ML20039A147

QA Program for Nuclear Power Plants,Revision 3A,topical Rept

ML20039A147
Person / Time
Site:	South Texas
Issue date:	10/31/1980
From:	Bechtel S BECHTEL GROUP, INC.
To:
Shared Package
ML20039A142	List: ML20039A141 ML20039A147
References
BQ-TOP-1, NUDOCS 8112160274
Download: ML20039A147 (141)

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{{#Wiki_filter:- - _ - -. 1 .t TOPICAL REPORT BQ-TOP-1 BECHTEL QUALITY ASSURANCE PROGRAM FOR NUCLEAR POWER PLANTS REV. 3A i i O BO TOP 1 DRkDOKO!$dhd9h-Tb8ER 1980 PDR

FOREWORD AND QUALITY POLICY STATEMENT This report establishes the Quality Assurance Program requirements for work performed by or for Bechtel on Nuclear Power Plants designed and/or constructed in accordance with the requirements of the Nuclear Regulatory Commission Regulation 10CFR50, Appendix B, Quality Assur-ance Criteria for Nuclear Power Plants. The program defined in this report shall be followed by all Bechtel entities for nuclear power pro-jects referencing this report in license applications. The President of Bechtel Power Corporation is authorized to issue revisions to this report and instructions for implementing the program. f-m' S. D. Bechtel, Jr. BO TOP 1 REV.3A OCTOBER 1980

p' [, _g !- [ ABSTRACT This coEument describe's the Bechtel Quality Assurance Program plan . for use - by the Bechtel organization during the design, procurement, and construction of nuclear. power plants. This Program plan meets the requirements of 'the Nuclear-Regulatory Commission Regulation 10 CFR - 50, Appendix B. h l l I l t BQ-TOP. Rev. ' 3 A li October 1980

CAVEAT:.THIS REPORT HAS BEEN PREPARED BY AND FOR THE USE OF BECHTEL' POWER CORPORATION AND ITS RELATED ENTITIES. NO ' WARRANTIES EXPRESS OR IMPLIED ARE MADE, AND NO LEGAL LIABILITY OR RESPONSIBILITY IS ASSUMED FOR THE ACCURACY, COMPLETENESS, OR USE-FULNESS OF THE INFORMATION OR CONCLUSIONS CON-TAINED HEREIN. 1 BQ-TOP-1 Rev. 3A lii October 1980

l' j. e 8 CONTENTS PAGE L INTRODUCTION SECTION 1 1 ORGANIZATION 6 1.1 BECHTEL ORGANIZATION 6 1.2 THERMAL POWER ORGANIZATION 6 1.3 PROCUREMENT 7 1.4 MATERIALS AND QUALITY SERVICES 8 1.5 POWER DIVISIONS 9 1.5.1 Management 10 1.5.2 Quality Assurance 10 1.5.3 Engineering 11 1.5.4 Division Construction 11 .1.5.5 Division Project Operations 12 1.5.6 Division Procurement 12 1.6 PROJECT ORGANIZATION AND FUNCTIONS 13 1.6.1 Project Quality Assurance 13 1.6.2 Project Engineering 1.6.3 Project Construction 14 1.6.4 Project Procurement 16 17 2 QUALITY ASSURANCE PROGRAM 19 2.1 SCOPE 2.2 POLICY 19 2.3 STOPWORK 19 21 2.4 PROGRAM DOCUMENTATION 2.5 PERSONNEL 22 2.6 PROGRAM CONTROL 22 24 -2.7 PROGRAM EVALUATION 2.8 MANAGEMENT REVIEW 24 25 2.9 PREOPERATIONAL TESTING AND PLANT TURNOVER 1 26 3 DESIGN CONTROL 27 4 PROCUREMENT DOCUMENT CONTROL 31 5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS 34 6 DOCUMENT CONTROL 35 7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT' 37 AND SERVICES BQ-TOP-1 Rev. 3A iv October 1980 l.

}: f. CONTENTS (Cont'd) PAGE -7.1 SUPPLIER EVALUATION AND SELECTION 37 7.2 SURVEILLANCE INSPECTION 38 7.3 RECEIVING INSPECTION 40 I -7.4 SUPPLIER AUDITS 42 8 IDENTIFICATION AND CONTROL OF MATERIALS, 43 PARTS, AND COMPONENTS 9 CONTROL OF SPECIAL PROCESSES 44 10 INSPECTION 45 11 TES'I CO8 TROL. 47 12 CONTROL OF MEASURING AND TEST EQUIPMENT 48 13 11ANDLING, STORAGE, AND SHIPPING 49 14 INSPECTION, TEST, AND OPERATING STATUS 50 15 NONCONFORMING ITEMS 51 16 CORRECTIVE ACTION 53 17 - QUALITY ASSURANCE RECORDS 54 18 AUDITS 55 LIST OF TABLES TABLE I BECHTEL QUALITY PROGRAM DOCUMENTS .57 l I BQ-TOP-1 1 Rev. 3A-v October 1980

LIST OF FIGURES AND APPENDICES FIGURES FIGURE PAGE 1 THE BECHTEL ORGANIZATION 59 2 THERMAL POWER ORGANIZATION 60 3 PROCUREMENT-61 4 SUPPLIER QUALITT ORGANIZATION 62 5 MATERIALS & QUALITY SERVICES SUPPORTIVE 63 l TO THE THERMAL POWER ORGANIZATION 6 SAN FRANCISCO POWER DIVISION 64 7 LOS ANGELES POWER DIVISION 65 j 8 GAITHERSBURG POWER DIVISION 66 9 PROJECT TEAM ORGANIZATION (TYPICAL) 67 { 10 PROJECT ENGINEERING ORGANIZATION (TYPICAL) 68 11 PROJECT CONSTRUCTION ORGANIZATION (TYPICAL) 69 12 DIVISION QUALITY ASSURANCE ORGANIZATION (TYPICAL) 70 13 QUALITY PROGRAM DOCUMENTS 71 14 TYPICAL POWER DIVISION PROCUREMENT 72 ORG"' !ZATION I APPENDICES APPENDIX A BECHTEL POSITION ON QA NRC REGULATORYA-1 GUIDES AND ANSI STANDARDS APPENDIX B DIVISION QUALITY POLICIES SCOPE AND RELA-TIONSHIP TO 10 CPR 50, APPENDIX B B-1 BQ-TOP-1 Rev. 3A vi October 1980

CONFIGURATION CONTROL This list contains the date and revision number for each page in this Topical Report and will be revised when changes are made. Page Rev. No. Rev. Date Page Rev. No. Rev. Date i 3A October 1980 33 3A October 1980 ii 3A October 1980 34 3A October 1980 ill 3A October 1980 35 3A October 1980 iv 3A October 1980 36 3A October 1980 v 3A October 1980 37 3A October 1980 vi 3A October 1980 38 3A October 1980 vil 3A October 1980 39 3A October 1980 viii 3A October 1980 40 3A October 1980 1 3A October 1980 41 3A October 1980 2 3A October 1980 42 3A October 1980 3 3A October 1980 43 3A October 1980 4 3A October 1980 44 3A October 1980 5 3A October 1980 45 3A October 1980 6 3A October 1980 46 3A October 1980 7 3A October 1980 47 3A October 1980 8 3A October 1980 48 3A October 1980 9 3A October 1980 49 3A October 1980 10 3A October 1980 50 3A October 1980 11 3A October 1980 51 3A October 1980 12 3A October 1980 52 3A October 1980 13 3A October 1980 53 3A October 1980 14 3A October 1980 54 3A October 1980 15 3A October 1980 55 3A October 1980 16 3A October 1980 56 3A October 1980 17 3A October 1980 57 3A October 1980 18 3A October 1980 58 3A October 1980 19 3A October 1980 59 3A October 1980 20 3A October 1980 60 3A October 1980 21 3A October 1980 61 3A October 1980 22 3A October 1980 62 3A October 1980 23 3A October 1980 63 3A October 1980 24 3A October 1980 64 3A October 1980 25 3A October 1980 65 3A October 1980 26 3A October 1980 66 3A October 1980 27 3A October 1980 67 3A October 1980 28 3A October 1980 68 3A October 1980 29 3A October 1980 69 3A October 1980 30 3A October 1980 70 3A October 1980 31 3A October 1980 71 3A October 1980 l 32 3A October 1980 72 3A October 1980 vii BQ-TOP-1 Rev. 3A October 1980

CONFIGURATION CONTROL (Cont'd) Page Rev. No. Rev. Date Page Rev. No. Rev. Date A-1 3A October 1980 A-15 3A October 1980 A-2 3A October 1980 A-16 3A October 1980 A-3 3A October 1980 A-17 3A October 1980 A 3A-October 1980 A-18 3A October 1980 A-5 3A October 1980 A-19 3A October 1980 A-6 3A October 1980 A-20 3A October 1980 A-7 3A October 1980 A-21 3A October 1980 A-8 3A October 1980 A-22 3A October 1980 A-9 3A October 1980 A-23 3A October 1980 A-10 3A October 1980 B-1 3A October 1980 A-11 3A October 1980 B-2 3A October 1980 A-12 3A October 1980 B-3 3A October 1980 A-13 3A October 1980 B-4 3A October 1980 A-14 3A October 1980 viii BQ-TOP-1 Rev. 3A October 1980

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.a ;. e.,lru.a.ua ityn.. Ass.ur;anqe ; nM-vD nei b"- .Thi,s'.. report..d. : 3 ofgan.ir.r.pf,t. applie,d 'lpy .a escribes....the dgsign, procu@rerne Bech.tel* tp the,jg' port.is inte'nddd.nt...and.construc nuclear. power (Thip.a t'o. 41srits. , safely analysis. reports,_. and,' (dr..gWerye as3'giafd]reTerence.for t .jdentification of ',xhe. Rechth!.scbpe '6f der.p.ecifg project,, req.uires, only a s a t vaces, an'd Elistlof~the-mantials l ' Chapter'.17 prescribed in the " Stand' ar;.d.'. Forma,1fl11,3h' Isi;iu'iremE ,froni., Table.1E applicable tp. fhe',, pidfect to 'fii t and ontent'of. Safe'ty Analysis"R6 ports"for Nuclear Power' Plants" arid'.Regd tory Guide J.70, Rev. 2, September 1975, " Additional Informafion blity ' Assurance .During., Design and Construction ".Tha. entire, ument.will.be reviewed l s . annually,ind-l revised,as necessaryT.Jndiv'idd

hdfdl cbples ;of' as. indica,ted on. a control,le(. copy.4, jiitipg@.1,igt. will rec,.,this eive yreport c

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.m. 97.. ..,.c o y. The Quality Assurance Program clescribed fri' this' 'rd' or, t '.is -consstent p with the Bechtel overall goals and objec:ives of maintaining 'the compe-tence.of its, service and the qualityppf.jts.end.prgducts atacontractyally required' levels. This ' Quality ' Assurance. goc,Jr,amjsja'ppli d b'y Bechtel to those safety-related structures, systems,' and, components TQ' Lfst citeras) jdentified 1.n appropriate.;sectiony gf othe safrety.-analypip3re. port u ( for -mhich :.Bechtel ;has...the responsibilityL.for lle' sign, procuremelit, and/or construction (or construqtion mali #g"ement). The report does not cover preoperational testing activities. . hNe te'rm '" Quality. Assurance hkSeehIqhhed as "ali tho'se planrie'dbr

systematic. actions neces.sary to : provide adaquate confidence that an item or facility will perform 5atisfactorily. in ge.gice."

Quality assurance is recognized as a function of the group performing the work and not the . sole responsibility of a qpality, assurance,gypup. - ,y .s,.,, Quality is acitieved throlighi the,..usieM/ Milled personnel, adequate planning, use of suitable tools and procedures, proper definition of job requirements,.and approprdate.:supervisiop and., technical,directi,on. Quality is verified through surveillance,,t.An,spection, testing', clieckin', ~ g and review.of-work activities arid doqmitentation. It is Bechtel policy that the organization orf Tjroup that iperforms the activity (i.e., Engi-neering, Procurement, Construction, etc.) is responsible for the gener-r,ation.of a:, quality product, s. Quality-controjr and quality.ver.ificAtion..are performed by individuals..who>ahe.-not,direc;tly responsible for perform-ing the work activity. The separation of responsibilities by organiza-- tion for performance of the work activities and for performance of quality control and quality verification is discussed in Section 1 of this -report.

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• The term Bechtel. is < employed in.4}iiMrepDr.t to; identify Jhe,Ee,qh,tel Power Corporation and associated companies which may be contractually responsible for all or part of a project.

- N. BQ-TOP-1 Rev. 3A I; October 1980 O'- r

Regulatory Guide 1.58 "Qu:lification of Nucletr Power Plant Inspec-tion, Examination and Testing - Personnel (Au-gust 1973)" Regulatory Guide 1.64 Quality Assurance Requirements for the De-sign of. Nuclear. Power Plants, (Rev 2, June 1976)" Regulatory Guide 1.74 " Quality Assurance Terms and Definitions - (February 1974)" Regulatory Guide 1.88 " Collection,

Storage, and Maintenance.of Nuclear Power Plant Quality Assurance Records (Rev. 2, October 1976)"

Regulatory Guide 1.94 " Quality Assurance Requirements for' Installa-tion, Inspection, and Testing of Structural. Concrete and ' Structural Steel During the Construction Phase of Nuclear Power Plants (Rev.1,~ April 1976)" Regulatory Guide 1.116 " Quality Assurance Requirements for Instal-lation, Inspection and Testing of Mechanical Equipment and Systems (June 1976)" Regulatory Guide 1.123 " Quality Assurance Requirements for Control of Procurement of items and Services for Nuclear Power Plants (October 1976)" ANSI Standard " Requirements for Auditing of Quality As-N45.2.12-1974 surance Programs for Nuclear Power Plants. (Draft 3, Rev. 4, February 22, 1974)" The terms used. in this report follow the definitions provided in ANSI N45.2.10-1973, " Quality Assurance Terms and Definitions," supplemen-ted by the following additional terms and definitions applicable to this report. 1. Administrative Direction (Administrative Supervision): Responsibility for hiring, salary review, and assignment of an individual. 2. Approve: When used in context with Bechtel review of supplier documents, the word " approve" or words of like import, such as " review" and " accept", shall mean, unless - the context clearly indicates otherwise, that the supplier shall, -before ' implementing the information in the document, submit -the document, obtain resolution of any comments, and obtain authorization to proceed, and shall not mean that a complete check will be performed. Authorization to proceed shall not constitute acceptance or approval of design details, calculations, analyses, test methods or materials ' developed or selected by the supplier and shall not relieve supplier from full compliance with contractual obligations. BQ-TOP-1 Rev. 3A 3 October 1980

14. Review:

Examination of any form of documentation for the purpose of establishing acceptability to the requirements of the function represented by the reviewer. Reviews may range from a thorough investigation to a spot check. Reviews are generally not holdpoints, but signoff evidence of review on the documents or records traceable to the documents is required.

15. Subcontractor:

Supplier of ' construction site services, materials, or equipment. On construction management jobs, contractors under direct contract to the client may provide construction site services.

16. Surveillance:

A broad term pertaining to and including both monitoring and witnessing.

17. Surveillance Inspection:

Review, observation, or inspec-tion of supplier personnel, material, equipment, processes, and test results at random or selected stages of manufac-ture for the purpose of determining if an action has been accomplished or a document (s) prepared in accordance with selected requirements of a contract document (s). Surveil-lance inspection does not take the place of supplier quality programs or assume any responsibility for such programs or product quality. Surveillance inspection is intended to f provide a degree of added confidence that supplier materi-als and equipment meet specific contract requirements. Such inspections will not relieve the supplier or construc-tion contractor of any responsibilities under the applicable contract, or act as waiver by Bechtel or Client of any of the conditions thereof. For additional information, see Section 7, subsection 7.2, l SURVEILLANCE INSPECTION.

18. Technical Direction:

Instructions and directions defining technical requirements for an activity. This may include furnishing prescribed procedures, technical requirements, design approaches, specifications, and design details.

19. Technical Guidance:

Providing advice representing a preferred method or approach to a function or activity. This may include establishing general requirements or policy but not specific procedures or instructions.

20. Witness:

To watch over, observe, or examine a specific test or work operation which includes signoff responsi-bility. Whenever an approved ANSI Standard or Draft (or portion thereof) is referenced herein without qualification, all requirements of the Standard as interpreted by Bechtel Quality Assurance management must be incor-parated in the program subject to the modifications in Appendix A of this report or in individual SARs. BQ-TOP-1 Rev. 3A 5 October 1980

~, a SECTION 1 (17.1.1) ORGANIZATION 1.1 BECHTEL ORGANIZATION Figure 1 provides an - organization chart for the Bechtel Organization. Nuclear power plant - work is performed by Bechtel through Bechtel Power Corporation (Thermal Power Organization) which includes the i three power divisions. The Thermal Power Organization is managed by the President of Bechtel Power Corporation. 1.2 THERMAL POWER ORGANIZATION (BECHTEL POWER COR-PORATION) Figure 2 provides_ more detailed definition of the Thermal Power Orga-nization. The Thermal Power Organization consists of a general management group l (Thermal Power Management) and three operating divisions: Gaithers-burg Power Division, Los Angeles Power Division, and San Francisco Power Division. Thermal Power Management, consisting of the President, Vice President, and a staff, establishes policy and is responsible for providing effective and close communication among the Power Divisions. A Sponsoring ( Corporate Officer is designated for each of the staff functions. The Sponsoring Corporate Officer for Quality Assurance is the Vice Presi-dent, Planning and Quality Assurance. The following are the primary responsibilities of the Sponsoring Officer for Quality Assurance: 1 i o

Develops, reviews, and approves new or revised TPO quality policy.

o Provides guidance on quality policy across the divisions (including coordination of quality functions of external l organizations, such as M&QS and Procurement). o Evaluates the effectiveness of the Divisions Quality Assur-ance programs and reports annually on the adequacy of the implementation of the quality programs to the President of Bechtel Power Corporation. The sponsoring officer for QA has staff support, as required, to assist him in carrying out these responsibilites. The quality policy statement for the Thermal Power Organization, in-cluding the progr_am described by this Topical Report, is authorized (approved for use) by the President of Bechtel Power Corporation. The staff of the Thermal Power Management supports and assists the President in carrying out his responsibilities. BQ-TOP-1 Rev. 3A 6 October 1980

The Division Procurement Manager assigned to a Thermal Power Organi-

zation Division is responsible for procurement of equipment, materials, and services for projects within that Division.

He reports to the re-spective Manager of Procurement TPO for technical guidance as shown l In figure 3. He receives administrative direction from the management l of his Division, as shown on figures 6, 7, and 8. As shown in. Figure 4, the Division Supplier Quality Managers receive l technical direction from the Manager of Procurement Supplier Quality. Administrative direction is the responsibility of the Division Procurement Manager, as shown on Figure 14. The following activities are the l responsibility of the Manager of Procurement Supplier Quality and are accomplished with the assistance of the Supplier Quality Managers in each of the Division offices:

1) Prepare, maintain, and implement the Procurement Supplier Quality Department Manual

2) Prepare the training and development program; train and qualify Procurement Supplier Quality personnel

3) Perform surveys and quality program audits at suppliers and offsite subcontractors as required by project and division procedures

4) Prepare and implement inspection plans

5) Provide qualified personnel and perform surveillance in-I spection of items; review quality verification documents and release items for shipment

6) Review supplier QA program

7) Coordinate Procurement Supplier Quality Department activ-ities with other quality functions

8) Monitor the adequacy of inspection plans and procedures in l

use by Supplier Quality personnel-1.4 MATERIALS AND QUALITY SERVICES The Materials and Quality Services Department (M&QS) is responsible for furnishing specialized metallurgical, quality control, and auditing services to Bechtel divisions. Figure 5 illustrates the organization of I the Materials and Quality Services Department. M&QS responsibilities are:

1) To develop and qualify welding and nondestructive exami-nation (NDE) procedures l

2) To qualify and certify Bechtel nondestructive examination personnel BQ-TOP-1 Rev. 3A 8

October 1980

E 1.5.1 Management Each division management organization is uniquely suited to the nature of-division activities and the functions directly associated with the of fice. The typical division management team includes the Division Manager, Manager of Project Operations, Manager of Engineering, -Manager of Construction, Manager of Procurement, Manager of Services, ' Manager of Business Development, and the Quality Assurance Manager. Each of these managers has the direct responsibility and authority for the functions of his department or group. 1.5.2 Quality Assurance Quality Assurance Managers provide technical and administrative direc-tion to the Quality Assurance Group within the division. A typical Division Quality Assurance Organization is shown in Figure 12. Each l Quality Assurance Manager is responsible for: '1) Formulating Division Quality Assurance Policies where necessary to implement or supplement quality policy pre-l scribed by the Thermal Power Organization l

2) Approving quality assurance procedures and instructions which define responsibilities and functions of quality assurance personnel within his division

3) Approving quality-related procedures and manuals pre-pared by departments and projects within his division for conformance to quality assurance policies

4) Formulating audit programs and conducting audits and reviews to assure Bechtel management and clients that the quality assurance programs of the division and its projects conform with policies and requirements of Bechtel and the client.

Identifying the need for corrective action and assuring follow-up

5) Providing periodic reports to the Division Manager and the Vice President, Planning and Quality Assurance - Thermal l

Power Organization, on the status and adequacy of division l and project programs and advising of any problems re-quiring special attention

6) Providing and maintaining a qualified and suitably trained staff of quality assurance engineers to carry out required project and staff functions

7) Formulating programs for maintaining the professional competence of personnel within his organization and provid-ing assistance in training and Indoctrination programs 'for division management, engineering, and construction per-sonnel whose activities affect quality BQ-TOP-1 Rev. 3A 10 October 1980

Pormal quality verification inspection and onsite subcontractor / con-tractor surveillance-inspection activities performed by Bechtel are the responsibility of Construction Quality Control. The Chief Construction Quality Control Engineer supervises the construction quality verification program and is responsible for administrative and technical direction of the Construction Quality Control Engineers. Chief Construction Quality Control Engineers:

1) Prepare and maintain. standard construction quality control procedures

2) Approve project quality control procedures and instruc-tions

3) Hire and assign quality control engineers to the projects

4) Train and qualify quality control engineers

5) Provide technical and administrative direction to construc-tion quality control engineers 1.5.5 Division Project Operations A Project Manager is assigned to each power project.

