ML20040G689
| ML20040G689 | |
| Person / Time | |
|---|---|
| Site: | Columbia, Washington Public Power Supply System, Satsop |
| Issue date: | 12/18/1981 |
| From: | Ferguson R WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | |
| Shared Package | |
| ML20040G656 | List: |
| References | |
| WPPSS-QA-004-01, WPPSS-QA-004-R06, WPPSS-QA-4-1, WPPSS-QA-4-R6, NUDOCS 8202160370 | |
| Download: ML20040G689 (57) | |
Text
D Effect e ruary 1,1982 3
D OPERATIONAL QUALITY ASSURANCE o
PROGRAM DESCRIPTION (WPPSS-QA-004) e IE~/I'k APPROVED:
Director, Quality Assurance Date p
ORIGINAL ISSUE: May 10,1978 D
D Washington Public Power Supply System Richland, Washington 99352 D
8W169 0$R D
KO 7
A PDR
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WASMNGTON FUBUCPOWER SUFFLY SYSTM OPERATIONAL enes QUALITY ASSURANCE PROGRAM DESCRIPTION ii O
MANAGEMENT STATEMENT It is the policy of Washington Public Power Supply System (hereinafter called the " Supply System") to design, construct and operate its nuclear power plants O
without jeopardy to the health and safety of the public.
In support of this policy, the Supply System has established a Corporate Quality Assurance Program that is described in the following three documents:
1.
Quality Assurance Program for Design and Construction.
ASME Quality) Assurance Manual (Design and 2.
Construction.
3.
Operational Quality Assurance Program Description (0perations Phase).
O The three documents contain the official Supply System Quality Assurance policies.
Adherence by all affected Supply System organizations is mandatory.
The Operational Quality Assurance Program Description meets the applicable requirements of 10 CFR 50, Appendix B and shall be implemented by written and e
approved procedures and/or instructions.
The Quality Assurance Directorate is mandated the responsibility and authority for establishing, administering and assuring implementation of the Supply System Corporate Quality Assurance Program. The Quality Assurance Director has the responsibility and authority, including stop work authority, to perform actions e
necessary to accomplish this mandate as delineated in the Corporate Quality Assurance Program manuals.
The Quality Assurance Director has my delegated approval authority for the Operational Quality Assurance Program Description and any necessary modifications, e
A f Z, Managing Director s
- R. L. Ferg n
[ Y /T jfRJ Date:
y
/'-
o W N IS R3 e
O WASHINGTON PUBLIC POWER SUFFLY SYSTEM OPERATIONAL QUALITY ASSURANCE PROGRA31 DESCRIITION iii O
LIST OF EFFECTIVE PAGES l
PAGE REVISION PAGE REVISION i
6 II.1-1-II.1-4 G
ii 5
II.1-5 5
iii 6
II.1-6 6
iv & v 5
II.1-7 5
1 1-24 6
II.1-8 6
2 2-3 6
II.1-9 & 11.1-10 5
3 3-3 5
11.1-11 6
4-1 & 4-2 5
11.1-12 5
5-1 5
I I.1 II.1 -20 6
6-1 & 6-2 5
II.1-21 & 11.1-22 5
6-3 6
II.1-23 & 11.1-24 6
7-1 5
II.1-25 5
7-2 & 7-3 6
11.1-26 6
O 3-1 & 8-2 5
11.1-27 5
9-1 5
II.1-28 & II.1-29 6
9-2 6
11.2-1 5
10-1 5
11.3-1 5
0 10-2 6
11-1 & 11-2 5
12-1 & 12-2 5
13-1 5
3 14-1 5
15-1 5
15-2 6
16-1 5
8 17-1 & 17-2 5
13-1 5
I-l & I-?
6 11-1 5
O wens na
- O WAS:lINGTON PUBLIC PO\\7EI'. SUPPLY SYSTEL:
OPEllATION A1.
QUAL. TTY ASSullANCE PitOGilAM DESCitil'I'lON iv O
TABLE OF CONTENTS SECTION TITLE PAGE 0
Cover Page i
Management Statement ii List of Effective Pages iii Table f Contents iv O
1 ORGANIZATION 1-1 2
QUALITY ASSURANCE PROGRAM 2-1 3
DESIGN CONTROL 3-1 4
PROCUREMENT DOCUMENT C2FDOL 4-1 0
5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS 5-1 6
DOCUMENT CONTROL 6-1 7
CONTROL 0F PURCHASED MATERIAL, EQUIPMENT, AND 7-1 SERVICES
'O 8
IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, 8-1 AND COMPONENTS 9
CONTROL OF SPECIAL PROCESSES 9-1 10 INSPECTION 10-1 11 TEST CONTROL 11-1
.O 12 CONTROL OF MEASURING AND TEST EQUIPMENT 12-1 13 HANDLING, STORAGE, AND SHIPPING 13-1 14 INSPECTION, TEST, AND OPERATING STATUS 14-1 NONCONNNG WERIM, M, OR COWONENN 15-1 O
16 CORRECTIVE ACTION 16-1 17 QUALITY ASSURANCE RECORDS 17-1 18 AUDITS 18-1 APPENDIX I QUALIFICATION REQUIREMENTS I-l APPENDIX II POSITION STATEMENTS Introduction II-l II.1 Position Statements for WNP-2 II.1-1 11.1.1 Regulatory Guide 1.8 II.1-1 w*ns as
-_d O
WAS;IINGTON PUBLIC POWEP. SUPPLY SYSTEL:
5 OPEll ATION A1.
PAGE QU Al,lTY ASSUltANCE PltOGitAM DESCitlPTION v
O TABLE OF CONTENTS O
SECTION TITLE PAGE O
11.1.2 Regulatory Guide 1.26 II.1-2 I1.1.3 Regulatory Guide 1.29 II.1-3 11.1.4 Regulatory Guide 1.30 II.1-4 11.1.5 Regulatory Guide 1.33 II.1-6 O
I1.1.5 Regulatory Guide 1.37 II.1-8 I1.1.7 Regulatory Guide 1.38 II.1-11 11.1.8 Regulatory Guide 1.39 II.1-13 1I.1.9 Regulatory Guide 1.58 II.1-14 O
II.1.10 Regulatory Guide 1.64 II.1-18 11.1.11 Regulatory Guide 1.74 II.1-19 11.1.12 Regulatory Guide 1.88 II.1-20 II.1.13 Regulatory Guide 1.94 11.1-23 o
11.1.14 Regulatory Guide 1.116 II.1-24 1I.1.15 Regulatory Guide 1.123 II.1-26 11.1.16 Regulatory Guide 1.144 II.1-28 11.1.17 Regulatory Guide 1.146 11.1-29 II.2 Position Statements for WNP-1/4 II.2-1 O
I ~. 3 Position Statements for WNP-3/5 II.3-1 O
O WN il f4 3 0
Q WASHINGTON FUBLIC FOWER SUFFLY SYSTEM OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 1 - ORGANIZATION 1.1 PURPOSE D
This section provides a description of the authorities and responsi-bilities assigned to Supply System organizational units and indivi-duals involved in establishing, implementing, verifying implementa-tion, and measuring the overall effectiveness of the administrative O
controls and quality assurance program during the initial testing (pre-operational and startup testing) and subsequent operations phases of Supply System nuclear power plants.
O 1.2 SUPPLY SYSTEM ORGANIZATION The Supply System organization responsible for establishing, imple-menting, verifying implementation, and measuring the overall effec-
'O tiveness of the administrative controls and quality assurance program for its nuclear power plants is as depicted in Figures 1-1 through 1-7.
Portions of these activities may be delegated to ex-ternal organizations qualified to the requirements of this Opera-O tional QA Program, hereafter referred to as QA Program, however, the responsibility shall remain with the Supply System.
1.3 MANAGEMENT RESPONSIBILITIES O
1.3.1 The Managing Director / Deputy Managing Director is responsible for the establishment of policies and for overall management of Supply System operations. The Managing Director has issued a " Management O
Statement" which commits the Supply System to design, construct, and operate its nuclear power plants without jeopardy to the health and safety of the public. The Managing Director is the ultimate Supply System authority on matters involving quality. The Managing O
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O WASHINGTON FUBLIC FOWER SUFFLY SYSTEM 6
OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 1-2 O
1.3.1 (Cont'd)
Director / Deputy Managing Director operates through the Director of Quality Assurance, the Director of Power Generation, and the Program g
Directors (Projects) to provide for all quality assurance and quality-related functions for all Supply System nuclear power plants. The Managing Director / Deputy Managing Director arranges through the Directors of Technology, Business Programs, and Safety &
O Security for support services to all Supply System nuclear power plants in such areas as engineering, fuel management, purchasing, licensing, health physics, and records management.
O 1.3.2 The Director, Power Generation, reports to the Managing Director, and is responsible for:
a.
Safe and effic ' ant operation of Supply System nuclear power O
plants subsequent to comercial operation.
b.
Establishment and monitoring of maintenance systems comon to all nucleai power plants.
O c.
Generic training of Power Generation staff.
d.
Development of corporate programs and procedures for power gen-O eration and providing the same to the Program Directors on each project to ensure uniform application.
To accomplish this role, the Director of Power Generation operates O
through the Plant Managers, the Generation Services Manager, and the Generation Training Manager.
1.3.2.1 The Plant Manager for each of the Supply System nuclear power plants O
reports to the respective project Program Directorate prior to comercial operations. Thereafter, the Plant Manager reports to the Director of Power Generation. Prior to comercial operation, the
=
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PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 1-3 0
1.3.2.1 (contd.)
Plant Manager has direct comunicatica access to the Director of O
Power Generation in order to facilitate coordinated development and uniform application of administrative controls and operational philosophies.
The Plant Manager is directly responsible for safe and efficient O
operation of the plant in accordance with the requirements of the Operating License, the Plant Technical Specifications, and the Plant Procedures Manual. Some of the specific responsibilities of the Plant Manager are:
a.
Planning, coordinating, and directing all test, operation, maintenance, and refueling activities subsequent to the issu-ance of an Op'erating License.
b.
Authorizing all plant modifications subsequent to the issuance of an Operating License.
O c.
Qualification and training of plant staff, d.
Approval and control of procurement documents for safety re-lated items and services.
O e.
Controlling purchased equipment and materials intended for plant use.
O f.
Establishment and implementation of a calibration pronram for I
Measuring & Test Equipment (including installed instruments covered by the Plant Technical Specifications).
g.
Dispositioning of nonconforming items.
O h.
Control and maintenance of on-site quality assurance records.
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O WASHINGTON PUBLIC POWER SUPPLY SYSTEM OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIP* ION 1-4 O
l 1.3.2.1 (Cont'd) i.
Implementation of the in-service inspection program.
O The Plant Manager operates through the Operations Manager, the Main-tenance Manager, the Technical Manager, the Health Physics / Chemistry Manager *, the Training Supervisor, and the Administrative Super-visor. The plant organization (see Figure 1-3) and functional g
responsibilities of key plant personnel are described in Cnapter 13 of the Final Safety Analysis Report for the applicable nuclear power plant.
O
- The Health Physics / Chemistry Manager administratively reports to the Director of Safety & Security.
1.3.2.2 The Manager, Generation Training, reports to the Director of Power 3
Generation and is responsible for operations training policy and guidance for the nuclear plants and for the conduct of central training services for nuclear plant operations.
1.3.2.3 The Manager, Generation Services, reports to the Director of Power Generation and is responsible for providing support services to the Plant Managers in acquisition, storage, and reporting of operational and maintenance data; planning and scheduling plant outages for re-O fueling and maintenance activities; preparation /coordMtion for review and approval / transmittal to the Nuclear Regulatory Commission of operating reports required by the applicable plant Technical Spe-cifications; maintenance of c common policy for test and startup for nuclear projects; managing support projects including Emergency Operating Facilities; and providing central maintenance and non-destructive examination services.
1.3.3 The Program Director, for each of the Supply System nuclear projects reports to the Managing Director and is responsible for plant WFttS R3 0
O WASHINGTON PUBLIC POWER SUFFLY SYSTEM OPERATIONAL 6
QUALITY ASSURANCE PROGRAM DESCRIPTION 1-5 O
1.3.3 (contd.)
activities prior to commercial operation. The Program Directorate
.O is described in Chapter 13 of the Plant FSAR.
