director to integrate the Quality Assurance and Safety mission with other Project organizations' activities and assures that Project Quality and Safety activities are in accordance witu state and federal requirements. He has access to the Quality Assurance Director for significant conditions adverse to quality.
The qualification requirements for the position of Manager, Quality Assurance and Safety are as follows:
85 degree in engineering or science and ten years experience in the nuclear industry or equivalent education and experience. Knowledge l
and ability in the areas of planning, organization, measurement, decision making; must be capable of broad overall performance under multiple project conditions.
The Project Quality Assurance Manager reports to the Program l
Director at the Project through the Manager, Quality Assurance &
Safety and is provided independence from the Supply System organizations responsible for engineering, procurement and construction, and is free from the responsibility of cost and scheduling during procurement, design and construction and startup.
i I
I C
i I
WNP - 1/4 PSAR The Project Quality Assurance Manager has the freedom and authority l
I to identify quality prcblems, initiate, recommend or provide corrective actions, verify the implementation of the corrective action and control further processing, delivery or installation of a nonconforming item, or a deficiency or unsatisfactory condition until proper disposition has been made, including-stopping work for
(
quality reasons.
The Project Quality Assurance Manager shall be responsible for:
a) verification of the implementation of the Quality Assurance i
Program Description and QA Manuals b) Stop Work Authority l
c) identification and reporting of nonconformances d) verification by audits and surveillances that the contractor's and other project organizations are implementing applicable e) quality requirements assuring that adequate staffing is obtained to implement QA actions at the project f) tia assignment cf adequately trained and qualified / certified personnel to perform quality verification activitfes g) cverview of the CM approval of contractor's procederes and instructions h) reporting to the Program Director significant conditions adverse to quality i) reporting all QA problems and trends to the Directcr of Quality Assurance for use in developing standards for QA Management Systems to preclude repetition of QA problems Major organizations to whom Quality Assurance functions have been delegated I
are:
a)
United Engineers and Constructors, Inc. (UE&C)
Architect - Engineering Construction Management Services as Constructor, ASME III Div 2 Quality Assurance Services, ASME III Div 2 li bl sechtel Power Corporation Ccnstruction Management and QA Services c)
Babcock & Wilcox (B&W)
Nuclear Steam Supplier UELC has been contracted to provide overall Architect-Engineering for WNP-1/4. In addition, UE&C has been contracted to provide Construction Management responsibilities as Constructor, including Quality Assurance for ASME III Div 2 related activities. As AE, UELC is responsible for generation of specifications for procurement of prepurchased equipment and construction activities. These contract specifications are sent to the Supply System for review and approval prior to award of contracts. ihe administration of
+
w.---
--w-w-e-v 3--,,--,,,p
-,r--
-.----y--g
--+-.i--~---,--w-
, - + -
,-----,---,-*-c-e.
. 3
--w-
WNP - 1/4 PSAR specificati~ons is performed jointly by the Supply System and UE&C for prepurchased contracts. The QA responsibility includes Home Office QA, vendor surveillance and site QA and Construction (ASME III Div 2). (See Sections 17.2 and 17.4)
Bechtel has been contracted ta provide overall Construction Management and QA for WNP-1/4. The Supply Syst.em and Bechtel will jointly perform the administration of construction specifications associated with WNP-1/4. (See Section17.4)
B&W has been contracted to provide the Nuclear Steam Supply System which includes the responsibility for the QA and Quality Control activities associated with their secpe of supply. (See Section 17.3) 17.1.2 Ouality Assurance Program The Supply System QA Frogram described in Section 17.1 is currently in effect for ongoing quality functions. Section 17.1 delineates in detail die intent and substance of the Supply System QA Program. The Supply System Program is based upon the Quality Clanification as assigned to the structures, components, and systems in Tables 3.2-1 and 3.2-2.
Structures, components, and systems are classified as Quality CTass I, II and G in accordance with their design basis or functional requirements. The applicable requirements of Appendix B to 10CFRSO are applied to those items classified as Supply System Quality Class I due to their relationship to a nuclear safety function. Those items classified as Supply System Quality Class II or G are not safety related and are not subject to the requirements of Appendix B to 10CFR50. Supply System Quality Class II or G are required to meet applicable commercial standards. The Supply System quality assurance classifications are as follows:
Quality Class I - Any nuclear structure, system, subassembly, component
~'
or design characteristic that prevents or mitigates the consequences of a postulated accident that could cause undue risk to the health and safety of the public. All safety-related items fall within this category.
l The Supply System QA Program defines non safety-related items as follows:
Quality Class II Augmented - The liquid radioactive waste system and those portions of the solid radioactive waste systems which centain liquid waste.
Quality Class G Augmented - Those portions of the fire protection system protecting safety related equipment or protecting areas which contain potential fire hazards to safety related equipment.
Quality Class II - Any 5tructure, system, subassembly, component or l
design characteristic which, as a result of being defective, could cause a safety hazard to plant personnel, an extended reduction in unit output, an unscheduled unit trip, or equipment damage.
Quality Class G - Any non-nuclear portion of the plant to which QA requirements are assigned in accordance with the consequence of failure and operating. costs. If necessry, Quality Class G can be upgraded to Quality Class II.
10
.a.
)
WNP - 1/4 PSAR The Supply System Quality Assurance Program Manual contains the written policies and procedures structured from the requirements of ANSI N45.2-1971 and 10CFR50, Appendix 8 by which the Supply System performs its
- elated quality assurance activities. A matrix of the Supply System QA Program procedures and the corresponding criteria of 10CFR50, Appendix 8 appears in the table below followed by des ription of the scope covered by these procedures.
10CFR50, Accendix B Criteria Sucoly System OAR I
Organization QAR-1 II Quality Assurance Program QAR-2 III Design Control QAR-3 IV Procurement Document Control QAR-4 V
Instructions, Procedures ano Drawings QAR-5 VI Document Control QAR-6 VII Control of Purchased Material, Equipment QAR-7 and Services VIII Identification and Control of Material, QAR-8 Parts and Components l
IX Control of Special Processes QAR-9 X
Inspection QAR-10 XI Test Control QAR-11 XII Control of Measuring and Test Equipment QAR-12 l
XIII Handling, Storage and Shipping QAR-13 XIV Inspection, Test and Operating Status QAR-14 XV Nonconforming Materials, Parts or Components QAR-15 XVI Corrective Action QAR-16 XVII Quality Assurance Records QAR-17 XVIII Audits QAR-18 l
C 11
=1 Organization, OAR-1 e tablishes an organizational structure that will direct the resources of s
the Supply System and its contractors to engineer, design, procure, fabricate, manufacture, install, construct trd test the Supply System i
Nuclear Projects to maximize safety, reliability and efficiency.
b)
Procram, OAR-2 Defines the Quality Assurance Program established by the Supply System for design and construction. Included in this program is a system for classifying structures, systems, components, design characteristics and procurement documents to determine the Quality Assurance activities associated with each item.
c)
Desion Control, OAR-3 Establishes a system of independent reviews to assure applicable quality regulatory, code and design basis requirements are properly translated into design and procurement documents for each structure, system and component. The documented review provides a check for design adequacy, inspectability and comatibility with intended usage.
d)
Procurement Document Control OAR-4 Establishes a system to assure that procurement documents and changes thereto incorporate the technical and quality assurance requirements necessary to assure the quality and integrity of procured material, equipment and services.
e)
Instructions, Procedures and Drawinos, OAR-5
~
Establishes system defining the requirements and responsibilities controlling the preparation, review, approval and release of instructions, procedures and drawings which imolement quality requirements.
f)
Document Control, OAR-6 Establishes a system to control the issuance of documents, including changes thereto, which prescribe activities affecting quality.
g)
Control of Purchased Material, Enuioment and Services, OAR-7 Establishes a system to assure material, equipment and services are procured in accordance with the requirements specified in the procurement documents.
c.
/0
_h..,__._._.,-.
Identification and Control of Materials, Parts and Comconents, OAR-8 Establishes a system for the identification and control of material, parts, components, equipment and partially completed assemblies to assure that items incorporated into the plant are of proper configuration and,
]
when necessary, traceable to all supporting quality assurance documentation.
1)
Control of Soecial Processes, OAR-9 Establishes a system for the control of special processes.
j)
Insoection, OAR-10 Establishes a system which assures the program requirements for i
inspection are delineated fn the specifications and contracts and assures that inspection and surveillance activities are performed in accordance with pre-determined requirements delineated in written instructions in a planned and systematic manner.
k)
Test Control, OAR-11 Establishes a system to assure that plant testing activities are performed in accordance with pre-determined requirements, approved and delineated in written instructions.
1)
Control of Measurino and Test Eouiement, OAR-12 l
Establishes a system for the control, calibration and adjustment of tools, gauges, instruments and other inspection, measuring, testing and maintenance devices at specified periods to assure the useage of proper type, range and accuracy necessary to verify conformance to established l
requirements.
l l
m)
Handlino, Storage and Shiocino, OAR-13 i
Establishes system to control the handling, storage, shipping, cleaning and preservation of material, parts, components and equipment in accordance with written and approved procedures, instructions and recommendations, to assure that the designed integrity and functionality of the item are maintained.
n)
Insoection, Test and Ooerating Status, OAR-14 Establishes a system to indicate the inspection, test and operating status for all structures, systems or components to preclude the inadvertent bypassing of their inspection and test requirements and to prevent their inadvertent operation.
A e
t3
Nonconformino Material, Parts or Comoonents, OAR-15 l
Establishes a system to assure that nonconformances are identified, documented, segregated or otherwise controlled, prevented from inadvertent use or installation and that notification of actions taken is transmitted to the affected parties.
I p)
Corrective Action, OAR-16 Establishes a system to assure that significant conditions adverse to i
quality are identified, the cause determined, documented, brought to the attention of upper management, corrected as soon as possible and that measures are taken to preclude repetition, q)
Quality Assurance Records, OAR-17 Establishes a system for the control and maintenance of all records sufficient and necessary to provide objective evidence of the activities affecting quality, r)
Audits, OAR-18 Establishes a system of audits to be performed in a planned and systematic manner to verify compliance and effectiveness of the Supply System Quality Assurance Program.
The Supply System Quality Assurance Program was in effect during the preparation of the PSAR.
Supply System Quality Assurance is responsible for establishing Quality Assurance policy, goals, and objectives through the development and administration of the Supply System QA Program. This program is defined in the Supply System QA Program Manual developed by the Manager, Quality Engineering, and reviewed and approved by the Director, Quality Assurance and endorsed by the Managing Director.
Supply System QA personnel have the authority and responsibility to perform any actions necessary, including Stop k Authority, to accomplish their i
mandate as delineated in the Quality Asst. nce Manual. This responsibility and authority is stated in a Management Statement signed by the Supply System Managing Director. The Management Statement appears in each Quality Assurance Manual, and is included as Figure 17.1-4.
In matters of conflict regarding Quality Assurance policies or the Quality Assurance organizations authority to enforce them at the working level, the Director of Quality Assurance has direct access to all levels of upper management including the Managing Director for satisfactory resolution.
l ik
WNP - 1/4 PSAR To assure that Supply System personnel performing quality related activities are knowledgeable of procedures and requirements, and will be proficient in implementing them, the Supply System Quality Assurance Training Program under coordination and direction of the Manager, Operations QA and Services, is established and documented as required by the applicable Supply System Quality Assurance Training Proedure and implementing instructions. This Training Program consists of:
1)
The initial formal training and crientation one receives as to the purpose, scope and implementation of applicable codes and standards, including 10CFRSO Appendix 8.
This initial training phase also includes specific detailed instruction on the Supply System QA procedures and instructicns, project specific procedures and other activities which directly relate to the employee's job functions. Supply System supervisory personnel also indoctrinate and train personnel performing quality related activities in the principles and techniques of the activity being performed.
2) on-going instruction by lecture, discussion, and pre-planned presentations, supplemented by outside courses as deemed useful.
In addition to the training delineated above, Quality Assurance personnel will receive training to provide them with an understanding and appreciation of the management of an effective Quality Assurance program. QA personnel will receive orientation and indoctrination to position responsibilities, and to applicable codes and standards. This training may be auamented by both inhouse trainirs and attendance at appropriate industry sponsored training sessions, the extent of which will be determined by an evaluation of the prior QA experience and knowledge of the employee, and the comparative requirements of the current QA position. After this training has been completed, such idividuals will be assigned initial work under the direction and guidance of qualified, experienced personnel (e.g., Lead Auditors) and will receive en-the-job training to ertablish and maintain proficiency.
The Supply System posi'.on on NRC Regulatory Guide requirements is stated in Secton 3.12. These requirements are verified as being included in the design specification during the design review process described in Subsection 17.1.3.
The Supply System QA Program will comply with the requirements contained in 10CFR$0, Appendix B, and will ccuply with the guidance contained in the Supply System position for NRC Regulatory Guides, the NRC's Gray Book, " Guidance on Quality Assurance Requirements During Design and Procurement Phase of Nuclear Power Plants-Revistor 1", and the NRC's Green Book, " Guidance on Quality Assurance Requirements During the Construction Phase of Nuclear Power Plants".
The Supply System QA Program's scope, implementation, and effectiveness is audited by the Corporate Office audit organization. Copies of all audit reports and correspondence are routinely routed to Supply System Project Management, and Project Quality Assurance so that management can regularly i
i assess the effectiveness of the Quality Assurance Program.
c.
/f
[
1, a
WNP - 1/4 P'AR Additionally, on an annual basis, management will arrange for an independent-audit and evaluation of the adequacy of the scope, implementation, and effectiveness of the Supply System QA Program. This will be accomplished by knowledgeable personnel outside the Quality Assurance Organization to assure achieving an objective program assessment. Results from this independent review will be reported to the Managing Director.
1 The Supply System requires its Quality Class I contractors, including UE&C, Sechtel, and B&W to establish and implement Quality Assurance Programs consistent with the applicable Criteria of 10CFR50, Appendix 8.
The Quality Assurance programs of UE&C, Cachtel, and B&W are reviewed for compliance with Appendix 8 by the Supply System. Quality Class I contractor's Quality Assurance programs are reviewed for compliance with Appendix 8 by UE&C and Bechtel, as appropriate.
(
The details of the UE&C. Bechtel and S&W QA Program are described in Sections 17.2 and 17.4, and 17.3 respectively.
17.1.3 Desfon control The Supply System has organized, and is following, a system of design review and approval by QA, Engineering, Licensing, Operations, and Project Management of Supply System and UE&c generated procurement documents for Supply System Quality Class I systems, structures, subassemblies, components and design characteristics. UE&C Engineering has been assigned the responsibility to review the remaining design contractor's procurement documents.
In all cases, prior to submittal to either the Supply System or UE&C for j
review and/or apper.aal, the design contractors, including UE&C, are responsible for verifying that the design meets the requirements of the specification, is comensurate with good design practices and that the conponents can be readily inspected. This ve ification it achieved by the performance of design reviews, the use of alternate or siuplified calculation methods, or by the performance of a suitable testing program. The verification or checking process is performed'by individuals cr groups other than those who performed the original design. Where a test program is used to verify the adequacy of a specific design feature in lieu of other verification or checking processes, it includes suitable qualification testing of a prototype unit under the most adverse design conditions. Design control measures are applied to items such as the following: reactor physics, stress, thermal, hydraulic, radiation, and accident analysis; compatibility of material; accessibility for inservice inspection, maintenance, and repair; and the delineation of acceptance criteria for, inspections and tests.
1 b
/6
l 1
WNP - 1/4 PSAR Supply System Project Engineering has the primary responsibility for the technical review and approval of Supply System and UE&C generated prepurchased i
equipment and constru: tion specifications. Each discipline, mechanical, electrical, nuclear, and civil reviews the specifications to assure they are technically adequate. The depth of this review is outlined ir. an engineering design review check list utilized by the reviewing engineer for each Supply System Quality Class I specification. The design review check list outlines a review of: 1) design requirements, including the appropriate section of the PSAR and referenced Regulatory requirements; 2) codes and standards requirements; 3) classification of characteristics; 4) materials selection i
adequacy; 5) testing requirements; 6) welding requirements; 7) identification and serialization; and, 8) preservation, packaging, and handling.
Supply System Licensing reviews and approves the specifications to assure conformance to PSAR/FSAR and other regulatory requirements.
l Supply System Operations reviews and approves the specifications to assure that the item being specified can be inspected, operated and maintained.
Supply System Project Management reviews and approves the specifications to assure that the general and special conditions sections contain adequate requirements for contract administration.
Supply System QA reviews and approves the specifications to assure that adequate requirements are included in the specifications. The QA review assures that: 1) the specifications contain the necessary QA requirements; l
- 2) the test and special processes are properly identified and contain l
appropriate acceptance / rejection criteria; 3) codes and standarcs are current and correct; 4) Quality Classifications are identified; and, 5) the applicable generic sections of welding, cleaning, and packaging are included.
Supply System QA signs the Design Review Route Sheet to indicate review of.
Coment Issues, and signs the Coment Issue Approval Sheets after assuring the
[
QA requirements are included and that the specifications have been through the required Supply System design review.
(SeeSubsection17.1.3.1)
Design changes, including field chcages, are sutject to design control I
measures comensurate with those applied to the original design and are I
approved by the organization that performed the original design unless the Supply System has designated another responsible organization.
Documentation pertaining to design control of Supply System Quaiity Class I procurement documents will become ' art of the objective evidence of the p
quality of the applicele items, and will be filed and maintained in a traceable, retrievable, systematic manner.
l 4
17 t
i WNP - 1/4 PSAR The details of the design control measures implemented by UE&C and B&W are described in Section 17.2 and 17.4, and 17.3 respectively.
The Supply System QA Program requires that Supply System and UE&C generated procurement documents be reviewed and approved to verify that requirements have been included which provide for the development and implementation of a Quality Assurance Program for Supply System Quality Class I items and activities which specifically comply with 10CFR50, Appendix B criteria. In addition, the contractors and vendors of Supply System Quality Class I items and activities are required to have Quality Assurance Programs which comply with ANSI N.45.2-1971 and additional requirements as delineated in the procurement documents.
The procurement documents specify that the contractors and vendors of Supply System Quality Class I items and activities develop and implement design and interface control procedures which assure:
1.
The translation of regulatory requirements and design bases correctly into the design documents; b.
The incorporation of appropriate quality standards with deviations and changes being controlled; c.
The application of design control measures to such items as:
reactor physics, stress, thermal, hydraulic, radiation, and accident analysis; compatibility of materials; accessibility for inservice inspection, maintenance, repair; and specifying criteria for in;pection and test; d.
That proper selecticr. and accomplishment of design verification or checking methods such as design reviews, alternate calculations, or qualification testing i; performed. Where a test program is used to vert"y the adequacy of a design, a qualification test of a prototype unit under the most d$1erse design conditions will be used; e.
That individuals or groups responsible for design verification or checking are other then those atJ ?:rformed the original design; f.
Design and specification changes, including field changes, are subject to the same design controls that were applicable to the original design; g.
Design documents and revisions thereto are distributed to' responsible individu(is in a timely manner and controlled to prevent inadvertent use of superseded material; l
h.
Errors and deficiencies which adversely affect safety related structures, systems and components in the design process are documented and that appropriate corrective action has been taken; 89
Design documents, design reviews, records, and changes thereto are collected, stored, and maintained in a systematic and controlled manner; j.
Standard "off the shelf" comercial or previously approved materials, parcs, and equipment (that are essential to the safety related ' unctions of the structures, systems, and componenets) are selected and reviewed for suitability of application.
17.1.3.1 Sucoly System er UE&C Generated Soecifications and Drawings Supply System or dE&C Engineering prepares Client Comment, Revised Client Coment and Bid Issues of specifications for WNP-1/4 in accordance with all applicable Codes and ' Standards and QA Procedures utilizing engineering data generated from Technical Memorandums, Project Criteria Documents, PSAR comitments and/or Supply System requirements. Calculations and specification data are independently reviewed and checked by engineers c.iperienced in the appropriau engineering discipline.
Supply System or UE&C Engineering prepares specifications and associated drawings which are reviewed and approved internally. The Client Comment Issue of the specifications are then sent to the Supply System for review and approval.
Client Coment Issues are received by the Su'pply System and are assigned to a Reviewing Engineer. Copies of the Client Coment Issues are also assigned to Supply System CA, Licensing, Operations, and Project Managerrent. Each discipline reviews the specification in accordance with the Supply System design review procedures and checklists. The Reviewing Engineer is responsible for the overall review, cbtaining signoffs from the reviewers, preparation of the Coment/ Resolution form for reso;ution of coments. For UE&C prepared specifications the form is transmitted to UE&C for resolution; for Supply System prepared specifications the form remains with the Reviewing Engineer foi resolution.
Pages and drawings which are affected by the Supply "" stem review are corrected and issued as a Revised Client Coment Iss6e. This document is reviewd to assure that coments have been resolved and incorporated based on the Coment/ Resolution form. The original Supply System reviewers' acceptance is secured en coments which have been rejected. Rejections which are unacceptable to the Supply System will be resolved and so noted on the Coment/ Resolution form.
l A Bid Issue is then prepared and sent to the Supply System for final l
approval. The Reviewing Engineer reviews the Bid Issue. The final Supply l
System approval is indicated by the signature of the Supply System Program Director on the Bid Issue Approval Sheet.
l l
19 m
WNP - 1/4 PSAR 17.1.3.2 Contractor and Vendor Generated Drawinas and specifications When a contractor or a vendor initiates a design he is required to perform design review activities in accordance with internal design review procedures. Upon completion of this review his design drawings and specifications are forwarded to UE&C Engineering for interface review.
UE&C conducts a review of the drawings and specifications in accordance with UE&C procedures which includes measures to contr.ol the receipt, approval, and transnittal of vendor drawings, and an approval of the procedures and specifications required to be submitted to UELC in accordance with the procurement documents.
The receipt of vendor drawings, specifications and other documents is acknowledged to the Supply System staff via a transmittal which lists and describes the material received. Supply System personnel review the attachments to these transmittals on a selective bas's and transmit any coments to UE&C for inclusion in the document.
17.1.4 Procurement Document control i
All procurement of materials, parts, components, and construction activities for WNP-1/4 is accomplished through prepurchased equipmeat and construction specifications and contracts prepared by the Supply System, or UE&C for the Supply System. Purchasing is accomplished by award of contracts by the Supply System Board of Directors and The Executive Comittee Personnel based on proposa! submitted in conformance with the specifications.
I Each proposal is evaluated by the Supply System and UELC. The evaluations l
include any exceptions taken to the specification requirements.
The Supply. System QA Program requires that Supply System and UE&C develop and i:mlement measures which asrure that procurement documents are prepared, reviewed, approved and issued under controlled conditions. These control measures have been established and are currently in effect. These measures are described in Subsection 17.1.3.
In addition, addenda issued prior to bid opening require a review and approval comensurate to the performed on the original procurement document.
The Supply System OA Program requires that Supply System and UE&C generated procurement documents be reviewed, and approval sheets signed off by Supply System 0A personnel. These reviews verify the inclusion of applicable organizational, program, design control, procurement control, document control, identification special process, inspection, testing, calibration, handling, storage, shipping, nonconformance control, corrective action, record retention, record control, record mainte lance, audits acceptance / rejection criteria and other quality requirements. The procurement documents require that contractors and vendors of Supply System Quality Class I items have a QA Program which meets the applicable requirements of 10CFR50, Appendix 8 and ANSI N45.2-1971.
l 1
i l
20
i WNP - 1/4 PSAR In addition, the Supply System QA Program requires that Supply System and UE&C generated procurement documents be reviewed, and approval sheets signed off by Supply System, and UELC (if UE&C generated) Engineering personnel. These reviews verify the inclusion of applicable design, regulatory, code, material, testing, metal joining, part identification, spare parts, cleaning, preservation, packaging, handling, storage, shipping, installation and other i
design and procurement related requirements.
The Supply System is responsible for the orientation and training of personnel i
performing quality affecting activities. The Supply System QA Program requires that Supply System personnel performing quality functions be adequately qualified, thus providing a mechanism to assure that personnel reviewing procurement documents are sufficiently knowledgeable to verify that proper quality related requirements have been incorporated.
The review and approval of Supply System and UE&C generated procurement documents is documented by thc Supply System. This documentation consists of approval sheets, connent/ resolution sheets and applicable correspondence.
This objective evidence is filed and maintained in a controlled, traceable, retrievable systematic manner.
Documentation requirements are specifically delineated in the procurement documents indicating to the bidders, contractors and vendors which documents must be submittri for information or approval.
Procurement documents include requirements which assure the right of access by Supply System and/or UE&C personnel to the contractor's operations or the vendor's facilities, and their reccrds. QA requirements are incorporated in 1
procurement documents in accordance with their Quality Class and complexity.
Bidders on Supply System Quality Class I documents are required to subnit with their bids a comprehensive QA Plan describing their QA system, policies, responsibilities and procedures which will be, or are being, implemented to control quality throughout all phases from design to final shipment, erection, f abrication, installation, testing or startup, as applicable.
After bid openings and prior to contract award, bids are reviewed by Supply System QA and Engineering Department personnel with assistance from UE&C Home Office QA and Engineering Department personnel to determine the acceptability of the bidders' QA programs." This evaluation consists of an examination of their QA Plan, evaluation of past quality performance based on previous experience with Supply System, UELC, and industry experience, and if a reasonable judgment cannot be made or the importance of the activity requires a QA evaluation of the vendor's facilities or contractor's operations, then a QA evaluation will be performed. After completion of the documented bid evaluation, the Program Director is notified as to the acceptability of the bidder's QA program based on his demonstrated ability of commitment to meet the procurement document requirements.
The details of the procurement document control measures implemented by UE&C and B&W are described in Sections 17.2 and 17.4, and 17.3 respectively.
J 1
4
- f
~
WNP - 1/4 PSAR 17.1.5 Jnstructions,ProceduresandDrawines The Supply System QA Program Manual delineates the methods by which the Supply System complies with the criteria of 10CFR50, Appendix 8.
Implementation of the Supply System QA Program assures control of the activities affecting quality.
The Supply System QA Program requires UE&C and Bechtel to have based the development of their QA Program, and the procedures for its implementation, on the requirements delineated in 10CFRSO, Appendix 8.
UE&C generated procurement documents require that instructions, procedures and drawings relative to the work being performed will be maintained in the general work area and available for reference by the personnel performing the work.
i Contractors and vendors, including UE&C, Bechtel and B&W, are required to have written instructions, procedures, policies and/or drawings which govern their quality related activities and which include appropriate quantitative and qualitative acceptance / rejection criteria. In addition, contractors and vendors, including UE&C, Bechtel and B&W, are required to impose similar documentation requirements on their subcontractors.
The details of the measures which UEet, Bechtel and B&W implement to assure the development and issuance of instru:tions, procedures and drawings are described in Sections 17.2 and 17.4, and 17.3 respectively.
17.1.6 Document Control Occument control is implemented by the Supply System, UE&C, Bachtel and B&W in accordance with the requirements delineated in their respective QA Manuals.
These requirements provide measures to Issure that appropriate written instructions, procedures, policies, drawings, and procurement documents including changes thereto, are properly reviewed and approved prior to release by personnel assigned review and/cr approval authority as delineated by the QA Program. Changes to these applicable documents require a review and/or l
approval commensurate to that performed on the original document. These reviews and/or approvals verify the inclusion of adequate quality requirements and evaluate the impact of the changes on other project activities.
Additionally, issuance of controlled documents is performed by personnel assigned' distribution authority as delineated by the QA Program. This controlled issuance is designed to distribute controlled documents in a timely manner to the locations where the applicable activity is being performed and to prevent the use of cbsolete or superseded documents.
The Supply System QA Program provides for the contolled updating of the Supply System QA Program Manual through a process that specifically requires holders of a controlled copy of the Supply System QA Program Manual to destroy or return superseded documents.
l l
C.
21
.. I
WNP - 1/4 PSAR Procurement documents generated by the Supply System, UELC, Bechtel and B&W require that contractors and vendors, including their subcontractors, of Supply System Quality Class I items have document control procedures in accordance with 10CFR50, Appendix 8.
The Supply System QA Program docu ont control measures, as delineated in the procurement documents, requires that quality related documentation be available prior to the performance of the activity to which they relate.
The Supply System QA Program document control measures pertain as a minimum to contract specifications, contract drawings, QA Program Manual procedures, operating procedures, quality related instructions and various process, test and inspection procedures as delineated in the contract specifications.
The details of the document control measures implemented by UE&C, Bechtel and S&W are described in Sections 17.2 and 17.4, and 17.3 respectively.
17.1.7 Control of purchased Material. Eouipment and Services As described in Section 17.1.4, procurement for WNP-1/4 is accomplished through procurement documents. These documents contain sections which describe the general conditions, special conditions,and technical specifications which the contractor is required to meet. The requirements of the general conditions, special conditions and technical sections are to assure that purchaced material, equipment and services, whether purchased directly or through contractors, conform to design requirements. Measures to control these activities include a review and approval of procurement I
documents by Supply System; source evaluation and selection, vendor surveillance, inspections, and audits by Supply System and/or UE&C; and receiving inspecticn of these items upon receipt at the site.
I Specifically, QA requirements are incorporated in procurement documents in j
accordance with their quality class and complexity. Bidders on Supply Systea Quality Class I documents are required to submit with their bids a congrehensive QA Plan describing their QA systems, policies, responsibilities and procedures which will be, or are being implemented to control quality throughout all phases, from design to final shipment, erection, fabrication, installation, testing, or startup, as applicable.
The Supply System QA Program requires that surveillance of contractors and vendors be performed in accordance with written procedures, and that surveillance activities be planned and designed to verify and document that the contractors and vendors are conforming to the requirements of the procurement document.
In addition, the Supply System QA Program requires that receiving inspection of items at the site be performed in accordance with written procedures, and that receiving inspection activites be planned and designed to verify and document that the material, equipment, or component being received conforms to the requirements of the procurement documents and that the required documentation is available at the site prior to installation or use.
l l
O WNP - 1/4 PSAR The Supply System QA Program requires that received items will be stored and handled on a controlled basis with nonconforming items being processed in accordance with the requirements described in Subsection 17.1.15.
Documentation pertaining to the control of purchased material, equipment, and services will become part of the objective evidence of the quality of the applicable items, and will be filed and maintained in a traceable, retrievable, systematic manner.
The details of the measures which UE&C, Bechtel and B&W implement to assure the control of purchased material, equipment and services are described in Section 17.2 and 17.4, and 17.3 respectively.
17.1.8 Identification and Control of Materials, Parts and Comoonents The Supply System QA Program requires that Supply System and UE&C generated procurement documents be reviewed and approved to verify that requirements have been included which provide for the development and implementation of measures for the identification and control of materials, parts, and cog onents. In addition, these reviews and approvals assure that identification and marking requirements have been adequately delineated and that the location and method of identification and marking do not adversely affect the function or quality of the subject item.
The requirements which are incorporated into the procurement documents provide for a positive system of identification and control of materials, parts, cogonents and partially completed subassemblies while in storage, warehousing and holding areas and during their fabrication, manufacturing, installation
(
and constructicn.
These identification and control measures establish a means by which items can be traced to, and conformance verified, with their applicable documentation.
Verification that the items have been properly identified is to be performed i
during vendor surveillance activities prior to shipment of the items.
Identification is further verified during receiving inspection at the site to assure that identification status was not adversely affected during shipping and to provide.a verification check if the vendor surveillance verification check was waived.
Documentation pertaining to the identification and control of materials, parts and components will become part of the objective evidence of the quality of the applicable items, and will be filed Md maintained in a traceable, retrievable systematic manner.
The details of the measures which UE&C, Bechtel and B&W implement to assure the identification and control of materials, parts, and components are described in Sections 17.2 and 17.4, and 17.3 respectively.
l I
s 7
1
17.1.9 Control of Soecial Processes The Supply System QA Program requires that Supply System & UELC generated procurement documents be reviewed and approved to verify that requirements have been included which provide for the development and implementation of measures for the control of special processes. These requirements specify applicable codes, standards, specifications and any special requirements necessary for the control of the delineated special processes.
In addition, the procurement documents specify that special proc:sses will be performed and controlled in accordance with written procedures and will further delineate which special processes procedures will be submitted to UE&C for information or approval.
The procurement documents will require that procedures be developed to control such special processes as:
a.
Welding b.
Cleaning c.
Heat Treating d.
Nandestructive Examination e.
Repairing Essential ingredients of these procedures shall assure that:
a.
Equipment utilized in the performance, inspection, and control of special processes that require qual *fication shall be qualified to its intended usage prior to being installed or used, b.