(A project in-volving engineering only may not have a project manager.). Project Managers report to Manager of Project Operations, who provides admin-istrative and technical direction and assures the division's consistent and coordinated application of Bechtel policies and skills for the benefit of the project. 1.5.6 Division Procurement The Manager, Division Procurement, is responsible for Procurement activities performed for projects within the Power Division. The Project Procurement Manager and his staff are responsible for coordinating Procurement activities for the project, as described in subsection 1.6.4. l They receive technical and adminstrative direction from the Manager, Division Procurement, and project direction from the Project Manager. The Division Supplier Quality Manager receives adminstrative direction from the Manager, Division Procurement (requires review by the Min-ager of Procurement Supplier Quality) and technical direction from the Manager of Procurement Supplier Quality. The Division Supplier Qual-ity Manager assigns Project Supplier Quality Supervisors to division projects and provides them with technical and administrative directions and - coordinates with the Manager of Procurement Supplier Quality Department. Pigure 14 illustrates a typical division procurement organization. l BQ-TOP-1 Rev. 3A j 12 October 1980 ~

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9) Serve as the focal point for project communication on matters _ relating to the project quality assurance program

10) Provide periodic reports to the Division Quality Assurance Manager and Project Manager eva'uating the status of the project quality assurance program and advising of any problems requiring special attention

11) Coordinate quality assurance functions within the project and with groups outside the division, such as M&QS and Procurement Supplier Quality -

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12) Assure that quality assurance-related procedures and manuals prepared by or used for the project meet project quality program requirements and initiate revisions when necessary

13) Review, prior to use, Procurement Inspection plans and Quality Control instructions for clarity and the existence of the information described in Sections 7 and 10.

In addition, evaluate the adequacy of selected plans and instructions by performing an in-depth review of: a. Accuracy of translation of drawing and specification requirements b. Basis for determining inspection level and sequence - c. Adequacy of inspection method This review provides assurance that the total quality program requirement inclusions are complete. Reviews of plans and instructions can be performed on a generic basis. In that case, the PQAE only verifies that the review has been performed.

14) Prepare quality assurance descriptions in Safety Analysis Reports 1.6.2 Project Engineering The Project Engineer is responsible for the conduct of engineering on his project.

The Project Engineer may be assisted by one or more Assistant Project Engineers. The Project Engineer provides project direction to the Group Supervisors. He is responsible for ensuring that engineering work under Bechtel cognizance is carried out in accor-dance with the project direction received from the Bechtel Project Manager and the technical direction received from the Engineering Manager. BQ-TOP-1 i Rev. 3A i 14, October 1980 j j ? i /

1.6.3 Project Construction A Field Construction Manager is assigned to each nuclear plant project involving construction or construction management assignment, and he is responsible for the project field construction' performance. The Field Construction Manager is responsible for assuring that construction activities are performed in accordance with the design requirements as established by project engineering and other applicable requirements. A typical project construction organization is shown in Figure 11. l The project construction organization includes Superintendents who are in direct charge of the crafts (on projects for which Bechtel is assigned direct construction responsibility); Field Engineers who perform field engineering, provide technical guidance and monitoring of construction I work; field procurement personnel under the Senior Field Procurement Representative who are responsible for purchase of field-procured items and ' control of materials prior to release for construction; the Field Contracts Administrator who coordinates activities of field subcon-tractors; and Construction Quality Control Engineers (assigned by and administratively and technically responsible to the Chief Construction Quality Control Engineer) who are responsible for the Bechtel field quality control program, including performance of all quality verification inspection performed by Bechtel. Construction Quality Control activi-ties are coordinated by the Field Construction Manager. ( Field quality control is the responsibility of the Project Construction Quality Control Engineer. Construction Quality Control personnel are responsible for quality verification at the construction site. This includes physical inspection of construction performed directly by Bechtel and surveillance inspection on construction work performed by subcontractors (or contractors for construction management activities). Surveillance inspection by Bechtel Quality Control supplements the quality control program of the subcontractor and determines confor-mance to quality requirements. This surveillance inspection includes either selected physical inspections at prescribed hold points, or obser-vation and witness of inspections performed by subcontractors, quality control personnel, or both. Construction Quality Control Engineers:

1) Perform Bechtel jobsite quality verification inspection

2) Prepare Bechtel jobsite quality control documentation and maintain construction quality control records

3) Prepare and approve additions to division approved quality control procedures and instructions

4) Perform surveillance of subcontractor / contractor quality program implementation when~ the subcontractor / contractor has responsibility for first-level quality control.

BQ-TOP-1 Rev. 3A 16 October 1980 s. v. e. 2 ~, s

y w i Project Supplier Quayty Supervisors report to the Division Supplier V Quality Manager for technical and administrative direction. The func-tions of the Project Supplier Quality Supervisors are:

1) Coordinate project procurement - surveillance' inspection activities with project engineering and Procurement Suppli-er Quality

2) Comment on technical specifications prior to issuance for bids

3) Initiate supplier surveys, Supplier. Quality assignments, and coordinate supplier audits with Procurement Supplier Quality

4) Review and accept procurement surveillance inspection reports

5) Give project direction on project Supplier-Quality assign-ments to the Bechtel Supplier Quality Representative Field procurement services are provided to the project construct [on team through the senior field procurement representative at the jobsite. The senior field procurement representative receives project direction from the Field Construction Manager and/or the Project Procurement Manager, w

and technical and administrative direction from the Field Procurement t Manager. h. m s BQ-TOP-1 Rev. 3A 18 October 1980

SECTION 2 (17.1.2) QUALITY ASSURANCE PROGRAM '2.1 SCOPE The program described in this report is applied to the design, procure-ment, and construction of those structures, systems, and components (items) whose -satisfactory performance is required to prevent accidents which.may cause undue risk to the health and_ safety of the public or to - mitigate the consequences of such accidents if they were to occur. These items are defined as safety 'related and are identified in the safety analysis report for the project. 2.2 POLICY The Bechtel Q' uality Program described in this report is designed to comply with the requirements of the NRC Regulations and ~ the practices prescribed by American National Standards, client requirements, and Bechtel policies. The program assigns the responsibility for quality to the organization responsible for performing the work and includes as a basic requirement that individuals responsible for verifying and checking are independent of the individual or group responsible for - performing the work. Additionally, independent review, audit, and surveillance are performed by individuals-not affiliated with the organi-zational entities responsible for performance of the work. The President of Bechtel Power Corporation is responsible for the overall quality policy of the Thermal Power Organization. Division Quality Assurance Managers assist in the development of revisions and/or additions to TPO Quality -Policies for review and approval of the Vice President, Planning and Quality Assurance. Division Quality policies and quality assurance procedures of the divisions are formu-lated by the Quality Assurance Managers in the divisions who receive policy guidance from the Vice President, Planning and Quality Assur-l ance, and report directly to management of the division. Division [ policies are authorized for use within the division by the Division Manager. Quality assurance practices for individual projects are implemented through the Division Quality Assurance Managers.

Project, department, and division quality practices are subject to audit by Quality Assurance.

Coordination of the Quality Program within the Thermal Power Organiza-tion is the responsibility of the Vice President, Planning and Quality Assurance. The Quality Program is defined by Division Quality Policies formulated by Division Quality Assurance Managers. These policies are implemented through procedures and manuals issued by the' various departments and groups. The implementing procedures are - approved for policy compliance and the program requirements of this report by Quality Assurance management (see Table 1). Project l quality programs-incorporate required division policies and ~ procedures BQ-TOP-1 Rev. 3A 19 ()ctober 1980

2.3 - STOPWORK-

The_. program provides Quality Assurance personnel with stopwork au-thority over_ certain portions of project activity, and this authority is delineated in procedures.

In addition, control of further processing of l unacceptable work.is provided by appropriate hold and release points as - follows: ~

1) ; Design.

Unsatisfactory work with respect to design docu-ments prepared by Bechtel is controlled through the inde-pendent review process (prescribed by written procedures) and the refusal of the checker / reviewer to sign off the acceptance of the document which blocks its further pro-- cessing and iss~ue for-use. Each non-Bechtel design document for which project engineering has an interface and review responsibility is logged upon receipt and has affixed a standard Bechtel stamp which signifies the status of the document when it is returned to the originator. Any status other than permission to proceed automatically sets in motion follow-up and close-out actions.

2) Procurement.

Bechtel control over Supplier work is as follows: the Procurement Supplier Quality Representative, when required by procurement documents, must authorize l 3 supplier release for shipment (for purchased items) and may recommend stoppage of work on selected activities /_ through designated contractual channels in situations \\ which, if uncorrected, would render the item unacceptable for release. In cases of gross deficiencies or violations, procurement documents provide contractual

relief, in-cluding termination, and these measures can be used when necessary.

3) Construction.

Construction Quality Control has two prima-ry mechanisms to control further processing of unaccept-able work. These are the nonconforming material control system and the authority to refuse acceptance of completed work. Quality Control has authority to recommend stop- ~ page in situations which, if uncorrected, would render the item nonconforming or unacceptable. In cases of con-tractor or subcontractor work, Construction Quality Con-trol exercises controls similar to Procure. ment in 2) above. i BQ-TOP-1 Rev. 3A 21 October 1980

x In addition to the basic indoctrination and training' programs and per-formance reviews,. certain minimum education and experience guidelines have ' been established for various positions responsible for managing and directing program activities. While these are used for guidance in selecting candidates for these positions, they are not considered abso-lute requirements when other factors, such as the individual's demon-strated capability and. staff technical support available to him, provide assurance that appropriate managerial and technical skill will be applied. The basic qualification requirements for key management positions in the quality groups are an advanced degree with five or more years of a apropriate management and quality assurance experience, or a bach-e or's degree with eight or more years of appropriate experience. Additional pertinent experience is considered in lieu of a bachelor's degree. The basic qualification requirements for supervirory and project quality functions, such as Project Quality Assurance Engineer, Project Con-struction Quality Control Engineer, etc., are an advanced degree with two or more years of appropriate supervisory and quality-related expe-rience or a bachelor's degree with five or more years of appropriate experience. Additional pertinent (technical) experience is considered in lieu of a bachelor's degree. Records are maintained showing qualifi-cations of key management, supervisory, and project personnel in quality groups. ( The following specific qualification requirements are applied:

1) Personnel performing pressure boundary and structural welding and nondestructive examination are required to meet applicable qualification requirements of ASME Code, SNT-TC-1 A, or other appropriate codes and standards.

2) Quality Control Personnel - Construction Quality Control Engineers and home office Quality Control staff and super-vision will be qualified in accordance with the provisions of Regulatory Guide 1.58 (August 1973) or SNT-TC-1A, as applicable.

3) Audit Personnel Personnel performing audits will be qualified in accordance with the appropriate requirements of ANSI N45.2.12.

4) Procurement Supplier Quality Representatives - A formal training program, developed by the Procurement Supplier Quality Department, is required for Supplier Quality Representatives assigned nuclear plant purchase orders.

This program is defined in the Bechtel Procurement Sup-plier Quality Manual (PSQM) and conforms to the applicable l requirements of Regulatory Guide 1.58 (August 1973). BQ-TOP-1 Rev. 3A 23 October 1980

v report to the President of Bechtel Power Corporation evaluating the. adequacy of the quality assurance program: 1. Quarterly reports by the Division. Quality Assurance Man-agers, the Manager of Procurement Supplier Quality, and 'the Manager of Materials and Quality Services (including their. summary. of quality problems and audits) 2. The results. of Division Quality Assurance Managers quality program coordination meetings, conducted at least semi-annually '3. Audits or reviews of quality activities in the Divisions and support services as directed by the Vice President, Plan-ning and Quality Assurance The. above-listed reports and activities are also used to recommend action on the part of the Division Quality Assurance Managers, develop new policies, or other action as deemed appropriate by the Vice Presi-dent, Planning and Quality Assurance. ~ 2.8 MANAGEMENT REVIEW Management reviews of the status and adequacy of the quality assurance program are accomplished through periodic reports and presentations by Quality Assurance Management personnel to their respective managers, and through reviews of quality assurance management audit reports. I Meetings are held on a regular basis at both TPO and division manage-ment level. Meetings at the TPO level are coordinated by the office of l the Vice President, Planning and Quality Assurance, and the division I level meetings are conducted by the Division Quality Assurance Man-ager. The overall TPO Quality Assurance Program and each Division Quality Assurance Program, including support service organization Quality Assurance Programs, are reviewed annually by individuals outside the quality assurance function. These reviews are performed by manage-ment above - or outside the QA organization for TPO and Division Man-agement. The results of these reviews are documented and submitted to division and corporate management. Management reports contain summary data on the status of outstanding audit and corrective action items and identify the status of other signif-Icant quality program activities which may include items such as training and qualification programs; development of standard procedures, work plans, and other documents; status of industry standards; and other external issues of interest. These reports and discussions combined with other reports on overall division performance are used by TPO and division management above the level of Quality Assurance Manager to l assess the scope, implementation, and adequacy of the quality assurance l program. BQ-TOP-1 Rev. 3A 25 October 1980

.q. a SECTION 3 '(17.1.3) DESIGN CONTROli Engineering department. policies, standards, design guides, procedures, and instructions are employed for control of engineering design work to n technical and' regulatory rer ufrements. These controls identify responsibilities. and provide procec ures to assure that the design - re- - quirements. are correctly translated into the final design. The controls also provide for preparation of appropriate documentation to permit review of the process used and of the results obtained. The controls provide for the identification and specification of appropriate quality standards and for control of changes and design interfaces. Design criteria are assembled by the project during the initial stages of ' design. These criteria include the criteria contained in safety analysis-reports and other project requirements. The design criteria are main-tained current and serve as a basis for preparation of the final design. The design control program incorporates measures for identification and control of design interfaces among the various engineering disciplines on the project, between the project and technical support groups within Bechtel, and of such external interfaces as nuclear steam supply system sup?ller, other equipment suppliers, subcontractors performing design war 4, and the client (plant owner). These measures include: (a) ( identification of technical responsibilities of the various design grou 3s and provisions. for coordination of design documents among them, ( 3) description of responsiblities of and provisions for coordination with other design and engineering sup aart groups within Bechtel, and (c) definition of interfaces and contro of communication with organizations external to Bechtcl. Essentially all engineering documents are prepared by project personnel and include drawings, specifications, design analyses, system descrip-tions, and technical reports. They are verified or checked in accor-dance with Engineering Department Procedures. Project Group Super-visors (Figure 10) are responsible for all engineering work performed l within their discipline and for approval of engineering documents prepared within their groups. procedures and instructions for verifi-cation and checking of drawings, calculations, and specifications are included in the procedures governing the preparation of these docu-ments or in separate procedures or instructions. These procedures identify the positions responsible for verification or checking and re-quire that design errors are identified and followed up through cor-rection. Verifiers and checkers on the project are required to verify the incorporation of required corrections. Documents cannot be released without verification or checking. BQ-TOP-1 Rev. 3A - 27 October 1980

.o '62 ~ When design nyerification 'is accomplished by an interdisciplinary design review,. the review team will-be composed of individuals knowledgeable . of. the type.of system or structure and the requirements thereof. They may or may not have participated directly in the design of that partic- ~ ular system or structure. An individual who has participated directly. in the design shall not be responsible for the independent design veri-fication of his discipline. The' above description of. design verification of key design documents satisfies the regulatory position of Reg. Guide 1.64, June 1976. Design documents other than key design documents, identified above. shall be checked for technical correctness and conformance to design input requirements. . Engineering Department Procedures establish the extent of checking, the duties of the checker, and the extent of his reponsibility for which he. attests with his signature or initials. The signature or initials of the checker and date affixed on the design document in accordance with the Engineering Department Procedure satisfies the regulatory position of Reg. Guide 1.64, June 1976. Traceability of characteristic signa-tures and initials to the individual will be provided. TPO designated Chief Engineers coordinate and assist in the preparation l of certain generic " standard" and " guide" documents. Standard docu-ments include design standards, standard details, standard specifica-( tions, and technical topical reports. Guide documents include design guides, guide key documents, guide specifications, and Regulatory Guide positions. Generic " standard" and " guide" documents which are l pre-engineered to a level suitable for direct project adoption are subject l to checking, review, and design verification as described in this Sec-tion. Standard or guide documents which have been qualified by a design verification need only be verified by a project for their applica-bility to project requirements. The acceptability of any significant. changes to the qualified standard document must also be verified and documented. As a matter of policy, Bechtel uses accepted industrial standards, specifications, and materials. Prototype testing is encouraged for equipment suppliers whose components have not previously demonstrated adequate performance. Prototype testing is not normally applicable to Bechtel design work; however, selected design details may be verified by test. When prototype testing is used for design serification, the test requirements are specified by Bechtel. Design changes, including field changes, are subjected to design con-trol measures commensurate to those applied to the original design. Checking and review of design. changes are performed by the Project Engineering team to the same level as that of the original design. Changes to design requirements or completed designs produced by Project Engineering, which may be proposed by suppliers, subcon-tractors, or Bechtel construction, must be reviewed and accepted by i Project Engineering. I BQ-TOP-1 Rev. 3A 29 October 1980

L SECTION 4 (17.1.4) -t_ L PROCUREMENT DOCUMENT CONTROL All procurement actions for 'Q-List items and services, including off-the-shelf items and bulk commodities, whether performed by home office or' field procurement groups, employ technical and quality requir'ements established. by project engineering. Project engineering prepares (or provides) the technical and quality requirements. appearing in procurement documents. These activities are governed by the same policies and procedures as those applied to design documents. Engineering and procurement department procedures delineate the sequence of quality-related action -to be accomplished in preparation, review, approval, and control of procurement documents and changes thereto. Project engineering is responsible for assuring that applicable regula-tory requirements, design bases, supplier quality assurance program -requirements, and other requirements which are necessary to obtain and verify quality are included or referenced in the procurement documents. While the project engineering team is responsible for preparation of specifications for supplier, contractor, or subcontractor quality assur-ance programs, these specifications are based upon program policy (- formulated by Quality Assurance and guidance provided in approved Engineering Department Procedures and standard ' engineering specifica-tions. The specifications are reviewed for appropriate quality program requirements by Project Quality Assurance. Prccurement documents include specific technical specifications for the equipment and services to be furnished which define specific codes, standards, tests, inspections, and records to be applied or furnished. The procurement documents also include quality assurance requirements either in separate specifications which define requirements for the supplier's quality assurance program or by incorporating appropriate requi ements in the technical specifications and associated documents. Quality programs may be specified by invoking the appropriate sections and elements of ANSI N45.2-1971, appropriate supplementary ANSI Quality Assurance Standards, and the ASME Boiler and Pressure Vessel Code, as applicable, or by incorporating requirements equivalent to those of these standards. The procurement documents also establish provisions for surveillance, inspection, and audits (including access to the supplier's and subsupplier's facilities and records for audit), provide for extension of the applicable requirements to subtier procure-ments, include provisions for control and approval of supplier noncon-formances, and establish requirements for preparation and delivery of documentation. Specific requirements for documents which must be submitted for review, approval, and/or verification are provided. BQ-TOP-1 Rev. 3A 3] October 1980

c The following describes the sequence of steps for Bechtel Field Pro-I curement: )

1) -field Engineering prepares requisitions employing technical and quality assurance requirement specifications which have been established by Project Engineering and have been reviewed by Quality Assurance.

2) The. Project Construction Quality Control Engineer reviews the field material requisition to verify inclusion of specified quality assurance requirements.

3) Field Engineering forwards the material requisition to the Senior Field Procurement Representative.

4) The Senior Field Procurement Representative prepares a bid request package which is forwarded to bidders.

5) Bids are received and reviewed for commercial terms by the Senior Field Procurement Representative and forwarded to Field Engineering for technical evaluation and selection of recommended supplier.

Quality program evaluation is normally performed by Project Engineering but may be performed by Construction Quality Control or Procurement Supplier Quality. I

6) The Quality Assurance Engineer reviews and concurs with the evaluation of the recommended supplier's quality assur-ance program.

7) Field Engineering approves the bid recommendation,

obtains other necessary approvals, and forwards it to the Senior Field Procurement Representative.

8) After receipt of necessary approvals, the purchase order /

subcontract is issued by the Senior Field Procurement Representative. ( BQ-TOP-1 Rev. 3A 33 October 1980

a ( SECTION 5 (17.1.5) INSTRUCTIONS, PROCEDURES, AND DRAWINGS The documented instructions and procedures governing the program were identified in Section 2. Procedures and manuals governing the activities of organizations and groups performing quality-related functions include procedures for the preparation and review of instructions, procedures, and drawings. Documented instructions from Project Engineering to Construction, subcontractors, and. suppliers is in the form of engineering specifica-tions and addenda or change notices thereto, drawings, and drawing change notices. These documents _ contain, reference, _ or. require pro-cedures and instructions, as appropriate, and provide necessary accep-tance criteria. When approved by Project Engineering, these documents l are released for construction work. I Bechtel procurement documents require suppliers and subcontractors to submit specified drawings and procedures to Bechtel for acceptance -prior to start of fabrication or construction. Bechtel reviews of these documents are performed to determine that interfacing design features are compatible with overall design and installation requirements and that procedures are acceptable. 1 Procedures for construction activities are prepared by Construction and contained in a procedures manual. These procedures describe, define, specify administrative and functional requirements for performing or construction activities. Procedures of this nature include training of personnel; jobsite housekeeping; storage, maintenance, and handling of items; document control; changes to design documents; reviewing sup-plier engineering documents; and field requisitioning of items and services. Field Engineering (construction) prepares other procedures when engi-neering documents require amplification to perform various discipline i activities associated with fabrication, cleaning, erection, installation, test, repair, modification, etc., of items. The requirements, proced Ires, and instructions for the Construction Quality Control activities are contained in the Construction Quality Control Manual. The ele: 1ents of this manual include qualifications, indoctrination, certification, and training; inspection, examination, and test control; control of no1 conforming items; field procurement control; control of measuring and test equipment; documentation and records contrei; final inspection an1 turnover; and contractor and subcontractor control. Assurance that work is accomplished in accordance with approved in-structions, procedures, and drawings is obtained through the various _k levels of surveillance, irspection, and audit described in other sections of this report. BQ-TOP-1 Rev. 3A 34 October 1980

[.. SECTION 6 (17.1.6)- DOCUMENT CONTROL o The program documents identified in Section 2 provide means for docu-p- ment control. These include procedures providing Engineering, Pro-curement Inspection, and Construction controls for the review,-approv-al, and release of documents and. changes thereto. Documents pertaining to quality-related items, as identified in this paragraph, are required to he controlled. The documents listed in l Table I are on controlled distribution. Instructions, procedures, speci-fications, drawings, procorement -documents, inspection plans, design calculations, design criteria, field change requests, safety analysis reports, and inspection test procedures are identified by control regis-ters or index lists. Nonconformance reports, supplier deviation reports, corrective action reports, documentary evidence of design reviews, memoranda, and correspondence are identified by logs which provide for traceability of closecut action. Document control centers for the project are set up in the Project Engineering office and the jobsite. Controlled documents are released, received, controlled, and distributed through these centers. Engineering Department procedures. prescribe the requirements for preparation, control, and distribution of design documents. Approved ( drawings and specifications prepared by Project Engineering are issued to organizations and individuals responsible for performing the work and to those responsible for inspection *. Control registers, issued i - periodically, identify the drawings, specifications, and other design l output documents and their current status. l . Transmittal forms are employed to forward drawings and specifications ( and require that signed receipts te returned from the addressee. L Changes. made to approved design documents by Project Engineering or proposed by I'ield Engineering are reviewed And approved by Project Engineering in accordance with established procedures which provide that changes are reviewed in the same manner as the original issue. l Supplier-submitted documents, such as drawings, specifications, proce-i dures, manuals, and other data, are controlled through the use of control logs which provide identification and status of supplier docu-men ts. Transmittal forms are used to return and show approval status

• Bechtel Procurement Supplier Quality Representatives receive copies of the transmittal notices listing the documents and their approval status but normally do not receive copies of the documents.

