ML20024J079
| ML20024J079 | |
| Person / Time | |
|---|---|
| Site: | 05200003 |
| Issue date: | 12/15/1993 |
| From: | Alsing D, Bruschi H WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | |
| Shared Package | |
| ML20024J078 | List: |
| References | |
| WCAP-12600, WCAP-12600-R02, WCAP-12600-R2, NUDOCS 9409190057 | |
| Download: ML20024J079 (110) | |
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1 AP600 Advanced Light Water Reactor Design Quality Assurance Program Plan prepared for Advanced Reactor Corporation Palo Alto, CA ARC-93-3-SC-001 December 15,1993 I
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j) Westinghouse Electric Corporation L
M E" B*dl M E L t__ _________________ ___ D ______________ _ ___ o n k._______________________________ _ _____ _ ______-_______ _ _ _ _ _ _ _
AP600 DOCUMENT COVER SHEET Form 58202F(9/93)[WP xxxx] AP600 CENTRAL FILE USE ONLY: RFS#- RFSITEM s:
ooS8.FRM AP600 DOCUMENT NO. REVISION NO. PAGES ATTACHED ASSIGNED TO GW-GAM-001 3 ALTERNATE DOCUMENT NUMBER: WCAP-12600, Rev. 2 ATTACHMENTS DESIGN AGENT ORGANIZATION: Westinghouse ,
WCAP-8370, Revision 12A j PROJECT:
I' WORK BREAKDOWN #: GW-GA TITLE: AP600 Quality Assurance Program Plan 1
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CALCULATION / ANALYSIS
REFERENCE:
None DCP #/REV. INCORPORATED: I None I ELECTRONIC FILENAME: APPLICATION:
I WESTINGHOUSE PROPRIETARY CLASS 2 This document contans information propnetary to Westinghouse Electne Corporaton: it is submitted in confidence and is to be used soisey for the purpose for which it is fumished and retumed upon request. This document and such information is not to be reproduced, transmitted, diecioned or used otherwise in whole or in part without pnor wntten authonzation of Wesanghouse Electric Corporabon, Energy Systems Business Unit, -
subject to the legends contained hereof.
p.1 WESTINGHOUSE CLASS 3 (NON PROPRIETARY) p:1 DOE DESIGN CERTIFICATION PROGRAM GOVERNMENT UMITED RIGHTS STATEMENT [See reverse side of this form)
@ (C) WESTINGHOUSE ELECTRIC CORPORATION 19_
A Icense is reserved to the U.S. Government under con *eact DE-ACO3-90SF18495.
@ DOE CONTRACT DELIVERABLES (DELIVERED DATA) ,
Subject to specified exceptons, disclosure of this data is restncted until September 30,1995 or Desirp Certficaton under DOE !
contract DE-AC03-90SF18495, whichever is later. 1 EPRI CONFIDENTIAllOBLIGATION NOTICES: NOTICE: 10 2 3 4 5 CATEGORY: A B C D E F@
g ARC FOAKE PROGRAM ARC LIMITED RIGHTS STATEMENT [See reverse side of this form]
@ (C) WESTINGHOUSE ELECTRIC CORPORATION 19 93 A heense is reserved to the U.S. Govemment under contract DE-FCO2-NE34267 and subcontract ARC-93-3-SC-001.
@ ARC CONTRACT DELIVERABLES (DELIVERED DATA)
Subject to specified excephons, disclosure of this data is restncted under ARC Subcontract ARC-93-3-SC 001.
E ORtGINATOR SIGNATURE /DATE f D. N. Alsing /f/,'f 4
h ASAASEiL SIGNATU
- APPROVAL DATE ATBA Genera Manager / . x L H.-J. Bruschi x W 6,/993 I
- Approval of the responstWe manager segnifes that%c Dmp6ete, all required revows are comp 4ete, emetronc file erTattached and Occument is released for use.
Form $8202F(95e3)
LIMITED RIGHTS' STATEMENTS DOE GOVERNMENT LIMITED RIGHTS STATEMENT (A) These data are submrtted with hmited nghts under govemment contract No. DE-AC03-9CSF18495. These data may be reproduced and used by the government with tne exprese 6mitabon that they will not, without wntten permission of the contractor, be used for purposes of manufacturer nor dsclosed outside the govemment; except that the govemment may disclose these data outado the govemment for the followmg purposes, sf any, provided that the govemment makes such disdosure subject to prohibiton against further use and disclosure:
g (1) This 'Propnetary Data' may be disclosed for evaluaton purposes under the restrichons above.
(11) The 'Propnetary Data' may be diadosed to the Electnc Power Research Insatute (EPRI), electne utihty repi e tanves and their drect consultants, exduding drect commercial compettors, and the DOE Natonal Laboratones under t., prohibitons and restnetions above.
(B) This nobce shall be marked on any reproducton of these data, in whole or in part.
ARC UMITED RIGHTS STATEMENT:
This propnetary data, fumished under Subcontract Number ARC-93-3-SC 001 with ARC may be dup 6cated and used by the govemment and ARC, subject to the hmrtabons of Artde H 17.F. of that subcontract, with the express hmitations that the propnetary data may not be diadosed outade the govemment or ARC, or ARC's Class 1 & 3 members or EPRI or be used for purposes of manufacture without pnor permismon of the Subcontractor, except that further disclosure or use may be made solely for tne followmg purposes:
This propnotary data may be diadosed to other than commercial compettors of Subcontractor for evaluaton purposes of this subcontract under the restncbon that the propnetary data be retained in confidence and not be further desdosed, and subject to the terms of a non-desclosure agreement between the Subcontractor and that organtzation, exduding DOE and its contractors.
DEFINITIONS DELIVERED DATA - Consists of docurnents (e.g. specifications, drawings, reports) which are generated under the DOE or ARC contracts.
EPRI CONFIDENTIALITY / OBLIGATIONN071CES NOTICE 1: The data in this document is subject to no confidentiality obligabons.
NOTICE 2. The data in this document is oropnetary and confidential to Westinghouse Electnc tion and/orits Contractors. Itis forwarded to recipient under an obhgation of Confidence and Trust for hmited purposes only. Any use, sure to unauthonzod persons. or copying of this document or parts thereof is prohibited except as agreed to in advance by the Electric Power Research insatute (EPRI) and Wesbn use Electne Corporanon. Recipient of this data has a duty to inquire of EPRI and/or Westinghouse as to the uses of the informabon con herein that are permitted.
NOTICE 3: The data in this documentis propnetary and confidential to Westngnouse Electnc Corporabon and/orits Contractors. It is forwarded to recipient under an obhgabon of Conhdence and Trust for use only in evaluation tanks speerfically authonzed b the Electne Power Research Insttute (EPRI). Any use, esdosure to unauthonzod persons, or copyng this document or parts thereof is beled except as agreed to in advance by EPRI and Westinghouse Electne Corporaton. Recipient of this data has a duty to inqare of EP I and/or Wasanghouse as to the uses of the information contarned herein that are permitted. This document and any copes or excerpts thereof that may have been generated are to be retumed to Westnghouse, drectly or through EPRI, when requested to do so.
NOTICE 4: The data in this document is proprietary and confidential to Westnghouse Electric Corporation and/or its Contractors. It is being revealed in confidence and trust only to Employees of EPRI and to certain mntractors of EPRI for kmsted evaluaton tasks authonzed by EPRI.
Any use, disclosure to unauthonzed persons, or copying of this document or parts thoroof is prohibrted. This Document and any copies or excerpts thereof that may have been generated are to be retumed to Wesenghouse, directly or through EPRI, when requested to do so.
NOTICE 5: The data in this document is proprietary and confidential to Weshnghouse Electnc Corporabon and/or its Contractors. Access to this data is given en Conhdence and Trust only at Wesenghouse facshties for hmited evaluation tasks asered by EPRI. Any use, disdosure to unauthonzed persons, or copying of this document or parts thereof is prohibited. Norther this document nor any excerpts therefrom are to be removed from Westinghouse facihtes.
EPRI CONFIDENTIALITY / OBLIGATION CATEGORIES CATEGORY "A" - (See Dehvered Data) Consists of CONTRACTOR Foreground Data that is contained in an issued reported.
CATEGORY *B" - (See Delivered Data) Consists of CONTRACTOR Foreground Data that is not contamed in an issued report, except for computer programs.
CATEGORY "C" - Consists of CONTRACTOR Background Data except for computer programs.
CATEGORY "D" - Consists of computer programs developed in the course of performing the Work. ,
CATEGORY "E" - Consists of computer programs developed pnor to the Effeebve Date or after the Effective Date but outade the scope of the Wort CATEGORY "F" - Consists of admrnestrative plans and administrative reports.
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AP600 RECORD OF CHANGES Form 58204 (1-91)
AP600 DOCUMENT NO. GW-GAM-001 REVISION 2 j ALTERNATE DOC. NO. WCAP-12600, Revision 2 DESIGN AGENT ORGANIZATION Westinghouse TITLE AP600 Quality Assurance Program Plan CHANGE PARAGRAPH CHANGE DESCRIPTION AND REASON ENGINEER NUMBER NUMBER APPROVA!/DATE 1 Foreword Revised to address ARC Comments on. Revision 1.
2 Part A, Revised per Current ATBA Section 1 Organization.
3 Part A. Revised to Address ARC Coments Section 2 on Revision 1.
4 Part B, Revised to address ARC Comments Section 2 on Revision 1.
5 Part B, Revised to clarify AP600 QA Section 11 Program Provisions for Test Control.
6 Part B. Revised'to Address ARC Comments Section 18 on Revision 1.
k.A.I h /J-7.z;j K. A. Kloes 0012.FAM
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QUALITY ASSURANCE PROGRAM PLAN !
TABLE OF CONTENTS i l
Page l Statement of Policy and Authority ii l Foreword iii - iv !
l PART A - MANAGEMENT I Section i 1 Organization 1-5 2 Quality Assurance Program 6 3 Regulatory Commitments 7 PART B - PERFORMANCE / VERIFICATION Section 1 Responsibilities 8 2 Instructions, Procedures, and Drawings 8 ;
3 Document Control 9 4 Design Control 9 5 Computer Software 9 6 Procurement Document Control 10 !
7 Control of Purchased Items and Services 10 - 11 8 Identification and Control of Items 11 9 Control of Processes 11 10 Control of Measuring and Test Equipment 11 11 Test Control 12 12 Handling, Storage, and Shipping 12 13 Inspection 12 14 Inspection, Test, and Operating Status 12 15 Control of Nonconforming Items 13 16 Corrective Action- 13 17 Quality Assurance Records 13 18 Audits 14 PART C'- SELF-ASSESSMENT 'l Section 1 Self-assessment 15 ATTACHMENT WCAP-8370, Revision 12A GW-GAM-001, REV. 2 i
e STATEMENT OF POLICY & AUTHORITY :
It is the policy of the Advanced Technology Business Area to provide systems, products and services that meet or exceed the quality assurance requirements of the Department of Energy and the Nuclear Regulatory Commission.
The Advanced Technology Business Area General Manager is responsible' for the AP600 quality assurance program. He ensures its development, t implementation and verification, and retains review and approval authority ,
in matters pertaining to the implementation of the requirements of the quality assurance prograin, r
The Quality Assurance Manager is empowered to act on behalf of the General j Manager to ensure the implementation of this Quality Assurance Program j Plan and has direct access. to the General Manager to ensure that appropriate action is taken to resolve all quality related issues. The Quality Assurance Manager is sufficiently free from direct pressure of cost and schedule, and has authority and access to work areas, to identify quality problems; initiate, recommend, or provide solutions to quality problems through designated channels; verify implementation of solutions; and assure that further processing, delivery, installation, or use of items or services is controlled until proper disposition of a nonconformance, deficiency, or unsatisfactory condition has occurred, including the authority to stop unsatisfactory work if necessary.
Each performer and manager is fully responsible for implementing these quality assurance requirements to achieve the quality and safety of the simplified passive advanced light water reactor Design Certification and First-of-a-Kind Engineering activities. Each manager is responsible for providing the necessary instruction and training to assure that work.is l performed in accordance with these requirements. ')
Changes to this document and ~ to this statement of policy and authority will be approved by the Advanced Technology Business Area General Manager.
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I GW-GAM-001, REY. 2 ii I
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FOREWORD The Vice President and General Manager of the Westinghouse Energy Systems l Business Unit has committed the resources and support of the Westinghouse l Electric Corporation to the Simplified Passive Advanced Light Water l Reactor Plant (AP600) Program. As a supplier of items and services to the l nuclear industry, Westinghouse has established a single Quality Assurance l Plan (QAP) that complies with the applicable government regulatory and industry requirements. The QAP is identified as topical report WCAP-8370, currently Revision 12A. WCAP-8370 applies to all Westinghouse activities affecting the quality of such items and services, including the AP600.
Since the scope of these activities includes operating plants and plants under construction, WCAP-8370 commits to meeting 10CFR50 Appendix B, ASME NQA-1 and NQA-2, and United States Nuclear Regulatory Commission (NRC)
Regulatory Guide 1.28 Revision 3. WCAP-8370 Revision 12A has been accepted by the NRC.
The AP600 Quality Assurance Program Plan (QAPP), WCAP-12600, affirms the commitments established in WCAP-8370 for the AP600 program. It does not replace WCAP-8370, although it does establish commitments for the AP600 program that are in addition to those in WCAP-8370. WCAP-12600 further describes how some specific features of the program relate to selected criteria of the NRC Standard Review Plan, NUREG-0800, Chapter 17.3
" Quality Assurance Program Description."
WCAP-12600 was initially developed for the Design Certification program, and it continues as an integral program for First-0f-A-Kind Engineering ,
(F0AKE). It therefore applies to work performed on both programs.
The commitments in WCAP-12600 to regulatory requirements and industry standards are tied to those established in WCAP-8370, and meet or exceed the requirements of the Design Certification and F0AKE contracts.
Commitments are revised when necessary to meet new NRC or customer requirements, or when deemed necessary by Westinghouse management to improve the quality of the items and services provided.
GW-GAM-001, REV. 2 iii
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4 FOREWORD (Continued)
WCAPs 8370 and 12600 also provide a foundation for implementing corporate !
Total Quality goals. The commitments established in response to NQA-1 requirements also support Westinghouse Total Quality initiatives. For i example, the provisions for training support the human resource excellence i initiative; management assessments support the management leadership !
initiative; self- assessments support the product / process improvement ;
initiative; and the utilization of the 'Aility Requirements Document as ,
input to the design process supports the customer satisfaction initiative.
Total Quality initiatives are also implemented by means that are outside 3 the scope of WCAPs 8370 and 12600, such as the Energy Systems Business Unit Bustrass Improvement Plan. This olan establishes quality improvement F and performance measurement object' a , integral with the financial and other non-financial business unit objectives. The Business Improvement Plan includes companion plans at lower organization levels within the Business Unit.
WCAP-8370 governs all Westinghouse nuclear work and provides for certain -
i interfaces with the NRC. For example, WCAP-8370 is submitted for NRC acceptance, and the NRC must be notified of changes in accordance with ;
10CFR50.55 (f)(3). Commitment to specified Regulatory Guides for the QA ,
program is addressed in the Standard Safety Analysis Report (SSAR), Since j WCAP-12600 continues to apply to activities associated with the Design Certification phase, the QA program provides for a management position with responsibilities for interfacing with the NRC. !
Changes to the commitments contained in this Quality Assurance Program Plan will be submitted to the Advanced Reactor Corporation (ARC) and to ,
the Department of Energy (DOE) for review and acceptance. ,
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PART A - MANAGEMENT !
SECTION 1 - ORGANIZATION See WCAP-8370 Part A, Section 1. Details of the specific organizational structure for AP600 activities are provided below.
1.0 General The Advanced Technology Business Area of the Energy Systems Business Unit l (ESBU) is responsible for Design Certification and First-of-a-Kind Engineering for the Simplified Passive Advanced Light Water Reactor Plant (AP600) and for control of the technical interface between Westinghouse engineering groups and suppliers providing engineering services.
Westinghouse management is responsible for activities affecting quality as required throughout this Quality Assurance Program Plan.
1.1 Responsibility .
The authority and responsibility of each group within the Advanced Technology Business Area is established by the General Manager. 1 Responsibility for the establishment of the Quality Assurance Program Plan f and for assuring its effective implementation is assigned by the General Manager to the Quality Assurance Manager.
The organizational structure, functional responsibilities, levels of authority, and lines of communication for activities affecting ' quality are defined in Figure 1, Page 5 and throughout this Quality Assurance Program - !
Plan.