Personnel performing any special process'es shall be qualified in accordance with applicable standards prior to the performance of work.
c.
Data collected in conjunction with the control of special processes shall include the type of operation, results, acceptability, action
' taken when deficiencies were noted, and the identification of inspector and/or data recorder.
Special processes procedures, qualification documentation, insoection and test results will become part of the objective ^ evidence of the quality of the applicable item, and will be filed and maintained in a traceable, retrievable, systematic manner.
The details of the measures which UELC, Bechtel and B&W implement to assure the control of special processes are described in Sections 17.2 and 17.4, and 17.3 respectively.
4 W
WNP - 1/4 PSAR 17.1.10 Insoection The Supply System QA Program requires that Supply System & UE&C generated procurement documents be reviewed and approved to verify that requirements have been included which provide for the development and implementation of inspection measures. These requirements specify that inspections will be performed by personnel who are independent from the individual or group responsible for performing the activity being inspected.
In addition, the procurement documents specify that inspection activities will be performed and controlled in accordance with written procedures, instructions and/or checklists. These procedures, instructions and/or checklists are required to provide for:
a.
The identification of1;uality enaracteristics to be inspected.
b.
The identification of those individuals or the organization responsible for performing the inspection operation.
c.
Acceptance / rejection criteria.
d.
A description of the method of inspection.
t e.
Evidence of completion and certification of inspection operation.
l f.
Record of the results of the inspection cperation.
i The procurement documents further require that procedures, instructions, and I
drawings relative to the work being performed will be maintained in the work area and available for reference by the personnel performiag the work.
Contractors and vendors are required by the procurement documents to specify the qualification requirements for inspection personnel, and to assure that each inspector's qualifications ara maintained current. The contractors and vendors are further required to perform inspection of modifications, repairs and replacement items, which are made after the initial inspections, in a manner comensurate with the original inspection requirements or to Supply l
System ancj/or UE&C aperoved alternatives.
1 Inspection equipment is required to be calibrated as described in Subsection 17.1.12.
i UE&C has been delegated the responsibility to perform source inspection activities associated with prepurchased items, and site construction surveillance of ASME III, Division 2 activities.. Bechtel has teen delegated the responsibility to perform site receiving inspection of prepurchased items, and site construction surveillance activities. Pre-surveillance planning developed by responsible organizations will define surveillance requirements, acceptance criteria, and provide documented results to provide objective evidace that the particular quality characteristic inspected ac'Jally i
l conforms to the specification requirement.
h
WNP - 1/4 PSAR Source inspection will be acccmplished by the UE&C vendor surveillance group from inspection plans developed by UE&C from the procurement documents. This inspection will assure adequate control of processes to assure that required quality is obtained when inspection is not possible or disadvantageous.
Surveillance data sheets will become part of the objective evidence of the quality of the applicable items inspected, and will be filed and maintair.ed in a traceable, retrievable, systemat*c manner.
The details of the inspection measures and/or surveillance activities implemented by UE&C Home Office, the applicable Project QA Origanization and B&W are described in Sections 17.2 and 17.4, and 17.3 respectively.
17.1.11 Test Control l
The Supply System QA Program requires that Supply System and UE&C generated procurement documents be reviewed and approved to verify that the test requirements which are required to be performed by vendors and contractors are specified. The test requirements include adequate test prerequisites, instructions for testing, proper instrumentation, documentation, and evaluation by qualified, responsible individual or group. The procurement documents require that testing be performed in accordance with written procedures, instructicas and/or plans which define the overall inspection and test requirements, the acceptance / rejection criteria and data to be recorded.
The Supply System QA Program further requires that site testing be monitored in accordance with testing inspection plans which provide for:
[
a.
An itemized list of the status identification system to be employed l
(i.e., tags numbering system),
b.
An itemized list of the occuments to be reviewed or referenced to verify the testing and inspection status of the system or component to be tested.
c.
An itemized list of the tests to be performed.
d.
An itemized list of the testing devices to be utilized.
l e.
A detailed list of acceptance criteria together with adequate space to reflect actual results.
Construction testing will be pe Normed by the contractors to ensure that the installation of equipment is done in accordance with applicable codes and standards. These tests include inspection of the equipment during and following installation, integrity tests to verify preper installations, and tests, and inspections to verify cleanliness.
l f-l
=7
WNP - 1/4 PSAR The contractors will be required to implement Inspection and Test Plans which define overall inspection and test requirements, criteria for acceptance, and data to be recorded. These plans shall be approved by the Supply System.
Integrity tests, i.e. hydrostatic, continuity, resistance, etc. and cleanliness tests will be performed in accordance with Supply System approved procedures. The contractor will be required to provide control of installed equipment in accordance with Supply System equipout tagging procedure. Upon cogletion of contractor installation and testing of a given system, all associated inspection and test records will be turned over to Bechtel and the Supply System for review and concurrence with results. System inspections will be performed by the Supply System to ensure tut equipment is installed in accordance with design requirements and that the system installation is coglete. Following resolution of any discrepancies, contractor tags will be removed, Supply System tags installed, and control of the system will then be transferred to the Supply System for functional testing purposes. Contractor test documentation will become a part of the overall permanent plant testing records.
Test control documentation will become part of the objective evidence of the quality of the applicable items tested, and will be filed and maintained 17 a traceable, retrievable, systematic manner.
The details of the test control measures implemented by UE&C, Bechtel and B&W are described in Section 17.2 and 17.4, and 17.3 respectively.
17.1.12 Control of Measurino and Test Eauiomm t The Supply System QA Program requires t h t Supply System & UE&C generated procurement documents be reviewed and approved to verify that requirements have been included which provide for the detalopment and implementation of measures to control measuring and test equipment. These requirements specify that:
a.
Contractor's and vendor's procedures will describe the calibration technique, calibration frequency, maintenance and control of all measuring and test instruments, tools, gauges, fixtures, reference standards, transfer standards, and non-destructive examination equipment which are to be used in the measurement, inspection, and monitoring of components, systems, and structures.
b.
Allowable deviations from calibration standards (tollerances) will be specified in the contractor's and vendor's procedures and submitted to the Supply System and/or UE&C for approval.
c.
Inspection, measuring, testing and maintenance devices are calibrated and adjusted at scheduled intervals against certified standards having known valid relationships to national standards, when such standards exists.
2r
Calibration intervals for each device are based on the type of equipment, required accuracy, intended usage, and other conditions affecting inspection, measurement, testing, and maintenance control.
e.
Calibration standards are maintained, calibrated ana used in an environment having tenpenture and humidity controls that are compatible with required accuracy and operating characteristics of the standards.
f.
Records are maintained that indicate the calibration history and the next scheduled calibration date for each controlled device.
g.
Each inspection, measuring, testing and maintenance device is properly identified with serial numbers, or other suitable identification, and has its last and next scheduled calibration dates clearly ~ indicated.
h.
Devices that have not been properly maintained or calibrated in accordance with specified schedules have been identified and removed for service, i.
An investigation xill be conducted and documented to determine the validity of previous inspections performed when measuring and test equipment are found to be out of calibration.
Documentation pertaining to the control of measuring and test equipment will become part of the objective evidence of the quality of the applicable items, and will be filed and maintained in a traceable, retrievable, systematic manner.
The details of the measures which UE&C, Bechtel and B&W implement to assure the control of measuring and test equipment are described in Sections 17.2 and 17.4, and 17.3 resoectively.
17.1.13 Handline, Storace and Shiocing The Supply System QA Program requires that Supply System and UE&C generated procurement documents be reviewed and approved to verify that raquirements have been inclutted which provide for the development and implementation of appropriate cleaning, preservation, handling, storage and shipping measures.
These requirements specify that procedures will be developed based on the requirements of the procurement documents, with consideration to the need for special tools, equipment and qualified personnel.
Cleaning, preservation, handling, storage and shipping requirements are I
incorporated into the procurement documents to assure that the item's designed integrity and ability to fonction are maintained.
I s
i M
{
WNP - 1/4 PSAR I,tems delivered to the site are stored, handled and preserved in accordance with procurement documents. Also the equipment manufacturer's recommendations are to be considered. These functions are performed in accordance with approved procedures and instructions. Site storage, handling and preservation are monitored by UE&C and Bechtel QA Surveillance Engineers on a scheduled basis and corrective action is taken when required. The UE&C and Bechtel QA Surveillance Engineers also have follow-up responsibility of corrective action.
Documentation pertaining to the cleaning, preservation, handling, storage and shipping of the items will become part of the objective evidence of the quality of the applicable items, and will be filed and maintained in a traceable, retrievable, systematic manner.
The details of the measures which UE&C, Bechtel and B&W implement to assure control of the cleaning, preservation, handling, storage and shipping of the items arc described in Section 17.2 and 17.4, and 17.3 respectively.
17.1.14 Insoection, Test and Ooeratino Status The Supply System QA Program requires that Supply System and UE&C generated procurement documents be reviewed and approved to verify that requirements i
have been included which provide for the development and implementation af inspection test and operating status measures. These requirements specity that procedures will be developed to assure that specified inspections and tests are performed, and that the acceptability of the items with regard to their inspection, test and operating status are known throughout the manufacturing, installation and startup testing phases.
i In addition, the procedures are required to specifically delineate the methods by which the inspection, test and operating status of an item will be identified and the controls which will be implemented to control the use of the identification methods. The implementation of the status identification system will be designed to preclude the inadvertent bypassing of required inspections or tests, unless formally waived, and to prevent the inadvertent operation of the equipment.
Documentation pertaining to the inspection, test and operating status of items will become part of the objective evidence of the quality of the applicable items, and will be filed and maintained in a traceable, retrievable, systematic manner.
The detatis of the measures which UE&C, Bechtel and B&W implement to assure implementation of an inspection, test and operating status system are described in Section 17.2 and 17.4, and 17.3 respectively.
l l
?*
"NP - 1/4 8
PSAR 17.1.15 Nonconforming Materials, Parts or Comoonents ThehupplySystemQAProgramrequiresthatSupplySystemandUE&Cgenerated i
procurement documents be reviewed and approved to verify that requirements have been included which provide for the development and iglementation of measures to assure control of nonconforming materials, par u or components.
The Quality Assurance programs of the Supply System, UE&C, Bechtel, B&W, other contractors, subcontractors, and vendors will provide for the ih nt.71 cation, documentation, segregation, review, disposition, and notification to affected organizations of nonconforming materials, parts, components, services or other orogram activities at any stage of manufacturing, fabrication, erection, or
.castruction to prevent their inadvertent use or installation. Written procedures will provide for the handling, processing, dispositioning and reinspection of nonconforming materials, parts, components, services or other I
program activities.
Nonconforming items shall be identified and marked with a " HOLD" tag (when possible); removed to a " HOLD" area, roped off, or otherwise segregated (when practical) to prevent their inadvertent use or installation.
17.1.15.1 Detection and Documentation of Nanconformances The detection cnd documentation of nonconformances detected by the Supply System follows:
a.
Site Nonconformances All Supply System Project /QA personnel shall have the authority to i
either issue a Hold Tag or assure that the appropriate Contractor / Supplier issue its Hold Tag to stop work or control further processing of nonconforming item (s) which may be in direct violation of the following:
1)ThePSAR/FSAR
- 2) Engineering, construction, or material specifications 3 Applicable codes and standards 4 Project Quality Assurance Procedures 5 Contractor's Quality Assurance Procedures Upon tagging, the individual shall contact the Supply System Site Quality Assurance Representative who shall assure the timely evaluation and appropriate acticns to further control the item or activity. If determined to be a nonconformance it will be documented by the Supply System, either using the UE&C or Bechtel Nonconformance form or brought to the attention of UE&C/Bechtel QA for their documentation, using the UE&C/Bechtel-NCR. In either case, from the point of origination, the nonconformance will be t
l handled in accordance with the UE&C/Bechtel NCR Procedura described in Section 17.4.
21 e
,.,__r, y
Vendor Nonconformances Honconforming material, parts, components, services, or other program activities detected by Supply System and/or UE&C during vendor surveillance activities will be brought to the attention of 1
the Vender's Quality Assurance personnel for their initiation of nonconformance control, using their procedure. Failure of the vendor to take appropriate actions will result in appropriate l
corrective actions initiated by the Supply System or UE&C.
i c.
System Nonconfermances A system has been established to assure quality discrepancies concerning documentation, procedures, instructions or program activities are identified, documented and corrected and that notification of action taken is transmitted to affected parties.
Quality Assurance personnel review AE and Supply System generated procurement documents to assure that requirements establishing a system of corrective action have been included. This review shall i
be accomplished in accordance with established procedures.
t 17.1.15.2 Review of Nonconformances Bechtel QA is responsible for assuring that a copy of nonconformance documents generated by vendors or contractors, UE&C Vendor Surveillance, Bechtel, UE&C l
or the Supply System which identify significant deviations are transmitted to l
the Supply System Quality Assurance organization.
I i
The Supply System Quality Assurance organization shall assure review of l
nonconformance documents to assure that proper corrective actions have been taken to preclude the rapetition of similar nonconformances, that all applicable nonconformances have been evaluated by the Nonconformance Review Board (See Section 17.4), and that those nonconformances pertaining to I
conditions outlined in the requirements of 10CFR50.55(e)/10CFR Part 21 have been properly processed. A monthly report of this review shall be prepared for Program Management.
The details of the measures which UE&C, 8echtel and B&W implement to assure the control of nonconforming materials, parts or components are described in Sections 17.2 and 17., and 17.3 respectively.
17.1.16 Corrective Action The Supply System QA Program requires that Supply System and UE&C generated procurement documents be reviewed and approved to verify taat requirements have be2n included which provide for the development and implementation of measures to assure that conditions advirse to quality are identified, evaluated, corrective action implemented, certified, documented and reported to the appropriate levels of management. In addition, the cause of e.
h esp
,. - - _ _ _.---.mw.
.. e
.-_ --- ~,
m
-_m.
WNP - 1/4 PSAR significant conditiens adverse to quality are required to be identified, evaluated, corrective action implemented to preclude repetition verified, documented and reported to the appropriate levels of management.
The Supply System QA Program requires that Supply System QA assure a review of nonconformance reports and other significant conditions adverse to quality to assure that dispositions have been effected, proper corrective actions have been taken to preclude the repetition of similar nonconformances, and that items pertaining to the conditions outlined in the requirements of 10CFR50.55(e) and 10CFR P* art 21 have been properly processed.
The pru Jrament documents require the contractor or vendor to take timely corrective action when requested by Supply System and/or UE&C/Bechtel. This requirement is in addition to their om procedure for implementing corrective action which the procurement documents specify.
Documentation pertaining to corrective actions will become part of the objective evidence of the quality of the applicable items, and will be fileo and maintained in a traceable, retrievable, systematic manne..
~
The details of the corrective action measures implemented by UELC, Bechtel and B&W are described in Sections 17.2 and 17.4, and 17.3 respectively.
17.1.17 Quality Assurance Records The Supply System QA Program requires that Supply System and UE&C generated procurement documents be reviewed and approved to verify that requirements have been included which provide for the developnant and implementation of measures to assure that documentation necessary to provide objective evidence of the activities affecting quality are generated, reviewed, approved, filed and maintained.
~
The procurement documents delineate which documentation is required for objective evidence. The objective evidence requirements include such documentation as inspection, test, nonconformance, corrective action and audit reports, as well as procedures, personnel qualifications, drawings and other procurement documents and related QA documentation.
li In addition, the procurement documents require that contractors or vendors:
a.
Have written measu'res to control the filing and retrieval of QA records.
b.
Have QA records which provide sufficient information to permit identification between the records and the iten or activity to which they apply, c.
Have QA records which are legible, complete, and authenticated and dated by authorized personnel.
M 22
Maintain control over the QA records to assure that revisions are performed under controlled conditions in accordance with written procedures by authorized personnel. Revisions will include the date and identifiction of the pers n authorized to make the revision.
e.
Maintain their QA records in a retrievable, identifiable manner.
f.
Have their QA records accessible for review by Supply System and/cr UE&C/Bechtel.
g.
Have QA record storage facilities which are constructed and located to prevent destruction by fire, flooding, or theft, and to prevent deterioration from temperature or humidity conditions.
Bechtel has been given the overall responsibility to receive, store and maintain the QA rer.ords for the Supply System at the site. 09&C has been given the responsibility to receive, store and maintain QA r 'rds associated with ASME.III Div. 2 activities.
QA records will be at the site in a storage facility constructed and located to prevent the contents from being destroyed by fire, flooding or theft, or deterioration by temperature or humidity conditions.
Sechtel Quality Assurance has been given the responsibility to review QA records to assure their correctness and completeness. QA recort's are required to be submitted to Bechtel in accordance with the requirements of the i
l procurement documents. QA records are utilized to verify that activities l
affecting quality have in fact occurred, and that they have been performed in conpliance with the specified requirements. Analyses of conditions adverse to quality are performed as indicated in Subsections 17.1.15 and 17.1.16. These analyses utilize QA records as one means of disclosing discrepancies and j
nonconforming conditions. Further, QA records provide the basis upon which dispositioning, and verification of resolutions are accomplished. UE&C has t
similar responsibility for QA records pertaining to ASME III, Div 2 activities.
Safety related equipment will not be installed until it is assured that either the documentation proving that the equipment does in fact meet the specification and code requirements is at the site, or a certification is received stating that this documentation is available and will be furnished, signed by an authorized representative of the manufacturer, and approved by l
UE&C Engineering with Supply System Engineering concurrence.
The details of the Quality Assurance record measures that are implemented by UE&C, Bechtel and B&W are described in Sections 17.2 und 17.4, and 17.3 respectively.
i 71*
y
--y m,----
.,-,.--.,-.r.,.
9.-
,.,,.c,.
,-,..y-
.,_,....,,-...-..-._,,,-~_.n-,_v
---y
s WNP - 1/4 PSAR 17.1.18 Audits The Supply System QA Program requires the contractors and vendors, and their subcontractors, to develop and implement a comprehensive system of planned and documented audits. These audit activities are required to be performed in
.lecordance with written procedures or checklists. Audit measures are required to assure that:
a.
Audits are performed by appropriately trained personnel not having responsibility in the areas being audited.
b.
Audits are conducted pe-iodically based on a preplanned schedule.
c.
Audits include an objective evaluation of quality related practices, procedures, instructions, work art.s, activities, items and documentation. In addition, audits include an evaluation of the effectiveness of implementing compliance to specified requirements.
d.
Management action is taken to correct deficient areas.
e.
Follow-ur rudits are performed to verify corrective action and to evaluate 1 e effectiveness of implementation.
Supply System audit activities are performed in accordance with written procedures by appropriately trained personnel not having direct responsibility for the areas being audited.
Supply System audits determine the adequacy of, and adherence to, the Supply System QA Program, and the effectiveness of its implementation. This is determined by:
a.
The Quality Assurance Director, Manager-Vendor Surveillance / Audits, and the Project QA Manager review reports of audits performed 5y the Supply System on UE&C Home Office, NSSS Vendor and the Supply System.
b.
The Project QA Manager reviews reports of audits performed by UE&C, Supply System and Bechtel quality assurence on UELC, Bechtel, site contractor and vendor activities.
Supply System audits are performed based on preplanned schedules and audit plans.
The implementation of each applicable Criteria of 10CFRSO, Appendix B, is scheduled to be audited by the Supply System annually. Additional follow-up audits may be scheduled to verify implementation of corrective action to findings identified by audits. The frequency of audits may be increased or decreased based on findings.
1,
WNP - 1/4 PSAR The scope of Supply System audits include:
a.
UE&C's home office, site and vender surveillance activities.
b.
B&W's home office, site (if any) and applicable manufacturing activities.
c.
Bechtel's site activities.
d.
Supply System home office and sitt. activities.
Supply System audit results are documented and reported to the appropriate levels of management for corrective action implementation. The responses to Supply System audit findings are verified for implementation and effectivene,ss during follow-up audits.
Documentation pertaining to audits will become part of the objective evidence of quality of the applicable items, and will be filed and maintained in a traceable, retrievable, systematic manner.
The details of the audit activities implemented by UE&C, Bechtel and B&W are described in Sections 17.2 and 17.4, and 17.3 respectively.
d O
e f.
7a
r I
SUPPLY SYSTEM ORGANIZATION l
M ANAGl*1G Dip:CTCR l
g g. C Od?UT'r l
MANAGING DiRECTGR l
f E..[a.'.3,7"_^7 VI 1 #'d *07'O A#-
es
... w g
1 I
t i
NUCLEAR SAFETY WNP.1. 4 WN8 2 f..V.3 5 C4RECTCA
- ROGRAM *1AECTCA PRCGRAM 12ECTOR 740 GRAM *,.A EC*04 i
C*
gg.g'NTRACT,j*g&
C'JAUTY AS3LRANCE TECMMCA' AC.',t',iSTR ATIC N pi;gg,
,y7
- iAECTCR 3:PECTCA
" P ECTO A wie- -. s R s.
t 6
l l
I!C7'*!E#*
VENCC ASe AUCiTS MANAGER N".. %.'u c;.',.
l
'*'S I
. y f
,I CA ENGINEEm*NG ENGINEERING
& Sv5TEMS CNSiON MANAGEA VANAGE:
CPEAAT:CNAL CA
& SE4 VICES MANAGER POWER GENERATION DIRECTOR l
l l
t 8CWE4 GENipATICN G E N E *AT.C N
- f,H P 1 4.
- WNp.a
. oggp,3 ra l
PLANT MANAGER PLANT MANAGER DLAN'T MANAI'sER SE V;CES Mdi wavijES MANAGs 4
MANAGER j
- g i
t
'PRICA TO CCMVERCIAL CPERATICN. THESE PCSITICNS REPORT TO THE RESPECTIVE PRCGRAM C.AgCTORS
- i i
i e
.t W ASHINGTON F JBLIC PC'AE R SL'PPLY SYSTE\\1 l
CEHomCN WPPSS NUCLEArt PRO;ECT NO. I,/h l
Peebrnevy Sategy anal. sis Reort I
m....
i WNP 1/4 ORGANIZATION (PRIOR TO OPERATING LICENSE)
I MANAGING OI AECTOR O tiPU TY MANAGING OIRECTOR I
I l
CUAUTY ASSURANCE PACCRAM CIAECTOR OIRECTCR HCME CFFICE g
I SITE I
l i
PROJECT OA &
SAFETY MANAGga l
- W.TMANAGER MANAGER OUAUIY IIUNANCI IAISI #800 UIN "
MANAGER CP[AAT;C.%3) p-I I
CPERATIONS CA STAATUP i
SUPERVISOA MANAGEA l
l LEGENO ADMINtSTAATIVE & PUNCTIONAL R EDOR T'NG UNES 08 CCMMUNiCAT3CN 1 TMS PCSATICN agpoaTS 70 MANAGER OPERAT ON AL CA L SE8 VICES A* CPERATING UCENSE.
2 TMS 80SLTION REDOATS TO DimECTOR POWER GENERAT;CN. AT CorpVERCIAL CPERATION W ASHINGTCN PUELIC 'C'AE R SUPPLY SYSTEM
'.VPP55 NUCLE A A PCC;ECT NO.1/h QUA!.ITY Asstax:CE CRC U:!!.'.TT0.':
Prefeivy Safe:v An.4ysis Repar:
l l
7tc. u.t-:
t WNP.1/4 PROGRAM PRCGRAM CIRECTOR DEPUTY PROGRAM QiRECTOR RESCURS QUAUTY A$$URANCE MANAG'.4ENT
& $Apg7y ENGINEERING CONSTRUCTION OPERATIONS AS$f **3Gaaw otatcton asst encomau ciascton
" ass? pecGaam castc*ca l
l WASHING 7CN PUBL:C 80WER SUFPLY SYS ':M g[p 1/( g g g gv373g
'*i8253 NUCLEAR 8ROJECT NO 1/h i
Prehmana v 34'ety Analysis Recort PRCJECT ORGA:'IZATIOW i
l
'l i
l
[
e3
=
y
-,w--
--y- -
-.,,-,7-g y
_.-4 y.n 9,+.-g y.
..._.7 y9-.
p-,_ww-y g4.
yv.c y
- f a
l.
n CORPORATE PCLICY AND PROCECURE QUALITI ASSURANCE REQUIREMENTS PMAGEMENT STATE'4ENT This Quality Assurance Manual describes Quality Assurance Recui a -
ments for the design and construction of Supoly System Nuclear I
Power Plants.
The manual meets the a;:pifcable requirements in Appendix 3 e
of 10CFR50 and meets the "0wner" requirements of the ASME code for ccnstruction of Class 1, 2, 3, and MC cc ponents, including piping systems, which are fabricated and installed at various field sites by contractors.
This CA Manual is official Supply System policy. Adherence e
to 1:s requirements, criteria and guidance is candatory f:r personnel and organiv:fons per#cming quality affecting activities during Design and Construction of Nuclear Pcwer Generating Plants. All Supply System personnel perfoming n
quality affecting activities descHbed in this manual are responsible for implementing the requirements.
o The Direc:Or cf Quality Assurance has the authority and l
organizational freedom to assure that the requirements are i
i me: and to; icentify quality problems, initiate ac:fon o solve quality problems, recommend and/or provice solutions, verify icolementation of solutions, con:rol ins allation of non-cenfaming items, control further processing of a detected deficiency or the continuation of an unsatis-factory work condition and s p work for quality reasons.
I fully support the requirements described in this manual and acknowledge the respcnsibility for enforcing :.9em.
f ll
?ba5i
-;..J Managin rector
'Date n
- 4ASHIMT03 FU3LIC PC'4ER SUPPLY SYSTE4 SUPPLY SYSTI4 MANAGDII'IT STAT ~E;T g
A
'4??SS NUCLEAR PROJECT NO. ]/h (TAFIN FRCM QUALITY ASSURANCI.%U:UAL)
Preli=ir.ary Safety Analysis Repor*.
i l
7 3 & l-1 I
1 i
j WNP-1 A=endment 10 PSAR September 1974
.g,
- 0
- .
~
17.2 QUALITY ASSUFx;CE DURING' DESIGN AND CONSTRUCTION UNITED ENGINEERS & CONSTRUCTORS (AP.C91TECT-ENGINEERING OA)
Secoe: This sectica su=arizes the Ec=e Office and Vendor Surveillance activities of the United Engineers and Constructors Quality Assurance Program as it pertains to the WNP-1 project. UE&C Reliability and Quality Assurance Department has been assigned the responsibility by WPPSS to l
provide Quality Assurance program which meets or exceeds 10CFR50, Appendix 3 and ANSI N45.2-19 71 requirenants. This section coordinates that portion of the total Quality Assurance program for the project with respect to the design, procurement and fabrication of WNP-1 equipment. The terms
" Vendor" and " Contractor" as used throughout this section are interchangeable ' ecause of the connotation that UE&C Vendor Surveillance activity will be conducted in the shops of " Vendors" and " Contractors".
Except where indicated, the terms " Vendors" and " Contractors" excludes the NSSS supplier whose quality assurance program is described in Se.ction 17.3.
1 17.2.1 Organization
- ' '.1.1 Engineerine Funetien Tne ULEC Power Division, headed by the Vice President <- Power Generation, is responsible for the design and engineering of nuclear power plants.
The Vice President - Power Generation, assigns a project manager to lead the UE&C effort for the WNP-1 Project and the Pcwer Generation - Engineering Depart =ent supplies the engineering manpower required for its design.
The control of quality-related activities affecting the design and engineering, is p'erformed in accordance with the Power Division procedures uhich are approved by' the Vice President - Power Generation and the Manager
- REQA.
Any UE&C Power Divisien department supplying services to the Pewer Generation Engineering Department will perform their work in accordance with the procedures of the Power Division. Work performed by the Power Generation Engineering Department is further controlled via compliance with detailed engineering and QA procedures, which is subject to audits performed by R&QA. The Corporate Organization Chart, Figure 17.2-1 shows this organizational structure.
17.2.1.2 Purchasing Function The Manager - Purchasing reports through the Manager - Project Supporting Services to the Vice President - Administration and is responsible for procure =ent of equipment to requirements specified by the UE&C Power Division.
~
. rucurement activity en this project provides for the coc=ercial evaluation
- t s'.1 bid packages and includes contract administration and expediting and is Q.$ performed in accordance with good procurement practices written into che contract e
specificatiens. Contract administration and expediting performed by the Purchasing &
Depart =ent is controlled through a system of audits by R&QA.
17.2-1
prp 1 A=end:ent 10 PSAR September 1974
?
I: is i=pertant to note tha :he Purchasing Depart =ent cannet vaive er change any engineering or QA require =ent or allow one to be changed without the prior approval of Power Generation Engineering and R&QA.
Further, the expediting group ha: no inspection responsibility or authority and cannot waive inspection or vitness points or release equipment for shipecnt without R&QA approval.
17.2.1.3 Cons truction Function The UE&C Cons tructf en Divisien, headed oy the Vice President - Cons truction, is responsible for providing Construction Manage =ent for building nuclear power plants, The Vice ? resident - Construction, assigns a Construction Manager, in the home office, and a Resident Construction Manager, on the site, to lead the UE&C construction management effort for the WhP-1 Project.
Supervision of the work force on the project site is handled throu,. Area and Craf t Coordinators.
Tcrk ;erferred by the Construction Department is controlled via a sys tem of surveillance, audit, inspection, test and examination, by R&QA as
[._
~'
described in other sections of this PSAR and in the UE&C QA procedures ranual for RNP-1.
Typical UE&C field QA/QC organization chart and interfaces with construction management are depicted in Figure 17.2-2 and 17.4-1,
- 17. 2. D'~5Ilali ty Assurance Function The respcasibility for Quality Assurance within UE&C res ts with the Vice President - Ad=inis tration.
The Vice President - Adminis tration is en an organizational level with the Vice President - Power Generation and the Vice Pre,sident - Construction, all reporting to the President as shown en the corporate organization chart, Figure 17.2-1.
The Manager - Reliability & Quality Assurance reports directly to the Vice President - Administration and has been delegated full 1 sponsibility for the tc::1 quality assurance activi:y wi:hin UESC which includes the es:ablish-nsnt, direction and management of the QA program vn the project. The Manager -
R&QA is also responsible for the final reviev and approval of the prcgram and has sufficient authority and organizational freedom to:
a)
Identify quality proble=s.
10 b)
Ini:iate, reco= mend or provide solutions through designated channels.
~
2 17.2-2
'r:NP-1 A=end:en* 20 PSAR Septe=ber 1974 c)
Verify i=ple=entation of.olucions.
d)
Control further processing or delivery of nonconforming articles cr deficien: conditions until satisfactory dispositions are =ade.
A manage =ent stata=ent by the UE&C compan'y President in the UI&C corporate te QA =anual, instrue:s all UI&C organi:ation and persennel to adhere.to the UE&C QA policies and procedures. A sta:e=en: by the "anager R&QA in the project QA procedures =anual imposes a similar requirement to the responsible project disciplines and individuals. The Manager, R&QA repor:s to the Vice President, Administration as shown on the Corporation Organization Chart Figure 17.2-1 and suppor:s the WNP-1 Project Manager by developing, i=ple=enting and =anaging the Quality Assurance Program.
In this wa'y, the R&QA Depart =ent maintains a direct and separate co==unication channeJ to higher canagement which is not directly responsible for the design effort.
2 The qualification requirements imposed for :he =anager R&QA are:
1.
Education - A graduate Engineer with a Professional Registration er eligible and capable of being registered.
~
Ixperience - A =inimum of ten (10) years of Quality Assurance experience in the Nuclear, heavy construe:1on or heavy equip =ent indus: ries. Mini =um experience require =ents =ay be reduced by:
a.
One year for each year of direct experience within the UE&C R&QA department.
b.
One year for each year of direct experience in Quality Assurance and Control on a nuclear pcwer project.
c.
One year for each year of direct experience in nuclear power plan: design engineering.
d.
One half year for each year of direct experience in nuclear power plant construe: ion supervision or job engineering.
8 Extensive previous experience in Reliability has alloued the Manager of Reliability and Quality Assurance to establish UILC's depart =ent with a l
dual fune: ion.
One objective of this dual func: ion is to evaluate'the l
state of the art (Reliability) in the Power Industry. The " Reliability" l
portion of the R&QA charter has been devoted to li:erature searching and study of reliability-oriented activi:ies elsewhere in industry and in i
)
providing co==unication :o :he company on these activities. No employee of the function has any significant co=mitments to support the Reliability i
function.
Tt is esti=ated that more than 95% of RE0A's activities are g
devoted :o developing and i=plementing Quality Assurance Progra: responsive
,7(;
to 10CFR50, Appendix 3 and N45.2.