These are available at the supplier's plant for the Supplier Quality Representative. I BQ-TOP-1 Rev. 3A 35 October 1980 -j

.r. SECTION 7 [ (17.1.7) CONTROL OF. PURCHASED MATERIAL, EQUlPMENT, AND SERVICES 7.1 SUPPLIER EVALUATION AND SELECTION I Files of ' suppliers and subcontractors are maintained by Procurement. These files identify suppliers and subcontractors who have demonstrated their. ability to provide quality material, equipment, or services, or who have been established as capable by survey. Suppliers' and subcon-tractors' quality history files contain information on scope of services and_ capability, and results of recent shop surveys and audits. Peri-odic reports identifying data contained in quality history files cre issued by Procurement Supplier Quality to interested groups within the ' divisions. The - Materials and Quality. Services Department _ reviews welding and nondestructive examination procedures for work involving compliance with the ASME Boiler and Pressure Vessel Code and for fabrication of metal structures and protective coating procedures. Materials and Quality Services reviews and evaluates these documents and provides Procurement with information for summary listings of the approved vendor information on file. This information is available to projects for assistance in identification and evaluation of qualified sources. -( Procurement Supplier Quality Department procedures include provisions for source surveys which may be used to supplement data in a suppli-l er's queiity history file. Reques.s for source survey are initiated by l Purchasing or Engineering in cases where inadequate historical data is ( available to evaluate the supplier's capability to produce the commodity. Feior to award *, the following technical and quality requirements must be met: 1-

1) Determination by Engineering that the source is responsive to the technical requirements of the specification

2) Determination by Engineering and Quality Assurance that the supplier or subcontractor quality program is capable of meeting the specified requirements.

This may be based on evaluations by Procurement Supplier Quality for manufac-turing suppliers or Construction QC for jobsite contractor or subcontractor. l In some instances it may be necessary to place a contract without fully satisfying these criteria. For these cases, the criteria shall be met prior to start of related work activities. i BQ-TOP-1 Rev. 3A 37 October 1980 e

c-Tor Q-List items, Bechtel Procurement Supplier Quality Representatives perforn their surveillance inspection in accordance with inspection plans ' I' and instructions. These plans are prepared by Procurement Supplier Quality ~ based on instructions in the Procurement Supplier Quality ~ Department Manual and may be modified by Project Engineering. They provide for identification of witness and hold points, identification of the examinations and tests which are selected to be witnessed by the Bechtel Supplier Quality Representative, 'and documentary evidence of completion of each witness and hold point operation, test, or exami-nation. A supplier _ may not proceed with the work beyond a hold point without written agreement of waiver of hold points from Procurement Supplier Quality based on agreement from Project Engineering and the PQAE. It is the responsibility of the Supplier Quality Representative-to verify, to the extent required by his inspection plan, that the supplier has met the quality requirements contained in the procurement documents before -the material or equipment is released for shipment. This responsibility of _ the Supplier Quality Representatives is met through surveillance inspection which includes observations and checks at random of selected intervals (or points) of materials of construction, in-process fabrica-tion, heat treatment, welding, examination, testing, dimensions, prepa-ration for shipment,

marking, tagging, and quality verification.

Bechtel Supplier Quality. Representatives do not perform nondestructive examinations or tests on material and equipment at suppliers' plants. Such examinations and tests are performed by the supplier-and selec-tively witnessed or otherwise monitored by the Supplier Quality Repre-sentative. Typical surveillance inspection plans have sections that describe the scope and define application, establish responsibilities, describe pre-planning activities to be performed prior to making initial contacts with a supplier, describe the activities to be performed during the initial, progressive, and final inspection visits, and describe reporting re-quirements. Procurement inspection may be performed by resident or area Supplier Quality Representatives assigned to several suppliers. Reports docu-menting inspections performed, tests witnessed, and discrepancies observed are prepared by the Supplier Quality Representative and distributed to appropriate Engineering, Construction, Procurement, and Quality Assurance personnel. Bechtel Supplier Quality Representatives are responsible for assuring that their inspections of material, equip-ment,- and specified documentation conform to the requirements of the inspection plan and/or ir structions and for releasing inspected items for shipment..Bechtel Supplier Quality Representatives have the authority to refuse release of nonconforming material. i BQ-TOP-1 Rev. 3A 39 October ' 1980

Documentary evidence that the item conforms to procurement documents, - required to be' available at the construction site prior to installation, or I-use as a conforming item, includes as follows:

1) For Bechtel procured

• and inspected items not covered by ASME Boiler and Pressure Vessel' Code requirements, a certificate of conformance**' (signed by an authorized representative of the supplier identifying the specific technical requirements. met by the item by referencing the appropriate Bechtel specification and other governing codes and standards) and acknowledgement that the Bechtel Procurement Supplier Quality Representative has reviewed the required documentation and has released the item.

This may be obtained by having the certificate signed by the Bechtel Supplier Quality Representative to verify that he has reviewed applicable supplier documentation sup-porting the certificate and released the items, or by receipt of a separate teletype or report from the Supplier Quality Representative indicating that his inspection is complete and the item has been released. Receipt of the certificate of conformance and the Bechtel Procurement Supplier Quality Representative release constitutes docu-mentary evidence that materials and equipment conform to procurement requirements and may be installed. If the balance of the documentation package required by the procurement documents is received prior to or with the shipment, the certificate of conformance may be waived.

2) For Bechtel procured and inspected items covered by ASME Boiler and Pressure Vessel Code requirements, the same requirements prevail as above, plus the appropriate Code Data Report.

3) For Bechtel procured and noninspected items, all quality verification documentation required to be submitted with the procurement documents must be reviewed and verified (as a part of receiving inspection) at the construction site by Quality Control personnel, such as Construction Quality Control or Procurement Supplier Quality personnel.

4) For nuclear s, team supply system supplier furnished items, appropriate certification from the NSSS supplier in accor-dance with his quality program Also applies to cases of Bechtel client (applicant) procured items for which Bechtel is acting as agent for the client.

• • The certificate of conformance conforms to ANSI N45.2.13.

BQ-TOP-1 Rev. 3A 41 October 1980

( SECTION 8 (17.1.8) IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS Identification requirements are determined during the generation of specifications and design drawings. Procurement documents provide the requirements for identification of purchased items. Parts, components, subassemblies and equipment, and partially fabri-ated items may be identified by stenciled or etched markings, strip c marking, imprinted tape, color coding, and tags. Large quantities of small items, unless specifically required by code or standard, may'be identified as to heat, batch, lot, or specification by applying markings to bags, bins, tanks, or other suitable containers. Identification of installed or assembled items requiring traceability may be transferred to inspection records or as-built documents if desired and is required if markings are -hidden or subject to obliteration during fabrication or installation. Organizations receiving materials, parts, or components verify that these are properly identified and are accompanied by appropriate docu-mentation. Provisions are made for handling and storing items to retain (- identification and to prevent intermixing. ( BQ-TOP-1 Rev. 3A 43 October 1980

(' SECTION 9 (17.1.9) CONTROL OF SPECIAL PROCESSES The requirements of the ASME Boiler and Pressure Vessel Code are invoked, as applicable, in the Bechtel program. Special processes requiring procedure and/or personnel qualification beyond those re-quired by the code are identified in technical specifications by refer-ence to appropriate industry codes and standards, where available, or by specific identification in the technical specification. Supplier and subcontractor special process qualification data are subject to review by Bechtel. Special processes performed by Bechtel Construction, including welding, nondestructive examination, -protective coating, cleaning and flushing, are performed in accordance with the requirements of applicable codes and standards. The requirements for welding and nondestructive examination comply with applicable portions of the ASME Boiler and Pressure Vessel code, American Welding Society Standards, and the Society of Nondestructive Testing (SNT-TC-1A and supplements), as applicable. Cleaning and flushing procedures and personnel qualifica-tions conform to the requirements of Regulatory Guide 1.37 (3/16/73). Other unique special processes or work operations identified by the / nuclear steam system supplier or Project Engineering are properly qualified and performed by trained personnel in accordance with, spec- \\ ified technical requirements. Current qualification records of procedures, equipment, and personnel are maintained at the jobsite. Active files are maintained in the home office, and copies are provided to each affected project of qualification records covering special processes and procedures. Projects are re-quired to maintain up-to-date lists of personnel qualifications and/or applicable equipment qualifications for special processes. Controls are provided to assure that personnel qualification records are regularly reviewed, and the appropriate requirements for requalification are implemented. Implementation of these controls is verified by Construc-tion Quality Control personnel and audited by Quality Assurance with the assistance of Materials and Quality Services. c ( BQ-TOP-1 Rev. 3A 44 October 1980 e

n SECTION 10 { (17.1.10) INSPECTION As described in Section 7, suppliers' and subcontractors' programs are subject to -surveillance inspection by Bechtel Procurement Supplier ' Quality ' Representatives and Construction Quality Control Engineers as applicable. The responsibilities for inspection of Bechtel construction work are identified.in Sections 1 and 2.. Quality verification inspection, witness of testing activities, and evaluation of test results are performed by Construction Quality personnel who are independent of field engineering and craft supervision. Quality Control Engineers are assigned-by and receive administrative and technical direction from the Chief Construc- -tion Quality Control Engineer in the division or area office. The over-all inspection program is monitored by resident construction site Quality Assurance personnel and audited by Division Quality Assurance. Inspection, witness of testing activities, and evaluation of test results are performed in accordance with procedures contained in the-Construc-tion Quality Control. Manual supplemented by construction quality control instructions, or work operations and planning documents. Inspection planning includes receiving inspection, construction and installation inspection, and testing. ( . Quality control instruction and inspection records are prepared to cover onsite receiving, maintenance, installation, testing, and subcontracted work activities performed during the construction phase. These are the controlling documents used by Quality Control Engineers for perfor-mance of onsite quality verification activities. These identify what inspections are required, the inspection acceptance / rejection criteria, how and by whom the inspections are to be performed, and the se-quence. They are available prior to inspection. Inspection and acceptance criteria are derived from engineering design documents, supplier information, and construction procedures. Stan-dard inspection instructions to be used on the project are approved by the Chief Construction Quality Control Engineer. In addition, all work covered by the ASME Boiler and Pressure Vessel Code, Section III, is also subject to independent inspection by autho-rized Code Inspectors in accordance with the Code rules. Inspection procedures or instructions and records provide the following information:

1) Reference to applicable documents such as drawings, specifications, and procedures

(- BQ-TOP-1 Rev. 3A 45 October 1980

• {

SECTION 11 (17.1.11) TEST CONTROL Tests required to qualify, demonstrate, or assure quality of procured items or completed construction are defined in. engineering drawings, specifications, or test procedures. Construction tests are an extension of construction inspection. Con-struction testing is conducted to demonstrate that the equipment instal-lation is complete and that the electrical systems are properly wired. Test plans or procedures, and test reports and records are used to demonstrate that completed tests have met test objectives. System cleaning, flushing, instrument and control settings, and perfor-demonstration are part of the preoperational and startup test mance program. Preoperational and startup testing is normally under the control of the client. Bechtel startup engineers may provide assistance to-the client in the-preparation of startup procedures and supervision of startup tests. Bechtel startup engineers are independent of the construction and the client's operating organization and are qualified to collect, analyze, and evaluate test results in accordance with the requirements of Regulatory Guide 1.28 (6/7/72). ( (- BQ-TOP-1 Rev. 3A 47 October 1980

^ f SECTION 12 \\ (17.1.12) CONTROL OF MEASURING AND TEST EQUIPMENT The Bechtel Construction Quality Control Program provides for calibra-tion, maintenance, and control of measuring and test equipment used by Bechtel in constructicn. Procedures provide for unique identification of each instrument or equipment item requiring calibration or checking, establishment of calibration schedules based upon the elapsed time or usage cycles, and provisions for identification of calibration status by tags, labels, or markings applied to the item. Records are maintained to show the status of items under the calibration program. Inspection procedures require that the inspector check calibration labels or tags as well as apparent proper functioning of the instrument prior to use to assure that the calibration period has not lapsed and the equipment is in proper working order. The identification of measuring and test equipment used in performing tests is entered in the test records when the validity of the test result is critically dependent on the accuracy of the test equipment. Calibration standards are traceable to nationally recognized standards, or the basis for calibration is properly documented. Calibration stan- ^ ( dards have an uncertainty (error) requirement of no more than 1/4 of the tolerance of the intended use of the equipment being calibrated. A greater uncertainty (error) is acceptable when limited by the state of the art. 1 Provisions for contractor's control of measuring and test equipment are included in procurement documents by specifying ANSI N45.2-1971, Section 13. The Bechtel surveillance inspection program of contractor's activities includes review of this element in the contractor's program. Contractors are required to apply practices similar to those described for the Bechtel program. Performance and adequacy of supplier, contractor, subcontractor, and l Bechtel construction programs for control of measuring and test equip-ment are verified by surveys or audits perfc"med by Bechtel Procure-ment Supplier Quality, Quality Control, or Quality Assurance personnel, as applicable. \\ ( BQ-TOP-1 Rev. 3A 48 October 1980

SECTION 13 (17.1.13) HANDLING, STORAGE, AND SHIPPING The -requirements for packaging, marking, and shipping are specified in . procurement documents for Q-List items by reference to ANSI N45.2.2-1972 or by provision of specific technical requirements which meet the intent of this standard. Procedures for equipment and system cleaning and flushing and clean-ness control conform to the appropriate requirements of Regulatory Guide 1.37 (3/16/73). For supplier, contractor, or subcontractor work, special handling, stor-age, shipping, and preservation requirements are identified in technical specifications which either provide, or require the vendor or subcon-tractor to provide, the required procedures and instructions. The packaging, handling, and shipping practices of the suppliers are sub-ject to review by Bechtel Procurement Supplier Quality Representatives at the source prior to shipment for compliance with requirements defined in procurement documents. At the construction site, materials and equipment are received, inspec-ted, stored, and maintained in accordance with standard field proce-dures supplemented by special procedures and requirements issued by ( project engineering or furnished by suppliers. Materials and equipment are physically inspected upon arrival at the jobsite and moved into prescribed storage areas or to the installation site if adequate protection is available. Immediate movement to the installation site is pemitted if it would eliminate multiple handling and is compatible with the construction schedule. Special environmental conditions, such as inert gas, specific moisture content levels, and temperature levels prescribed in procedures or specifications, are controlled at the site. Procedures are provided, as appropriate, for handling special items and for the care and maintenance of material handling equipment. Other-wise, standard material handling methods are used to ensure care and protection against physical damage. Special handling instructions and procedures for major or special items are included in procedures reviewed by Project Engineering or Bechtel construction specialists. Personnel responsible for handling these major or special items will be qualified to the extent required by these special handling instructions and procedures. Preparation for and performance of rigging operations involving major equipment, such as reactor vessels, steam generators, and pressurizers', are witnessed by Bechtel construction rigging spe-cialists. ( BQ-TOP-1 Rev. 3A 49 October 1980

SECTION 14 (17.1.4) INSPECTION, TEST, AND OPERATING STATUS Construction procedures and inspection instructions provide for identifi-cation of inspection status of receipt inspection or work-in-process by using work sequence plans, inspection records, physical locations, tags, markings, or other devices compatible with the item, system, or operation being inspected or tested. Progress of work is entered in records, and status identification is changed to reflect current condi-tions. At the completion of construction, a tagging system is employed to visually indicate the operating status of equipment and systems which are in test or rework. Records of test results are prepared and main-tained. Work is peformed according to prescribed sequences required to assure quality, and in accordance with the provisions contained in this report. Inspection points may be deferred or waived without generation of a nonconformance report only when specifically provided for in the gov-erning procedure. Inspection points can be deferred only when the element can be inspected at a later time in the sequence and a later hold point exists. In these cases, the inspection records or checklists are not completed until the. inspection point is picked up at a later date. If physical control of the item is required to prevent its in-advertent use or installation beyond the point where the inspection can L be performed, the item is tagged or otherwise identified and condi-tionally ' released with a limit placed on future work operations. Procedures or instructions include identification of the individuals or groups responsible for application and removal of status indicators. Field Engineering and supervisory personnel are authorized to apply and remove identifying tags, markings, and labels on equipment in accordance with approved field procedures. Quality Control personnel are the only ones authorized to direct application and removal of inspec-tion status indicators. Bechtel, in cooperation with the plant owners' operating personnel, establishes a tagging procedure which delineates those authorized for applying and removing tags during preoperational testing phases. ( BQ-TOP-1 Rev. 3A 50 October 1980 m

ry SECTION 15' (17.1.15) NONCONFORMING ITEMS Suppliers and. subcontractors are required to advise Bechtel of all nonconformance from procurement documents or Bechtel-approved de-signs for which the recommended disposition is " repair" or "use as is." Bechtel reserves the right to accept or reject the disposition. Bechtel requires. suppliers to submit proposed repair procedures for major nonconformances 'for approval by. project engineering prior to their use. Reports of nonconformances identified by Bechtel personnel are pre-pared by the supplier, Bechtel Procurement Supplier Quality Represen-tatives, or Project Engineering to assure complete and adequate docu-mentation. Copies of completed nonconformance reports are forwarded to the jobsite prior to, or with, the release of the item; or identifi-cation of outstanding nonconformances are included in the Supplier Quality Representative's release. Nonconformances discovered during Bechtel receiving inspection or construction activities are controlled and documented in accordance with a standard Quality Control procedure. The procedure provides for identification and documentation of the nonconformance and control of - the item, identifies the authority for approval of proposed resolution, and provides for documentation of reinspection results. Important elements of the procedure include requirements to: (

1) Tag and segregate whenever practical

.2) Determine interim dispostion by Project Field Engineering

3) Have Project Engineering approve " repair" or "use as is" dispositions

4) Advise Project Engineering after implementation for stan-dard preapproved repair procedures

5) Provide conditional release of nonconforming items upon approval of Quality Control and Quality Assurance

6) Review completed nonconformance reports by Quality Assurance to establish need for corrective action.

Repeti-tive nonconformances are reported to higher levels of management for review and resolution on a generic basis. The authority for disposition of nonconforming items follows the rules for approval of design changes described in Section 3 of this report. Field Engineering personnel are authori7.ed to provide for disposition involving " reject," " rework" (if Bechtel performed.the original work), or " repair" (for those cases where standard preapproved repair pro-cedures have been provided by Project Engineering). Other " repair" and "use as is" dispositions require Project Engineering approval prior 1 ( BQ-TOP-1 Rev. 3A 51 October 1980

{ SECTION 16 (17.1.16) CORRECTIVE ACTION The corrective action program provides procedures for prompt identifi-cation and correction of conditions adverse to quality which may require corrective action. Corrective action, when initiated, shall be docu-mented. A decision that corrective action is not required need not be documented. Within the Bechtel program, the identification of situations which may need corrective action is accomplished through review of nonconformance reports, supplier surveillance activities, quality assurance surveillance and monitoring programs, and quality assurance. audits. Corrective action is controlled and documented by means of corrective action reports and the associated procedure. These provide for (a) the identification and reporting by any member of the project team of situa-tions or occurrences which warrant corrective action, (b) determination of the cause and identification of the corrective action to be taken by the responsible organization, (c) reporting the cause and corrective action to proper level of management, (d) final verification by the Project Quality Assurance Engineer that corrective action has been taken, and (e) review by Quality Assurance management for implication or effect on other work. ( Corrective action involving design documents, investigation of cause, and actions taken to preclude recurrence is applied to errors detected after the design document is issued for use. Such errors, detected after the design document is issued for use, are formally documented and are reviewed for corrective action. These are documented by design change notices, revision block entries, or reports, such as supplier discrepancy reports, field nonconformance reports, startup reports, or feedback from utilities during operation of the plant. Significant problems are also reviewed for programmatic corrective action by Quality Assurance. This program also provides for the evaluation of conditions reported which may require reporting to the NRC by Bechtel clients in accor-dance with the requirements of 10 CFR 50.55(e). ( BQ-TOP-1 Rev. 3A 53 October 1980

f-- SECTION 17 (17.1.17) QUALITY ASSURANCE RECORDS The requirements of Regulatory Guide 1.28 (6/7/72) are applied to Bechtel activities. Records produced as a result of the quality program are prepared and maintained by project groups, suppliers, and subcon-tractors as their work is being performed. Project engineering records are retained by the project engineering team as work is performed. It is normal practice to microfilm documents at regular intervals, unless duplicate copies are available at an alter-nate location. Provisions for collection of completed records in the design office, or at the jobsite, and the criteria for storage and reten-tion recommended in ANSI N45.2.9-1974 are applied to quality records. l Documentation of the design review process is prepared and maintained in accordance with Section 3 of this report. Design changes may be issued on an interim basis by means of change notices. However, these are ultimately -incorporated in revisions to the governing documents, unless the change is a limited waiver (e.g., "use as is" on a noncon-formance report) which does not generally apply to the desian docu-ment. Copies of released drawings, specifications, technical reports, and similar documents are placed in Engineering office files, Construc-f tion office files, and submitted to the client. At the completion of \\ engineering, final copies of these records are provided to the client. Bechtel Engineering retains control of design calculations and analyses. These are available for review by client and appropriate regulatory bodies. Supplier records which identify as-built status and verify quality of the work are requested from the supplier and placed in construction site quality record files. In some instances, with the agreement of Bechtel and the client, suppliers are permitted to retain custody of certain records if retention procedures and storage facilities are adequate and access is provided to the Bechtel client. Completed quality verification records, including nonconformance reports for " repair" and "use as is" dispositions, are placed in quality record files. The client and appropriate regulatory groups are provided access to these files while they remain in Bechtel custody. At the completion of the Bechtel assignment, these files are turned over to the client. The requirements and guidelines for receipt, control, and retention of permanent quality assurance records contained in Regulatory Guide 1.88 (Rev. 2, October 1976), in accordance with provisions of Appendix A of this report and ASME Boiler and Pressure Vessel Code, Section III, are employed for the control of construction site quality record files. Identification of the records and method of turnover to the client are I established for each project through agreement between Bechtel and the client. BQ-TOP-1 Rev. 3A 54 October 1980

e l SECTION 18 1 (17.1.18) ( AUDITS A comprehensive program of audits is conducted by Bechtel covering the various activities of the Quality Assurance Program. The Bechtel audit program includes both monitoring of daily activities conducted by Quality Assurance personnel at the construction site or home office as well as formal periodic team audits performed by per-sonnel independent of project activities. The combination of project and division Quality Assurance management audits of Bechtel activities satisfies the requirement for-annual audits of the applicable elements of the Quality Assurance program. Audit activities include the following:

1) Audits of Project Engineering activities by Quality Assur-ance personnel. These audits are plan'ied, scheduled, and documented.