Responsibility for achieving quality is assigned to each' individual or organization performing the work. The verification of quality achievement is assigned to individuals or groups r.ct directly responsible for i performing the work.
1 GW-GAM-001, REV. 2 1
1.1 Responsibility (Continued)
Each manager with responsibilities in the quality assurance program may delegate work to others but shall retain responsibility for the work.
Each manager is responsible for control of engineering cost and schedule for assigned activities; ensuring that the design effort is performed in accordance with approved design criteria and guidelines and applicable government, industry and environmental standards; and developing standards and procedures as needed.
1.1.1 Advanced Technology Operations The Advanced Technology Operations Manager is responsible for the 1 administration, implementation, and maintenance of the Westinghouse AP600 management control system; program cost and schedule reporting; customer interaction on contractual matters; configuration management administration and administration of all subcontracts and technical j agreements with international participants. '
In addition, the Advanced Technology Operationr danager is responsible for-the AP600 systems engineering management activities which include serving as the Configuration Control Board Chairman; Reliability, Availability, and Maintainability (RAM) Program implementation; evaluation of plant cost objectives; URD Conformance Assessment and maintenance of the URD database; coordination of utility participation in reviews of the plant design and maintenance; and coordination of Competitive Technology evaluations for optimization of the AP600 design.
1.1.2 AP600 Design Certification Project The AP600 Design Certification Project Manager. is responsible for all aspects of managing and directing the successful implementation of the AP600 Design Certification program. These activities include Design Certification test programs and related analyses; safety, regulatory, and probabilistic analyses; interfacing with NRC on licensing matters; coordinating responses to NRC Requests for Additional Information (RAls);
and maintenance and revision of the Standard Safety Analysis Report (SSAR)
GW-GAM-001, REV. 2 2
1.1.2 AP600 Design Certification (Continued) and the Probabilistic Risk Assessment Report (PRA).
1.1.3 AP600 FOAKE Project The AP600 F0AKE Project Manager is responsible for managing and directing all aspects of implementing the F0AKE contract with ARC and DOE, consistent with the design developed in the Design Certification phase.
These activities include the design and analysis of safety and non-safety systems, structures, and components throughout the plant; establishing functional requirements; review and approval of design and manufacturing drawings and specifications; man-machine interface design, control systems, and control room design; modularization; plant arrangement; constructibility, construction methods, and construction schedule; plant cost estimate; and plant information management system. The AP600 F0AKE Manager is also responsible for managing, directing, and integrating the technical design and development activities performed by supporting engineering groups, both internal and external to Westinghouse. l
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1.1.4 Quality Assurance The Quality Assurance Manager is responsible for developing the Quality Assurance Program Plan; documenting, approving, and verifying implementation of a quality assurance program that meets the requirements of this Quality Assurance Program Plan; assuring the development of implementing procedures; verifying that activities affecting quality have been correctly performed; and reporting to management the degree of compliance. In addition, the Quality Assurance Manager has no responsibilities unrelated to quality assurance that would prevent full attention to quality assurance functions.
Quality Assurance activities include review of design' specifications for which Advanced Technology Business Area is the design agent (and drawings I
when used as such design specifications) and procurement documents; performance of supplier evaluations and audits; maintenance of the quality assurance program, review and development of procedures; performance of 4
GW-GAM-001, REV. 2 3 i
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1.1.4 -Quality Assurance (Continued) ,
l internal audits and, at the discretion of the Quality Assurance Manager, ;
participation in work schedule and status meetings. l l
The minimum qualification requirements for the Quality Assurance Manager are as stated in WCAP-8370.
1.1.5 Procurement Services ;
Through a matrix organization, the ESBU Procurement Services Department l provides procurement services and acts as the interface between the Advanced Technology Business Area and suppliers of procured items and services. Procurement Services also provides cost information on components from suppliers to support the plant cost estimate. Procurement j activities for items and services are accomplished in accordance with i established procedures and the requirements of this Quality Assurance Program Plan.
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GW-GAM-001, REY. 2 4
$ AP600 ORGANIZATION a
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VICE PRESIDENT AND N GENERAL MANAGER ENERGY SYSTEMS BUSINESS UNIT GENERAL MANAGER !
ADVANCED TECHNOLOGY BUSINESS AREA I
l l l l ADVANCED AP600 DESIGN TECHNOLOGY CERTIFICATION l AP600 FOAKE QUALITY OPERADONS PROJECT PROJECT ASSURANCE l
1 ESBU PROCUREMENT SERVICES FIGURE 1
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I SECTION 2 - QUALITY ASSURANCE PROGRAM See WCAP-8370 Part A, Section 2. Application of WCAP-8370 to AP600 activities includes the following:
o The graded application of quality requirements is based on a documented safety classification system that designates the safety class of equipment, components, and structures. Quality requirements appropriate to each safety class are applied.
o The training of personnel who perform or manage activities affecting quality includes indoctrination to the requirements of this Quality Assurance Program Plan, related quality program standards and implementing procedures, and special skills required for the performance of activities. This training is documented and identifies the name of the trainer, personnel in attendance, the subject and scope or content of the training, the location where the training was received, and the duration of the training. Management annually evaluates and documents the maintenance of proficiency of personnel in activities affecting quality.
o Management regularly assesses the adequacy and effectiveness of the quality assurance program and its implementation for compliance with the requirements of this Quality Assurance Program Plan. Management assesses their functional areas by evaluating such documents as internal and external audit reports, self-assessment reports, nonconformance reports, procedures and instructions. Additionally, consideration is given to updating the program as the result of changes brought about by reorganizations, new technologies and quality concepts, to ensure its continuing suitability and effectiveness.
These assessments are documented, and actions are identified and followed to close-out.
GW-GAM-001, REV. 2 6
SECTION 3 - REGULATORY COMMITMENTS l
Regulatory commitments are as specified in AP600 Standard Safety Analysis Report GW-GL-021. The commitments in WCAP-8370 are consistent with those ,
in the Standard Safety Analysis Report.
GW-GAM-001, REV. 2 7
PART B - PERFORMANCE / VERIFICATION SECTION 1 - RESPONSIBILITIES See WCAP-8370 Part B, Section 1.
SECTION 2 - INSTRUCTIONS, PROCEDURES, AND DRAWINGS See WCAP-8370 Part B, Section 2. Application of WCAP-8370 to AP600 activities includes the following:
o The principal document establishing the procedures for activities that affect quality is WCAP-9565, " Nuclear and Advanced Technology Division Quality Assurance Program." Additional procedures specific to the AP600 program are contained in WCAP-12601, "AP600 Operating Procedures Manual." WCAP-12601 contains a matrix that shows the relationship between WCAP-12601 procedures, the applicable procedures of WCAP-9565, ai.d the QA program criteria of NQA-1.
o Project-specific procedures are prepared by the organizations that have primary responsibility for the activities. Procedures identify the responsible functions and specific actions necessary to implement these activities. Procedures are reviewed by Quality Assurance.
GW-GAM-001. REV. 2 8
SECTION 3 - DOCUMENT CONTROL See WCAP-8370 Part B, Section 3. Application of WCAP-8370 to AP600 activities includes the following:
o Documents that portray the AP600 design or its basis are uniquely ;
identified in accordance with a documented numbering system that is applied to all internal and external participating design organizations, o An Information Management System (IMS) is implemented among l interfacing internal and external design organizations, which provides !
an effective means (using a plant-wide numbering system) to acquire, store, and retrieve the documents and data necessary to design the plant.
l SECTION 4 - DESIGN CONTROL See WCAP-8370 Part B, Section 4. Application of WCAP-8370 to AP600 activities includes the following:
o Changes to a design that has been previously released in a document for project use and placed under configuration control are subject to review and approval by a Configuration Control Board. The organization, responsibilities, and activities of the Configuration ;
Control Board are in accordance with written procedure.
SECTION 5 - COMPUTER SOFTWARE i See WCAP-8370 Part B, Section 5.
GW-GAM-001, REV. 2 9
SECTION 6 - PROCUREMENT DOCUMENT CONTROL i See WCAP-8370 Part B, Section 6. Application of WCAP-8370 to AP600 activities includes the following: !
o Technical and quality requirements are communicated to organizations that supply testing and engineering services through Purchase Orders and technical cooperation agreements. Technical cooperation agreements require the same degree of review and approval as Purchase Orders.
o Procurement documents specify technical requirements (for procured I items) by reference to design documents that are prepared, reviewed, approved, issued, and revised in accordance with NQA-1 Supplement 35-1. When changes to technical requirements are made directly in procurement documents, the appropriate design documents are revised and incorporated into the contract before the item is released.
SECTION 7 - CONTROL OF PURCHASED ITEMS AND SERVICES See WCAP-8370 Part B, Section 7. Application of WCAP-8370 to AP600 activities includes the following:
o The initial qualification and subsequent performance evaluation of suppliers to which technical cooperation agreements apply is performed in the same manner as for suppliers of purchased items and services.
o Supplier selection is not based on history alone unless at least one of the following conditions applies:
- 1. The supplier has been audited within 3 years for procurement of similar products or services, 1
- 2. An evaluation of the supplier's technical and quality capability is made, or 1
GW-GAM-001, REV. 2 10
SECTION 7 - CONTROL OF PURCHASED ITEMS AND SERVICES (Continued)
- 3. The items are both relatively simple and standard in design, manufacturing, and testing and are adaptable to standard or automated inspections or tests of the end product to verify critical characteristics after delivery.
o The performance of each supplier is evaluated on an annual basis, commensurate with the complexity and importance to safety of the items or services provided. The evaluation is documented and includes evidence, based on direct observation of work performed by the i supplier, that the supplier's quality assurance program is continuing to operate successfully.
SECTION 8 - IDENTIFICATION AND CONTROL OF ITEMS See WCAP-8370 Part B, Section 8. Application of WCAP-8370 to AP600 activities includes the following:
o The AP600 program uses a comprehensive, plant-wide numbering system to provide standard identification for all systems, components, facilities, and documentation.
SECTION 9 - CONTROL OF PROCESSES See WCAP-8370 Part B, Section 9. j i
SECTION 10 - CONTROL OF MEASURING AND TEST EQUIPMENT See WCAP-8370 Part B, Section 10.
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SECTION 11 - TEST CONTROL See WCAP-8370 Part 8, Section 11. Application of WCAP-8370 to AP600 activities includes the following:
l o AP600 testing activities are categorized as safety related, non-safety related, or basic research tests; quality requirements appropriate to each category are applied. ,
o A Test Specification and Test Procedure (s) are developed for each test program. Test Specifications define the test objective (s) and prescribe requirements for the test facility, test articles, instrumentation and data acquisition system, test conditions and ;
parameters, quality assurance, reports, and records. Test Procedures detail the activities and provisions for assuring that calibrated ;
instruments, appropriate equipment, and trained personnel are used; that the condition of test equipment and the item (s) to be tested are verified; that suitable environmental conditions are maintained: that adequate instrumentation and provisions for data acquisition are used; ,
and that the necessary monitoring is performed.
SECTION 12 - HANDLING, STORAGE, AND SHIPPING See WCAP-8370 Part B, Section 12.
SECTION 13 - INSPECTION See WCAP-8370 Part B, Section 13.
i SECTION 14 - INSPECTION, TEST, AND OPERATING STATUS l J
See WCAP-8370 Part B, Section 14.
GW-GAM-001, REV. 2 12
SECTION 15 - CunTh0L OF NONCONFORMING ITEMS See WCAP-8370 Part B, Section 15.
SECTION 16 - CORRECTIVE ACTION' See WCAP-8370 Part B, Section 16. Application of WCAP-8370 to AP600 ;
activities includes the following:
l o The root causes of significant conditions adverse to quality are determined and documented, and the impact of such conditions on completed or related items and activities is evaluated.
l SECTION 17 - QUALITY ASSURANCE RECORDS See WCAP-8370 Part B. Section 17. Application of WCAP-8370 to AP600 activities includes the following:
o Advanced Technology Business Area retains responsibility for maintaining AP600 design documents by requiring submittal of all lifetime design documents from suppliers unless otherwise agreed by contract.
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SECTION 18 - AUDITS-See WCAP-8370 Part B, Section 18. Application of WCAP-8370 to AP600 activities includes the following-o Audits are scheduled and prioritized based on the activity's importance to safety. Audits, however, include non-safety activities ,
important to quality. Emphasis is placed on.the successful performance of activities, and provision is made for the direct :
observation of activities in process.
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PART C - SELF-ASSESSMENT SECTION 1 - SELF-ASSESSMENT See WCAP-8370 Part C, Section 1. Application of WCAP-8370 to AP600 activities includes the following:
o A self-assessment program is implemented to confirm that activities affecting quality are performed in compliance with the quality !
assurance program and to identify opportunities for quality improvement. Following established instructions, periodic self-assessments are performed in each department on a part of the program for which that department is responsible. The f self-assessments typically focus on instructions and procedures which i control activities affecting quality, with the intent of assessing ;
both the adequacy of those instructions and procedures and the -
effectiveness of their implementation. The results of the self-assessment are reported to management for action.
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WCAP-8370, REV.12A WESTINGHOUSE CLASS 3 l
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WESTINGHOUSE ELECTRIC CORPORATION ENERGY SYSTEMS BUSINESS UNIT POWER GENERATION BUSINESS UNIT QUALITY ASSURANCE PLAN APRIL 1992
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Approved '.;;r: J:d /
N. D. Woodson / F. R. Bakos Vice President & General Nanager Vice President & General Manager Energy Systems Business Unit Power Generation Business Unit i
WESTINGHOUSE ELECTRIC CORPORATION ENERGY SYSTEMS BUSINESS UNIT P. O. B0X 355 PITTSBURGH, PENNSYLVANIA 15230 4
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- NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. m APR 23 y Docket No. 99900900 Mr. N. J. Liparulo, Manager ;
Nuclear Safety and Regulatory Activities NATD, Energy Systems Westinghouse Electric Corporation Post Office Box 355 !
Pittsburgh, Pennsylvania 15230
Dear Mr. Liparulo:
Your letter of March 24, 1992, forwarded a proposed revision of WCAP 8370,
" Quality Assurance Plan." WCAP 8370 is the quality assurance (QA) topical report applicable to the Energy Systems Business Unit and the Power Generation Business Unit of the Westinghouse Electric Corporation.
We have reviewed the proposed revision of WCAP 8370 against the acceptance i criteria provided as guidance in Section 17.3, " Quality Assurance Program Description," of NUREG-0800, the NRC's Standard Review Plan. We find the proposed revision describes a QA program that when properly implemented will ;
meet the noted guidance and, therefore, the requirements of Appendix B of 10 CFR Part'50. The proposed revision can be ' referenced by applicants for a ;
combined construction permit-operating license for a nuclear power plant in accordance with.10 CFR Part.52, without further NRC review. The proposed revision is also acceptable for other Westinghouse nuclear activities such as ,
those involved with advanced reactors, nuclear fuel, and maintenance and modifications of existing nuclear power plants. .
Please ident,1fy the revision of WCAP 8370 as Revision.12A,-incorporate a copy of this letter into it, and forward one copy to the NRC in actordance with 10 CFR 50.4. Any questions on the above should be directed to Jack Spraul of.my staff on (301) 504-1023.
9 Gary G. ech, Chief :
Performance and Quality Evaluation Branch !
Division of Licensee Perfomance ;
and Quality Evaluation :
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FOREWORD AND QUALITY POLICY STATEMENT This topical report establishes the Quality Assurance Program require-ments for the Westinghouse Electric Corporation applicable to activities affecting the quality of Westinghouse (H) supplied nuclear power plant items and services. It is the policy of Westinghouse Electric Corporation to comply with the requirements of 10 CFR Part 50, Appendix B as prescribed in Regulatory Guide 1.28, Rev. 3, when supplying items and services to Nuclear Power Plants. The Westinghouse Corporate Policy Statement and Program Requirements defined in this report shall be followed by ESBU and PGBU-Pensacola Plant for items and services supplied to nuclear power plants.
"It is the policy of Westinghouse Electric Corporation to be a reliable supplier of quality equipment, parts and services for nuclear power plants. Orders for such equipment, parts and services, that are requested to be qualified for safety-related applications by Westinghouse, are to be given the attention that is required for applicable regulatory requirements."(1) ,
This topical report, hereafter called the Quality Assurance Plan (Plan),
is implemented by the Energy Systems Business Unit (ESBU) and the Pensacola Plant within the Power Generation Business Unit (PGBU). All orders for items used in nuclear power plant facilities are processed through the ESBU order entry process and, in the case of servic.es, are processed through a Westinghouse Division or organization approved by the ESBU. Items and services supplied are controlled by the ESBU through the procurement control systems described in this Quality Assurance Plan.
