ML20035E588
| ML20035E588 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 04/01/1993 |
| From: | Link B WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-93-047, CON-NRC-93-47 VPNPD-93-078, VPNPD-93-78, NUDOCS 9304190011 | |
| Download: ML20035E588 (34) | |
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POWER COMPANY 231 W TAchgan PO b 204a W osea Wi 53201-2043
[414)221-2345 l
i VPNPD-93-078 10 CFR 50.54 NRC-93-047 i
April 1, 1993 l
l Document Control Desk I
U.S. NUCLEAR REGULATORY COMMISSION Mail Station P1-137
'j Washington, DC -20555 Gentlemen:
DOCKETS'50-266 AND 50-301 SUBMITTAL OF OUALITY ASSURANCE PROGRAM DESCRIPTION CHANGES I
POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 i
In accordance with the requirements of 10 CFR 50.54 (a) (3), Wisconsin Electric Power Company is submitting the latest revisions to Section 1.8 of the Final Safety Analysis Report (FSAR) for Point i
Beach Nuclear Plant.
Section 1.8 of the FSAR describes _the present Quality Assurance Program implemented for Point Beach Nuclear Plant.
j This section was last submitted to the NRC on-March 23, 1992, and
-t subsequently accepted in an NRC letter dated June 25, 1992.
Changes to the program description since that time are highlighted in the l
attachment.
l None of the changes are considered to be reductions in Quality Assurance Program commitments as previously approved by the NRC.
These changes are listed and summarized in Attachment A to this letter.
Please note that the enclosed Section 1.8 pages include revision numbers which are incorporated at the bottom of each page.
The l
June 1993 changes in the text are noted by bars in the right margin.
Since we intend to include these Section'1.8 changes in-the FSAR update to be printed this June, your timely review of this infor-i mation would be appreciated.
If you have any questions regarding this matter, please contact l
Jeff Anthony at (414)221-2481.
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Sincerely,
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~ Bob Link l
Vice President Nuclear Power 190011 930401 p
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ADOCK O N 266 i
Enclosures em
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NRC_ Resident Inspector 8
NRC Regional Administrator, Region III I
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Attachment A FSAR 1.8 Chances - 1993 Update 1.
Page 1.8-2 1st paragraph - Last standard changed to " ANSI N45.2.12-1977" l
l 2.
Page 1.8-4 3rd paragraph - Changed QA Section subdivision to j
"Four" groups l
3.
Page 1.8-5 1st paragraph - Changed heading to " Quality Verification" 2nd paragraph - Changed heading to " Quality Support" Deleted " Maintain and" in item 1 I
and all of item 3 4.
Page 1.8-6 3rd & 4th items - Deleted " Perform" and "and trending of QAS" from item 3 l
- Added new " Item 4" l
1st paragraph - Deleted " limited" from the sentence 5.
Page 1.8-7 Top paragraph - In 3rd sentence deleted "the Nuclear Services (NS)
Administration Manual" 4th item - Deleted "NS Administration Manual, the" and " respective" in the sentence 6.
Page 1.8-22 Last paragraph - Deleted 1st sentence "In a footnote.
7.
Figure 1.8-1 Changed title of Vice President Human Resources to
l 8.
Figure 1.8-2 Revisions to reflect changes in NPD Section titles.
No major structural changes.
9.
Figure 1.8-3 Revisions to reflect recent changes in QAS organization, denoting minor structural changes, i
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1.8 OVALITY ASSURANCE PROGRAM In accordance with Paragraph 50.34 of 10 CFR 50 and 71.24 of 10 CFR 71, a Nuclear Quality Assurance Program Description is provided by Wisconsin Electric Power Company (WE). This Program assures that the required manpower, l
l procedures, and management of Point Beach Nuclear Plant are directed toward satisfying the Company objectives of providing safe and reliable structures, systems, and components; and complying with the provisions of 10 CFR 50, l
Appendix B " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants"; 10 CFR 71, Subpart H " Quality Assurance for Packaging and Transportation of Radioactive Material"; and the applicable Sections of the ASME Boiler and Pressure Vessel Code. This description is structured in accordance with the 18 criteria of Appendix B.
The following describes the quality assurance program established and imposed i
by the Company for application to the functional aspects of structures, systems, components, including the design, purchasing, construction, and fabrication, handling, storage, shipping, cleaning, installation, erection, inspection, testing, operation, maintenance, refueling, repair, and modification of equipment considered significant to safety by the Company.
These structures, systems, and components may be classified as safety-related in that they prevent or mitigate the consequences of postulated accidents.
Others, as in the case of radioactive material packaging, fire protection, and f
station blackout may be classified as QA-scope in that they could contribute to causing undue risk to the health and safety of the public or loss of services should they fail or malfunction.
Structures, systems, and components not classified as safety-related or QA-scope items are controlled as necessary to provide assurance of quality commensurate with the importance of the function (s) to be performed.
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The principal objectives of the quality assurance program and the key functions and elements which it contains are not expected to change. However, circumstances may make advisable changes in the organization or in the implementing detail necessary, and such changes will be made in accordance with established procedures. Changes in the quality assurance program description will also be submitted to the NRC as required by 10 CFR 50.54.
1.8-1 June 1992
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'The Point Beach Nuclear Plant Quality Assurance Program commits to the guidance provided in ANSI N18.7-1976, except as specifically noted. Where exceptions are noted in the text of this section, the PBNP alternative system is discussed. Commitment to ANSI N18.7-1976 includes either complete or f
partial commitment to the following additional standards:
ANSI N18.1-1971 Selection and Training of Nuclear Power Plant I
Personnel ANSI N18.17-1973 Industrial Security for Nuclear Power Plants ANSI N45.2.1-1973 Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants.