Results are reported. to the Project Engineer, Project Manager, and the immediate functional supervisor of the office Quality Assurance Engineer.

2) Audits of field Construction activities (including con-tractors for Bechtel Construction Management jobs) by Quality Assurance personnel.

These audits are planned, e scheduled, and documented. Results are reported to the Field Construction Manager, Project Manager, and the ( Immediate functional supervisor of the Quality Assurance Engineers.

3) Audits of Supplier activities by the Procurement Supplier Quality Department.

l

4) Audits of Project Engineering, Procurement, Construction, and Quality Control activities by Quality Assurance audit teams under the direction of Division Quality Assurance Managers, assisted by Materials and Quality Service spe-cialists and others as required.

These audits are con-ducted at least annually and results are reported to the management of the function audited, coanizant project management, and division management. A sammary of the results of these audits is reported by the Division QA Manager to the Vice President, Planning and Quality Assurance.

5) Audits of division engineering technical staff and services activities performed on an annual basis under the direction of the Division Quality Assurance Managers.

These audits cover those groups doing design and/or review outside direct control of the Project Engineer. Results of these audits are reported to the manager or supervisor of the ( BQ-TOP-1 Rev. 3A 55 October 1980

n TABLE I BECIITEL QUALITY PROGRAM DOCUMENTS Originating Review for QA Policy Authorizing Document' Authority and Program Requirements Approval Contents

• Division Quality Division QA QA-TPO Division Manager Division policy supplementing policies (Division Manager and implementing TPO Quality.

- QA Manual) Policy

• Bechtel Quality Manager-M&QS Q A-T PO*
• President and Policies and procedures for l

Assurance Manual-appropriate overall' Bechtel program ASME Nuclear Authorized Code applicable to ASME Components (BQAM-Inspection Agency work ASME III)-

• Procurement Supplier Manager Pro-Q A-TPO *
• Manager Procure-Procurement Supplier l

u"' Quality Manual curement ment Supplier Quality procedures Supplier Quality Quality

• Construction Quality Division Chief Division QA Manager

_ Manager Division Definition of responsibilities Control Manual Constr. QC Construction and procedures for Construc-Engineer tion Quality Control activities Division QA Division QA NA Division QA Manager Procedures for conducting Procedures Manager Division QA activities

• Available on request to appropriate regulatory agencies.
  • Includes review by Division QA Managers.

Note: Revisions to these documents require the same review and approval as the original. BQ-TOP-1 Rev. 3A October 1980

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• e RECEIVES FUesCTIONAL CUtDANCE FROed THE 800TE :

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m . - ~. SUPPLIER QUALITY ORGANIZATION REV.1. DATE APR.1,1978 THERM AL POWER PROCUREMENT ORG ANIZ ATION DEPARTMENT OUALITY ASSURANCE { l DEPUTY M AN AGER MANAGER PROCUREMENT SUPPLIER OUALITY MANAGER AREA /DtvlSION DEPUTY MANAGER OF F ICES PROCUREMENT ADMINISTR ATlVE MANAGER l ASSISTANT 2 y sum uma um um e e e e um mun sus ay sus aus e e e sum um mas amm 5a a I I DOMESTIC A/D OFFICES INTERN ATION AL OF F ICES DIVISIONS AND FIELD SERVICES TECHNICAL SERVICES MANAGERS RPea SUPPLIER QUALITY SUPPLIER OUALITY MANAGER MANAGERS MANAGERS I m 5 I I 2 PROJECT SUPPLIER PROJECT SUPDLIER DIVISION (S) OUAllTY OUALITY ImIII DIVISION SUPPLIER R EGION AL SUPERVISORS REPRESENTATIVES R EPR ESE NT AT IVES QU ALITY SUPERVISOR (SURVE YORS) DIVfSION TECHNICAL DIVISION SERVICES SUPPLIER QUALITY sees SERVICE Imus COOR DIN ATION REPR ESENT ATIVES REPRESE NT ATIVES SUPERVISOR ^ ADMINISTRATIVE AND TECHNICAL DIRECTION SUPERVISOR me me sum uma m e me TECHNICAL DIRECTION POLICY AND PROGRAM b AUDITS AND SURVEYS COORDINATION SUPE RVISOR eteesseesseteessess ADMINISTR ATIVE E DIRECTION AUDITORS FIGURE 4 BO-TOP-1 R EV. 3 A OCTOBER 1980

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DIVISION 0.UAllTY ASSURANCE ORGANIZATION l (TYPICAL) DIVISION QUALITY ASSURANCE I I I I INDOCTRINATION SPECIAL PROGRAM AUDIT PROJECT & TRAINING PROJECTS B$E"E TOB R 1980

e ^. O.UALITY PROGRAM DOCUMENTS 10 CFR 50 APPENDIX B ASME QUALITY POLICY l BO-TOP-1 B & PV ANSIQA NUCLEAR CODE STANDARDS OA PROGR AM f h u u i ASME ROCUREMENT MOCUREMENT POLICY AND SUPPLIER DIVISION QUALITY POLICIES MANU A LS PROCEDURE QUALITY PROCEDURES GUIDE DEPT. MAN UAL l PROCEDURES 0 QUALITY ASSURANCE ENGINEERING QUALITY CONTROL CONSTRUCTION PROCUREMENT l' PROJECT REQUIREMENTS REFERENCE, AMEND & CLIENT INPUT SUPPLEMENT ABOVE FIGURE 13 BO-TOP 1 R E V. 3A OCTOBER 1980

l e ^ TYPICAL POWER DIVISION i PROCUREMENT ORGANIZATION ANEE#e!EE'ESI#s?sYOYils i DIVISION PROCUREMENT l l (Aree O*fice) SERVICES IBudgets) I i I I I I i PROJECT SUPPLIER PURCHASING SUSCONTRACTS EXPEDITING FIELD PROC. TRAFFIC MANAGER MANAGER y PROCUREMENT OUALITY MANAGER MANAGER MANAGER MANAGERS MANAGER m Ip--------

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APPENDIX 'A m ~. -BECHTEL POSITION ON QA NRC. REGULATORY GUIDES k: AND ANSI STANDARDS Page. Title A-2 Regulatory Guide 1.30 (ANSI N45.2.4-1972, IEEE 336,. Installa-tion, Inspection, and Testing Requirements for Instrumentation and Electric Equipment During the Construction. of Nuclear ' Power Generating Stations) ' A-3 ' Regulatory Guide 1.37. (ANSI N45.2.1-1973, Cleaning of Fluid Systems and' Associated Components During Construction Phase of Nuclear Power Plants) i A-4 Regulatory Guide 1.38 ( ANSI N45.2.2-1972, Packaging', Ship-ping, Receiving, Storage, and ~ Handling of ~ Items for Nuclear Power Plants [During the Construction Phase]) l A-6 Regulatory Guide 1.39 (ANSI N45.2.3-1973, Housekeeping During the Construction Phase of Nuclear Power Plants) A Regulatory. Guide 1.58 (ANSI N45.2.6-1973, Qualifications of Nuclear Power Plant Inspection, Examination, and Testing l Personnel) I ' A-14 Regulatory Guide 1.64, Revision 2, June 1976 (ANSI l N45.2.11-1974, Quality Assurance Requirements for the Design of Nuclear Power Plants) A-16 Regulatory Guide 1.88, Revision 2, October 1976 (ANSI l N45.2.9-1974, Requirements for Collection, Storage, and Main-tenance of Quality Assurance Records for Nuclear Power Plants) A-17 Regulatory Guide 1.94 (ANSI N45.2.5-1974, Quality Assurance Requirements for Installation,. Inspection, and Testing. of Structural Concrete and Structural Steel During the Construc-tion Phase of Nuclear Power Plants) A-18 Regulatory Guide 1.116, June 1976 ( ANSI N45.2.8-1975, l Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants) ' A-20 Regulatory Guide 1.123, October' 1976 ( ANSI N45.2.13-1976, l Quality Assurance Requirements for. Control of Procurement of Items and Services for Nuclear Power Plants) .A-22 ANSI N45.2.12-1974, Draft 3, Rev. 4, February 22,-

1974, l

Requirements for Auditing of Quality Assurance Programs for.- ( Nuclear Power Plants BQ-TOP-1 Rev. 3A ' A -1 - October 1980 ~ c w P -F-

APPENDIX A e Regulatory Guide 1.37 (ANSI: N45.2.1-1973, Cleaning of Fluid Systems [. and Associated Components During Construction Phase of Nuclear Power Plants) The requirements of-the' referenced standard as modified in the regula-tory position will be applied to cleaning activities specified or applied by Bechtel to safety-related items as modified and interpreted below.

1) Section 2.1, ' Planning.

The required planning is fre-quently performed - on a generic basis for application to many installations on one or more projects..This results in standard procedures or ' plans for installation and inspec-tion and testing which meet the requirements of the stan-dard. Individual plans for each item or system.are not normally prepared unless the work operations are unique. However, standard procedures or plans will be reviewed for applicability in each case. Installation plans or proce-dures are also limited In scope to those actions or. activi-ties which are essential to maintain or achieve required quality. This is consistent with Section II, Paragraphs 2 and 3 of ANSI N45.2-1971 which provides for examination, measurement, or testing to assure quality or indirect control by monitoring of processing methods.

However, final cleaning or flushing activities will be performed in accordance with procedures specific to the system.

-(

2) Section 4,- Preinstallation Cleanliness.

This section states, " Items should not be delivered to the point of installation' site sooner than necessary unless the installed location is considered a better storage area." As an alternate to this requirement, items may be delivered to the installation site sooner than absolutely necessary when determined to be advantageous for other considerations, for example, re-duced handling or easier access, thereby reducing suscep-tibility to handling damage. in all such cases, equipment 4 stored in place will be protected in accordar.ce with Sec-tion 5 of ANSI N45.2.1.

3) Section 3.1.2, Bechtel interprets the lighting level of 100 footcandles to be guidance.

It is Bechtel's normal practice that the lighting level for determining " metal clean" of accessible surfaces of piping and components is determined by the inspector. Typically he uses a standard two-cell flashlight supplemented by other lighting as he deems necessary. h ( BQ-TOP-2 Rev. 3A A-3 October 1980

T , APPENDIX A .= o. '6) '. Appendix, A 3.4.2, Inert Gas' Blankets. There may J be -

(-

cases involving large. or complex shapes for which an inert or dry afr purge flow is provided rather 'than a static' gas - blanket.in. order, to provide adequate protection due. to difficulty of providing:a leakproof barrier. In these cases a positive - pressure purge -flow may be utilized as.an alternative to the leakproof. barrier. ( L(. BQ-TOP-1 Rev. 3A A-a

October l'J80

v E APPENDIX A c I Regulatory Guide 1.58, dated August 1973 (ANSI N45.2.6-1973, Qualifi-cation of Nuclear Power Plant _ Inspection, Examination and Testing Personnel) The requirements of the referenced standard, as modified and inter-preted in the regulatory position will be applied to the Bechtel Quality Program -during.the construction phase.as. described in Section 2.5 of this report, subject to the _ following clarifications:

1) Substitute new Sections 1.1 and.1.2 and modify first paragraph only of 1.3.

Section 1.1, Scope This standard delineates the requirements for qualification of personnel who perform inspection, examination, and testing. to, verify conformance to specified requirements of nuclaar facility items (structures, systems, and components of nuclear power plants, fuel reprocessing plants, pluto-nium _ processing plants, and plutonium fabrication plants) whose satisfactory performance is required to prevent postulated accidents which could cause undue risk to the health and safety of the public; or to mitigate the conse-quences of such accidents if they were to occur. The .(.- requirements may also be extended to other items of nuclear facilities when specified in contract documents. Section 1.2, Applicability l The requirements of this standard apply to personnel who perform inspections, examinations, and tests during fabri-cation prior to and during receipt of items at the construc-tion site, during construction, during preoperational and startup testing, and during operational phases of nuclear facilities. The requirements of this standard do not apply to personnel who perform inspections for goverreaent or municipal authorities, or who perform as authorized inspec-tors in accordance with the ASME Boiler and Pressure Vessel Code. The requirements of this standard are not intended to apply to personnel who only_ perform inspection, exami-nation, or testing in accordance with employer practices which are in compliance with " Recommended Practice No. SNT-TC-1 A," since these personnel are certified in accor-l dance with the requiraments of SNT-TC-1A and its appli-cable supplements. The requirements of this standard are optional, at the discretion of the employer, for application to personnel who perform calibration, or to craftsmen who l perform installation checkoute as pyt of their basic instal-lation responsibility to ready the installation for preopera- .(' tional testing. BQ-TOP-1 Rev. 3A A-7 October 1980

APPENDIX A (

4) The requirements of this standard shall apply only to personnel who perform inspection,

examination, and testing, and accordingly, Sections 3 and 3.1 shall be revised to read: 3. Qualifications 3.1 General The rec uirements contained within this section define t le minimum capabilities that qualify per-sonnel to perform !nspections, examinations, and tests which are within the scope of this standard. There are three levels of qualification. The re-quirements for each level are not limiting with regard to organizational position or professional status, but rather, are limiting with regard to functional activities which are within the scope of this standard. Following is the recommended personnel education and experience for each level. These education and experience recommendations should (be treated to recognize that other factors may provide reason-able) assurance that a person can competently ( perform a particular task. Other factors which may demonstrate capability in a given job are previous performance or satisfactory completion of capability testing.

5) The education and experience requirements shall make provision for personnel who have not graduated from high school, or who have earned an Associate degree.

Accord-ingly, paragraphs 3.1.1, 3.1.2, and 3. ) 3 shall be revised to read: 3.1.1 Level I (1) Two years of related experience in equivalent inspection, examination, or testing activities, or (2) High school graduation and six months of related experience in equivalent inspection, examination, or testing activities, or (3) Completion of college level vark leading to an Associate degree in a related discipline plus three months of related experience in equiva-lent inspection, examination, or testing activ-ities BQ-TOP-1 Rev. 3A A-9 October 1980 l

C APPENDIX A (4) rour-year college graduation plus five years ( of related experience in equivalent inspection, examination, or testing activities. At least two years of this experience should be asso-ciated with nuclear facilities; or, in lieu of two years' experience, the individual shall have training sufficient to be acquainted thoroughly with the quality assurance aspects of a nuclear facility.

6) Section 3.2.1, Physical (revise to read):

Bechtel shall identify any special physical characteristics needed in the performance of each activity. Personnel requiring these characterisitics shall have them verified by examination at intervals not to exceed one year.

7) Section 3.2.2, Technical (revise to read):

a. Level I Personnel Capabilities A Level I person shall be capable of performing the inspections, examinations, and tests that are required to be performed in accordance with documented pro-cedures and/or industry practices. The individual shall be familiar with the tools and equipment to be ( employed and shall have demonstrated proficiency in their use. The individual shall also be capable of determining that the calibration status of measuring and test equipment is current, that the measuring and test equipment is in proper condition for use, and that the inspection, examination, and test procedures are approved. b. Level 11 Personnel Capabilities A Level 11 person shali have all the capabilities of a Level I person. Additionally, a Level II person shall have demonstrated capabilities in planning inspections, examinations, and tests; in setting up tests, including preparation and setup of related equipment, as appro-priate; in supervising or maintaining surveillance over the inspections, examinations, and tests; in super-vising and certifying lower level personnel; in re-porting inspection, examination, and testing results; and in evaluating the validity and acceptability of inspection, examination, and test results. ( BQ-TOP-1 Rev. 3A A-11 October 1980

APPENDIX A TABLE 1 MINIMUM LEVELS OF CAPABILITY FOR PROJECT FUNCTIONS Project Function Level L-I L-II L-III Recording inspection, examination, and X X X testing data Implementing inspection, examination, and X X X testing procedures Planning inspections, evaluations, and tests; X X setting up tests, including preparation and setup of related equipment Evaluating the validity and acceptability of X X inspection, examination, and testing results Reporting inspection, examination, and testing X X results Supervising equivalent or lower level X X personnel Qualifying lower level personnel X X Evaluating the adequacy of specific X programs used to train and test inspection, examination, and testing personnel Reviewing and approving inspection, X examination, and test procedures Evalu ting the adequacy of activities X to acccmplish inspection, examination, and test objectives ( BQ-TOP-1 Rev. 3A A-13 October 1980

y APPENDIX A

4) Section 10, Records.

In-process documentation,- relating (: to checking - and coordination of drawings (for example, check and coordination arints) or copies of marked-up - ' specifications used to so icit comments shall be retained until the drawing 'or s aecification is approved and issued for use outside of Bec;1tel Engineering. Such in-process documents. will be available for review / audit until the document.is approved, but -may be discarded once the-document has been approved. In the first sentence of the second _ paragraph the phrase " final design documents" shall mean those documents which are the latest revision that has been issued for use.

5) Regulatory. Position, Section C-2:

If, in an exceptional circumstance, the originators' immediate supervisor is. the .only technically qualified individual available, the design verification or checking will be conducted by the super-visor with the following provisions: a. The other: requirements of Regulatory Guide 1.64 will be met. b. The justification will be individually documented and approved by the next level of-supervision. (. c. Quality. Assurance audits will include review of the frequency and effectiveness of the use of the immediate supervisor to assure that this provision is used only in exceptional circumstances. J BQ-TOP-1 -Rev. 3A A-15 October 1980 >.e.%._c_

APPENDIX A o- / Regulatory Guide 1.94 - (ANSI N45.2.5-1974, Quality Assurance Require-t- ments for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power. Plants) The requirements of the referenced ' standard will be applied to the Bechtel Quality Program for construction of. safety-related items as fo; lows: . Any exceptions to. ANSI N45.2.5 and/or Regulatory Guide 1.94 will be resolved with the NRC during licensing on an Individ-ual project basis. I l-i k i ' BQ-TOP Rev. 3A A October 1980

APPENDIX ; A.' r S

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5).- Section~ 4.6, - Care.of Items.

Bechtel, acting ' as Con - structor or Construction Manager, is.arsumed to have authority and is the " responsible organization" 'for tem---- porary. usage of equipment or facilities unless specifically prohibited. by contract or in writing from.the client. All ~ other conditions-and. considerations for temporary use :in this section will be app!!cd. O BQ-TOP-1. - Rev. 3A-A-19 October 1)80 p

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n APPENDIX A e

[:: ' supplier has. fulfilled;~ procurement ' document requirements and whether.or not a '. certification system is effective. i b i i t + 1 - 4 -{ i .BQ-TOP-1 r-. Rev. 3A A-21 October 1980 - 4 1 g g +- -f*4 m e yge 9 =yd 9-29-7 f '**F d q T

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APPENDIX A .o The annual audit requirement shall not apply to standard [- off-the-shelf items and bulk commodities where required quality can adequately be determined by receipt inspection or post-installation checkout or test.

6) Section 3.4.3.6, (Verification).

Delete this section. Section 4.5, follow-up, By Auditing Organization, will provide adequate coverage of the verification process without resorting to an audit, audit reports, etc. Verifi-cation will be accomplished during the performance of follow-up action by the auditing organization.

7) Section 4.3.3, Post Audit Conference.