WCAP-8370, REV. 12A i l
These procurement control systems define provisions necessary to apply appropriate technical and quality requirements to all tiers of procurement.
Changes that may reduce the commitments contained herein will be submitted to the NRC for approval prior to implementation; other changes will be submitted for approval within 90 days of the change. NRC notification is in accordance with the requirements contained in 10CFR50.55(f)(3).
(1) Excerpted from the Westinghouse Corporate Policy - Equipment, Parts and Services for Nuclear Power Plants. (Rev. 1, 12/89) i WCAP-8370, REY.12A 11
CONTENTS Page Foreword and Quality Policy 1 - 11 Contents jij - vi Introduction 1-3 PART A MANAGEMENT Section 1 ORGANIZATION 4-9 1.0 Organization Structure 1.1 Responsibilities and Authority 1.1.1 Self-Assessment Position 1.2 Functional Department Responsibilities 1.3 Interface Control 2 QUALITY ASSURANCE PROGRAM 10 - 15 2.0 Commitments 2.1 Graded Approach 2.2 Training, Indoctrination, and Qualification 2.3 Management Assessment
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16 - 18 3 REGULATORY COMMITMENTS 3.0 General I' 3.1 Regulatory Guidance PART B PERFORMANCE / VERIFICATION Section 1 RESPONSIBILITIES 19 2 INSTRUCTIONS, PROCEDURES, DRAWINGS 20 3 DOCUMENT CONTROL 21 - 22 ,
3.0 General 3.1 Document Preparation, Review, Approval and Issuance 3.2 Document Changes i 3.3 Controlled Documents i 3.4 Drawing Control WCAP-8370, REV.12A iii l l
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i Section Page 4 DESIGN CONTROL 23 - 28 4.0 General '
4.1 Design Input !
4.2 Design Process 4.3 Design Analyses 4.4 Design Verification 4.4.1 Design Reviews '
4.4.2 Alternate Calculations 4.4.3 Qualification Tests 4.5 Design Specifications 4.6 Design Change Control 4.7 Interface Control 4.8 Documentation and Records 5 COMPUTER SOFTWARE 29 - 30 5.0 General !
5.1 Computer Software Development 5.2 Software Control and Documentation 5.3 Software Testing 5.4 Software Procurement 6 PROCUREMENT DOCUMENT CONTROL 31 - 32 !
6'. 0 Procurement Document Content 6.1 Procurement Document Review 6.2 Procurement Document Changes ,
7 CONTROL OF PURCHASED ITEMS AND SERVICES 33 - 39 7.0 Procurement Planning 7.1 Supplier Selection .
7.2 Bid Evaluation 7.3 Supplier Performance Evaluation 7.4 Control of Supplier Generated Documents 7.5 Acceptance of Items and Services 7.5.1 General 7.5.2 Methods of Acceptance 7.5.3 Acceptance of Services Only '
7.6 Control of Supplier Nonconformances 7.7 Commercial Grade Items 8 IDENTIFICATION AND CONTROL OF ITEMS 40 - 41 8.0 Methods 8.1 Traceability 8.2 Limited Life Items 8.3 Maintaining Identification of Stored Items.
9 CONTROL OF PROCESSES 42 - 43 9.0 Process Control l 9.1 Special Processes WCAP-8370, REY.-12A iv i
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Section Page 10 CONTROL OF MEASURING AND TEST EQUIPMENT 44 - 45 10.0 General 10.1 Selection 10.2 Calibration and Control 10.3 Handling, Storage and Records 11 TEST CONTROL 46 - 47 11.0 General 11.1 Test Requirements 11.2 Test Procedures 11.3 Test Results and Records 12 HANDLING, STORAGE AND SHIPPING 48 12.0 General 12.1 Special Requirements 12.2 Marking 13 INSPECTION 49 - 50 13.0 Personnel 13.1 Planning 13.2 Hold Points, In-Process and Final Inspections 13.3 Records 14 INSPECTION, TEST AND OPERATING STATUS 51 14.0 Identification and Traceability 14.1 Control of Status Indicators 15 CONTROL OF NONCONFORMING ITEMS 52 15.0 Identification, Segregation and Disposition 16 CORRECTIVE ACTION 53 - 54 ,
16.0 General 16.1 Corrective Action 16.2 Follow-up 17 QUALITY ASSURANCE RECORDS 55 - 57 17.0 General 17.1 Record Administration 17.2 Classification 17.3 Storage, Preservation and Safekeeping ,
17.4 Status, Retrieval and Disposition 18 AUDITS 58 - 59 18.0 General ,
18.1 Scheduling 18.2 Preparation 18.3 Audit Personnel 18.4 Performance 18.5 Reporting 18.6 Response, Follow-up Action and Records .
WCAP-8370, REV. 12A v
PART C - SELF-ASSESSMENT Section Page 1 SELF-ASSESSMENT 60 - 61 1.0 General 1.1 Organization 1.2 Objectives and Responsibilities 1.3 Assessment Process LIST OF FIGURES 1 Classification of Items / Services 14 2 Logic Chart for Determining Appropriate 15 Quality Requirements 3 ESBU and PGBU Divisional Structure 62 4 Typical QA Organization Reporting Structures 63 5 Quality Assurance Manuals 64 APPENDICES -
Appendix A Positions on Regulatory Guides A1 - A12 and ASME NQA-1 Appendix B Correlation of WCAP-8370 to ASME NQA-1-1989 B-1 through Addenda Ib and ASME NQA-2a-1990, Part 2.7 Requirements Appendix C Positions on ASME NQA-2 C1 - C2 I
WCAP-8370, REV.12A vi
1 INTRODUCTION This Quality Assurance Plan complies with the criteria of ASME NQA-1-1989 Edition, with Addenda through NQA-lb-1991 and ASME NQA-2-1989 [
edition, with Addenda NQA-2a-1990, Part 2.7, (See Appendix B, Page B-1) l subject to the positions described in Appendix A and C, and is implemented :
by the Energy Systems Business Unit (ESBU) and the Pensacola Plant of the .;
Power Generation Business Unit (PGBU) for the design, procurement, !
fabrication, inspection and/or testing of nuclear power plant items and f services.
The authority and responsibility within ESBU and PGBU is established by the ESBU Vice President and General Manager and the PGBU Vice President ;
and General Manager. Responsibility for the establishment and revision !
of this Plan is assigned by the Vice President and General Manager of j ESBU. Assuring the effective implementation of the commitments of this Plan is assigned by both the Vice President and General Manager of ESBU [
and PGBU. Statements of activity, scope, and function are issued for each Division implementing this Plan. Required documentation of specific j organizational detail, including the authority, responsibilities and interfaces is established and maintained in the ESBU Quality Assurance j Program. Also contained in the ESBU Quality Assurance Program are policies which describe activities that are implemented consistently by each Division in procedures.
Each Division participates in an interdivisional audit program to verify that each participant is implementing its quality assurance program, which complies with this Plan, for items and services provided to nuclear power i plants and/or items and/or services provided to each other. Procurement services supplied by ESBU Procurement Services and project management ,
services provided by the Project D o c tments to the divisions in accordance with that divisions' quality assurance program are included in the scope of these audits. When support services are provided by one division to another, management of the division providing the items or services is responsible for the work performed.
WCAP-8370, REY. 12A 1 l
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This Plan is arranged in three parts that describe the three components of I quality assurance: management; performance / verification; and. self-assessment. These three components of quality assurance place emphasis on the individual performing the work to achieve the level of quality described in this Plan. _j Personnel within ESBU and the Pensacola Plant are responsible for i implementing these. quality' assurance requirements to achieve the highest quality and reliability of the items and services provided to nuclear power plants. Each manager is responsible for providing the necessary personnel indoctrination and training to assure that work is performed in accordance with these requirements.
Terms used in this Plan follow the definitions provided in ASME NQA-1 (for position, See Appendix A, Page A-4), ASME NQA-2 and supplemented by the following terms and definitions applicable to this Plan.
ESBU: The Five (5) Divisions and ESBU Procurement Services-form the Energy Systems Business Unit. [
The Pensacola A functional unit within thr. Power Generation ,
Plant: Business Unit (PGBU). ,
Division: One of the functional units within ESBU and PGBU, i.e., Nuclear and Advanced Technology Division (NATD),
Nuclear Services Division (NSD), Process Control Division (PCD). Electro Mechanical Division (EMD), and Commercial Nuclear Fuel Division (CNFD), and Pensacola Plant.
l Department: A collection of groups having related functions.
Group: A collection of personnel performing the same t i function.
l i Organization: A common term for a division, department or group within ESBU or outside of ESBU. ,
WCAP-8370, REV. 12A 2
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1 Consumable Material: Expendable items that must be renewed or replaced and ;
which have an effect on permanent plant equipment.
Empirical Data: Data obtained from direct observation or experience such as experimental data and plant performance data.
Quality Assurance: The organization (s) to which the Division General ,
t Manager has assigned responsibilities'for specific
- quality verification activities. Titles for these ;
i organizations may vary, and may include Quality Assurance, Quality Control, Product Assurance or _,
similar names. !
Supplier: Any individual, organization or division who furnishes items or services in accordance with a ;
procurement document. ;
{
f The Quality Assurance Program that contains policies ESBU Quality Assurance Program: and procedures that are common to one or more ESBU ;
Divisions and procurment services. !
Safety Class The classification, Safety Class -1, -2, or -3 and' Class 4, for items and related services as defined in i the ESBU Quality Assurance Program. !
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WCAP-8370, REV. 12A 3
PART A MANAGEMENT SECTION 1 ORGANIZATION i i
1.0 ORGANIZATIONAL STRUCTURE The Energy Systems Business Unit is a functionally organized group of divisions, including ESBU Procurement Services, responsible for the design, procurement, fabrication, inspection and/or testing of certain ,
nuclear power plant items and services, coordination of the supply of items and services, and for control of technical interfaces among the :
licensee or applicant, his primary agents and ESBU. Activities, responsi-bilities, authority, acceptance of work and interfaces are established and !
documented for items and services provided by ESBU divisions. These items I
and services are provided in accordance with quality assurance programs which comply with the requirements of this Plan. ESBU management is responsible for quality assurance program activities as committed to throughout this Plan.
The Pensacola Plant is a functional unit within the Power Generation j Business Unit with the responsibility for the design, procurement, fabrication, inspection and/or testing of certain nuclear power plant items. Activities, responsibilities, authority, acceptance of work and interfaces are established and documented for items and services provided through the ESBU order entry process. 1hese items and services are provided in accordance with a quality assurance program which complies with the requirements of this Plan. Pensacola Plant Management is respons-ible for the quality assurance program activities contained in this Plan, through the commitment of the PGBU Vice President and General Manager.
WCAP-8370, REV.12A 4
i 1.0 ORGANIZATIONAL STRUCTURE (Continued) i Figures 3 and 4 (Pages 62 and 63) provide the general organizat.ional structure of ESBU and PGBU. ESBU will inform the NRC Vendor Inspection Branch of organizational changes on the division level, including the organizational levels of the quality assurance organization with respect to the engineering / construction / manufacturing organizations. The quality assurance structure changes will also be included down to the supervisor or first level management. ;
1.1 RESPONSIBILITIES AND AUTHORITY Each Division General Manager is responsible for establishing and l implementing a quality assurance program that meets or exceeds the i requirements of this Plan. Responsibility for documenting the quality assurance program is assigned to a quality assurance (or similar title) manager (s). This quality assurance manager is sufficiently free from direct pressure for cost / schedule and has the authority to stop unsatisfactory work, control further design activities, processing, l testing, delivery or installation of nonconforming ' items and services. The quality assurance manager has access to higher management levels to assure the ability to: identify quality problems; initiate, recommend or provide ;
solutions through designated channels; and verify implementation of solutions. This quality assurance management position has the following characteristics:
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- a. Has direct access to the highest level manager in
~
the division on all quality related issues;
- b. Has effective communication channels with other senior management positions;
- c. Has responsibilities for approval of quality assurance manual (s); and :
WCAP-8370, REV. 12A 5 l
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1.1 RESPONSIBILITIES AND AUTHORITY (Continued)
- d. Has no other responsibilities unrelated to quality l assurance that would prevent attention to quality !
assurance matters. !
i Disputes involving quality arising from differences of opinion between quality assurance and other department personnel are elevated to a level of management necessary to assure resolution. ;
i Responsibility for achievement of quality is assigned to each individual or organization performing the work. The verification of quality j achievement is assigned to individuals or groups not directly responsible f for performing the work.
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Functional departments within ESBU and the Pensacola Plant are responsible j for performing activities that assure the quality of items and services.
supplied. Each manager with responsibilities in the quality assurance l program may delegate work to others, but shall retain responsibility for ;
the work and the responsibility for the effectiveness of the quality assurance program. Authority to accomplish the delegated work is. also provided.
1 1.1.1 SELF-ASSESSMENT POSITION: SEE PART C, SECTION 1 - SELF-ASSESSMENT 1
1.2 FUNCTIONAL DEPARTMENT RESPONSIBILITIES l
Engineering is responsible for perfonning the various technical func- l tions associated with the design and specification of items and for !
technical follow of the design cycle at suppliers' facilities. Engineer- -
ing groups are also responsible for providing safety analyses, including j safety evaluations of system and equipment design and safety performance criteria. Control of design interfaces between the various engineering departments is' described in Part B, Section 4 of this. Plan.
t WCAP-8370, REY.12A 6 J
1.2 FUNCTIONAL DEPARTMENT RESPONSIBILITIES (Continued)
Project Groups are responsible for receipt of customer orders, trans-l mittal of the customer requirements to the implementing division, and
( serving as the prime interface between ESBU, Pensacola Plant and the applicant or Licensee. Processing of customer orders is controlled by documented procedures which describe the requirements for the~ order entry system.
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Manufacturing is responsible for the manufacture, fabrication, construction, testing and/or servicing of items. This responsibility includes material control, generation and control of manufacturing information, product planning and control, manufacturing functions, process qualification and control, in-process verification and qualification of personnel.
Quality Assurance is responsible for verifying that the quality !
assurance program is established, properly implemented and effective. ]
Results of this verification are reported to management, including the General Manager. Quality assurance activities include, as applicable, reviews of drawings, specifications and procedures; source surveillance and audits of suppliers; inspections and examinations and recording of results; preparation of documentation associated with the release of items; schedule and performance of internal audits; development and maintenance of specific quality assurance program documents; qualification of inspection personnel and auditors; and, at the discretion of quality assurance, participation in work schedule and status meetings.
The minimum qualification requirements for the quality assurance manager are:
- a. Bachelors Degree in a technical field (or equiva-lent);
WCAP-8370, REV. 12A 7
1.2 FUNCTIONAL DEPARTMENT RESPONSIBILITIES (Continued)
- b. At least six (6) years experience in quality assur-ance (with related technical or manufacturing experience);
- c. Management experience through assignments to responsible positions commensurate with this position;
- d. Knowledge of applicable quality related codes, ,
standards, regulatory and statutory requirements; and,
- e. Demonstrated ability to prescribe, apply and assess compliance with applicable requirements.
ESBU Procurement Services provides total procurement services for NATO and NSD and acts as the interface for the two divisions and their suppliers. Procurement Services also provides services to PCD on a ,
limited basis. Although PCD is structured with its own procurement l department, services of ESBU Procurement Services are requested depending ;
on capability and work load. Procurement Services provides services to l CNFD for those locations that do not have their own procurement ;
department. Procurement Services does not provide services to either EMD or the Pensacola Plant, which have within their respective divisions a ;
Purchasing Department providing procurement activities.
Procurement activities, performed either by the division's procurement departments or ESBU Procurement Services are controlled and accomplished in accordance with established procedures and the requirements of this t Plan. ,
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i 1.3 ' INTERFACE CONTROL i
' Internal and external organizational interface responsibilities and changes thereto are defined and documented in procedures. ESBU and ;
Pensacola Plant interface responsibilities and authority are established and documented in the ESBU Quality Assurance Program. i I
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._______-_-__-_-______________._-_________________--_]
SECTION 2 QUALITY ASSURANCE PROGRAM 2.0 COMMITMENTS This Quality Assurance Plan is applied to activities affecting the quality of items and services identified in Section 3.2.1 of the applicable Safety Analysis Report (SAR) document, as well as other items ,
and services requested by the applicant / licensee. The applicability of this Quality Assurance Plan, is as determined by contract at, or prior to, the outset of work and application is based on the safety class of the item or service as well as on the complexity of the scope of work. The ,
safety class of items is documented and approved by responsible management.