7 i
17.2-3 1
WNP-1 Amend =ent 8 PSAR July 1974 59.
4 The organizational relationship of Reliability and Quality Assurance with other UI&C functions is shown in Figure 17.2-2.
5 Table 17.2-2 su=narizes the interface between WFPSS and UE&C as related to T.1e various QA progrs= activities. This chart presents those significant interactions between UE&C and WPPSS as related to pertinent design, manufacturing and installation QA activities which are described throughout the revised Chapter 17 of the PSAR.
Tha R&QA function is Occposed of personnel who are experienced in the dsvelop=ent and implementation of Quality Assurance Progra=s for Nuclear 4
Power Plants. The functions major divisions, which are applied to the l
WNP-1, are as follows:
4 1
7 4
e
.7 -
l l
l l
l l
i
.n=
l l
t i
i' 17.2-3 (a)
L
wNP-1 A=endment 10 PSAR Septe:ber 1974
,yu n)
Plan and' coordinate surveillance of the NSS Contractor and their l
equipment suppliers, b
17.2.1.4.2 Vender Surveillance The Vendor Surveillance Group under the direction of a Supervising Engineer who reports to the Manager P.&QA through the Manager Quality Services directs GIO personnel assigned t; surveillance functions at Vendor and Contractor off-site shops. This function is conducted primarily as a surveillance action of man-ufacturers' quality control and inspection programs. In addition.- the Vendor Sutveillance representatives witness shop tests and inspect equipment to the extent designated on the check plans prepared by Quality Engineering.
The Vendor Surveillance Supervising Engineer works with the QAE in natters relating to liaison and coordination for the. projects' purchased equipment.
g The principal responsibilitics of the Vendor Surveillance Group include:
l g) 6 a)
Perform facility surveys at prosocctive Vendors' and Contractors' plants, if required by the project.
6 b)
Coordinate scheduling with Vendor, Contractor (for off-site l
vork) and Washington Public Power Supply System representatives, g
fer perfor ance of surveillance check points identified en the surveillance check plan.
c)
Cenduct surveillance of Vendors and Contractors (for off-site l
work), including NSSS, prepare inspection reports on the results g
of the. surveillance actions and distribute reports.
17.2.1.4.3 Welding Eneineerinc
'?alding Engineering, under the direction of a Supervising Engineer who l
reports to the Manager R&QA through the Manager Quality Services, consists 6
of personnel with experience in all forms of welding including the writing 3
and qualification of procedures and qualification of p2rsonnel. The principal responsibilities of the Walding Group are the following:
l e
s a)
Review and approve Vendor and Contractor submitted welding
~
procedures and their qualification records.
b)
Conduct training sescAons, administer tests and qualify UE&C personnel for welding evaluatien.
c)
Censult with UE&C Engineering in =acters relating to welding requirenents in drawings and specifications.
d)
Provide assistance and guidance to Vendors and Contractors
=atters of welding techniques and procedures.
"t.
2.
t=:=
%:s 17.2-5
WNP. 1 Amendmen t 8 PSAR July 197t.
(*f.
17.2.1.4.4 Audits I
rne Audits Group under the direction of a Manager who reports to the 0
Manager R&QA, is composed of personnel with experience in the area of planning eind conducting various types of audits. The duties of the Auditing Group are as follows:
a)
Plan, develop and implement UE&C's Quality Auditing procedures.
b)
Schedule audits in coordination with the QAE.
4 c)
Conduct project internal audits.
d)
Conduct Vendor and Contractor off-site audits and coordita.e 0
facility surveys with the Vendor Surveillance Group.
e)
Document and dis tribute report of findings and observations.
f)
Conduct follow-up audits verifying corrective action.
g)
Coordinat' QA requirements of AEC regulations, codes and scandards.
17.2.1.4.5 Ncndestructive Examinaqton l
30 The Nondes truc tive Examination (NDE) Group, under the direction of a g-Supervising Engineer, who reports to the Manager R&QA through the Manager Quality Services, consists of personnel with experience in all forms of NDE including preparation of procedures and qualification of personnel.
In addition, the group has MDE examiners who are qualified to Level III in acc3 4nce with ASNI-TC-1A.
The principal duties of the NDE Group are d
as follows:
a)
Es tablish and approve me thods and procedures, testing and certifying of UE&C NDE personne'..
I Conduct training sessions on NDE.
c)
Assist in selection of Field NDE personnel.
d)
Review Vendor and Contractor procedures, facilities and personnel, e)
Provide evaluation and disposition of NDE problems.
17.2.1.4.6 Materials Engineering Tae Materials Engineering Group, under the direction of a Manager who b$
ra--m *o the Manager R&QA. consists of Engineers with expertise in cani"_urr;, corrosion, non -ce tallics, coatings and welding. This group g
essists in selecting materials for new applications and assists the QAE 4
2 17.2-5(a)
!?NP-1 Arendment 8 PSAR July 1974
,90 in solving inspecticus report proble=s and perfor=ing audits of metallurgical procedures and controls. In addition, the Materials Engi$eering Group has these major duties:
a)
Provide liaison with major =aterial and cc=penent suppliers.
b)
Review contract specifications.
l c)
Review design ecdificati:ns material application.
d)
Evaluate new caterials and processes.
I e)
Review Vendor and Centractor procedures including cleaning and heat treatment procedures.
f)
Investigate component failures and review repair procedures.
g)
Maintain alloy and material application files.
17.2.1.4.7 Field Ouality Assurance Field Superintendent QA reports to the Supervising Engineer - Field QA 8
who is located in the home office.
The Field Quality Assurance organi:aticn including its resp:nsibilities will be discussed in Paragraph 17.1.1.
y The qualification requirements impesed for the Manager R&QA are:
i 1.
Education - A graduate Engineer with a Professional Regi;tration or eligible and capable of being registered.
2.
Experience - A minimum of ten (10) years of Quality Assurance experience in :he Nuclear, heavy cons tructicn or heavy equipment indust:ies.
"'-4-"-
experience requirenents may be reduced by:
a.
One year for r:a-h year of direct experience within the UE&C R&QA department.
F.
One year for each year of direct experience in Quality Assurance and Control on a nuclear power project.
c.
One year fer each year of direct experience in nuclear p:ver plant design engineering.
d.
One half year for each year of direct experience in nuclear power plant construction supervision of job engineering.
2 4
.l4_.
.g 17.2-5(b) a
a WNP-1 Amend =cnt 8 i
PSAR July 1974
/.E. M
]
17.2.2 Quality Assurance Program 17.2.2.1 Introduction The Quality Assurance and Quality Control activities performed on WPPSS Nuclear Project No. 1 (WNP-1) are under the control of or are subject to audit by the Reliability and Quality Assurance Department (R&QA). The department has authority and organizational freedom to identify quality problems; to initiate, reco=cend or provide solutions; and to verify implementation of solutions independent of individuals or groups directly respcesible for performing a specific activity. UE&C's. Quality Assurance p re g
's ec= plies with the AE2 Regulatory Guidas positions as described in 3.12, and the applicable requirements of 10CFR50, Appendix B, the AEC Grey Book, and the ANSI Standards contained in 17.1.2.
The basic elements E
of ce=pliance are described under 17.2.2.2.
A cross index of UE&C Procedures and the 18 Point Criteria is shewn in Table 17.2-1.
The structures, systems and co=ponents to be covered by the UE&C QA program are those designated as WPPSS Quality Class I in Table 3.2-2.
1 l
17.2.2.2 Response to AEC Criteria a)
Organization The Reliability & Quality Assurance Department is responsible for assuring that the QA program established for this project co= plies with regulatory and specific proj ect requirements and that the i
progra= is properly inplemented. The R&QA Department carries out tr-the QA program as defined in Paragraph 17.2.1 which ouclines the structure and responsibilities of the R&QA organization and its relationship with other corporate departments. Paragraph 17.2.1 also defines the depart =ent's organizational freedom and indepen-
__,,_;. dance for identifying quality proble=s, including effecting resolu-
~
tions and verifying that the solution has been implemented.
b)
Quality Assurance Program The QA program established for WNP-1 consists of specific Project
- QA Procedures approved by WPPSS and defined in this Section (17.2.2) of the PSAR.
c)
Design Control Quality Asse ance Procedures define the actions of the Engineering Department and R&QA to assure the application of eequired design basis, Codes and Standards into the specifications. Through a planned system of reviews and audits, and the use of a " Unit Control" form, these actions will provide measures of assurance f or compliance.
Design changes (Engineering, Vendor or Field), will be subject to the sa=e design control measure as are the original specification requirements.
__Wm 17.2-6
_-r,
WNP-1 Amendment 2 PSAR January 1974
@C?
d)
Procure =ent Document Control
=-
UE5C Engineering Designe are translated into WNP-1 procurement require =ents pri=arily by =eans of specifications and drawings.
Tha Engineering Design require =ents, regulatory requirenents, quality require =ents and any other require =ents which are necessary to en-sure adequate product conformance are specified and referenced in the Contract Specification for =aterials, equip =ent and services.
The control over input, review and approval of Quality Control and Quality Assurance require =ents set forth in procure =ent specifica-tions and approved design drawings is =aintained through procedures centai=ed in the t= sic UE C =cnua"c.
e)
Instructions, Procedures and Drawings UE&C's quality-related activities on the WNP-1 project are perfor=ed in accordance with the WNP-1 proj ect Quality Assurance Procedures Manual as described in 17.2.2.
This QA =anual defines the technical, ad=inistrative and quality-related inputs to docu=ents affecting the quality of WPPSS designated Quality Class I structures, syste=s
~
and ce=ponents. Appropriate qualitative and quantitative acceptance criteria for determing that quality-related activities have been satisfactorily accc=plished are contained in contract specifications, precedures, drawings and other apprcpriate decu=ents.
f)
Document Control Written instructions and procedures for i=plenenting document centrol =easures are contained in the UE&C Quality Assurance Procedures Manual, Vendors and Contractors Quality Control Manuals and Prepurchased and Cons truction Equip =ent Specifications. These
r ? '
instructions and procedures control the issuing oi docu=ents such e
as specifications and drewings, including authorized changes, and assure that the docu=ents and revisions are reviewed for adequacy j
and approved for release by authorized personnel.
g)
Control of Purchased Material Eculp=ent and Services The Quality of purchased =aterial equip =ent and services is I
controlled through review of sub=itted Vendor and Contractor QA l
prograss, data and drawings, progressive surveillance at vendors' shops, audits, witnessing of tests and site receiving inspections (17.4. 7). Pre-award evaluation of Prospective Contractors and Post-award evaluation of successful bidders are conducted to j
assure co=plianca with Contract require =ents.
Vendors and Contractors will be required to show evidence of their ability to satisfy all QA require =ents of the contract to be awarded. UE&C QA and Engi-neering depart =ent personnel will assist WPPSS in reviewing the bids to deter =ine the acceptability of the bidders QA progra=.
a:"
M.
m..
2.
~
17.2-7 i
I WNP-1 Amendment 2 PSAR January 1974 i
55h
[
[qgiF=
h)
Identification and Control of Materials, Parts & Components 1
UE&C drawings and specifications include requirements for the indentification of ma'erials, parts and cceponents, which directs the supplier of WNP-1 safety related equip =ent to provide a system to assure that these items incorporated into the plant are properly I
identified and traceable to all supporting quality assurance docu=entation. Vendor and Contractor identification procedures will be established, maintained and audited to assure implementation.
1)
Centrol of Special Processes UE&C will not be required to perform any special processes, but will i= hose applicable requirements on Vendors and Contractors, of WNP-1 equipment and services. These special processes include velding, cleaning, repairing, heat treating, nondestructive testing and other processes which affect the quality of a nuclear or engineering safeguard structure system or component during fabrica-tion, manufacturing, installation and construction activities.
UE&C's procurement documents require Vendors and Contractors to control these special processes in accordance with UE&C processing requirements, appropriate codes and s tandards. Vendors and Contrac-tors will be required to sub=it written procedures and records of
?rocess and Personnel qualification for UE&C approval prior to use cf the process.
j)
Inspection The Quality Assurance program of UE&C, requires participating Vendors and Contractors to provide for a controlled system of inspection of =aterials, parts, components and equip =ent associated with the NN?- 1 proj ect. Written and UELC approved procedures provide for this control to assure that the =aterials purchased are f abricated, tes ted and delivered in confor=ance with specification and contract require =ents.
(S ection 17.2.10).
k)
Test Control A program of testing during Vendor and Contractor plant activity will be performed in accordance with a pre-established approved contractor procedure or program based on contract specification requirements, and the results will be fully docu=ented. These activities will be subject to surveillance and audit by REQA for assurance that the test results meet contract specification pre-requisites and the approved test procedure requirements.
l l
l i$h 17.2-8 l
n o
WNP-1
.dend ent 3 PSAR March 1974 00~
1)
Control of Measurement and Test Ecuioment Vendor and Contractor QA programs will establish and provide for the syste=atic control over the calibration, use, recall and recalibration of test equipment used in their plant operations.
Vendors and Contractors will be required by the procurement docu-mants to provide these calibration control measures within their quality control system with calibrations performed against standards of known accuracy, which will be subject to audit and surveillance by UE&C R&QA personnel.
3 c)
Handling, Storage and Shipping Vendors and contractors providing equipment will i=ple ent an approved program detailing the requirements for handling, storing, cleanliness, preservation and shipping of their equipment. Any special requirements for handling and storage of the equipment af ter receiving at the site will be contained in UE&C contract specifica-tions. The Vendor will be required to furnish approved instructions for protection of his equipment.
n)
Inspection, Tes t and Operating Status The UE&C Quality Assurance Program provides for procedures to be developed by vendors and contractors, compatible with UE&C, for indicating the status of tests and inspections perfor=ed at their m;_.
plants upon caterials, parts and co=ponents. The status of an item is indicated by means of tags and stamps to (a) preclude the inadvertent bypassing of their inspection and test requirements and to (b) prevent their inadvertent operatic'n.
o)
Nonconforming Materials. Parts or Co=conents The UE6C Quality Assurance Program provides that vendors and contractors are suppliers of WNP-1 equipment, establish and =ain-tain a system for controlling nonconforming material to preclude its use until it has been properly dispositioned. This syste= will I
be compatible with the UESC system of NCR control which will assure that vendor and UE&C. processing and activity procedure nonconfor:-
ances are identified, documented, segregated and dispositioned and l
that notification of the actions taken are transmitted to the affected parties. Provision is also made for implementation of UE&C program of Nonconformance activity.
p)
Corrective Action l
UE&C QA program provides for the use of available in pection and auditing procedures and UE&C vendor or contractor nonconfor=ance and disposition reports to identify and ob tain corrective action e
17.2-9 t
.-,m.,,.,
'4N P - 1 A=endment 5 PSAR April 1974 (f$
for conditions adverse to quality. Typical of these conditions are vendor quality program or procedural inadequacies, f ailures, mal-functions, deficiencies, deviaticas, defective =aterial and equip-cent and vendor nonconformance to specified requirements. A program q
of corrective action control is also implemented for UE&C Home F
Office Activity corrective action.
G q)
Ouality Assurance Records 1
The UE&C Quality Assurance program provides for drawings, contract.
specifications and procurecent documents to delineate ty7es of-Quality Assurance records that Vendors and Contractors etre r2 quired to prepare, maintain and submit for review and UE&C apsroval.. These records will be identifiable and retrievable and will provide the documentary evidence of quality. UE&C will caintain the WNP-1 Quality Assurance files for activities and items unt.er UE&C cognizance.
These files will be available for WPPSS review.
- )
Audits The Quality Assurance program for the WNP-1 project provides for planned and unplcnned periodic audits which.wil.', verify compliance with the applicable Manage =ent, Engineering, Pracurement and QA I
activities. The audit records of UILC internal practices effer
-'-~~
objective evidence of implementation of and compliance with require-ments, and consistency in the discharge of responsibilities.
17.2.2.3 Indoctrination and Training The UE&C Coordinator of Education and Trair;ing is responsible for preparing I
fer=alized programs for all personnel conoucting QA-related activities. These progr1Es"T,ver all QA-related activities between conceptual design and the cb cperational phase of a nuclear power generation plant.
i i
a) - Training of QA Engineering personnel is being implemented by their attendance at monthly one and one-half hour training sessions on QA and related subjects.
b)
Scheduled 2-day training sessions are held for _ UE&C QA Vendor Representatives in the home office for training in. discipline and i
related matters.
c)
Training sessions in QA' procedures, code regulations, the PSAR and QC procedures are in effect for the WPPSS project' management and technical team.
4 17.2.3 Desien Control UELC has standard company procedures which clearly define the control of design activities associated with saf ety related items. These procedures gffs
' define the scope, purpose, responsibilities and step-by-step procedures
\\i.
s l
17.2-10 2.
WNP-1 A=andment 4 PSAR March 1071-l5==:
a utilized in the preparation, revie', approval and centrol of design docu=ents, such as specifications, drawings, procedures and instructions, including changes thereto. These control measures are utill:ed to ensure that the gral'ity requirements are sufficiently, clearly, and accurately stated in the docu=ents prior to their release, and to ensure that the applicable tegulatory requirements and design bases are correctly translated into these documents.
Deviations and changes from the appropriate quality requirements are controlled by the review actions outlined in the UE&C proceddres.
In order to ensure that suitable design analyses, such as physics, stress, caterials, thermal, hydraulic, radiation and accident, are perfor=ed where applicable, check lists are provided for document revie:7 These check lists are initialed and dated by the reviewers, indicating incorporatien cf applicable design analyses.
L O
/==
O,
=
17.2-10(a)
~.
i WNP-1 A=endnent S PSAR July 197-S?t E
17.2.3.1 Design Control Procedures l
The CE&C procedures contain provisions and responsibilities for monitoring internal disciplines and external organizations to ensure that the design work and procedures described therein are being i=plemented, and to ensure proper interface between internal disciplines and external organizations.
In order to ensure that proper selection and accomplishment of design veri-fication metheds, such as design reviews, alternste calculations and qualifi-cation tasting, are performed, the UELC procedures contain provisions for the extent of, and responsibility for, design verification. The depth and degree
-: review is established by UE&C project engineering =anagement. The indivi-duals or groups responsible for the design verification are other than those who performed the original design, and who are designated as being qualified by UE&C Proj ect Engineering management.
Changes and/or revisions to the design documents are covered by the UE&C procedures. These procedures require the same review and approval for changes and/or revisions as the original document. These reviews and approvals are performed by the same organizations that performed the original tasks, or delegated to another responsible organization by the design originator.
The UE&C procedures contain steps to ensure that approved design documents, and revisions or changes thereto, are distributed to responsible individuals in a ti=ely manner and that obsolete docu=ents are purged from the system.
Control of.the design docu=ents will be in accordance with Section 17.2.6.
17.2.3.2 Design Control Verification.
In order to ensure that measures are provided describing when and how errors and deficiencies in the design process are documented and dispositioned, and j
how corrective actions are deter =.'.ned and implemented, the UE&C procedures l
require all safety related ite=s to undergo an independent design review.
The result of the design review effort is clearly documented.
Where applicable, the report of the design review is resolved by the respon-sible Discipline Supervising Engineer to the satisfaction of UE&C Project Engineering management, and the report is amended to record the resolution, and filed in a controlled area for future reference, a
i A comprehensive system of planned and documented audits is utiliced on all phases of tLe design process by UE&C in accordance with Section 17.2.18.
Audits are also conducted by WPPSS QA, a qualified unit independent of the design organization, in accordance with Section 17.1.18.
Design docu=ents, records and changes thereto are collected, stored and main-tained in a systematic and controlled manner in accordance with the provisions of the UE&C standard company procedures.
57.
(ig b
17.2-11
.. ~
WNP-1 A=end=ent S PSAR July 1974 17.2.4 Procure =ent Document Control 5
UESC Engineering Designs are translated into WNP-1 procure =ent require =ents 4.is primarily by means of specifications. and drawings. The Engineering Design requireuents, regulatory require =ents, quality require =ents and any other require =e.its which are necessary to ensure adequate product confor=ance are specified or referenced in the Contract Specification for materials, equipment and services. The control over input, review and approval of Quality Assur-ance requirements set forth in procurement specifications and approved design drawings is maintained through procedures contained in the basic'UE&C =anuale.
17.2.4.1 Procurement Soecifica* ions a)
UE&C co=pany standard procedures, in addition to the WNP-1 Project Manual of Procedures and The WNP-1 Quality Assurance Procedures Manual, clearly define the basic control of procurement docu=ents associated with Quality Class I items. These procedures collectively provide co=pliance with ANSI N45.2.13 (May 1973), " Supple =entary QA Require =ents for Control of Procure =ent of Equipment, tiacerial and Services for Nuclen: Power Plants" for procurement actions as well as the procurement documents themselves.
b)
WNP-1 purchased equipment contract specifications, provide the technical, Quality Assurance, processing and administrative re-quirements as individual sections, each of which are reviewed, approved and centrolled in accordance with an established UE&C precedure.
1)
The Technical Sections of the Contract Specifications are V-~
developed and controlled by UE&C Engineering which then beco=e the central section from which the Contract Specification is developed.
I 2)
The Vendor and Contractor Quality Assurance requirements
~~"~I are developed and controlled by UE&C Reliability and Quality Assurance, and are made part of the Contract l
Specification by being inserted into the various technical l
and ad=inistrative sections. Accuracy requirements and provisions for review, filing, maintenance, examination I
and access of QA records for purchased equipment and services are specified in Section 13 of the Procure =ent Contract Specification and detailed in Technical Section 52A of the Procurement Contract Specification. ~their QA Provisions for requiring vendor and Contractors to submit Records Program including applicable procedures for the review and approval of QA records are also specified in the appropriate Technical Section of the Pracurement Contract Specifiertion. The basic QA require =ents sections are sent to WPPSS for review and concurrence prior to their use in a contract specification.
3)
Soecial orocessing recuire=ents are developed and controlled 1
by the Quality Assurance " Technical Support" personnel fl" of the R&QA Department. These requirements prcvide QA 1.
technical inputs to the design and fabrication cf WNP-1 equip =ent, and are reviewed and approved by UE&C and WPPSS in accordance with UE&C procedures.
2 17.2-12
WNP-1 A=end=ent 8 PSAR July 1974
- =.
f
~"
c)
The Procure =ent Quality Control and Quality Assurance require =ents 3
are made part of the Contract specifications and the process procedures with the review and approval of Quality Class I Equip =ent and Ccntract Specifications being perfer=ad by QA personnel in the Reliability and Quality Assurance depart =ent.
Af ter review and approva", the signature of the UE&C Quality Assurance l
Engineer for WNP-1 on an internal Memo and Document Review Form E
provides the approval release by the R&QA department. Revisions and addenda to these Specifications are reviewed and approved by l
the R&QA department in the same =anner as the original docu=ents.
d)
Figure 17.2-3 is a typical flow chart which depicts the development, l
flow and approval cycle of WNP-1 Contract Specifications by UE&C.
3 Subsequent to the final resolution of UE&C and WPPSS co=nents, the Contract Specification is submitted to WPPSS for final review and approval, af ter which UE&C distributes and releases the Specification for bids.
17.2.5 Instructions, Procedures and Drawings UE&C's quality-related activities on the WJP-1 project are perfor=ed in accordance with the UNP-1 Qualit: Assurance Procedures Manual as dese 1 bed in Subsectica 17.2.2.
This =anual provides procedures which describe the technical, administrative and quality-related inputs to these documents affecting the quality of WPPSS designated Quality Class I structures, systens and components.
Appropriate qualitative and quantitative acceptance criteria for deter =ining that quality-related activities have been satisfactorily acce=plished are con-tained in specifications, procedures,. drawings and other appropriate documents.
17.2.5.1 Procedures a)
"Proiect Manual of Procedures" is a document of written procedures issued and controlled by UE&C Project Management for the WNP-1 project which defines the scope of Engineering :nd Design work, i
responsible organizations and administrative practices such as correspondence exchange procedure, cost control, planning and scheduling procedure, docu=ent identification procedure, etc.
The Project Manual of Procedures co=ple=ent the QA Procedures Manual by detailing those administrative procedures specified in the QA Pro-cedures Manual as being critical in the implementation of quality-related activities on the project. The =anual is a controlled document incorporating procedures which are distributed, reviewed, co=mented on, approved, issued and revised in accordance with an approved UE&C Procedure. Distribution is in accordance with an established distribution list under the control of the UE&C Project Engineering Department.
1
..g[:.
17.2-13 y
WNP-1 A=end=ent 8 PSAR July 1974
.e-k:
.ua b)
Quality Assurance Procedures.Vanual is a docu=ent of written Procedures issued and controlled by UE&C Quality Assurance for the WNP-1 Project which addresses itself to assuring that the WNP-1 project is engineered, designed, procured, fabricated, =anufactured, installed, erected, ccnstructed, and tested in a safe, reliable and efficient manner. The QA procedures have been. developed to corres-pond to the criteria of 10CFR50 - Appendix B and the applicable sections of ANSI N45.2 and detail the* UE&C effort to establish and control the quality-related activities of Vendors, Contractors, UE&C Construction Management, UE&C Engineering, UE&C Purchasing, UE&C Project Management and UE&C Quality Assurance. The QA Proce-dures are developed by UE&C Quality Engineering with support and assistance by specialists within the Reliability & Quality S
i Assurance Department. Past practices, regulatory require-cents, sefety analysis reports requirements and UE&C Corporate Standards are used in the procedure development. The QA written procedur i are distributed, reviewed, co= ment on, approved, issued and revised in accordance with an approved UE&C procedure. Distri-bution of these QA procedures is in accordance with an estiblished dis tributien list under the control of the UE&C Reliability &
Quality Assurance Department.
I 17.2.5.2 Drawines a
a)
UESC issued drawings for WPPSS designated equipment are developed,
'~
issued, reviewed, approved and revised in accordance with detailed written procedures outlined in the UE&C WNP-1 Project Manual of Procedures (17.2.5.1.a).
R&QA drawing review and approval of Quality Class I equipment provides additional assurance that the equipment can be manufactured to' the specificatiens and also provides assistance
-==-To Engineering in translating the marketing requirements of the applicable equipment into drawings of ecu1prent that can be quality f ab ricated. Vendor, Contractor and NSSS Supplier drawings submittals l
are also reviewed, distributed and co==ented on in accordance with detailed written procedures as outlined in the UE&C Project Manual of Procedures, with UE&C R&QA Department in the sequence of review. The l
R'QA Department ensures, by their review, that the drawings contain, as i
a =ini=u=, the necessary conformance limits, the effective methcds of identification of the item, reference to appropriate process specifications which detail adequate inspection and. test cethods and those necessary characteristics determined te influen'ce quality.
i 17.2.5.3 Safety Analysis Report l
l a)
The Safety Analysis Report for WNP-1 is the principal controlled l
document which provides information needed to understand the basis l
for constructing and operating the WNP-1 plant safely and efficiently.
l
~
f$2:-
2 t
l 17.2-14 c
-,.,.,,....--e, y..-
n,,-
-y
WNP-1 Arend:ent 8 PSAR July 1974
- 5=-
"~'
As part of the total quality assurance program, the internal review, submittal and i=plementation of a=end=ents and changes to the Preliminary and Final Safety Analysis Report for WNP-1 are in accordance with detailed written procedures contained in the 7::P-1 Proj ect Man.ual of Procedures. CELC Licensing and Environ = ental Section personnel coordinate the documenting, reviewing, processing, distribution and submission of amendments and changes to these Safety Analysis Reports.
17.2.5.4 S af a t.* ?alated Documents a)
"Ato ic Energy Regulatory Guides" are maintained and distributed l
throughout UE&C in accordance with an approved UE&C written proce-3 dure by UE&C Licensing and Environmental Section personnel. The i= pact of each regulatory guide, on the WNP-1 Project, is considered by UE&C technical disciplines as it affects the design, fabrication, construction and testing of the equipment.
b)
" Reactor and Construction Operating Experiences" published by. the AEC are maintained and distributed in the same manner as AEC Regula-l tory Guides per 17.2.5.4.a.
The review and consideration of occur-3 ences during operation of other reactors, as they impact the WNP-1.
Proj ect, is considered by CE&C Engineering in accordance with written procedures as defined by the UE&C Licensing and Enviren= ental Section.
17.2.6 Document Control Written instructions and procedures for i=ple=enting Jocument control measures are contained in the following project documents as used on the WNP-1 program:
, UE&C WNP-1 Quality Assurance Procedures Manual UELC Project Manual of Procedures Vendors and Contractors Quality Control Manual
. Pre-purchased Equipment Contract Specifications Construction Contract Specifications These inJtructions and procedures control the issuing of documents such as specifications and drawings, including authori:ed changes, and assure that the documents and revisions are reviewed for adequacy and approved for release i
by authorized personnel.
17.2.6.1 Contract Specifications i
a)
UE&C standard co=pany and project procedures clearly define the l
control of WNP-1 Contract Specifications associated with safety i
.9?9 releted items.
.==-
I l
17.2-15 1.
i WN?- 1 A=end=ent 8 PSAR July 1974 h
':..~
Thes e control =easures assure that the quality require =ents are
~
sufficiently, clearly and accurately stated in the specifications prior to their release and that they are distributed in accordance with the approved procedure. Revisions and/or changes to the Specifications are covered by the UE&C procedures and will undergo the same reviews and approvals as the original document, with these being perfor=ed by the sa=e organization that perfor=ed the original tasks.
Obsolete specifications are identified as such, with ins tructions of "not to use" or " destroy" being issued.
17.2.6.2 Drawings a)
UE&C drawings, including revisions thereto, are prepared and control-led by UE&C Engineering and are reviewed, and approved in accordance with procedures outlined in the Project Manual of procedures.
Similar procedures govern the review of Vendors and Contractors drawings and revisions to assure compliance with specification requirements, b)
Approved modifications th drawings are documented in schedules and lis ting which.are updated and reviewed =enthly to identify current revisions. Design changes incorporated into drawings by the cognizant Design Engineer will be reviewed and approved in the sa:e manner as the original issue.
17.2.6.3 Quality Assurance Procedures u-a)
Quality Assurance Procedures are prepared and controlled by the Reliability and Quality Assurance department and are reviewed and approved in accordance with procedures outlined in the UE&C WNP-1 Quality Assurance Procedures Manual. The procedure defines the review, approval and control cycle of the QA procedures including hanges and revisions thereto and ensures that all recipienr.s have the latest applicable revision.
b)
All users of the QA procedures are required to destroy obsolete procedures. Internal ccepliance with these require =ents is =easured by the UE&C Quality Assurance Audit section through internal audits conducted in accordance with Sub Section 17.2.18.
17.2.6.4 Vendors and Contractor Submittals a)
Vendor and Contractor, including NSSS, documentation submittals are received, processed, distributed and coordinated by the UESC Engineer-ing department. Appropriate documents tulevant to QA are distributed to the UE&C WNP-1 Quality Assurance Engineer and other UE&C Techni-l cal Specialists to review for conformance to the QA require =ents of 3
applicable contract specifications, codes and standards.
n, 1
17.2-16
WNP-1 A=endment 8 PSAR July 1974 jh.
UE&C Engineering collects all generated co==ents, evaluates and consolidates th,t= and trans=its them to the Vendor or Centractor. Problem areas developed by the co==ents are resolved between Engineering and the co==entor priot transmission to the Vendor.
17.2.6.5 Document Files a)
The UE&C Project Engineering department maintains the Project document file which includes the copies of the latest revision of UE&C and Vendor originated drawings, specification and procedures.
In addition, each Engineering Discipline maintaiur their own document file which includes the originals of their issued drawings, calculations and specification. A master file index is used to facilitate unifor=ity and 1 prove retrievability.
2 b)
The Reliability and Quality Assurance department maintains the Project Quality Assurance document file, copies of which will be transferred to the Site Quality Assurance Files concurrent with the equipment and contract specification requirements so that the docu=ent will be available for the onset of construction effort.
c)
Obsolete documents are controlled throughout the project by written ackaculedgement certifying that previous issues have been collected and destroyed, or by clearly =arking the original i
document as void.
Internal compliance with these require =ents is measured by QA Audits, d)
Project distrib? tion of incoming and outgoing documents is
-^**i ? "
concolled by Proj ect engineering. Dis tribution is noted by a-l stamp and copies are distributed to key project personnel.
Each category of document, e.g. transmittal letter, correspondence, drawings, foreign prints, proc 2dures, etc. has specified distribution list so that pertinent documents are directed and made available to the cognitant project personnel.
The project engineering group provides additional availability of these documents upon request.
e)
The central file index consists of primary categories relating to equipment, documentation, quality assurance and other i
disciplines, regulatory requirements and project information, etc.