1.3.4 The Director, Quality Assurance, reports to the Managing Director and is responsible for establishing QA Program requirements, O
verifying implementation, and measuring the overall effectiveness of the administrative controls and the QA Program. The Director of Quality Assurance is also responsible for directing performance of QA/QC functions and for interfacing QA/QC-related activities with the Nuclear Regulatory Commission and the Authorized Inspection
- O Agency. The Director of Quality Assurance or his designated alter-nate has the responsibility and authority to stop unsatisfactory work and control further processing, delivery or installation of nonconforming material during plant operation, maintenance, modifi-O cation, and in-service inspection. The Director of Quality Assur-ance has comunication channels with all senior management personnel responsible for the performance of quality-related functions. To accomplish this role, the Director of Quality Assurance operates
'O through the Manager of Operational Quality Assurance, the Manager of Procurement Quality Assurance, the Manager of Quality Performance &
Measurements, and the Manager of Plant Modifications Quality Assur-l ance. The qualification requirements for the position of Director, Quality Assurance, are described in Appendix I, " Qualification Requirements".
1.3.4.1 The Manager, Operational Ouality Assurance, reports to the Director of Quality Assurance and has direct management responsibility for QA/QC functions related to initial testing and subsequent operations phase activities. He has stop work authority to prevent noncon-formances and maintain quality. The Manager of Operational Quality 9
Assurance operates through the Plant QA Managers (located on-site) wetts R3 0
- O WASHINGTON PUBLIC POWER SUFFLY SYSTE51
" 'V*
OPERATIONAL 6
QUALITY ASSURANCE PROGRAM DESCRIPTION 1-6
'O 1.3.4.1 (Cont'd) and staff engineers. The qualification requirements for this posi-O ti n are as described in Appendix I, " Qualification Requirements".
J Some of the spe'cific responsibilities of the Manager, Operational Quality Assurance, are:
a.
Establishment of (i) the Operational QA Program Description O
(WPPSS-QA-004), and (ii) the Supply System Quality Assurance Manual for Operation.
b.
Providing functional and administrative direction to the Plant QA Managers for the performance of their activities.
c.
Providing supporting QA/QC staff, to the Plant QA Managers in order to assure adequate coverage of peak period activities (such as maintenance, modification, refueling, and in-service inspections).
d.
Procurement control and inspection of nuclear fuel.
- O 1.3.4.1.1 The Plant 0A Manaaer for each nuclear plant (located on-site) reports to the Manager of Operational Quality Assurance and is responsible for conducting plant 0A/QC activities in accordance O
with the Supply System QA Manual for Operation and 0A/QC procedures and/or instructions. He directs the activities of the plant QA Supervisor and the plant QC Supervisor and has the authority and responsibility to issue a stop work order when
'O the activity being performed does not comply with the appli-cable provisions of the Supply System QA Manual for Operation and its implementing procedures. When the unit is operating, the Plant QA Manager may recommend to the Plant Manager that O
the unit be shutdown. The Plant Manager, however, has the Whits R3 lh
O CASHINGTON PUBLIC POWER SUPPLY SYSTEM OPERATIONAL 6
PAGE QUALITY ASSURANCE PROGRAM DESCRIITION 1-7 O
1.3.4.1.1 (Cont'd) final responsibility for the overall evaluation of all aspects o
and implications of shutting down the operating unit. Qualifi-cation requirements for this position are described in Appendix I " Qualification Requirements". The Plant QA Manager is speci-fically responsible for:
.O a.
Review of and concurrence with documents affecting safety, including changes thereto, to assure that applicable QA requirements (e.g., the necessary inspection requirements,
.g QC hold points, final documented verification of imple-mented procedures and checklists, methods, and acceptance criteria) have been identified and specified therein.
Examples of documents subject to review and concurrence by QA reviewers are (i) procedures and/or instructions which 10 address: operations, maintenance, technical specifica-tions, in-service inspection and testing, modifications, calibration, testing, fuel handling, and procurement; (ii) plant originated design changes and specifications; (iii)
O l
nonconformance and corrective action reports; and (iv) plant originated procurement documents.
b.
Surveillance verification of in-plant activities to assure O
that they are being conducted in accordance with approved.
l procedures and/or instructions.
Included in the scope of this surveillance program are:
(i) Control room opera-tions; pre-operational, startup, and operational tests; O
maintenance, modification, repair, and calibration; per-sonnel training; and refueling activities; (ii) activities associated with satisfying technical specifications and inservice inspection and testing; and (iii) activities O
associated with the implementation of security, emergency response, fire protection, and radiological protection programs.
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.O WASHINGTON FUBLIC FOWER SUFFLY SYSTEM OPERATIONAL PAGE l
QUAL.ITY ASSURANCE PROGRASI DESCRIPTION 1-8 0
1.3.4.1.1 (Cont'd) c.
_ Ferformance of required inspections, examinations, and O.
measurements associated with maintenance, modification, repair, test, nuclear fuel receipt,-radioactive waste shipping, and refueling activities.
~
d.
Participating in plant staff meetings which involve dis-O cussions of daily and projected plant work loads and as-suring proper staffing (QA/QC) levels during peak period activities (such as maintenance, refueling, modifications, or In-Service Inspection).
1.3.4.2 The Manaaer, Procurement Quality Assurance, reports to the Director of Quality Assurance and is primarily responsible for the implementation of surveillance / audit program of off-plant activities performed by O
the Supply System vendors and the Nuclear Steam Supply System (NSSS) suppliers. Some of the specific responsibilities of the Procurement QA Manager are:
O Establishing, maintaining, and issuing a listing of evaluated a.
vendors who are utilized for procurement of safety-related items (other than comercial grade off-the-shelf items as defined in 10CFR 21) and services.
O b.
Planning, coordinating, and performing surveillances and audits of off-plant activities of vendors.
O c.
Exercising stop work authority over off-plant vendor's/
contractor's activities to prevent nonconformances and maintain quality.
O d.
Performing receiving inspection of items other than nuclear fuel.
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.O WASHINGTON PUBLIC FOWER SUFFLY SYSTEM OPERATIONAL PAGE QUALITY ASSURANCE PROGRA.\\1 DESCRIPTION
,g O
1.3.4.3 The Manager, Quality Performance & Measurements, reports to the Director of Quality Assurance and is primarily responsible for verifying implementation of administrative controls and the quality assurance program through the establishment.and conduct of an audit D
program over activities performed by Supply System organizations and to assess the overall effectiveness of the quality assurance program implementation. Some of the specific resoonsibilities of the Manager of Quality Performance & Measurements are:
_0 4
a.
Certification of Supply System personnel who are required to be qualified / certified in accordance with SNT-TC-1A and its Supplements.
O b.
Qualification / certification of audit personnel.
c.
Audits of activities performed by Supply System organizations O
(both on-site and off-site); identifying quality assurance pro-gram nonconformances, and if appropriate, recommending solu-tions; evaluating corrective actions; and verifying correction of identified nonconformances.
O d.
Maintenance and control of (i) QA procedures and/or instruc-tions for home-office activities, (ii) the Operational QA Pro-gram Description (WPPSS-0A-004), and (iii) the Supply System 0A
!O Manual for Operation.
e.
Exercising Stop Work authority as necessary to prevent noncon-formances and maintain quality.
O f.
Verifying implementation of administrative controls and the l
quality assurance program by establishing and conducting a surveillance program over activities of off-site Supply System O
organizations.
l l
l WNis na lO 1
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O CASHINGTON PUBLIC FOWER SUFFLY SYSTEM 6
OPERATIONAL QUALITY ASSURANCE PROGRAM DESCRIPTION 1-10 O
1.3.4.3 (Cont'd) g.
Reviewing and concurring with administrative directives and procedures of site Supply System organizations.
g h.
Periodically analyzing nonconformance reports, surveillance reports, audit reports, and I&E reports to identify any quality trends and reporting significant results to appropriate manage-g ment for review and assessment.
1.3.4.4 The Manager, Plant Modifications Quality Assurance, reports to the Director of Quality Assurance and has direct management responsibil-
.O ity for QA/QC functions related to plant modification activities that are comparable to activities occurring during the construction phase. The Manager of Plant Modifications Quality Assurance has the stop work authority to prevent nonconformances and maintain quality.
1.3.5 The Director, Technology, reports to the Managing Director and is responsible for providing engineering and design control, reactor safety evaluation, nuclear and environmental analysis, plant simu-O l
lator support, nuclear fuel supply, and maintenance / surveillance engineering support as required for each Supply System nuclear plant.
The Director of Technology is specifically responsible for:
- O a.
Coroorate design control establishment and maintenance, b.
Design and engineering for plant system design changes and modifications.
'O c.
Planning and over-viewing the implementation of the plant pre-service and inservice inspection.
O d.
Technical resolution of nuclear safety, licensing, environ-mental, geological, and radiological issues.
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O WASHINGTON PUBLIC FOWER SUFFLY SYSTEM 6
OPERATIONAL QUALITY ASSURANCE PROGRA31 DESCRIPTION 1-11 0
1.3.5 (contd.)
e.
Initial fuel supply.
O f.
Reload fuel supply, design, and licensing.
g.
Maintaining a current engineering data base for each plant.
O To accomplish this role, the Director Technology, operates through Assistant Directors, Technology-Systems Engineering, Generation Engineering, Nuclear Engineering Services, and Fuels & Environment.
O 1.3.5.1 The Assistant Director Technology - Systems Engineering, reports to the Director of Technology and is responsible for:
a.
Design and engineering for plant changes and modifications.
b.
System engineering support for plant turnover.
c.
The control of the plant design data and drafting.
d.
Control of Q-list changes.
e.
Design procedures and standards required for plant coafigura-O tion control.
1.3.5.2 The Assistant Director Technology - Generation Engineering, reports to the Director of Technology and is responsible for:
'O a.
Environmental and seismic qualification of plant equipment.
b.
Preparation, maintenance, and distribution control of pre-O service and inservice inspection programs, technical overview of program implementation, and preparation of data reports.
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O WASHINGTON FUBIJC FOWER SUFFLY SYSTEh!
" "V" OPERATIONAL 6
PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 1-12 0
1.3.5.2 (Cont'd) c.
Materials and welding engineering.
O d.
Technical program management and licensing issue resolution.
e.
ASME Code interpretation.
.O f.
Maintenance engineering support to the plant staff.
g.
Construction engineering support for plant modifications.
'O h.
Coordination and control of the plant design change process.
1.3.5.3 The Assistant Director Technology - Nuclear Engineering Services, reports to the Director of Technology and is responsible for:
a.
Providing reliability and related analyses, including probabil-istic risk analysis.
o b.
Review of nuclear fuel designs.
c.
Providing analytical support in areas such as fuel, reactor and plant performance, fuel isotopic concentrations and analysis of O
off-standard reactor operating conditions.
l l
d.
Providing engineering support in acquiring, operating and main-taining training simulators.
O e.
Providing anlayses to demonstrate the response characteristics of training simulators and to certify the validity of the simu-lation.
O l
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O CASHINGTON FUBUC FOWER SUFFLY SYSTEM OPERATIONAL 6
emoa QUALITY ASSURANCE PROGRAM DESCRFTION 1-13 0
1.3.5.3 (Cont'd) f.
Providing plant transient analyses to support operational decision making and to form a basis for reload licensing and g
technical specification changes.
g.
Reviewing, upon request, Reportable Occurance Reports.
g h.
Reviewing and/or authorizing, upon request, portions of Safety Analysis Reports and Environmental Reports.
1.3.5.4 The Assistant Director Technology - Fuels & Environment, reports to the Director of Technology and is responsible for:
a.
Assuring an adequate and timely supply of high-quality fuel for each plant through fuel cycle planning and surveillance, O
acquisition of fuel and fuel cycle services, technical control administration and coordination of reload licensing, b.
Providing for the effective and efficient utilization of fuel O
resources by preparing near and long-term planning of procure-ment and inventory strategies.
I c.
Environmental monitoring and assuring compliance with environ-
.O mental regulations during design, construction and operation.
I d.
Review of proposed changes to the Environmental Technical Spe-cifications.
- O e.