Appendix A and Appendix C of this Quality Assurance Plan describes commitments to the regulatory guides, ASME NQA-1 and ASME NQA-2. The exceptions, clarifications and alternates described in Appendix A and C may not all apply to all of the divisions. Divisions, including ,
Procurement Services, comply with the guidance of the regulatory guides, ASME NQA-1, and ASME NQA-2 as written or with the exceptions, clarifications, and alternatives listed in Appendix A and Appendix C.
Also, all organizations covered by this plan comply with the requirements of 10CFR50.55a, (with the specific editions of the Codes and Standards identified in individual SARs) and Criterion 1 of Appendix A to 10CFR Part
- 50. As applicable, American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, and American National Standard ASME NQA-1 requirements are supplemented with the guidance of the Regulatory Guides
' per Appendix A. (Se'e Part A, Section 3 of this Plan for the listing of applicable regulatory guides).
Each division's quality assurance program contains provisions for the evaluation of reported conditions which may require NRC notification in accordance with the requirements of 10CFR Part 21 and 10CFR 50.55(e).
I WCAP-8370, REV. 12A 10
2.0 COMMITMENTS (Continued)
Each division that provides items and services to nuclear power plants has programs and procedures that describe compliance with the commitments of this Quality Assurance Plan, and for special equipment, environmental conditions and processes as necessary. These programs and procedures are documented and controlled as described in Part B, Section 3 of this Plan.
These programs and procedures are reviewed and approved by the appropriate quality assurance department before an activity within the scope of this Plan is undertaken by a division or by others and are made mandatory by the responsible division General Manager. Figure 5 (Page 64) provides a listing of QA Manuals.
Procedures that implement division's Quality Assurance programs are approved by the manager responsible for the activities performed.
2.1 GRADED APPROACH Control over activities affecting the quality of items and services is to the extent consistent with the complexity of the scope of work and safety related function of the item or service, lo ensure consistency in identifying those items, classification processes are documented in procedures. The processes rely on the use of the term safety class (See Figure 1 for clarification - Page 14). All applicable requirements contained in this Plan are applied to Safety Class 1, 2 and 3 l items. For Class 4 items, selected requirements contained in this Plan apply (See Figure 2 for logic used to determine appropriate quality requirements - Page 15). Other similar identifiers may be used for safety class identity, such as, A, B, C and etc.; however, the requirements contained in this Plan are unchanged. These quality requirements are specified in design documents, procurement documents, procedures, etc.
This Plan may be applied to items or activities other than those designated Safety Class -1, -2, -3 and Class 4 as specified by management.
WCAP-8370, REY. 12A 11
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2.2 TRAINING, INDOCTRINATION AND QUALIFICATION l I
l Training and indoctrination requirements contained in this section apply j to personnel performing or managing activities affecting quality. Each manager is responsible for training personnel, as necessary, to the applicable programs and procedures prior to their performing or managing work in accordance with NQA-1 Basic Requirements and Supplement 2S-4 (for position, See Appendix A, Page A-4) and assuring necessary resources are l available to accomplish their assigned tasks. This includes indoctrina-tion to the requirements of this Quality Assurance Plan, applicable quality assurance programs and procedures, special skills training required for the performance of activities, job responsibility and authority, and assurance that personnel achieve and maintain suitable proficiency. Training and/or indoctrination is documented.
Personnel performing inspection, testing, examination and audit activities :
are qualified in accordance with ASME NQA-1, Basic Requirements and Supplements 2S-1 through 2S-3 and Appendix 2A-1 (for position, see (
Appendix A, Regulatory Guide 1.28 exception to 2A-1, Section C.1, Pages A-1 and A-2). Personnel qualification programs include documentation of j capability using either formal written tests or a physical demonstration of skill, and include the maintenance of proficiency based on retraining i or continuing satisfactory performance. Qualification requirements include specific provisions for education and/or experience. ;
Documentation, in the form of certificates of qualification or other similar records, includes the activities the individual is qualified to j perform and the basis used for certification.
The quality assurance manager assures that personnel performing surveil-lance and audits are qualified and certified. Personnel qualification includes the documentation of capability and the maintenance of proficiency based on continuing satisfactory performance or retraining.
Documentation, in the fonn of certificates of qualification, includes the activities the individual is qualified to perform and the basis used for I
certification. l I
1 WCAP-8370, REY. 12A 12 l
1
- 2.3 MANAGEMENT ASSESSMENT l Division Management regularly reviews the status and adequacy of their Division's quality assurance program for compliance with the commitments of this Quality Assurance Plan, and provides the results to each Division General Manager. This review includes familiarity with program status (through reports, meetings and/or audits, internal and external audit trend data), and performance of an annual assessment of the program. An .
annual assessment includes identification of corrective action when !
necessary and provisions for tracking the status of the action (s) ]
specified. ;
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l' WCAP-8370, REV.12A 13
FIGURE 1 CLASSIFICATION OF ITEMS / SERVICES w a,a SC.t. SC.E DC.4 L
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WCAP-8370, REY. 12A 14
FIGURE 2 LOGIC CHART FOR DETERMINING APPROPRIATE QUAUTY REQUIREMENTS 30 Witme a 09FFT a g,gypfy (31 84,8TV c== a c.L.c====ASS Cpt CLA48 ac,u. ..
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WCAP-8370, REV. 12A 15
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SECTION 3 :
REGULATORY COM ITMENTS 3.0 GENERAL Divisions comply with the regulatory positions included in the Regulatory Guidance listed in 3.1 of this section. Specific exceptions to, and inter-pretations of, this guidance are contained in Appendix A and C of this Plan. Individual projects may identify additional exceptions which will be included in the individual SAR. When work scope does not involve an SAR, exceptions and interpretations contained in Appendix A and C apply. ;
3.1 REGULATORY GUIDANCE 3.1.1 Regulatory Guide 1.8, Revision 2, " Personnel Selection and Training."
+
3.1.2 Regulatory Guide 1.26, Revision 3, " Quality Group Classification, and Standards for Water , Steam , and Radioactive- Waste-Containing Components of Nuclear ,
i Power Plants.
3.1.3 Regulatory Guide 1.28, Revision 3, " Quality Assurance I
Program Requirements (Design and Construction),"
using NQA-1 and NQA-2.
3.1.4 Regulatory Guide 1.29, Revision 3, " Seismic Design Classification."
3.1.5 Regulatory Guide 1.33, Revision 2, " Quality Assurance Program Requirements (Operations)," with appropriate substitution of ASME NQA-1 and ASME NQA-2 for ANSI N-45.2 and its daughter standards.
)
WCAP-8370, REY.12A 16
t 3.1.6 Regulatory Guide 1.152. Revision , " Criteria for Programmable Digital Computer Systems Software in Safety-Related Systems of Nuclear Power Plants."
3.1.7 Generic Letter 89-02 endorsement of EPRI NP-5652, J
" Guideline for the Utilization of Commercial-Grade Items in Nuclear Safety-Related Applications (NCIG-07)."
3.1.8 Fire protection QA controls are to be in accordance with Regulatory Positions 2 and 4 of Branch Technical Position CMEB 9.5-1 as given in SRP Section 9.5.1.
3.1.9 Radioactive waste QA controls are to be in accordance {
with Regulatory Position 6 of Regulatory Guide 1.143, !
Revision 1, " Design Guidance for Radioactive Waste Management Systems, Structures, and Components Installed in Light Water-cooled Nuclear Power !
Plants." ,
l 3.1.10 QA controls are required by a commitment to Regula-tory Guide 1.36, Revision , " Nonmetallic Thermal Insulation for Austenitic Stainless Steel." I 3.1.11 Regulatory Guide 1.54, Revision , " Quality Assurance l Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants." ;
3.1.12 Regulatory Guide 2.5, Revision , " Quality Assurance Program Requirements for Research Reactors."
3.1.13 Regulatory Guide 3.3, Revision 1, " Quality Assurance Program Requirements for Fuel Reprocessing Plants and for Plutonium Processing and Fuel Fabrication ;
Pl ants . "
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3.1.14 Regulatory Guide 3.21, Revision , " Quality Assurance Requirements for Protective Coatings Applied to Fuel Reprocessing and to Plutonium Processing and Fuel Fabrication Plants."
3.1.15 Regulatory Guide 4.15, Revision 1, " Quality Assurance for Radio. logical Monitoring Programs (Normal '
Operations), Effluent Streams and the Environment." -l 3.1.16 Regulatory guide 7.10, Revision 1, " Establishing Quality Assurance Programs for Packaging Used in the Transport of Radioactive Material." l 3.1.17 Class 1, 2, and 3 items covered by Section III of the ASME Boiler and Pressure Vessel Code, the Code quality assurance requirements (NCA-4000) are supple- I mented by items 3.1.1 through 3.1.7. of this section.
WCAP-8370, REV. 12A 18
PART B PERFORMANCE / VERIFICATION SECTION 1 -
RESPONSIBILITIES Individuals performing activities described in this Plan are responsible for achieving acceptable quality. These activities are accomplished by competent personnel using written instructions or procedures, or other appropriate guidance, which identify acceptance criteria, and which are of a detail commensurate with the complexity of the activity and its importance to safety.
Individuals performing verification activities are responsible for the verification of acceptable work using established acceptance criteria procedures, instructions, and other applicable guidance.
Individuals performing verification are independent from those responsible for performing the activities being verified.
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SECTION 2 INSTRUCTIONS, PROCEDURES AND DRAWINGS Activities affecting the quality of items and services are accomplished in accordance with documented instructions, procedures or drawings that include appropriate quantitative and qualitative means of verifying quality. Actions required and responsibilities for preparation, review, control, implementation and approval by the manager responsible for these documents are established in procedures or instructions. These procedures and instructions are reviewed by quality assurance.
Revisions to quality assurance programs that change the system used to accomplish an activity are identified and the reason for the change documented.
Drawings are prepared and revised based on documented design information and requirements specified by engineering. The completed drawings and revisions are reviewed and signed by engineering and processed for retention and retrieval.
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SECTION 3 DOCUMENT CONTROL i
3.0 GENERAL A program for the development, identification of scope, review, approval, issuance and use of documents and changes thereto is established to assure technical adequacy and inclusion of appropriate quality requirements prior to implementation. This program includes responsibil-ities, as appropriate, for independent reviews by qualified individuals for quality provisions. Procedures provide methods to assure that the proper document revisions are used; that document changes are controlled to prevent inadvertent use of obsolete or superseded documents; that individuals or groups responsible for reviewing, approving, and issuing documents and revisions thereto are identified; and that review and approval of changes are performed by the organizations which originally reviewed / approved the document, or by a designated alternate organization (s).
C 3.1 DOCUMENT PREPARATION, REVIEW, APPROVAL AND ISSUANCE Document control requirements include the identification of documents that are controlled and distribution thereof, and the review of documents for adequacy, completeness (for position see Appendix A, ASME NQA-1, Supplement 6S-1, Page A-6) and correctness prior to approval and issuance. Distribution of new or revised documents are made available in a timely manner to assure effective implementation.
3.2 DOCUMENT CHANGES Changes to documents are evaluated, approved and controlled.
Inconsequential editorial changes and corrections do not require that the )
revised document receive the same review and approval as the original document. To avoid a possible omission of a required review, the types of changes that do not require such a review and approval and the persons who can authorize such a decision are clearly identified. All other WCAP-8370, REV. 12A 21 i
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3.2 DOCUMENT CHANGES (Continued) changes are reviewed and approved by the same organization that performed the original review and approval or by an auth'orized alternate ;
organization. Changes to procedures, instructions, drawings and other documents are approved and documented prior to implementation, and are made available at the location where the activity will be performed prior to commencing the work. ,
3.3 CONTROLLED DOCUMENTS Documents describing activities affecting quality or specify quality requirements are controlled in accordance with this Quality Assurance Plan and implementing procedures. Controlled documents include but are }
not limited to instructions,- procedures, design calculations, specifica- !
tions, drawings, computer software documentation, design review reports, >
procurement documents, nonconformance reports, the standard safety
- analysis report, and this Quality Assurance Plan. Document control procedures include provisions for the maintenance and use of master ;
lists, receipt acknowledgement systems, log and verification systems or ,
tables of contents to identify the current versions of documents.
3.4 DRAWING CONTROL Drawings prepared by the Divisions and supplier drawings requested for submittal are reviewed and approved by Engineering and controlled in accordance with established procedures. Drawings are processed for issue, retention and retrieval in accordance with these established procedures.
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SECTION'4 DESIGN CONTROL 4.0 GENERAL Procedures and instructions define the design process associated with design interfaces, control of the design, identification of design inputs, preparation of design documents, design verification, and design changes.
Translation of applicable regulatory requirements and design bases into design, procurement, and procedural documents is also established, implemented and controlled.
4.1 DESIGN INPllT Design input, such as design bases, functional requirements, performance requirements, regulatory requirements, and codes and standards are documented, reviewed, and approved by the responsible design groups.
Design inputs are correctly translated and specified in sufficient detail to permit a consistent basis for making design decisions, accomplishing design verification, and evaluating design changes. Changes from approved design inputs, including the reason for the changes, are documented, approved, and controlled.
4.2 DESIGN PROCESS Design documents are prepared by the engineering organizations and include design input and criteria, functional requirements, drawings, system and design specifications, design analyses, structure descriptions and engineering studies, as appropriate. Engineering managers are respons~
ible for work performed and the approval of that work. Methods and responsibility for verifying calculations, specifications, and required ;
documentation are included in procedures or instructions where appropri-ate. Quality requirements are specified by engineering and are reviewed and approved by quality assurance.
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4.2 DESIGN PROCESS (Continued)
Approved design output documents contain the identification of any assemblies and/or components that are part of the item being designed.
Further, if the assembly and/or component is a commercial grade item that is modified, inspected and/or tested to requirements more restrictive than the supplier's published product description, the assembly or component is identified as different from the commercial grade item and traceable to the documented difference. Approved design output documents are of sufficient detail to permit design verification.
Changes from approved quality standards, including the reason for the changes, are approved by the same organizations which reviewed and approved the original design. Design methods and processes that are essential to the function of the structure, system or component are selected and reviewed for suitability of application by the responsible engineering manager.
4.3 DESIGN ANALYSES Design analyses are performed in accordance with procedures and/or instructions. Prepared design analysis documents are legible, reproduc-ible and sufficiently detailed as to purpose, method, assumptions, design input, and references such that the analysis can be reviewed and the adequacy of the results verified by a person technically qualified in the subject without recourse to the preparer.
Computer programs used for design analysis need not be individually verified prior to each application provided: 1) the encoded mathematical model has been shown to produce valid solutions to known problems; and 2) the encoded model has been verified for the specified range of inputs and outputs. Changes to computer programs are controlled, documented and l approved by authorized personnel. Changes to previously verified computer programs are verified, including evaluation of the effects of these
( changes on 1) and 2), above.
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l 4.3 DESIGN ANALYSES (Continued) !
Documentation of design analyses includes, either directly or by reference, the definition of the objective of the analysis; definition of Jesign inputs and their sources; results of literature searches or other applicable background data; identification of assumptions and indication of those that require verification as the design proceeds; identification of computer calculations, including computer type, computer program name, revision, inputs, outputs, evidence of, or reference to, computer program verification, and the bases or reference to supporting application of the computer program to the specific physical problem; and review and approval .
4.4 DESIGN VERIFICATION In accordance with established procedures, engineering managers are responsible for assuring that appropriate design verification methods used are established and implemented. These procedures ensure appropriate verification methods are used for each design, the acceptance criteria are identified, the verification is satisfactorily accomplished, and the results are properly documented. Verification is accomplished using methods such as the following, as described in procedures: design reviews, alternate calculations, or qualification tests. Design verification is performed by competent individual (s) or group (s) other than those who performed the original design. Verification may not be performed by the originator's supervisor, except when the supervisor is the only qualified person available, or provided the supervisor did not specify a singular design approach or rule out certain design considerations, and did not establish the design inputs used in the design. In these cases, the justification is documented and approved in ,
advance by the supervisor's management. Nevertheless, a supervisor never verifies his own work or inputs. The frequency and effectiveness of the supervisor's use as a design verifier are verified during quality assurance audits to guard against abuse. Results of design verification are documented with the identification of the verifier clearly indicated (for position, see Appendix A, Page A-5).
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4 4.4 DESIGN VERIFICATION (Continued)
Design inputs, processes, outputs, and changes are verified prior to release of design documents to others for use in design activities, procurement, manufacture, or construction except where unverified portions of the design are identified, documented and controlled. Procedures require that design verification is completed before relying on the item to perform its function and before its installation becomes irreversible requiring extensive demolition or rework. Engineering managers determine the extent of design verification required as a function of the importance to safety, the complexity of the design, the degree of standardization, the state of the art, and the similarity with previously proven designs.