ANSI N45.2.2-1972 Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants (During the Construction Phase)
ANSI N45.2.3-1973 Housekeeping During the Construction Phase of Nuclear Power Plants i
ANSI N45.2.4-1972 Installation, Inspection, and Testing Requirements for Instrumentation and Electric Equipment During the l
Construction of Nuclear Power Generating Stations ANSI N45.2.5-1974 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural t
Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants ANSI N45.2.6-1973 Qualification of Inspection, Examination, and Testing Personnel for the Construction Phase of Nuclear Power Plants ANSI N45.2.8-1975 Supplementary Quality Assurance Requirements for i
lastallation, Inspection, and Testing of Mechanical Equipment and Systems for the Construction Phase of i
Nuclear Power Plants ANSI N45.2.9-1974 Requirements for Collection, Storage, and Maintenance i
of Quality Assurance Records for Nuclear Power Plants ANSI N45.2.10-1973 Quality Assurance Terms and Definitions l
ANSI N45.2.11-1974 Quality Assurance Rrquirements for the Design of Nuclear Power Plants ANSI N45.2.12-1977 Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants i
1.8-2 June 1993
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1 ANSI N45.2.13-1976 Quality Assurance Requirements for Control of I
Procurement Items and Services for Nuclear Power Plants i
ANSI N45.2.23-1978 Qualification of Quality Assurance Program Audit Personnel For Nuclear Power Plants ANSI N101.4-1972 Quality Assurance for Protective Coatings
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Applied to Nuclear Facilities i
To the extent required by ANSI N18.7-1976 as hereinafter specifically noted, j
PBNP hereby commits to the above standards. Table 1.8-1 provides further l
information regarding commitments to regulatory guides and related standards.
i 1.8.1 ORGANIZATION The authorities and responsibilities of persons and organizations performing l
quality related activities are established, assigned, and documented in a formal system. Quality assurance and quality control functions are performed j
by Company organizations (including both on-site and off-site personnel) except when the scope of-specific projects dictate the need to engage f
contractors to perform specific services or as otherwise noted.
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Those persons and organizations assigned such functions are given appropriate and sufficient authority and organizational freedom to identify quality problems; verify implementation of the solutions; and prevent further j
processing, delivery, installation, or use of nonconforming items until proper I
dispositioning has occurred.
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The organizational structure and functional responsibility assignments are such that: (1) attainment of quality objectives is accomplished by individuals l
assigned responsibility for activities affecting quality or performing work to specifications, (2) audits verifying conformance to established quality l'
requirements are accomplished by those who do not have direct responsibility for performing the work being verified, and (3) personnel in key quality assurance functions have direct access to responsible management. The education and experience required of individuals assigned to QA positions is documented and approved by management.
1.8-3 June 1992
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'The operating organization is reflected in Figure 15.6.2-2 of the Technical l
Specifications. The organization for quality assurance is reflected in Figures 1.8-1, 1.8-2, and 1.8-3.
The Vice President-Nuclear Power Department, l
who reports directly to the President - Wisconsin Electric Power Company, has j
been delegated the authority by the President to establish quality assurance j
policies, goals, and objectives as applicable to the Point Beach Nuclear Plant and the Nuclear Power Departm::nt although the President retains ultimate j
responsibility, i
Manaaer - Nuclear Operations
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The Manager-Nuclear Operations is the senior company representative at the plant facility and, as such, is in direct day-to-day control of all normal plant administration and technical operations.
In matters related to quality l
assurance, the Manager remains cognizant through direct involvement and j
through input from various sources including the Site Quality Assurance group.
i Manacer - Ouality Assurance
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l The Manager - Quality Assurance as the head of the Quality Assurance Section (QAS) reports to the Vice President - Nuclear Power Department and has n
responsibility for both " headquarters" quality assurance functions and various l
quality assurance activities at the site. The QA Section has staff located both in the corporate office and at the plant. The QA Section is divided into four groups (see Figure 1.8-3) with primary responsibilities summarized as j
follows-Site Ouality Assuray_cg j
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1.
Perform quality assurance reviews of maintenance and modification l
documents.
In regard to modifications this includes scoping for QA i
applicability of work to be performed.
2.
Perform reviews of all NPD generated procurement documents. These reviews include. scoping for QA applicability and establishment of i
i appropriate quality assurance requirements.
3.
Verify conformance of received items to purchase document requirements j
through various activities including review of documentary evidence of l
quality prior to release of the items (Section 1.8.7).
I 1.8-4 June 1993 I
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'4.
Monitor performance of in-plant contractors through surveillances.
5.
Provide primary interface between plant groups and other department groups in matters related to quality assurance.
6.
Report to the Manager-QA on matters involving quality assurance.
7.
Assist plant groups in interpreting quality related codes, standards and procedures.
8.
Provide guidance and direction as necessary to in plant groups in regard to conformance to NPD QA policies and procedures and performance of quality related functions, e.g. records administration, quality control.
Quality Verification 1.
Implement the internal audit program to verify compliance to established quality assurance program requirements and satisfactory performance of quality activities. This includes audits of in-plant groups as well as off-site company organizations performing quality-related activities for Point Beach.
It also includes audits of the Technical Specifications which are performed under the cognizance of the Off-Site Review Committee.
2.
Perform quality assurance evaluations, audits and surveys of vendors and contractors commensurate with the importance, complexity, and quality of the product or services provided.
3.
Maintain lists of qualified suppliers including periodic review of supplier performance.
4.
Provide support to Point Beach for source verification of procured items.
5.
Provide quality support to Point Beach for major projects under the scope of the WE QA program.
6.
Perform periodic surveillances of day-to-day plant activities.
Quality Suonort 1.
Control issuance of quality assurance instructions and procedures manuals including the Nuclear Power Department QA Policy Manual, Nuclear Power Department QA Procedures Manual, and the QAS Instructions Manual.
l 2.
Coordinate and perform QA indoctrination and training, as applicable.
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~3.
Tracking internally identified deficiencies. Tracking includes monitoring of open items and notifying appropriate management when items become delinquent.
4.
Self-assessment support and facilitation for PBNP.
i Ouality Technical Services i
Provide support to Point Beach for nondestructive examination services related l
to inservice inspection activities.
Off-Site Review Committee The Off-Site Review Committee (0SRC) is established in accordance with Technical Specifications, Section 15.6.5.2.