This index is supplied to all supervisors, engin'eers, secretaries and administrators. Use of this index in conjunction with current released lists of specifications, drawings, foreign prints and other documentation, provides the latest status of the project definition.
E j
.=::
17 2-17
A=end:ent S
- .,7 3 1
July 1974 PSAR (5 -
sE=
f)
A General list of documents that are controlled by docu=ent centrol procedures is as follows:
Contract Specification Project Manual of Procedures Project Quality Assurance Procedures Manual Carperate Quality Assurance Manual Operations Manual - Power Engineering Design Review Reports Safety Analysis Reports Systems Descriptions Design Calculations Stress Reports Standard Technical Secticas (for Ocntract Specs.)
CISC Drawings Vendor and Contractor Submittals QA Procedures Regulatory Guides Reactor Operating Experiences QC Bulletins Internal Audits 1
17.2.7 Control of Purchased Material, Ecuio=ent and Services The Quality of purchased =sterial equipment and services is centolled through review of submitted Vendor and Contractor QA programs, data and drawings, progressive surveillance at vendors' shops, audits, witnessing of tests and site receiving inspection (17.4.7). Af ter the bid opening and prior to the award of a contract, Vendors and Contractors whose bids appear to be the lowest will be required to show evidence of their ability to satisfy all QA requirements of the contract to be awarded. UE&C QA and Engineering personnel will assist 'JPPSS in reviewing the bids to
(.~ '
determine the acceptability of the bidders QA program.
S l
1
- 17. 2-17 (a) l
i !
l t@TP-1 Amendnent 8 PSAR July 1974
- ..?.
t 17.2.7.1 PTa Ausrd Evaluation a)
UE&C Quality Assurance Engineering p< /sonnel are responsible for providing a Quality evaluation c prospective contractors l
based en the review of sub=it;.al docu=entation. After reviewing prospective vendor bin packages, UE&C Engineering and Quality f
Assurance review the submitted data on a technical and economic basis to determine compliance with contract specifict-ion and intended use. UE&C Quality Assurance evaluates the Vendors and Contractors responsiveness and ability to =eet the specified Quality requirenents.
2 i
J 4
I N
W i
i l
i l
,m l
- 17. 2-17 (b)
_,,,..y
..y.
,m
O W5?- 1 A=end ent 8 PSAR July 1974 a.
b..
b)
At the completion of the QA evaluatien, an evaluation report is submitted to the UE&C WNP-1 Project Engineering Manager in which is included QA recocmendations, and where appropriate, identification of those Venders and Contractors who are non-responsive to the bid do cumen ts.
17.2.7.2 Post-Award Evaluation a)
Af ter the award of the contract for WPPSS Quality Class I Equip =ent the Vendor oc Contractor QA program and procedures are sub=1tted for UESC approval in accordance with the applicable contract specification and ANSI N45.2, both documents assuring vendor and Contractor com-pliance with Appendix 3 of 10CFR50. The successful bidders programs are reviewed by UE&C Quality assurance personnel and the results of this review are transmitted by UE&C Engineering to WPPSS for eneir assessment prier to further procurement activities.
b)
Subsequent to receipt of the Contract Purchase Order, but prior to beginning of f abrication, the Vender or Contractor is required to identify their fabrication process steps including inspections and tests. From this and the Contract Specification, UE&C QA will identify the docu=entation requfre=ents and surveillance actions by utilizing Vendor and Contractor fabrication processes, appropriate eu; specifications, drawings, codes and standards. All surveillance reports are reviewed by UE&C QA and distributed to WPPSS and the WNP-1 Project Manager, i
17.2.7.3 Vender Surveillance Activities c)ec:UE&C Vendor Surveillance activities associated with caterial procure =ent control provide a surveillance function at the Vendor and Contractor off-site facilities, including NSSS, as a means of l
verifying that the requirements of the Contract Specification, purchase 8
docu=ents, approved Vendor procedures, and all specified codes and standards are being adhered to.
l b)
For pre purchased and contractor purchased equipment ready for shipnent, UE&C Vendor Surveillance personnel may perform a final inspection surveillance with the Vendor and Contracto.r inspection personnel in accordance with written procedures and check-off lists to verify the identity and conditions of the items and that the requirements of the procure =ent documents are cat.
1
.. u l
17.2-18 i
1
WNP-1 A=end:ent S PSAR July 1974
. :.L A " release" tag is applied which provides evidence to the site that the equipment has been released for ship =ent and that all surveillance activities have been satisf actorily co=pleted. Notificatien is then
=ade to UE&C Field Quality Ar.surance of the impending ship =ent.
c)
Typical UE&C Vendor and Contractor Surveillance and Audit Activity during the f abrication cycle is conducted in accordance with 17.2.17, to assure that the Vendor and Contractor co= ply with quality l
require =ents as defined in the Contract Procure =ent Docu=ents.
a 17.2.7.4 Receiving Inspection Vendor and Contractor receiving inspection is performed in accordance with 17.4.10.
17.2.8 Identificacion and Control of Materials, Parts & Cc=ponents UELC drawings and specifications include requirements for the identification of =aterials, parts and components, which directs the supplier of WNP-1 safety related equipment to provide a syste= to assure that these ite=s incorporated into the plant are properly, identified and traceable to all supporting quality assurance documentation.
17.2.5.1 Procure =ent Docu=ents The UILC procurement doc.u=ents specify that equipment suppliers (vendors cnd contractors) establish procedures which describe the identification and control of =aterials, parts and components. When implemented, the vendor and contractor progra= will provide traceability of all parts and =aterials used in a particular product configuration and will also exercise control over essential procedures, drawings and test docu=ents. UE&C procureuent documents also provide the vender and contractor with procedural docu=ents covering l
assential aspects involved in the identification and control progra=. These l
procedural docu=ents provide an integrated syste= to all vender and contractors for inple=enting a unifor= approach to nonconfor=ances, tagging, corrective action, and records to ensure that only specified =aterials are used through-out production and fabrication. Traceability will be maintained by the Vendor and Contractor by their quality related docu=entation or by a physical l
=arking system.
j 17.2.8.2 Procedure a)
Vendor and Contractor identification procedures will apply to l
production =aterials, bulk raw =aterials and parts and asse=blies i
at all stages of =anufacture fre= r'eceipt of purchased =cterial l
to shipment of the completed article.
b)
UE&C Vendor Surveillance personnel monitor the Vendor and Contractors
(
i=ple=entation of these procedures and verify that the identification syste= (i.e. tagging, sta=ps, =arkings, etc.) is correct.
ed.@$_
1 17.2-19
~
f I
j WNP-1 A: enc ent 3 PSAR March 1974
(?hk
#~
17.2.9 Control of Seecial Processes UESC is not' required to perform any special processes, but i= poses applicable require ents en Vendors and Contractors of WNP-1 equipment and services.
Thsse special processes include welding, cleaning, repairing, heat treating, nondestructive testias and other processes which affect the quality of a nuclear or engineering safeguard structure system or component during fabri-cation =anufacturing, installation and construction activities. UE&C's procurement docu=ents require Vendors and Contractors to control these special processes in accordance with UE&C processing requirements, appropriate codes and standards. Vendors and Contractors are required to submit written procedures and records cf qualification for UESC approval prior to use of the process.
17.2.9.1 Processing Recuire=ents Spacial processing require =ents documents for.the WNP-1 Project are prepared and controlled by UE&C in accordance with applicable codes and standards and are included in the Contract Specification by UE&C Engineering for fabrication work perfor=ed by Vendors and Cantractors. These processing docu=ents are stintained by UE&C and are continually reviewed, updated, revised and supplemented ta pr: :de sufficient infor=at; >n pertaining to codes, standards and methods of testing so that special quality control functions can be perfor=ed properly.
17.2.9.2 Process Audit and Surveillance a)
UE&C surveillance and audits of Vendor and Contractor processing are conducted by Quality Assurance to assure that their -
Special processes are being conducted in accordance with qualified procedures by qualified personnel as prescribed by
~""~'_?
applicable codes or standards.
Records are being =aintained which document the satisfactory acco=plish=ent of special processes and which indicate the current qualification and certification status of all special process procedures, equipment and personnel.
Special process procedures are being regularly reviewed to l
assure their confor=ance with latest revisions of codes and standards imposed by contract specification.
l b)
Deviations from approved Vendor or Contractor procedures will be reported to UE&C in writing and implemented only if approved b'y UE&C.
I 2.
V 17.2-20 L
WNP-1 Anendnant 8 PSAR July 1974 17.2.9.3 Qualification Ven'ders and Contractors personnel responsible for perfor=ing special processes will be qualified in accordance with the applicable code or regulation. These qualifications are reviewed and docu=ented by UE&C Vendor Surveillance represent-atives in Vendors and Contractors off-site shops. Personnel employed by the Vendor or Contractor to witness, perfo m or inspect special processes fer which A
qualification and certification is mandatory, shall be certified in accordance with the applicable code or regualtion. Active files will be maintained by the Vendor or Contractor, of qualification records of Vender or Contractor personnel perfor=ing special processes.
17.2.9.4 Process Docu=entation and Records a)
The control of these special processes by the Vendor or Contractor will include documentation and records sufficient to ensure that the requirements of these special process procedures, in accord with specification requirements, have been met.
These records will be controlled and retained in accordance with Subsection 17.2.17.
b)
UE&C Home Office Quality Assurance personnel. review the centract specification to verify inclusion of any special process or process.
controls and with UE&C Engineering, review and approve all suinitted Vender and Contractor special process procedures pric: te fabrica-tion. UE&C Vendor Surveillance personnel provide the surteillance effort ta assure that Vendors and Contractors conform to their procedures.
1 17.2.10 Inspection The UE;C procurement documents require participating Vendors and Contractors
-""578' provide for a controlled syste= of inspection of =aterials, parts, cc=ponents and equip =ent associated with the WNP-1 project. Written Vender or contractor procedures provide for this control of inspections to assure that the =aterials purchased are fabricated, tested and delivered in conformance with specification and contract requirements. UE&C surveillance i
pers.onnel determine the accept or reject status of the work and implement i
their decision by pursuing a course of action as defined in Subsections 17.2.15.8 and 17.2.16.6.
17.2.10.1 Personnel a)
UE&C, is not responsible for performing first level inspections.
1 However, UE&C R&QA Vendor Surveillance representatives will conduct surveillance activities within the scope of the UE&C QA program l
associated with Vendor and Contractor inspections, examinations and other activities at the aquipment suppliers p,lant.
UE&C Vendor Surveillance personnel contzaually verify that the Equipment Vendor and Contractor firs t level inspection capability is =aintained at the high level required for the WNP-1 proj ect.
l
- =-
L 17.2-21 4
l
WNP-1 Amend:ent 8 PSAR July 1974
?
6 (2=-
- =-
i Procedures for maintaining this high standard of inspection c'apability are developed by the appropriate Vendor or Contractor for review and approval by CE&C. UE&C R&QA Vendor Surveillance assures that Vendor and Centractor Quality Control departments i
i continually monitor, through examinations, indoctrination programs and orientation and training, the proficiency and independence of their inspection personnel.
17.2.10.2 E:ui;nent Sur:lic - In process insee:tien end surveillcnce a)
The surveillance activities associated with the in-process shop inspections, tests and docu=entation for pre-purchased and Contractor purchased equipment are in accordance with UE&C Quality Assurance Procedures which define in detail UE&C control of purchased items at the Vendor or Contractor Plant.
b)
UE&C inspection requirements are outlined in the Contract specifi-cation and su==arized as a surveillance check plan. This surveil-lance Check Plan is prepared by the UE&C WNP-1 Quality Assurance Engineer developed from the contract specification, and outlines the contract requirements for docu=entation, testing, inspection
~
points, sa=pling plans, processing procedures, and receiving re-6 quire =ents fer the applicable equip =ent.
The check plan is used by the UE&C Vendor Surveillance representative as a check list guide for UESC in-process and final surveillance inspection of the purchased equipment prior to delivery to the site. The shop inspections designated are perfor=ed by the Vendor or Contractor's personnel charged with the quality responsibility and these inspections are audited by UE&C surveillance representatives.
17.2.10.3 Ecuipment Supplier - Final Inspection and Release y
When pre-purchased =aterial is to be inspected by UE&C prior to shipment, the Vendor notifies the UE&C purchasing depart =ent, who in turn notifies appropriate UE&C Vandor Surveillance Quality Assurance personnel and =akes arrangements with Vendor Quality Personnel for the final inspection at the Vendor Plant. Signing of Vendors For=s, notification of UE&C Field Quality Assurance Office and tagging, prior to shipping co=pletes the UE&C Surveillance inspection effort. Completed approved documentation is then transmitted to g
the UE&C Field Quality Assurance Office.
b)
When Contractor purchased =aterial for construction contracts is ready for final inspection and release, the UE&C Vendor Surveillance representative may participate, when specified, through surveillance at the Contractors ' final inspection and release activities at the plant, to the extent necessary to assure that the Contractor is conforming to his approved procedure for releasing the equipment for shipment.
6 ii L
17.2-22
_________._____m.__
W:~P-1 A=end ent 8 PSAR July 1974 c)
If it is not possible or is disadvantageous to final inspect the equip =ent at the point of f abrication prior to shipment, then the acceptance inspection of the equip =ent is i=ple=ented at the site in accordance with the Receiving Inspection Procedure as defined in 17.4.10.
17.2.11 Test Control Ehe CE6C Quality Assurance Progra= establishes a systen of control to assure that Vendcr and Contractor test activities are perfor=ed in their plants in accordance with require =et;s which are predeter=ined, approved and delineated in written Test Plans and instructions. This syste= will also assure that test results are acceptable and fully documented.
17.2.11.1 Test Recuirements a)
Test require =ents for Vendor and Contractors are delineated in the Contract Specifications in conformance with engineering practices and Code requirements. Conformance to AEC~ regulatory guides are also considered when the required tests are specified in the Contract Specification.
b)
Vender and Centractor written test procedures for revica and audic by UELC Quality Assurance, describe the methcd cf test concrcl, through verification that tests have been performed in accordance with specified plans and procedures, and that test results are s_.
within the specified limits. Qualification, and special proof tests when specified in the contract specification require the Vendor or Contractor to prepare test programs adequate for the application and subject to review and approval by UE&C.
c)
Witnessing of shop performance testsi nondestructive tests, =aterial tests, acceptance tests, proof tests, and qualification tests as l
conducted by the. Vendor or Contractor is acco=plished by UE&C l
Engineering and Quality Assurance in accordance with test and inspection require =ents outlined in the Contract specification and accompanying Quality Assurance documents.
17.2.11.2 Test Evaluation Final test reports and documentation supplied by the Vendor or Contractor are reviewad and evaluated by CE&C agai:.st acceptance criteria, operating limits and perfor=ance s tandards. Deviations, Discrepancies or questionable test l
I data are reviewed by UE&C Engineering with UE&C Quality Assurance support when required. Appropriate instructions follcwing the nonconfor=ance procedure, as outlined in the Contract Specification, are issued for dispositien.
fi...:.
2.
.g 17.2-23 4
IGp-1 A~endment 8
.PSAR July 1974
?
17.2.11.3 Operatine Experience a)
When Contract Specifications allow the use of Vendor or Contractor operating experience data to demonstrate equipment conformance to operating test requirements, UE&C Engineering personnel and, as required, UE&C Quality Assurance personnel assure that the certified data are pertinent to the application and that the operating experience data provides those specifications, features, comparisons, rationale, su== aries and sources from which a basis for deter =ining the suitability of the data is obtained.
b)
Suitability and acceptability of the operating experience data is reviewed and evaluated as defined in 17.2.11.2.
17.2.11.4 Test Personnel 1
]
a)
Venders and Contractors shall assure that personnel employed to perform or interpret the results of testing activities are properly qualified in accordance with their approved procedures.
Where code or contract specification requirements specify qualification criteria for such personnel, the applicable procedures shall be in accord with such criteria.
17.2.12 Control of Measuring and Test Ecuipment a)
UELC Contract Specifications require that Vendors and Contractors must have control over the calibration and use.of cools, gauges, instru=ents and other measuring and testing devices used in activities affecting product quality on designated equipment
_end rervices. The Contract Specifications also require that
~ ~ "
' Contractors' procedures shall describe the calibrations l
technique, calibration frequency, =aintenance and control of i
all =easuring and tes t instrumentation tools, gages, fixtures, l
reference standards, transfer standards and nondestructive test equipment which are to be inspection and monitoring of co,iused in the =easurement, mponents, systems and structures.
p b)
Allowable deviatier.s from calibration standards shall be
[
specified in the Contractor's procedures and submitted to UE&C l
for approval.
Inspection, testing and ceasuring equ'ipment items shall be uniquely identified and have traceability to their calibration test data.
11.2.12.1 Procedure g
a)
Vendors' and Contractors' calibration policy, schedule and system for the control of measuring and test equipment are detailed in their applicable quality control procedures. These h;p-2.
h-!
l
-a.,
l 17.2-24 l
e
10'P-1
~ >=end:ent 8 PSAR July 1974 procedures are reviewed by UE&C Ho=e Office Quality Assurance personnel for adequacy prior to authorization to use. UE&C Vendor Surveillance personnel audit the Vendor or Contracter adherence to these approved procedures.
b)
Vendors and Contractors procedures establish a system for the control, catibration and adjustment of tools, gauges, instruments and other inspection, measuring, testing and maintenance devices. This system is established such that confor:ance to established requirements is verified as specific periods of time to assure the usage of proper type, range and accuracy of the device.
17.2.12.2 Control Requirements Vendor and Contractor procedures require thnt the following detailsd control require =ents be implemented as part of their measuring and cast equipment calibration program -
a)
Maintenance and c'ontrol of pri=ary and secondary standards b)
Measuring capability of standards in accordance with Contractor or Vendor defined tolerance ranges 2
e t
{
l l
l l
2l::
.=
l 17.2-24(a)
WP-1 Amend =ent 2 PSAR January 1974 5m.._
c' c)
Method of correcting, adjusting, returning for repair and replace-
=ent of measure =ent standards.
6 d)
Calibration control of new devices and positive identification of calibration status.
e)
Calibration instructions f)
Calibration schedule, listing and location for usable test equipment g)
Reca2ibration review h)
Environmental control limitations and requirements for calibration i'
17.2.12.3 Standards of Control a)
In establishing the degree and type of environmental control whare calibration of items are performed, the accuracy requirements of the measurement para =eter is taken into consideration by the Vendor and Contractor. The conditions under which " reference standards" by the Vendor and Contractor are calibrated suggast conditions
= ore rigidly controlled than those cenditions under which " working standards" for measuring and test equipcent are calibrated.
b)
Vendor and Contractor procedures provide for the calibration of "pri=ary reference standards" with certified accuracies traceable to the National Bureau of Standards (NBS) and to be performed,
. I where a *-ble, subject to surveillance by UE&C Vendor Surveillance persont er the applicable controlled conditions of -
~
Temperatare Te perature Rate of Change Relative Humidity Dust c)
Vendor and Contractor calibration frequency charts provide require-ments for frequency of calibration and a certified percent of accuracy traceable to the NBS for pri=ary standards (Dimensional, pressure, electrical, thermal, weight), secondary standards and general test instruments.
I 1
17.2-25
4 wp-1 Amendment 3 PSAR July 197!.
l
/7 17.2.12.4 Calibration and Control Records I
a)
Ifentification of calibration records for Testing and Measuring equipment used by Vendor or Contractor during in-pr9 cess and final inspection are established so that equipment can be readily recalled for recalibration or adjustment. These records also serve as an indication of which devices were used on specific tests and in-spections and also provide for traceability if such devices are i
found to be out of calibration and require corrective action.
b)
The use of uncalibrated equipment constitutes a rejection of the test or inspection with the disposition identifiea as part of the l
nonconformance report which is issued.
)
./.2.13 Handling, Storate and Shippine UE&C Contract Specifications specify the requirements for cleaning, handling, storage and shipping from which Vendor and Contractor procedures are developed.
j Thsse procedures are subject to UE&C review and approval and where appropriate, l
Vanders and Contractors submit recommended cleaning, preservation, handling i
and storage instructions for use at the Construction Site.
3 17.2.13.1 Procedure a)
Vendors and Centrattors establish and docu=ent procedurec to be
(
e= ployed to control cleaning, preservation, handling, corage and i
shipping of their responsible equipment during the plans fabrication, testing, inspection and subsequent shipping to the sitt The procedures to be developed cover cleaning, packaging at. preserva-tion of the material and equipment to prevent da= age, ceterioration and loss at the plant. These Vendor and Contractor procedures also
" c'ontain provisions for utilization of special covers, special equipment and special protective ewiron=ents, such as inert gas atmosphere, specific moisture content levels and temperature levels attributible to the special maintenance care and cleanliness required whan the equipment is kept at the site, b)
The Vendor and Contractor procedures for their equipment also contain suitable provisions for verifying the above conditions. UE&C Vendor Surveillance personnel provide the surveillance activity necessary to assure that the Vendor or Contractor has implemented his
~
procedures with qualified personnel. Contract specifications govern the UE&C Q.A. Vendor Surveillance inspection of packaging and pre-paration for shipment at the Vendor or Contractor off-site Plant.
l 17.2.13.2 Ceneral Recuirements a)
All procedures defining specific packaging, preservation, shipping and storage of materials shall confor= to applicable material codes-and standards including consideration of the applicable AEC
(
Regulatory guide.
5 2.
17.2-26
- -~
=...
INP-1 Ansndment 2 i
PSAR January 1974 1
i f. b) Shipping containers for equipment specified in UE&C Contract j
- ~
specifications, when selected at the option of the Vendor or Contractor, are utilized where appropriate and in accordance with specific approved criteria. Protection of equipment during preser-ation, handling, shipping and storage requires an assessment of the j allowable protection criteria by the Vendor and Contractor. c) The Vendor and Contractor procedures will provide instructions for marking and labeling for packaging, shipment and storage. These i written procedures contain provisions for the marking of identifying information on the exterior of shipping containers. The narking is { adequate to identify, maintain and preserve the shipnent, including l indication of the presence of special envirqaments ' cr the need for special control. 17.2.13.3 Cleanliness a) UE&C Contract specifications specify a cleanliness requirement for equipment which is applied by the Vender and Contractor during and af ter fabrications and during storage and shipping. The cleaning and cleanliness control program, as utilized by the Vendor and Contractor, is designed not only to minimite preoperational cleaning i of installed components and post-assembly cleaning of components at the plant, but to establish site cleaning of equipment and main-j tenance of equipment cleanliness at the site. Cli. b) Vendor and Contractor procedures provide for the facilitation of cleaning and inspection for cleanliness during fabrication of the equipment. UE&C Vendor Surveillance personnel provide the aclit and surveillance activiry to assure that the vendor and Contractor i has implemented his procedure with properly qualified personnel. e ;- c) The site Receiving Inspection provides for verification of the Vendor and Contracter cleanliness progran during unpackaging. 17.2.14 Inspection, Test and Operating Status The UE&C Quality Assurance Program provides for procedures to be developed by' vendors and contractors, compatible with UE&C, for indicating the status of tests and inspections performed at their plants upon materials, parts and components. The status of an item is indicated by means of tags and stamps to (a) preclude the inadvertent bypassing of their inspection and test require-ments and to (b) prevent their ir. advertent operation. ' 17.2.14.1 Item Status a) UE&C approved vendor and contractor procedures provides for' their own tagging methods to indicate inspection and testing status and acceptance of applicable equipnent during plant fabrication. R% k+N. L 17.2-27 e
3 UNP-1 Astud cnt 2 PSAR January 1974 b) Vendor and contractor items are indentified by =arkiag, tagging, (( labelling o'r other appropriate =eans either en the ite=s or on ,docunents that are traceable to the ite=s. c) Identification of items in the vendo-or c~ontractor plant is directed toward categories of ACCEPT status, REJECT status, REPAIR or REWORK status and HOLD status. These item categories differentiate in the applicab.le procedure between ite=s awaiting inspection, items that have satisfactorily passed inspection and iters that are discrepant (see 17.4.14), d) UELC vendor surveillance effort provides the in process and final inspection surveillance activity to assure that tagging and item identification has been tcplenented by the vendor and contractor in accordance with the approved procedure. 17.2.14.0 Insoection Stamps a) Vendor and contractor approved procedures and their quality system control the use of inspection, welding, NDE, etc., stanps and status indicators, including their authority for application and renoval of such application. b) The apptoval procedure provides for the definition, issuance, control and application of these inspection stanps by their own quality responsible personnel. UE&C vender surveillance personnel pr: vide the audit and surveillance activity to assure that the responsible centractor personnel are i=plerenting their approved procedures. 17.2.14.3 surveillance Targing Upon satisfactory co=pletion of the work at the plant by the vendor or the centractor, the UE&C vendor surveillance personnel issue a "7 ender Surveillance Tag" which serves as a notification to the construction site that the UE&C surraillance actions have been satisfactorily ce=pleted. 4 Qance in Status a) Provisions are nade in the UE&C Quality Assurance program for j L=ple=enting a change in cratus of Veador and Contractor items. The inspection status of any item may be changed on the basis of inspectica and surveillance, only by instructicns fro: UE&C Quality Assurance, WPPSS Quality As'urance or Vendor or Contractor Quality Assurance. b) If ite=s are " released" by the Vendor or Contractor and new con-confor=ances are discovered, they will be handled in accordanes with Subsection 17.2.1I. ( L ~ i 17.2-28 +
1;NP-1 A=endnent 8 PSAR July 1974 je: k h_ ~ 17.2.15 Nonconforming Materials. Parts or Components The 'UE&C Quality Assurance Program provides that vendors, who are suppliers of UNP-1 equip = cat, are required to establish and maintain a system for controlling conconfor=ing =aterial to preclude its use until properly dispositioned. This system will be compatible with the UE&C system of NCR control, which will assure that both vendor and UE&C nonconfor=ances are identified, documented, segregated and dispositioned and that notification of the actieas taken are transmitted to the affected parties. 17.2.lf.1 Cla ssification i A nonconfor=ance is a deficiency in characteristic, documentation or procedure which renders the quality of an item unacceptable or indeterminate. Examples of nonconfor=ance include physical defects, test failure, inaccurate or inadequate documentation or deviating from prescribed processing inspection or test procedures. Nonconfor=ances are classified as follows: a. Diserupancies - Nonconfor=ances which do not affect the safety, perfor=ance or durability of the material. A discrepancy can be repaired or reworked providing an " approved" repair or rework procedure exists; or it can be " accepted as is" providing the non-confor=ance does not co= promise design or contract criteria. b. Deviations Nonconfor=ances thich affect the safety, perfor=ance er dura-j bility of the material. Discrepancies which can be repaired or reworked for which an approved procedure is not a railable. Nonconfersances which cannot ba reworked. Deficicneies - Nonconforming conditions detected within UE&C during c. "home office" activities involt.ng Design Specifications, program 7 procedures, and Drawing Regnirements, related to Home Office Quality 1 Assurance, Construction Man.ge=ent Engineering, Purchasing and Project Manage =ent, but not to site activities. These conditions represent departures froc an approved procedure, approved Design or Drawing which.could adversely affect the quality of the "home office" activity being i=plemented on the WNP-1 project. E 1 h.g 11.2-29 L
WUP-1 A=end=ent 8 PSAR July 1974 p. 17.2.15.2 Procedure "i" Nenconfor=ing =aterials, parts, co=ponents or progra= procedure activities are docu=ected by the organization detecting the nonconfor=ance as follows: a. UE&C initiated: 1) Nonconfor=ances detected against in-house UE&C "home effice" activities are docu=ented using the UE&C deficiency report. These are handled as nonconfor=ances subject to investigation, disposition, rejection, corrective action 9 reporting to UE&C =anagement and close out in accordance with UE&C approved quality assurance procedure. 2) Nonconformances (Discrepancies and Deviations) detected at the vendor's plant againct vendor activities are initiated by UE&C Vendor Surveillance using UE&C NCR For=s or brought to the attention of the vender for his own initiation and documentation of actions in accordance with 17.2.15.2.b. b. Vendor initiated: 1) Nonecnfor=ances at the vendar's plant which are classified as " Discrepancies" are docu=ented on the vendor's own non-confor=ance t aport form. m 2) Nonconfor=ances at the vendor's plant which are classified as " Deviations" are documented on the vendor's own nonconfor=ance report for= with a UE&C Contract Waiver Request (CWR) also being generated. 17.2.13.3 Control: !ng NCR For=s (Ho=e Office) a. UE&C Deficiency Report forms, for in-house use, contain a description of the nonconforming ele =ent activity and the deficiency, a reco== ended disposition with a technical justification, the disposition (i.e., incorporate drawing or spec co==ent, rework elemenc procedura, rework files, etc.), verification that the dis-position was accomplished and an evaluation af the need for correc-tive action to prevent a :-currence. Standard distribution of pre-li=inary and co=pleted deficiency Reports is =aintained. l 6 b. UE&C NCR for:s, for vendor activity, contain a description of the nonconfor=ing ite= and activity, a recc== ended disposition l with a technical justification, the disporition (i.e., S accept as is, repair, rework or reject), verification by reinspec-tion that the disposition was acco=plished and an evaluation of the need for corrective action to prevent a recurrence. Standard distribution of preliminary and co=pleted NCR's is =aintained. 9 17.2-30 1
i WSP-1 A=:nd=snt 8 i ?SAR July 1974 =s. 2pc Vendor NCR for=s, for Vendt e activity, contain a description of the c. nonconforming ite=, a reco=; ended disposition and justification, ~ verification by reinspection that the disposition was accceplished, a stata=ent of corrective action to prevent a recurrence and iden-ti'ication of contract waiver request action, if. required. Standard distribution of co=pleted NCR's is =aintained. 17.2.15.4 Maintenance of Noncenformance Records a) Copies of vendor nonconfor=ance docu=ents are sub=itted to UE&C Qcality Assurance with the equip =ent. UE&C provides a copy of all trans=itted noncent'or= ant. docu=ents generated by vendors or U4hc to WPPSS Quality Assurance Organization for information. b) A log is =aintained by UE&C Quality Assurance Engineering for UE&C initiated NCR's at the vendor plant. This log also includes a cross index of NCR's with the applicable Contract Waiver Request (CWR) identification, for Deviations. l 6 c) A log is =aintained by the vendor for vendor initiated NCR's listing as a =ini=um the date, nu=ber, item and nonconfor=ance description and disposition. This log also -includes a cross index of "CR's j and the CWR listing. i 42_. d) A log is =aintained by the UELC Quality Engineering Section for UE&C initiated Deficiency Reports in the Ho=e Office. This log beco=es a part of the permanent WNP-1 project file. t l l e) All NCR's re=ain in the "open" file (whether at the vendor or UE&C) l until disposition has been resolved, i=ple=ented and reinspected. 17.2.15.5 Contract Waiver Recuest (CWR) A CWR is a vendor request for a change in contract specification a. .requir ements. Processing of a CNR occurs through imple=entation of the contract change process in accordance with the requirements as defined in approved UE&C project procedures and 17.2.3 Design "ontrol. 'b. If approved, the disposition results in an " accept as is" disposition. If not approved, the vendor must reject the ite= or repair or re-l work it in accordance with an approved vendor procedure in order l co satisfy requirements. l l t 1 ib.= 17.2-31 ~e w r +
WNT-1 A=end=ent 3 PSAR July 1974 (E-17.2.15.6 Diseositien Disposition of all nonconformances, either at the vendor or at UE&C, are noted on the respective NCR forms with the dispositioning action as follows: a) Disposition of vendor " Discrepancies" shall be b'y the person responsible for the QA function of the organization originating the nenconfor=ance document. Dispositions shall be " accept as is" providing the design or contract is not compromised, " repair" or " rework" in accordance with an existing approved vendor procedure, or " reject" for items unsuitable for their intended purpose and/or uneconomically feasible to be reworked or repaired. b) Disposition of vendor " Deviations" shall be in accordance with 17.2.15.5 Contract Waiver Request. e, Jisposition of UE&C " Deficiencies" is determined by the UE&C "Ho=e Office Activity" manager. Dispositions shall be co=patible with satisfying the UE&C and WPPSS approved QA and project g, procedures for that element of in-house effort. 17.2.15.7 Reinsoection a) Af ter the responsible organization has perfor=ed the required actiens to clear the nonconfor=ance: \\c " 1. For vendor ncnconfor=anc. J the originating organization's QA (UE&C or Vendor) inspects the item, deter =ines its acceptability and signs off the nonconfor=ance docu=ent _,--- as approved. 2. For Ho=e Office Deficiencies, the UE&C Quality Assurance Organization verifies the disposition action, evaluates g the resolution and signs off the nonconformance document as approved. 1 17.2.15.5 Accen t-Rej ect Authority a) Dis crecancies (Vendors / Contractors Off Site Plant) rinal authcrity for the acceptance or rejection of Discrepancies is as follows: Vendor / Contractor Quality Assurance - for nonconformances discovered by their own QC inspection. UE&C Quality Assurance - for nonconformances discovered by UESC Vender Surveillance. (E 17.2-32
l g c:?- ) A=end ent S PSAR July 1974 i in t l b) Deviations (Vendors / Contractors Off Site Plant) t Final authority for the acceptance or rejection of Deviatiens t is as follows: i UE&C Engineering - in accordance with Project Contract j Waivar resquest procedures. c) Deficiencies - (Home Office) Final authority for the acceptance or rejection of Home Office Deficiencies is as follows: UE&C Quality Assurance - in accordance with existing Profect Quality Assurance Proce'.ures. 17.2.16 Corrective Action UE&C uses available inspection and auditing procedures and vendor nonconformance and disposition reports to identify and obtain corrective action for conditions adverse to quality. Typical of these conditions are vendor quality program or procedural inadequacies, failures,_ malfunctions, deficiencies, deviations, defective naterial and equip =ent and vendor ncnconfor=ance to specified require =ents. 17.2.16.1 Corrective Action During Desien Effort a) Errors and nonconformances which. adversely affect safety related s tructures, sys t' ems and components discovered during the UE&C, vendor and contractor design process are docu=ented on review -y forms and cor=ent prints and resolved by UESC prior to approval of the document. 1 .IY..