Design changes are evaluated to determine their effect on the overall design and on any design analysis upon which the design is based. Changes to final designs, including field changes and dispositions of nonconforming items to "use-as-is" or "-epairs" are subject to design control measures commensurate with those applied to the original design.
These changes are approved by the organization that performed the original design or a qualified designate.
4.4.1 DESIGN REVIEWS Independent reviews are performed by an individual (or individuals) or multi-disciplined design review teams. These reviews are performed by competent personnel and, where applicable, the following are addressed:
design input selection, described and reasonable design output compared to design input, design input and verification requirements from interfacing organizations, appropriate design method used, design inputs correctly incorporated into the design, and adequately described, rr.asonable, and identified assumptions.
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-4.4.2 ALTERNATE' CALCULATIONS The requirements for verification by alternate calculations.are described in procedures which include the review of appropriateness of assumptions, input data, and computer program or other calculation method used.
4.4.3 QUALIFICATION TESTS Qualification tests demonstrate the adequacy of performance under conditions that simulate the most severe design conditions in accordance with written test procedures and test specifications. Test specifica-tions are reviewed and approved by the responsible engineering group.
Results of the qualification tests are approved by the engineering group responsible for the design. For tests performed on models or mockups, -j scaling laws are established and verified (for position, see Appendix A, Page A-5). Test results obtained for model or mockup test work are ;
subject to error analysis, where applicable, prior to use in final design l J
work. Information regarding verification that is incomplete, including incomplete qualification tests, is available to the applicant prior to installation of equipment.
4.5 DESIGN SPECIFICATIONS Design specifications are used to specify technical and quality requirements either by their inclusion in the specification or by reference. These specifications are reviewed to verify accuracy and ,
completeness. They are also reviewed by quality assurance to assure that proper quality requirements are addressed, including inspection, test, and documentation requirements. The term " Design Specification" includes drawings when they are used in lieu of design specifications.
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4.6 DESIGN CHANGE CONTROL Written procedures describe the control of design changes, including those for identified design deficiencies. Changes to approved design documents including field changes are subject to the same review and approval process as the original document. Where changes to previously verified design are made, design verification is performed.
4.7 IKTERFACE CONTROL Design interfaces are identified, documented and controlled. Interface controls include the assignment of responsibility and the use of proce-dures among participating design organizations, including the applicant or his agent, for the review, approval, release, distribution and revision of documents including revision of design inputs and outputs (for position, see Appendix A, Page A-6). Transmittal of design information is documented and controlled, and the status of the information is identified.
4.8 DOCUMENTATION AND RECORDS Design documentation which provides evidence that the design and design verification were performed in accordance with procedural requirements is collected, stored and maintained. Design records also include calculations, analyses, computer programs, and sources of design input that support the final output.
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4 SECTION 5
. COMPUTER SOFTWARE 1
5.0 GENERAL 5.0 COMPUTER SOFTWARE Computer software used in the design or analysis of components, struc-tures, and systems and operation of components and systems is controlled by software procedures and instructions which comply with this plan and ASME NQA-2a-1990, Part 2.7.
5.1 COMPUTER SOFTWARE DEVELOPMENT Development of computer codes is performed in accordance with a documented program which establishes the policies and procedures necessary to produce quality software. Any suitable software life cycle model may be adopted provided it encompasses the activities 4ssociated with requirements analysis, design documentation, code implementation and testing, installation, and operation and maintenance. ,
Functional requirements, design documents, and test requirements and ,
results are verified by the responsible software group in accordance with procedures written by technically competent personnel who do not have direct responsibility for development of the code. Verification is performed at each phase to ensure tnat the products of a given phase fulfill the requirements of the previous phase. Software validation is performed'at the end of the implementation phase to ensure that the code satisfies the identified requirements.
5.2 SOFTWARE CONTROL AND DOCUMENTATION Documented controls are established to capture the approved configura-tion of computer programs, and identify all approved changes. The l
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l 5.2 SOFTWARE CONTROL AND DOCUMENTATION (Continued) development and maintenance of computer software include docume.ntation describing software requirements, software design, verification and validation (testing), configuration control, and error reporting and resolution. Written procedures describe how records are collected, maintained, and stored. Individuals or organizations developing or supplying software are required to utilize policies and procedures that meet the applicable requirements of this Plan.
5.3 SOFTWARE TESTING Computer programs are tested for all intended applications by the responsible design organization. The extent of testing may include, as appropriate, verification tests, hardware integration tests, and in-use tests. Verification tests are performed to demonstrate the capability of a computer program to produce valid results. In-use tests are conducted to confirm acceptable performance of programs in the operating system and are used when codes are installed on different computers, or when significant hardware or operating systems changes are made. Acceptance criteria may be based on hand calculations, documented results from other verified computer programs, empirical data or published data in technical literature. The degree of testing is dependent on the importance to safety and complexity of the program. Testing is conducted in accordance with written procedures and the results are documented and independently verified by a responsible authority. Records are stored, controlled, and protected in accordance with documented procedures.
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Individual or organizations developing or supplying software or providing software services are required to utilize established policies and procedures that meet the applicable requirements of this plan.
Existing, procured, or otherwise acquired software that has not been L developed in accordance with the requirements of this plan shall be controlled, evaluated, and tested prior to use as described in documented procedures.
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SECTION 6 PROCUREMENT DOCUMENT CONTROL 6.0 PROCUREMENT DOCUMENT CONTENT Technical, quality, regulatory, administrative, and reporting requirements applicable to the procurement of items and services are specified in procurement documents. Technical and quality requirements include criteria such as applicable codes and industry standards, test and inspection requirements, and special process instructions. The quality requirements also include supplier quality assurance program requirements, requirements for access to the supplier's facility, documentation require-ments, and requirements for nonconformance control. Where necessary, technical and/or quality requirements are specified in procurement documents by reference to design specifications and/or other documents.
As necessary, procurement documents require suppliers to have a quality assurance program consistent with the applicable requirements of this Plan.
Spare or replacement parts are procured to requirements equal to or more stringent than the original requirements, and are suitable for their ,
intended service. ,
6.1 PROCUREMENT DOCUMENT REVIEW Procurement documents are reviewed by engineering, as appropriate, and quality assurance prior to contract award (for position, see Appendix A, Page A-6). This review is documented, and assures that technical and i quality requirements, are correctly specified, including adequate acceptance criteria, and that procurement documents have been prepared, reviewed and approved in accordance with applicable procedures, f
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i 6.2 PROCUREMENT DOCUMENT CHANGES Procurement document changes. to technical and quality requirements are controlled and processed.in the same manner as the original procurement !
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SECTION 7 CONTROL OF PURCHASED ITEMS AND SERVICES 7.0 PROCUREMENT PLANNING Procurement of items and services is controlled by procedures which describe the responsibilities and methods to ensure conformance with specified requirements contained in procurement documents.
Procurement planning provides for the preparation of required procedures prior to initiation of the activity, procurement document preparation, selection of suppliers, bid evaluation and award (for position, see Appendix A, Page A-8), control of supplier performance, verification activities, including hold and witness points (for position, see Appendix A, Page A-7), control of nonconformances, corrective action, acceptance of items or services, and quality assurance records. The items and/or services required, applicable scope of work, and all techni-cal and quality requireaents are defined in writing. Authorization for the work is by the procurement documents.
7.1 SUPPLIER SELECTION Prior to placing an order with a new supplier, an evaluation is conducted by quality assurance and, as appropriate, engineering and/or purchasing.
Supplier evaluation 'and selection measures provide for the evaluation of a potential suprelier's capability to provide items and/or services in accordance with specified requirements. Suppliers are evaluated before purchase order placement and the results documented. Evaluation and selection methods include one or more of the following (for position, see Appendix A, Page A-7): a) evaluation of the supplier's history (including current capability) of providing an identical or similar product which was !
satisfactorily accomplished in accordance with specified requirements; l
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7.I SUPPLIER SELECTION (Continued) b) review of supplier's current quality records supported by documented qualitative and quantitative information which can be objectively evaluated; and c) supplier's technical and quality capability is deter-mined by a source evaluation of his facilities, personnel, and the content and implementation of his quality assurance program.
Significant deficiencies are documented and corrected, and commitments to resolve all other unacceptable conditions are obtained from the supplier prior to contract award.
7.2 BID EVALUATION l
l Bid evaluations are performed by designated individuals or organizations )
to determine the extent of conformance to the procurement documents. This I evaluation addresses the following subjects, as applicable to the types of procurement: technical requirements consideration, quality assurance I requirements, suppliers' personnel capability, supplier's production capability, suppliers' past performance, alternates and exceptions. Prior to contract award or prior to start of related work activity, unacceptable quality conditions resulting from the bid evaluation are resolved or commitments are obtained to resolve the conditions.
7.3 SUPPLIER PERFORMANCE EVALUATION Suppliers a're evaluated initially for the items and services specified to detennine the acceptability of their quality assurance programs for the items and services specified. Acceptability of suppliers is documented.
A formal evaluation of suppliers is performed each year to determine if additional actions such as audits are required during the upcoming year.
This evaluation includes a review of some or all of the following: prior quality program audits, supplier surveillance activities, nature and frequency of hardware discrepancies, results of audits from other sources (customers, ASME, NRC, etc.) if available, significant changes in the supplier's QA program, procurement document compliance, supplier required WCAP-8370, REV. 12A 34
i 7.3 SUPPLIER PERFORMANCE EVALUATION (Continued) i submittals, processing required change information and document i
exchange, and the supplier's responsiveness and cooperation in resolving-quality questions or problems. As a result of this evaluation, suppliers -
requiring a complete quality program reaudit are identified. The results I of this evaluation are documented and approved by responsible management. l Regardless of the results of the evaluation, suppliers are reaudited every ;
three years. Evaluations are not conducted for the year a supplier is scheduled to be audited. At divisions holding the appropriate ASME !
certificates of authorization, suppliers are categorized as ASME Code and l non-ASME code suppliers. ASME accredited suppliers are selected and )
evaluated in accordance with the requirements of this Plan for items and :
services supplied.
I Based on an evaluation conducted and documented in accordance with NQA-1, Section 5.1 of Appendix 4A-1, supplier audits are not necessary for procuring items that are (1) relatively simple and standard in design, l manufacturing, and testing and (2) adaptable to standard or automated inspections or tests of the end product to verify quality characteristics after delivery. i i
Evaluations of Divisions and ESBU Procurement Services are performed by auditing their documented quality assurance programs to the requirements contained in this Quality Assurance Plan. .!
7.4 CONTROL 0F SUPPLIER GENERATED DOCUMENTS Supplier submittal of documents such as specifications, procedures, f i
certified material test reports, nondestructive examination reports, and t
drawings required for review or approval or-information, are identified in the procurement documents. These submittals, when required, are evaluated against approved acceptance criteria for technical correctness, adequacy. -
of inspection methods, and completeness of test data. The submittal and review of supplier documents and the methods used for their ,
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I 7.4 CONTROL OF SUPPLIER GENERATED DOCUMENTS (Continued) control are detailed in written procedures. Contingent conditions that require additional action after delivery of the item to the applicant / licensee are documented. Contingent conditions are monitored and their resolution is documented and provided to the applicant / licensee before the item is placed in service or use.
l 7.5 ACCEPTANCE OF ITEMS AND SERVICES 7.5.1 GENERAL I Procedures are established for the acceptance of items or services supplied by the Divisions and their suppliers. ,
A quality release based on importance to safety and/or complexity of the item is authorized by quality assurance when items are shipped for use in nuclear power plants. The quality release is a document which includes specific information identifying the item and the applicable procurement documents, and certifies that the item meets all procurement requirements. The quality release includes identification of any approved deviations from the procurement requirements and is signed by a person (s) ;
authorized by quality assurance. Procedures describe the actions necessary to initiate, authorize, issue, distribute and revise quality releases. These procedures include provisions for ensuring documented evidence of item acceptance is at the nuclear power plant before the item is placed in service or used.
For items that are shipped to a Division facility or transferred from one Division facility to another for further processing, receiving or source ;
inspections are performed in accordance with established requirements commensurate with the complexity and use of the item and the status of the supplier or facility. This receiving or source inspection verifies that the item and specified documentation comply with the applicable requirements. The status is identified on, or traceable to, the item.
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7.5.2 METHODS OF ACCEPTANCE Items or related services are accepted by one of the following methods or a combination thereof.
Certificate of Conformance (C of C) - When a C of C is used for acceptance, criteria (a) through (f), as a minimum, are met: (a) the pur-chased item will be identified on the C of C by purchase order number.
(b) the C of C identifies er references documents that identify the procurement requirements, such as codes, standards and other specifica-tions; approved changes, waivers, or deviations are also identified on the .
C of C; (c) procurement requirements that are not met are identified along with an explanation of how the nonconformance was resolved; (d) the person responsible, as described in the responsible division's or supplier's quality assurance program, signs the C of C; (e) the C of C process, which includes preparation, review and approval, is described in the ,
l responsible division's or supplier's quality assurance program; and (f) verification of the supplier's C of Cs and certification process is '
performed during audits or surveillance, or both, at intervals commensurate with the supplier's past performance. !
Source Verification - When specified in procurement documents, quality assurance surveillance of suppliers during fabrication, inspection, testing or release of items is provided. For complex items, guidance for surveillance activities is provided by established quality procurement standards or procurement quality requirements generated prior to the activity. Audits, surveillance, and/or inspections by quality assurance i personnel are performed to verify suppliers' compliance with quality assurance procedures and procurement document requirements. Where no established quality standards exist, the specific technical requirements of the procurement documents are used as the basis for surveillance. The degree of surveillance varies with the degree of importance of the item, supplier performance and complexity of the item, and may result in a requirement to verify lower tier activities of the suppliers.
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7.5.2 METHODS OF ACCEPTANCE (Continued)
Receivino Inspection - Receiving inspections are performed in accordance with procedures and inspection instructions. These inspections are performed to verify conformance to specified requirements. Such features as proper configuration, identification, dimensional, physical and other characteristics, freedom from shipping damage and cleanliness are also verified. The supplier's quality performance, as verified during audits and/or surveillance, is considered in determining the extent of receiving inspection to be performed. Any required documentation specified in the procurement documents to be furnished prior to receiving inspection is reviewed during surveillance and release of the item.
Post-Installation Testina - The responsible division and the applicant / licensee or his agent will mutually establish the test requirements and acceptance documentation in test specifications when post-installation tests are used.
7.5.3 ACCEPTANCE OF SERVICES ONLY Acceptance of procured services is by any or all of the following methods: technical verification of data produced; surveillance or audit of the activity; review of objective evidence for conformance to procurement document requirements. These methods are described in procedures. ,
7.6 CONTROL OF SUPPLIER NONCONFORMANCES Procedures that describe the method of disposition of items and services that do not meet procurement document requirements are established by divisions and the supplier.
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l 7.6 CONTROL OF SUPPLIER N0HCONFORMANCES (Continued) i These procedures contain provisions for the evaluation and approval of l the supplier's disposition of nonconformances to procurement documents, )
nonconformances to division approved supplier documents (for position, see Appendix A, Page A-7), verification of the disposition and maintenance of records. Nonconformances identified in division supplied documents are controlled in the same manner.
7.7 COMMERCIAL GRADE ITEMS Requirements for the use and control .of commercial grade items are described in procedures which meet the requirements of this Plan and Generic Letter 89-02 [NRC endorsement of EPRI NP-5652, " Guideline for the Utilization of Commercial-Grade Items in Nuclear Safety Related Application (NCIG-07)"). Engineering responsibilities for the identification of important characteristics are also contained in the procedures and include: special processes and tests, design, material ,
and performance characteristics and acceptance criteria. When used, l commercial grade items are identified in approved design output j documents. Source evaluation, as applicable, is performed by divisions j in accordance with 7.2 of this Section and is based on the item's l complexity and importance to safety. !
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Commercial grade items are identified in the purchase order by the !
manufacturer's published product description. After receipt of the !
conrnercial-grade item the following are verified: item meets product description; freedom from shipping damage; required inspections and testing were accomplished; and required documentation is &cceptable and traceable to the item.
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SECTION 8 IDENTIFICATION AND CONTROL OF ITEMS 8.0 METHODS Identification and control requirements are established in quality assurance programs and are specified in procurement documents for items including consumable materials and items with limited shelf life or limited calendar or operating life, to prevent the use of incorrect or defective items.