The OSRC selectively reviews l
designated activities involving the operation of Point Beach Nuclear Plant including Technical Specification compliance.. The committee's specified duties and functions are described in the PBNP Technical Spacifications,
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Section 15.6.5.2.1.
In addition to the above, the OSRC is also tasked with the responsibility of j
assessing the adequacy and effectiveness' of the Nuclear Power Department (NPD) i Quality Assurance Program. This is done in concert with their review l
functions as described above.in addition to review of NPD QA policies, l
procedures and practices. Assessment of the program is also achieved through i
other means such as initiation of periodic audits.
j 1.8.2 QUALITY ASSURANCE PROGRAM l
A quality assurance program is established and implemented in accordance with written policies, procedures, and. instructions which comply with the requirements of 10 CFR 50 Appendix B and 10 CFR 71, Subpart H.
The program is also applied to-activities such as fire protection to a degree commensurate i
with Wisconsin Electric commitments. Specific QA Program applicability to fire protection, radioactive material packaging and station blackout is j
defined in Tables 1.8-2, 1.8-3 and 1.8-4, respectively. The Nuclear Power l
Department Quality Assurance Program is set forth in the NPD QA Policy Manual, j
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1.8-6 June 1993 l
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'the NPD QA Procedures Manual, the QAS Instructions Manual, and the PBNP l
l Administrative Control Policies and Procedures Manual.
Control of the above manuals is as follows:
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4 1.
Distribution and maintenance of the " Nuclear Power Department Quality f
Assurance Policy Manual" and revisions thereto are controlled by the Quality Assurance Section. The policies in this manual are approved by the Vice President - Nuclear Power Department.
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3 2.
Distribution and maintenance of the " Nuclear Power Department Quality l
Assurance Procedures Manual" and revisions thereto are controlled by the t
Quality Assurance Section. The manual procedures and subsequent revisions are approved by the designated section manager within the f
Nuclear Power Department assigned primary responsibility for the Quality l
Procedures.
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a 3.
Distribution and maintenance of the "PBNP Administrative Control Policies J
& Procedures Manual" and revisions thereto are controlled by the Nuclear f
Operations Section. The manual is reviewed and approved on-site by the plant organization.
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4.
The QAS Instructions Manual, and revisions thereto, are controlled and l
approved by the QAS section manager.
Final responsibility for modifications, repairs, maintenance, and operations, j
including the quality assurance program, lies with the President. Management i
review of the status and adequacy of the quality assurance program is f
accomplished by at least semiannual review by the Off-Site Review Committee j
(Section 1.8.1) and by regular briefings (at least once every two months) with
.j the President.
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The quality assurance program applies to structures, systems, components (including expendable and consumable items which are used therein) and services which are classified as QA-scope based upon the safety-related functions to be performed. QA-scope structures, systems and components are identified by various means. QA scoping is consistent with requirements of a
the regulations as described in this FSAR, and also includes non safety-related systems and components requiring quality assurance coverage such as 1.8-7 June 1993
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fire hotection, radioactive material packaging and station blackout.
l Positive controls are implemented to assure updating of the various means as necessary.
The classification of a system or component as QA-scope does not imply that the complete system, or all the components or component parts within that system, are QA-scope. Those specific portions of systems considered to be QA-scope are also identified in appropriate documents.
The program provides for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained. The indoctrination and training program is structured to assure that:
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1.
Personnel performing quality activities are instructed as to the purpose, I
r scope and implementation of the quality-related manuals, procedures and instructions; and it is emphasized that these are mandatory requirements i
which must be implemented and enforced.
i 2.
Personnel performing quality-related activities are trained and qualified
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in the principles and techniques of the activity being performed.
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f 3.
Appropriate training procedures are established and that records of training are maintained.
Section 5.2.10 of ANSI N18.7-1976 states that the provisions of ANSI N45.2.3-l 1973 shall be applied to those activities which are comparable in nature and extent to related activities occurring during construction.
Point Beach j
Nuclear Plant practices good housekeeping and cleanliness involving activities l
performed by plant and contractor personnel to maintain the necessary standard I
of cleanliness.
j Scheduled and documented daily-to-weekly surveys of potentially contaminated or radioactive areas are conducted by health physics personnel, followed by l
decontamination or radioactive cleanup as necessary. Surveys ensure i
cleanliness checks of even the least traveled areas. An additional program provides that Operations shifts are assigned specific plant areas to patrol
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and clean up as a housekeeping duty. Plant policy is that each person is
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1.8-8 June 1992-l l
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responsible for cleanliness and good housekeeping in their own immediate work Final inspections of work areas following completion of work, including area.
final internal inspections of pressure vessels, tanks, etc., are routinely completed by supervisory personnel.
Such inspections are formally documented only in special cases when considered necessary; these normally being final inspections by plant supervisory personnel following work by outside l
contractors.
i Storage of items are controlled to established quality assurance and fire protection requirements. Access to safety-related equipment or radiation controlled areas is controlled by security regulations or defined health physics rules.
PBNP is committed to comply with OSHA regulations in the physical safety and environmental condition of work places.
i Significant attention to housekeeping is provided by plant management on a periodic basis.
1.8.3 DESIGN CONTROL l
Procedures and practices are established and documented to assure that applicable regulatory requirements and design bases are correctly translated into design documents, such as specification and drawings, for work involving changes or additions to the original design of safety-related structures, systems, and components. These measures include provisions to assure that appropriate quality standards are specified and included in the design documents and that deviations from such standards are controlled. The measures also include provisions to control selection and review for the suitability of application of materials, parts, equipment, and processes that are essential to the safety-related function.
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l Procedures and practices are established and documented for the identification and control of design interfaces and for coordination among design organiza-tions. These include procedures among participating design organizations for the review, approval, release, distribution, and revision of design documents.
The design control measures provide for verifying or checking the adequacy of design by design reviews, by alternate or simplified calculational methods, or 1
1.8-9 June 1992 l
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'by suitable testing programs performed by individuals or groups other than the originator.
Where a test program is used to verify the adequacy of a specific design feature, provisions include suitable qualification testing of a prototype unit under the most adverse design conditions. Design control measures consider, as appropriate, reactor physics; stress, thermal, hydraulic, and accident analyses; compatibility of materials; accessibility for inservice inspection, maintenance and repair; and delineation of acceptance criteria for inspections and tests.