- 17. 2-32 (a) o P
WP-1 Amendment 8 I PSAR July 1974 sp 57 b) Design'nonconfor=ances discovered during vendor or contractor =anufacturing, and the subsequent corrective action are docu=ented, approved and the original design document (s) revised in acecrdance i with UE&C approved project procedures. c) Effectiveness of corrective action is checked by UE&C audits in accordance with subsection 17.2.13. 17.2.16.2 Corrective Action Recuests l a) The UE&C Quality Assurance progra: provides that the vendor initiate his own Corrective Action Requests in accordance with an approved procedure and that the vendor responds in a timely manner to Corrective Action Requests written by UE&C Quality Assurance. 4 i b) The UE&C Quality Assurance Progran providas that "Home Office Activity" practices in which repeated violations of the same nature either are occurring er would occur require the initiation of a Corrective Action Request by UE&C Quality Assurance b in accordance with an approved procedure. 17.2.16.3 I=plementine corrective Action ' a) For He=6 Office corrective a: tit: the designated respcasible Ecne Office d'- Activity addressee describes the corrective action that he intends to implement and specifies the date by which it will be i=ple=ented. If the cortective action specified is not adequate or does not =eet the intent of the request, UI&C Quality Assurance resolves the difference in accordance with an approved procedure. t b) For Vendor corrective action initiated by UE&C Quality Assurance, the designated cesponsible vendor describes the corrective action that he intends to i ple=ent and specifies the date by which it will be 1=plemented. UELC Vendor Surveillance personnel maintain an audit and surveillance activity to ascertain the adequacy and intent of the corrective action in accordance with the approved vendor practice. 17.2.16.4 Verification and Ar.alvsis } a) When actual corrective action by the Home Office Activity has been satisfactorily implemented, UE&C QAE will describe the actual corrective action on the Cerractive Action Request, date and g sign the request form to indicate Quality Assurance approval of acceptable action. Standard distribution of this information to affected activities is then i=ple=ented. 2. 1 17.2-33 4 _.,m,... m -.,g n ,,..,,__.--,..--.,m-..m --_...,w._ e
WNP-1 A=end=ent 8 PSAR July 1974 gm= b) When actual corrective action by the Vendor has been satisfactorily i=plemented, UE&C Vender Surveillance will describe the actual corrective action on the Corrective Action Request, date and trans-mit the request form to the QAE. The QAI's signature on the " CAR" indicates QA approval of acceptable action. Standard distribution I of this information to affected activities is then implemented. c) Vendor and Home Office corrective action forms are filed and logged, and the effectiveness of the corrective actions is reviewed by Ho=e Office Quality Assurance Engineering personnel. Such actions =ay include stopping the vendor effort for poor quality performance or stopping the Home Office Activity effort for disregard l of approved QA or project procedures. g d) Feedback infor=ation on nonconformances is transmitted from both Procurement and QA Vendor Surveillance to UE&C Quality Engineering. I The data are analyzed and evaluated by UE&C QA and UE&C Engineering I personnel, af ter which corrective action is reco= mended to assist in controlling and preventing recurrence of nonconformances. c' O.'gnificant deficiencies in design or construction will be reported prc:ptly to WFPSS. These activities are gove.rned by written procedures. 17.2.16.5 Failure to Respond t a) Failure to respond either by the vendor or UE&C Hoce Office Activities l ' ' ~ to Corrective Action Requests within the allotted time will result 9 in notification of UE&C or Vendor Management with a requirement for i==ediate -espons e. Lack of response by UE&C Management may result in stoppage of work in the affected area in accordance with approved _-,hT.iC quality assurance procedures. Lack of response by vendor Management =ay result in stoppage of work in the affected area in accordance with UE&C approved Vendor Procedures or, when necessary, by UE&C. i 17.2.16.6 Stop Work Authority fj !i 2. a) Stop work authority for "Home Office Activity" rests with the UE&C Project Engineering Manager < for the project based on direction received via a "Stop Work Order" from the M,anager, UE&C Reliability & Quality Assurance, b) Stop work authority for Vendor and Contractor Off Site Plant activity rests with the UE&C Project Engineering Manager for the project based on direction received via a "Stop Work Order" from the Manager, UELC Reliability & Quality Assurance. c) Work =ay be restarted with the approval of the Manager, R&QA only af ter action has been taken by either the "Home Office Activity" or the Vendor and Contractor to eliminate the fps nonconformance and the UE&C Project Engineering Manager for "= the project has satisfactorily replied te the "Stop Work Order". S 17.2-34
WN?- 1 Arendnent 8 PSAR July 1974 17.2.17 Quality Assurance Records The'UE6C Quality Assurance progra= provides for drawings, contract specifications and procurement documents to delineate the Quality Assurance records that Vendors and Contractors are required to prepare, caintain and submit for review and approval to provide documentary evidence of quality. These records must be identifiable and' retrievable and include, but are not limited to, drawings, specifications, material test reports, qualification records of personnal, procedures and, 4 'uipment, calib ration procedures and reports, nonconfor=ance and corrective cction reports and inspection and test records. UE&C will maintain the WWF-1 Quality Assurance files for activities and items under UE&C cognizance. Thesa files will be available for WPPSS review. 2. ~ we Ms( r= y 17.2-34(a) ~
i i WNp-1 Amend ent 8 PSAR July 1574
- ? '..
17.2.17.1 Records Recuire=ents a) Specific records require =ents for Vendors and Contractors are identified in procure =ent docu=ents, Centract Specifications, Codes and Standards, and in the UE&C Quality Assurance procedure manuals I which govern quality associated activities. These include records of the results of reviews, inspections, tests, audits, =aterial analysis, monitoring of work performance, qualification of personnel, procedures and equip =ent and other docu=entation as defined in Subs ection 17.2.17. b) The record system at UE&C in the initial phases of the Engineering and Procurement program includes those quality assurance records associated with the design, engineering, manufacture, testing and inspection of st.ructures syste=s and co=ponents. This record system is initiated with the early concept of the WNP-1 project. UI&C quality assurance procedures govern the general and specific require-ments, development, transmittal and receipt, audits, stcrage, retrieval, and disposition of quality control and quality assurance records. c) The recorcs that Vendors are required to retain are =aintained sub-sequent to completion of work in accordance with the applicable codes, s tandards and procurement docu=ents. .~. d) Records that are shipped with Vendor or Contractor equipment are '~ trans=itted in accordance with the applicable codes, standards and contract procurement docu=ents; and upon receipt at the Con-struction site (17.4.17) become the responsibility of the appropriate receiving organization (UE&C for pre-purchased equipment and site contractors for Contractor purchased equipment). 17.2.17.2 Records Accuraev and Traceability a) UE&C Contract procure =ent docu=ents establish the provision for the Vendor and Contractor to have a systemized method for verifying and docu=enting that their documentation is complete and correct. Vendor records will provide sufficient infor=ation to permit identification between the records and the item or activity to which they apply. Contract specifications direct the vendor and contractor to provide a positive =ethod of traceability from docu=entation to the part. Their method will be defined in procedures approved by UE&C. b) QA records which are sub=itted by the Vendor as part of Contract Specification requirements are continuously reviewed by UE&C Quality Assurance. Nonconfor=ances or shortcomings l which are identified through these reviews are i= mediately g reported to UE&C Engineering where corractive action with the ,s Vendor is i=plemented. Continuous UE&C i= position of Quality 3-e Assurance require =ents on these vendors results in close control of their sub=ittals. Continued analysis of the data by UE&C Quality Assurance and UE&C Engineering indicates the I extent of Vendor positive actions. S 17.2-35 2. sj
WNP-1 Amendment 8 PSAR July 1974 {Eih 17.2.17.3 Records Exa=1 nation a) All UELC, Vendor and Contractor Quality Assurance records for the WNP-1 proj ect are the property of WPPSS and are subject to review, audit and inspection by UE&C and WPPSS Quality Assurance. Records are not to be destroyed or otherwise disposed of without l written consent of UE&C or WPPSS Quality Assur'ance. UE&C contract 1 documents allow for UE&C or WPPSS to acquire possession of any Quality Assurance Records generated. b) Vendor or Contractor Quality Assurance records will not be altered, changed, modified or corrected without proper justifications and in accordance with a Vendor or Contractor procedure which provides for appropriate review or approval. Any change or correction includes the date and identification of the person authorized to make the change or correction. c) UE&C Quality Assurance records are under the same requirements as that specified in 17.2.17.3.b. d) Analysis by UE&C of the Vendor drawing control system is also effected to ensure their use of correct revisions of drawings and procedures. An evaluation of the Vendors in-process inspections is perfer=ed to assure early detection on nonconforming conditions in the manufacturing cycle. Verification that contract NDE and inspection and test require =ents are properly incorporated into =anuf acturing operation instructions is also accomplished. 17.2.17.4 Record File and Storage ga), _,.T.LC's records of design activities are maintained at the Home Office and are identified and retrievable. These records include drawings, Contract Specifications, calculations, stress reports and evidence of design verification. UE&C maintains these records in accordance with applicable codes and standards by maintaining a duplicate set of records in separate locations (ie Master Project File and Engineering discipline files) so that both sets could not be si=ultaneously lost or destroyed thru fire, flooding, theft, and deterioration by temperature or humidity conditions. These records ( are available for WPPSS or Regulatory Agency review and audit. Upon co=pletion of the work, a complete set of records wlll be transmitted in accordance with applicable codes and standards to W2PSS for retention. b) UE&C's Quality records are maintained, identified and filed at the Home Office. UE&C will provide a surveillance activity at the Vendors and Contractors offsite plants to assure that QA records for i WNP-1 equipment are filed and stored with the safety, accuracy and timeliness required for records control. (irw 17.2-36 l \\
t l WNP-1 A=endnent S PSAR July 1974 '.3f=5 'EL 17.2.17.5 Records Ratention a) UE&C Engineering Records and drawings are indexed and =lerofil=ed in accordance with the approved Project procedures and under the responsibility of UE&C Project Engineering. UE&C QA records received i or generated at UE&C Home Office, which are required at the site will be duplicated and transmitted to the Site Quality Assurance Master File as required. b) Retention period for data will be determined with WPPSS in accordance with guidance afforded by ;ESI N45.2-9, Appendix A in which the " lifetime" and "Non-per=anent" categories for data are indicated. 17.2.18 Audits The Quality Assurance program for the WNP-1 project provides for planned and unplanned periodic audits which wil) "erify compliance with the applicable Management, Engi.teering, Procurement and QA activities. The audit records,of UE&C internal practices offer objective evidence of i=plementation of and compliance with requirements, and consistency in the discharge of responsibilities. 17.2.18.1 Tyees and Categories a) Audits are being performed as " internal" audits, where audits are perfor=ed on specific elenents of the WNP-1 Quality Assurance ~~ Program; and as " External" audits, where audits are conducted at l Vendors or Contractors facilities to ascertain his conformance to 3 contractural requirements, including engineering specifications, codes and standards. Both types of audits are perfor=ed in accord-ance with written chech lists by Quality Assurance personnel who, -~==c F ' by the nature of their position, are independent fro = c3e Engineering & Manufacturing disciplines. "Managenent" audits will be perfer=ed by the UE&C Vice President of Ad=inistration on an annual basis to verify compliance with the established corporate QA program, b) Internal Audits _ The general categories of Engineering, Purchasing (Procurement), Hcue Office Quality Assurance & Vendor Surveillance are these QA functions of UE&C which are subject to the UE&C -internal audit program. The effectiveness of the technical portion of the UN?- 1 program is also subject to the UE&C audit program. Prior to non- [ ducting an audit, the auditor (Team Chairman) prepares a written g checklist delineating the characteristics to be audited. The audit is then conducted in accordance with this chacklist and upon completion of the audit, the results are presented, discussed and summarized in a written audit report. 5 2. .. =. 1 17.2-37 r-,, .. ~.,.,. _,,,, _,, _.,.. -., _,..,, _ ....-_,,v.., _.y..
o. 1CP-1 .t-endrent S July 1971 PSAR i c) External Audits _ The purpose of external audits is to determine if the supplier has 3 provided adequate control over his manufacturing processes connected with the component being manufactured. 1(nile UE&C QA Vendor Surveil-l lance has the responsibility to perform a QA Surv6111ance function 3 for the procurement of purchased items, the UE&C Audit function l has the responsibility to verify that the supplier is implementing his approved QA Sys tem. d) Management Audits The purpose of UE&C Management Audits is to ensure that the adequacy and status of the Corporate Quality Assurance program is being accomplished. Annually the UE&C Vice President Administration arre-nges for a corporate audit of the activities of the UE&C Relia-bility and Quality Assurance Department for Conformance to the provisions of the UE&C Nuclear Quality Assurance Manual. A by-product of the audit is the eventual impact of the results on various UE&C Nuclear projects including the WNP--1 project. The audit is conducted under the responsibility anu authority of the UE&C VP Ad.inistration and his designated Audit Team, selected from areas of corporate Manage =ent and other activities for not having direct respensibilit.es for UI&C Quality Assurance Actions. . ~ ( 17.2.18.2 Audit Planning a) The Manager'- Audits prepares a Mas:er,Audic Matrix for the WNP -1 l project identifying QA and technical program elements or activities, a established frequencies per specific project commitments, dates of audits, including verification audits, auditer(s) and tentative dates of subsequent audit. The frequency of scheduled audits is a: least once annually or at least once uithin the life of the ~ activity, whichever is shorter, or as established by the Manager Reliability and Quality Assurance department or his designate. The Manager - Audits is then responsible for the preparation, selection of audit teams, conducting the audit, post audit review / critique, audit report / distribution and. completion of the~ audit b) Unscheduled audits are conducted as required on the basis of the following factors.- 1. Areas of work and activities just starting and not scheduled for an audit 2. Verbal or written complaints of quality Deficiencies, noncon-forming trends or Discrepancies. g 9 I fY .2. 17.2-38 l L. i
i WNP-1 A=end ent 8 PSAR July 1974 iE l ~ 3. ' Previous audit of areas or activities which indicated a need for additional auditing 4 Verification that proposed corrective action has been i=plenent-ed satisfactorily 5. Major equip =ent suppliers, for problem conditions based en previous e:.geriences with the supplier. c) The following general audit categories will be covered as 4ee=ed appropriate by the Manager of Rnliability & Quality Assurance - 1) Engineering design controls and technical program assessment 2) Purchasing activities 3) Facility surveys as required l 3 4) Vendor Surveillance activities 5) Ho=e Office Quality Assurance Activities 6) Support of WPPSS NSSS Audits l 3 '-~ 17.2.18.3 Audit Team i r a) One or = ore individuals co= prise an audit team, although CI&C prefers that a team of at least two " qualified" individuals perform an l audit. At leas t one Quality Assurance Engineer is a ce=ber and usually functions as the team leader, with other term me=hers being selected from various UE&C departments or Projects as arranged for t by the Audit Function. j b) The selection of Auditors is based on their qualifications, special abilities or expertise, and personal characteristics, co==ensurate with the complexity or special nature of the activity to be audited. c) Suitable training 'is conducted for auditors as required and deemed necessary which entails on the job guidance and counseling under direct supervision of an experienced auditor. Special instructions by the team leader to Technical Specialists participating on an l audit team and for=al orientation sessions with personnel provide general and specialized training in audit techniques. l d) A proficiency record of auditors is maintained by UE&C Audit Function to reflect qualification based on -
- Regular, active participation in the audit process I
.: 5 ' gQ: l l l 1_ 17.2-39 ~ -~. -.. -
WNP-1 Anend ent 8 PSAR July 1974 (5t= te. . Working knowledge and understanding of applicable ele =ents of ~~ AEC 10CFR50 Appendix 3, ANSI N45.2 and Supple = ental St niards, related to the quality assurance program.
- Participstion in audit related training and orientation program describer: in 17.2.18.3.C.
17.2.18.4 Internal Audit Procedure a) Preparation for the internal audit includes reviewing reference docunents applicable to the verk, activity or procedure to be audited, preparation of check lists and a brief pre-audit cenlerence with the cognizant activity supervisor to confirm the audit scope, present the audit plan, introduce auditors and establish channels of co==unication. b) The audit is conducted and upon completion of audit actions, the audit team holds a critique to inform the responsible canage=ent of the result of the audit. c) The Audit report is issued within a designated time period after the audit in which the overall results of the audit are su==arized. Each nonconfor=ing condition is listed separately with recoc=endation for corrective action and tentative completion date. Copies of the Audit report are then sent to various UE&C corporate manage =ent levels including -=- " ice President Administration (as applicable) Manager Reliability and Quality Assurance ^ Manager - Audies Manager - Quality Engineering Proj ect Manager Proj ect Engineering Manager Construction Manager (as applicable) Quality Assurance Engineer (for the project) 3 Responsible Supervision of Activity audited i Others as required or identified by the Audit Team leader i ..m. ~ 17.2-40 l l ~
4 rip-1 Amendnent 10 Sep te:Ser 1974 PSAR d) A response in writing to the audit report findings is made to the +m Manager Audits end the Audit Team Leader by the responsible super-l vision of the activity audited. The R&QA Audit functica evaluates ,g and analytes the reply for responsiveness to corrective actions and conducts a follow-up action to assure impletent actica as scheduled. Folicw-up action may be acce=plished by - Written communication Verificatisa Audit Subsequent regularly scheduled (planned) audit of activity. Failure to respond by the audited activity could result in work steppage of the " activity" in accordance with an approved UESC Quality Assurance procedure. 17.2.18.5 External Audit Procedure S a) Preparation for and Conducting of External Audits proceeds in accord-ance with 17.2.18.4.a thru 17.2.18.4.d except that the Audic Team Leader coordinates with the appropriate Project Engineering and Purchasing Per-sonnel and the QAE for scheduling arrangements with Vendor or Contractor. b) Preparation for and coaducting audits of Engineering Consultants proceeds in accordsnce with 17.2.lS.4.a thru 17.2.18.1.d except that the Audit Team Leader coordinates with tne apprcpriate Project Engineering personnel and the QAE for scheduling arrangene:.ts with the Engineering Consultant. 17.2.13.6 Management Audit Procedure Preparation for and conducting of management audits 9 oceeds in accordance 31{.3, subsection 17.2.18.4.a thru 17.2.lS.a.d except tL st audit reports are cis t'riouted to Vice President - Administration and the Manager, R5QA and tne audit team leader coordinates with the manager R5QA fo; scheduling arrangements. 17.2.18.7 Audit File I A cceplete record file is kept of all audits, which provides UE6C and WPPSS Manage =ent with the means to analyze and evaluate the total WNP-1 Proj ect Quality Assurance Program.' 2 17.2.18.8 AL*DIT ANALY M a) The monthly status report of QA audit activities is published by the Manager-Audits with distribution to UE&C Project and Corporate Management. The report identifies QA Audit findings from audits conducted during the reporting period and records the status of ite=s I still pending from previous audits. 7 b) The Manager-Audits uses these reports as the basis for determining. i f5h quality trends developing in the various areas of the Project Quality j -5E Assurance Program. When unsatisfactory trends are observed, the l Manager-Audits publishes a repoct to UE&C Corporate Management with . particular actention to those areas showing the trend. l c) The Manager R&QA pursues resolution of those areas of concern which l indicate a decrease in the effectiveness of the Project QA program. 17.7-41
'4N?- 1 Arandrant 5 i PSAR April 1974 .i i l 6 E* E ~ = lE TABLE 17.2-1 UE&C PROCEDGES - 18 POINT CRITERIA e UELC TITLE 10 CFR 50 Procedure No. Appendix 3 Criteria I QA-1 Organization I QA-2 Quality !.ssurance Progras II yA-2-1 Indoctrination and Training II l QA-3 Design Control III QA-4 Procurement Dccument Centrol IV 1A-3 Instructions, Procedures and Drawings IV 3-Document Control VI QA-7-1, 7-2 Centrol af Purchased.'S:eri:1 Equipren: and Services VII QA-3 Identification and Control of Material, Parts and Components VIII l QA-9 Control of Special Processes IX QA-10 Inspection X QA-11 Tes t Control XI QA-12 Control of Measuring and Test Equipment XII l QA-13 Handlingi Storage and Shipping XIII QA-14 Inspection, Test and Operating Status XIV l l QA-15 Noncenferning Materials, Parts or C ponents XV QA-16, 16-1 Corrective Action XVI' QA-17, 17-1 Quality Assurance Records XVII i QA-18, 19 Audits
- XVIII, MD f.l. 5.
l l t
I w k j!O:t[3 e ' 3 n (>W
- g q(t euD 4
nr i! Qm!d] j o!i la W r t U U U U U U V C N p U U U W n U o C e t u, t ir U U U U U V C N N y U U W ts i D eus U U U U U V C N N y U U W s I tu ms W e U U U U U U U V C N N U U W U lp m I t rop W U p u T s R A l lC ev W W W W U U y o Cl-r. U I. U U e H H U U II W ?. - g U U p I U Y C g 2 I A hl 2 R E 1 T 1 li W W t l wu U W U W W W W U U W y E ec U U L C ie s s e U U W s B l. vn U U U U U U U Y C U g A E e o N N RC T U
- S, er a
l p P
- U U
U U U U U Y C N N U y U U W W-i 't l e t a i t U U U U U U U Y C 4 1 N U y U U W in I y t ni ol pi U U U U U U U Y C N N U y U U W cb ei R s s er ) u d d e s e n t e c n s m o a r o o e i i u r e g ? s t t t d P r en rt t I a s i e u ci s oa i c e n c n s d nl t t t d e i r I o o e e u n cn u r
- a. d c
m f u ( r i r c s e ae A o a a i d P t u o l e en m rm t f r c e s c d r s a lh a gu t u l r n g e c g t u e P g t ccl l ac nc a c e o o t p o n c r c n t ySt al o oo ns s ra t i r nS r i e t o r i i r a isD CD rt t .S or n t P e P w j s r o w m u .t cs en i CSdt S I a nt a o n P t a b S qn eet tnm u e d &P nnS A z A ec A r r o c r u s a pcc Qi Q r a Q D P C r a D S rim S oa rs i u A EP eoS ,.I n ur a r one r r ot c UWVCN C a. C ct C C C C d t S S d nl CPt di C o S Cw:'"i & r on A n n S S nap n nd &. D S
= = =
rr l r o E C E E e o S S el m EA o eu l S uO U PC U U U U V C N N VPI UQC VA U& N UWVCN
M. F. q, 9 ,. m : w.eem a M UtilitD E F4 GIN (Iki & cot 45IRt#CIOR5 ft4C. _I PktSIDItii 2'$ uE m ~4 5$0 l l ?Ea < 0 03 VICE PRESIDENT VICE rat 5tDEHI VICI ratilDi HI g8 mC CONSTRUCIlote POWit Gttit RAllON ADMINiilRAllOta
- > 0 g3 m O 2 o$ G b
I I m E jf
- hh MANAGt t MANAGla "MU pgggggg g m
i CONSTRUCilOta ItELIAkillIY & FilOJECT SUPPORTING - NRC4tA5 LNG = 2 'O QUAtlTY ASSURANCE st3: VICES E.O Q 3 e DivtLOP & MANAGE e rROVIDt PURCitASING
- y Q.A. PROGRAM
& 1XrtDiltNG 5:RVICE sn H e A554Gte O.A. thG't e A554GN DUYt R 10 m IO PRO.Vi PROJE CI 2. l MANAGIR MNA R NAJ R ANAQ R PROJE CI mat 4AGEME NI POWLR ADVAt4CID PLANNING & mHAGt R 51RVICI5 E t4Gitit! EttaG E P4GINEt RING SCI 11DULING l e PROVIDE e PROVIDE e PROVIDE 4Atatair4G & Q ADM;N15tRAlivt (NVIROt4 MINI AL SO E DLAING 5t RV6Cl 5 5t RVICt 5 & 5AttIY SUPPORI e A551Gie rtAt4. & 5CIN D. O . A551Gt4 tiCit45tt4G ING'A IO rROM.I e A554Gt4 5tRVIC15. Q ADMIN!$lRA10R E NG*R IO FROJf Ci O IO PROJECI h N mat 4AGI R PROJECI O it4Gir41ikir4G g h IN1tGRAft & COORDINAli Att tt4GitettagNG e p & Dt5!Gt4 (If ORIS Of PkoJICT N , ($3Attg53g OvtRAtt Distcri EA1.5 At4D y N DCCirLit4E R15 Pol 45leltill 5 O ' filRICE A CONTROL litt a t #Oe:Dat4Allora = e u un p Of DOCUMENIAllote $E [ n e l'ROVIDE IECitNICAt Glelt At4Cf i
- t 2-j rumDE rRO A Ci i Noim nNG rROCtDi 15 i
- =
co r el 03 K mm 33 2 8o
. f !;! ,+ 8 L e N> (n Z k yy o e T -4 .e. y e.. c
- . vi o ess e S.p a.4,.
2 gz= 2 CC Om F r
- m. m -
a-*= p O
- <3 m O
V'C E PE S'DE "I N d * '# E ' D ' ' ' ' ' ' ' ' * ' " ' ~ * ' ' y g POWER GENEhAT40H aba4e.a s a.f d a s so.'4 Bom e o*e.n etut v.o *4 a m. m
- O u*
4 C u 5 E 9 I'< e Z M MANA0IN "M A *4 P - 4 44 a 6J & as h at h4 a *4 & da n el 4 ON8. v sf 4 ed 140*J POWER pgo / d_4 E NG B H E E ftlH(, asa me's t c y a d. s d . pin. i v y l a <.....t a.4 e t-I ett *s os.t es t a,,,,,,,, i.ia. s.t.n. veo a * * * ** ; c.p Psto a t 4 T WNP,4 & aat.e eEE(26 46. QAE ~ Oc
- u p1 O Ca*
> O HW
- P L4 8' F.f ' * **.* 8 d e gANAst R 64ANAGLE M464AGER BAANA6ER 4e J Es de MAlkUAM
@AW @AW @DU o, ENC iWig StuG SEltVIC Eh Eth 9EERING E NGINE titsNG OU "4 01 (PHILA) ( Bob 10N ) . en =
- o
- o H 11 *."
L-fA v +-t +4 = y g VENooit LtseWilil Anact W[LbiNb ih6R. NDE IsELD q A. [3. ?s* 60PV D4Gil. SUPV. ENGR SUPV. D Ell SUPV. ENGR. Ha ,MU
- 2
/ l e.e.. - s. e H *' ) W t p Ad.ui.n.$t r a l e J e '/ 1 rs h n.c a i D. o r. l....i r % J. .i cy v' tn tst aa 4y s t ec hner al D. < c a l.a.n g N
- b. O f'.
(,. .o.., a 1. s... 4 m 2 -1 D3
m.t.. ....u...m......, a esa.s ,,.f d. Sed ef.. a t aett ik 'r o .u.. ir u u..r..... ~. u. L..=o..... .....e o A ndG Wurf souff 0 4 ..,, At,,, .o o e, l 04 A o.r s.4 5c o.d,u.w.id TE .vass e I T l. m. .a Aar...e.. u.. l a u,.ia ...... a u L u,, p.~a.. c . o o. <- l T ..mr c... o. o.. a T'G Cw u .woer.s C & L 4TA SS.g &.4 TlQ'O) & W o =orruv ca. w rr.s. e.a ter 7ttitw A.40 Cou.4.uf 1r ew. - =g.e...,.4v.......or. .. m.1 ,,,,,,,,,,,,g,,,,,,, ~aT 41...a o ei,,o.e..... t, ......<o<.<. u..... j e. <c.u.... a.. u e 44 quiurv murrsace o re.n sia.o '" * * * *'"" I 4 ' .s+ iou er.a a s.w.es.o..ef ..... ~ si..~. .. a -aa u. t< -.. a.. . -u a Do4 r,e,.Ju.t.u.T,C.04 71 6.C.l.w..f E 4 s,. i m 4 ~ ..,~.u....a,.. o .,.....,...s.<.... e 14 S *.e A L..r! M 4T. ou <.. 4 e ft..f1 AT p.is., i,. uw. t, 1P .t .m u. 4 ~,. m y.g;;~o,y .......a,..- mm.. i..., u.wo.a ev -v u-- -< ~. -> --* m- .E YTA44*diffGO fo 14PP 4 l re..uc m ut.a. A.*ts.*rar tuu,utsg 'd "** 'f *d' * *** {'**"***Th 464te.scAvrow T P.T aL&T. o w...g es Laaeso A 0 219e. 4.u wwwf. 8W 6.au.= 6t et i ...c s4&v ow.mansvisi.e.u.a9 c1.iew-r 4. Auttff t.JCS s. t Awo f,TAsoustfs. To a.a. 44 A t t.w.ucLE.A.tt.4 sc.i. 4 A.t.o =. &~ u..u..A.. A, C. A.we I* art CELA5.b0 v.fue a.=fw .J.... A.. fr ov &L $as ATIO *SU
- I *'T t!6'D6uvi T. 1415.C AT e o w A4 t
s e .ttis. CA fto w '*s.ded.w4. g,, ,4,gg ....s. 4..se rtw a s t v a us 4.c w... = awo c ev Gu.onvA.inusue 45rra4-rutta 4 etts o u :::,. s si ev A u s seawe.ow 1 A.J o o ,p ,Jefc on.frfieurs.= Awo rratsa.t ocas.a 4as.tv ge LA v eo e qui u tur or sercier.4 Avio u se e ww p -i f51 DS AMENDMENT 8 . JULY 1974 . s. WASHINGTON PUBLIC POWER SUPPLY SYSTEM ...c: WPPSS NUCLEAR PROJECT NO.1 UESC SPECIFICATION FLOW CHART Prefirninary Safety Analysis Report [ l FIC. 17.2-3 9 .x
o S PSP 3.5.3 Wiip-1/4 PSAR DEVIATICN REQUEST ~ 17.4 4 (WP) Volume 7 Chacter 17.4 5/13/81 CEVIATION ti0. P5AR VCLUME ti0. PARAGRAPH tiO. DATE 1. P5AR CC!<iliMEliT A5 CF 02/19/81 -(LAST AMiliCMENT OATE): (incluce 5AR statement) t%eter 17.4 current 1v describes the Field Ouality Assurance creanization and resconsibilities of United Engineers & Constructors, Inc. 2. OESIREO C;-ANGE: (incicate cesirec statement) Revise Chapter 17.4 to incorporate the NRC approved Topical Report BQ-TOP-1, Rev. 3A, Bechtel Ouality Assurance Program for Nuclear Power Plants, as amended 11 c,4e s e..,. e m.. p e g,........ s.. < - ar --..; bv the att= chad, e o construction; 2) Bechtel Ouality Assurance Precram. 3. STATEMEliT.10ENTIFflNG SIGNIFICANCE OF OEVIATICN: (i.e., wnat is ceing pr:posec that is different frcm PSAR cc:: nit: ant) The chances described in this deviaticn rec;est are re:uired to 1 :le.s-t the 3echtel Peuer Cerceration rescensibilities for Censtruction "weee ent uri n.+= 14 +v S ss ur= nce s ervicae at W o-1/.i. (eveact ee* ame tit. n 4,, 9 _resconsibilities which are retained by UE&C) 4 JUSTIFICATION: (i.e., explain wny the desired cha' ige is justified anc is expected to be defensible before the NRC) This deviation recuast is recuired to reflect the revicad "asc0*'45414'ia' for Ccnstruction Management and Quality Assurance services at WNP-1/4 PSAR acendment is not required as changes described in this deviation do not alter in a non-conservative manner Sucolv Svstem commit ents as delineated in the P533 5. WPPSS APPROVALS: DATE PREPARED SY: kru. a A 'd. m _ y f w.,v o,,, As.-, S SI wriP-1/4 PROGRAli OIR CATE / 'DMb % 4, ) ~ A5SISTANT PRCGRAM O'r.ECTOR, Y N::' NG CATE * / Af u% w ;j.- '2 E/' ( .r -~ AS5ISTANT PROGRAM OIPc' "? %NSTRUCTION DA'iE I V' 6WW [-2/~$ ~r i MANAGER, QA Og,,,g $*-/3 9 / r LICENSitiG PROJECT MANAGER CATE h-QL. A 2-,--,/ OATE MANAGER LICENSING [~ I~N - M ~ O.-.e w nt 51 4
UNP-1/4 PSAR r 17.4 OUALITY ASSURANCE OURING DESIGN AND CONSTRUCTION Scoce: This section summarizes the Field Quality Assurance activities assigned to the Bechtel Power Corporation an.d United Engineers & Constructcrs, Inc., as they pertain to WNP-1/4 Project site activities. The Bechtel Power Corporation has been assigned by the Supply System to provide a Quality Assurance program to implement the responsibilicy of Construction Management and related Quality Assurance services at 1!NF-1/4. UnitedEngineersandConstructors,Inc.hasbeenassignedbytheSuppfy System to provide a Quality Assurance program to implement the responsi-bility of Architect Engineer for llNP-1/4 and Construction Management and related Quality Assurance services as they pertain to ASME III Div. 2 responsibilities as " Constructor". The Bechtel Qtality Assurance program plan is described in the NRC approved Bechtel Topical Report, SQ-TOP-1, Rev. 3A. The Bechtel secpe of' responsibility differs frem that indicated in BQ-TOP-1, in that Bechtel does not provide design, engineering, construction, or procurement services for !!NP-1/4. 9 o j e e 0
I '.* i Ouality Assurance procram i BECHTEL POWER CORFORATION ~ WNP l/4 Ouality Assurance Tonical Recort The Bechtel Quality Assurance Program Plan for use by the Bechtel Power Corporation During Construction fianagement of Washington Public Power Supply System (Supply System) Project WMP 1/4 is described in the NRC - approved Bechtel Topical Report BQ-TOP-1, Rev. 3A, Bechtel Ouality Assurance Program for Nuclear Power Plants. Scoce of Resoonsibility 9 This section describes 3echtcl respontibilities for providing quality - related services in Construction Management to the Su:: ply System on the WNP-1/4 Project excluding ASME III, Div. II activities. The sco;e of responsibility differs frcm that indiceted in 30-TOP-1 in that Bechtel does not provide d': sign engineering, prc urement services nor perfom construction. Therefore, those provisions in BQ-TOP-1 associated with design engineering, procurement services and perfor=ance of construction do not apply. Sechtel will have an Engineering Liaison group under the direction of the Project Engineering Manager available to support the Construction P.anagement organization. Engineering personnel will assist in coordination resolution of generic QA/QC problems with responsible design engineering grouss. interfacing with Supply System licensing personnel; and assisting in engineering /startup interfacing areas Construction Management provisions 'for quality-related services incluce: Receiling including receipt inspecticn of Supply System purchased o items Storage and maintenance of Supply System purchased items o l o Contractor / vendor QA documentation review, retent.n and turnover l to the Supply Syste.n Review and approval of on site contractor quality-related Precedures o and Manuals QA/QC audit and surveillance inspection over on-site centry: tor o activities Administration of the projecc program for controlling ncnconfaming, i o items i { Administration of the project program for control of dt sign d:cuments o j l ProjecL Unique Modification to 20-TCP-1, Rsv. 3A introducticn Page 2 - Replace Regulatory Guide 1.53 (August 1973) o with P.egulatory quide 1.58, Fev.1 (Sect. - 1930). Introduction Page 2 - Add Raoulatory Guide 1.146 " qualification of l o i Ocality Assurance Program Audit Parsenrel for Nuclear Powe 31tnts (Rev. O, 1973)". t _.