Delete the last sentence. The minutes of the post audit conference are - recorded and distributed to the attendees and management. It is not considered necessary to have the auditing organi-zation and the audited organization sign these minutes to signify understanding. ( t BQ-TOP-1 Rev. 3A A-23 October 1980

. e := ( APPENDIX B DIVISION QUALITY POLICIES, SCOPE, AND RELATIONSHIP TO 10 CFR 50, APPENDIX B Page Title. B-2 Nuclear Quality Assurance Manual San Francisco Power Division B-3 Quality Program Manual Los Angeles Power Division -( B-4 . Nuclear Quality Assurance Manual Gaithersburg Power Division ( BQ-TOP-1 Rev. 3A B-1 October 1980

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' HOUSTON LIGHTING'AND POWER COMPANY - QUALITY ASSURANCE PROGRAM DESCRIPTION ~ SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION ' QUALITY-ASSURANCE DURING DESIGN AND CONSTRUCTION - i s t e \\i

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G .s; e. ATTACHMENT 1 QUALITY ASSURANCE PROGRAM DESCRIPTION 4 South Texas Project Electric Generating Station Quality Assurance During Design and Construction Houston Lighting &- Power Company (HL&P),' as a licensee and as Project-Hanager for itself and the other owners,'has quality assurance responsibility for design, engineering, procurement; fabrication, construction and operation associated with the South Texas Project Electric Generating Station (GTP). Although HL&P has delegated certain of its quality assurance authority to its contractors, it nevertheless retains the responsibility for the quality assurance program controlling all aspects of the STP. -As an initial step in fulfilling its responsibility, HL&P establishes quality assurance requirements for the project in a Project Quality Assurance Plan..The Project Quality. Assurance Plan specifies requirements applicable to prime contractors and HL&P. The HL&P quality assurance staff monitors the performance of HL&P staff and contractors-to assure compliance.with the Project Quality Assurance Plan. HL&P has contracted with Westinghouse Electric Corporation (Westinghouse) for the design, fabrication and quality assurance services for the nuclear steam supply system and with Bechtel Power Corporation'(BPC) for plant design, procurement, engineering, construction management, quality assurance services anf other related services, including quality assurance services for Westinghouse items-upon receipt at the project site. This quality assurance program 1 description addresses the HL&P quality assurance program (Part A) and the quality assurance program of BPC (Part B). The Westinghouse quality assurance program is described in WCAP-8370, " Westinghouse Nuclear Energy System Divisions Quality Assurance Plan" and is not included in. this program description. 4 b ,A, y + v g.

r .c-HOUSTON LIC" TING & POWER COMPANY QUALITY ~ ASSURANCE PROGRAM DESCRIPTION Table of Contents SECTION~ TITLE PAGE' l.0- ' Organization 2 2.0 ' Quality Assurance Program 11 3.0-Design Control 14 4.0 Procurement Document Control 16 - 5.0 Instruction, Procedures and Drawings-18 6.0 Document Control 18 7.0-Control of Purchased Material, Equipment and Services-19 8.0 . Identification and Control of Material, Parts and Components 22 9.0 Control of Special Processes 23 10.0 Inspection 24 11.0 Test Control 25 12.0 Control-of. Measuring-and Test Equipment 26 13.0 Handling, Storage and Shipping 27 14.0 Inspection, Test and Operating Status 27 15.0 Nonconforming Materials, Parts or Components 28 '16.0 Corrective Action 28 17.0 Quality Assurance Records 29 18.0 Audits 29 c.

- ; =.w s ..; e HOUSTON LIGHTING'&. POWER COMPANY ' QUALITY ASSURANCE PROGRAM DESCRIPTION ' List of Tables NUMBER TITLE 'l Plan / Procedures used.co Implement Quality for the Major ~ Activities 2 ANSI Standard and Regulatory Guide ' Compliance ~ List of Figures -NUMBER TITLE 1- . South Texas Project Internal-QA Relationship 2' Lines of Communication HL&P-&-BPC/ Westinghouse (Contractors) J I f l l t l.

ATTACHMElff 1 PART A HOUSTON LIGHTING & POWER COMPANY QUALITY ASSURANCE PROGR/.!! DESCRIPTION South Texas Project Electric Generating Station Quality Assurance During Design and Construction Houston Lighting & Power Company (HL&P), as a licensee and as Project Manager for itself and the other owners, has the Quality Assurance (QA) responsibility for design, engineering, procurement, fabrication, construction, preoperational testing and operation of the South Texas Project (STP) Electric Generating Station. HL&P's Quality Assurance Plan requires that HL&P, its prime contractors, subcontractors and vendors comply with the criteria established by 10CFR50 Appendix B. It is the intent of HL&P to comply with ANSI N45.2 and the applicable daughter standards and implementing Regulatory Guides as indicated in Table 2. Furthermore, HL&P will assure through programmatic direction that the Prime Contractors and all their subcontractors and suppliers performing nuclear safety-related work comply with 10CFR50 Appendix B, ANSI N45.2, and the Regulatory Guides as referenced herein consistent with their scope of work. Programmatic direction is defined as the role of the owner in establish-ing the program requirements and ensuring the adequacy of the Prime Design, Engineering and Construction Management Quality Assurance Program. The programmatic direction consists of review and approval of the system features initially and continued monitoring of those systems during implementation and further refinement or revision of the systems if the systems need strengthening. The assurance of compliance by first level nuclear safety-related suppliers and contractors will be accomplished through the Engineer / Construction Manager's review and approval of the supplier's/ contractor's Quality Assurance Program. The system monitoring is achieved through audits and surveillance of work in progress. The HL&P Quality Assurance program is implemented in two phases: the design and construction phase as defined by the Project Quality Assurance Plan and the operational phase, including preoperational testing and startup, as defined by the Operational Quality Assurance Plan. The Project QA Plan is described herein. The Operational QA Plan is described in Chapter 17 2 of the FSAR. The combination of these Quality Assurance programs augmented by definitive procedures provide HL&P with the assurance that its quality commitments are met. { I

.o 1.0 Organization 1.1 The organization chart shown in figure 1. illustrates: (a) groups within HL&P having quality responsibilities (engineering, procurement construction) and (b) Quality Assurance interdepartmental: relationships for the -South Texas Project. 1.2 ' The Project Quality Assurance Manager, South Texas Project, is responsible for providing the programmatic direction, and administering policies. goals, objectives and methods which are described in the Project Quality Assurance Plan. The HL&P Executive Vice President, Nuclear Group reviews and approves the Project Quality Assurance Plan and has ultimate responsibility for Quality Assurance activities. The Project Quality Assurance Plan interfaces sdth the corporate Quality Assurance program objectives by describing specific Quality Assurance controls to be established by HL&P and the prime contractors on the South Texas Project. 13 Two levels of control have been implemented by HL&P to monitor the effectiveness of the Quality Assurance Programs at the South Texas Project. ~ a) Corporate level control - Corporate level control is t*,hieved through the direct _ involvement of the HL&P-Executive Vice President, Nuclear Group and corporate audits and vendor surveillance as described below. The Executive Vice President regularly meets with QA management and receives reports on the status of the QA Programs to aid him in evaluating the overall effectiveness. Corporate QA audits and vendor surveillance are conducted under the direction of the Manager, QA to evaluate the overall program effectiveness of HL&P Project QA, Westinghouse and its suppliers. Corporate audits of the Architect Engineer / Construction Manager's activities may be performed as requested by the Project QA Manager. b) Project level control - Project level control is achieved through Project QA Program approval and monitoring of the effectiveness of implementation by HL&P, prime contractors and subcontractors. The Project QA staff under the direction of the Project QA Manager prepares the Project QA ~ Plan and reviews and approves the Project QA Program for the Architect Engineer / Construction Manager. The monitoring is implemented by scheduled project audits performed by~ qualified auditors. Additional monitoring is accomplished by Project QA personnel performing unscheduled selected surveillance of in-process work. HL&P Project QA also maintains the capability to perform inspection verifications of in-process or completed work if determined to be nececaary by the Project QA Manager. If necessary the inspections are performed by personnel qualified in accordance with ANSI N45 2.6. 2

1.3.1 Manager, Quality Assurance The Manager, Quality Assurance, has the authority. -and responsibility to identify, initiate, recommend, or provide solutions to quality related problems and verify the implementation and effectiveness of the solutions. He has the authority to "Stop Work" for cause in the design, construction and operation phase of the nuclear plant. The minimum _ requirements established for this position are: A college degree in a field of engineering or a.- ~ science, or equivalent experience. b. Familiarity with nuclear power generation facilities and the related operations. Knowledge of the industry's quality assurance c. standards and' regulatory requirements. d. Management experience and familiarity with HL&P corporate organizations.' The Manager, Quality Assurance, provides technical guidance and administrative direction to: a. Support QA Manager b. Operations QA Manager The Manager, Quality Assurance, reports to the Executive Vice President, Nuclear Group. 1 3.2 Project Quality Assur_ance Manager, South Texas Project The Project Quality Assurance Manager, South Texas Project, has the responsibility to identify, initiate, recommend, or provide solutions and authority to solve quality related problems and to verify the implementation and effectiveness of the solutions. He has the authority to "Stop Work"= for cause on any quality-related activity of the South Texas Project. The Project Quality Assurance Manager, South Texas Project, must, as a minimum, have: A college degree in a field of engineering or a. science, or equivalent experience. 3

a b. Familiarity with nuclear power generation facilities and related operations. c. Knowledge of the Quality Assurance standards and regulatory rwquirements. d. Management experience and familiarity with HL&P corporate organizations. The major responsibilities of the Project QA Manager, STP, are: a. Develop and administer QA policies and, ensure the proper planning, development, implementation, coordination and administration of the Project Quality Assurance Plan. b. Provide programmatic direction on QA related matters to HL&P, and contractor management, and provide the primary interface with NRC. c. Coordinate activities relating to auditing and vendor surveillance in conjunction with the HL&P Support Quality Assurance Manager. The Project Quality Assurance Manager reports on all quality assurance matters directly to the Executive Vice President, Nuclear Group. The Project QA Manager receives administrative guidance from the Manager, QA. This organizaticnal arrangement provides independence from cost and scheduling influences. 133 Support Quality Assurance Manager The Support Quality Assurance Manager reports on all technical ano administrative matters directly to the Manager, QA. This organizational arrangenent provides independence from cost and scheduling influences. The Support Quality Assurance Manager is responsible for directing all HL&P corporate office auditing, vendor surveillance and technical services activities. He has the authority to "Stop Work" for cause on any quality-related i activity of the South Texas Project. The Support Quality Assurance Manager must, as a minimum, have: 4

A college degree in a field of engineering or s. science, or equivalent experience. b. Familiarity with nuclear power generation facilities and the related operations. c. Knowledge of the industry's Quality Assurance standards and regulatory requirements. d. Management experience and familiarity with HL&P corporate organizations. The major responsibilities of the Support Quality Assurance Manager are: a. Provide administrative guidance and direction for the HL&P Corporate Quality Assurance Audit Program. b. Direct the HL&P NSSS vendor surveillance programs. Manages the Technical Services Organization c. of the support division. 1.3.4 Project Quality Assurance General Supervisor, Quality Engineering The Project Quality Assurance General Supervisor, Quality Engineering reports directly to the Project Quality Assurance Manager, South Texas Project. He is responsible for technical direction and administrative guidance to the discipline Quality Engineering personnel, providing programmatic direction to prime contractors and interfacing with the NRC. He is responsible for directing the onsite audit and surveillance activities. He has the authority to "Stop Work" for cause on any activity related to fabrication and construction. 1.3.5 Supervisor, Quality Systems / Administration The Supervisor, Quality Systems / Administration reports directly to the Project Quality Assurance Manager, South Texas Project. He is responsible for providing technical direction and administrative guidance to the site Quality Systems personnel; developing and administering the HL&P Project QA Plan; evaluating the Engineer / Construction Manager's QA program; administering the HL&P STP QA personnel training and certification program; administrative control of 5

7 HL&P STP project quality assurance procedures and providing mechanisms to correct the QA programs as necessa ry. He has the authority to "Stop Work" for cause on any activity related to fabrication or construction. 1.3.6 Supervisor, Quality Control The Supervisor, Quality Control reports directly to the Project Quality Assurance Manager, South Texas Project. He is responsible for technical direction and administrative guidance to the HL&P Quality Control personnel, coordinating inspection of selected fabrication and construction activities, ensuring proper nonconformance identification and assuring that'the personnel performing inspections are properly certified. He has the authority to "Stop Work" for cause on any activity related to fabrication or construction. 1 3.7 Quality Engineering (QE) Project Quality Assurance Supervisors The QE Project Quality Assurance Supervisors report to the Project Quality Assurance General Supe rviso r. They are responsible for technical direction and administrative guidance to the HL&P Quality Engineering personnel in their respective discipline group; conducts audits of the Construction Manager and contractor activities, including QA; interface with NRC during audits; identifying' deficiencies; reviewing procedures applicable to their respective discipline; and providing programmatic direction to the prime contractor. They have authority to "Stop Work" for cause on any activity related to fabrication or construction. 1.3.8 Design Office Project Quality Assurance Supervisor The Design Office Project Quality Assurance Supervisor reports directly to the Project Quality Assurance Manager, South Texas Project. He is responsible for providing technical direction and administrative guidance to HL&P Design _ Office Quality Assurance personnel, coordinating the resolutions of vendor problems identified by HL&P QA, coordinating with site QE personnel for input to vcador surveillance / audit activities and providing programmatic direction to the Engineer / Construction Manager regarding design control, vendor surveillance and auditing functions. He is responsible for directing audits / surveillance of 6

~ 4 -! i i the Engineer's design,-procurement and Engineering ' activities, including QA. He has the authority to "Stop Work" for cause on~any' activity related to ~ engineering, design, or procurement.- 1.3.9 Manager, South Texas Project-The Manager, South Texas Project reports to the HL&P Vice-President, Nuclear Engineering and Construction. He has overall responsibility for the engineering, construction, procurement, cost, schedule, and startup of the South Texas Project. He has authority to "Stop Work" for cause in all activities of the project. 1 3.10 Manager, Support Services The Manager, Support Services reports to the Manager, South Texas Project. He is responsible for procurement, project control services, accounting, project administration, contract administration and records management services. He has the authority to "Stop Work" for cause in activities related to purchasing and expediting. 4 1.3.11 Manager, Engineering 4 The Manager, Engineering reports to the Manager, South Texas Project. He directs project engineering personnel in the performance of the owner's review of the design and engineering work performed by the prime contractors. The Manager, Engineering ensures that adequate engineering planning and coordination of solutions to problems and work priorities are established by the prime contractor. He has the authority to "Stop Work" for cause in the engineering and design of all items. 1.3.12 Supervising Project Enginc Components e. Engineering The Supervising Project Engineer, Components Engineering reports to the_ Manager, Engineering. 3 He is responsible for direction coordination and administration of the components engineering functions. This work includes engineering planning, coordination of solutions to problems, and work priorities in the areas of components and physical design performed by the prime contracters. He can recommend "Stop Work" for j cause in the engineering and design for those { items within his area of responsibility. ) 4 7

1.3.13 Supervising Project Engineer, Site Engineering The Supervising Project Engineer,_ Site Engineering reports to the Manager, Engineering. He also receives Project direction from the Project Site Hanage r. He is responsible for coordinating the site engineering interface in the technical resolution of all site related engineering problems, reviewing field change requests, and site-initiated design change notices. He assists in the release and interpretation of design documents. He can recommend "Stop Work" for cause in the engineering and design for those items within his area of responsibility. 1.3.14 Supervising Project Engineer, Systems Engineering The Supervising Project Engineer, Systems Engineering reports to the Manager, Engineering. He is responsible for direction, coordination and administration of the Systems Engineering functions. This work includes interfacing with prime contractors in the area of engineered systems, fluid and electrical. He can recommend "Stop Work" for cause in the engineering and design for those items within his area of responsibility. 1.3.15 Leader, Engineering Administration The Leader, Engineering Administration reports to the Manager, Engineering and is responsible for the control, distribution and maintenance of engineering manuals and documents. 1.3 16 Supervising Engineer, Licensing The Supervising Engineer, Licensing reports to the Manager, South Texas Project. He is responsible for overseeing, coordinating and administering the South Texas Project Licensing effort. 1.3.17 Team ueader, Licensing The Team Leader, Licensing reports to the Supervising Engineer, Licensing. He is responsible for coordinating alt regulatory activities related to the nuclear safety analysis and licensing of the South Texas Project. He is the chairman of the Incident Review Committee. i 1 8

1.3.18 Records Management System Manager The Records Management System Manager reports to the Manager, Support Services. He is responsible for managing the Records Management personnel and interfacing with the prime contractors and all project organizations with respect to the establishment of systems that control, collect, store and transfer records related to the South Texas Project. 1 3 19 Project Site Manager The Project Site Manager reports to the Manager, South Texas Project. -He is responsible for providing technical direction and administrative guidance to HL&P and its prime contractors in the area of construction, site purchasing, security, startup, accounting, construction control and reviewing documents, drawings and specifications related to construction. He also provides administrative guidance for HL&P site engineering. He has the authority to "Stop Work" for cause in all activities related to construction. 1 3.20 startup Manager The Startup Manager reports to the Project Site Manager. He is responsible for conducting and recommending for acceptance the facility startup test program. He reviews and recommends approval of startup test reports, instructions, and procedures which assure conformance to design and safety requirements. The final approval authority for the startup program is the Plant Superintendent's responsibility. 1 3.21 Startup General Supervisor The Startup General Supervisor reports to the Startup Manager. He works as directed by the Startup Manager and assists in the effective administration, control, and implementation of the test program. 1 3.22 construction Superintendent The Construction Superintendent reports to the Project Site Manager. This position is responsible for ensuring that the prime contractors comply with all contractual and construction requirements, evaluates and ensures that work is preplanned, that work packages are i i 9

.being utilized in a timely and effective manner and provides recommendations for conduct of construction activities. 1.3.23 Construction Engineering Supervisor The Construction Engineering Supervisor reports to the Construction Superintendent. He is responsible for providing technical and administrative support to all HL&P Construction Engineers. He coordinates preparation and issuance of Project-Site Procedures. -1.3.24 Construction Area Supervisor (s) 4 The Construction Ares. Si pervisor(s) reports to the Constru: tion Superintencent. They are responsible for monitoring and surveillance of the prime contractor's construction activities, expediting the resolution and corrective actions of problems identified by QA/QC and verifying that construction planning includes requirements for inspection and testing. 1.3.25 Project Purchasing Manager The Project Purcha' sing Manager reports to the Manager, Support Services. He is responsible for the overall coordination and administration of purchasing and subcontracting activities for the South Texas Project including the development and implementation of procedures, vendor selection, contract negotiatisns and preparing purchase orders for those prime contracts to HL&P. 1.3.26 Supervisor (s), Project Purchasing The Supervisor (s), Project Purchasing report to the Project Purchasing Manager. They are responsible for the development and implementation of procedures related to purchasing, material control and contract administration for HL&P direct procurement. They assist in the detection and resolution of procurement problems. The Site Supervisor, Project Purchasing reports for project direction to the Project Site Manager. 1.3.27 Contract Administrator The Contract. Administrator reports to the Manager, Support Services. He is responsible for preparing .the scope of contracts, implementing procedures and reviewing' invoices to assure contract 10 l

compliance for prime contractors. He participates in contract negotiations, contract changes and operation monitoring to ensure contract compliance for prime contractors. 14 The organizations or entities listed below may be delegated quality assurance authority within their scope of work. HL&P has the responsibility to audit and nanitor all of the below listed organizations' or entities' performance to assure that their quality programs provide sufficient authority and organizational f reedom for personnel performing QA functions and that they are effectively implementeo. Houston Lighting & Power Company as a licensee and Project a. Manager for itself and the other owners has the overall responsibility for design, engineering,. procurement, construction, operation ano quality assurance activities. Bechtel Power Corporation and Westinghouse Electric Corporation have contractual responsibility to provide acceptable QA programs to HL&P. The contract provides HL&P the authority to audit and monitor BPC and, Westinghouse performance to assure that the Quality Assurance Programs provide for sufficient authority and organizational freedom to be effectively implemented. b. Bechtel Power Corporation as the Architect / Engineer and Construction Manager provides HL&P with design, engineering, procurement, construction management, and quality assurance services. Westinghouse Electric Corporation as the Nuclear Steam c. Supply System (NSSS) supplier provides HL&P with the NSSS design, engineering, procurement, fabrication, and quality assurance services. d. Constructor - Shall provide HL&P with construction quality assurance and quality control services under the direction and as approved by the Construction Manager. Consultants - HL&P utilizes the services of qualified e. consultants to assist in the performance of quality tasks. Figure 2 illustrates how these companies interrelate with HL&P for the South Texas Project. 2.0 Quality Assurance Program 2.1 The HL&P Project Quality Assurance program for the South Texas Project has been developed in accordance with the criteria of 10CFR50 Appendix B, ANSI N45.2 and Regulatory Guides as referenced herein, to provide programmatic direction on quality requirements for the prime contractors and subcontractors during design and construction. 1 i 11

M 2.2 The nuclear _ safety-relatei-structures, systems and components covered by this progra4. ara listed-in Section 3.2 of the FSAR. Westinghouse Electric Corporation provides quality assurance services for the items listed in~ Table'3.2.B-1 of the FSAR until delivery to the site. Bechtel Power Corporation,'the prime contractor for construction management, provides quality-assurance services for the items listed in Table 3.2.A-1 of the ~ FSAR and QA responsibility within the BPC scope of work for the Westinghouse items (Table 3.2.B-1) upon receipt at the site. . 2.3 The HL&P Quality Assurance program for'the South Texas Project is described by the HL&P Project Quality Assurance Plan. The plan requires that1 written procedures, training and certifica-tion, issuar.ce of specifications and drawings, and work and inspection planning be accomplished in advance of performing nuclear safety-related activities. HL&P Project Quality Assurance ensures through procedure reviews that this advance preparation is accomplished. The Project Quality Assurance Plan for the South Texas Project (STP) has in the past been structured in accordance with the Regulatory Guides (RGs) and Industrial Standards that are addressed in the NRC publications " Guidance on'QA Requirements During Design and Procurement Phase of Nuclear Power Plants," (The Gray Book) Revision 1, dated May 24, 1974 (WASH 1283) and " Guidance on QA Requirements During the Construction Phase of Nuclear Power Plants," (The Green Book) dated May 10, 1974-(WASH 1309). Presently the regulatory guides and standards listed on Table 2 are in effect for the South Texas Project. 2.4 The HL&P Plans and Procedures which are used to implement the quality related activities for each major organization and the reference to the applicable criteria of 10CFR50 Appendix B are listed in Table 1. Verification that plans and procedures are + properly implemented is accomplished by HL&P Quality Assurance through audits, surveillance and regular management assessment of the Quality Assurance Program. 2.5 lt is the policy of HL&P acting as a licensee and Project Manager for the other owners for the South Texas Project 1 Electric Generating Station (STPEGS.' to assure that the design, fabrication, construction, testing, ano operation of STP are in conformance with project specifications, procedures, codes, and NRC regulations. It is the responsibility of each organization assigned to the STPEGS to ensure that project procedural review methods include provisions to ensure that the requirements stated in this program description are incorport " into 4 project procedures. The Project Quality Assurance Plan identifies activities and establishes requirements for procedures which identify, initiate and verify the resolution 4 of nuclear safety-related quality problems. The implementing procedures call for the resolution of quality problems at the lowest possible authorized level. However, if a dispute is - encountered in the resolution of a quality problem which cannot 12