Providing support to the Plant Managers in the implementation of off-site Environmental Technical Specifications.
'O f.
Performing off-site environmental, geological and radiological monitoring studies.
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CASHINGTON PUBLIC POWER SUFFLY SYSTEM
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PAGE QUALITY ASSURANCE PROGRAM DFSCRIPTION 1-14 3
1.3.6 The Director, Safety and Security, reports to the Managing Director 1
and is responsible for development and implementation of policies and programs which support operation of Supply System plants in the 3
areas of safety and security. Areas in which the Director of Safety and Security, provides support for the plant include radiological programs, health physics and chemistry, safeguards and physical l
security, industrial safety and fire protection, emergency prepared-3 ness, nuclear safety assurance, and licensing. The Deputy Director of Safety and Security serves as Chairman of the Corporate Nuclear Safety Review Board which functions to provide an independent review of plant activities in accordance with the Technical Specifications for the applicable nuclear power plant. To accomplish this role, the Director of Safety & Security operates through the Manager of Health & Safety Programs, the Manager of Nuclear Safety Assurance, the Manager of Licensing Programs, and the Manager of Security Programs.
1.3.6.1 The Manager, Health & Safety Programs, reports to the Director of Safety & Security and is responsible for the development and coor-dination of Supply System programs for industrial safety & hygiene, health physics, fire protection, medical, and emergency preparedness.
The Manager of Health & Safety Programs is specifically responsible for providing:
a.
Assistance to appropriate management in the implementation of their responsibilities for an effective program of personnel safety and loss prevention.
b.
Technical assistance and support services in the areas of health physics, radio-chemistry, and emergency preparedness, i
i c.
Dose assessment, dosimetry and bio-asshy function.
?
l l
wpsts as t
l
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CASHINGTON PUBLIC FOWER SUFFLY SYSTD1 OPERATIONAL 6
PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 1-15 b
1.3.6.1 (Cont'd) d.
Maintaining a radiation exposure program which meets the intent l3 of as low as reasonably achievable (ALARA).
e.
On-site meteorological services.
,)
f.
Development and maintenance of emergency preparedness plans and providing related training.
1.3.6.2 The Manager, Nuclear Safety Assurance, reports to the Director of
)
Safety & Security and is responsible for conducting independent evaluations of the adequacy of plant safety programs. An on-site Safety Engineering Group (SEG) for ei nuclear plant reports to the Manager of Nuclear Safety Assurance and is responsible for:
S a.
Evaluation of plant operations froa a safety perspective.
b.
Evaluation for technica' adequacy and clarity of all procedures important to the safe operation of the plant.
c.
Assessment of plant performance regarding conformance to re-quirements related to safety.
9 d.
Comparison of the operating experience of the plant and plants of similar design.
e.
Assessment of plant nuclear safety programs.
O f.
Any other matters involving the safety of the nuclear power plant that an independent review deems appropriate for con-sideraticn.
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O wasa Nc1ON PUBLIC POWER SUFFLY SYSTE11 6
OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 1-16 O
1.3.6.3 The Manager, Licensing Programs, reports to the Director of Safety and Security, and is responsible for:
a.
Providing coordinated corporate-level management of licensing O
activities,
b.
Providing a coordinated and controlled interface with the Nuclear Regulatory Commission (NRC) on issues pertaining to NRC g
Operating Licenses.
c.
Developing and implementing consistent corporate licensing policies.
d.
Assuring technical adequacy of licensing submittals.
e.
Review of plant activities to assure compliance with the O
environmental licensing comitments.
1.3.6.4 The Manager, Security Programs, reports to the Director of Safety &
Security and is' responsible for overall Supply System security ac-O tivities. The Manager of Security Programs is specifically respon-sible for:
a.
Administration of a security program which includes pre-O employment screening, physical security surveys, and inves-tigations and loss prevention.
I b.
Management of security force during the operational phase by O
assuring that physical security is consistent with needs and is maintained within individual plant safeguards security plans.
c.
Providing training, administrative, and technical assistance to
'O Plant Managers in the area of plant security.
Wet 15 R3 O
- O WASMNGTON PUBUC FOWF.R SUFFLY SYSTut 6
OPERATIONAL QUALITY ASSURANCE PROGRAM DESCRIITION 1-17 O
1.3.7 The Director, Business Programs, reports to the Managing Director, and is responsible for providing records management and procurement services. To accomplish this role, the Director of Business Programs operates through the Manager of Records Management, the O
Manager of Central Procurement, and the Manager of Central Materials Management.
1.3.7.1 The Mansger, Records Management, reports to the Director of Business
- O Programs and is responsible for the establishment, maintenance, and implementation of the following
a.
Records control system for obtaining, processing, filing, re-O trieving, and dispositioning of both corporate and plant records.
b.
Distribution control system for corporate procedures.
lO 1.3.7.2 The Manager, Central Procurement, reports to the Director of Busi-ness Programs and is responsible for:
O Procurement of items and services in response to approved pur-a.
chase requisitions.
b.
Preparation, negotiation, administration, and maintenance of O
procurement contracts.
1.3.7.3 The Manager, Central Materials Management, reports to the Director of Business Programs and is responsible for providing the following O
support functions:
1 a.
Procurement of operational spares.
,O b.
Coding, cataloging, handling, storage, and shipping of procured
~' ems.
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cAsmNGTON FUBUC FOWER SUFFLY SYSTEM OPERATIONAL enea QUALITY ASSURANCE PROGRA.\\1 DESCRIPTION 1-18 O
FIGURE 1-1 g
MANAGING DIRECTOR DEPUTY MANAGING DIRECTOR O
I WN P-1/ 4 WNP 2 WNP-3 / 5 POWER GENERATION PROGRAM DIRECTOR PROGRAM DIRECTOR PROGRAM DIRECTOR DIRECTOR O
SAFETY & SECURITY OUAUTY ASSURANCE TECHNOLOGY DIRECTOR BUSINESS PROGRAMS IRECTOR DIRECTOR I
'O DEPUTY DIRECTOR O
- O SUPPLY SYSTEM ORGANIZATION RELATIVE TO OPERATIONAL QA O
W>t tS R3 lO
"*V*
UASHINGTON PUBLIC FOWER SUFFLY SYSTD1 6
OPERATIONAL Pact QUALITY ASSURANCE PROGRA31 DESCRIITION 1-19 O
FIGURE 1-2 O
POWER GENERATION DIRECTOR O
GENERATION GENERATION SERVICES TRAINING MANAGER MANAGER O
e uma e e e e e nas e uma e um e num e sum a me e uur a mum e ums a su a sus e uma e uns e um e uma e sus e um a mas e e
e man e uma e um ON. SITE O
. wNP. i,4
. wNe.2
. wNP-se s PLANT MANAGER PLANT MANAGER PLANT MANAGER O
+ THESE POSITIONS REPORT TO THE RESPECTIVE PROGRAM OIRECTORATE PRIOR TO COMMERCIAL OPERATION 10 1
POWER GENERATION ORGANIZATION 1
'O l
lO l
l w>tts na O
O
" "V-CASHINGTON PUBLIC POWER SUFFLY SYSTEh!
OPERATIONAL 6
PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 1-20 O
FIGURE 1-3 O
PL-nNT MANAGER ASSISTANT PLANT MANAGER O
- H H HYSICS/
MAINTENANCE OPERATIONS TECHNICAL MANAGER MANAGER MANAGER MANAGER O
TRAINING ADMINISTRATIVE Q
SUPERVISOR SUPERVISOR
- THIS POSITION REPORTS ADMINISTRATIVELY TO THE DIRECTOR OF SAFETY & SECURITY.
O O
PLANT ORGANIZATION O
- O O
WASHINGTON PUBLIC POWER SUPPLY SYSTEM 6
OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION j.,g O
FIGURE 1-4 g
QUALITY ASSURANCE DIRECTOR O
QUAUTY PLANT PROCUREMENT OPERATIONAL P
QUAUTY A ANCE QUAUTY A ANCE 3M UREMENTS QU L A SU A E MANAGER MANAGER OFF. SITE I
B e um e sus e uma e e e um e uma e uma e um e am a sum ll emm a amm o amm o se e se summ a uma e aus e sum e amm o sum e aus e um o e e e e m ON-SITE WNP 1/4 PLANT WNP-2 PLANT WNP-3/5 PLANT QUAUTY ASSURANCE QUAUTY ASSURANCE QUAUTY ASSURANCE MANAGER MANAGER MANAGER QUAUTY QUAUTY QUAUTY ASSURANCE ASSURANCE ASSURANCE SUPERVISOR SUPERVISOR SUPERVISOR QUAUTY CONTROL QUALITY CONTROL QUAUTY CONTROL SUPERVISOR SUPERVISOR SUPERVISOR b
QUALITY ASSURANCE ORGANIZATION D
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""V-WASHINGTON PUBLIC POWER SUFFLY SYSTE&i OPERATIONAL mas QUALITY ASSURANCE PROGRAM DESCRIPTION 1-22
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!O FIGURE 1-5 TECHNOLOGY l
DlHECTOR lO NUCLEAR SYSTEMS GENERATION FUELS &
EN IN E"'NG l
ENGINEERING ENGINEERING ENVIRONMENT
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- sst maecroaricmotoov assr.anscroa rsemotocv Assi Dmicroa rECmOLOGY i
lO O
lO TECHNOLOGY ORGANIZATION O
1 i
- O i
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O wasmNGTON PUBUC F0WER SUFFLY SYSm1 OPERATIONAL 6
enes QUALITY ASSURANCE PROGRAM DESCRIPTION 1-23
- O FIGURE 1-6
'O lj SAFETY & SECURITY DIRECTOR
- O l
HEALTH & SAFETY NUCLEAR SAFETY UCENSING SECURITY PROGRAMS ASSURANCE PROGRAMS PROGRAMS MANAGER MANAGER MANAGER MANAGER
- O
.O O
O SAFETY & SECURITY ORGANIZATION
- O O
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O cAsmNTION PUBUC POWER SUFFLY SYSm!
" V" OPERATIONAL 6
PAG E QUALITY ASSURANCE PROGRAM DESCRIPTION 1-24 O
FIGURE 1-7 O
BUCINESS PROGRAMS DIRECTOR
'O RECORDS CENTAAL CENTRAL MANAGE AGE M N GE T
MANAGER O
O O
BUSINESS PROGRAMS ORGANIZATION O
O l
WkttS R3 0
O WASHINGTON FUBLIC FOWER SUFFLY SYS'IEM OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 2-1 0
2 - QUALITY ASSURANCE PROGRAM 2.1 PURPOSE O
This sectidn provides an overall description of the QA Program that will be applied to initial testing and subsequent operation and maintenance activities throughout the life of Supply System ruclear O
p wer plants.
2.2 GENERAL 2.2.1 The QA Program and its implementing procedures and/or instructions O
are or will be structured to comply with the Regulatory Position of QA-related Regulatory Guides as identified and modified in Appendix II, " Position Statements". A matrix of implementing procedures /
instructions cross referenced against each criterion of Appendix B to 10CFR50 will be included in this section not later than ninety (90) days prior to initial fuel loading.
l 2.2.2 A list of safety-related items that will be subject to the appli-O cable controls of the OA Program is included in the Final Safety Analysis Report (FSAR) for the applicable Supply System nuclear power plant. Changes to this listing shall be controlled by the Assistant Director Technology-Systems Engineering and approved by O
the Plant Manager.
O O
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O WASHINGTON PUBLIC POWER SUFFLY SYTTE11
"'V' OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 2-2 O
2.2.3 Applicable provisions of the QA Program shall be implemented by the earliest of the following and shall remain in effect for the life of Supply System nuclear power plants:
O a.
Prior to inception of the activity, b.
At the time of temporary / permanent transfer of system / component custody to the Test and Startup Organization.
c.
Ninety (90) days prior to initial fuel loading.
2.2.4 Revisions to the QA Program will be made by the corporate Quality
.O Assurance. The Nuclear Regulatory Commission will be notified of (a) programatic changes (except for those that are editorial in nature) for review prior to implementation of these changes, and (b) organizational changes of substantial nature within thirty (30)
O days after announcemeat.