Secticn 1 ORGANIZATION Subsecti:n 1.5.1 Page 10 - Add Subsection o 1.5.1 Attachment 1. Section 1 ORGANIZATION Subsecticn 1.5.2 Page 10 - Replace Subsectica o 1.5.2 with Attachment 2. Section 1 ORGANIIATION Subsectica 1.5.4 Page 11 - Replace Subsection o 1.5.4 with Attachment 3. Section 2 " Quality Assurance Pr: gram" S:5 Paragraph 2 & t' Page 23 - o change Regulato y Guide 1.53 (A; gust 1973) to Regulat:ry Guide 1.53 Rev. 1 (Sept. - 1980). o Secticn 2 " quality Assurance Pr: gram Sub Daragraph 3' Page 23 - a change ANSI N45.2.12 to ANSI Nti.2.23. TASLE 1 "Sechtel Quality Fregram Occuments" Page 57 & 58 - Add to Table 1 'the Pref ect Documents shewn on Attachnent 4. ADD Fig. Bechtel Projects Management Organizatien Attachment 5. 15 ADD Fig. Quality As.surance/ Quality Centrol Cr;ani:stica Attachment 5. 15 Sechtel ?csitien en QA NRC Reg;1atcry Guides and ANSI Standards A?:5HDIX A Pages A-7 thru A-13. Delete in its entirety. Division Quality Policies, sec;e, and relationship to 10 CFR 50, AF?ENDIX S Appendix 3 - Add Project. Nucl, ear Quality Assurance Manual as shown by Attachment 7. l 4 i b e,
_~ I ., 1 I ? ATTAC'r:MEi4T 1 4 The Manager of Projects (Fig.15) is :he senior Sachtel re;resen:ative assig.ed
- o the W:i?-1/4 Froject. The Manager of Projects reports to the Divisien Manager of Projects operaticas and services, and is responsible fcr providing everall project direction to assure the ce6sistent and coordinated application of iechtel ;olicies and skills for the benefit of the Wil?-1/4 project. The Manager of Project's staff includes a Deputy Manager of Projects and other managers to coordinate activities in labor relations, the quality program and administra 1ve e
services. l T l l l 1 \\ 7
I, ATTACHMENT 2 1.5.2 OUALITY ASSURANCE The SFF0 OA Manager (SFHO) is independent cf the other managers within the division and has the authority to carry cut the res;cnsi- .bilities listed below in directing the Division Quality Assurance He is assisted by a staff of Ouality Assurance Manacers (SFHO) Program. assigned to functional areas of Program, Training, Project QA, and Audit (as :; hewn in figure 12). The SFFD QA Manager (SFHO) functicns for the WN?-1/4 Project include: Frovide tec%ical guidance and concurrence for the WNP-1/a c Project Ouality Assurance Pr: gram for confermance with :ne requirements of ICCFR30 Appa.. dix 3. Formulate and approve Divisien Quality Assurance Department o Prucedures which d'efine resp:nsibilities, authority and functions cf SF?D hcne office sthff Quality Assurance Department perscnnel. Review and c:ncur with the WN?-1/a FqR4 and revisions. ~ project status, through manacement Maintain an awareness of WN?-1/ l. o audit and day to day centact with the Manager of Quality, and' provide. assis ance to the Manager of Gellity t: assure':1.ely and effective implementation of the tlNP-li4 quality assurance program. Formulate and conduct managszent QA audits to assure c::pliar.ca l with the UNP-1/4 Nuclear Quality Assurance Manual (N0%4) and c j icplementing procedures and :o identify quali:y problems; identify the need for corrective action and initiate, rec 0=:end, ccordinate or provide solutions;. and yerify implementatica of soluticns and I . i ' ~ corrective actions. Provide and caintain a qualified and suitably trained staff of o Juality Assurance Engineers to carry cut recuired project and Assign Quality Assurance Engineer (s) to the staff functions. WNP-1/4 project and provide then with administrative direction f^ thrcugh the qA Manager - Pr:jects (SFHO). Fo~nulate and implement pr grams to provide indcctrination and training of Ouality Assuran:e Ca; art.ent Fers:nnel to assure that o suitacle proficiency is maintained. Frca infor=atien supplied by the Manager of Quality, provide I quarterly reperts to the Manager of Cuality Assurance - 3?C (S?HO) o evaluating the status and adequacy of the WP-1/4 quality assurance program, and advising of any pr:blems requiring program revision or special ettentien including -ecem=endations for corrective i At least annually, a casting is held with the Division actions. Manager (SFHO) and his staff on the subject of status and adequacy of The Manager of Ouality participates in this the Divi:fon OA Progrer.. meeting to cover the status and adecuacy of the WN?-1/4 OA precran. ? age 1 6
MANAGER OF QUALITY The Manager of Quality receives ad=inistrative, technical, and pr: ject direction frem the Manager of P-ajects and is responsible for the project i and technical directica of the WNP-l/4 quality assurance pregram. The the Manager of Quality receives technical guidance f:r QA and QC frc SFPC QA Manager and Chief Construction Quality Ccntrol Engineer (SFHO) respectively. He'is assisted by, and ;rovides project and technical ' direction to the Project quality Assurance Engineer and Project Censtructica (Fig. 16). The Manager of Quality is independent Quality Control Engineer. of the other line managers within the Project Management orps.nizatica and nas the authority to carry cut the responsibiitties iisced belew in dire::ing the Quality Assurance Program including authority to st:p work er c:ntrol fur:her processing. The Manager of Qus.lity's functicns include: Provide technical and project direction to Quality Assurance o Engineers assigned to the Supply System Projects. For=uiate and approve, after review and concurrence by the o SFFD QA Manager (SFHO) th6 Supply Systen Frcjeccs SAR and Quality Assurance Programs as defined in the NNP-1/4 Projects The NQAM's shall Nuclear Quality Assurance Manuals.(NQAM's). be in confermance with the require ents of 10CFR50 Appendix 3, the BPM Quality Program Policy Manual, and the apprcpria:e Pr: ject SAR. For=uiate and appr:ve, after reviert and cencurrence by the SP?D OA o Manager (SFHO) the revisiens to the Su; ply System Projects SAR's and Coordinate revisions to icplementing procedures to improve NQAM's. effectiveness of the quality assurance program and update the program. Formulate and approve, after review and concurrence by the SFF0 QA o Manager (SFHO) the Project Quality Assurance Department Procedures and revisions for Supply System Projects which define respensibilities, authcrity and functicns of Supply Systan ?-:jects Quality Assurance persennel. Msintain an awareness of project status, through contact with the \\ o l Manager of Projects. WNP-1/4, and assure timely and effective implementation of the cuality assurance pr:; ram. 1 l I i Page 2 I ( ( 9
I i .i Direct the performance of project audits to assure compliance with i o Supply Systan Project MQtit's and ircismanting crocedures, and to identify quality problems; identify the need for corrective actica and initiate, recc= end, coordinate or crovide solutiens; and verify implementatien of solutiens and corrective actions. Provide quarterly reports to the SFFD QA Manager (SFHO) evaluating o the status and adequacy of the Supply Systam Projects quality assurance program and advising of any problems requiring progran revisien or special attention, including racemmendations fer corrective actions. Review Divisier standard criteria for specifyine cuality assurar.:e o program requirements applicable to contractors and subcontractors, and approve for use en the Cu; ply System ?rojects, Coordinate the Quality Assurance and Quality Control functions for o the Supply System Projects with the Division groups having quality functions, and with groups cutside the Division having quality funccions, e.g., M&QS, C&S, and FSQD. t 0 5 e e e I 9 esce 3 e a k o
ATTACHMENT 3 1.5.4 DIVISION CONSTTdJCTICN The Manager of Division Construc.tfon (SFHO) provides technical and administrative direction to the C:nstruccion Cesartment The Manager of Divisien C:nstruction (SFHO) is assisted personnel. by Construction Managers (SFHO), Chief Constructica Enginee-s (SFHO) where a: signed, tai the Chief COnstre:tien Quality Control Enpineer (SFHO). Constructicn !!anagers (5FHO) are respcasible for tre canagement and technical directi:n of assigned pr0jects, 'and for assuring that constructi:n proje:ts are pr:vided with appr:;riate personnel and are folicwing prer:ribed divisien practices and pre-cedures for conduct of construction activities. Chief Constructicn Engineers (SFHO).are responsible for providing division standard work procedures to the projects. Fomal quality verification inspectica and onsite centra: tor surveillance inspection activities performed by Bechtel are the responsitflity of Construction Quality Centrol. The Chief Ccnstruction Quality ;catrol Engineer (SFHO) is responsible f:r pr:viding administrative directi:n i to the C:nstruction Ouality Centr:1 Ingineers assi;ned to -he UN?-1/a ?rejec. The Chiaf Construc.icr C a:i-- 2n r:1 En-instr's (5FHO) func:icns include: Provides ad.7inistrative direction te the Project Cens ructicn o Quality Control Engineer. 'l Assigns quality c:ntrol engineers to the project. i i o Assists with the training and qualification of constr2:tien i o quality con +.rol engineers, i Frovides technical guidance to the Manager of Quality fer tha o preparaticn of quality centrol procedures and instructicns. l i l i I * { l I ' f i I I l i t I i l I r n w
...___._n______.... All AulHtlli 4 TMi'. 1 titlP-1/4 Pit 0 JECT QUAll1Y Pit 0GRAli DOCUtiEllTS Originating iteview for 0A Policy and Autliorizing Docunents Anihority Program Requirements Approval Contents llNP-1/4 Project QA SFPD_QA Hanager (5f!!0) lianager of Quality program policy. Based !!uclear Quality Engineer Quality on Division policy as container Assurance fianual (IlQAli) in SFPD Standard liqAM 4 HilP-1/4 Project QA SFPD-QA llanager (Sfil0) Hanager of Procedures for conducting Quality Project QA Engineer llanudi (PQAti) QA activities s s litiP-1/4 Project Project QA Eprelocer llanager of flesponsinilities and procedure Construction Construcilon Quality for Construction QC activities Quality Control flanual (CQCl) Quaiity Control Engineer b UtiP-1/4 Field Construction Project QA Engineer ClaicI Con-Responsibilities and requireme ' struction for construction management si Construction lianager Cng!neer. !rocedures (5f110) activl'.les W 9 9
.O><= Cc e cO l C l m T s w ! U W=) M U uw 5' u, '9 w e r. v = .P o=- 3 c<= g .*a .C= C v J g v.t U U ~ 4 =* -C C ""* [ ~ C = = c.:= =J g N = W== v h i 2" 6! >= W = y g
- P E
"E 5 ~. I = Y 3-el 3 = = u, a .= L. o o L.a. ts L O W W D l.J 6 kJ W = C >= _= I U. M H l< C A = 0 c ~ .= 4 n e ~. y 7 C M F '"= L 'd O_ d 1 < = = U = c w c .a ~ L c. "2 = l b m v2 m O C C l'I w w c c = C a U C O 3 I [ W .= l r Cu-I. v m. A **
- =
N-, g m 1 . e,,: ./ p l U. 'J Q Y d l = C. a iJ 3 I d. L I"'" 'W-5 = v. = c >. 7 = I >.L - = = E4' C j - A< O
- O s.: <
L I 2,. u e
== u < =, OC< .E 2 = c= F /. o-C -f .=w c.3 O C kI - = > = i en < ~ = f,I r= l -= i l ; >w I 5 ( 5 ~ 7 ~ :- ~ C I O 0 g l , l e l A 4 2 J ,M,, mo C== c3 >== 6 l. .,J a
== e d 9 \\ l 1 g U i l l Uw w C'W "'3 < b C=C CC $ 3 ~ 1 =~ i i i I I s' e e e-~ p-e --- ,n--,
Attacionent 6 STPD SFPD Chicf Constructio i QA ilANAGEll Quality Control (Sfil0) Engineer (Sfil0) A l O. ^ I I I I O IlAlincl.It ) i_________..-- 0F. qual.lTY ( g O I) t O ) O j O i O P!10 JECT Pfl0 JECT QUALITY C0flSTittlCTlotl AssuitAtlCE qual.ITY CotlTitol. EllGillEE t EllGIIII:Clt 1.EGEND AllD 110lE tt0TE: The SFPD QA Hanager (SFil0) is responsibic for perfoniting management QA auslits of tlie tillP-1/4 l'roject. Pit 0 JECT Ai10 TECllillCAL Dil(ECT10fl Quali ty Assurance / Quality Conirol TECil.'llCAL GulDA lCE AtID C00llDillAT10ll Organization -O- -O-ADilillIST!!AllVE DillECTI0ri Figure 16
$.I Hji iiii!!;i i fi 2 c i s-mu um mma ..:::.n e n n :v cxy :- m s '. l, ie! I ! l 4 I i i i I I l!! ! i i i: I j m e n et=v u:w e !.I i i iiili;iii i m===mun=wn;-i IiilIIIIIIliiIe !. t.1lijelIii!l.!IIii n== m=seu.L D- ='==i-IiilIIIIIll1111l1
- == m n= = =rm k'i l l l l l l l l \\ l I I I l lel i m emm: c=vm== l-i.liIIIIilII!lIIIi
.mmm.a ne=m =uern =w=l-lllllliillll>!l!I! ims: n = n==u m:x Li i i.I ! I i l l l l l l lj!lll
======== c=u W IIIIIIIIlolI;IilIi1 11IIIlllll,i. I I. i. i : u=..= s. I u= m um,m u
u
========== i-i llIIIIlallIIiil.loll m:ca m=u,= =u l-j l.1 l l l l l l I.l.1 l j l [ l-l lol.ll,1,,.!. ..I:...i .-mm,s=m =,==m. l a: i 4 i i m u m.=n v:mm e =55 Hide"E l-1 1 1 !.l.: 1Ii1.!I11!!!
==<=um =u=u l-f H I I I l ! l l l l 1 1 l l l l l
== I ms mum, =u=u H .i i1.11111;Il!!l!ll q_'c',lj!.! ! '. '. i i i,i., uu :::n:.:2 =:=u ,i I _,i mu==vm =mu :- fi c i lIl11 I!Ii.Iiitil =u===n==re=muF 3 1IIIIIIllll l l l l-l umm eu cu= u m l- .IIillliilllllllij, m u m m..
====v==a H lel l l 1 1 I I I l 1 1 I l l l l
==ca:l-llalIIillIIIII!IIiii el.i.Ii i i i i i.Ii i li . i i. > i, i cm m=u
==.*f*4*f fY 11:~v.*.3 I' I I I i I { l l l { 8 =: " 1-MM # G # # l- 'H.I I i i iliIIiiiI;i S i s===an=l 5 Illlllillllillill 9 _i a a = . 'b :L l m
- i tr..
E -g 2 :
- Li-l 3 :==
1 [ 5 y.. = Et a 47=. 1-UE
- U l25$
I E E $. dI a:pi ;l ifieE!tC. !43 =d2!I = g 5 0 x dei l a Esi .: 3 8 t-y ; E 3 4 $ !. ; p$ 09 ) r". E' ] 5 8k ): $ f. t Ei P E
- " h'*,E't.
- f.'
, h..j. j p =ts
- *82 CM OC=
M Et ' 5 w'g =as e %!4 3 1: g: 3
- : =
_3=. 3 = ,W iii'-%, El E *:: E 5 E5: 5 .l -9 J l ~; g I O 2 l ; -j m, g ) u, q - ,t 5 2 a f-a a w g &g = ,q jJd: -1.Es 2 ". j _(!j l_= I -o ?, iII .li'l
- t::
3 ;,2 ,j p _ ,- - I e I e e. y._,- ,~.,-.~-,,.w--
i PSF 3.S.3 t-Rev. 0 ...../, 4 a s.- 5 FSAR DEVIATION REQUEST 17.4-5(WP) 7 section 17.4 6/3/81 OEVIATION N0. PSAR VOLUME NO. ? ARAC-RA3M NO. DATE 1. PSnR C0:44!TMENT A5 0F 2/75 (LAST AME:.0:;i:.I OATE): (incluca SAR statemen 1 i Section 17.4 - United Engineers & Constructors Quality Assurance During Construction (In It's Entirety) l 2. DESIRED CHANGE: (indicate desirec s atecent) i \\\\ Revise Section 17.4 to limit the secpe cf IJESC's C nstruction !!anagenent QA responsibilities to the Quality Class 1, AS:'.I Section III, Div. 2 Project l Activities. 6 3. STATEMENT IDENTIFYING SIGNIFICANCE OF DEVIATION: (i.e., what is being proposed that is different from PSAR connitment) There is no chance in erevious PSAR cer ritrents as the r cert 31-te the Ar n-l See:10n III, Div. 2 Activities. 4 4 JUSTIFICATION: (i.e., explain why-the desired change is justified and is l expected to be defensible before the NRC) i' .,,. y This PEAR deviation is required to a:curately refle:: the transfer cf I Construe:10n Managenent GA respens ' 4 -d as frc= '.IIC to Bech:el. S. WPPSS APPROVALS:" 0 ATE - PREPARED BY: I N M rwX G-3-8i W iP-1/4 PROGRAM 010"C. CATE,Me ./, ASSISTANT 'ROGRAM OIP2 TOR, ELSEER::iG DATE, -a n v ' ;) % W fI ASSIS p R ad TOR, CONSTRUCTION DATE [w ^ - 6-ze-P/ DATE MANAGER, QA Mgey g efs /Jh n-ek 4-17 4 ! b~i '#$l' LICENSING FROJECT MANAGER DATE W D^& b-ls. 9-) DATE MANAGER LICENSING $ /oJ.-t n &8 / c---
2 w WNP-1 PSAR t 17.4 United Engineers & Constructers Quality Assurance Durin; Construction i 4 Scope: This section summarizes the UE&C Site Quality Assur-ance program as it pertains to the WNP-1 Site ASME Section III, Div. 2 activities. The Project Quality Assurance Program meets or exceeds 10CFR50, Appendix 3 and ANSI N45.2-1971 requiremente. This section des-cribes that portion of the ::: quality Assurance program for the project with respect to the receiving inspection and construction QA activities for the q WNP-1 ASME Section III, Div. 2 Equipment and Struc-i ture at the Constructicn Site. The UEsc design and procurement QA related activities are included in Section 17.2. The term " site contractor" as used throughout this section refers to those contractors having construction site activity responsibility .for providing WNP-1 ASME Section III, Div. 2 Equip =ent and Services. 17.4.1 crganizaticn The Project will maintain an independent Site Quality Assurance organication. Perscnnel performing quality functions will not be responsible fer performing the work which they are inspecting nor will they be res-ponsible for performing the. work cver which they are providing surveillance. ---cry
- The Field Superintendent - Quality Assurance (FSCA) reports to the project Quality Assurance Manager (PQAM) and is responsible for the on-site implemen-l tation of the QA progra=.
The PQAM has access to the manager Reliability _and Quality Assurance thru the Assistant Manager R & QA. The FSQA is assisted by a staff with experience in the various disciplines in-volved in the ASME Section III, Div. 2 activities. The Field Superintendent Quality Assurance qualifi-cation requirements are: 1. Education - Technical degree in mechanical, elec-trical, civil, nuclear er metallurgical engineer-ing, or equivalent, plus special study of quality assurance and centrol techniques, testing and inspection methods. , ~
4 .I. i e'! WNP-1 PSAR I. i 2. Experience - Ten years of related experience 'g in responsible engineering or quality Centrol positions =ay be considered equivalent to I required technical degree. A cinimum of five years experience as a Quality Centrol Super-visor or Engineer or the equivalent in respen-sibility and scope, is a prerequisite for the pcsition. T i T ) 4 + i l l -g - 4 i i -la-f t I i __,.._-..,_...._-.,_..-.-.,-_.u_._..-,.__-._-.-.
tc;p-1 PSAR 17.4.1.1 Site Quality Assurance The Site QA Organization is supervised by the Field Superintendent Quality Assurance and includes Ingi-neers knowledgeable in all phases of construction, quality assuranca and quality control. The Quality Assurance interface with Ccastructicn Management is shown in Figure 17.4-1. The Field QA Personnel are responsible for these activities: a) Plan, develcp and i=plement audits of site con-tractors. b) Develop receiving inspection check plans for pre-purchased equiprent. c) Develop surveillance check plans for censtruction activity. d} Provide surveillance over material storage, handling and control activites. e) Identify and document ncnconfor=ing caterials and conditions. f) Frevide receiving inspection cf pre-pur:hased items. g) Perfor= surveillance and audit of site contractors, h) Provide site QA liaison with client, Ingineering, __,,7g7-Ccnstruction Managccent and Sito Centracters. i) Assure necessary QA documentation has been provided, reviewed and approved by appropriate pers:nnel. j) Establish and maintain site =2 ster Quality Assurance Tiles cf records generated by Site QA or turned over to Site QA by others. k) Provide those inspecticas requested by Construc-tion ::anagement to verify quality of c:ntractor
- nstruction.
17.4.2 Quality Assurance Precram The quality Assurance program is cceprised of these planned and systematic actions responsive to the ap-plicable requirements of ASnz Section III, Div. 2 10CFRSO, Appendix 3 and A!;SI ;i45.2-1971 necessary to provide adequate co.nfidence that Safety Related Structures, systems and ::=ponents will perform sat-isfacterily in service. The Nuclear QAgpanual.and change,s thereto will be subject t appreval by the client..
e t s h3P-1 PSAR 17.4.2 Ouality Assurance Program (Ocntinuedi The nuclear QA manual forms the basis of the Quality Assurance program and response to the ::RC criteria fer site implementaticn as folicws: 17.4.2.1 Response to NRC Criteria a) Organication The Project will maintain.an independent Site Quality Assurance organication. The Field Superintendent Quality Assurance (FSQA) reports to the UE&C Projec Quality Assurance Manager and is respcnsible for the on-site implemensation of the QA program. The FSQA reports directly to the PQAM in all quality matters. The Project QA Man-ager has access to the UE&C Manager Reliability and Quality Assurance througn the Assistant Man-ager R & QA for administrative directions. The FSQA will be assisted by a staff of experienced QA Engineers in various technical disciplines. The organicational interface of the Sita QA group is shown en Figure 17.4-1. Site Centractor QC crganications will he reviewed and approved by Site QA prior to implementatien of the contracts. b) Quality Assurance Program The QA Program as described in the Nuclear QA Manual established 'for h'Up-l censists of speci-fic QA requirements to be carried cut within Project QA's predeternined secpe of work at the site. UE&C will require site contracters and suppliers providing Quality Class I equipment to implement Quality Assurance programs that are in compliance with the applicable criteria of ASME Section III, Div. 2, 10CFR50, Appendix 3 and ANSI U45.2-1971. c) Design Control i Through a planned system of review and approval cycles, design changes and censtruction revisions will be controlled. Errcrs and deficiencies in the design change precess which adversely affect safety related structures, systems, or components 3 will be documented and the proper corrective action taken. Design and specifications including field changes, will be subject to the same design centrols applicable to the original design. _3-
I....... + ' '
- WP-l pSAA 17.4.2.1 Eas:::se to N2C Cri artz (C ::i=ued)
O d) h::curece.: De e t=er.: C:::rol Site QA vill i=ple: :- a 7:cgra= ci cc::::1 c've: site ec=:: actor p:ccure=en: docu=en:3, p;ccessi:g a d cons::ue:ic: p ccedures in c:de: tha: Cc:- l
- acto: Quality Assurance p:cgra:s, as specified, are censiste:: vi:h :he apprep:da:e p::visic s j
of '10CT?.50, Appe: dix 3. The details of :he cos:: actors p :grs= for spare and replace:e : 1 i parts vill be reviewed for c =pliance vi:h :he j Co:::ac: Specifica:1 s. 1 e)._I:structions. ?:ocedures, and Dravin:s l ~ The ? ojec: i:ple:e :s a p:cgra= cf c:::::1 eve: Site Co ::ac:c: p;ccesses and ce=s::ue:1c: p: - cadures, i:strue: ices a:d dravi:gs :.o assu:e. tha: all quality rela:ed C :::ac::: a :ivi:ies are cc ::olled. Audi: a:d surveillances of these ac:ivities will be perfor:ed := verify these activities by S1:e QA. f) Docu=er: C ::::1 ?:cvisies f : :ain: ens:ce, app;cval, reviev, dis-
- 1*:ucies, fd g, upd.ating, a:d :::1::ri:g of C ::: actor ap' pit:able do:::en:atics vill be i=pl~ =ested as a resul: of the ?:oj ec: a:d C::-
e
- actor Size QA ?:cgrs=s. Doc==e:: files vill be cc : rolled and :ais:aised to preclude the inad-ver:en: use :y the C::::ze:::s cf obsele:e or superseded docu=e::s. Decu=e:: c:::::1 sys:e:s vill be established a:d i=plemented by the Ce -
- ac:c:s i= acec:da::e vi:h C::::ac: Specificatic:
require:e::s. g) C::::el of ?urchased M2:arial. Ieui:=e : & Services _ ~ I:spectio:s of =aterials and equip =es: a :he c= structics site vill be perfor:ed is ac:c da::e vi:h pre-de* - ' ed 1: spec:ic: 1:s:::::1::s p rio: :o their use. ?:oj ec and Si:e C::::ac::: ~ -proceduras vill also p:cvide for audi:1:g and su:reillance activity :o assure :ha: c.uali:v. require =e :s for accepting a:d releasi:g sa:arials -a:d equip =es: including =cace:f=r:ance ac:1vi:7 is bei=g i=ple:ented. C :::cl of rece ds vill be in ace :disce vi:h 17.4.17. e - 4. (.. 1 s e
- .eum emmen m e
.e e y p-w-w p-gr -.as y 9 9 -+,, -w y.a ,.w.ut -e yif. m-r-- r-
1 \\ 1 h7;P-1 l' PSAR 17.4.2.1 Response to NPC criteria (centinued) l h) Identification and Control cf '4aterials, Parts. and co=conents I, ^ ) Identification and control systen.s using tags and stamps will be employed where appropriate at the site for pre-purchased and Centractor purchased 3 materials, parts and ecmponents to provide iden-tity and traceability of the status of materials, parts and compenents thru storage and release fer installation. Verification cf the correct identi-fiention cf these itsms will be acocmplishel in the program pricr to installation. t 1) Control of Scecial Processes The Project (CE&C) will not perform special pro-cesses during construction, but the QA program imposes the applicable controls of processes and personnel on the Site Centractors. Special pro-cedures and requirements for the qualification and certification of the process and for the personnel performing these processes will be im-posed. Site QA audit and surveillance of these activities will assure that the contractors are conforming to their approved procedures. Occu-mentatien and records will be retained and maintained current and active. j) Inspection -*=re? ' Site inspection activities of site contracters affecting quality will be verified thrcugh surveillance and audits of these inspections of materials, parts and components when received, handled, stored, and installed. Procedures and instructions will be implemented te assure that receiving inspections, construction inspections and final acceptance inspections are conducted by qualified site contractor personnel to verify acceptability. Initial receiving inspection of pre-purchased ACME Section III, Div. 2 material, parts and components will be conducted by Site Quality Assurance personnel to assure, through planning and imple=entation, the acceptability of the i material / equipment received at the site.
9 i r.- EG-1 p.e.: a.. 17.4.2.1 Res cese te N?.C Crite:La (0:n-inued) k) Tes: C::::31 .The QA progra= for Ies: Cc::rol is deli ea:ed in the Contract Specifica:ic: 4:d p cvides for :he perfor=a:ce 'of :es:s i: ec=for:ance vi:h I:gisce:- ing and C st :::10: practices.a:d code require- =e:;:s. 5:orage :es:s, =easuring a:d tes: equip =e:: tests, receivi:g tests,:stalla:i:: i
- ests, a:d -other field :es:s a:e typical of these tes:s perf::=ed by qualified pers:::el.
p~r e-cpera:i::.".'. a i p :f: a :.s ::::::. :s:s are in acec da:ce vi:h Chap:c: 14 of this pSAp..