Changes to designs are subjected to commensurate design control measures.
When a contemplated change is considered by appropriate management to be of sufficient scope as to be beyond the expertise of in-house personnel, these changes are reviewed by the organization that performed the original design, or other design organizations determined to be equally qualified. Design activities associated with modifications of safety-related structures, systems and components are accomplished in accordance with the provisions of Section 8 of ANSI N45.2.ll-1974.
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r 1.8.4 PROCUREMENT DOCUMENT CONTROL Procedures and practices are established and documented to provide assurance that applicable regulatory requirements, design bases, and other requirements which are necessary to assure adequate quality are verified during procurement and acceptance of materials, products, or services. These measures are applied to spare and replacement parts and equipment, new material, and equipment and contracting of services.
Procedures require that procurement i
documents be prepared, reviewed, and approved in accordance with QA program requirements. The Quality Assurance Section reviews procurement documents to t
ensure the inclusion of adequate quality criteria.
Records of the review are maintained.
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1.8-10 June 1992 t
~ Procurement documents require suppliers, contractors, or subcontractors to implement quality assurance programs to the extent necessary. The programs may be reviewed by the QA Section, qualified third party organizations such as the American Society of Mechanical Engineers (ASME), industry organizations such as the Nuclear Procurement Issues Committee (NUPIC) or joint utility groups. The evaluation and qualification of supplier programs is documented.
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Further details of the system for control of procurement documents is contained in Section 1.8.7.
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1.8.5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS L
Activities affecting quality are prescribed by documented instructions, procedures or drawings appropriate to the work at hand with the work i
accomplished in accordance with these documents. Measures are established for the preparation, revision, and control of procedures, instructions, or j
drawings.
Instructions, procedures, and drawings are required to include appropriate i
t quantitative or qualitative acceptance criteria to ensure work has been satisfactorily accomplished. Supervisors may direct that data be taken without the data taker taing cognizant of the acceptance criteria when it is l
considered that forehand knowledge of the acceptance criteria may prejudice f
results. The supervisor is then responsible for verifying conformance. To the j
I extent applicable, as-built drawings and original equipment and system specifications, subject to improvements resulting from operational experience i
and subject to the necessary design control, establish acceptance criteria.
When required, these instructior.s, procedures, and drawings provide methods for f
complying with appropriate regulations.
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Section 5.2.2 of ANSI N18.7-1976 requires that temporary major procedure l
changes which do not change the intent of an approved procedure be approved by f
two members of the plant staff knowledgeable in the areas affected by. the procedure. One of these individuals is to be the Duty Shift Superintendent
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who holds a senior operator's license. As described'in Section 15.6 of the l
Technical Specifications, Nuclear Operations follows the above guidance for operating procedures.
For Maintenance, Instrumentation and Control, Technical l
Services, Chemistry, and Health Physics procedures, approval is not required i
1.8-11 June 1992 i
'from the Duty Shift Superintendent for temporary changes.
For a further description of the system for temporary changes, refer to Section 15.6.8 of the Technical Specifications.
Section 5.3.2 of ANSI N18.7-1976, which discusses the content of procedures, states in part, "... procedures shall include, as appropriate...(8) Acceptance Criteria." We have determined that the incorporation of acceptance criteria i
is not always advantageous, as discussed herein.
1.8.6 DOCUMENT CONTROL Procedures and practices are established and documented to control the issuance and revision of documents, such as: maintenance and modification procedures; design specifications; design, manufacturing, construction, and f
I installation drawings; procurement documents; manufacturing, inspection, and testing instructions; test and operating procedures; QA manuals; safety i
analysis reports; and related design criteria documents. The procedures identify responsibility for review, approval, and issuance of the documents and associated changes. For quality related documents, the review includes an assessment of applicable quality requirements.
i The procedures provide assurance that documents, including changes, are i
reviewed for adequacy, approved for use by authorized personnel and distributed to and used at the location where the prescribed activity is l
performed prior to commencement of the activity. These include prompt issuance of changes and control of the obsolete or superseded documents to prevent inadvertent use. Controls, such as maintenance and distribution of indices, are also implemented to identify current revision of documents to be used. Document control procedures include provisions for determining responsibility for review of changes to documents.
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Documents classified as QA records are subjected to the additional require-ments described in Section 1.8.17.
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1.8-12 June 1992
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1.8.7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES Procedures and practices are established and documented to assure that purchased material, equipment and services conform to the procurement f
documents. These measures include review of all purchase requisitions by the j
Quality Assurance Section. QA scope requisitions are processed by the Quality j
Assurance Section to ensure in orporation of appropriate quality requirements.
l The bases for selection of suppliers may include previous experience,
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satisfying the required qualifications of the contractor who erected the plant, or a pre-award evaluation of the proposed supplier's capabilities and j
qualifications.
Industry programs, such as those applied by ASME, NUPIC, or
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other established utility groups, are used as input or the basis for supplier i
qualification whenever appropriate.
t Control of purchased items includes provisions, as appropriate, for source l
evaluation and selection, objective evidence of quality furnished by the contractor or subcontractor, inspection at the source, and examination of l
products at receipt. These controls also include provisions for monitoring j
4 contractors providing services through performance of audits and i
surveillances, as necessary, to verify conformance with procurement i
requirements. These are performed by appropriately trained personnel in 3
accordance with written procedures and instructions.
l Documentary evidence is required to be available prior to use of equipment.
Procedures require assignment of a Quality Assurance Release (QAR) identi-f iication number prior to placing the purchased items into service. These
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l procedures require all documentation required by the purchase order to be available and satisfactory prior to issuance of the QAR. Measures are-provided for monitoring the effectiveness of contractor control of quality consistent with the importance, complexity, and quality of the product or services.
l The requirements of ANSI N45.2.13-1976 are met for the procurement of i
components within the scope of Section 5.2.13 of ANSI N18.7-1976.
i 1.8-13 June 1992 i
'1.8.8' IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND j
COMPONENTS Procedures and practices are established and documented requiring identi-fication of materials, parts, and components, including partially fabricated assemblies, to prevent use of incorrect or defective items.