2.2.5 Managers of Supply System organizations responsible for implementing the applicable provisions of the QA Program shall assure that acti-O vities that affect safety-related functions of plant items are per-formed by personnel who have been indoctrinated and trained. The 1
l scope, objective, and method of implementing the indoctrination and training program shall be documented. Proficiency of personnel per-O forming activities that affect safety-related functions of plant items shall be maintained by retraining, re-examinaticn, and/or re-certifying, as applicable. Methods shall be provided for document-ing training.
'O O
l l
Wells R3 lO
O CASHINGTON FUBLIC FOWER SUFFLY SYSTEM OPERATIONAL QUALITY ASSURANCE PROGRAM DESCRIPTION 2-3 0
2.2.6 The scope, implementation, and effectiveness of the QA Program is routinely audited by the corporate Quality Assurance. Copies of audit reports are presented to Supply System management to provide O
for assessment of the effectiveness of the QA Program. Addition-ally, on an annual basis, the Supply System management arranges for an independent audit and evaluation of the adequacy of the scope, implementation, and effectiveness of the 0A Program. This is ac-O complished by knowledgeable personnel outside of corporate Quality Assurance to assure achievement of an objective program assessment.
Results of these independent audits are reported to the Managing Director / Deputy Managing Director.
O O
O O
O O
W> TIS R3 0
1
_ ________j
- O WASHINGTON PUBUC POWER SUPPLY SYSTEM OPERATIONAL PAGE QUALITY ASSURANCE PROGRA31 DESCRIITION 3-1 O
3 - DESIGN CONTROL 3.1 PURPOSE O
This section sets forth requirements for the control of new designs, changes thereto, and plant modifications that affect safety-related functions of structures, systems, and components.
g 3.2 GENERAL 3.2.1 Organizations (both internal and external) participating in the pre-0 1
.paration, review, approval, and verification of design documents (drawings, design input and criteria, specifications, design analy-sis, computer programs, system descriptions, procedures, and instruc-tions) associated with new designs, changes thereto, and plant modi-O fications shall develop and implement procedures that clearly de-lineate actions to be accomplished. These procedures shall contain provisions to assure that:
- O a.
Applicable regulatory requirements and design bases specified in the Final Safety Analysis Report are correctly translated into design documents.
lO b.
Appropriate quality standards are specified and included in de-sign documents and that changes from such standards are docu-mented, approved, and controlled.
O c.
Design analysis (reactor physics, stress, thermal, hydraulic, accident, etc.) is performed, where applicable.
lO WFI15 R3 10
O WASillNGTON PUBLIC POVIEi'. SUPPLY SYSTEL*
- * 5 OPERATIONAL PAGE QUALITY ASSUllANCE PROGRAM DESCitlPTION 3-2 O
3.2.1 (cont'd.)
.O d.
Items such as compatibility of materials, parts, components, and processes selected; accessibility for inservice inspection, maintenance, and repair; and delineation of acceptance criteria for inspections and tests are considered, where applicable, dur-O ing the design development and review phases.
e.
Errors and deficiencies discovered in approved design documents that could adversely affect safety-related structures, systems, O
and components are documented and that appropriate corrective action is taken, f.
Development, maintenance and use of computer code programs is
- O controlled. Where the use of a particular computer code for performing design calculations is specified, such computer code is verified and certified for use.
.o 3.2.2 Where two or more design organizations are involved in the perform-ance of design, necessary interface controls (both internal and ex-ternal) shall be documented and controlled between the participating organizations, particularly in the area of review, approval, release,
!O distribution and revision of interface documents.
3.2.3 Design verification, to provide assurance that the design meets the specified design inputs, shall be performed by utilizing methods such i
- g as design reviews, alternate calculations, or qualification testing.
3.2.4 Design verification procedures shall be established and implemented.
These procedures shall:
O a.
Provide for the determination of the method for design verifica-tion that will be utilized.
WP 115 R3 O
WASIIINGTON PUBLIC PO)7En SUPPLY SYSTEI."
5 OPEllATIONAL PAGE QUALITY ASSURANCE PitOGRA31 DESCitII"FION 3-3 0
3.2.4 (cont'd.)
O b.
Provide assurance that the design verification is performed and documented by personnel other than those who performed the ori-ginal design, but who may be from the same organization.
O c.
Identify the responsibilities of the verifier; areas, features, and pertinent considerations to be verified; and the documenta-tion to be generated.
O d.
Require that where verification method is only by test, the pro-totype, component, or feature testing is perfonned at the earli-est practicable stage.
O e.
Require the accomplishment of design verification, in all cases, prior to relying upon the item to perform its safety function.
3.2.5 Design documents shall be reviewed for adequacy by the originating O
rganization unless delegated to another qualified organization.
Such reviews shall be documented and maintained on file.
l 3.2.6 Changes to approved design documents shall be subjected to design O
c ntrol measures comparable with those that were applied to the ori-ginal design and shall be approved by the same organization that ap-proved the original design, unless delegated to another qualified organization.
O 3.2.7 Measures shall be established to assure that plant personnel and other affected organizations are made aware of design changes /-
modifications that affect the performance of their duties.
O W W19 $ R3
!O i
.O CASIIINGTON PUBLIC POUER SUPPLY SYSE 5
OPERATIONAL,
'$41 QUALITY ASSURANCE PROGRAM DESCRIITION O
4 - PROCUREMENT 00CUMErir CONTROL O
4.1 PURPOSE This section sets forth requirements for preparation, review, and approval of procurement documents and changes thereto in order to O
control the quality of vendor furnished safety-related plant items and services.
4.2 GENERAL
- O 4.2.1 Procedures / instructions shall be establishea and implemented to con-trol procurement-related activities such as procurement planning; preparation, review, approval and control of procurement documents; O
vend r selection; bid evaluations; and review and concurrence of ven-dors' quality assurance programs. These procedures / instructions shall clearly delineate the sequence of actions to be accomplished in the preparation, review, and approval of procurement-related docu-O ments and shall identify those positions or groups responsible for performing those actions.
4.2.2 Procurement documents for items (other than commercial grade off-the-shelf items, as defined in 10CFR21) and for services shall re-O quire, where necessary, vendors or subvendors to provide a quality assurance program consistent with the applicable provisions of the QA Program.
O 4.2.3 As deemed necessary, the procurement documents will provide for right of access to the vendor's facilities and records for source inspection / audit by Supply System or its designee.
- O WA115 m3
'O
d'O WASilINGTON F81BLIC POUEI'. SUFFLY SYSTEI.:
OPERATIONAL, QUALITY ASSURANCE PROGRAM DESCRIMION 4-2
.O 4.2.4 Procurement documents shall contain er reference applicable technical requirements (such as regulations, specifications, drawings, codes, lO and standards), test and inspection requirements, and special process instructions that must be complied with by vendors.
4.2.5 Procurement documents shall contain, as. applicable, requirements
- O which identify the do umsntation (such as drawings, specification, inspection and test records, personnel and procedure qualifications, Certificates of Conformance or equivalent certifications, and mater-ial chemical and physical test results) to be prepared, maintained,
- O submitted, or made available to Supply System for review and/or ap-proval.
4.2.6 Procurement documents shall be reviewed by QA personnel.
This review
!O will be performed and documented to assure that quality requirements are correctly stated, that they can be inspected and controlled, and the procurement documents have been prepared to incorporate appro-priate provisions of 4.2.2 through 4.2.5.
1 O
i 4.2.7 Changes (other than those that are of administrative natu're) to ap-proved procurement documents shall be subjected to the same degree of control that was applied during the preparation of original procure-lg ment documents.
O
- O WW195 R3 iO
4 rO WAS:IINGTON PUBLIC PO\\7EI'. SUFFLY SYSTEL:
^ * * -
5 OPEllATIONAL QUALITY ASSUltANCE PitOGilAM DESCillPTION I-Y
,O 5 - INSTRUCTION
S. PROCEDURE
S. AND DRAWINGS
- O 5.1 PURPOSE This section sets forth requirements for instructions, procedures, and drawings for activities that affect safety-related functions of
'O plant itams.
5.2 GENERAL O
5.2.1 Activities that affect safety-related functions of plant items shall be described by and accomplished through implementation of documented procedures, instructions, or drawings, as appropriate.
5.2.2 Procedures / instructions shall be established to assure that procedures, instructions or drawings include appropriate quantitative (such as dimensions, tolerances, and operating limits) or qualitative (such as comparative workmanship samples) acceptance criteria for O
determining satisfactory work performance and quality compliance.
O
- O O
Wbl15 R3
"O WAS*IINGTON PUBLIC POVIEI'. SUPPLY SYSTEL:
OPEllATIONAL PAGE QUALITY ASSUltANCE PitOGilAM DESCitlPTION 6-1
- O 6 - DOCUMENT CONTROL
- O 6.1 PURPOSE This section sets forth requirements for the control of documents pertaining to activities that affect safety-related functions of
- O plant items.
6.2 GENERAL O
6.2.1 Procedures / instructions shall be established and implemented to con-trol the issuance of documents such as instructions, procedures, and drawings, including changes thereto, which pertain to activities af-fecting safety related functions of plant items. These procedures /
- O instructions shall provide assurance that:
a.
Documents are reviewed for technical adequacy, by qualified in-dividuals, prior to approval for release.
- O b.
Procedures / instructions addressing maintenance, calibration, testing, drawings, specifications and etc. are reviewed and con-curred with by qualified QA personnel for quality-related as-pects prior to approval for release except in unusual situations wherein QA concurrence shall be obtained at the earliest avail-able opportunity.
c.
Maintenance, modification, and inspection procedures are re-
.O viewed by QA personnel to assure the need for inspection, iden-tification of inspection personnel, and documentation of inspec-tion results plus necessary inspection requirements, methods, and acceptance criteria is provided.
- O WP 115 R3 j
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!O WASHINGTON PUBLIC PO)7EI'. SUPPLY SYSTEL" "E*-
OPEltATIONAL 5
PAGE QUALITY ASSURANCE PROGilAM DESCRIPTION 6-2 0
6.2.1(cont'd.)
'O d.
Documents are approved for release by authorized personnel prior to implementation.
e.
Documents are available at the location where prescribed acti-
- O vity will be perfonned prior to coninencing the work, f.
Char.ges (other than those that are of administrative nature) to approved documents are reviewed and approved by the same organi-
- O zations that performed the original review and approval unless delegated to other appropriately qualified organizations.
g.
Approved changes to documents are promptly incorporated into jO instructions, procedures, drawings, and other appropriate docu-ments.
~
h.
Obsolete or superseded documents are controlled to prevent their O
inadvertent use.
6.2.2 Current revision status of documents, such as instructions, pro-cedures, drawings, and specifications shall be identified and main-lO tained.
6.2.3 As a minimum, the applicable requirements of this section, shall be applied to the following documents:
!O a.
Design documents b.
As-built drawings O
c.
WW115 R3 lO 4
O UASmNGTON FUBUC FOWER SUFFLY SYSTEM OPERATIONAL QUALITY ASSURANCE PROGRAM DESCRIPTION 6-3 L
O 6.2.3 (cont'd.)
d.
Operational QA Program Description e.
Final Safety Analysis Report
'O f.
Procedures and/or instructions for plcnt modifications, opera-tion, maintenance, inspection, testing and calibration O
g.
Reports of nonconformances h.
Supply System QA fiantal for Operation.
O O
O O
O O
... = >
0
O WAS;IINGTON PUBLIC POV/EP. SUPPLY SYSTEI.;
OPEll ATi()N A1.
PAGE QUAL.lTY ASSultANCE PltOGilAM 1113ClllPTION 7-1 O
7 - CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES 7.1 PURPOSE
.O Tnis section establisnes controls to assure tnat safety-related items and services, whether purchased directly or througn contractors and suocontractors, conform to procurement documents.
O 7.2 GENERAL 7.2.1 Procedures / instructions snall be estaulisned and implemented for the g
' control of purchased materials, equipment, and services. Tnese procedures / instructions snall clearly descrioe tne actions to be ac-complished and identify those positions or groups responsible for performing those actions.
O 7.2.2 Material, equipment, services and spare / replacement parts (other tnan commercial grade /off-tne-shelf items as defined in 10CFR21) for safety-related structures, systems and components:
O a.