~. s . r - be resolved at ~1ower. levels, the' Project. Quality Assurance. Manager, presents the problem ultimately to the HL&P Executive ' Vice-President, Nuclear Group for resolution. f 2.6 HL&P. Quality Assurance -Department ~is responsible for' conducting s' quality oriented-indoctrination program for new HL&P: personnel who have quality-related functions. ~ The HL&P Project - Quality-Assurance Plan requires that prior to performing activities-affecting quality the-personnal are trained,'as: necessary, in the applicable procedures.. The training provides.

aLthorough understanding of the purpose, scope, policies,

= principles, and. techniques of the specific procedures or

instructions. -When personnel perform special process l

1 activities, a' training and certification program is' established l. and maintained. Refresher 1 training is conducted as necessary. [ to. ensure that. proficiency is maintained. Bechtel is required. to establish a training program ~for Bechtel and administer the' constructor's -training program ' including refresher training, as j. necessary. to ensure proficiency is achieved and maintained. 4 ' HL&P Quality Assurance. audits and surveillances are performed to ensure compliance with these criteria. { 2.7 The ProjIect Quality Assurance Manager, is diredtly responsible-for assuring -effective implementation of the Quality Assurance program. The qualifications for this position are defined in i Sectica 1 3. 2.8 The HL&P -Project Quality Assurance Plan requires BPC to review and approve these-procedures which control nuclear safety-related construction activities. It is the responsibility of BPC's Project Quality Assurance to determine that the contractor's procedures require proper equipment, environment and other prerequisites to perform the ' associated activity. The implementation of these requirements is verified through audits and surveillance by BPC QA. p 2.9 The results of the HL&P QA audit and surveillance activities are presented in a periodic report to the HL&P Executive Vice President, Nuclear Group.. Regular executive management review of these activities and~the direct-involvement of the HL&P l Executive Vice President, Nuclear Group assures that an + objective program assessment of the South Texas Project Quality i Assurance programs is being. performed. HL&P STP Quality. Assurance reviews and documents approval of the Bechtel Project Quality Program Manual (PQPM); and audits j' and'surveillances are performed by HL&P Quality Assurance to l ensure compliance with the BPC PQPM. I h F [. f.- 13 ..am-y-.- ,. -., _ +. ,.i.-,,.., ,. _., +. .mn.v., ,4 m, w- ,smrcy.c.---

2.10 HL&P and Bechtel Project Quality Assurance will establish and document a program for transferring responsibilities and controla for quality-related activities from BPC to HL&P during phaseout of design / construction and plant turnover. This program will be implemented prior to preoperational testing. This program will be in accordance with and consistent with the requirements of this section and/or 17.2 of the FSAR. 211 HL&P is committed to maintaining the Project Quality Assurance Plan as an effective and meaningful document to provide programmatic direction to HL&P and the prime contractors on the South Texas Project. When proposed substantive changes to the Project Quality Assurance Plan affect the docketed Quality Assurance Program description HL&P will notify the NRC of the change (s) for their review and acceptance prior to implementation. Organizational changes of a substantive nature will be reported to the NRC within 30 aays of announcement. 3.0 Design Control HL&P has the overall responsibility for design and engineering of the South Texas Project and imposes the requirements of 10CFR50, Appendix B, Criterion III, Regulatory Guide 1.64 and ANSI N45.2.11 on the prime contractors and applicable subcontractors. HL&P ha's assigned the authority to BPC and Westinghouse to perform the design, engineering and design verification. HL&P, as appropriate, selects contractors / subcontractors to perform design related tasks. These tasks include but are not limited to the following: New design Special design studies Design work outside the scope of prime contractors Changes to existing design performed by contractors no longer associated with the South Texas Project. To be eligible to participate in design activities the contractor must be approved to assure he has the capability to perform the design or requested task in accordance with specified requirements. When a contractor has been selected, HL&P Manager, STP or designee shall ensure that all appropriate design background information with which to perform the task is provided. HL&P Engineering performs reviews of selected elements of the { completed design, design documents and specifications to ensure that contractual requirements are met. 14

^ The HL&P_ Manager, Engineering is responsible :for ensuring that project engineering activities are conducted in accordance with approved engineering procedures. -The ' project engineering organization providesl programmatic direction and overview of the engineering activities. The HL&P project engineering activities are conducted in accordance with Project Engineering Procedures.(PEP's). These procedures are delineated in Table I.= When HL&P has direct responsioility or assumes direct responsibility for conducting design activities, :these activities will be conducted in accordance wfth the, requirements of this section and/or the FSAR Section 17.2.3. HL&P contractors are required to provide the following design control measures in theirLquality assurance programs: A design control system is established to' document the methods of accomplishing and controlling essential design activities. Design documents such as calculations, ' diagrams, specifi i cations, and drawings are prepared and records developed such that the final design is traceable to its sources. Design activities, documents, and interfaces are controlled to assure that applicable input such as design bases, regulatory requirements, codes, and standards are incorporated into the final design. Design input requirements, including design criteria, are documented and their selection reviewed and approved. Design documents include an indication as to their importance to safety and shall specify the quality characteristics, including materials, parts, equipment and processes, that are essential to safety-related aspects of structures, systems, and components. Design documents also include, as appropriate, acceptance criteria for inspections and tests. Design control measures are applied to safety-related items such as seismic, stress, thermal, hydraulic, radiation, and accident analyses, as they apply to the development of design { input or as they are used to analyze the design. Safety-related designs, including Seismic. Category I designs are verified for adequacy and accuracy through independent objective review of design documents by individuals competent in the subject activity. This verification may include the use l of alternate or simplified solution methods or qualification testing, as appropriate. 4 Design changes, including engineering, vendor, and construction originated changes, are controlled in a manner commensurate with the control imposed on the original design. 15

s .3 9 Document. distribution is controlled such that all individuals using a~ design document'or its results and/or conclusions for, further 6esign work can 'be_ notified-~if the document is revised or-cancelled. Design documentation includes evidence that design control. requirements have been satisfied. Errors and deficiencies in approved design documents, including. design methods (such as computer codes), that could adversely affect' safety-related structures, systems and components are 4 - documented; and action taken to' assure that all errors and l deficiencies are corrected. ~ Deviations from specified quality standards are identified and 7 procedures are established-to ensure their control. An accurate' definition of the quality classes, including j. systems designated as safety-related is provided. HL&P LQuality Assurance performs audits of HL&P, BPC and Westinghouse i to ensure that _ design controls, requirements, specifications and 2 documents are in accordance with the design control-criteria. In addition HL&P Project Quality Assurance reviews selected 'l ' quality / construction procedures to ensure that the quality requirements of the design specifications are incorporated. HL&P Project Quality Assurance also performs audits and surveillances to ' ensure that the work-is accomplished in accordance with the design requirements and to ensure.that field changes to the design are {- processed in accordance with the design control criteria. 4.0 Procurement Document Control To assure that nuclear safety-related items are purchased in a planned and controlled manner, the HL&P Project Quality Assurance Plan establishes basic requirements which are to be used -by HL&P and prime contractors in. preparing procurement procedures for the South Texas Project. ' BPC performs procurement activities for nuclear safety-related equipment, materials and services, exclusive of the NSSS contract, which is performed by Westinghouse. BPC and Westinghouse verify-through contract, vendor surveillance and audit. that their suppliers' comply with the established requirements. When HL&P has direct responsibility or assumes direct responsibility for procurement activities, these activities will be conducted'in ^ accordance with the requirements of this section. The basic requirements are: T Written procedures are established clearly delineating the = sequence of actions ~to.be_ accomplished in the preparation, review, approval, and control of procurement documents. 16 ,r--, ew- ,w,,- y-. t-,,--+-+s ene--v v= - ---iir-i---w---- -*---v - - --w--+w w s-v- e

' A review of the adequacy of quality req"irements stated in = procurement documents is performed by usalified personnel knowledgeable in the QA requirements. This review is to determine all quality requirements are correctly stated; they can be inspected and contrclied; there are adequate acceptance and rejection criteria; and the procurement document has been prepared in accordance with QA Program requirements. Documented evidence of the review and approval of' procurement documents is provided and available for verification. Procurement documents identify those' quality assurance requirements which must be complied with and described in the supplier's QA Program to meet 10CFR50 Appendix B, ANSI-N.45.2 and applicable ANSI standards and reg. guides. This QA Program shall be reviewed for adequacy by qualified personnel knowledgeable in quality assurance. Procurement documents contain or reference applicable design bases, technical requirements including regulatory require-ments, component and material identification, drawings, specifications, codes, and industrial standards, including their revision status, tests and inspection requirements and instructions for such activities as fabrication, cleaning, erecting, packaging, handling, shipping, storing, and inspecting. Procurement documents contain as applicable, requirements which identify the documentation to be prepared, maintained, submitted, and made available to the procuring agent for review and/or approval, such as drawings, specifications procedures, inspection and test records, personnel and procedure qualifications, and material and test reports. Procurement documents contain the requirements for the retention, control, submittal and maintenance of records. Procurement documents contain the procuring agency's right of access to Vendor's facilities and records for source inspection and audit. Cnanges and/or revisions to procurement documents are subject to at least the same review and approval requirements as the original document. Purchase documents for spare or replacement parts of safety-related structures, systems and components are reviewed for adequacy of quality requirements by qualified personnel knowleageable in quality assurance. The review is to determine the adequacy of the quality assurance requirements and acceptance criteria relative to the original design. 17

The evaluation and selection of suppliers are determined by qualified personnel in accordance with written procedures acceptable to ~ HL&P. - Procurement documents,-records and changes thereto are collected, stored. maintained.and retrievable in a systematic and controlled manner.. HL&P Engineering is responsible for review of selected BPC p Procurement _ Specifications. HL&P Quality' Assurance is responsible for performing audits and surveillance ~ to verify that the requi'rements have been -implemented and that they are. effective. 5.0 ' Instructions, Procedures and Drawings The HL&P Project Quality Assurance Plan requires HL&P, the prime i ' contractors and their suppliers to establish and implement a Quality Assurance-Program which-is in compliance with 10CFR50 Appendix B, 'ANS1 N45.2 and applicable ANSI standards and reg. guides. Each program is required to be ef fective in verifying that the defined activities are accomplished and documented in accordance.with written procedures, instructions, and drawings and that they provide quantitative and qualitative acceptance criteria. HL&P Project ' Quality Assurance reviews and approves the BPC South Texas Project Quality Assurance Program. To measure the effectiveness of the prime contractors' quality assurance programs, HLhP Project QA has implemented a monitoring program consisting of 4 audits and.surveillances. HL&P Houston Quality Assurance also audits HL&P Corporate organizations that perform functions for the South Texas Project, HL&P Project QA and Westinghouse for compliance with their respective Quality Assurance Programs. 7 6.0 Document Control The HL&P Project Quality Assurance Plan and implementing procedures require that HL&P, the prime contractors and subcontractors implement a document control system for nuclear safety-related items for the South Texas Project. The established system ensures that 1 design, engineering, procurement, fabrication, construction, and QA/QC procedures, plans, and changes thereto are reviewed and approved. by procedurally authorized groups and that the documents are issued, maintained current ano controlled by the use of 4 controlled lists of document holders to ensure that superseded documents are replaced in a timely manner. heasures are established and documented to control the issuance of t' documents, such as instructions, pcocedures, and drawings, including changes thereto, which prescribe activities affecting quality. ] These measures assure that documents, including changes, are 1 reviewed for technical adequacy and the inclusion of appropriate i I 18 ,-,w-e -,-+-----,-.sn e,-m-va.,ww-. e-

quality requirements and approved for release by authorized personnel and are distributed to and used at the location where the prescribed activity is performed. Changes to documents are reviewed and approved by the same organizations that performed the original review and approval unless other organizations. are specifically - designated. The reviewing organizations have access to pertinent background information upon which to base.their approval and shall have adequate understanding of the requirements and intent of the original document. Those participating in-an activity are made aware of and use proper and current instructions, procedures, drawings, and engineering requirements for performing the activity. Participating organization have procedures for control of the documents and changes thereto to preclude the possible use of outdated or inappropriate documents. Document control measures provide for: identification of individuals or organizations responsible for preparing, reviewing, approving, and issuing documents and revisions thereto; identifying the proper documents to be used in performing the e activity; coordination and control of interface documents; a ascertaining that proper documents are being used; e establishing current and updated distribution lists; e a listing identifying the current revision of instructions, procedures, specifications, drawings, and procurement documents. The list is updated and distributed to pre-determined responsible personnel. HL&P Quality Assurance performs audits and surveillances to verify that document conttui systems are in place and effectively implemented. 7.0 Control of Purchased Material, Equipment, and Snrvices The HL&P Quality Assurance Plan and implementing procedures require that HL&P, prime contractors and subcontractors define and document the system and requirements for the control of nuclear safety-related purchased material, equipment and services. Control and verification of supplier's activities during f abrication, inspection, testing, and shipment of materials, equipment, and components is planned and performed as early as possible, as required to assure conformance to the purchase order or contractual requirements. These procedures provide for: 19

Requiring the supplier to identify processes to be utilized in tulfilling procurement requirements. Reviewing documents required to be submitted by the procurement requirements. Specifying the characteristics or processes to be witnessed, inspected, or verified and accepted based upon the f abrication schedules; the method of surveillance and the extent of documentation required; and those responsible for implementing these procedures. Audits, surveillance, and/or inspections which verify that the supplier complies with the quality requirements of his QA program. Control and verification of organizations performing services is accomplished by technical verification of data provided, surveillance and/or audit of the activity and review of objective evidence such as certifications, reports, etc. The selection of suppliers is based on evaluation of their capability to provide items or services in accordant'e with the requirements of the procurement documents prior to award of contract. Procurement source evaluation and selection measures are implemented by HL&P and BPC which provide for the identification of the organizational responsibilities for determining supplier capability. Measures tor evaluation and selection of procurement sources, and the results thereof, are documented and include one or more of (a) through (c) and also must include (d) below: Evaluation of the supplier's history of providing an identical a. or similar product or service which performs satisfactorily in actual use. The supplier's history shall reflect current capability. b. Supplier's current quality records supported by documented qualitative and quantitative information which can be objectively evaluated. Supplier's technical and quality capability as determined by a c. direct evaluation of his facilities and personnel and the implementation of his approved quality assurance program. d. Evaluation of bid documents including review for technical adequacy, quality assurance, and commercial considerations. Procurement of spare or replacement parts for safety-related structures, systems, and components is subject to QA program controls, to codes and standards, and to technical requirements at i 20 l

~ least equal to the invoked original technical requirements or any properly reviewed and approved revisions. A Receipt inspection is planned and implemented to assure: Timely inspection of items upon receipt. The material, component, or equipment Je properly identified, and corresponds to the identification on the purchase document and receiving documentation. Material, components, equipment and acceptance records satisfy the receiving inspection instructions prior to installation or use. Specified inspection, test, and other records are accepted and available at the South Texas Project prior to installation or use where required unless otherwise authorized by conditicnal release. Items accepted and released are identified as to tneir inspection status prior io torwarding them to a controlled storage area or releastag them for further work" or installation. Coordination of receipt inspection with vendor surveillance activities to verify the required vendor inspection has been performed or a waiver documented. Deficiencies if applicable have been resolved prior to shipment. Suppliers' control and use of Certificates of Conformance when required by procurement documents are evaluated by audits, vendor inspections, or tests to ensure they are valid. The supplier's records shall include a description of those nonconformances from the procurement requirements dispositioned " accept as is" or " repair," including evidence of acceptance by the purchaser's engineering organization. Site receiving inspection ensures that, for nuclear safety-related items received at the South Texas Project, there is accompanying documentation that indicates review and concurrence by the appropriate primo contractor or designee, that the item complies with established requirements or has an authorized waiver prior to shipment. BPC Quality Assurance audits and surveillances are performed to ensure compliance witn these criteria. IiL6P Design Of fice QA ensures by audits / surveillance of the A8/ construction manager's vendor surveillance 1 unction that source surveillance and inspection are perf ormed in accordance with the quality assurance program. In addition !!L6P QA performs audits and surveillances of activities commencing with receiving inspection at 21

e the site to ensure proper controls of purchased material and equipment are exercised and to insure overall compliance. 8.0 Identification and Control of Material, Parts and Components The HL&P Project Quality Assurance Plan requires that prime contractors'and suppliers establish written procedures which ~ identify, control and ensure traceability of materials, parts and components including partially assembled components. Prime con-tractor's and supplier's procedures shall include the documented verification of correct identification of materials, components and subassemblies, and that the method of identification does not affect the function or quality of the item prior to release of the items for assembly or installation. These procedures must: Establish controls to identify and control materials (including coneumables), parts, and components (including partially . fabricated subassemblies). Provide a method for identification of quality related materials and parts and to provide traceability to the appropriate drawings, specifications, purchase orders, manufacturing and inspection documents, deviati~on reports, and physical and chemical mill test reports. Provide a method for identification and control of incorrect or defective items. This system includes verification and documentation prior to release for fabrication, assembling, shipping, and installation. Bechtel QA verifies that the above criteria are incorporated into the Quality / Construction procedures during the review / approval cycle and then follows up with audits and surveillances'to verify compliance. In addition HL&P QA performs audits and surveillances on prime contractors for evaluation of the conformance to identification and control criteria. 22

.n t .o 90 Control'of Special Processes - The HL&P Project _ Quality Assurance Plan requires that written procedures 'im established by prime contractors and subcontractors. for the activities associated with all special processes. For special processes the qualification of personnel, procedures and equipment relating to specif.ic codes, atandards, specifications and contractual requirements shall-be documented and maintained current. Special Processes - special manufacturing processes, metallurgical, chemical, material cleaning, welding, plating, and other processes where assurnace of the procesa quality is dependent largely on the inherent skill of the operator and cannot be assured by the inspection of' articles alone. Special processes for the South Texas Project include but are not limited to Welding Heat treating Cadwelding ~ Nondestructive testing Chemical cleaning Organizational responsibilities aro' defined in procedures for qualification of special processes, equipaent and personnel. These responsibilities will include the provision to assure that special processes are pertormed by qualified personnel using procedures qualified and approved in accordance with applicable codes, standarde, or other requirements. Special processes are performed under controlled conditions by qualitied perewnnel using procedurva qualified and approved in accordance 'with applicable codes, standards, or other requirtments. For special processes not covered by existing codes or standards the specific equipment, personnel qualitication, and procedure qualificetion requirements are defined prior tu application of the special process. Records are maintained for the qualification of procedures, equipment, and personnel associated dith special processes. Records are in sufiicient detail to clearly define the procedures, equipment, or personnel boxng qualified; criteria or requirements used for qualification; and the individu21 approving the qualification. HL&P QA ensuren that the special process control criteria are met by Bechtel's review and approval of special process procedures and performance of auaits and surveillances to ensure compliance. 23 i I

e hL&P will retain the capability with a quality control group to 'perf orm, as directed' by the 'PQAM, certain special process examinations (NDE) during the inspection verification process. - These examinations will be performed by personnel qualified in accordance with ShT-TC-1A-75 using qualified procedures approved by HL&P NDE Level Ill personnel. HL&P QA performs audits and surveillances of special process activities-to ensure' compliance with all aspects of the Quality Assurance program. 10.0 Inspection The HL&P Project Quality Assurance Plan requires the prime 1 contractor for construction and subcontractors to establish and implement an inspection operation whose activities are independent f rom the group performing the activities being inspected. The training, qualifications and certifications of inspectors include criteria from appropriate codes, standards, and procedures. Inspector training shall be documented and kept current. Inspection activities relating to construction, fabrication, installation and testing are documented, kept current and identify al1 mandatory inspection hold and test points and the criteria to be witnessed by autho rized. ins pe cto rs. Operations and inspections (including rework, replaced items) are performed in predetermined, documented sequences. Deviations or deletions must be accomplished in accordance with approved and documented systems. Inspection procedures include all required inspection operations defined by the specifications, drawings, codes and standards. These procedures provide for the following: Identification of characteristics and activities to be a.- inspected b. A description of the method of inspection Identification of the individuals or groups responsible for c. performing the inspection operation d. Acceptance and rejection criteria Identification of required procedures, drawings, and e. specifications and revisions f. Recording the identification of inspector and/or data recorder if applicable and the results of the inspection operation g. Specifying necessary measuring and test equipment including accuracy requirements and verification of calibration h. Evaluation of inspection results 24 j m,