- 1) Centrol of Measu-ize a:: Tes: I:uiere::
- he o
All =easuri=g a:d :esti g equip:e:: esad a site to dete==1:e :he a:ceptabili:7 cf =a:erial, equip =e:: or 1:stallat': s, vill be under cc ::cl of a si:e calibrati = progra=, ".:h calibra: Lens perfor=ed agains: s:andards of k ov. accuracy.. The sys a= es:ablished by :he Qi p::gra= cc::::ls, calibra:es and adjus:s :hese :: ls, gauges, i:s::::e :s and c:her i:s;ec-1::, :s as u.:i.n g, testi:g and =ai::e:a ce devices used a: : e site. - ~. The systa= v.'_11 also ce= :el the usage of :he p :per type, :::ge a=d accuracy cf the aas. a:d tes:i=g der ces 1:cludi g records and dt =e::ati: pertai=1:g thereto. 1,
- ) Ea dline. Stera:e. and Shi::12:
.S::: age, prese: ::1:, handli:g, a:d clea:1:g i ac:1ri:1es a: the size are c :::011ed by a QA progra= ad=i=is ered by ec ::acters at the n'-l - Size. Each si:e c::: a :c: respcusible for ad ' 's:eri=g :he s:crage of site =aterials a:d equip =en: p cvie'.s v:i::e=, app::ved precedures 'o defi=1:g their progra= 1: :e==s of s:crage '=- ~ spec lon, :ai::eca:ce, handi' g, su:seilla:ce a d records activi ies. Periodic surveil?.ance a:d 1: spec:10: of s:c: age rece:ds vill enable Si:e QA :o verifv, the adequacv, of :he c::::31, esa=ica: ice, review and #'M:s procedures.
- ) Inseec:dce.Tes: a:d Ceera:1== Status The QA progra= pr: vide.s =ea:ures f:: 1: dica:ing the s: acus of :es:s and inspectic s perf :=ed c
=a:erial, par:s a:d cc:pe en:s whe: receired,. M a O a O .e e. e.e .n,.-- ~.--r
) I l' WNP-1 i PSAR 17.4.2.1 Rosconse to NRC Criteria (Centinued) n) tested, inspected, stored and installed at the construction site. The status of the item is established by a Project system of tagging which, l when applied and recorded, prevents their inad-vertent operation and precludes the inadvertent by-passing of their inspection and test require-ments. C) Nenconforming Materials, Parts, and cer_:enents The QA program provides that Site Centractors identify, document, segregate, review and dis-pose of noncenforming materials, parts and ecm-ponents at any stage of fabrication, erecticn or construction to prevent their inadvertent use or installation. Nonconformances detected either by Site QA or Site Contractors are initiated, cen-trolled and documented in accordance with an ap-proved precedure. A Nencenformance Review 30ard will ha autherized ta cen:r:1 site deviatiens and will be represented b' he; site pers:nnsi frem WPPSS and UEIC. The program cisc provides for the reinspecticn of all site affected activities to clear i nonconformances. p) Corrective Action The QA pregram provides for the identification, documentation, reporting and dispositiening of ~"""I?, those site c:nditions adverse to quality. These site conditions adverse to quality are determin-ed tre corrected to preclude repetition. The contractor implements an approved program and i responds in a timely manner to his own corrective action requests or to Site QA's. The program also prevides for the impleccntation, verification, and analysis of corrective actions and assures man-l agement action for lack of response. g) Qualit/ Assurance Records t Site master files of QA records will be maintained and controlled by Site QA. The QA program also provides for the accumulation, organization, cus-tody and retention of QA and QC records by Site Contractors as referenced in Contract Specifica-tiens and the Nuclear QA "anual. Records will j also be reviewed, filed, stored and retained in l -accordance with approved procedures, . 1
.~ 'w'N?-l
- o. S..,
17.4.2.1 Resocese :o NRC Cri:eria (C:::inued) q)
- o pr: vide c::;1e:s and acceptable "Tu:::ve:"
docu=e::stica packages. Records. vill be iden:1-find and filed :: ; : vide accura:e retrieval whhou: delay.
- ) Audits
~he Audh Pro 5:a: a: :he si:e p::vides... regula:ly scheduled and u: scheduled audi:s of si:e qualhy p :g:t=s :s verify c::;112:ce
- h' app :ved QA 1:d QC ;;;ced::es. Audi:s of the cc:::ac:: s c::s::ue:10: and ins:Alla:ic: ;;a:-
tices vill assure ces:: actor 1:ple:en atien and c:=pliance vi:h :he require ents. Audi:s vill - be perfe::ed at :he site to verifv. the activi-i ties of ?:cj ec: C::structics Ma: age =en: and Si a QA are consis:en: w hh :he. app :ved.p:ccedu:es and docu=en:s governing their size activities. Record files of aud.3.:s vill be kep: to provide ?:cjec: Manage =en: vi:h a =eans-: analy:e and evaluate the c::::ac::: effor. 17.4.3 Cesir C:::::1 The ?:cject, th: ugh its de: tiled p::cedures fe; i=;1e=enting design ec:::el c the *J5?-1 p cj ec, pr:vides the assura:ce ~'
- ha: field design ac:ivhies-of safe:y related he=s are carried cc: in a pla: ed, cc:::elled and orderly =a::er.
The d::ig activity 1: the fi' eld vill be essentially i=plementa- ~ . ties and cc::::1.o.f desh: changes ici:iated i: :he field. All field design changes vill be evalua:ed, reviewed a:d app::ved y in accordance with app::ved hgineering and QA p::cedures a:d vill be subject :c s' a: desig. cc:::01 as :he basic design de e.::est. 17.4.3.1 Field Deste: Chaeres a) Design changes initiated i: the field vill be subj ec: :o a ec :::lled p ccedure of 1:itia:10, evaluatics, review, sig:-off a:d i=ple:e::a:ic. All changes a:d devia:ie:s f::= :he origi ai, desis: Vill he I*vitVed f: i:7EC: C R511 7 ces::ci, quality assura:ce and c:de require:e :s associa:ed '-1:h :he i= pace on :he design speci- ~ fica:ics. Si:e Q'nli:y Assurance persensel vill review such changes and the resul:i:g QA/QC i= pac:. i e e 8 - s, s e S g
- e*.
O e
- ----=
r-w-
WNP-1 PSA3 17.4.3.1 Tield Oesien Changes (Continued) b) Approved revisions to design documents will be distributed to Cens :::ti:n Management, Site QA, 'g and Engineering persennel via standard distribu-tion lists se that approved changes will be timaly. c) Errors and deficiencies developed as a result of these design changes which are found :: advars C-affect safety related s-- --"-as, systa=s and cemponents vill be d::umented in ac:crdance with 17.4.13 and corrective ac:icn taken in acc rdan:e .,i .4.h .,..%._o. 1 17.4.3.2 Chance Reecrds a) Cesign documents, field design reviews and design change records initiated at the site will be collected, stored centrolled and caintained in accordance with written precedures, 17.4.4 Procurement Occu=ent Centrol g i che 7 reject implements :ntr:1 Over Site Centra:ter rceure-ment d::uments thr ugh detailed A precedures da: ribing these l activities. Site Centract:rs who perfer= werk en Quality Class I items will suh=it for appreval by site QA their Quality ~~ Assurance progra: which will he :::sistent with the appr:pri-ate provisiens of 1CCFR50, A;;endix 3. Che survey and re- ,l view by site QA of site C:ntract=:s qualificatiens and QA programs are governed by the ::cclear QA Manual. 17.4.4.1 Precurement S_ecifications W:s?-l Centract Occu=ents.::: vide those design require-l ments, Quality Assurance previsiens, Supplier bidding l, requirements, and general c=nditiens fer equipment delivery and centractual requirements, which are pa:k-aged to p* vide ec=plete definition of the C:ntract:r/ Cwner/In a neer respensibility for the purchase of ~<.'.;P-1 Ita=s, materials and services. Che vendor and contrac-ter procura=ent documents selectively apply applicable Quality Assuran:e require:ents en their sub-vendors :: reflect basic centract QA requirements. 9 17.4.4.2 Site Centracter Occu=entation a) Che Nuclear QA Manual contains steps to assure th+t-e e e r -,..-7 ..w. u ~., _
WN?-l PSAR 17.4.4.2 Site Centracter Occunentatien (0:ntinued) a) the Contractor purchased equipment p::curemen: documents for Quality Class I equipment indentify those criteria in 10C77,50, Appendix 3 that must be complied with and described in the Site Cen-tractors QA Program. The details of the Site Centracters QA Progra= are suh=itted with bids and reviewed in ac erdance with subsections 17.1.4 and 17.2.4. b) The Quality Assursnes subsecti:n in the technical c.-.>.. c....,....,.. 1...a--........ -, n..a.a : n.. - e tiens specifies to the Site Centrac =r, these processing and constructica submittal requirements and the ad-4".istrative sub=ittal requirenents relevant to the Centract GA requirements. 17.4.5 Instructions, ?recedures and Crawin s Provisions are made for assuring that all quality related activities en structures, systens and ec penents within the Site.uali:v. Atsurance.::cira: sre.:erformed in a:: r-c dan:e with written instructions, appr:ved precedures and issued drawings. Each Site C:::ra::::, in his Quality Centrol progrs=, will picvide similar ec.. trol in verify-ing installatica cf structures, syste=s end :: p:nents --e at the C: structica Site. 17.4.5.1 7:ceslurcs ""'~7 7 ~ a) Che Nuclear CA Manual is distributed and centrclied as defined i-the manual. All field changes :: the manual will he issued threugh =-d -aviewed by Site QA pers:nnel. In this way, cent:01 of the W"?-l Nuclear.QA Manual remains within the Site Quality Assurance Cepartment. b) Cenatructica Precedures and Instruction initiated by each site Centrac c: at the site provide clearly l l written docu=ents for perfor ' g quality related activites during the W"?-l proje:t c:nstrue ica effort. These will be reviewed, c 'rected and up-dated to reflect changes in censtruction practice while =aintaining ce=p"iance with the quality re-quire =ents. Instructiens and precedures which pre-vide directica in accepuing er rejecting quality related werk are reviewed by Site Quality Assurance cersennel to assure that acceptance criteria have been included and clearly described. 1 O ? e a ,,p-
4 WNP-1 PSAR 4 17.4.5.~1 Procedures (Centinued) c) Site Quality Assurance will p cvide an audit and surveillance functicn to verify that activities are bein; performed in accordance with applicable instructions and precedures. 17.4.5.2 Drawines a) Written instructions governing the review, apprev-al, release, distribution and revisien of design dr -rings at the site will be develeped by Ingineer - ing. Thess precedures will p c tide fer the 000r?.1 ' natien and approval cf changes, thcrecy =aintaining control of the WNP-1 project design interfaces and equipment ec." figuration. I b) Irrors.and deficiencies which adversely effect safety related structures, systa=s, and ce=ponents discover-ed during the construction and installation precess will be documented and resolved prior to incorpora-tien of the change into the drawing. 17.4.5.3 safety Re'= =4 c-- ents a) Ccnstruction Ixperiences published by the Nuclear Regulatery Cc==ission are =aintained and distri-buted in the same manner as NRC Regulatery Guides I eer 17.2.5.4.a The, review and censideratien of I O 1 these occurrences during constructica cf nuclear plants, as they impact the WN?-1 project, is in ~ acccrdance with written procedures as defined by the UI&C Licensing and Envirennental Section. 17.4.6 Occu=ent Centrol The surveillance and audit responsibility cf Centracter site document control at the constructica s.te residas l-with Site Quality Assurance. Iach Site Centracter will I =aintain their cwn decu=ent centrol center fer the re-ceipt and distribution of documents pertinent to the applicable centract. Site CA will audit each site Cen-
- acter's Cocu=ent Control System.
17.4.6.1 Decu=ent Files . a) Site Centracters will distribute docu=ents to the work location for use at the work 1ccation under a ' carefully centrolled syste= cf logs, receipts, 9 \\ I i
f WNP-1 PSAR 17.4.6.1.0ccu=ent Files (Centinued) a) and audits by centracters Quality Centrol. Site Centracecrs' document centrol s,' stem will also include as a mini =u= p:cvisicas for =aintenance, approval, review, distribution, filing, updating, and =cnitoring of their applicable documentatien. b) Site documentation files will.be ec= posed essen-tially of centractual QA decu=ents pertaining te each site contract. Typical docu=ents controlled at the site will inclufe Oesign Specificatiens, Manufacturing, Constructica and Installatica Orawings, CA ? cgra: Manual and Operating Frece-dures, Test Precedures and Manufac;uring Inspec-i f tion and Testing Inscructions. The document ] file will be updated Lnd maintained, as required, thereby providing ec=plete contract historical QA data. Site Quality Assurance will =aintain the Master QA Reccrds file as part of the site records responsibility in acec: dance with subsection 17.4.17. -- ;) Docu=ent Coatrol of Centracter site files will be verified by project Quality Assurance audits to =easure and evaluate site Centracter, Construe:ic: Manage =ent and Site QA cc=pliance 6ith this criteria. Site Quality Assurance will audit and survey re-vised drawings and Ingineering and esign change repcrts against actual field work perfer=ed for accuracy. 17.4.7 Control.cf Purchased Material, Icui =ent and Services -e- ~ 23ceiving inspectica cf materials and equi;=cn upon de ~ livsrf at the constructica site is perfer ed and con-l trelled by Site QA for pre-purchased equipment and by the ( Site Centractor fer Centractor purchased equipment 10 l accordance with subseepic: 17.4.10. Both Site QA anc che l Site Centracters.will assure that.as a =ini=u=, =aterial I and equip =ent will be inspected for identification, free-den frc= shipping damage, availability of purchasers re-l lease and availability of preper quality docu=entation. Any discrepancies, including the lack cf preper documen-tation will be handled in acccrdance with the ncnconfer- =ance precedure as defined in subsection 17.4.15. Upon ecepletica of receiving inspection, the =aterial will be identified as specified in subsectica 17.4.14. P l, I e ~ P o ,,m, r. _,,,,, _
WP-1 pSAR 17.4.7.! Surveillance Activities a) Audits and surveillance by the Site quality Assurance organi:stien will assure that the Site Centracters are c = plying with the Quality Re-quire =ents. This surveillance will verify that procurement requirements for equip =ent and ser-vices are followed and that t.he Centracters are 1.2 accord with Applicable Centract specificatiens, Drawings, Manufacturers Instructions, Tield pro-cedures and Codes. b) Centracter precedures for ::ntr:1 ef the;r ;ur-chased =a erial and egrip=ent wi'.1 ha audited by Site QA and assessed for their adec.uaev.. in s ec-r ifying characteristics and processes to be wit-nessed, inspected and verified, and the respon-sibility for their i=plementatien. c) Site QA will perform audit and surveillance to assure that Site C:ntractors are accepting and releasing items in accordance with approved pro-cedures and that ncne:nforming ite=s are con-tr:11ed in acec dance with their approved pre-cedures. 17.4.S Identificatien and Centrol of Materials, Par s and Cc=penents The Centract Specification provides for :he identificati:n and centrol of =ater161. parts, c:=penents and equipment for site centracter pur:hased =aterial and f: pre-purchased =aterial. rer site centracter purchased =aterial, the centracter imple- =ents his own accreved pr::edures. Ter =re-curchased =aterial ~ ~ ~'*"'E Site QA will pr'evide and i=ple.ent the Nuclear QA Manual for assuring enly properly released equi;=ent is used er installed. 17.4.8.1 Centrol Sys~.e= a) Site centracecr iden*.ification and centrol prece-dures will be provided and i=ple=ented by the site Centractor using his cwn tags or project supplied tags per subsection 17.4.14. The site centractor procedures will include pr:visiens -te preclude the use of incorrect or defective =aterial, :: verify identification of material pric: to release f:r, installatica or corstruction and to assure that the locatica and =ethod of identificatien does not affect the function er quality cf the ite= being .a sen. a.a.se-. a O b e b ~ n,, r - -., ~ - - -.
W::;-1 PSAR t 17.4.8.1 Contral System (Continued) b) The Project identifi:a ica and con:::1 syste: enployed at the site f:: pre-pur:hased e:uip- =ent is defined.n the Nuclear QA Manual. This system precludes the use of ine rrect er defec-tive items which, based on the use of tags or tags and sta=ps, provides identity and trace-ability of the status of materials, parts, ce=- ponents and work operations th: ughout the con-struction activities, c) pre-purchased =aterial received a: the site f:== a Vender will ta pac. Aged, ::sted, bundlea, sized ~ and =arked in accordance with the applicable cen-tre.ct specification and the approved shipping p:c-l Oedures. Receiving inspection tags nall be ap-plied as required (subsection 17.4.14). 17.4.8.2 Identification of Stered ta=s a) Stored =aterials on the site will be inspected by Site QA and site centractors in acec: dance with their approved p.ocedure (subse:tien 17.4.13). Nen :nfer:ances de ected by the con::act:r c - Site QA at this ti=e will be re;:rted and dis-positioned in ace =rdance with an app::vei p:::e- --e dure (subsection 17.4.15) snd tagged and identi-fled accordingly. If noncenfer:Ances are detect-ed on =aterial in s:crage, additienal tagging and identificati n precedures will be i=plemented to centrol the status. Tags, sta:ps and storage inspection reports will previde suitable identi-2'?, fication control := preclude their inadverte..: use in construction. 17.4.9 _ Control of s_=ecial ? recesses The project'(UI&C) will net be required := perform any special processes during the constructica of WNp-l p c-ject, but will impose applicable requirements en the Site Centractors respcnsible fer constreetien, instal-lation and testing of the equip =ent. ? :curement doc-l u=ents f:==nstruction :ntracts require site cen-
- actors to control their s.:acial cens:::cti:= pro-cesses in acccedance with appropriate cedes and 'stan-dards. Site Centractors, when indicated in the speci-fication, are required to sW-mit written p:ccedures for review and approval.
r -r , %-n -w. -we-www-.et e v -y nw ---r--w--* = = w -*---e.ic'=-
etetw--**:---t aw- *-
- -----*r*
- e
+c+e =
WMP-1 PSAR /, 17.4.9.1 Process Re:uirements o a) Special precess requirements unique to the c:n-struction activity will be included in the c:n-tract specificatien with the requirement : hat when required by the specification, operating prccess precedures be sub=itted for review and app cval. Review and concurrence of Project Quality Assurance will also be required pric: to use. 17.4.9.2 Qualificatien a) Pr: cess pr:cadures preparad :y S;te 0:n=racters requiring qualificatien, are qualified in ac:=r-dance with applicable codes and standards fer erection and construction work perfor:ed by the S!.te Centractor Field personnel. Site Quality Assurance review and c:ncur with these p:cce-dures pric: to their issue and use at the cen-struction site. Site Quality Assurance is also responsible for certifying by audit and surveil-lance that the applicable procedure qualificatien has in fret, been perf:rred as stated. b) ?:: cess perscnnel e=pl:yed at the c:nstrue:1:n site will be qualified by applicable cede re-quirements to perfer= the required p:: cess. At the c nstruction site, each Site Cen :act:r cen-trols the qualification examination, requalifi-catien ex=-'"atien and rates: of their operators as required. Persennel certificati:ns cre issued by the appropriate Site Centracter and cepies are - ^ - ~7, =aint:ined in the applicable per:anent rec:rd file at the site. c) Active files will be =aintained by the Site Con-tracter ef qualification records of their person-nel performing these special precesses. 17.4.9.3 Process Documentatien and Records, a) The centrol and retentien of applicable Site Contract: quality cen:rcl reccrds pertaining to special ; : cesses used at the constru::ica site will be in accordance with subsection 17.4.17 and will include sufficient documentatien and ree:rds to ensure that the requirements of these special peccess precedures and specificatica requirements are current and are being i:ple=ented. 9 O e e--- w w n -m... ---,-r-g e e m e ny e-en-
O 'Ci?-l pSA?. 17.4.9.3 Precess Cecumentation and P.ecords (Centinued) b) project Quality Assurance persennel review the construction centract specifications to verify inclusion of any special process or process con-trol and with Engineering, review and app;cve all sn' 4tted Site Centractor special prccess procedures pric: to construction or installation. Site Quality Assurance perse'nnel previde the site surveillance effort to assure that site Centrac-ters confer = to their procedures. 17.4.10
- spection a) First level inspecticns at the site are perfor=-
ed by Site Centractors persenne? charged with the Quality Centrol responsibility in acccrdance with approved Site Centractor inspection procedures. ) Site inspe=tien activities affecting quality will be verified by Site C:ntractors through a systa= of inspections of =aterials, parts and cetponents at the site to assure that Site Contractor pur-chased =aterials are received, handled, st: red, installed and tasted in c:nfer= anes with speci-ficatien and centract require =ents. Site C:ntra - ter quality C:ntrol ;ersen.:el are chargei with the pri=ary respensibility to deter. ine the accept c: reject status of the site Centracters werk and to i=ple=ent their decisi:n by pursuing a c urse of actica in accordanc'e with their approved site pro-cedures. b) Fer pre-purchased =aterials, parts and c =penents -~*'T Y, received at the site, site CA will perf:r= those l receiving inspections necessary to verify the quality of this inc==ing naterial. Site CA per-sennel provide a secondary verification of the accepta.7.ce status of the work, identifying and reporting of nonconfor=ances detected by surveil-Lance and when required, pursuing a course of action as defined in ruhsection 17.4.16.5 (Stop tork Authority). c) Centractor's precedures shall contain the ident.'- fication of ~hese individuals er the organiza- ~ tien respensible for perfor=ing each inspection i cperation with the qualification require =ents fer l the inspecticn personnel, and previsiens for as-l suring that each inspector's qualificatien is kept current. Site CA app cval of the Centrac-l ter Quality Assurance organi:stien and the cen-l tinued audit and surveillance of their QA progra: will rea phasize the independence of their inspec-tien organization. ( s I I
wgy_1 PSAA I 17.4.10.1 Receivine, Plannine and Inspection I - a) Pre-curchased Materials i 1. Receiving inspection check plan sheets are required for the performance of receiving i i inspection by Site QA^ personnel in addition } to criteria of acceptance shown on approved drawings, centract specifications and nanu-1 facturer's special instructions. These give additional cetailed instructions for the pre-purchased =aterial to be inspected upcn receipt at the Constructi:n Site. The'f ars prs;1 red i by Sita Quality Assurance pers:nnel, in advance of the anticipated equipment delivery to the site, if at all pessible. 2. Pre-purchased equipment to be installed will be inspected by Site CA personnel at the site in accordance with the Nuclaar QA Manual. This Manual provides for detailed planning by Site Quality Assurance personnel, visual in-spection for shipping da= age and identifica-tien, dis;esitien and tagging :f a::aptthis, nonconfor=ing, and rejected natarial and re-noval er isolati:n cf reje: able and n:::en-forming naterial fre= re:eiving areas. 4 .g-Site Quality Assurance perscnnel aise pr:- l vide the necessary surveillance and audit ac-tivity of the Receiving Inspectica activities to assure that pre-purchased =aterial is ce - trolled during receiving inspection. i b) Centracter Furchased Mate-ials 1. Each C:ntracter develeps and inglenents -(after approval) his own procedure for receiving inspection of Centractor purchased materials with the procedure assuring that unacceptable material is not inadvertently released for installation or use. Centractors' precedures also provide for the identification and centrol of material by tagging in the varicus stages cf receiving precess, t7 prevent uninspected or unacceptable =aterial from being used or i installed. i i 1 l i l i l ..._,,4m- -_- -_~-.,,.. -,.,~, _,e-r
e.s _1 o . Sc.,. 17.?.10.1 ?.eeeivier, pizenir; and et e::ien (C:::inued) b) C::::a ::: ?ur-hased Ma:e-ials (C ::1:ced) 2. Tne Cc ::a:::: p::cadures als'o provide f= he use of his c -. tags or ?:: ject su'pplied tags (Sectie: 17.4. 4) th:cughou: his receivi=g 1:spectic: 7:ccess. 3. S':e Qual':7 Assura:ce vill par:1cipa:e,
- h:: ugh audi: a:d surveillance of the C :::a : r's re:ei-i:g i:s;ec-10:'ac:ivi:1es;
....e,.,._...,ces.,_.,.,s............,. C.-... ac. a. _sc...."..-'.-.-..'..'s<.--.-.-a.d p: cedure f:: receiving inspectie: a:d :*..a:
- he C :::ac er received ca:erial in ces:::11ed as re.5cized.
17.4.10. 2 C::st=c:i:: Pla- # e and I-sree:ien - a) Each Si:e C :::ac:c: de eleps and i=ple=e :s (af:e: app:: val) his ev: p::cedure f:: s c: age, installa:1 :, :esting,1: spec ics, =ain:enance, c.s ,_:..s ,.:.a. .... _a _ _ a _. ._a.ca_.n._ _a _ _ . v., _ m. b) App:cved size c::::ac::: quali:y c:::::1 ~ p :cedures ar._e :::vided fe: :he fellevi_s _ __ s _. _ e, e. _- s.,. e,..s, _ s c,,_ _ a _ _ _ a c__m _a _ a, s. perfo=ed : - assure c:=plia= e vi:h the applicable dravi:gs and speciticatie requirene::s; periodic review cf files := ass =:e cha: cc:::ac::: files i. accurately reflec: :he v :k 4 :::plished; _.-.4 =cclicting equip:e : :es:s a:d check.s := assure c==plia:ce := p:ccedures; and reper i:g of :::- cc f ::ances. c) Site quali:7 issurance per::::el vill p:: vide
- hese addi:10:al 1:spectic:s :eques:ed by C: s:=c:ie: E : age =e : : verify the quali:7 of cc:::ac::: cess:=ctics.
d). Master surv #"acce check pla:s are prepared by Site QA f : su-veilla::e ac:ivi:les := assure
- he perf:::a::e cf C :::ac::: 1:s;ec:ic:s a:
t ~ the cc:s::uc.1:= si:e. T ese check pla:s are suf ficien:ly de: ailed := date::1:e :'-a: the C::::ac:::s are c:=plyi=g vi:h their app::ved QC 1: spec:ic: ;::cedures and p:= ject require =e :s. I e) Tne f=11pvi:g :ypical s: veillance po'::s vill b e c _3.. : ed d...e _ _ c,_s_.__..._,._. t l -13.-
t b'Np-l -n., r a n.s 17.4.10.2 constructica Planninc and Ins:ecti:n (Continued) 1. In-process review of Centracter's doeursntatica and data re:Ords to assure that required pr::ess cperatiens and inspections have been c: pleted before the werk is rendered inaccessible by construction progress and to avoid delay in final release to test and stait-up. 2. Cest Centrol (i.e., NDI, pressure, electrical, concrete, etc.). I 2. Calibratien and type of tes: equipment c:ed. 4 4. Verificatien of dimensienal inspections. 5. Verify drawing status (i.e., c nfiguration, revision, etc.). 6. Verify that welding and NOI pr: cesses are in accordance with approved precedures and codes. 7. Verify personnel certification and qualifica-tien. 3. Painting censideraticas (i.e., coverage, runs, thickness, certification of c:=pliance, etc.). 9. Shelf life censiderations (i.e., gaskets, lubrication, etc.). 10. Other inspection part=eters as required. ,-- y f) Each Site Centracter develops and inplements (after appr val) his cwn :::cedure fer st::17e, instal ~ation, testing, inspectica, =aintenance and handling of site Centracter purchase d -* a - ials and equi;=ent. Site Quality Assurance audi: and surveillance activities assure that the Site Contracter is confer =ing with his approved pro-cedures for this effort. 9 e O 9 ---n,-
,-m
.y ,-w--, n,,. ~.am-,y- ,-w
WNp-l pSAR 17.4.10.3 Final Acceptance Inspectien a) The inspection activity associated with verifying and establishing the acceptance of completed items which have been installed and erected on the Cen-structi:n site are in accordance with approved site Centracter precedures. These procedures provide fer, as a mini =u=, the following requirements: Specific steps ce ha followed fer verifying eork-sansnip, lack cf damage and acceptability of na-terial and equipment. Methed and steps for supporting data review as-se:iated with the installation effort. Method of recerding changes, reinspecting pre-vicusly accepted material and establishing accept-ance status of modified caterial. Cafinition cf that pertion cf wcrk reruired to be completed in a Ccnstructi:n Operatien before in-a: essabilit,' wocid limit the a :eptance insre:- tica (Removal, replacement and : difications in-spectien). b) UE&C Field Quality Assurance personnel, through audit and surveillance cf the site Contractors final accept-ance inspecticn activities, assure that the Site Cen-tracter is conforming with his approved procedure fer --e-T O ' final acceptance inspection and the rencval.nd re-placement effort and that the turncver documentatien package fer the equipment is complete and acceptable. c) UE&C Field QA performs a Final verification which iden-tifies as a minimum the follcwing: Listing of applicable documentatien which shall be considered as substantiating the quality of the ite=, activity or installation. Listing of these visual cbservations, including clean-liness, lack of da=ags, painting, etc., which shall be considered as affecting the physical quality of the item or activity. Statement that cutstanding NCR's have been resolved and hold tags have been cleared. e e
8 W::y-1 PSA.:e f 17..".10. 3 c) (CO!.7Ih"JIO) Cther unique attributes of the item er system necessarv for final acceptance, such as ccfe sta: ps, =ackings, i identificatien, punch list, etc. ? e 4' w*T* 9 -2Ca-T d
- N W me en ese a w
.e
i I Wr?-l PSAR 17.4.11 Test Centrol The Nuclear QA.v.anual for the Construction Site estab-lishes a syste= cf cont:cl to assure that Site Centrac-tors' test activities are perfer=ed in ace : dance with predeter=ined centractc requirements, app cved and delineated in written test procedures and instructions. This syste= will als assure that these site test re-suits are a::eptable and fully documented. 17.4.11.1 Tes: Keeu_re=ents a) Test require =ents for Site Contracters during Construction and installation at the job site are delinesced in the Contract specificatiens in confer =ance with goed engineering and C:n-struction practices and code require =ents. Ccafer=ance to NRC regulatory guides are also censidered when the required tests are speci-fled in the Centract specificatien. b) Site Cen :ac:::s wri::an tes p ccefures f:: review and audi: by site Quality Assurance, describe the =e:hed Of inspection and test cen-trol, and verificati:n that tests have been -= perfer=ed in accordance with specified test p c-cedures and instructions, and that test results are within the specified limits.
- )
Storage tests pr= vide a pericdic check cf stored --m ~, equip =ent which are ::nducted in a:::: dance wita Site Centract : and 7:cje : a,p cved written test instructions. Met.suring and test equipment checks previde periodic calibratica checks in ace:rdance with 17.4.12 as defined in the app cpriate app:cv-ed contract = p:ccedures. Receiving tests previde continucus inspecticn test control based en P:cje:: a:Oreved test decu=entation for.cre.curchased =a-terial and Centracter approved test docu=entation for Centracter purchased =aterials. Tests perfor=- ed te verify installations are in ace:: dance with e b 9 o
WNP-1 PSAR 17.4.11.1 Test Requirements (centinued) c) written precedures and verified by centract:r persennel charged 5,ith the Quality Centrol responsibility for the installatien. d) Records of all field tests and field check re-sults are fully decenanted and available f : audit by Site Quality Assurance. Assurance is maintained, by this Site QA audit and surveil-lance function, that adeq; ate test instru=en-taticn and qualifiad persennel are used in tha performance of these tests. 17.4.11.2 Pre-C;erational and Start-up Test I a) Plant pre-cperational testing and start-up phases of construction are in ace:rdance with Chapter 14 of this PSAR. The systes of QA Surveillance and Auditing i=plemente'd at the ccnstructica site will be further developed, as centractual respen-sibilities are defined, to assure that the pre-cperati:nal and start-up a:tivities have been carried cut in a:: riance with spa:ifi:ati:ns and precedures. 17.4.12 Centrol of Measuring and rest Equi men: All =easuring and testing equi;=ent which is used := ~ deter:J.ne the acceptabili:y of materials, equipment er installations at the site is under c:ntr:1 of a .,- n 7,. site centrol and calibration.:: gram =aintained ac-
- Ording to written procedures :entained in the UE&O Nuclear QA Manual and Sita C:ntra: Ors' Quality As-surance programs. Site Quality Assurance perform auditing and surveillan=e of this pr: gras te ensure i
l that it is functioning pr:pe-ly. 17.4.12.1 Prcesdure a) The CIsc Nuclear QI '.tanual and Site Centracters' approved precedures establish a systa= for the c=n-tr:1, calibration and adjust =ent cf tecls, gauges, instruments and ether inspectica, =easuring, test-ing and =aintenance devices used at the site. This I system is established such that c=nfernance to estab-i lished require =ents is verified by Site Quality As-surance at specific periods of ti=e to assure the usage of proper type, range and acruracy of the device. i S 9
e i NNP-1 l' PSAA i + 17.4.12.1 Precedure (Continued) b) Prior to releasing f:r use, =easuring and tes: equipment is identified by the Site centracter (e.g., color codes, tags, labels, stan;s, seri-alizatien) to indicate that it has been calibrat-ed, when the next calibration is due and who per-fer=ed the calibration. c) Schedules are established by the Centracter and re=crds are maintained t assure that calibra-tien is perfor=ed periedically and has been fully d:encanted. E-te quality Assuran:e per-4 sonnel audit and survey these schedules to ver-g ify centracter condermance to these precedures. .I 17.4.12.2 Control Reeuire=ents a) Site Contractor appr:ved p cceferes require that the following detailed centrol requirements shall he imple=ented at the site as part of the site 4 ~' - =casuring and test equip =ent calibratica pregram. i
- 1) Maintenance and con:::1 Of the a:::::riate standards facilities with the associated rec =rds.