Shall oe procured from vendors wnose quality assurance qualifi-cations nave been affirmed, either prior to or after award of I
tne contract, by the corporate Quality Assurance, and
-O b.
Shall De subject to the quality assurance program controls and to tecnnical requirements at least equal to the original techni-cal requirements or to revised controls that have oeen properly reviewed and approved.
7.2.3 Evaluation of vendors, including review and concurrence of vendors' QA programs, shall be performed by QA personnel competent in deter-mining the ability of vendors to provide acceptable quality prod-ucts. Source selection will be based on one or more of the following:
l l
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CASHINGTON FUBIJC FOWER SUFFLY SYSTEM
"'V' OPERATIONAL 6
PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 7-2 O
7.2.3 (cont'd) a.
The ability of the vendor to comply with those elements of
.O 10CFR50 Appendix B applicable to the type of material, equip-ment, or services being procured.
b.
A review of previous record and performance of vendors who have g
provided similar articles of the type being procured.
c.
A survey of the vendor facilities and QA pro 5 ram to determine his capability to supply a product which meets design, manufacturing, O
and quality requirements.
7.2.4
- Source verification (vendor surveillance, inspection and audit) shall be comensurate with the relative importance, complexity, and quantity g
of the items or service procured and the vendor's quality performance.
In-process and final surveillance requirements of vendor products shall be determined in advance and performed to as-sure conformance with procurement document requirements. Source verification is not required where the quality of an item can be O
verified by review of test reports, inspection upon receipt, or other l
means.
7.2.5 Receiving inspection of vendor-furnished items shall be performed to
- O assure that:
a.
The item is properly identified and corresponds to the identi-l fication on the procurement document and receiving documentation.
O l
!O
CASHINGTON PUBLIC POWER SUFFLY SYSTEM OPERATIONAL 6
PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 7-3 e
a 7.2.5 (Cont'd) b.
The item and the acceptance records satisfy the inspection in-3 struction prior to relying upon the item to perform its safety
- function, c.
Specified inspection, test, and other records are complete and
-)
available at the site prior to relying upon the item to perform its safety function.
d.
Inspection status of accepted items is identified prior to 3
their being released for storage, use or further work.
7.2.6 Documentary evidence that vendor-furnished items conform to procurement requirements shall be retained at the site for the life
,3 of the items.
7.2.7 The validity of vendor-furnished Certificates Of Conformance (or equivalent certifications) shall be evaluated by either audits /
surveillances of the vendor or independent inspection or test of the
,3 items. Such evaluations shall be performed at intervals commen-surate with the vendor's past quality performance.
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O WAS:llNGTON PUBLIC P017ER SUPPLY SYSTE:.:
5 OPEllATIONAI, QUALITY ASSUltANCis PitOGitA31 DisSCitIPTION
~
PAGE
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8-1 G
8 - IDENTIFICATION AND CONTRCL OF F TERIALS, PARTS, AND COMPONENTS 3
8.1 PURPOSE This section sets forth requirements for identification and control of safety-related materials, parts, and components.
J 8.2 GENERAL Procedures and/or instructions shall be established and implemented J
for the identification and control of items so as to prevent use of incorrect or defective items. These procedures and/or instructions shall assure that:
'O a.
Identification requirements for items are established during initial planning (i.e. during generation of specifications and design drawings).
D b.
Identification of the item is maintained by heat number, part number, serial number or other appropriate means.
c.
Identification of the item is maintained either on the item or D
on records traceable to the item.
d.
The traceability of the item to appropriate documentation, such as specific inspection / test records, code data reports, and 3
physical / chemical mill test reports, is maintained when such traceability is required by codes, standards or specifications.
e.
Identification of the item is maintained throughout fabrication, b
shipping, installation and use of the item.
WP 115 14 3
O WAS:iINGTON PUBLIC POVIEP. SUPPLY SYSTEI.:
^*V*
Ol'EllATION Al.
l PAGE QUAI.lTY ASSUllANCE PitOGilA.\\1 DESCitilrl' ION 8-2
.O 8.2 (Cont'd.)
f.
Tne location and metnod (sucn as application of metal tags or O
markings) of identification do not affect the safety-related function of the item.
g.
Correct identification of the item is verified prior to release O
of the item for fabrication, snipping, assemoling and installation.
10
.O
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.O iO WbllS pt3 10
'O
- WAS:llNGTON PUBLIC POYlER SUFFLY SYSTEl.:
^E**
OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 9-1 O
9 - CONTROL OF SPECIAL PROCESSES lC 9.1 PURPOSE This section sets forth requirements for special process activities (3
which affect safety-related structures, systems, and components.
9.2 GENERAL
' C) 9.2.1 Special processes are those that require interim in-process controls in addition to final inspection and/or examination to assure achieve-ment of required quality.
- C) 9.2.2 Procedures / instructions shall be established and implemented to as-sure adequate performance and control of special processes such as welding, heat treating, non-destructive testing, and chemical clean-ing. These procedures / instructions shall contain provisions for:
!O a.
Qualifying the personnel, equipment, and procedures to be uti-lized for performing special processes.
b.
Documenting the evidence (inspection or process results) of ac--
j) ceptable performance of special processes.
9.2.3 Special processes shall be performed by qualified personnel utilizing qg, qualified procedures and qualified equipment in accordance with an-plicable codes, standards, and specifications. For special processes not covered by existing codes or standards, the necessary qualifica-tions of personnel, procedures, and equipment shall be defined in appropriate documents.
)
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O WASWNGTON PUBLIC POWER SUPPLY SYSTEM i
6 OPERATIONAL PAGE QUALI'T ASSURANCE PROGRAM DESCRIPTION 9-2 O
9.2.4 Procedures, equipment, and personnel to be utilized for the per-formance of spect.il processes shall be qualified / certified by au-thorized personnel from acolicable organizations (e.g. Quality Assurance, Generation Services, Generation Engineering, and Plant O
organizations, etc).
9.2.5 Qualification records of procedures, equipment, and personnel as-sociated with special processes shall be established, filed, and g
maintained.
l
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WASHINGTON PUBLIC P0t7En SUPPLY SYSTEI."
5 OPEllATIONAL QUAIlTY ASSUllANCE PitOGilA31 DESCittITION Y-1 g
10 - INSPECTION O
10.1 PURPOSE This section sets forth requirements for inspection of activities that affect safety-related functions of plant items.
O 10.2 GENERAL 10.2.1 Inspections which provide assurance that safety-related plant items
.O and activities conform to applicable specifications, drawings, codes, standards, and regulations, shall be performed and documented in ac-cordance with written and approved procedures, instructions or check lists.
O 10.2.2 Inspection procedures, instructions or check lists will, as appropri-ate, provide for:
O a.
Date inspection performed b.
Description of inspection method O
c.
Identification of characteristics and activities to be inspected.
d.
Acceptance or rejection criteria o
e.
Identification of required procedures, drawings and specifica-tions.
f.
Specifying necessary measuring and test equipment including ac-g curacy requirements g.
Identity of inspector and/or data recorder, wmsn
q WASHINGTON PUBLIC POWER SUPPLY SYSTEM OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 10-2 0
10.2.3 Inspections shall be performed by individuals other than those who performed or directly supervised the activity being inspected.
Inspections, in general, o
will be performed by or under the supervision of the Supply System QA organization. However, personnel from the performing groups (Operations, Maintenance, Technical, Test & Startup, etc.) may be utilized for performing O
certain inspections associated with normal plant opera-tion. When such is the case, the related work proce-dures shall require (a) demonstration of correct perfor-mance of the work through:a funct;onal test where the O
w rk involves breaching a pressure retaining boundary, and (b) review and concurrence by the Supply System QA organization of qualification criteria of inspection personnel prior to initiation of inspection activity.
O 10.2.4 Individuals performing inspections shall be qualified and the status of their qualifications shall be main-tained current.
10.2.5 Where mandatory inspection holdpoints are identified in pertinent documents, work shall not proceed beyond those holdpoints without the consent of the responsible l
inspection personnel or group.
O 10.2.6 Inspection results shall be documented, evaluated, and their status recorded.
l O
O W Wtl$ R3 O
I
O WASHINGTON PUBLIC FOWER SUPPLY SYSTEM OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIITION 11 - 1
. C) 11 - TEST CONTROL
-O 11.1 PURPOSE This section sets forth requirements for testing to assure that JC) safety-related plant items will perform satisfactorily in service.
11.2 GENERAL
()
11.2.1 Tests required to demonstrate that plant items will perform satisf actorily in service shall be identified, documented, and performed in accordance with written and approved procedures / instructions.
O 11.2.2 Tests will include, as appropriate, the following:
a.
Prototype qualification tests.
"O b.
Proof tests prior to installation.
c.
Preoperational and startup tests.
- C) d.
Surveillance tests during plant operation.
e.
Tests associated with plant modification and maintenance activities.
33, 11.2.3 Test procedures / instructions shall incorporate or reference, as appropriate, the following:
O a.
Instructions for performing the test.
wensn
)
O WASHINGTON PUBLIC FOWER SUFFLY SYSTEM 5
OPERATIONAL ha QUALITY ASSURANCE PROGRAM DESCRIPTION 11 - 2 O
11.2.3 (Cont'd.)
O b.
Test prerequisites such as calibrated instruments, adequate test equipment, completeness of the item to be tested, and suitable environmental conditions.
~O c.
Mandatory inspection hold points.
d.
Acceptance / rejection criteria.
.O e.
The requirements and acceptance limits contained in the applicable design documents, f.
Methods of documenting or recording test data and results.
.O g.
Provisions for assuring that test prerequisites have been met.
11.2.4 Test results shall be documented, evaluated, and their status O
recorded by a responsible individual or group.
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'[-1 QUALITY ASSI!RANCE PROGRAM DESCRIPTION 1
^O 12 - CONTROL OF MEASURING AND TEST EQUIPMENT O
12.1 PURPOSE This section sets forth the requirements to establish those meas-ures which will assure that tools, gages, instruments, and other O
measuring and testing devices used in activities affecting quality are controlled, calibrated, and adjusted at specified periods in order to maintain accuracy within necessary limits.
- O 12.2 GENERAL 12.2.1 Measuring and test equipment (M&TE) shall be calibrated and ad-justed using approved procedures / instructions.
'o 12.2.2 A calibration program for the control and use of M&TE shall be es-tablished, and implemented. This program, as a minimum, shall pro-vide for:
O a.
Unique identification of the item and its traceability to the calibration test data.
l lO b.
Labeling or tagging (or otherwise controlling) to indicate the due date of the next calibration.
l c.
Calibration technique and frequency.
lO l
d.
Generation and maintenance of records which indicate the com-plete listing of all items under the calibration system toget-her with their current calibration status.
e.
Controlled environment conditions for sensitive and close tol-l-
erance M&TE.
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QUALITY ASSUllANCE PitOGItA.\\1 DESCitIITION 12 - 2 0
12.2.3 M&TE shall be calibrated against certified calibrating standards having known valid relationships to nationally recognized stand-O ards.
If no national standards exist, the basis for calibration will be documented.
12.2.4 Calibrating standards that are used for calibrating M&TE shall have O
tolerance not greater than one fourth (1/4) the tolerance of M&TE.
Tolerances greater than 1/4 will be acceptable when limited by the state-of-the art. Calibrating standards shall be calibrated against higher level standards.
.O 12.2.5 M&TE shall be calibrated and maintained at specified periods based l
on the required accuracy, purpose, stability characteristics, and other conditions affecting the measurement.
- O 12.2.6 When an item of M&TE is found to be out of calibration, an evalua-tion shall be made and documented to determine the validity of pre-vious inspection / test results and the disposition to be made of lO items previously inspected / tested.
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13 - HANDLING, STORAGE, AND SHIPPING
'O 13.1 PURPOSE This section establishes controls for cleaning, handling, storage, packaging, shipping and preservation of safety-related items.
O 13.2 GENERAL 13.2.1 Cleaning, handling, storage, packaging, shipping and preservation of O
items shall be accomplishr.d in accordance with written procedures /
instructions, to prevent damage, loss or deterioration by environ-mental conditions. These procedures / instructions shall be prepared in accordance with the design and procurement requirements of the O
items.