Items of production, such as batches, lots, components and parts, are identified from their initial receipt and fabrication through their i installation and use. This identification is traceable to the design or other specifying documents. Identification markings on the item are used to the maximum extent possible. When this method of identification is impractical, physical separation, procedural control, or other appropriate controls are used. Marking of items is accomplished by .dng material and methods that provide a clear and legible identification. darkings are ;
transferred to each part when an item is subdivided, and these markings are not obliterated or hidden by surface treatment. These requirements take j into consideration the location and the method of identification so that I the fit, function, or quality of the item being identified is not adversely ' '
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8.1 TRACEABILITY Identification and control procedures assure that identification is maintained on the item or on records traceable to the item to preclude use of incorrect. or defective items, to an extent consistent with the item's I importance to safety. Item identification can be traced to appropriate documentation such as design documents, procurement documents, process control documents, or inspection records. Item identification is verified and documented prior to release of the item for further use.
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8.1 TRACEABILITY (Continued)
Specific requirements for identification and traceability of items when specified by codes, standards, or specifications, such as grade of material, heat, batch, test and erial number are also controlled by the quality assurance programs.
8.2 LIMITED LIFE ITEMS Items having limited calendar or operating life are identified and con- !
trolled to preclude use of items whose shelf life or operating life has expired. 1 l
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8.3 MAINTAINING IDENTIFICATION OF STORED ITEMS The control of item identification for stored items is based on the duration and conditions of storage. This control considers provisions such as maintenance or replacement of markings when damaged or deterioration occurs due to environmental conditions.
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SECTION 9 CONTROL OF PROCESSES 9.0 PROCESS CONTROL Processes affecting quality of items or services are controlled by i.nstructions, procedures, drawings, checklists, process control documents, or other appropriate methods. These methods control process parameters and assure that specified environmental conditions are maintained.
Special processes may include welding, heat treating, nondestructive examination, electro-mechanical machining, explosive forming, cleaning, and painting.
9.1 SPECIAL PROCESSES Special processes are those which are highly dependent on the control of the process or the skill of the operators, or both, and in which the specified quality cannot be readily determined by inspection or test of the product. Examples of special processes include, but are not limited to, welding, heat treating and nondestructive examination.
Special processes are performed in accordance with documented instructions which include or reference procedure, personnel and equipment qualification requirements. These requirements comply with applicable codes, standards, specifications, or other documents. The documented instructions also specify conditions for accomplishing the process, use of proper equipment, parameters to be controlled, calibration requirements, including acceptance criteria, and any special requirements.
Qualification records are maintained and quality assurance personnel are involved in the control of qualification activities through procedure ,
approval, surveillance or audits, as appropriate.
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9.1 SPECIAL PROCESSES (Continued) 1 Qualification of processes and personnel for welding and inspegtion is in accordance with the ASME Boiler and Pressure Vessel Code or other specified requirements. Nondestructive examination is in accordance with ASNT SNT-TC-1A or other specified requirements. For suppliers, quality assurance personnel perform audits and/or surveillance at the supplier's facility to specified requirements of special process qualification and process activities.
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SECTION 10 CONTROL OF MEASURING AND TEST EQUIPMENT l 10.0 GENERAL Control of measuring and test equipment, including identification of equipment controlled, is specified in procedures, instructions or procure-ment documents. These documents specify the requirements contained in this Plan for calibration and the maintenance and control of measuring and test equipment. Examples of the equipment defined and controlled are micrometers, gages, hardness testers, transfer standards, electronic instruments, etc., and include peripheral devices such as PCs, micropro-cessors and software when used as an integral part of the measuring and test equipment. PCs, microprocessors and software when used as an integral part of the measuring and test equipment are not interchanged without recalibration.
10.1 SELECTION Measuring and test equipment is selected to assure proper type, range, accuracy and tolerance to accomplish specified requirements contained in test procedures, test instructions or procurement documents.
10.2 CALIBRATION AND CONTROL Measuring and test equipment is calibrated using calibration standards with greater accuracy than the equipmer;t being calibrated. Calibration standards with the same accuracy may be used if adequacy for the requirements and the basis of acceptanca, are documented and authorized by the responsible engineering manager. Measuring and test equipment is
. calibrated prior to use, after use, or at specified intervals based on ;
the required accuracy, purpose, degree of usage, and stability i characteristics. Measuring and test equipment is calibrated against WCAP-8370, REV. 12A 44 l
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10.2 CALIBRATION AND CONTROL (Continued) l certified equipment having known valid relationships to nationally )
recognized standards. Calibration standards have an uncertainty (error) the required accuracy, purpose, degree of usage, and stability characteristics. Measuring and test equipment is calibrated against' certified equipment having known ' valid relationships to nationally recognized standards. Calibration standards have an uncertainty (error) limit requirement of no more than 1/4 of the tolerance of the intended use #
of the equipment being calibrated. If no nationally recognized standards.
exist, the basis for calibration is documented. :
Measuring and test equipment is uniquely identified and affixed with tags, labels or markings- that indicate calibration status. Records are maintained to show the status of each item within the calibration program. Controls include documented disposition and/or corrective measures when discrepancies are noted. Damaged or inaccurate measuring l and test equipment is tagged or segregated until repaired and recali-brated, or replaced. Documentation to determine the validity of previous measurements performed when measuring and test equipment is found to be j out of calibration is maintained.
10.3 HANDLING, STORAGE AND RECORDS The handling and storage of measuring and test equipment are controlled ;
to assure that the accuracy of the equipment is maintained. !
9 Calibration records are maintained, traceable to the measuring and test equipment, and provide calibration status. Calibration records provide the information required to determine the validity.of previously recorded test results. .
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b WCAP-8370, REV. 12A 45 a-. ___ - - - m m
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.SECTION 11- ,
TEST CONTROL 11.0 GENERAL Testing is planned, executed, documented, and evaluated to specified requirements in accordance with written procedures, to demonstrate that items will perform satisfactorily in service. Characteristics to be tested and the test methods used are specified prior.to test. : Test-requirements and applicable acceptance criteria are specified.in procurement documents, test specifications, technical documents or a procedures.
When acceptance criteria are not met and modifications, repairs and/or-replacements are necessary, these modifications, repairs and/or replacements will be retested to the original acceptance criteria. I i
11.1 TEST REQUIREMENTS i i
Test requirements and acceptance criteria may be documented in various j controlled forms, such as test procedures, test specifications, drawings, travelers, or test instructions; and, are provided or approved by the-organization responsible for the design.
Test controls are established to identify criteria that specify when testing is required, the development of procedures, a means.of assessing the adequacy of the test items, and designation of the responsibility for perfoming the various phases of the testing. Controlled tests include, as appropriate, proof tests before installation, post-modification tests, .
prototype qualification tests, and production tests, construction tests and pre-operational tests.
11.2 TEST PROCEDURES Test procedures and/or associated instructions include: a) method and ,
instruction for performing the test; b) test prerequisites, such as WCAP-8370, REV. 12A 46
11.2 TEST PROCEDURES (Continued) calibrated instrumentation, adequate and appropriate equipment, qualified personnel, preparation, condition and completeness of the item to be tested, suitable and, if required, controlled environmental conditions; c) requirements and acceptance criteria, by incorporation or reference to design or other technical documents; d) mandatory inspection hold points, if required for witness by owner, contractor, or inspector; and, e) requirements for documenting test data results.
11.3 TEST RESULTS AND RECORDS Test results are documented, evaluated, and their acceptability deter-mined by a qualified, responsible individual or organization. Test results that determine final product acceptability are evaluated by a responsible authority to assure that test requirements have been.
satisfied.
Test records shall, as a minimum, identify the following: item tested, date of test, tester or data recorder, type of observation, results and acceptability, action taken for any deviation noted, and person (s) evaluating test results.
WCAP-8370, REV. 12A 47 1
SECTION 12 HANDLING, STORAGE AND SHIPPING 12.0 SENERAL A program commensurate with the safety significance of the item is implemented to control the handling, storage, shipping, cleaning, and preserving of items to prevent loss, damage, and deterioration. This program is documented in procedures or instructions.
These procedures / instructions may be in different formats, such as manufacturing procedures, shipping instructions, drawings, process control documents and cleaning process specifications.
12.1 SPECIAL REQUIREMENT 3 Special handling, storage and shipping requirements are contained in various documents, such as drawings, specifications or procurement documents, and these requirements are provided to the applicant / licensee when equipment is shipped to the plant site or storage facility. Special protective equipment, such as containers, shock absorbers, accelerometers, special protective environments (e.g. gas atmospheres, specific moisture ;
content levels, temperature levels), and special personnel training are specified, provided and verified.
Special handling equipment used is controlled, inspected, tested and verified at specified intervals to assure the equipment is maintained in accordance with documented instructions. Operators of special equipment are experienced or trained in the proper use of the equipment.
12.2 MARKING Instructions for marking and labeling are established as necessary to identify, maintain, and preserve the item. Any special controls, such as environmental considerations, are also indicated.
WCAP-8370, REV. 12A 48
SECTION 13 INSPECTION 13.0 PERSONNEL Inspections for product acceptance are performed by personnel who are qualified to perform the assigned inspection task and not responsible for the work being inspected. Qualification is certified as described in Part A, Section 2, Para. 2.1 of this Plan.
Inspections by personnel during on-the-job training shall be performed under direct supervision of a qualified person. Ultimate verification of conformance is always by the qualified person.
13.1 PLANNING Planning for these inspection activities is accomplished and documented using checklists, procedures, travelers, procurement documents or supplier procedures. These documents identify characteristics and activities to be inspected, the inspection method, the acceptance criteria, the organiza- ;
tion responsible for performing the inspection, and the documentation of inspection results.
If sampling is used to verify acceptability of a group of items, the sampling procedure is documented and based on recognized standard practice.
I 13.2 HOLD POINTS, IN-PROCESS AND FINAL INSPECTIONS Procedures are established and implemented for inspection of items which include source, in-process, modification and final inspection.
Hold points, if required, are identified and defined in inspection documents. Work shall not proceed beyond hold points without consent I
WCAP-8370, REY 12A 49 4
13.2 HOLD POINTS, IN-PROCESS AND FINAL INSPECTIONS (Continued) from the organization which established the hold points. This consent is recorded prior to continuation of work. Corrected areas are reinspected when acceptance criteria is not met. Modifications, repairs, or replacement of items subsequent to final inspection require reinspection or retest, as appropriate, to verify acceptability.
Items in process are inspected commensurate with their complexity and importance to safety. Monito*ing methods are used where inspection of items is impossible or otherwise impractical. Both inspection and process monitoring are used when control is inadequate without both. When both inspection and process monitoring are required, coordination and sequencing of these activities are established and documented.
Final inspections are planned and performed to verify conformance of the item to specified requirements. Completed items are inspected for completeness, marking, calibration, adjustments, protection from damage, or other characteristics as required to verify quality. Inspection also includes the review of the adequacy and completeness of the inspection results and the resolution of any nonconformances.
13.3 RECORDS Inspections are documented, and the inspection records contain, as a minimum: item inspected, date of inspection, inspector, type of obser-vation, results or acceptability, and reference to action taken for any nonconformances.
Inspection results are recorded either by qualified inspectors or by '
personnel during on-the-job training. Inspection results recorded by personnel during on-the-job training are verified by qualified inspectors and this verification is documented. Completed inspection records are reviewed to the extent necessary to determine the adequacy and completeness of the inspection records.
WCAP-8370, REY. 12A 50
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SECTION 14 INSPECTION, TEST AND OPERATING STATUS 14.0 IDENTIFICATION AND TRACEABILITY Procedures have been established to assure the inspection, test and operating status of items is verified before release, fabrication, receipt, installation, test and use. Inspection, test and operating status is indicated either on the item or in documents traceable to the item.
14.1 CONTROL OF STATUS INDICATORS The application and removal of status indicators are controlled through the use of inspection control cards, process control documents, or other documents, or by computerized control systems. Altering the sequence or tests, inspections or other operations requires the same control as the original review, and approval.
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l WCAP-8370, REV. 12A 51
SECTION 15 CONTROL OF NONCONFORMING ITEMS 15.0 IDENTIFICATION, SEGREGATION AND DISPOSITION Procedures are established to control the identification, documentation, evaluation, segregation, and disposition of nonconforming items which include failures, malfunctions, deficiencies, deviations and defective material and equipment. Nonconformance documentation identifies the nonconforming item, describes the nonconformance and its disposition, and documents approvals and any reinspection or testing required.
Individuals, including appropriate engineering and quality assurance personnel, or organizations, who are authorized to segregate, control and approve the disposition of nonconforming items are identified.
Nonconforming items are controlled to preclude their inadvertent use.
l l Nonconformances are "used-as-is," " rejected or scrapped," " repaired," or
" reworked." Technical justification for the acceptability of a noncon-forming item to be repaired or used-as-is is documented. Items used-as-is or repaired that do not conform to design requirements are subject to design control measures commensurate with those applied to the original design. Repaired or reworked items are reinspected in accordance with appropriate procedures / instructions, and with the original acceptance criteria. In accordance with this plan, quality assurance verifies implementation of the controls applied to nonconforming items during audits and surveillance.
WCAP-8370, REV. 12A 52
SECTION 16 CORRECTIVE ACTION 16.0 GENERAL Conditions adverse to quality such as failures, malfunctions, nonconformances, and out-of-control processes (including failure to follow procedures) shall be identified. These adverse conditions are also analyzed, documented, and corrected commensurate with their importance to safety. A "no-fault" attitude towards identification of problems is applicable to all personnel and is described in implementing procedures and training. Responsibility for implementation of any portion of the corrective action program may be delegated but management retains responsibility for its effectiveness.
16.1 CORRECTIVE ACTION Personnel performing activities in accordance with this Plan identify conditions adverse to quality and suggest, recommend or provide solutions to the conditions as appropriate. Procedures describe the identification, documentation, classification, cause analysis, and correction of the conditions adverse to quality.
Conditions adverse to quality are reviewed to determine the need for additional corrective action. These conditions are also analyzed for trends in quality performance and the results of these trend analyses are provided to appropriate management levels. Provisions are contained in procedures or instructions that ensure corrective actions (including procedural software and hardware) are reviewed and not inadvertently nullified by subsequent actions. Corrective action involving rework, repair and replacement of items includes any inspections or tests that are to be performed in accordance with either the original requirements, or approved and specified alternate requirements. For significant WCAP-8370, REV. 12A 53
16.1 CORRECTIVE ACTION (Continued) conditions adverse to quality, the causes are determined and documented and the impact of such conditions on items and services is evaluated for significant trends and reported to the appropriate level of management.
Actions taken to prevent recurrence are documented and reported to-appropriate levels of management.
16.2 FOLLOW-UP _
Implementation of corrective action is. verified by responsible individuals or organizations. For corrective action resulting from reports (e.g., nonconformance reports, audit reports, computer softwr.re error reports, NRC inspection reports, customer audit reports, etc..)
quality assurance participates in verifying that appropriate corrective action is documented and implemented.
WCAP-8370, REV.12A 54 1
SECTION 17 QUALITY ASSUPANCE RECORDS 17.0 GENERAL Quality Assurance Record "A completed document that furnishes evidence of the quality of items and/or activities affecting quality."
(NQA-1) (for position, see Appendix A, Page A-4)
Records that furnish evidence of quality are specified, prepared and maintained in accordance with established procedures. Requirements and responsibilities are identified and contained in these procedures and include methods for indexing, distribution, identification, classifi-cation, retrieval and retention. These requirements assure the generation and maintenance of records that reflect the quality of completed work.
Quality Assurance Records listed in Appendix 17A-1 of NQA-1 are controlled in accordance with this section. As required by contract, quality assurance records are maintained and/or forwarded to the applicant / licensee for retention.
17.1 RECORD ADMINISTRATION Design specifications, procurement documents, test procedures or other documents specify the records to be generated. Managers responsible for the generation of quality assurance records are also responsible for ensuring that they are evaluated for completeness, accuracy, indexing, record classification (as lifetime or nonpermanent records), and record validation.
Documents are considered valid records only if stamped, initialed or signed and dated by authorized personnel or otherwise authenticated.
This authentication may take the form of a statement by the responsible individual or organization. Handwritten signatures are not required if the document is clearly indicated as a statement by the reporting individual or organization. These records may be originals or copies.
WCAP-8370, REY.12A 55
17.1 RECORD ADMINISTRATION (Continued)
I Correction of quality assurance records is in accordance with procedures, which include provisions for review or approval by the originating organization, and the date and identification of the person authorized to issue the correction.
j Each group generating and collecting quality assurance records is responsible for indexing (for position, see Appendix A, Page A-8),
identifying the status, and maintaining a retrieval system for records.