Where direct inspections are impossible or disadvantageous, in-process monitoring is specified in the inspection procedures and both direct and in-process monitoring are used when control is inadequate without both. All required procedures, specifications and drawings.are made available to the inspectors prior to perform-ing inspection. If mandatory inspection hold points are required beyond which work cannot proceed without the specific consent of the designated representative, the specific hold points will _ be indicated in appropriate documents. Inspection results are documented, evaluated and their acceptability determined by a responsible individual or group. BPC QA verifies that inspection control criteria are complied with by review and epproval of the inspection procedures and by audits and surveillances of inspections. s HL4P QC may occasionally perform inspection verifications as deemed g necessary by the Project QA han'ager. HL&P QA performs audits and surveillances of inspection activities to ensure compliance with al,1 aspects of the quality assurance program. The HL&P Inspectors are trained and certified by a program conforming to ANSI N45 2.6 and as applicable, SNT-TC-1A-75. S-11.0 Test Control The HL&P Project Quality Assurance Plan requires that a test control program be developed and documented by the prime contractors and ,) contractors for tests that they are responsible for, which demonstrates that the facility performs in accordance with the South Texas' Project requirements and specifications. The training, certification of personnel, calibration and certification of test equipment, system or component status, environmental conditions, inspection hold points and configuration of the items to be tested are included in the procedures. Test results are documented, evaluated and the acceptance status determined by the authorized departments. Test procedures or instruct ions provide for the following as required: The inclusion of requirements and acceptance limits contained a. in applicable design and procurement documents b. Instructions ;for performing the test Test prerequisites such as calibrated instrumentation, adequate c. test equipment ano instrumentation including their accuracy requirements, completecess of item to be tested, suitable and controlled environmental conditions, and provisions for data il collection and storage 25 or

d. Mandatory inspection hold points for witness by Owner and the contractor's inspector (as required) e. Acceptance and rejection criteria f. Methods'for documenting or recording test data and results g. Provisions for assuring that test prerequisites have been met h. Evaluation of results BPC QA verifies inclusion of adequate test control criteria by review and approval of contractor's testing procedures. They also perform audits and surveillances to verify that the controls are implemented and effective. HL&P will perform audits and surveillances on Bechtel's Quality Assurance activities. The test control activities are an example of a case in which HL&P Project QA monitoring activities and the Operational QA monitoring activities will interface and in some instances overlap. HL&P Project QA procedures will specifically define the responsibilities for this period. 12 0 Control of Measuring and Test Equipment The HL&P Project Quality Assurance Plan requires the establishment, documentation and implementation of a Measuring and Test Equipment Control System. The system is to include calibration techniques, specifications, accuracy, frequency and maintenance of all measuring instruments / test equipment used in the measuring, inspection and monitoring of nuclear safety-related items. dalibration and maintenance data shall be filed and kept current. Calibration standards are to be traceable to nationally ' ized standards where standards exist. If standards do not ex., the basis'for calibration of the equipment shall be documenteo. If measuring or test equipment is found to be out of calibration, missing or lost, an investigation is required to be performed to determine the validity of the use of the instrument and whether measurements or teste are required to be reperformed. Reinspection when required will be documented. Equipment is identified and traceable to the calibration test data and suitably marked to indicate calibration status. Markings include the last day calibrated and next calibration due date. Measuring and test equipment is calibrated at specified intervals based on the required accuracy, purpose, degree of usage, stability characteristics, anc other conditions affecting the measurement. Calibration of this equipment is against standards that have an accuracy of at least four times the required accuracy of the equipment being calibrated, or when this is not possible, have an accuracy that assures the equipment being calibrated will be within 26

~ u ~ e ! required tolerance and that the basis of acceptance is documented and authorized by responsible management. Calibrating standards will, wh'en possible, have greater accuracy

than standards being calibrated. Calibrating standards with the same accuracy may be used if they can be shown to be adequate for the requirements and the basis-of acceptance is documented and authorized by responsible management.

i' Bechtel QA reviews the constrnetion contractors calibration procedures to ensure these criteria are incorporated. In addition, BPC QA audits and surveillances are performed to verify compliance. HL&P performs audits and surveillances on 'Bechtel's QA activities. 4 In the conduct of its inspection verifications, as directed by the PQAM, HL&P-Quality Control is required to use measuring and test equipment of the appropriate accuracy level which is controlled by procedures meeting the requirements of this section. i 13.0 Handling, Storage and Shipping The HL&P Project Quality Assurance Plan requires that for nuclear safety-related items, written procedures be develope ~d in accordance-I with design requirements, specifications and standards to control the cleaning, handling, storage, packaging, shipping and preserva-tion to preclude damage and deterioration by environmental condi-tions. The activities are to be accomplished by _ appropriately trained and experienced personnel. BPC QA reviews quality construction procedures for receiving, 3 handling, storage and cleaning to verify that the appropriate criteria of Regulatory Guide 1.38 and ANSI N45.2.2 are included. Periodic audits and surveillances are conducted by BPC and HL&P QA, to verify compliance with the procedures. 14.0 Inspection, Test and Operating Status The HL&P Project Quality Assurance Plan requires that the prime contractor and construction contractors indicate the current inspection, test and operating status of nuclear safety-related items through the use of stamps, markings, tags or other suitable j means. Procedures include the requirements for: Y Controlling the application and removal of inspection status a. indicators such as tags, markings, labels, and stamps Documenting the status of nonconforming, inoperative, or b. i maltunctioning structures, systems, and components to prevent inadvertent use c. Defining and documenting the use, application and removal of I inspection tags, labels or markings which identify the status-of inspections or' tests performed and attest to the ' acceptability of the structure, system, or component i L 27 1

d. Controlling the altering of the sequence of required tests, inspections and other operations. HL&P and BPC Quality Assurance personnel review these procedures and conduct periodic audits and surveillances to assure compliance. 15.0 Nonconforming Materials, Parts or Components ' The HL&P Project Quality Assurance Plan requires that. HL&P maintains and the prime contractors' Quality Assurance Progr'ams include ~a system which is documented by written procedures for the identification, segregation and disposition of nonconforming materials, parts and components. The procedures shall specify the preparation and handling of nonconformance documents, segregation requirements and which groups are responsible for review and ' disposition of the items. Documentation identifies the nonconforming item; describes the nonconformance, the disposition of the nonconformance, and the inspection requirements; and includes signature approval of the disposition. Nonconformances are corrected or resolution determined prior to initiation of the preoperational test program on the item. Rework, repairs and subsequent reinspection, and tests are conducted in,accordance with the original inspection and test requirements or accepted alternatives. These tests shall be performed in accordance with controlled procedures and contain mechanisms for providing information to the identifying group as to the disposition of the nonconformance. For NSSS items, HL&P coordinates nonconformance resolution through Westinghouse. HL&P QA performs an evaluation of the Cons t.ruction Manager's nonconformance trend analyses. ProcctJret are established by BL&P to report significant deficiencies during the design, construction, and operations phase to HL&P executive manage cut and to the Nuclear Regulatory Commission in accordance with 10CFR50.55(e),10CFR21, and 10CFK71, where applicable. Compliance of these activities with Project Quality Assurance Plan requirements is verified through the performance of audits and surveillances by BPC and HL&P QA. 16.0 Correct"re Action The HL&P Project Quality Assurance Plan for the South Texas Project requires that a system be established and documented by HL&P and the prime contractors which defines the responsibilities, authorities and methods used by specific groups involved in the evaluation of nonconformances and trending to determine the need for corrective action. The system includes measures to identify the cause of significant conditions adverse to. quality, measures to ensure that the rcot causes are corrected, and measures to ensure that timely actio.. is taken. Follow-up is performed to ensure the ef fectiveness of currectiva action and that appropriate levels of management are informed of the results. HL&P Project Quality Assurance performs trend analyses to determine the need for corrective action. 28

) Compliance of these actions with Project Quality Assurance Plan requirements is verified by BPC and HL&P Quality Assurance through the performance of audits and surveillances. 17.0 quality Assurance Records The HL&P Project Quality Assurance Plan requires that a Quality Assurance record system be developed by HL&P and the prime contrac-tors for the South Texas Project. The record system provides evidence that activities relating to quality are defined, imple-mented and that inspection and test documents contain a description of the type sof observation, reference to nonconformance reports, evidence relating to status of observation, date and inspector identification. Quality records shall include reviews, audits, reports, specifica-tions, nonconformance reports, analyses, personnel and equipment qualification procedures. The Project Quality Assurance Plan requires that HL&P and prime contractors establish requirements to ensure that records generated during the design, procurement, and construction are identifiable, retrievable and meet the requirements of 10CFR50 App'endix B and ANSI N45.2.9 as endorsed by Regulatory Guide 1.88. As an alternative to the ANSI h45.2.9 Storage Requirements, records may be maintained for the South Texas Project in a two-hour rated fire resistant file room meeting NFPA No. 232 including the following provisions: An automatic fire suppression system and an early warning fire detection system is utilized Records are stored in fully enclosed metal cabinets Smoking and eating / drinking are prohibited within the records storage facility Work not directly associated with record storage or retrieval is prohibited within the records storage facility Ventilation, temperature, and humidity control equipment is controlled where they penetrate fire barriers bounding the storage facility. Compliance with Project Quality Assurance Plan requirements is verified by BPC and HL&P Quality Assurance through the performance of audits and surveillances. 18.0 Audits The HL&P Project Quality Assurance Plan establishes the requirement that ht&P, prime contractors and subcontractors develop, document and implement audit activities which are structured in accordance I 1 29

with the requirements of ANSI N45.2.12 for the South Texas Project. As required by the ANSI standard, results of audits are presented for review to management of the audited organization and, in the case of HL&P performed audits the HL&P Executive Vice President, Nuclear Group. Where indicated HL&P performs followup action. HL&P has the ultimate responsibility for the auditing of quality related activities on the project. HL&P corporate audits are performed primarily on the HL&P Project QA group, HL&P corporate organizations providing services to the project and Westinghouse. HL6P Project QA is primarily responsible for audits of the Engineer / Construction Manager, constructor, subcontractors and the HL&P Project team organizations. Cases may arise in which audits may be required by either the Corporate or Project audit groups in the primary area of responsibility of the other group. The prime contractors and subcontractors - perform quality related audits of internal activities and suppliers of material, components end systems. HL&P and Bechtel perform supplemental audits when required, based on such f actors as significant changes in the Quality Assurance Program, results of trending programs or investigati~ons into the root causes of problems. 30

e TABLE 1 PLAN / PROCEDURES USED TO IMPLEMENT QUALITY ASSURANCE FOR THE MAJOR ACTIVITIES 10CFR50 App. B 1.0 Project Quailty Assurance Plan Criterion 1. Organization 1 2. Quality Assurance Program II 3. Design Control III 4. Procurement Document Control IV 5. Instructions, Procedures, and Drawings V 6. ' Document Coatrol VI 7. Control of Purchased Material, Equipment VII and Services 8. Identification and Control of Materials, VIII Parts, and Components 9. Control of Special Processes IX 10. Inspection X 11. Test Control XI 12. Control of Measuring and Test Equipment XII 13. Handling, Storage and Shipping XIII 14. Inspection, Test, and Operating Status XIV 15. Nonconforming Material, Parts, and Components XV 16. Corrective Action XVI 17. Records XVII 18. Auditing XVIII Table 1-1

a-TABLE 1-Plan / Procedures used to Implement Quality Assurance for the Major Activities 10CFR50 App. 8 2.0 Project Specific Quality - Assurance Procedures (PSQP) Criterion ~ PSQP-Al : Organization & Responsibility of Project QA/QC ' Personnel ~ 'I, II .A2 Generation and Control of Project Specific V, VI Quality Assurance' Procedures 'A3 Deleted N/A A4 Control of Site Documentation .VI 1A5 Non-Nuclear Site Quality Assurance N/A [ A6 Document Reviews V, VI l A7 Stop Work ~ XV, XVI A8 Trend Analysis Administration XVI A9 Implementation Review (To Be Deleted) II, IV thru XVII i A10 Quality Control Administration IX, X i

All Certification of Quality Control Personnel II, IX, X A12 Indoctrination and Training II A13 Corrective Action XVI A14 Construction QA - Operations QA Interface II, XI, XVII (Future Procedure)

AIS Handling of NRC Inspection Reports & Immediate XV, XVI Action Letters A16 Qualification and Certification of Nondestructive II, IX, X Examination Personnel A17 Forms Control V, VI A18 Preparation of' Project QA/QC Instructions V, VI l A19 Quality Assurance Activity Log X A20 Audits XVIII A21 Surveillances XVIII Table 1-2 w

TABLE 1 ' Plan / Procedures used'to Implement Quality Assurance for the Major Activities 10CFR50 App. B -3.0 HL&P Support Division Quality Assurance Procedures Criterion SDQAP-1.1 QA' Department Organization I, II 2.1 Indoctrination, Training, Certification of HL&P QA II Support Division Personnel 2.2 ' Training, Qualification and Certification of X Surveillance Personnel 2.3 -Training, Qualification, and Certification of II, XVIII Audit Personnel (Formerly QAP-SA Rev. 7) 2.4 Training, Qualification and Certification of NDE IX Surveillance Personnel 3.1 Document Review ^ III 4.1 Procurement of Items and Services VII 7.1 Surveys of Vendors VII 7.2 Evaluation, Control and Issuance of QA Approved VII Vendors List 7.3 Quality Assurance Procedure HL&P Vendor Surveillance VII (Formerly QAP-3A) 7.4 Quality Assurance Procedure Use of Approved VII Surveillance Agencies 7.7 Review of Nuclear Steam Supply System (NSSS) VII Quality Assurance Records Packages (Formerly QAP-Il Rev. 1) 7.8 Review of Vendor QA Manuals VII 15.2 Stop Work Procedure XV 16.1 Audit Deficiency Tracking List XVI 16.2 Action Item Tracking System XVI 16.3 Trend Analysis XVI 17.1 Audit Filing (Formerly QAP-SC Rev. 7) XVII I

18. Auditing QA Programs (Formerly QAP-5B Rev. 7)

XVIII 18.2 Joint Auditing of QA Programs XVIII Table 1-3

a O TABLE 1 Plan / Procedures used to Implement Quality Assi,rance for the Major ictivities 4.0 HL&P, South Texas Project 10CFR50 App. B Project Engineering Procedures Criterion PEP-I Introduction II Manual Provisions III Scope IV Definitions 01 Preparation and Control of Project Engineering VI Procedures 02 Document Receipt & Handling N/A 03 Engineering Approval Authority III 04 Reference Document Library N/A 05 Performance of Owner's Reviews III 06 Design Change Request N/A 07 Administration for approval of basic design documents III, VI and vendor originated supplier deviation requests (SDRS) 08 Engineering Action Item Tracking N/A 09 Transmittal of Review Comments to External N/A Organizations 10 Project Engineering Organization & Responsibilities I 11 Reporting Design and Construction Deficiencies XV, XVI to NRC 12 Deleted N/A 13 Deleted N/A 14 Designation & Handling of Confidential Security N/A Documents 15 Preparation of Purchase Authorizations .N/A 15 Procurement of Engineered Items IV, VII 17 NSSS~ Proposal Authorization N/A Table 1-4 h w, r

TABLE 1 Plan /Proce/,tes used to Implement Quality Assurance for the Major Activities 4.0 HL&P, South Texas Project 10CFR50 App. B' Project Engineering Procedures Criterion 18 Preparation and Control of Specifications III,.IV 19 Processing Supplier Deviation Requests III, IV 20 Document Change Notice control (IP) VI, III 21 Design Verification (IP) III 22 Personnel Training II 23 Numbering and Identification of Systems and VI Structures (IP) 24 Design Interface Control (IP) III 25 Preparation of System Design Descriptions (IP) III 26 Preparation of Technical Reference Documents (IP) III 27 Preparation of Diagrams (IP) III 28 -Preparation of Drawings (IP) III 29 Preparation of Calculations (IP) III 30 Preparation of Design Reports (IP) III 31 Preparation of 0 & M Manuals (IP) III, XIV 32 Preparation of ASME Section-III Documents (IP) III 33 Preparation of ASME Section VIII Documents (IP) III 34 ALARA Review (IP) II 35 Issuance and Control of Design Documents (IP)- III, VI Note: (IP) indicates procedure is in preparation or a proposed procedure and not yet issued for use. 'I 1 Table 1-4a

TABLE I Plan / Procedures used to Implement Quality Assurance for the Major Activities - 10CFR50. App. B 5.0 Project Site Administrative-Procedures' Criterion . PS AP-01:. Preparation and Control of Project Procedures V 02 Project Directives N/A 03 Telephone Minutes N/A 04 Project Correspondence N/A 05 Processing Project Mail N/A 06 Project Meetings N/A 07. Trip Requests N/A 08' Open Items List N/A 09 Critical Action Items List N/A 10 Monthly Manhour Reporting N/A 11 Processing / Distribution of NRC Correspondence VI 12 Document Review / Comment Process VI 14 Processing Current STP Correspondence / Documents by RMS XVII 15 Obtaining Overdue STP Correspondence N/A 6.0 Project Contract Administration Procedures PCAP-50 Authorization of out-of-estimate work N/A 51 Not Assigned N/A 52-Proposed Contract changes N/A i Table l-5, 1-6 c_ ~ 'l

U TABLE 1 Plan / Procedures used to Implement Quality Assurance for the Major Activities 10CFR50 App. B 7.0- Project-Site Procedures Criterion' PSP-01 Preparation and Control of Project Site Procedures V 02 Project Site Organization 1 03 Not Assigned 04 Not Assigned 05 Field Change Requests for Engineering Action III 06 Deficiency Reporting and Temporary Waiver Request XV 07 Construction Review of Documents VI 08 Control of Construction Documents VI, XVII 09 Processing Site Correspondence N/A 10 Review and Approval of field procurement requisitions IV 11 Construction Interfacing for Testing & Turnover (IP) II, X 12 Not Assigned 13 Indoctrination & Training II 14 Equipment Inventory & Maintenance VIII, XIII 20 Issuance of Photo Identification Badges N/A 21 Camera Control (Deleted) N/A 22 Visitor Clearance N/A 23 Vendor Access N/A 24 Vendor Control N/A Table 1-7

l TABLE 1 Plan / Procedures used to Implement Quality Assurance for the Major Activities 10CFR50 App. B 8.0 Records Management Systems Procedures Criterion RMSP l-1 General Flow of Nuclear and Fossil Correspondence XVII Within RMS 1-2 Recorde Management Responsibilities and Interfaces I l-3 Preparation and Periodic Review of RMS Procedures VI 1-4 Records Management Personnel Training II 2-1 Records Center Micrographic Section Proce' dure XVII 2-2 Document Logging VI 2-3 Log Maintenance VI 2-4 Document Distribution VI 2-5 Storage & Maintenance of Nuclear Records XVII 2-6 Document Checkout XVII 2-7 Correspondence Serial Number Assignment VI 2-8 Correspondence Serial Number Corrections VI 2-9 File Number Assignment XVII 2-10'NSSS Data Packages Handling XVII i Table 1-8' . ~, -

3 e TABLE 1 Plan / Procedures used to Implement Quality Assurance for the Major Activities 10CFR50 App. B 8.0 Records Management Systems Procedures Criterion RMSP 2-11 Processing of Current Correspondence / Documents N/A by Data Center 2-12 Preparation of Computer Input Forms for Master N/A -Purchase Order Module 2-13 Processing Computer Input Forms By Operations N/A Personnel 2-14 Backfitting Project Records XVII 2-15 Charge Number and Project Code Usage N/A 2-16 To be issued at a later date N/A 2'-17 Password Control N/A 2-18 Distribution of STP Spare Parts Correspondence VI Table 1-8a

TABLE 1 Plan / Procedures used to Implement' Quality Assurance for the Major Activities 10CFR50 App. B 9.0 Project Licensing Procedures Criterion PLP-01 Preparation & Control of Project Licensing Procedures VI 02 Reporting Design & Construction Deficiencies to NRC (IP) XV, XVI 03 FSAR Change Notices II 04 NRC Inspection & Enforcement Bulletins (IEB), II Circulars (IEC), and Information Notice's (IN) 05 Personnel Indoctrination training (IP) II 06 Control of NRC Correspondence N/A 08 Organization (IP) I 09 NRC Regulatory Guides, NUREGS, CFR Rule Makings (IP) N/A 10 NRC Inspection Reports (IP) N/A 11 Miscellaneous Industry Correspondence (IP) N/A 12 Verbal Communication N/A 13 Control of Nuclear, Licensing Manual (IP) VI 14 Procurement of Items & Services (IP) VII NOTE: 1 (IP) indicates procedure is in preparation or a proposed procedure and has not yet been issued for use. 2 due to a reorganization, licensing is operating to several engineering procedures and will continue to do so until the licensing procedures are issued. l Table 1-9 -.n

o. . TABLE 1 Plan / Procedures used to Implement Quality Assurance for the Major Activities 10CFR50 App. B .10.0 Project Procurement Procedures Criterion PPP-01 General Procurement VII 02 ' Establishing Bidders Lists VII 03 Site Procurement VII 04 Inquiry Issuance VII 05 Proposal Evaluation and Supplier' Selection VII 06 Purchase Order and Change Order Preparation, VII Approval and Issuance 08 Training II 091 Preparation and Control of Project V. Procurement Procedures 11 Document Review IV 13 Processing Purchase Order and Change Order VII Acknowledgements 4 l 1 i Table 1-10

TABLE 2 ANSI STANDARD AND REGULATORY GUIDE COMPLIANCE-The STP Quality Assurance Program complien with the.following ANSI Standards and associated Regulatory Guides except as noted: STANDARD TITLE ANSI N.45.2-1971 Quality Assurance Program Require-R.G.I.28 (Rev. 0,6/72) ments for Nuclear Facilities ANSI N.45.2.1-1973 Cleaning of Fluid Systems and Asso-R.G.I.37(Rev. 0,3/73) ciated_ Components During Construc-(see Notes 8 through 10) tion Phase of Nuclear Power Plants ANSI N.45.2.2-1972 Package, Shipping, Receiving, Storage R.G.I.38 (Rev. 0,3/73)- and Handling of Items for Nuclear (see Notes 11 through 16) Power Plants ~ ANSI N.45.2.3-1973 Housekeeping During the, Construction R.G.I.39(Rev. 0,3/73) Phase o' Nuclear Power Plants (we Ntes 17 and 18) ANSI N.45.2.4-1972 Installation, Inspection and Testing R.G.I.30(Rev. 0,8/72) Requirements for Instrumentation and (see Notes 19 and 20) Electric Equipment During the Con-struction of Nuclear Power Generating Stations ANSI N.45.2.5-1974 Supplementary Quality Assurance Re-(see Notes 1 and 2) quirments for Installation, Inspection and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants ANSI N.45.2.6-1973 Qualifications of Inspection, R.G. 1.58 (Rev.0,8/73) Examination and Testing Person-Plus Positions C.5, C.6, C.7, nel for the Construction Phase C.8 and C.10 of Rev. 1 of Nuclear Power Plants ANSI N.45.2.8 - 1975 Supplementary Quality Assurance Reg. 1.116 (6/76) Requirements for Installation, (see Notes 21 through 23) Inspection and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuc1 car Power Plants Table 2-1

TABLE.2 ANSI STANDARD AND REGULATORY CUIDE COMPLIANCE (Continued) ANSI N.45.2.9-1974 Requirements for Collectior, Storage R.G. 1.88.(Rev.2,10/76) and Maintenance of Quality Assurance (see Notes 24 through 26) Records for Nuclear Power Plants ANSI N.45.2.10-1973 Quality Assurance Terms and R.C. 1.74 (Rev. 0,2/74) Definitions ANSI N.45.2.ll-1974* Quality Assurance Requireaents for R.G. 1.64 (Rev. 2,6/76) the Design of Nuclear Power Plants (see Notes 3 through 7) ANSI N.45.2.12 - 1977 Requirements for Auditing of Quality Rg. 1.144 (Rev.1,9/80) Assurance Programs for Nuclear Power Plants ANSI N.45.2.13 - 1976 Quality Assurance Requir_ements for R.G. 1.123 (10/76) Control of Procurement of Items and (see Notes 27 through 31) Services for Nuclear Power Plants ANSI N.45.2.23 - 1978 Qualification of Quality Assurance R.G. 1.146 (Rev.0,8/80) Program Audit Personnel for Nuclear Power Plants Exception Notes 1. ANSI N.45.2.5-19744 Section 4.8, states " Pumped concrete must be sampled from the pump line discharge". In lieu of this statement, in-process strength samples of pumped concrete are taken at the delivery point. Correlation tests of air content, slump, and temperature are performed to verify these plastic properties of the concrete at the placement point in accordance with the following frequency requirements: A. A minimum cf 2 currelation tests are performed for each pumped placement exceeding 200 cu. yds. B. Otherwise, a minimum of 2 correlation tests per week are performed when any individual pumped placement during a week requires delivery of more than one truckload of concrete. C. During a week when a pumped placement exceeding 200 cu. yds, is made, the correlation tests performed on that placement will satisfy the weekly requirement for performing two correlation tests as specified in Item B above. Table 2-2

TABLE 2 ANSI STANDARD AND REGULATORY GUIDE COMPLIANCE (Continued) When any of the specified limits and tolerances on loss of air content, slump, or temperature are exceeded at the placement point, correlation tests between the delivery point and placement point will be accomplished for each 100 cu. yds. of concrete placed as long as limits and tolerances are exceeded. If two consecutive tests are out of tolerance, corrective action will be implemented to adjust the limits for the concrete entering the pump intake so that no concrete from the subsequent trucks will enter the pump intake as long as the tolerances are exceeded. " Correlation Tests", " Delivery Point", and " Placement Point" are as defined in ANSI N.45.2 5-1978, Section 1.4. 2. Samples and frequency for cadweld testing is in accordance with ACI-359/ASME Section III, Division 2, issued for trial use and comment in 1973, including addenda 1 through 6, (see Sections 3.8.1.6.3 and 3.8.3.6.3 of the STP Final Safety Analysis Report).