13.2.2 When necessary for particular iteins, special coverings, special equipment and special protective environments, such as inert gas
- O atmosphere, specific moisture content levels, and temperature levels, shall be specified, provided, and their existence verified.
13.2.3 Responsible personnel shall assure that items are identified, inven-O toried, adequately packaged to ensure integrity during transit, properly addressed and released and that these activities are docu-mented.
13.2.4 Measures shall be established and implemented to control the storage O
of chemicals, reagents (including control of shelf-life), lubricants and other consumable materials for safety-related application.
O
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5 OPERATIONAL QUALITY ASSURANCE PROGRAM DESCRIITION 14 - 1
- O 14 - INSPECTION, TEST AND OPERATING STATUS
.O 14.1 PURPOSE This section sets forth the requirements for identifying the inspection, test, and operating status of safety-related items.
O 14.2 GENERAL Procedures / instructions shall be established and implemented for
_g identifying the inspection, test, and operating status of plant items. These procedures / instructions shall include provisions for assuring that:
a.
The application and removal of status indicators (stamps, tags, O
labels, routing cards, physical barriers, etc.) is controlled.
9 b.
Items which require inspections and tests are identified and controlled to preclude bypassing of such inspections and tests.
c.
The status of inspections and tests performed upon individual plant items is indicated by the use of status indicators or other suitable means.
iO d.
The operating status of nonconforming, inoperative, or malfunctioning installed plant items is documented and identified to prevent inadvertent operation.
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15 - NONCONFORMING MATERIALS, PARTS, OR COMPONENTS O
15.1 PURPOSE This section sets forth requirements for the control of safety-related items, services, or activities which do not conform to speci-O fied requirements.
15.2 GENERAL O
15.2.1 Measures shall be established to control nonconforming items to pre-vent their inadvertent use or installation. These measures shall include, as appro7riate, procedures / instructions for identification, review, documentation, segregation, disposition, approval, and noti-O fication to affected organizations of nonconforming items.
15.2.2 Measures shall be established and documented defining the responci-bility and authority for determining and approving the disposition of O
nonconforming items.
15.2.3 Nonconformances shall be documented. This documentation shall:
3 a.
Clearly identify the nonconforming item; and b.
Describe the nonconformance, the disposition of nonconformance, and inspection / test requirements (where applicable).
O 15.2.4 Nonconforming items shall be reviewed and accepted for use-as-is, rejected, repaired, or reworked in accordance with documented procedures / instructions. The Supply System Quality. Assurance shall 3
review nonconformances to assure that dispositions have been eval-uated and approved.
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15.2.5 Acceptability of repaired, reworked and replaced item shall'be veri-fied and documented by inspecting and/or testing the item in accor-dance with original inspection and/or test requirements or approved alternatives.
g 15.2.6 Where feasible, nonconforming items shall be segregated from other acceptable items and/or uniquely identified as nonconforming until properly dispositioned for use.
O_
15.2.7 Reports of nonconformances shall be periodically analyzed by the Supply System QA organization to identify quality trends.
Significant results, shall be referred to appropriate management for O
review and assessment.
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QUALITY ASSURANCE PROGilA.\\1 DESCillPTION 16 - 1 0
16 - CORRECTIVE ACTION 16.1 PURPOSE
- O This section sets forth the requirements for identification, correction, documentation, and reporting of conditions adverse to I
quality such as failures, malfunctions, deficiencies, deviations,
.O defective material and equipment, and nonconformances.
l 16.2 GENERAL f
O 16.2.1 Conditions adverse to quality shall be evaluated and the need for corrective actions determined in accordance with established j
procedures. These procedures shall provide for prompt identification and correction of conditions.
.O 16.2.2 For conditions significantly adverse to quality, the corrective I
action procedures shall provide for the following:
a.
Determination of the cause of the condition.
'O b.
Corrective action so as to preclude repetition of the condition.
O c.
Verification of the implementation of the corrective action.
16.2.3 Conditions significantly adverse to quality, its cause, and the corrective action taken shall be documented and reported to O
appropriate levels of management for review and assessment.
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17 - QUALITY ASSURANCE RECORDS 17.1 PGAPOSE O
Tnis section sets forth requirements for generation, transmittal, retention, and maintenance of quality assurance records for Supply System's nuclear power plants.
O 17.2 GENERAL 17.2.1 Sufficient records snall be maintained to furnisn evidence of tne g
quality of safety-related plant items and activities. As a minimum tnese records snall include the following:
a.
Operating logs O
b.
Results of design reviews, inspections, tests, audits, and material analysis c.
Monitoring of work performance g
d.
Qualifications of personnel, procedures, and equipment.
e.
Drawings, specifications, procedures, and procurement
,J documents, f.
Nonconformance and corrective action reports 9'
g.
Records as required by plant technical specifications.
17.2.2 Inspection and test records snall identify the following wnere applicable:
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.o 17.2.2 (Cont'd) a.
Inspector and/or data recorder
- O Tnetypeofobsirrvation b.
c.
The date and results of inspection or test.
.g d.
Acceptability of results.
e.
The action taken to resolve any deficiencies noted.
- O 17.2.3 Quality assurance records shall be generated (prepared, reviewed, and approved), accumulated, trans.aitted for incorporation into the records retention system, retained, maintained, and controlled in O
accordance witn documented procedures and/or instructions.
17.2.4 Tne quality assurance recoros shall be organized and filed so that each document is identifiaole and retrievaole.
10 17.2.5 The quality assurance records shall be filed and maintained in facilities tnat provide protection from possible deterioration or damage and shall be controlled to prevent loss.
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QUALITY ASSUltANCE PROGRA31 DESCitIITION 18-1 O
18 - AUDITS O
18.1 PURPOSE This section sets forth requirements for auditing to verify imple-mentation and.ietermine the effectiveness of the QA Program.
O 18.2 GENERAL 18.2.1 A comprehensive system of planned and documented audits by the
- O corporate Quality Assurance, shall be carried out to verify compli-ance with applicable aspects of the QA Program. These audits shall consist of both internal audits of Supply System's nuclear power plants and other Supply System organizations and external audits of
.O Supply System vendors performing activities covered by the QA Program.
18.2.2 Audits shall include the objective evaluation of work areas, acti-vities, processes, and items; review of documents and records; and O
quality-related practices, procedures and instructions to determine the effectiveness of implementation of the QA Program.
l 18.2.3 Audits shall be scheduled based upon the status and safety impor-tance of the activities.
lO 18.2.4 Audits shall be performed in accordance with written procedures or check lists and conducted by appropriately trained personnel not
'O having direct responsibilities in the areas being audited.
l 18.2.5 Audit results shall be documented by auditing personnel and re-viewed by management having responsibility in the area audited.
- O 18.2.6 Follow-up action on deficiencies shall be accomplished.
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APPENDIX I QUALIFICATION REQUIREMENTS
'O l
l The minimum qualification requirements for key Quality Assurance personnel that will be met at the time of initial core loading or appointment to the O
active positions are as follows:
I.1 Ouality Assurance Director a.
Education: Bachelor Degree or equivalent
- in Engineering or related O
- science, b.
Experience: Ten (10) years experience in the field of quality assurance, or equivalent number of years of nuclear inductry experience in a management position or a combination of the two. At O
least two (2) years of this ten (10) years experience shall include detailed involvement in the administration of and adherence to the quality assurance program in a significant management rold directly inv Iving nuclear p wer plants.
O I
I.2 Operational Quality Assurance Manager l
a.
Education: Bachelor Degree or equivalent
- in Engineering or a g'
related science.
b.
Experience: Six (6) years experience in the field of quality assurance, or an equivalent number of years of nuclear plant experience in a supervisory position, preferably at an operating O
nuclear plant, or a combination of the two. At least two (2) years of this six (6) years experience shall be nuclear power plant experience in the implementation of the quality assurance program.
I.3 Plant Quality Assurance Manager i
I a.
Education: Bachelor Degree or equivalent
- in Engineering or w> sis as l
iO WASHINGTON FUBLIC FOWER SUFFLY SYSTEM 6
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QUALITY ASSURANCE PROGRAM DESCRIPTION
,0 1
I.3 Plant Quality Assurance fianaaer (cont) related science, b.
Experience: Four (4) years experience in the field of quality O
assurance, or an equivalent number of years of nuclear plant experience in a supervisory position, preferrably at an operating nuclear plant, or a combination of the two. At least one (1) year of this four (4) years experience shall be in the implementa-O tion of the quality assurance program.
c.
Training: Shall have acquired familiarization and working knowledge of plant systems, facilities, plans, and programs necessary for the performance of assigned functions in a safe and competent manner.
O
- Equivalency will be determined based upon an evaluation of the following fa'ctors:
O 1.
High school diploma or GED.
2.
Sixty (60) semester hours of ielated technical education taught at the collete level (900 classroom or instructor conducted hours).
3.
Qualified as an i!RC senior operator at the assigned plant.
O 4.
Four (4) years of additional experience in his area of responsibility 5.
Four (4) years of supervisory or management experience.
6.
Demonstrated ability to communicate clearly (verbally and in writing).
7.
Certification of academic ability and knowledge by corporate management.
O 8.
Successful completion of the Engineer-In-Training examination.
9.
Professional Engineer License.
- 10. Associated degree in Engineering or a related science.
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()U AI,lTY ASSUltANCE PitOGilAM DisSCitIPTION II-l D
APPENDIX II
" POSITION STATEMENTS" D
INTRODUCTION I
This Appendix identifies those quality-related Regulatory Guides which the Supply System inteads to follow during operations phase of its nuclear power plants. However, where the Regulatory Positions stated in these Regulatory Guides could lead to misunderstanding, or where alternate methods and/or solu-tions are implemented for accomplishment of Regulatory Positions, they are also described in this Appendix.
This Appendix is organized in three sections.Section II.1 describes Supply System Position Statements applicable to nuclear power plant WNP-2,Section II.2 is applicable to WNP-1/4, and Section 11.3 is applicable to WNP-3/5. The Supply System commitments to comply with applicable Regulatory Guides not addressed 1 s these sections of this Appendix are or will be documented in the applicable Final Safety Analysis Report.
4D The Supply System Positions, described in this Appendix, will be incorporated by Supply System organizations in their procedures and/or instructions for applicable activities.
8D This Appendix will be revised, as and when necessary, by the Supply System Quality Assurance Director, in accordance with the provisions of Section 2 of the QA Program.
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PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION II. 1-1
- O APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2"
'O I1.1.1 REGULATORY GUIDE 1.8, REV 1-R (May,1977)
" Personnel Selection and Training"
- O Supply System Position The Supply System will implement the Regulatory Position of Regula-O tory Guide 1.8, Rev. 1-R (May, 1977) and the requirements in the endorsed standard ANSI N18.1-1971.
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eaas i
QUALITY ASSURANCE PROGRAM DESCRIPTION II.1-2 O
APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" O
11.1.2 REGULATORY GUIDE 1.26, REV 3 (February, 1976)
" Quality Group l
Classifications and Standards for Water, Steam, and Radioactive-Waste-Containing Components of Nuclear Power Plants" g
Supply System Position The Supply System will implement the Regulatory Position of Regula-O tory Guide 1.26, Rev. 3 (February 1976).
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QUALITY ASSURANCE PROGRAM DESCRIPTION II.1-3 O
APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" O
II.1.3 REGULATORY GUIDE 1.29, REV 3 (September 1978)
" Seismic Design Classification" O
Supply System Position The Supply System will implement the Regulatory Position of Regula-tory Guide 1.29, Rev. 3 (September 1978).
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OPERATIONAL PAGE QUALITY ASSURANCE PROGRA31 DESCRIPTION 77,y,4
- O
? APPENDIX II
+
i II.1 "p0SITION STATEMENTS FOR WNP-2" O
11.1.4 REGULATORY GUIDE 1.30, fSafety Guide 30, August 11, 1972)
" Quality Assurance Requirements for the Installation, Inspection and Testing of Instrumentation and Electric Equipment"
'O Supply System Position The Supply System will implement the Regulatory Position of Regula-O tory Guide 1.30, (Safety Guide 30, August 11,1972) and the require-ments in the endorsed standard ANSI N45.2.4-1972 (also designated as IEEE Std 336-1971), subject to the following:
- O 1.