Identification requirements are based on as-built drawings and specifications.
Identification requirements for other than identical replacement items are determined during planning for the modification or addition.
Identification methods and locations are selected so as not to affect the function or quality of the item.
These measures assure that identification is maintained by stock number, system identification, part number, or other appropriate means, either on the item or on records traceable to the item, as required during installatiot, and use. These measures apply to plant items as well as those provided by on-site contractors.
Procurement documents invoke appropriate requirements for identification and control of material during manufacture, including provisions for WE in-process audits of the manufacturer's program.
1.8.9 CONTROL 0F SPECIAL PROCESSES Procedures and practices are established and documented to assure that special processes, such as welding, heat treating, and nondestructive examinations are controlled and accomplished by qualified personnel using qualified procedures I
or process sheets in accordance with applicable codes and standards.
Verification of conformance is documented. These measures require copies of qualifications to be on site during process performance whether by WE personnel or contractors.
Procurement documents specify appropriate control requirements for processes performed off-site.
1.8-14 June 1992
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'1.8.10 INSPECTION 3
Procedures and practices are established and documented providing for i
appropriate inspection of activities affecting quality and to verify l
I conformance with the documented instructions, procedures, drawings, or specifications for accomplishing the activity.
Inspection procedures, l
instructions, and checklists include the following, as applicable:
f 1.
Identification of characteristics to be inspected.
2.
Identification of the individuals or groups responsible for performing the inspection operation.
3.
Acceptance and rejection criteria.
4.
The method of the inspection.
5.
Verification of completion and documentation of the inspection.
1 Maintenance, replacement, or rework items are inspected in accordance with original inspection requirements and criteria or improved requirements based on operating experience.
Modified items are inspected by methods at least equivalent to the original inspection methods.
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i These measures provide for verification of conformance to be performed by l
certified individuals other than those who performed the activity.
Certification of these individuals in accordance with appropriate requirements is documented. Provisions for Code Authorized Inspection are included when j
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required.
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Examinations, measurements, or tests are performed for work operations where i
necessary.
Procurement documents for materials or products specify examinations, measurements, or tests to be performed for each work operations l
where necessary to assure quality. Quality Assurance personnel perform receiving inspection on procured materials as appropriate per the procurement f
documents, specifications, procedures, and instructions.
Procurement j
documents for materials or products,- for which direct inspection is impossible or disadvantageous, specify provisions for indirect control'by monitoring processing methods, equipment, and personnel. When control is inadequate without both inspection and process monitoring, provisions for both are included. Mandatory hold points are specified and used where required.
1.8-15 June 1992
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'Section 3.4.2. of ANSI N18.7-1976 states that personnel performing inspection, examination, and testing activities shall be qualified to ANSI N18.1-1971, or shall meet the requirements of ANSI N45.2.6-1973. With few exceptions, Point Beach personnel meet or exceed the qualification requirements of ANSI N18.1-1971, and are therefore qualified to perform plant inspection, examination, and testing activities. Those few exceptions are in job functions not
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discussed in ANSI N18.1-1971 and certain inspection and test personnel who work for contractors as discussed below.
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All positions at Point Beach have been evaluated to determine the minimum l
qualification requirements. The areas considered during the evaluation i
included regulation, code and standard requirements, education and training, work experience, and physical condition. Applicants for positions at Point l
Beach not meeting the minimum requirements, or not satisfying preemployment f
l aptitude testing requirements are not considered for the position.
f Additionally, prior to employment, all plant personnel are interviewed by l
senior plant management and, in most cases, are interviewed by the Manager-l Nuclear Operations.
These individuals make the final determination of acceptability. There is only one level of qualification at Point' Beach, not three levels as indicated in ANSI N45.2.6-1973.
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When the extent of the maintenance or modification is such that it must be i
I performed by contract, the potential contractor's QA program is evaluated by the QA Section to determine its acceptability.
Included in the evaluation is consideration of the qualifications of inspection and test personnel.
In cases where it-is determined that a contractor's organization is suitably qualified in all'other respects, including qualified personnel, a-qualification and certification program which meets all the requirements of ANSI N45.2.6-1973 is not insisted upon.
Implementation of the audit program l
assures qualification of such personnel.
All nondestructive examination personnel are required to be qualified in accordance with the appropriate sections and editions of ASNT Recommended f
Practice No. SNT-TC-1A.
l 1.8-16 June'1992 L.,-
--.,..n,
, 0.,
'Section 3.2 of ANSI N18.7-1976 requires that verification of conformance be performed by individuals other than those performing or directly supervising the work. Verification of conformance is conducted in this manner at Point Beach.
Section 5.2.17 of ANSI N18.7-1976 requires inspections for modifications and non-routine maintenance to be performed in a manner similar to that associated i
with construction phase activities. Modifications and non-routine maintenance for which outside contractors are used are performed in this manner.
Modifications and non-routite maintenance items within the capabilities of the onsite operating organization are performed as a routine maintenance activity.
1.8.11 TEST CONTROL Procedures and practices are established and documented to provide a program of periodic testing and continuing surveillance to demonstrate that structures, systems, and components continue to perform satisfactorily in service. The measures require tests to be performed by appropriately trained and qualified personnel in accordance with written test procedures which incorporate the requirements and acceptance limits (except as noted in Section 1.8.5) from applicable design documents.
Test procedures include provisions for assuring that all prerequisites for the test have been met, that adequate test instrumentation is available and used, and that the test is performed under suitable environmental conditions. Test results are documented and evaluated to assure test requirements have been satisfied.
These measures require replacement or modified structures, systems and components to be subjected to sufficient proof, preoperational, and operational testing to demonstrate that they will perform satisfactorily in service.
t 1.8.12 CONTROL OF MEASURING AND TEST EQUIPMENT Controlled procedures and practices are established and documented to assure that tools, gauges, instruments, and other measuring and testing devices used in activities affecting quality are properly identified, controlled, calibrated, and adjusted at specific intervals to maintain accuracy within necessary limits. Calibration procedures specify standards to be used for performing the calibration.