- 2) Istablishing identifi:atica me heds of de-vices under calibratica centrol.
- 3) Methed of correcting, adjusting, returning
( for repair and replace =ent of measurement
r' standards.
l
- 4) Calibration ::::::1 cf new devices and establishing cf calibratic,n guidelines.
- 5) Qualification of persennel using these
"=easuring devices".
- 6) Provisien f== frequency of surveillance activity.
t ! P f e g
- w.
9 "S ..c
i fji'.;N?-L 2 S A.4, 17.4.12.3 5:andards of C.::e1 5 l a) ?:i=ary and sece:dary s:andards _a:;e =ti=:ained, at a p;cper si:e 's.111:y 'b.v., f. e. r.e.s.t.. ens.ible 4 S ' '. e C.-.....c. c. a' -...-*..* c... ' '. ' c a.*. d a.. a. Calibration of si:e =easuri:g devices are pe:- for:ed is accorda:ce.-1:h gui.d. e.l.iz.e.s 1:'.N.a:i.o a.1 and equip ='e:: =a:ufacturers recc= e:,Di..=senals .sureau of S:::dards ~(N35) =atua.ls ; A.S a: ices. ~ . b), S1:e Ces::acter precedures pr: vide fe: :hese ~ cilib: hic s :c. ' f,.a,3..e. i.s,::if.i..el'-ic.iufacies iss:n-i- T able :c che-N3S a: - a :e :eri:::ed u:de: ---.2 e.. ;.<. 3 e. 2,. 3 <., 3. 43, .e:peratur e. ,,,e::erature rate c, c:a:ge........... s Rela. ve h=idit.i - ,..s... Cust c) Site C :::aetbh" al'i'Na:ib~i !! Aqt:et' 1'.c'. arts -- c 1 c...-- --.-.a
- ,...,-.,,.s.. 25.
-....a 2
- c. a ; a c,..... s -.1... e...,,... :..
,<sa. 1 a .......... w. able :o che, NIS: fer-pri=a:y s:a:dards.(e.g., di=ensic al, pressure, ele::r cal, :b's::al, veigh:), sece:da:9 sta:dards a-d.ge:eral'.res: inst:.=:e :s. l l Calibraries a 8 Cc ::e1 ?.ecerds 17.4.12.4 1
- 1) - e.a:
c.-. ~.: c ' - =. ' ' %. a.' c. = ~ ~. 's.'o.. a s.*.. ' -2 n l and =easuri:g equip =en: used by Si:e C::::ac:::s duri:g reecivi:3, s::: age, c::s::ue:ie: and iss:alla:ie: 1:s:ee:ie:s and :es:s are e.s:ablished . can be readily recalled #c so that equip =e:: recalibrati:= or adjus=ent. These si:e records also se:.*e as. a:. indi:stics of which devices vere used on specific tes:s a:d i: spec:ie:s, and also provide for ::aceab'li:y if such devices are fcc:d to be cu: of ealibra: ice,a:d require c...e~.dve a.-.'~-. b) The use of u:calibra:ed equi;:e : cc:sti:::es a rejec: ion of :be si:e tes: c: si:e 1: spec:ie: vi:h :he dispcsi:10: iden:ified as part of the nesec for=acce re:c:: which is issued. l I e 6 a 1 m 4 n.- .c
I~.' J/ hi-1 .v.e., 17.4.13 -zedli r S:::ste and Shitsin: Si:e "s:erage" of =a:erial and equip:e:c acu t.te p:cgA. fer ' i=ple=en:ing :::::ci of "s::: age" areas are 1:\\ ac:c:da:ca vi:h vri::en p:ccedures based c: :he cc:::ac: specifica:ic: require- =es:s, supplie:s rec==enda:1c= and accep:ed prae:1:es. She QA provides the audi: and..surveilla:ce activi:y := assure that. i che Site C::::acters fra i=ple=e::13 apprev.ed " storage" p:ccedures vich qualified pe:s===el. 4
- I: this sec:ics, "s::: age" (1: que:es);e::Einstas::: age, prese: ta:1::, handling a:d clea.1:g a :ivi:ies.
17.4.13.1 ?::cedure a) Storage" of si:e =a:erials a:d equip:e':i vill
- he u:da: he responsibili:"s cf Cen::a :::s, whether equip en: is pre-purchased or purchased by iss:alli:g Si:e C :::ae:c:s,' vi;h the
.cos::ac: specificatic p :vidi:g :he require-ments for these ac ivities. b) CO::: actors respe:sihle fe: :he ad ' 's::a:1c of the pre-purchased equipre : "st::2ge" pr:gra:.i:ple=en: v-1::e, a;;;;ved ;::cafures which 7:cvide f:: "s:::ag e" 1:sp e::1::, ~~ ~ ~~' " storage" =ai=:e:a :n, "sterage" ha:dli:g, " storage" se: reillance and generati:3 all "s:crage"-re ::ds. Si:e Qualipy Assura=ce perse::el p:: vide :he audi: a:i surveilla:ce ( ac:1vi:7 :o assure i=ple=enza:ic cf thess ,,p
- cedures.
I. A c). Si:e Cc ::acters respensible fe: "s::: age" of f
- a. '.-e:: devele.:.:1::e:
Cen::ac:c: urchased p:ccedures uhich are suh 1::ed fe: review and .s '4 .(approval. Site Quali:y Assu:a:ce persc :al p:: vide the audi: a:d su:veilla:ce, activity :o [ assure C :::ac:c: i=ple=en:a:1:: cf his ]g, ...p:ecedures. 17.4.13.2 S: crate Ca erorf es and Recuire=er:s l a) The Si:e Quality Assurance ?::gra=.p::vides j for es ablishing and =ai=:aici:g various ca:egories cf s::: age c che 'she. Each Ve:do: ,he delive:f, a:d Cc :: actor procedure fo: receiving inspec:ie: and si:e s:crage of equip- =es: provides the require =e::s f:c: which the ype of s::: age is selec:ed and applied. e s O g
- 9 a
~ - -., wc.. .-----c,-<v .,w + em--.* y,-.
~. WP-1 PSAR 17.4.13.3 Periodie Inspection and surveillance a) Audit and surreillan:e of "sterage" cetivities on the site is previded by site Quality Assur~ ance to assure that Site Storage Centractors are imple=enting approved precedures. b) Storage inspection peccedures provide for ini-tial and periodic inspection of stered arcip-ment to assure that the integrity of the eTaip-ment has not been c =prc=ised when received and during st: rage, and that specified =aintenance reg; ire =2nts havs hea. ;sr::::ed. 3:hedulas of inspections are established by the Centracter for :r.aterials in storage with unsatisfactory conditiens being brought to the attentien of respcasible parties, in a :erdance with Centrac-tual procedures, for corrective action. Ader: ate records of s crage inspection are maintained-by the appropriate Centracter to show satisfactory conditien er report of unsatisfact ry c ndition. 17.4.13.4 Records and Handling a) "Sterage" pre:edures pr vide f:r each " Storage" Centracter to ad=inister his "sterage" progran by =eans of a systa= cf records, legs, and re-pcrting. ' Centractual d::::ents pr vide how such " storage" rec =rds pertaining to Teality are to be controlled, examined, reviewed and filed. 17.4.14 Inspectien, Tes and C;eratin: Status The Nuclear QA Manual prevides measures for indica-I tine. the status of tests and inspections rerfer:ed l upon =aterials, parts and components when received, i tested, inspected, stored an: installed at the con-structicn site. The status cf the ites is estab-lished by a Project system of tagging which, when a;. plied and recorded, prevents their inadvertent operatien and precludes the inadvertent bypassing of their inspecticn and test rercire=ents. 17.4.14.1 Ita= status Inspection and test status are defined in~ the general categcries described telew: 9. 4 I 1 m ._,,,,_.m._~ s.,_,
i. s. ,KF-1 e pSAR t 17.*.*i.1
- e= 5:a:us (Cis: int..,
a) AcCI?? sta::s is assigned to =a:erials, par:s a:d ec=pene::s veich are inspected a:d f:::d sa:isfac:ory fe: cc:s: rue:ics use, a:d i: c:sfe:- l =ance with applicable cc ::ac: specifica:1: s. This s:a:us is recceded a:d :hs =a:erials, par:s i a:d cc= pere::s are re. leased to warehouse facili-ties, storage areas :: fabrica ic: a:d erec:1c: areas. b) RIJICTsda:: sis.tssigned:o:::e:ials, par:s a:d cc=peze :s vnich are inspected a:d f:::d = sa:isfa:: cry f:: c::s:::::i: use, a-d ::: is accc: dance with applicable ec ::ac: specifica-tices. This status is rece:ded 4:d rejected ite=s are s' gregated o a cc:::=_ led re,jee: e area us:i1 such ti=e tha: a disposities is =ada. If segregatio: of rej ec:ed caterials is =c: practical, :he 1:e=s are physically :agged 1 to clearly shev s:atus. Sc ce:for=1:g =a:erial identified with a "RIJECT" tag is subj ec:ed to the =cccc:for=1:g =a:erial cont: 1 pr:cedure as described is 17.4.15. c) I013 s:atus is assig:ed :: =a:erials, par:s and cc=:c:ents.: hat have :een ide::ified as :::- i cc:forzi=g a:d are avaiti:g dispcsi:10: of a: - - + I'.. a:::ibute. vhich diffe:s fr:= specifica:1:: .. require =q::I. The held s:atus is ide::ified c: a v i::e: :ecord a:d the 1:e= is app cpria:ely tagged. Such i:e=s are segregated f::= accepted i:e=s u=:11 a dispositi:: of the held sca::s is ~~ =ade. yo: :a:e.ials, pt :s a:d c::pe e::s which are released f:: li=1:ed verk, avai:ing dispc- ~ l sition of a :::ce:f::=asce, a "C::di:io:a1 Eelease" is assig:ed. t d) CONDITIONAi RIiEASI s:stus is assir:ed :o ..-_ =aterials,.:ar:s a:d ce=pe e::s :ha: have ::: ' been fully accepted f= use, bu: vhidi a:e cct-di:1c: ally released :o reloca:e, s:cre is place or 1:s:all :o a poin: where che 1:es can be re=oved c: ::::ected vi:heu: dar ' -
- or cc::a=1-na:1c :o the associa:ed per:ase:: plan: equip::::'
or structures. This sta::s is scorded a:d cc:-
- olled in acec:da:ce vi:h wri::e: p:ccedures.
e) A"AITING INS?ICTICN s:atus is assig=ed o' =aterials, parts and c==pene::s : hat have bee: redeived a: the si:e and are avai:1:g: . s b p i -
- C.~ -l
- 9 r a n.s 17.4.14.1 Ite= Status (Centinued) e) 1. ' Inspection 2. Identificatica r 3. Docu=en ation 17.4.14.2 Records and Sta=ps a) Subsequent to =aterial and equip =ent installa-tien, the inspectien, test er cperating status is indi:sted by attached tags :: by tr:ceable re:Ords such as inscaction checa. clans, ins.:s:- tien reports, or :=uting for=s. Sole authority for the attach =ent and re= oval of these tags rests with the applicable quality centrol cr-ganizatien. b) Lots of =sterials which can be identified by heat nu=her, let nu=her, ute., =ay be identi-fled with a single tag, providing the tag is =arked to c =pletely identify the lot. When y.fs.< ,1 s.4.e C- -3...a s, .. f s.a..a..,.-,.,..a,-
- =g a..sab...o...
(a.. .e a.., g 3 ;. a. ;.e.., g3 2, w y e.=. ), .k.. .J
- s. e e.. d a.... s. s....
.J s .4 A.e ._d.X.J A..%. . y ....a traceable re :rds. c) a' _. e _ c a..s -" -. 4...=..'. 8-m.s - = _ ' _= '..c... e s '.i.., _' s ce=pleted and accepted, W7PSS procedures pro-vide for the attach =ent of test accepted tags to the systa= or structure. O.is precedure prevides f=r the centinuation of equipment ~'""7, status identidicati:n thr: ugh the pre-epera-tional test.:eried and finai s:ste= testing by Wp?SS. I r i c) Appr:priate inspecticn sta=ps (e.g., welding, NCE, radiography, inspecticn, etc.), when utilized by the siti centracters and site Quality Assurance persennel, are applied to docu=ents (e.g., dispatch orders, etc. ), to I .crevide notice to the site centracter instal-latien functi:n that equipment and parts have been inspected. Issuance, application and re- =cval of these sta=ps is under strict centrol of Site Centractor and Site Quality Assurance to prevent use by anyone other than the person l to whc= it was issued. 7 hm e O .e e
h t j i WN?-l PSAR i 17.4.15 Nencenf =in; Materials. Parts and C = enents { Che Nuclear QA. Manual prerides f : the identification, doc =entation, segregation, review, disposition and l notification to affected organi:ations of nonconfer=ing a materials, parts and ec=penents at 5 'v st age of =anu-facturing, fabrication, erection er c:ns cuctica *a prevent their inadvertent use er install.ica. Written precedures provide f r the handling, prec..ssing, and dispositioning of noncenf= =ing aterials, parts er C:=pCnents.
- 7.4.15.1 Nen :nfC=ance3 A noncenfer=ance is a deficiency in characteristic, decu=entation er precedure which renders the quality of an ite= unacceptable er indete=inate. Exa=ples of noncenfor=a=ce include physical defects, test dailure, inaccurate er inadequate dec=entation or deviating frc= prescribed processing, inspection er test precedures.
17.4.15.2 ?recedure a) ::ene:nf ' g =aterials,.: arts, :::;:..ents er activities at.he site are doc =ented by the Site Centract:rs a=d Sit's CA by use of the Project Nencea.fc =ance Report for=. b) Ncnconfer=ing ite=s are identified and marked i with a "hcid" tag (when possible), re=cved to l a site " hold" area, :: ped off, er otherwise w -y segregated to preve-- - % '- '-=dvertent use. 4 The dispcsitioned 1:07, is returned to the cr-gani:atien responsible for carrying cut the ccrrective actien. 17.4.15.3 centrolling NCR Ferns (Site) a) NCR forms for site activity previde for si=ilar require =ents, explanatiens, justifications, concurrences, dispositions, c=:rective actions, reinspections and approvals. 31stributien of preli=inary and ce=pleted :CR f _ s is standard and they are maintained in ac: rdance with an estab7.ished precedure. b) Centrol of ncncenfer=ances by Site Centractors is evaluated by site quality Assurance audits during perf ance of the werk. b d k e --e ,r.- ~,. - - - -- .n-,- -m. n
I WNP-1 l. PSAR ../ 17.4.15.'4 Maintenance of NCR Records 4 I a) A leg is maintained by the Site Quality Assurance for NCR's initiated at the site. b) A leg is =aintained by the site contractor for centractor initiated NCR's listing as a mini =u=, the date, nunber, item and noncen-for=ance description and disposition. c) All site NCR's rs=ain "cpen" until dispositica has been resclved, implemented and reinspa::ed and the NCR ::rplaced (c'_2srad). 17.4.25.5 Ncncenfermance Review 3eard a) All site nonconfor=ances are suh=itted to Lite Quality Assurance. Each NCR is evaluated for adequate disposition or the necessity for Non-confor=ance Review 3 card (NR3) approval. The NR3 approves dispositions when required as deter =ined by reference te specific critaria and in ac crdanes with applicable prcie:t pre-
- cedures, b) Che Ncn:cnfcr:ance Review 3 card =ests as required at the ecnstruction site to review and ap;rcve the disposition cf applicable site The NE3 has the following noncunformances.
representatien: 1. CI&C Ingineering 2. WPPSS Ingineering 3. UI&C Quality Assurance 4. WPPSS Quality Assurance i 5. WPPSS Construction 17.4.15.6 Disposition Dispositien of all nenecaformances at the site are approve d by Project Engineering and are noted en the rerpective NCR for=s with the dispositioning action in accordance with the Nuclear QA Manual. 17.4.15,.7 Reinspection I l l After. the respersible organization has performed the required actions to clear the ncnconfermance, i the originating crgani:atien's QA inspects the ite=, i i I l, k, r s i (
7 6 M;?-l PSAR 17.4.15.7 Reinspection (0:ntinued) dete=2ines its a=:eptability and signs eff the none:nfor=ance as approved. 17.4.15.8 Reportine Copies of all nodeonfor=ance rescres are submitted to Site Quality Assurance when originated, when dispositioned and again when cleared. 17.4.16 C:rrective Aetien The !!uelear QA Xanual pr:vides for precedures fer identifying, docu=enting, reporting to =anagement and . dispositioning these site conditiens adverse te quality. The progra= also provides a =ethod for assuring that site conditiens adverse to quality are determined and corrected to preclude rapetition. 17.4.16.1 Corrective Actien Re uests a) The : uclear CA Manual requires that the Site cen tact:r initiate C:rrective A:tien Requests in a :Ordance with an appr:ved pr::edure whnn the centractor is f:und to be cperating in such a way that his c:==itted QA/QC pr:gra: cannet ha i=ple=ented as required. The con::act:r is als: required to respend in a ti=ely =anner to corree-tive action requests written by Site Quality As-strance. i b) The QA Progra= requires that a corrective actica ~'"~7,, j reques: be initiated by Site Quality Assurance when site ecnstructi:n practices indicate that repeated violations of the sa=e nature are ec:uring. 4 17.4.16.2 :=ple=entine Corrective Action a) For project corrective actien i=pla=entatien, the desicaated responsible party describes the corrective action that he intends to i=ple=ent and specifies the date by which i't will be i=- ple=ented. If c rrective actica specified is not adequate er does not =eet the intent of the request, Site Quality Assurance resolves the difference in accordance with an approved procedure. s = b e l e v-
W::7-1 e PSAR 6 17.4.16.2 I=ple=entine cerrective A::len (C:ntinued) b) For Site Centracter :::rective action initiat-t ed by Site Quality Assurance, the designated j responsible site centractor describes the corrective action that he intends to i=ple=ent and specifies the date by which it will be L=- ple=ented. Site Quality Assurance =aintains a site audit snd surveillance activity to ascertain the adequacy and intent with the app:cved centracter ; :cedure. 17.4.16.3 "erifica:icn a-d Anal:. sis a) When actual corrective action has been sat!s-factorily implemented, the Field Superintendent Quality Assurance verifies the i=ple=entation of the corrective actica en the C rective Action Request, dates and signs the request for= to indicate Quality Assurance approval of acceptable action. Standard distribution of the infer =ation to affected a:tivities is then L;ple=ented. b) Site ::ntract:r and Pr:je:t :::re::ive a:tien fer=s are filed and 1:gged and the effe=tive-ness of the : rrective acti:ns are reviewed by ~* Site Quality Assuran=e. Scch actions nay in-clude stepping the site centracter inspection er constructi:n effert for pec: quality pe:for- =ance or stepping the project c=nstru:tica =an-agement effer: for disregard cf app: ved QA or _,o__ -y project precedures. c) Feedback infor=atien en :::c:nf --= ces is obtained fr== site c:stracters and Project C nstructica Management by Site Quality As-t surance. The data are analyzed and evalu-ated by Project Ingineering and QA personnel, 1 after which corrective acticn is ree:== ended to r assist in centrolling and preventing re:urrences i, el site nonconfor=ances. ( I d) Significant differsness in design and c:astruc-( tien will be docu=ented and reported pr.' ptly. These activities are governed by written pre-cedures. e) Iffectiveness of corrective action is checked by site QA audits in a : rdance with 17.4.18. l 6 0 t a t
8 i.7:p-l PSAF. 17.4.16.4 Failure to Ressend a) Failure to respond either by the Site Centra:- 4 tors er Proje:t Construction Manage:2nt to Cerrective Action Requests within a reasonable time will result in notifi. ation of the site Contractor or Centractor Management with a i requirement fcr immediate respcase. Lack of response will Issult in steppage of work in the affected area in accordance with the Nuclear QA Manual. 17.4.16.5 Step E'c % authority a) Step work. authority for site activity rests with the Project Manager based en directicn received via a " Step Work Crder" frem the Field Superintendent Quality Assugance. b) Ucrk may be restarted with the approval of the Field Superintendent Quality Assurance only after acticn has been taken to eliminate the noncon-4 fermance and the respcnsible party has satis-ia::crily replied t: the " Step ;;crk Crder". 17.4.17 Ouality Assurance Records Site Qualit. Assurance is resp:nsible fer the main-tenance and control of the WNP-1 Site Quality Assurance Master Files. During cc,nstruction of the ASME Section III, Div. 2 Containments. Applicable records will be maintained throughout the receiving, storage, constructica, ,,, __ y installatien and testing phases of the project and will he ~ collected at the site.to for= a pernanent file of d::uren-tatien furnished by the Project. The Mu: lear QA Manual describes the method for the acec=ulation, organizatien, custedy and retentien of GA and CC records for materials, equipment and activities at the constru: tion site. 17.4.17.1 Site Record Recuirements -a) Quality records requirements for s'ite centrac-1 2 ters are defined in the applicable Constructica Contract specification, codes and standards and in the Nuclear Quality Assurance Manual which govern quality associated site activities. These records include, but are not limited to, results of receiving and stcrage inspections, Site QA surveillance and audits, construction and installi'..on tests, material analysis, meni-toring of work performance, NCR's, maintenance i reports, corrective acti:n requests, qualifica-tion of persennel, pr::edures and equipment and other decu=cntation. 0,. 1 a 1 m m, -. ...v w,- ,.,m-- v -r.
_ l
- 4Np-l PSAR 17.4.17.1 Site Record Recnire=ents (Cc.:inued) b) Records are identified with the systa=, struc-ture or ccepenents to whi:h they pertain and are filed (17.4.17.3) to provide accurate re-trie. val withcut undue,ielay. Records will be
=aintained in accordance with ANSI N45.2.9, " Require =ents for Cc11ectica, Storage and Main-tenance of Quality Assurance p.ecords for Nuclear pcwer plants". Contract specificatiens direct the Site Centractor to pr: vide a positive =ethod of traceability fr== de:::entatien to installati:n c' the part. \\ P 17.4.17.2 Site Records Review il el a) Site Quality Assurance i=ple=ents an aud.'.: and surveillance effort of Centractor inspectlen groups in order to be assured that each site contractor is follcwing approved =ethods of verifying acceptability of their data. Sur-veillance of reports and inspectica data ap-plicable to (1) vender generated d:cumenta-tien f:: pre-purchased equip =ent; (2) centract:r generated d--"-a--=:i:n f:: c::::ac:c purchased equip =ent and; (3) site con.rae::: generated d:cu=entation, is i=ple=e..ted to assure pr:per appr:vals and accepta.ces. b) The review of records (data) at site receiving areas for pre-purchased egaip=ent is initiated perfor=ed, appreved and filed by Site Quality Assurance i: ac:wrdance with the Nuclear QA Manual. This data review ::nfir:.s that the data, as received, is consistent with the c:n-tract decu=ents. c) The review of records (data) at site receiving areas for site contra:ter pur:hased etaipment, is initiated, perfor:ed and re==rded by cen-tractor persennel in accordance with an approved procedure. This records review is to check the docu=entation received fer availability and tech.ical adequacy agains: required d:cu=entation as defined in the Centrac:cr procurement docu=ents. d) The review of reco.ds at curnover for pre-pur-chased and centracter purchased egaipment at the construction site is initiated, perfor=ed and S o
~
- WP-1 s
PSAR 17.4.17.2 Site Reccrds Review (Centinued) d) recorded by Site Quality Assurance. This records review is to check the available decurentation I used for the equipment installatien against the required documentatica and to verify the ec=plete- ' ness and acceptability of turnover documentation package for the equipment. 17.4.17.3 Site Records File .i a) The Master QA file centains reccrds pertinent to Quality Centrol and Q;ality Ac2urance and will be located within the offices of the Site Quality lll Assurance. Access to these master files will 4 be controlled by the Project Quality Assurance i , I Manager. Authorized representatives of site QA, inspection agencies and audit pers:nnel will' be permitted access to the Master files under the direct supervision of the Field Superintendent Quality Assurance. h? The Master Quality Assurance rile will consist of: i 1. ?urchase Docunenes which contain fata packages received tiith the cenpenents and asecciated documentation whether purchased by the Project er a centractor. 2. CL.aral Deccmerts such as surveillance i repcrts, noncenfor=ince reports and cer-rective acticn requests. 3. Cemcenent Docu=ents which censists of a ecpy of all Receiving Records Review. 1 il 4. Systems Decuments which censists of a copy of all Data Review Receiving and Oata Re-view Installation Records. 5. Site Contractor Documents. The original l site contractor files will be caintained l by the contractor until turned over to l Site QA during the course of construction. l -3s-l 8 l l j e s o i t t r-w- .~ ,-r'w m-- e e, w,- -~ e ,,c,w -e -rn,--eve-, w-- y e w -, w,-~e e m +---e,- v
1.sP-1 PSAR I 17.4.17.3 Site Records File (Centinued).
- ) To provide prctection against 1:ss or destruc-t tien, records will be naintal:.ed in accordance with JNSI N45.2.9.
Documents shall be indexed and microfilmed in accordance with appropriate procedures. d) QA records filed as part of the Sita Master Quality Assurance Files shall be indexed, cross-referenced, filed and controlled in accordance with the ::uelear QA Manual. 17.4.17.4 Site Records Stcrase a) The Master gua.1., Assurance files will be lo-cated in ( su2t-bly protected environment at the construction site for storage of quality related records generated during the precure-1 ment and construction phases of the project, and will serve the function of p cviding readily accessible doen?.entary evidence of ccepliance with the quality requirerents cf equipment and installa:ica spe:ifications and applicable codes and s:1ndards. b) QA records s:crage facilities at the site will be constructed and located as : prctect cen-tents fr m possible destruction by causes of fire, ficoding, larceny, vandalism, redents and frem possible deterioratien by a ecmbina-tien of extreme variations in temperature and ~"'i,- humidity conditiens. c) Access to Quality Assurance Ae:Ord st: rage facilities will be restricted te designated individuals within the Site Quality Assurance organization responsible fer safekeeping cf the documents. 17.4.17.5 Site Records Retention a) All reccrds will be re:sined during the site construction offert, at the end of which, retentien perieds (i.e., life ti=r, nonper- =anent time period) fer the records will be assigned. b) Site Contracters will maintain their en-site QA files, and original rec:rds shall not be removed frem the site without prior approval of Site Quality Assurance.. O e -6
9 3
- s i
I j WNP-1 PSAR c) All records are the property of the owner and shall not.be destreyed cr.etherwise disposed-1 of without the written consent of the Cwner. All records shall be turned over to the Crner or his agent after cocpletica of construction. W' + i! MR S b ( 1. l' l l .i ( i l l t I I l i . l-t i -36a-( I i I l 8 i 1 [. ~. - -. ~ - - - -.. - - -
q L WNp-1 PSAR 19,.,A 10 A.Ja.s 1 The Site QA Audit program pr:vides for regularly scheduled and unscheduled audits of each site cen-tracter's Quality Assurance.cregra= which will verif.v their cenpliance with their a.c.eroved QA and QC.crece-dures. These audit records of the contracters con-struction and installatien practices offer objective evidence of i=plementatica of and c: pliance with re-quire =ents, and censistency in the discharge of their site responsibilities. 17.4.19.1 Tvres and Catscerias Audits will be performed en Site Centractors, to verify that activities and ite=s are in cenfernance with specified requirements and to ascertain that the procedures and other docu=ents governing their res-pective site activities and constructica ite=s cen-tain sufficient requirements to assure that the quality specified is achieved. Ghese audits will be perfor=ed by Site Quality Assurance persennel she, by the nature cf their pcsitiens, are inde.:endent f :: the Manufac-turing and Construction disciplines and who hava nc ...,.-. s.a.a.,......u.., s.a.,. a.. a.. a. a, s.-,..a
..2
...u, a) Site Centracter Audits The audit program of site contract::s activities is imple=ented by the Field Superintendent Quali-ty Assurance. The FSQA defines the scope, se-1ects auditors, schedules audits and fellows up --,s en c=rrective actions. The auditer (team chair- =an) prepares a written checklist delineatin the C,,an.,.a..-_ s.a s.o _e a..a.t.,.s.. ..u.,. ,. J.a.. c.a...,. .m activity is then condu:ted in a:cerfance with this checklist and upon completien cf the audit, the results are presented, discussed and sun =ar- ~ ized in a written repert. 17.4.18.2 Audit Planning a) The general s:hedule fer the activities for which audits are required is established fefining the frequency of audits for each activity; dates of audits, if feasible; including verification audits, auditor (s) and tentative dates of subsequent audits. The fre uenev. cf audits in any..txticular site acti-vity is predicated by: 9.
3 e c
- M.s *J. T a..
pSAR Ii-17.4.13.2 Audit planning (Centinued) a) 1. The level cf activity in the particular i area, as dictated by the stages of cen-i struction. l 2. Results of crevicus audits of that par-j ticular site centractor a:tivity, i ~ 3. Adverse indications throu7h an analysis of ncnconfer=ance reports er ccrplaints. Unless otherwise detar.ined by the aheve cen-ditions, each area will be audited en an annual basis. b) The audit categories ence: passing quality re-lated activities will be based en the applicable criteria cf ICCIRSO, Appendix 3, and ASME Sectica III, Div. 2 by Site Quality Assurance. Audits of these site activities include an evaluatien of precedures in use in the area being checked, the effectiveness of their irplenentation and a sa:- pling cf the area cu:put and ssecciated documents and rec:rds. 17.4.18.3 Audit Team a) The requirements for audit taas sele::ica and par-ticipation for site Centract:r audits, audit pre-paratien, planning and reporting, and suitable training and the maintenance f prefi:iency records --c for audit:rs of c:nstructica activity are in a :::- dance with the Nuclear QA Manual. 17.4.12.4 Audi precedure a) preparation for the site contracter audit by the Audit Team *eader entails eccrdinatien with the appropriate Site Contract: QA personnel for scheduling arrangements. b) Site audits are perf:r=ed in = -- '*- e with the Nuclear QA Manual. c) A ce=plete re:Ord ".le is ke:: cf audits.cer-fermed, which prev de project Management with the e means te analyre and evaluate the centractor is-ple=entation of the quality Assurance program. I g e
.t s a WNP-1 PS7 R 17.4.18.5 Site Audit Analysis a) A conthly site audit status rescrt of site QA findings will be published by the FSQA with dis-tribution to the appropriate Prcject :anagenent personnel. The report will identify findings of site audits conducted during the repceting period and record the status of items still pend-ing frc= previcus site audits. b) FSQA uses these reports as the basis for deter-mining quality trends developing in the various areas of the site Quality Assurance Program for the project. c.' FSQA pursues resolution of these areas of concern which indicate a decrease in the effectiveness of the site QA program for the project. d) Unsatisfactory trends will be resolved by the FSQA in accordance with Section 17.4.16. -a . ~' i l l I E o I
ec Us r0 M i f.3 ( e =r UU a Ul%C Vice .UELC Mgr. (,C l'j N I'res. & Group g g pg g i Mariager te ne O n H (Cons trtie t.iori) H e8 fee fI[;e 1 0, Asst. Mgr. RG 9^ D0 COltl'OltATM m ec m *- eC d. bz PII*I.D
- O i
NS a ls l'roj.ect. Itcsident getoject U [/ Mgr Construction
- .I I I QA Mgr.
[.. m Mgr. eI u til () i _L ^ ~~ Field I'roject. I Eng. Mgr. I l I i i UA I i l y Staff l l I ge si m se t i i >+ o i n m -4 >e L_--________L___________i .,t ,ao p M wt De ni D ( e en un U.1 e tN 5 i (4 * ) m3 = g.: q c .c n. el o ne 64 h et i Oe GP O4 1 49 sJ s N sta U Us D '.1
- $e g) 84 is nmn o m ::
(4 De e4 O 11 'f t Z Jlb *e k:' !r!, "a,! o et De g 3 = 9 e .s ? $~ f '.../. i ,....-~ -.. .}}