Regulatory Position C.1 of Regulatory Guide 1.30 (Safety Guide 30, August 11,1972) states that ANSI N45.2.4-1972 should be used in conjunction with ANSI N45.2-1971, "0uality Assurance.
.O
' Program Requirements for Nuclear Power Plants".
It is the Sup-ply System position that ANSI N45.2-1971 is not applicable for operational phase activities of nuclear power plants.
Instead the Supply System will comply with its Position Statement on Regulatory Gui M 1.33.
O 2.
Regulatory Position C.3 of Regulatory Guide 1.30 (Safety Guide 30, August 11,1972) states that the requirements promulgated by ANSI N45.2.4-1972 are also to be considered applicable for O
the installation, inspection, and testing of instrumentation and electric equipment during the operational phase of nuclear power plants.
It is the Supply System position that the intent of ANSI N45.2.4-1972 will be maintained for all plant O
modifications.
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QU Al.lTY ASSUllASCE Pito(;1tAsl DESGillPTION II.1-5 0
APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" II.1.4 REGULATORY GUIDE 1.30 (Cont'd) 3.
Section 3(3) of ANSI N45.2.4-1972: Checking of records is normally accomplished during periodic surveillances and audits
- O of the storage facility. The checking of storage records for each individual item prior to installation is not planned.
4.
Section 5.1.2 of ANSI N45.2.4-1972:
Inspections to verify g-housekeeping will be done as stated in the Supply System Position Statement on Regulatory Guide 1.39.
1 5.
Section 5.2.1 of ANSI N45.2.4-1972: Tests will include those listed as appropriate. The manufacturers' reconynendations
'O shall be considered. The test procedure will specify the actual test to be performed.
6.
Section 9 of ANSI N45.2.4-1972: The Supply System position,
~O stated herein, does not address the codes and standards listed and/or referenced in this paragraph. Such position will be developed in the future, if the need arises.
O
-7.
Appendix A. " Supplementary Provisions for Multi-Unit Stations" to ANSI N45.2.4-1972=is not considered applicable to WNP-2.
I 8.
Appendix B " Additional Codes, Standards and Guides" to ANSI O
N45.2.4-1972: Refer to Supply System Position on Section 9 of ANSI N45.2.4-1972.
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APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2"
- O II.1.5 REGULATORY GUIDE 1.33, REV 2 (February 1978)
" Quality Assurance Program Requirements (Operation)"
Supply System Position
- O The Supply System will implement the Regulatory Position of Regula-tory Guide 1.33, Rev. 2 (February 1978) and the requirements in the endorsed standard ANSI N18.7-1976/ANS-3.2, subject to the following:
- g 1.
Regulatory Position C.2 of Regulator.y Guide 1.33, Rev. 2 (February 1978) implies that the provisions contained in the latest revisions of the Regulatory Guides, listed therein, will O
be followed. The Supply System will follow its Position State-ments on applicable Regulatory Guides as described throughout Section II.1 of this Appendix.
O 2.
Section 5.2.13.4 of ANSI N18.7-1976/ANS-3.2: The third para-graph of this section is revised to read, "Special handling tools and equipment shall be inspected and/or tested, as neces-sary, in accordance with written procedures and at specified O
times to verify that the tools and equipr:ent are adequately maintained."
3.
Section 5.2.17 of ANSI N18.7-1976/ANS-3.2 states that inspec-O tion of operating activities may be conducted by second-line i
supervisory personnel or by other qualified personnel not as-signed first-line supervisory responsibility for conduct of the work. The Supply System position is to allow the olant opera-O tions' shift supervisors (first-line supervisors) to perform inspections of surveillance tests, provided that an after-the-I fact review of surveillance documentation is performed by the Wells R3
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5 PAGE QUAI,lTY ASSullAN(:E PltOGilAM DES (:ltlPTION II,1 7 O
APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2"
.O II.1.5 REGULATORY GUIDE 1.33 (Cont'd.)
Operations Supervisor (a second-line supervisor) or by other personnel not assigned first-line responsibility for the conduct O
of the work.
4.
Sections 5.2.19.1 and 5.2.19.2 of ANSI N18.7-1976/ANS-3.2 describe rules of practics for preoperational and startup test O
program. The Supply System intends to comply with the provi-sions of these sections.
In cases, where conflicts exists between these sections and Regulatory Guide 1.68, the Supply System will comply with the implementation of Regulatory Guide 0
1.68 as described in Chapter 14 " Initial Test Program" of the Final Safety Analysis Report.
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APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2"
.O 11.1.6 REGULATORY GUIDE 1.37, (March 16, 1973)
" Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants" O
Supply System Position The Supply System will implement the Regulatory Position of Regula-O tory Guide 1.37, (March 16, 1973) and the requirements in the en-dorsed standard ANSI N45.2.1-1973 subject to the following:
1.
Regulatory Position C.4 of Regulatory Guide 1.37 (March 16, 1973)
O states, in part, " Chemical compounds that could contribute to intergranular cracking or stress-corrosion cracking should not be used with austenitic stainless steel and nickel-base alloys".
In clarification, the Supply System will abide by the chemical O
composition limits established by its Nuclear Steam Supply System vendor with regard to control of marking materials, paints, chalk, mineral and organic acids, chemical compounds, materials, solvents and chemicals used for cleaning, and plastic films.
O 2.
Regulatory Position C.5 of Regulatory Guide 1.37 (March 16,1973')
states, in part, "Specifically, tools which contain materials that could contribute to intergranular cracking or which, because
'O of previous usage, may have become contaminated with O
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O APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" 11.1.6 REGULATORY GUIDE 1.37 (Cont'd.)
such materials should not be used on surfaces of corrosion-resistant alloys".
In clarification, the Supply System will O
abide by the chemical composition limits established by its Nu-clear Steam Supply System ven6or, with regard to control of grinding tools and materials, wire brushing tools and materials, chipping tools and materials, and sanding tools & materials.
0 3.
Section 2.1 of ANSI N45.2.1-1973 states, in part, " Planning for cleaning activities shall include a review of the system and component design specifications and drawings.
In clarification
'O of this requirement, a review of system and component design specifications and drawings will be required for only those mod-ifications which change the design of a fluid system.
O 4.
Section 2.3 of ANSI N45.2.1-1973, last sentence, is revised to read, " Test reports shall include an evaluation of the accept-ability of inspection and test results and provide for identify-ing the individual who performed the evaluation."
O 5.
Section 3.1.2.1 of ANSI N45.2.1-1973 states, in part, " Scattered areas of rust are permissible provided the aggregate area of rust does not exceed two square inches in any one square foot O
area." The Supply System considers this two square inch limit as a guide only. Adequate discretion by experienced personnel will be used in all cases.
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APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" O
I1.1.6 REGULATORY GUIDE 1.37 (Cont'd.)
6.
Section 3.1.2.5 of ANSI N45.2.1-1973 states, in prt, "There shall be no evidence of organic contamination in the effluent
,O water or on the filter." The Supply System intends to comply with this requirement. The presence of organic contamination will be determined visually or by feel.
!O 7.
Section 4 of ANSI N45.2.1-1973, second sentence, is revised to read, " Inspections, examinations, or tests for cleanliness shall be performed if it is suspected that cleanliness has been af-fected by transportation to, or storage at the installation O
site."
8.
Section 7.4 of ANSI N45.2.1-1973 requires checking of cleaning solutions for effectiveness of inhibitors (if used).
In clari-O fication of this requirement, the effectiveness of inhibitors l
(if used) will be determined by documentation in technical lit-erature or manufacturer's or vendor's recommendations.
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l O
APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" O
11.1.7 REGULATORY GUIDE 1.38, Rev. 2 (May, 1977)
" Quality Assurance Re-quirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Water-Cooled Nuclear Power Plants" O
Suoply System Position The Supply System will implement the Regulatory Position of O
Regulatory Guide 1.38, Rev. 2 (May, 1977) and the requirements in the endorsed standard ANSI N45.2.2-1972 subject to the following:
1.
Section 3.2.1 (1) of ANSI N45.2.2-1972: Temperature and humi-O dity control considerations for packaging of Level A items are not considered applicable to nuclear fuel assemblies unless recommended otherwise by the nuclear fuel manufacturer. The Supply System will abide by the manufacturer's recommendation.
O 2.
Section 3.5.2 of ANSI N45.2.2-1972, last sentence, is revised to read as, " Tapes used for identification rather than sealing which are not near a welding operation may remain indefinitely O
(see also Appendix section 3.5.2 for additional requirements)."
3.
Section 3.7.1 (1) of ANSI N45.2.2-1972: The Supply System may use cleated, sheathed boxes for loads up to 1,000 pounds rather O
than 500 pounds limit imposed here. This type of box has been tested by the WNP-2 Nuclear Steam Supply System vendor and found safe for loads up to 1,000 pounds. Other national stand-ards allow the 1,000 pounds designation (see Federal Specifica-O tion PPP-B-601).
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APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" O
II.1.7 REGULATORY GUIDE 1.38, Rev. 2 (May. 1977) (Cont'd.)
4.
Section 6.1.2 (1) of ANSI N45.2.2-1972: Temperature and humid-g ity controls required for the' storage of Level A items are not considered applicable for nuclear fuel assemblies unless recom-mended otherwise by the nuclear fuel manufacturer. The Supply System will abide by the manufacturer's recommendation.
O 5.
Section 6.4.2 (6) of ANSI N45.2.2-1972: Provisions of this section, concerning periodic rotation and the degree of rota-tion of shaf ts of rotating equipment, while in storage, will be Complied with unless recommended otherwise by the manufac-turers. The Supply System will abide by the manufacturers' reconinendation.
6.
Appendix Sections A3.4.1 (4) and A3.4.1 (5) of ANSI O
N45.2.2-1972: During printing of the standard, a transposition occurred between the last sentences of these sections. The Supply System will comply with the correct wording which reads as follows:
O A3.4.1 (4), last sentence: However, preservatives for inacces-sible inside surfaces of pumps, valves and pipe for systems containing reactor coolant water shall be the water flushable O
typ,,
A3.4.1 (5):
The name of the preservative used shall be indi-cated to facilitate touch up.
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.O CASHINGTON PUBIJC FOWER SUFFLY SYSTEM 6
OPERATIONAL QUALITY ASSURANCE PROGRAM DESCRIPTION II.1-13 O
APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" O
11.1.8 REGULATORY GUIDE 1.39, Rev. 2 (September, 1977)
" Housekeeping Re-quirements for Water-Cooled Nuclear Power Plants" O
Supply System Position The Supply System will implement the Regulatory Position of Regula-tory Guide 1.39, Rev 2 (September, 1977) and the requirements in the O
endorsed standard ANSI N45.2.3-1973 subject to the following:
Section 2.1 of ANSI N45.2.3-1973 requires the establishment of cleanness requirements for housekeeping activities on the basis of O
zone designations. The Supply System considers these zone designa-tion and the requirements associated with each zone as impractical for implementation during the operations phase. Procedures or in-structions for housekeeping activities, which include the applicable
.O requirements outlined in Section 2.1 of ANSI N45.2.3-1973 and which take into account the radiation control considerations, security considerations, and cleanness requirements, will be developed on case by case basis for maintenance and modification work to be
'O performed.
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maa QUALITY ASSURANCE PROGRA31 DESCRIPTION II.1-14 gi APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" O
11.1.9 REGULATORY GUIDE 1.58, Rev. 1 (September, 1980)
" Qualification of Nuclear Power Plant Inspection, Examination and Testing Personnel" Supply System Position The Supply System will implement the Regulatory Position of Regu-latory Guide 1.50, Rev 1 (September, 1980) and the requirements in O
the endorsed standard ANSI N45.2.6-1978 subject to the following:
1.
Regulatory Position C.5 of Regulatory Gu'ide 1.58, Rev. 1 (September 1980) implies that individuals who review and ap-O prove inspection, examination, and testing procedures and those l
who evaluate the adequacy of such procedures to accomplish the inspection, examination, and test objectives, should meet the Level III capability requirements delineated in Table 1 of O
ANSI /ASME N45.2.6-1978. Not all Supply System personnel per-forming the types of cited functions will meet the Level III capability requirements of Table 1 of ANSI /ASME N45.2.6-1978.
l However, personnel performing the cited functions will be de-lO termined by Supply System management (through evaluation of their education, training, and experience), to be fully qualified and competent. The basis for the determination will be documented.