Procedures require that standards used have 1.8-17 June 1992
s greater accuracy than the item being calibrated. These measures provide for identification of the equipment and associated records and appropriate corrective action when out-of-calibration conditions are noted.
1.8.13 HANDLING, STORAGE, AND SHIPPING Procedures and practices are established and documented to control the handling, storage, shipping, cleaning, and preservation of material and equipment by qualified individuals in accordance with work and inspection instructions to prevent damage or deterioration and preclude loss of identification. The measures include specification and use, when necessary, of special protective environments, such as inert gas atmosphere, specific moisture content, and temperature levels.
1.8.14 INSPECTION, TEST, AND OPERATING STATUS Procedures and practices are established and documented to indicate by suitable means, the status of inspections and tests to be performed upon individual items. These measures include provisions for the identification of items which have satisfactorily passed required inspections and tests when necessary to preclude inadvertent bypassing of such inspections and tests.
Procedural controls to perform operations out of sequence are established.
These measures also include provisions for indicating nonconforming, inoperative, or malfunctioning components within a system to prevent inadvertent operation.
1.8.15 NONCONFORMING MATERIALS, PARTS, OR COMPONENTS Procedures and practices are established and documented to control materials, parts and components, or quality activities which do not conform to established requirements. To prevent the inadvertent use or installation of purchased material, parts, or components, these measures may include timely return of nonconforming materials, parts, or components to the vendor for replacement with satisfactory items.
Formal nonconformance control systems are in place to assure control and disposition of nonconforming items or activities including adherence to 10CFR21 as necessary.
1.8-18 June 1992
b
' Maintenance Work Requests identify and control nonconforming items requiring j
repair or rework to be returned to satisfactory condition. Where a safety-j related component is required to be temporarily or permanently changed, such
{
l that it no longer complies with the original and approved design, such changes, with required approvals, are made via the approved modification l
l request procedure.
l j
The Nuclear Power Department has established provisions for. documenting and j
i dispositioning nonconforming items or conditions, which are identified during inspection, surveillance or auditing activities.
l 3_
4 1
j 1.8.16 CORRECTIVE ACTION' j
a 2
Procedures and practices are established and documented to assure that conditions adverse to quality; such as failures, malfunctions, deficiencies, deviations, defective material, and equipment and nonconformances; are I
i promptly identified and corrected.
In the case of significant conditions f
adverse to quality, these measures include assurance that the cause of the i
condition is determined and corrective action taken to preclude recurrence.
These include provisions for identification of the significant condition f
adverse to quality, the cause of the condition and the coi tive action taken-j which is documented and reported to appropriate levels of management.
l Provisions are included for followup reviews to verify proper. implementation j
of corrective actions and to close out the corrective action documentation.
j 1.8.17 QUALITY ASSURANCE RECORDS i
Procedures and practices are established and documented to assure that sufficient records are generated and maintained to furnish evidence of activities affecting quality. Where practicable, the guidelines of ANSI N45.2.9-1974 apply. The records consist-of at least operating logs and the results of reviews, inspections, tests, monitoring, work-performance, and materials analyses. Also included are closely related data such as qualifica-tions of personnel, procedures and equipment.
Inspection and test records include, as a minimum, identity of the inspector or data recorder, the type of observation, the results and the acceptability, or action taken in connection with'any deficiencies noted. Records are identifiable and retrievable.
1.8-19 June 1992
-. a
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' Requirements concerning records retention, such as duration, location, and assigned responsibility, are established to be consistent with applicable regulatory requirements. Radiographs, with the exception of those associated with ASME Section XI components or systems (to be retained for the service life of the component or systems), are retained as non-permanent records for a minimum of ten years after the date of the radiograph.
In either case, associated radiographic review records are permanently retained and provide necessary weld quality / acceptance information.
l In 1971, Wisconsin Electric recognized the need to improve its records manage-ment program in the area of preservation of records.for Point Beach.
In the absence of any guidance in the form of regulatory guides or national stan-dards, it was decided to generally follow the requirements of NFPA 232-1970.
i The requirements of NFPA 232-1970 were reviewed in light of importance of the records being stored and the risk of destruction of the records.
It was determined that the records being stored required positive protection as many were irreplaceable.
Possible locations for records storage facility were j
studied, and it was determined that the lower level of the Point Beach Energy l
Center located on the plant grounds, offered an ideal location for a records j
storage facility.
f This location was chosen since it was an area of minimum weight of combusti-j bles and the building itself was fire resistant.
It was determined, based on l
l the above factors, that a separate room would be constructed in the lower j
level of the Point Beach Energy Center to provide further protection.
The room was built to meet Wisconsin Administrative Code requirements for four-hour construction, and was treated to minimize the risk of water infiltration.
In addition, the room was equipped with an inert gas fire suppression system which is automatically' triggered by smoke or heat.
Triggering of the fire suppression system also activates an alarm signal and a visible alarm which can be observed from a continuously manned guard station.
1.8-20 June-1992 B
1 Based ~on the analysis of the fire hazard present in the Point Beach Energy Center, the alarm system, and the sophisticated fire suppression system, it was decided that the requirement for a four-hour vault door was unnecessary.
The entrance to the room is closed with a Class A 250*F labeled fire door.
In addition, the fire suppression system required an electrical supply, which led to the waiving of the requirement that walls could not be penetrated by electrical conduit. The electrical supply for room is brought into the room via a conduit through one of the walls and ceiling which has been installed to minimize the risk of fire passing through the wall via this penetration.
1.8.18 AUDITS Procedures and practices have been established and documented to provide a comprehensive system of planned and periodic audits to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program.
Audits are performed in accordance with written procedures or checklists by appropriately trained personnel not having direct responsibilities in the areas being audited. The QA program is audited periodically, by the QA Section. The QA Section also performs audits under the cognizance of the Off-Site Review Committee as required by PBNP Technical Specification 15.6.
On-site and off-site contractor audits are scheduled commensurate with the work's importance to plant safety and reliability and are timed as appropriate for the work scheduled.