• The following interpretations (Notes 3 through 7) of ANSI N45.2.11-1974 and Regulatory Guide 1.64, Rev. 2-6/76, apply to HL&P, their contractors, and consultants working under HL6Ps Quality Program.

3. Section 3.1, Design input Requirements, General. This section implies that all necessary design input (as listed in Section 3.2) should be available prior to the start of a design activity. In practice, certain design activities are initiated before the firm input requirements are available. (For example, foundation designs prepared based on preliminary information or equipment sizes and mounting, embedded conduit run based on preliminary estimates of circuit requirements, etc.) The design phase QA program will be structured to ensure that all necessary design input is available before completion of final design of the work affected by the input, and that final design input is available for use in verification of the final design. 4. Section 4.a. Design Process, General. Paragraph 3 implies traceability back from final design to the source of design input. In practice, a literal interpretation of this is not always possible. For example, final design drawings do not identify the related calculations. This paragraph will be interpreted to mean that it shall be possible to relate the criteria used and analyses performed to the final design documents and that record files will permit location of analyses supporting specific design output documents. Table 2-3

TABLE 2 ANSI STANDARD AND REGULATORY CUIDE COMPLIANCE (Continued) 5. Section 4.2, Design Analyses. This section implies a requirement for retention of all calculations. In principle, it is considered good practice for the responsible engineer or engineering organization to retain all final calculations, and this will be done for all manual calculations covered by the program. However, for computer programs only documentation of the design input, assumptions made in the analyses, results obtained, and evidence of verification will be retained since permanent retention of all versions of all-computer programs is not considered practical or necessary if sufficient information is available for a competent individual to verify the results using the input and assumptions. 6. Section 10, Records. In process documentation, relating to checking and coordination of drawings (for example, check and coordination prints) or copies of marked-up specifications used to solicit comments shall be retained until the drawing or specification is approved and issued for use outside of Engineering. Such in process documents will be available for review / audit until the document is approved, but may be discarded once the document has been approved. In the first sentence of the second paragraph the phrase " final design documents" shall mean those documents which are the latest revision that has been issued for use. 7. Regulatory Position, Section C-2: If, in an exceptional circumstance, the originators' immediate supervisor is the only technically qualified individual available, the design verification or checking will be conducted by the supervisor with the following provisions: The other requirements of Regulatory Guide 1.64 will be met. a. b. The justification will be individually documented and approved by the next level of supervision. Quality Assurance audits will include review of the frequency c. and effectiveness of the use of the immediate supervisor to assure that this provision is used only in exceptional circumstances. 8. Section 2.1, Planning. The required planning is frequently performed on a generic basis for application to many installations on one or more projects. This results in standard procedures or plans for installation and inspection and testing which meet the requirements of the standard. Individual plans for each item or system are nor normally prepared unless the work operations are unique. However, standard procedures or plans will be reviewed for applicability in each case. Installation plans or procedures are Table 2-4

TABLE 2 ANSI STANDARD AND REGULATORY CUIDE COMPLIANCE (Continued) also limited in scope to those actions or activities which are essential to maintain or achieve required quality. This is consistent with Section II, Paragraphs 2 and 3 of ANSI N45.2-1971 which provides for examination, measurement, or testing to assure quality or indirect control by monitoring of processing methods. However, final cleaning or flushing activities will be pe formed in accordance with' procedures specific to the system.

9. Section 4, Preinstallation Cleanliness. This section states, " Items

. should not be delivered to the point of installation site sooner than necessary unless the installed location is considered a better storage area." As an alternate to this requirement, items may be delivered to the installation site sooner than absolutely necessary when determined to be advantageous for other considerations, for example, reduced handling or easier access, thereby reducing susceptibility to handling damage. In all such cases, equipment stored in place will be protected in accordance with Section 5 of ANSI N45.2.1.

10. Section 3.1.2, HL&P interprets the lighting level of 100 footcandles to be guidance.

It is HL&P's normal practice that the lighting level for determining " metal clean" of accessible surfaces of piping and components is determined by the inspector. Typically he uses a standard two-cell flashlight supplemented by other lighting as he deems necessary.

11. Section 2.7, Classification of Items. The four-level classification system may not be used explicitly. However, the specific requirements for each classification as specified in the standard will be applied to the items suggested in each classification and for similar items.

Classification differing from Section 2.7 will be considered acceptable provided no degradation is assured; for example, electric motors designed for outside service may be stored in level C area rather than a level B.

12. Section 6.2, Storage Areas.

Paragraph 6.2.1 requires control and limited access to storage areas. In lieu of and to amplify this paragraph, the following will be applied: " Access to storage areas for levels A, B, and C will be controlled by the individual (s) responsible for material storage." Level D items will be stored in a site area which will have access control consistent with 8ne IV of ANSI N45.2.3-1973. While the areas will Le posted to limit access, other positive controls (other than that for the overall site area) or guards may not be provided. Table 2-5

TABLE 2 ANSI STANDARD AND REGULATORY GUIDE COMPLIANCE (Continued)

13. Section 5.5, Correction of Nonconformances.

This section provides for " rework" and "use as is" dispositions for nonconforming items. As an alternate, the " repair" disposition (as defined in ANSI N45.2.10-1973) will also be used.

14. Section 6.2.4, Storage of Food and Associated Items.

Controlled areas, within storage areas, will be established for the storage of food, drink, and salt tablets. These areas will be controlled through normal supervision and inspection.

15. In Section 8, the control of documentation and records shall be in accordance with Section 17 of this Progrsm Description.

16. Appendix, A 3.4.2, Inert Gas Blankets. There may be cases involving large or complex shapes for which an inert or dry air purge flow is provided rather than a static gas blanket in order to provide adequate protection due to difficulty of providing a l'eakproof barrier.

In these cases a positive pressure purge flow may be utilized as an alternative to the leakproof barrier.

17. Section 2.1, Planning. The required planning is frequently performed on a generic basis for application to many installations on one or more projects. This results in standard procedures or plans for installation and inspection and testing which meet the requirements of the standard.

Individual plans for each item or system are not normally prepared unless the work operations are unique. However, Nrd procedures or plans will be reviewed for applicability in Installation plans or procedures are also limited in _ase. scope to those actions or activities which are essential to maintain or achieve required quality.

18. Alternative equivalent zone designations and requirements may be utilized to cover those situations not included in the subject standard; for example, situations in which shoe covers and/or coveralls are required but material accountability is not.

In addition, zones might be combined into the next more restrictive category in order to reduce total number of zones.

19. Section 1.2, Applicability. The standard is applied to the items and systems identified in Paragraph 1.1.1 and to additional systems depending on the nature and scope of the work to be performed and the importance of the item or service involved.

Table 2-6

TABLE 2 ANSI STANDARD AND REGULATORY GUIDE COMPLIANCE (Continued) i

20. Section 2.1, Planning. The required planning is frequently performed on a generic basis for application to many installations on one or more projects. This results in standard procedures or plans for installation and inspection and testing which meet the requirements of the standard.

Individual plans for each item or system are not normally prepared unless the work operations are unique. However, standard procedures or plans will be reviewed for applicability in each case. ' Installation plans or procedures are also limited in scope to those actions or activities which are essential to maintain or achieve r, quired quality. '21. Section 1.1, Scope. The term "important items" will be interpreted to apply to those activities or quality attributes of an item or service that could af fect a nuclear safety-related characteristic. For example, if a barrier is required for leakage control, but serves no structural function, the leaktight characteristic would be considered "important", but appearance, dimensional re'quirements, and structural features would not necessarily be considered important; or if a pump casing is required for coolant boundary integrity, but the pump does not have to operate to provide for nuclear safety, those attributes which affect its operation would not be considered important from the standpoint of nuclear safety. Section 2.1, Planning. The required planning is frequently performed on a generic basis for application to many installations on one or more projects. This results in standard procedures or plans for installation and inspection and testing which meet the requirements of the standard. Individual plans for each item or system are not normally peepared unless the work operations are unique. However, standard procedures or plans will be reviewed for applicability in each case. Installation plans or procedures are also limited in scope to those actions or activities which are essential to maintain or achieve required quality.

22. Section 3.3, Process and Procedures. The terms " installation site,"

" installation area," and " site" used in this standard shall be interpreted as follows: a) " Installation site" or " site" will be interpreted the same as " construction si'.." When applied to documents, these may be at the central office or work area document control station. b) Insta11ction area - Immediate proximity of location where work is to be performed. Table 2-7 i

TABLE 2 ANSI STANDARD AND REGULATORY CUIDE COMPLIANCE (Continued)

23. Section 3.S(e), Site Conditions. This requirement will be applied only if subsequent correction of adjacent nonconfermances could damage the item being installed.

Section 4.6, Care of Items. HL&P retains the authority and is the " Responsible Organization" for temporary usage of equipment or - facilities unless specific (i.e. on a case by case basis) or general authority is granted in writing to the Construction Manager's organization. 24._Section 1.4, Definitions. Quality Assurance Records - A document is considered completed when it has finished full processing and has been issued for use in design, procurement, construction, or manufacturing.

25. Section 1.4, Definitions. Authenticated Records - Tho,se records which are clearly identified as a statement by the individual or organization holding responsibility.

Handwritten signatures are not required if the document or printout is clearly identified as a statement by the reporting individual or organization.

26. For Appendix A, an installation shall be considered to be in an "as constructed" condition if it is installed within the tolerances established by Project Engineering indicated in the design output docunents.

27. Section C.3 of the Regulatory Guide - A corrective action system may, depending upon complexity and/or importance to safety of the item or service provided, be imposed upon the supplier. When a corrective action system is imposed on a supplier, the applicable elements of Section 9.0 of the standard will be included and its implementation will be verified.

28. Section C.4 of the Regulatory Guide - Applicable information concerning the method (s) of acceptance of an item or service will be made available to receiving inspection personnel.

29. Section 4.2.a of the Standard - When evaluation of a supplier is based solely on historical supplier data, these data will primarily include HL&P's or a prime contractor's records that have been accumulated in connection with previous procurement actions. Data that includes experience of users of identical or similar products of the prospective supplier and product operating experience will be used if they become available; however, such data are normally available only to those involved in plant operations.

Table 2-8

TABLE 2

ANSI STANDARD AND RECULATORY CUIDE C6MPLIANCE (Continued)

-30. Section 10.2,d of the Standard - The requirements of this section are interpreted as follows: The person attesting to a certificate shall be an authorized and responsible employee of the supplier'and shall be identified by the supplier. 31.'HL&P's position relative to ANSI N45.2.13-1976, Section 10.2.f. Verification of the Validity of Supplier Certificates and the Effectiveness of the Certification System, is as follows: The verification of the validity-of supplier certificates and the effectiveness of the certification system are. accomplished as an (- integral part of the total supplier. control and product acceptance l program, and no separate HL&P system exists that addrases itself solely to such verification. The degree of verification required willLdepend upon the type of item or service and their safety impo rtanc e..The means of verification may include source witness / hold points, source audits,- and document revie,ws; independent inspections at the time of material receipt; user tests on selected commodities, such as. concrete components; and tests af ter installation on selected. components and systems. All of these means verify whether or not e supplier has fulfilled procurement document requirements and whether or not a certification system is effective. i l l t Table 2-9

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Administrative Guidance EXECUTIVE VICE-PRESIDENT, Programmatic Direction

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BECHTEL QUALITY ASSURANCE PROGRAM DESCRIPTION FOR THE SOUTH TEXAS PROJECT INTRODUCTION -The Bechtel Quality Assurance Program Description used by the Bechtel Power Corporation for the South Texas Project is described in the NRC approved Bechtel Topical Report BQ-TOP-1, Rev. 3A, Bachtel Quality Assurance Program for Nuclear Power Plants and the modifications and additions described below. SCOPE OF SERVICES Bechtel Power Corporation is responsible for Engineering, Procurement, Con-struction Management and Quality Assurance of the South Texas Project. Bechtel Construction Management is responsible for management of the construction and quality assurance / quality control activities of the contractor (s). Construc-tion Management consists of planning, scheduling, monitoring end evaluating the contractors construction and quality assurance / quality control activities. The construction, field engineering, and quality control activities defined in the topical will be the responsibility of the contractor (s). The contractor (s) will be responsible for submitting to Bechtel, for approval, a quality program which is consistent and compatible with the applicable sections of Bechtel's Topical 80 port. The following is a description of the South Texas Project modifications to meet the scope of the project and client requirements. 1.5.4 Division Construction Managers of Division Construction provide technical and administrative direction to the Construction Department personnel. Managers of Divi-sion Construction are assisted by Construction Managers and Chief Con-struction Engineers, where assigned. Construction Managers are respon-sible for the management and technical direction of assigned projects, and for assuring that construction projects are provided with appropriate personnel and are following prescribed division practices and procedures for conduct of construction activities. 1.6.1 Project Quality Assurance The project quality assurance program is directed by the Project Quality Assurance Manager who is responsible to assure that quality assurance actions listed below are accomplished in accordance with the requirements of the project 1) Coordinate the functions of the project quality program. _

2) Coordinate project quality-related activitics of Engin= ring, Pro-curement, and Construction. 3) Audit and surveillance of project quality-related functions and adherence to procedures. Advise management of the status of program implementation. Conduct prescheduled project audits and supplemental audits directed by the Project Quality Assurance Manager. 4) Review supplier and subcontractor quality assurance program requirements in procurement documents, conditional releases of nonconforming items at the construction site, and completed quality verification records packages prior to turnover to the client. 5) Concur with evaluation of recommended supplier's quality assurance program in accordance with subsection 7.1. 6) Take stopwork action when warranted. 7) Identify quality problems, initiate documented action leading to a solution, and verify implementation of solutions. 8) Review project plans and schedules for quality-related activities to assure timely and effective implementation of the quality assurance functions for the project. 9) Serve as the focal point for project communication on matters relating to the project quality assurance program.

10) Provide periodic reports to the Division Quality Assurance Manager and Project Manager evaluating the status of the project quality assurance program and advising of any problems requiring special attention.

11) Coordinate quality assurance functions within the project and with groups outside the division, such as M&QS and Procurement Supplier Quality.

12) Assure that quality assurance-related procedures and manuals prepared by or used for the project meet project quality program requirements and initiate revisions when necessary'.

13) Review, prior to use, Procurement Quality Surveillance Inspection plans and Quality Control instructions for clarity and the existence of the information described in Sections 7 and 10.

In addition, evaluate the adequacy of selected plans and instructions by performing an in-depth review of: a. Accuracy of translation of drawing and specification require,2nts. b. Basis for detennining inspection level and sequence. c. Adequacy of inspection method. This review provides assurance that the total quality program require-ments inclusions are complete. Reviews of generic plans and instruc-tions can be performed on a generic basis. In that case, the PQAM only verifies that the review of the generic plan or instructions has been performed.

14) R; view contractcr quality programs.

15) Prepare quality assurance descriptions in Safety Analysis Reports.

16) Review Nonconformance Reports and other quality problem related documents to detennine trends, identify significant deficiencies, and recommend appropriate corrective action.

The field quality assurance _ program includes the capability to perform: Surveillance inspection of work performed by contractors. This inspec-tion supplements the quality programs of the contractors who have re-sponsibility for their work and quality verification. Surveillance inspection includes either selected physical inspection at pre-scribed hold points and observation or witness of inspections performed by the contractor. Reviewing quality control documentation. Reviewing Bechtel and/or contractor quality documentation. Providing technical direction to testing laboratories and inspection subcontractors. Reviewing supplier quality verification document packages for complete-ness and traceability to the item (s). Identifying quality problems, initiating action leading to solutions, and verifying implementation of solutions. Reviewing contractors / subcontractors quality verification documents. Reinspection of contractor completed work may be imposed as deeined necessary. 1.6.3 Project Construction Management A Field Construction Manager is assigned to each nuclear plant project involving construction or construction management assignment, and he is responsible for the project field construction performance. The Field Construction Manager is responsible for assuring that construction acti-vities are performed in accordance with the design requirements as esta-blished by project engineering and other applicable requirements. A typical project construction management organization is shown in Figure 11. The contractors are assigned first-level responsibility for the control of the quality of their work. Their performance is coordinated and monitored by the Bechtel field organization. The Bechtel Quality Assurance organization performs documented audits and surveillances and has the capability to perform surveillance inspection. l In cases where the contractors are responsible for quality verification inspection or other quality assurance functions, the contract documents incorporate tha requirements' ftr th2 contracters' quality assurance pro-gram. Contractors' quality assurance and quality control personnel are required to have the appropriate authority, organizational freedom, and independence within their own organization. Contractors' program require-ments are specified by incorporation of the requirements of Reg. Guide 1.28 (6/7/72) or the ASME Boiler and Pressure Vessel Code, Section III, as appropriate. In the event that the contractor is unable to provide an acceptable program, Bechtel may assume quality verification inspection responsibilities or these may be contracted to another organization. 'l,

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LINES OF COORDINATION 14sTRuut4 TAT 10N F10ure 11

i ~ Th] following is a modificaticn to Appendix "A" of tha topical which describes Bechtel's position on Regulatory Guide and ANSI standards: Reg. Guide 1.58 Rev. O, 8/73 Plus positions C.5, C.6, C.7, C.8 ANSI N45.2.6,1973 and C.10 of Rev.1 ' Reg. Guide 1.144 Rev. 1, 9/80 ANSI N45.2.12, 1977 Full Compliance - No Exceptions Reg. Guide 1.146 Rev. O, 8/80 ANSI N45.2.23, 1978 Full Compliance - No Exceptions l i l i

o Attachment A is a modified Tablo I to the topical which describes Bechtel's Quality Program Documents. 1 ~ 7

Attachmerit A - Page 1 c.f 2 O TABLE I BECHTEL QUALITY PROGRAM DOCUMENTS Originating Review for QA Policy Authorizing Document Authority and Program Requirements Approval Conteng Los Angeles Power Division QA N/A Division Manager Division policy supple-Division QA Macual Manager menting and implementing TP0 Quality Policy

• Bechtel Quality Manager-C&S/RRE QA-BPC**

President and Policies and procedures Assurance Manual-Division QA Manager appropriate for overall Bechtel ASME Nuclear Authorized Code program applicable to Comp.nents (BQAM-Inspection Agency ASME work ASME III) (Procurement Supplier Manager Pro-QA-BPC** Manager Procure-Procurement Supplier Quality Manual curement ment Supplier Quality procederes Supplier Quality Quality Division QA Division QA N/A Division QA Procedures for conductini Procedures Manager Manager Division QA activities Available on request to appropriate regulatory agencies. Includes review by Divisfon QA Managers. Note: Revisions to these documents require the same review and approval as the original. BQ-TOP-1 Rev. 3A l l

y mgm TABLE I (CONTINUED) o BECHTEL QUALITY PROGRAM DOCUMENTS Originating Review for QA Policy Authorizing Document Authority and Program Requirements Approval Contents Engineering Designated Division QA Manager *** Manager of Definition of responsi-Department Procedures Individuals Engi neeri ng*** and procedures.for desig and Instructions design review, and docu-ment control in the engineering departments - Construction Construction Division QA Manager Manager Division Responsibilities and Procedures (Quality Construction practice for constructiq Program related) site activities includi[ standard work plans Procurement Manuals Procurement QA-BPC** Cognizant Procedures for home offC (Quality Program Procurement and field procurement related) Managers necessary to follow TP0 Quality Policy M&QS Procedure and Manager M&QS QA-BPC** Manager M&QS Policies and procedures Policy Guides (Quality for performing M&QS Program related) functions Project Manuals Pro-Cognizant Project PQAM Cognizant Note 2 cedures (Quality Team Merber Managers Program related) Includes review by Division QA Managers. Area office EDP's are reviewed and approved by the area office QA Manager and area office Manager of Engineering. Notes: 1 Revisions to these documents require the same review and approval as the original. 2 There are provisions for project unique modificaticns to the above documents to delineate specific project requirements but not depart from the program requirements of this report. Review and approval authority for such modifications are defined within the governing procedures. BQ-TOP-1 Rev. 3A .}}