Records indices, i.e., records flow schedules, include, as a minimum, record retention times and location of the records. Identification of the item or activity is provided by the record and/or the index.
I 17.2 CLASSIFICATION Records are classified as lifetime or nonpermanent in accordance with the following guidelines:
Lifetime - Those records which meet one or more of the following criteria:
- Those records which would be of significant value in demonstrating capability for safe operation.
- Records which would be of significant value in maintaining, reworking, repairing, replacing or modifying an item.
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- Records which would be of significant value in determining the cause of an accident or malfunc- a l
tion of an item.
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- Records which provide required baseline data for in-service inspections.
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WCAP-8370, REV. 12A 56
17.2 CLASSIFICATION (Continued) e Nonnermanent - Records which show evidence that an activity was j performed in accordance with applicable requirements but which do not meet any of the criteria for lifetime records. Examples _of ;
nonpermanent records are system audit reports, design control procedures, design procedures, training records and surveillance reports. Retention periods for nonpermanent records are established i and documented in accordance with Regulatory Guide 1.28, Regulatory '
Position 2.
17.3 STORAGE, PRESERVATION AND SAFEKEEPING 1
Records are maintained in a manner which allows access by index to the j information contained in the records. Records Flow Schedules are used to ;
identify records maintained. The schedules identify the retention l periods, the classification and disposition requirements, microfilming requirements (active records), and retention period at the permanent records storage facilities (inactive records). These requirements are specified in procedures that describe the system for identifying, accepting, maintaining, protecting and retrieving quality assurance records, and as clarified in Appendix A of this Plan, Pages A-8 through A-12.
17.4 STATUS, RETRIEVAL AND DISPOSITION Each group generating and collecting quality assurance records is responsible for identifying the status, and maintaining a retrieval system for records. The receipt control system is structured in accordance with procedures and alternatives to NQA-1 described in Appendix A (Page A-9) of this Plan. Retrieval of records is men 0'ed by authorized personnel. Disposition of records is described m procedures which delineate responsibilities and requirements and processing of these records in accordance with this Plan.
WCAP-8370, REV. 12A 57
SECTION 18 AUDITS 18.0 GENERAL Quality Assurance is responsible for planning and performing internal and external' audits in accordance with established procedures to verify compliance with this Quality Assurance Plan. Quality Assurance is also responsible for determining and reporting to management the overall effectiveness of the implementation of the quality assurance program.
Audits include follow-up action where indicated.
18.1 SCHEDULING Audit scheduling and resource allocation are based on the status and safety importance of the activity and audits include the full scope of quality related activities being performed. Internal audits are conducted at least once a year or at least once during the life of the activity, whichever is shorter. External audits are conducted every three years or more frequently as determined by the annual supplier performance evaluations. The audit schedule is reviewed and revised when necessary to assure coverage is maintained. Supplemental audits are performed when necessary to provide verification of specific activities and processes.
18.2 PREPARATION Audit plan; are developed and documented prior to each audit. The audit plan identifies the audit scope, requirements, audit personnel, activities to be audited, group (s) to be notified, applicable documents, schedule and written procedures or checklists to be used during the performance of the audit.
WCAP-8370, REV.12A 58
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1 18.3 AUDIT PERSONNEL I l
Auditors are independent of any responsibility for performance of the activity which they will audit. Auditor selection is based on knowledge and experience required for the activity being audited. Auditors are j qualified in accordance with ASME NQA-1, Supplement 25-3. Audit team members are selected prior to the audit. Lead auditors are responsible for ensuring that team members are prepared to participate in the audit prior to its initiation.
18.4 PERFORMANCE Audits are conducted in accordance with written procedures or checklists. Activities being audited are evaluated against quality assurance program requirements, and the results of the audit are reported to management. Where corrective action is required for significant conditions adverse to quality, management is informed immediately.
18.5 REPORTING The audit report is signed by the audit team leader and contains the following information: description of the audit scope; identification of the auditors; personnel contacted during the audit; summary of audit results, including effectiveness of the quality assurance program; and, description of each audit nonconformance and request for corrective action in sufficient detail to enable corrective action to be taken.
18.6 RESPONSE, FOLLOW-UP ACTION AND RECORDS Managers of the audited activities are responsible for evaluation of the audit nonconformance(s), scheduling and implementing corrective action, identifying measures to prevent recurrence, and providing written response of action taken or planned. Lead Auditors evaluate corrective action plans and provide for follow-up action, including the reaudit of deficient areas where appropriate, to verify that corrective action is accomplished as scheduled. The completed audit files include audit plans, audit reports, written replies, and a record of completed corrective action.
WCAP-8370, REY. 12A 59
PART C SELF-ASSESSMENT SECTION 1 - SELF-ASSESSMENTS 1.0 GENERAL Self-assessment is a means to a balanced approach where the quality assurance department and other functional departments work together to accomplish the quality objectives of each Division.
The self-assessment process objective is for functional departments to independently review and evaluate overall performance to determine the level of quality that is achieved through their individual activities and compliance to procedures.
1.1 ORGANIZATION Each Division General Manager and the ESBU Proutranent Services Manager is responsible for identifying a management position with responsibility ,
for assuring the implementation of the self-assessment function. This l
management position possesses the following characteristics: 1) l sufficient authority and organizational freedom exist to implement l assigned responsibilities; 2) it is sufficiently free from direct pressure for cost / schedule; 3) effective lines of communication exist with persons in other senior mtnagement positions; and, 4) there are no l
duties or responsibilities that preclude adequate attention to assigned self assessment responsibilities. When site activities warrant, an l on-site management position that possesses the same characteristics and responsibilities will be established. ;
1.2 OBJECTIVES AM) RESPONSIRILITIES l Personnel responsible for implementation of the self-assessment function are aware of division or organization activities so they can act in a management advisory function. Responsibilities of the personnel include assessment of overall performance; identification of potential WCAP-8370, !!EV.12A 60 f
1.2 OBJECTIVES AND RESPONSIBILITIES (Continued) problems; reporting of assessment findings in a timely fashion to a level of management having the authority to cause corrective action; and verifying satisfactory completion of corrective action. Personnel performing self-assessment activities are technically and performance oriented, having the quality of the end product as their primary objective. Procedures and processes are of secondary importance to them and they have no direct responsibilities in the area they are assessing.
1.3 ASSESSMENT PROCESS Assessments are performed to a planned and scheduled program. Planning identifies the characteristics and activities to be assessed, and the acceptance criteria. Scheduling is dynamic and based on the safety importance of the activity, and self-assessment resources are supplemented when the quality assurance program effectiveness is in doubt. Assessments are accomplished using documented instructions, procedures, checklists or other documentation of a detail commensurate with the activity's complexity and importance to safety. Implementation of the quality assurance program for work delegated to others is also assessed as described in this section.
Results of self-assessments are documented and reviewed by the assessor's management and management having responsibility in the area assessed.
Corrective action is initiated when deficient areas are identified or the effectiveness of the quality assurance program is in doubt.
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WCAP-8370, REV.12A 61 t
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FIGURE 3 ESBU AND PGBU DIVISIONAL STRUCTURE POWER SYSTEMS EXECUTIVE VICE PRESIDENT
' i ENERGY SYSTEWS POWER GENERATION BUSINESS UNIT . BUSINESS UNIT VICE PRESIDENT & VICE PRESIDENT &
GENERAL WANAGER GENERAL WANAGER l l NUCLEAR & COWWERCIAL NI ADVANCED NUCLEAR ESBU OMON C NG TECHNOLOGY FUEL CONTROUIR DM510N DMS10N DMEN l l
NUCtIAR DICTil0 ES8U j PENSC M SERYlCES WECHANICAL PROCUREWENT g DMSION DMSiON SERYlCES DOWESTIC PROCESS CUST0W0t CONTROL PROJECTS DMSiON WCAP-8370, REV. 12A 62
i i
l FIGURE 4 TYPICAL QA ORGANIZATION REPORTING STRUCTURES GENERAL !
WANAGER j
4
,/
QUAUTY '
ENGINEERING WANUFACTURING MSUM l !
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- I ,
QUAUTY [ _j l ASSURANCE I I I
- QUALITY ASSURANCE MAY REPORT TO A FUNCTIONAL DEPARTMENT, BUT THE QUALITY ASSURANCE MANAGER HAS DIRECT ACCESS TO THE GENERAL MANAGER.
WCAP-8370, REY. 12A 63
FIGURE 5 QUALITY ASSURANCE MANUALS Manual Title J l
ESBU Quality Assurance Program Nuclear and Advanced Technology Division Quality Assurance Program Advanced Energy Systems Quality Assurance Program l Electro Mechanical Division Commercial Nuclear Quality Assurance Program Manual Process Control Division Quality Assurance Program Manual Commercial Nuclear Fuel Division Product Policy-Procedure Manual Nuclear Services Division Quality Assurance Program Plan Pensacola Plant Nuclear QA Program Manual WCAP-8370, REV. 12A 64
i APPENDIX A POSITIONS ON REGULATORY GUIDES AND ASME NQA-1 l Additional positions on Regulatory guides and ASME-NQA-1 may be given in individual SARs, except as noted below. The Westinghouse divisions will conform to the latest NRC guidance unless the SAR specifies a different revision.
Reculatory Guide 1.8. Rev. 2 Oualification and Trainina of Personnel for Nuclear Power Plants.
This Regulatory Guide is not applicable to scope of work.
Reculatory Guide 1.26. Rev. 3 Ouality Group Classifications and Standards for Water . Steam . and Radioactive-Waste - Containino Components of Nuclear Power Plants.
See specific SAR document.
Reculatory Guide 1.28. Revision 3 Ouality Assurance Procram Recuirements (Desian and Construction)
ESBU follows NRC Regulatory positions with the following clarifications.
Reculatory Guide Regulatory Guide 1.28, Revision 3, Section C.1 " Appendix 2A-1, Nonmandatory Guidance on the Qualification of Inspection and Test Personnel" provides guidance on the qualification of inspection and test personnel.
Position - Alternativt Where high school graduation is specified in Appendix 2A-1, Paragraph 3.0, a General Education Development equivalent of a high school diploma is considered acceptable.
I Where three levels of qualification are to be utilized depending on the complexity of the function involved, specific level designations for personnel involved in inspection, examination, and testing activities may not necessarily be used. A combination of position descriptions and c
pre-determined qualification requirements for a position define the level of capability required to perform the function. These methods are used to identify levels of capability that include the comparable requirements of the levels identified in Appendix ~ 2A-1.
WCAP-8370, REV. 12A A-1
Reaulatory Guide 1.28. Revision 3 (Continuedl Ouality Assurance Proaram Recuirements (Desian and Construction)
Reculatory Guide Regulatory Guide 1.28, Revision 3, Section C.3 " Audits" scheduling /
supplementary requirements for audits.
Position - Clarification The regulatory position provided in Section C.3, along with alternatives to NQA-1, which are compatible with Regulatory Guide 1.28, Revision 3 will be followed.
Reaulatory Guide 1.29. Revision 3 Seismic Desian Classification See Specific SAR Document Reaulatory Guide 1.33. Revision 2 Ouality Assurance Procram Reauirements (Oceration)
This Regulatory guide is not applicable to scope of work.
Reaulatory Guide 1.36. Revision -
Nonmetallic Thermal Insulation for Austenitic Stainless Steel See Specific SAR Document Reaulatory Guide 1.54. Revision -
Quality Assurance Reauirements for Protective Coatinas Acolied to Water-Cooled Nuclear Power Plants See Specific SAR Document Reculatory Guide 1.143. Revision 1 Desian Guidance for Radioactive Waste Manaaement Systems.
Structures. and Components Installed in Licht-Water-Cooled Nuclear Power Plants See Specific SAR Document WCAP-8370, REV. 12A A-2
Reculatory Guide 1.152. Revision - f Criteria for Procrammable Diaital Comouter Systems Software.in Safety-Related Systems of Nuclear Power Plants.
Divisions follow NRC Regulatory Positions ;
Reaulatory Guide 2.5. Revision - +
Quality Assurance Proaram Recuirements for Research Reactors This Regulatory guide is not applicable to scope of work. .
Reaulatory Guide 3.3. Revision 1 :
Quality Assurance Proaram Reauirements for Fuel Reorocessina Plants and for Plutonium Processino and Fuel fabrication Plants l This Regulatory Guide is not applicable to scope of work.
Reculatory Guide 3.21. Revision -
' Ouality Assurance Reauirements for Protective Coatinas Acolied to .
Fuel Reorocessina and to Plutonium Processina and Fuel Fabrication l Plants This Regulatory Guide is not applicable to scope of work.
Reculatory Guide 4.15. Revision 1 Ouality Assurance for Radioloaical Monitorina Proarams (Normal Operation) - Effluent Steams and the Environment This Regulatory Guide is not applicable to scope of work.
Reaulatory Guide 7.10. Revision 1 Establishina Ouality Assurance Proarams for Packaaina Used in the Transoort of Radioactive Materials Divisions follow NRC Regulatory Positions.
i WCAP-8370, REV. 12A A-3
l ASME NQA-1 I DIVISIONS FOLLOWS ASME NOA-1 WITH THE FOLLOWING CLARIFICATIONS. ALTERNATIVES AND EXCEPTIONS.
NOA-1 (Supplement S-1. Section 2) Standard Paracraoh l
Definition of a Quality Assurance Record: "A completed document that furnishes evidence of the quality of items and/or activities affecting quality." ,
Position - Alternative At manufacturing divisions, product-related records are not considered complete until the time of product shipment.
" Quality assurance records are provided long-term protection either by storage of duplicate records at geographically separate locations, .
or by storage of single copy records at either the Corporate Records. !
Center, or another facility meeting the requirements of Section 4.4.1-or 4.4.2. Prior to their delivery to the long-term storage facility, records are protected by normal office procedures, including either duplicate copies or the capability to reconstruct records lost during '
this period."
i NOA-1 (Supplement 2S-2. Section 2.1) Standard Paracraoh "The American Society of Nondestructive Testing Recommended l Practice No. SNT-TC-1A, June 1980 Edition and its applicable supplements shall apply as requirements to NDE personnel covered by this Supplement."
- Position - Alternative Divisions holding an ASME Certificate of Authorization may qualify nondestructive examination personnel as requested by the ASME Code. ,
NOA-1 (Supplement 25-4. Section 4) Standard Paracraoh
" Training shall be provided, if needed, to: (a) achieve initial I proficiency; (b) maintain proficiency; and (c) adopt to changes in .
technology, methods, or job responsibilities."
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Position - Clarification j Manufacturing divisions have programs for training personnel performing fabricating, handling, shipping, storing and cleaning activities .to achieve initial proficiency. Maintenance of .;
proficiency is accomplished through continued assignments in that activity. Additional training is performed, as needed, when the job function / responsibility is changed.
WCAP-8370, REV. 12A A-4
ASME NOA-1 ,
NOA-1 (SuDDiement 25-4. Section Si Standard Paraaraoh
" Records of the implementation of indoctrination and training may take the form of: (a) attendance sheets; (b) training logs; or (c) personnel training records.
Position - Clarification At manufacturing divisions training records for personnel performing fabricating, handling, shipping, storing and cleaning activities are available for review, however, they are not maintained as nonpermanent quality assurance records.
NOA-1 (Supplement 3S-1. Section 4) Standard Paracraoh ;
Design Verification: "The results of design verificttion shall be clearly documented with the identification of the verifier clearly indicated."
Position - Clarification For Design Verification activities performed, the signature of a responsible reviewer may be used to document and substantiate the '
performance of the verification activity. Procedures define the responsibilities of the verifier and required verification actions. ,
Additionally, these procedures contain requirements for independence of the verifier, qualification of the verifier, and checking of the ,
assumptions, techniques, inputs and results of the design activity.
NOA-1 (Supplement 35-1. Section 4.2.3) Standard Paraaraoh Qualification Tests: "When tests are being performed on models or mockups, scaling laws shall be established and verified."
Position - Clarification for scale modeling, scaling laws are identified, documented and the i appropriateness of the scaling techniques is verified.
WCAP-8370, REV. 12A A-5 -i l
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ASME NQA-1 NOA-1 (Supplement 3S-1. Section 6.01 Standard Paraaraoh Interface Control: " Interface controls shall include the assignment of responsibility and the establishment of procedures among participating design organizations for the review, approval, release, distribution and revision of documents involving design interfaces."
Position - Clarification The responsibilities and authority of persons involved in the design process are defined by organization charts, management.
appointment letters and internal procedures. These documents are available for audit but are not transmitted to external organizations. Various interface agreements are established among the design departments, suppliers, customers and architect-engineers to ensure the proper flow and control of design information among the participants, and are documented by correspondence procedures, memoranda of understanding or contract documents.