Where practical, audits are conducted using performance-based techniques.
As an example, periodic operational readiness assessments of safety-related plant systems may be conducted using vertical-slice audit techniques.
Audit results are documented and reviewed by management personnel having responsibility in the area audited. Audit reports are routed to management responsible for correcting any unsatisfactory items noted.
Follow-up action, including reaudit of deficient areas, is taken when indicated. When follow-up
)
audits reveal repetitive occurrences which reflect possible trends adverse to the effectiveness of the QA program, these results are reported to the appropriate management level to effect corrective action.
1.8-21 June 1992 l
4
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f j
' Sufficient audits are performed, by the QA Section, in accordance with the j-provisions of ANSI N45.2.12 to meet the requirements of Section 4.5 of ANSI N18.7-1976. Also, internal audits performed by the QA Section are led by.
I individuals certified as Lead Auditors in accordance with the requirements of I
It should be noted that Section 3.2 of ANSI N18.7-1976 l
4 l
}
recognizes that quality assurance is an interdisciplinary function and that advantages may accrue from having reviews of. certain plant functions performed by individuals other than quality assurance personnel. WE strongly endorses this position. Typically, the QA Section assigns technically competent quality assurance personnel to perform audits, however when necessary, QA i
personnel are supplemented with other technically qualified WE and/or
)
contractor personnel. Audits are sometimes supplemented by surveillances of f
quality related activities. Surveillances are performed by. qualified t
individuals, although not necessarily certified as lead auditors.
In j
addition, certain review functions may be assigned to technically qualified individuals in lieu of quality assurance personnel.
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- l 1
)
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1.8-22 June 1993
TABLE 1.8-1 COMMITMENT TO REGULATORY GUIDES AND ANSI STANDARDS t
1.
Regulatory Guide 1.8 (Safety Guide 8) dated March 10, 1971 Full commitment except that Wisconsin Electric commits to ANSI N18.1-1971 in lieu of the proposed ANSI N18.1 dated June 22, 1970.
2.
Regulatory Guide 1.28 (Safety Guide 28) dated June 7, 1972 ANSI N18.7-1976 states in part, "This standard fully and completely describes the general requirements and guidelines of ANSI N45.2-1971 as those requirements, and guidelines apply during the operational phase of plant life."
As such, commitment to ANSI N18.7-1976 for Point Beach obviates the need to commit to Regulatory Guide 1.28 which endorses ANSI N45.2-1971.
t Wisconsin Electric does,
- however, commit to the position of Regulatory Guide 1.28 to the extent of requiring its vendors to have quality assurance programs which meet the appropriate requirements of ANSI N45.2-1971 as mentioned in Section 5.2.13.1 of ANSI N18.7-1976.
3Property "ANSI code" (as page type) with input value "ANSI N18.7-1976.</br></br>3" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
Regulatory Guide 1.30 (Safety Guide 30) dated August 11, 1972 Commitment to follow the position of Regulatory Guide 1.30, which j
i endorses and supplements ANSI N45.2.4-1972, for activities occurring during the operational phase that are comparable in nature and extent to related activities during construction.
June 1992
i I
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l TABLE 1.8-1 (Continued) l l
4.
Regulatory Guide 1.37 dated March'16, 1973 t
Commitment to follow the position of Regulatory Guide 1.37, which f
endorses and supplements ANSI N45.2.1-1973, for activities occurring j
during the operational phase 'that are comparable in nature and l
I extent to related activities occurring during construction.
5.
Regulatory Guide 1.38, Revision 1, dated October 1976 l
Commitment to follow the position of Regulatory Guide 1.38, which l
endorses and supplements ANSI N45.2.2-1972, for activities occurring j
during the operational phase that are comparable in nature and j
extent to related activities occurring during construction.
6.
Regulatory Guide 1.39, Revision 1,. dated October 1976 f
Commitment to follow the position of Regulatory Guide 1.39, which endorses and supplements ANSI N45.2.3-1973, for activities occurring-l f
during the operational - phase that are comparable in nature and extent to related activities occurring during construction except
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that Wisconsin Electric does not commit to the documentation f
requirements of ANSI N45.2.3-1973 and provides an alternative to the j
housekeeping zone requirements therein.
Descriptions of these differences are provided in Section 1.8.2.
[
t 7.
Regulatory Guide 1.54 dated June 1973 l
Commitment to follow the position of Regulatory Guide '1.54, which endorses and supplements ANSI N101.4-1972, for activities occurring during the operational phase that are comparable in nature and extent to related activities occurring during construction.
June 1992 l
)
l
?
TABLE 1.8-1 (Continued) 8.
Regulatory Guide 1.58 dated August 1973 Commitment to follow the position of Regulatory Guide 1.58, which endorses and supplements ANSI N45.2.6-1973, for activities occurring in the operational phase that are comparable in nature and extent to l
related activities during construction, except that Wisconsin Electric does not commit to the levels of qualification nor separate certification requirements of ANSI N45.2.6-1973.
Descriptions of these differences are provided in Section 1.8.10.
9.
Regulatory Guide 1.64 dated October 1973 Commitment to follow the position of Regulatory Guide 1.64, except i
that Wisconsin Electric commits to ANSI N45.2.ll-1974 in lieu of Draft 3 Rev. I dated July 1973, for design activities associated with modification of safety-related structures, systems and components.
- 10. Regulatory Guide 1.74 dated February 1974 Full commitment.
l
- 11. Regulatory Guide 1.88, Revision 1, dated December 1975 l
Commitment to follow the position of Regulatory Guide 1.88, which endorses and supplements ANSI N45.2.9-1974 and NFPA 232-1970.
i Wisconsin Electric has determined that the existing records storage-facility provides a level of protection to the vital records at the plant which is equivalent to the requirements of Regulatory 1
Guide 1.88.
Description of the differences are provided in Section 1.8.17.
The Point Beach policy for the retention of radiographs and associated review records is outlined in l
Section 1.8.17.
l June 1992
TABLE 1.8-1 (Continued) l
- 12. Regulatory Guide 1.94 dated April 1976 i
Commitment to follow the position of Regulatory Guide 1.94, which endorses and supplements ANSI N45.2.5-1974, for activities occurring during the operational phase that are comparable in nature and extent to related activities occurring during construction.
- 13. Regulatory Guide 1.146 dated August 1980.
Commitment to follow the position of Regulatory Guide 1.146, which endorses ANSI N45.2.23, for internal audits performed by the Quality Assurance Section (QAS).
l i
- 14. ANSI 18.7-1976 b
I Refer to Section 1.8-.0 for details of the Wisconsin Electric i
l commitment.
l i
i l
i i
I June 1992
i i
I TABLE 1.8-2 l
l SUBSECTIONS OF SECTION 1.8 APPLICABLE TO THE FIRE i
PROTECTION PROGRAM l
l l
Suttiect Subsection t
t t
I Administrative and Organizational 1.8.1, 1.8.2 f
l Design and Procurement Document Controls 1.8.3, 1.8.4 l
Instructions, Procedures and Drawings 1.8.5 i
Document Control 1.8.6
[
Control of Purchased Materials, 1.8.7, 1.8.10 r
i Equipment and Services l
(
Inspection 1.8.10 j
Test and Test Control 1 8.11 l
i l
Inspection, Test and Operating Status 1.8.14 i
1 Nonconforming Items 1.8.15 i
l Corrective Action 1.8.16 Records 1.8.17 Audits 1.8.1, 1.8.18 June 1992 i
i l
i TABLE 1.8-3 l
SUBSECTIONS OF SECTION 1.8 APPLICABLE TO SHIPPING l
PACKAGES FOR RADI0 ACTIVE MATERIALS (10 CFR 71. SUBPART H)
I Sub.iect Subsection Organization 1.8.1 r
Quality Assurance Program 1.8.2 Design Control
- not applicable l
Procurement Document Control 1.8.4 Instructions, Procedures and Drawings 1.8.5 l
Document Control 1.8.6 l
Control of Purchased Material, 1.8.7 Equipment and Services l
Identification and Control of 1.8.8 Materials, Parts and Components l
Control of Special Processes 1.8.9 l
Inspection 1.8.10 Test Control
- not applicable Control of Measuring and Test Equipment 1.8.12 Handling, Storage and Shipping 1.8.13 Inspection, Test and Operating Status 1.8.14 Nonconforming Materials, Parts or Components 1.8.15 Corrective Action 1.8.16 Quality Assurance Records 1.8.17 Audits 1.8.18 Design and testing control are activities which are not normally performed by Point Beach Nuclear Plant personnel.
However, these l
activities are imposed on suppliers providing radioactive material packaging or associated services, as appropriate.
June 1992 l
l
i i
TABLE 1.8-4 SUBSECTIONS OF SECTION 1.8 APPLICABLE TO STATION BLACK 0UT (IOCFR 50.63)
I i
Sub_iect Subsection i
Administrative and Organizational 1.8.1, 1.8.2 l
i Design and Procurement Document Controls 1.8.3, 1.8.4 Instructions, Procedures and Drawings 1.8.5 Document Control 1.8.6 Control of Purchased Materials, 1.8.7, 1.8.10 Equipment and Services Inspection 1.8.10 Test and Test Control 1.8.11 Inspection, Test and Operating Status 1.8.14 Nonconforming Items 1.8.15 4
Corrective Action 1.8.16 Records 1.8.17 Audits 1.8.1, 1.8.18
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i June 1992 i
t!SCONSIN ELECTRIC PDnER COMPRNY ORGRNI?R110NS DITH QURL11Y RSSURANCE l
INTERFRCE 10 POINT BERCH NUCLERR PLRNT l
CHRIRMAN OF THE B3443 PRESIDENT l
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OFF-SITE RE VIEW COMMITTEE I
t VICE PRESIDENT SENIOR VICE I
L PRESIDENT GENERAL COUNSEL i
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DIRECTOR VICE VICE RSSISTANT ENGINEERING &
PRESIDENT PRESIDENT vlCE CONSTRUCTION NUCLERR PDWER SYSTEM PRESIDENT TRERSURER DEPARTMENT DEPARTMEN1 OPERR110NS HUMAN DEPRRTMENT RESOURCES (SEE FIG 1 0-2) l
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DIRECTOR DIRECTOR MRTERIRLS &
ENVIRONMENTRL SERVICES DEPARTMENT DEPRRTMENT I
h MR*AGER LRB MANRGER RISK SERvlCES MANRGEMENT DIVISIDN CORPORRTE FIRE SECURITY PROTECTION' 0FFICER DFFICER FIGURE 1 0-1 MARCH 1993 i
o NJCLERR PCEER DEPRRTMENT ORGRNIZATION I
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t VICE PRESIDENT t
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I tfJCLERR PLANNING.
INDUSTRY &
DURLITY ASSURANCE N'JCLEAR OPERRT}DNS NUCLERR ENGINEERING SYSTEMS & SUPPORT RELJLATORY SERVICES 1
SECT]DN SECTION SECTION SECTION SECTION MRNRGER MRNRGER MRNRGER MRNRGER MRNRGER I
(See Fsgure 1.S-3) l l
Figure 1 0-2 MARCH 199?
i
OURLITY RSSURRNCE SECTION ORGANIZRTIDN l
i i
t DURLITY ASSURRNCE SECTION i
MANRGER i
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00RL1TY QURLITY TECHNICRL i
SITE 09 DURLITY SUPPDRT VERIFICATION SERVICES j
QURLITY ENGINEER PROJECT ENGINEER SR. PROJECT SR. PROJECT ENGINEER ENGINEER i
J i
l SUPPLIER RSSESS-.
INTERNRL RSSESSMENT FOSS!L SUPPORT j
PROJECT ENGINEER PROJECT ENGINEER PROJECT ENGINEER i
QUALITY RESURRNCE DURLITY RSSURANCE OURLITY RSSURANCE QUALITY RSSURRNCE ENG/ SPEC ENG/ SPEC ENG/ SPEC ENG/ SPEC 1
Fsgare 1 0-3 MARCH 1993
,