NOA-1 (Supolement 4S-1. Section 3) Standard Paraaraoh Procurement Document Review: " Reviews shall be performed and documented to provide objective evidence of satisfactory accomplishment of such review prior to contract award." i Position - Alternative At some divisions, purchase order review is not documented because the purchase requisition, which is the basis for the purchase order, is reviewed and approved by quality assurance.
At other divisions, the review of purchase requisitions is not formally documented. Emphasis is placed on review of the purchase order. Purchase order reviews are documented.
NOA-1 (Supolement 65-1. Section 2) Standard Paraaraoh "The control system shall be documented and shall provide for (a) through (c) below:...(c) review of documents for adequacy, ,
completeness and correctness prior to approval and issuance."
Position - Alternativ_g l Procedures identify requirements and provide guidance for completing quality assurance records. These procedures require that applicable portions of these records be completed. It should be recognized that it is not always appropriate to " completely fill out" all records, particularly for those records completed on pre-printed ;
forms. )
1 WCAP-8370, REV. 12A A-6 1
i
1 ASME NOA-1 i NAO-1 (Supplement 7S-1. Section 2) Standard Paracruoh Procurement Planning: " Planning shall provide for the integration of;....(e) verification (surveillance, inspection or audits) activities by Purchaser, including notification of hold and witness points;"
Position - Alternative Divisions routinely identify notification points in procurement documents when applicable. Such points are not always identified in pre- and post-award meetings. However, the required notification / hold points are specified by changes to the procurement documents in a reasonable time prior to their being accomplished to allow the Purchaser the opportunity to witness the event.
NOA-1 (Supplement 75-1. Section 3.1) Standard Paraaraoh Source Evaluation and Selection: " Measures for evaluation and selection of procurement sources, and the results therefrom, shall be documented and shall include one or more of (a) through (c) below:"
Position - Alternative In addition to methods (a), (b) and (c) for the evaluation and selection of procurement sources, ASME accredited certificate holders may be selected for the supply of ASME Section III code items and services as identified within the scope of their ASME certificates, based upon ASME acceptance of their Quality Assurance Program.
Audits and annual evaluations are performed in accordance with the commitments and requirements of this Plan.
NOA-1 (Supplement 75-1. Section 9) Standard Paracraoh Control of Supplier Nonconformances: Nonconformances to the procurement requirements or Purchaser approved documents, which consist of one or more of the following, shall be submitted to the Purchaser for approval of the recommended disposition: (2) require-ments in supplier documents which have been approved by-the Purchaser, are validated."
Position - Clarification Suppliers are required to submit deviations from technical procurement requirements for approval. When suppliers are required to submit selected process or manufacturing procedures for approval, the term approval means a review to assure that the supplier under-stands the procurement requirements and is applying appropriate measures to assure compliance with these requirements. The approval l
WCAP-8370, REV.12A A-7
ASME NQA-1 Position - Clarification (Continued) action does not relieve the supplier of responsibility for assuring the acceptability of the product. Thus, suppliers are not required to submit nonconformance reports on deviations from these procedures, unless they constitute deviations from the Westinghouse procurement requirements.
NOA-1 (Supplement 75-1. Section 2 Standard Paracraoh Procurement Planning: " Planning shall provide for the integration of:. . . . (c) bid evaluation and award;"
Position - Clarification Contract Award - A contract award is initiated by the preparation of a procurement document. One of the several methods below may be used. -
- 1) Quality assurance reviews and approves purchase requisitions and purchase requisition changes. Necessary corrections or additions are completed prior to signing. A purchase order or change which accurately reflects the technical and quality requirements of the purchase requisition is then prepared by the purchasing department and issued to the vendor. In some cases, the quality requirements are predetermined for the item being procured. In this situation the quality requirements referenced in the procurement documents are previously approved by quality assurance.
- 2) Quality assurance reviews purchase requisitions and changes prior to contract award / order placement. In addition, purchase orders and changes are reviewed concurrently with issuance. If there is a discrepancy in the purchase order, quality assurance initiates a corrective action notice requesting resolution of the item, and if appropriate, identifies the point to which order processing may proceed (without effect on quality-related activities) prior to resolution of the discrepancy. Where required, a hold is placed on manufacturing until the item in question is resolved.
- 3) Quality assurance reviews and approves purchase orders and 1 changes prior to issuance.
NOA-1 (Supplement 175-1. Section 2.41 Standard Paracraoh Index: "The records shall be indexed."
WCAP-8370, REV. 12A A-8 l
ASME NQA-1 Position - Clarification :
Divisions maintain more than one index for quality assurance records to provide necessary access and retrievability. The practice is utilized as an alternative to a single index for all quality assurance records.
NOA-1 (Supolement 175-1. Section 3.2) Standard ParacraDh Receipt Control: "As a Minimum, a receipt control system shall include the following:...(b) a method for identifying records received."
Position - Alternative Receipt control systems are maintained to fit individual needs and requirements. Each system is defined in procedures and identifies the types of records to be processed. Files are established in accordance with these procedures establishing a separate file location for each category of record. When a record is received, it is filed in its pre-assigned location. ihe large volume of records and the diverse nature of the activities being performed practically '
preclude keeping a running inventory of each record received into an in-process / working file. The presence of the document itself serves ,
as the record of what has been received. When action is completed for a particular activity or component, the in-process information is ,
checked to assure that all appropriate records are available.
NOA-1 (Annendix 175-1. Section 4.4.11 Standard ParacraDh ,
Single Facility: " Design and construction of a single record storage facility shall meet the criteria of (a) thru (i) below:"
L Position - Alternative The Westinghouse Corporate Records Center (CRC) in Boyers, PA is utilized as a permanent records storage facility for inactive records which are stored in duplicate and/or single records as accepted by ,
the U.S. Nuclear Regulatory Commission (6/02/80 and 3/08/79 letters from Mr. W. P. Haass and 4/23/81 letter from Mr. U. Potapovs). This ,
facility is located in an underground limestone mine that is no longer being worked and is approximately 200 feet beneath the surface. Entry is made down a gradual graded hard surface roadway to a 24-hour guarded steel gate. This records storage facility provides an alternate to the construction criteria for a permanent records storage facility (as described below) which adequately protects i records from possible destruction.
i WCAP-8370, REV. 12A A-9 ;
ASME NQA-1 I
NOA-1 (ADDendix 17S-1. Section 4.4.1) Standard Paracraoh Enforced concrete, concrete block, masonry, or equal construction; l
Position - Clarification The walls which constitute the perimeter of this storage facility are limestone ribs,15-20 feet thick with eight inch heavy duty concrete blocks constructed between the ribs from floor to ceiling with sealed expansion joints. There are no doors or other openings in this perimeter to permit access to non-Westinghouse sections of this storage facility.
NOA-1 (ADDendix 175-1. Section 4.4.1 Standard ParacraDh Floor and roof with drainage control; if a floor drain is provided, a check valve (or equal) shall be included; Position - Alternative The limestone mine, approximately 200 feet below ground level, is impervious to water and is 38 feet above the water table.
Additionally, the entrance to the (CRC) is located approximately five miles away and 100 feet above the nearest stream. Floor and roof drains are not necessary.
NOA-1 (ADDendix 175-1. Section 4.4.1 Standard ParacraDh Doors, structure, frames and hardware shall be designed to comply with the requirements of a minimum two hour fire rating; Position - Clarification All doors, frames and hardware are constructed of non-flammable materials such as steel or brass.
NOA-1 (ADDendix 175-1. Section 4.4.1) Standard ParacraDh Sealant applied over walls as a moisture or condensation barrier; Position - Clarification Aluminum enamel paint is applied to the walls and eiling as a sealant.
WCAP-8370, REV. 12A A-10
ASME NQA-1 NOA-1 (Annendix 17S-1. Section 4.4.11 Standard Paracraoh ]
Surface sealant on floor providing a hard-ware surface to minimize concrete dusting; Position - Clarification Floors in the storage area are constructed of either asphalt or concrete over four feet of limestone. The asphalt floors are coated with a sealant. Concrete floors are coated with a hard wearing deck enamel.
l NOA-1 (ADoendix 17S-1. Section 4.4.11 Standard Paraaraoh Foundation sealant and provisions for drainage; Position - Clarification The foundation consists of four-foot thick limestone base covered j with concrete or asphalt acting as the foundation sealant. Because {
of the underground location and the fact that limestone is impervious to water, no foundation draining is necessary.
l NOA-1 (ADDendix 175-1. Section 4.4.1) Standard Paraaraoh Forced-air circulation with filter system; Position - Clarification A natural draft of air flows through the mine and passes through forced-air circulation fans when entering and existing the storage I areas. This air is also filtered as it enters the storage facility.
This system assures adequate air circulation through the storage areas. The ventilation openings are equipped with fire rated dampers that close in guillotine fashion upon sensing heat.
NOA-1 (ADDendiX 175-1. Section 4.4.11 Standard Paracraph Fire protection system; Position - Clarification A series of smoke detectors are located at strategic locations throughout the storage facility which would alert the fire crew at the first sign of a fire. This alarm system is tied into a central fire alarm board at the guard station located at the mine entrance.
A volunteer fire crew with equipment is located at the storage WCAP-8370, REV. 12A A-11
l ASME NOA-1 Position - Clarification (Continued) facility. Additionally, fire extinguishers are located throughout the storage areas. ~ A guard makes a tour inside the area every four hours during non-working hours. A volunteer fire department in a neighboring town is located within 1-1/2 miles of the mine entrance.
NOA-1 (Appendix 175-1. Section 4.4.1) Standard Paracraoh No pipes other than those providing fire protection to the storage facility are to be located within the facility. Only those penetrations used exclusively for fire protection, communication, lighting or temperature / humidity control are allowed; all such penetrations shall be sealed or dampened to comply with the minimum two-hour fire protection rating.
Position - Alternative A single waterline is located within the storage facility to provide service water for sanitation and kitchen facilities. This line is equipped with shut-off valves both inside and outside the storage area. A drainage line is also located in the storage area to remove the discharge. ,
9 F
i l
WCAP-8370, REY.12A A-12 )
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APPENDIX B CORRELATION OF WCAP-8370 TO ASME NQA-1-t see THROUGH ADDENDA tb AND ASME NQA-2a-10mo. PART 2.7 REQUIREMENTS WCAP-8370 SECTIONS REQUtREMENTS SECTION IN NQA-1 EfI!N M M M E R M M M M E M M R19111112112111 R11 Et til fit Supplement S-1 I i i i i i '
i i i ! ! 1 I i I i i i i 1 1 Crganuaton i t n ' i Supsmomeet 13-1 i e i e i i 2 QA progam Suspement 23-1 __ZZ1 i ' T- T ' " ' ' i . ' T- i 1 Suppeement 2S-2 ____ _i_ i
- i i i i * '
' i i ' i suppeement 23-3
(( ,,,_ ((((
t'*en*";'"J' 'i' -F- r------t--Humr-H---H 3 Desogn Contot I i i i i i i i i 6 l l >
! ! . 4 e 1 1
Suppeement 3S-1 I i i
! I i i i i i i i i i t i I
4 procuronent Documorit Contof I i i i
- i i l i i f I i i i a l a 4 i Suppeement 45-1 I i l i i i i
! l , i i i
! ! 4 i i ! I 5 Inoruemons.Promeares end 0rawings I i ' I i 1 I i i i ! i i i i i e i l 6 thcumentContoi l i i i I i 6 e i i ! ! ! i i i e i i l
'- :-.:88-t i I t i i i i i i ! i e ! 4 i i e i 1 7 Confed of Pwenesed items and Servtone i i i i ! I I i i i t i i t i i i i 1 Suppennent 75-t l . i 6 I i t i i i i i i i i , , . 1 l 8 identAceton and Contal of Ipome I i i ? i i i i 6 . i i l I i e i >
t i Suppeament 88-t 1 i ! 1 i i I t 4 i i l i i i i i e i I 9 Confod of Pr-a I s ! ! I I i 1 l i i i i i ! ! l ! i i Suppeement 98-1 I i t I i i l i i ! i i t i i ! I i i i 10 hepocean I i i 1 1 i i ! i i i l l 1 I i i i i i Suppeement 108-1 I i i i 1 i i i t i i i i i i I e i
! i
- " " " " ~ - " " ' " ~~"" - ~~'"
11 Test Contal i l
Suppeement i18-t e i e i
- - ~
Suppeement 118-2 ;
_ , , , , , _ _ _ Z _ C _
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i j i i i 12 Contalof Measurtig and Test Eomment I i ! I i ! l 4 ! ! 1 I i i I e i ; i l Suppeement 129-1 1 I i l l ! ! l i i i i i ; j j j i j l 13 Herwarig Sktego,and Sheppetg I l 1 i i i i i i i I i I ! i i I , 1 1 Suppenment 136-1 1 I i i i i i l i i i i i i i i i l i l 14 Wiepocean. Test and Opereeng Statas l l 1 i 6 i e i ! i l l 6 l l l 1 i i 1 19 Cantoiof NoncontwmriS tems 1 1 i I i ! l 1 1 i i 1 i i 1 i i ! i !
Supptoment 1SS-t i i ! I i i i l I l i i I 6 i 1 ) i e !
10 Correceve Admen l I i i i i l I i i i i ! ! I I i i ! l g --------------
Appends 17A-1 ---------- --- -
10 Aus91s I i 6 i I i i i I i i i i 1 i i I ! I I fuppemment iss-t I i i t i i i i i i j l t I i i I . j i i
SECT 10N IN NOA-2 '
Pwt 2.7 I i e i i i I I i t i i i i i i I i i l l
i l
WCAP-8370, REV.12 A B-1
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APPENDIX C POSITIONS ON ASME NQA-2 ,
Divisions follows ASME NOA-2 identified in Aooendix C with the followino clarifications. alternatives and exceptions.
NOA-2 Part 2.1 Quality Assurance Recuirements for cleanina of Fluid Systems and Associated Components for Nuclear Power Plants.
Divisions follows the requirements of Part 2.1 for those portions of the construction site work within their scope.
NOA-2 Part 2.2 Ouality Assurance Reauirements for Packaaino.
Shionina. Receivino Storace. and Handlino of Items for Nuclear Power Plants.
Subsection 4.2.3 Special Shioments Position - Exception For special shipments, W implements requirements for bracing and tie down, identification of the shipment, use of impact recording meters and escorts, and investigation of the carrier and transportation route when appropriate. However, M does not consider it desirable or feasible to implement subsection 4.2.3 in all situations. For example -
it may not always be desirable to identify special shipments with large letters or it may not always be possible to install impact recording i meters prior to handling. In summary, M implements controls for I special shipments based upon engineering judgement and experience to assure proper transportation of the special shipment.
Subsection 3.6.2 Vapororoof Barrier Material "Vaporproof barrier material should be colored to contrast with the '
l material on which it is used."
Position - Alternate 'l l
M utilizes vapor barriers in packaging processes that contrast with I the material being packaged when such packaging materials are commercially available. A variety of colors for these packaging materials is not readily available because of the limited supply of material which meet other physical and chemical requirements.
Section 5 Receivina (Requirements for receiving contained in i Section 5)
Position - Clarification The divisions follows this section for those portions of the construction site work within their scope.
I WCAP-8370, REV. 12A C-1 I
POSITIONS ON ASME NOA-2 Section 6 Storace(Requirements for storage contained in Section 6.)
The divisions follows this section for those portions of the construction site work within their scope.
Section 7 Handlino (Requirements for handling contained in Section 7.)
Position - Alternate The divisions and their suppliers use conservative industrial engineering practices for controlling the lifting and moving of completed component during packaging and shipping operations.
NOA-2. Part 2.3 Ouality Assurance Recuirements for Housekeepino for Nuclear Power Plants !
Divisions follows the requirements of Part 2.3 for those portions of the construction site work within their scope.
NOA-2. Part 2.5 Ouality Assurance Recuirements for Installation. I InsDection. and Testino of Structural Concrete. Structural Steel . Soils.
and foundations for Nuclear Power Plants Part 2.5 of NQA-2 is not applicable to the divisions' scope of work.
NOA-2. Part 2.7 Ouality Assurance Recuirements of Computer Software for Nuclear Power Plants.
Divisions follows the requirements contained in Part 2.7 (Detailed in Section B-5 of this Plan.
NOA-2. Part 2.8 Ouality Assurance Recuirements for Installation.
Inspection. and Testino of Mechanical Eauioment and systems for Nuclear Power Plants Part 2.8 of NQA-2 is not applicable to the divisions' scope of work.
1 WCAP-8370, REY. 12A C-2
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