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2.
Section 1.2 of ANSI /ASME N45.2.6-1978, fourth paragraph, states that the requirements of this Standard apply to personnel of the owners and their suppliers.
In clarification, the extent O
of application of the requirements of ANSI /ASME N45.2.6-1978 to l
Supply System suppliers will depend upon the nature and extent Wells R3 l
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APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" D
11.1.9 REGULATORY GUIDE 1.58 (cont'd) of materials or services furnished, and as further described in 3
Supply System Positions on Section 2.4 and 3 of ANSI /ASME N45.2.6-1978.
3.
Section 2.1.2 of ANSI /ASME N45.2.6-1978 implies that personnel l
0 performing non-NDE type of inspections, examinations, and test-ing will be formally certified. The Supply System does not plan this formal certification. Instead, the Supply System will select such personnel to predetermined qualification re-O quirements for the specific task based on their education, ex-perience, and training. Formal training records, when used as the basis for qualification, will be maintained on file.
4.
Section 2.4 of ANSI /ASME N45.2.6-1978 requires issuance of for-l mal certification to individuals and specifies the details of the information to be included in the certificate. The Supply System does not plan to issue formal certificates to indivi-8 duals performing inspections, examinations, and testing that fall within the scope of ANSI /ASME N45.2.6-1978 and Regulatory Guide 1.8.
However, information similar to that described in this section of the Standard will be available in documented G
form attesting that the individual is capable of performing the assigned task (s). The Supply System will use a similar ap-proach in evaluating supplier compliance with this section of l
the Standard.
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APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" O
11.1.9 REGULATORY GUIDE 1.58 (cont'd) 5.
Section 3 of ANSI /ASME N45.2.6-1978 divides the capability re-O quirements of inspection, examination, and testing personnel into three levels, namely Level I, level II, and Level III.
The Supply System will not assign these levels to its personnel performing inspection, examination, and testing activities.
O However, the selection of personnel for particular tasks will be such as to match the capabilities to the types of tasks and maintain the intent of the three levels. The judgement to de-termine that a person's qualifications and capabilities meet O
the intent of a certain level of inspection, examination, and testing function is ma.de through the normal management process by using established adminstrative and personnel procedures.
Documentation for such justification will be maintained on O
file. A similar approach will be used to evaluate the qualifications of non-NDE personnel of Supply System suppliers.
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11.1.10 REGULATORY GUIDE 1.64, Rev. 2 (June, 1976)
" Quality Assurance Re-quirements for the Design of Nuclear Power Plants" O
Supoly System Position The Supply System will implement the Regulatory Position of Regula-tory Guide 1.64, Rev 2 (June 1976) and the requirements in the en-O dorsed standard ANSI N45.2.11-1974 subject to the following:
Regulatory Position C.2 of Regulatory Guide 1.64, Rev 2 (June 1976) states that individuals performing design verification should not O
have imediate supervisory responsibility for the individual per-forming the design.
It further states that while design verifica-tion by the imediate supervisor is encouraged, it should not be construed that such verification constitutes the required indepen-O dent design verification.
It is Supply System position that if the designer's immediate supervisor is the most technically qualified individual available in the organization to perform a design verification by design review, this review may be conducted by the O
supervisor, providing that; a.
the justification is individually documented and approved in advance by the supervisor's management and O
b.
Quality Assurance audits cover the frequency and effectiveness of use of supervisors as design verifiers to guard against abuse.
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APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2"
'O II.1.11 REGULATORY GUIDE 1.74, (February 1974)
" Quality Assurance Terms and Definitions" O
Supply System Position The Supply System will implement the Regulatory Position of Regula-l tory Guide 1.74, (February 1974) and the quality assurance terms and definitions in the endorsed standard ANSI N45.2.10-1973, subject to the following:
1.
Regulatory Position "C" of Regulatory Guide 1.74 (February O
1974) specifies certain documents recommended be included in the definition of " procurement documents", defined in ANSI N45.2.10 - 1973. The Supply System will use the following
~
definition:
O Procurement Documents - Purchase requisitions, purchase orders and contracts with attachments necessary to specify/ verify requirements.
O 2.
Section 2 of ANSI N45.2.10 - 1973: The definition of "specifi-cation" is revised to read as follows:
'O Specification - A statement of a set of requirements to be sat-isfied by a product, a material, a service or process indicat-ing, whenever appropriate, the procedure by means of which it may be determined whether the requirements given are satisfied.
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APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2"
'O II.1.12 REGULATORY GUIDE 1.88, REY. 2 (October 1976)
" Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records."
Supply System Position O
The Supply System will implement the Regulatory Position of Regula-tory Guide 1.88, Rev. 2 (October 1976) and the requirements in the endorsed standard ANSI N45.2.9-1974, subject to the following:
g 1.
Regulatory Position C.2 of Regulatory Guide 1.88, Rev. 2 (October 1976) endorses the 4-hour fire rating requirements for a single records storage facility as described in Section 5.6 of ANSI N45.2.9-1974. The Supply System modifies this 4-hour rating requirement of ANSI N45.2.9-1974 to 2-hour fire rating requirement. Accordingly, the Supply System will comply with a substitute'to the third, fourth, and fifth paragraphs of Section 5.6 of ANSI N45.2.9-1974 which reads, "Where a single record storage is maintained, the QA records shall be maintained in either:
a.
A 2-hour vault meeting NFPA (National Fire Protection As-O sociation) No. 232-1975 without additional provisions or b.
2-hour rated file containers meeting NFPA No. 232-1975 (Class B) without additional NFPA provisions or O
c.
2-hour rated fire resistant file room meeting NFPA No.
232-1975 with the following additional provisions:
O (1) Early warning fire detection and automatic fire sup-pression shall be provided, with electronic supervi-sion at a constantly attended central station.
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QUAL.lTY AF4UltANCE PitOGitAM DESCittlTION II.1-21 APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" O
11.1.12 REGULATORY GUIDE 1.88 (Cont'd)
(2)
Records shall be stored in fully enclosed metal cabi-nets. Records shall not be permitted on open steel shelving. No storage of records shall be permitted on the floor of the facility. Adequate access and aisle ways shall be maintained at all times throughout tre facility.
- O (3)
Work not directly associated with records storage or retrieval shall be prohibited within the records stor-age facility. Examples of such prohibited activities C'
include but are not limited to: records reproduction, film developing, and fabrication of microfiche cards, i
i (4)
Smoking and eating / drinking shall be prohibited
'O throughout the records storage facility.
l (5)
Ventilation, temperature, and humidity control equip-ment shall be protected inside with standard fire-door i
lO dampers where they penetrate fire barriers bounding the facility."
l 2.
Section 3.2.2 of ANSI N45.2.9-1974 is revised to read, "Index -
!O The qua;ity assurance records shall be indexed. The indexing system (s) shall include, as a minimum, record retention times and the location of the records within the record system. The indexing system (s) shall provide sufficient information which lO can be used to identify item (s) or activity (ies)."
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5 Ol' Ell ATION A1, QU Al.lTY ASSUllANCE PitOGilAM DIGCittlTION II.1-22 3
EPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" 11.1.12 REGULATORY GUIDE 1.88 (Cont'd) 3.
Section 5.4.3 of ANSI N45.2.9-1974 is revised to read, "Special Processed Records - Provisions shall be made for special proces-O sed records (such as radiographs, photographs, negatives, and microfilm) to prevent damage from excessive light, stacking, electromagnetic fiC is, and temperature. These provisions will be delineated in procedures and/or instructions which will in-O corporate, or take into consideration, available manufacturers' reconinendations."
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APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" O
11.1.13 REGULATORY GUIDE 1.94, REV. 1 (April 1976)
" Quality Assurance Re-quirements for Installation, Inspection, and Testing of Structural Steel During the Construction Phase of Nuclear Power Plants" O
Supply System Position Regulatory Guide 1.94, Rev. 1 (April 1976) and the endorsed standard
- O ANSI N45.2.5-1974 are not considered applicable to operations phase activities. However, the Regulatory Position of Regulatory Guide 1.94, Rev. 1 (April 1976), where appropriate, will be implemented for those applicable. operational phase activities that are compar-O able to construction phase activities.
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II.1 " POSITION STATEMENTS FOR WNP-2" l
O II.1.14 REGULATORY GUIDE 1.116, REV. 0-R (May 1977)
"0uality Assurance Requirements for Installations, Inspection, and Testing of Mechani-cal Equipment and Systems" O
Supply System Position The Supply System will implement the Regulatory Position of Regula-O tory Guide 1.116, Rev. 0-R (May 1977) and the requirements in the endorsed standard ANSI N45.2.8-1975, subject to the following:
1.
Regulatory Position C.3 of Regulatory Guide 1.110, Rev. 0-R O
(May 1977) recomends that the requirements of Section 5 of ANSI N45.2.8-1975 pertaining to preoperational tests, cold functional tests, and hot functional tests should be used in conjunction with Regulatory Guide 1.68.
The Supply System will O
comply with the implementation of Regulatory Guide 1.68 as described in Chapter 14, " Initial Test Program", of the Final Safety Analysis Report.
- O 2.
Section 2.3 of ANSI N45.2.8-1975, last sentence is revised to read, " Test reports shall include an evaluation of the accepta-bility of inspection and test results and provide for identify-ing the individual who performed the evaluation."
O 3.
Section 2.8.2 of ANSI N45.2.8-1975 states, " Records of calibra-l tion shall be included in inspection and test results." Supply l
System does not intend to include calibration records in in-lO spection and test results.
Instead, the calibration records will be maintained in a separate file.
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- O APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" 11.1.14 REGULATORY GUIDE 1.116 (Cont'd.)
4.
Section 2.9.e(6) of ANSI N45.2.8-1975 states, " Evidence that engineering or design changes are documented and approved prior to O
installation." The Supply System may permit installation of an item prior to approval of the related engineering or design change provided procedural controls, requiring evidence of engineering or design change approval prior to placing the affected item into O
service, are instituted.
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11.1.15 Regulatory Guide 1.123, REV. 1 (July 1977)
" Quality Assurance Re-quirements for Control of Procurement of Items and Services for Nu-clear Power Plants" D
Supply System Position The Supply System will implement the Regulatory Position of Regula-O tory Guide 1.123, Rev. 1 (July 1977) and the requirements in the endorsed standard ANSI N45.2.13-1976, subject to the following:
1.
Regulatory Position C.3 of Regulatory Guide 1.123, Rev. 1 (July 3
1977): During printing of the Regulatory Guide, an error oc-curred in the last sentence. The Supply System will comply with the correct wording which reads as follows:
O While Section 9 of ANSI N45.2.-13-1976 addresses elements of the Purchaser's corrective action system, these same elements are applicable to the Supplier's corrective action system when one is required.
O 2.
Section 1.3 of ANSI N45.2.13-1976: The Supply System will com-ply with the definition of " procurement documents" as stated in Supply System Position Statement on Regulatory Guide 1.74 O
(February 1974).
3.
Section 3.2.2 of ANSI N45.2.13-1976: The first sentence of this Section is revised to read:
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APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" 3
11.1.15 Regulatory Guide 1.123 (Cont'd.)
" Technical requirements shall be specified in the procurement documents by reference to or inclusion of applicable specific 3
drawings, necessary portions of specifications, codes, regulations, procedures, or instructions (including revisions thereto) needed to accurately descr1be the products or services to be furnished."
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O CASHINGTON FUBLIC FOWER SUFFLY SY7 TEM OPERATIONAL PAGE QUAUTY ASSURANCE PROGRAM DESCRIPTION II.1-28
-O APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" lO.
11.1.16 REGULATORY GUIDE 1.144, REV. 1 (September 1980)
" Auditing of Qual-ity Assurance Programs for Nuclear Power Plants."
O Supply System Position The Supply System will implement the Regulatory Position of Regula-tory Guide 1.144, Rev. 1 (September 1980) and the requirements in O
the endorsed standard ANSI N45.2.12-1977, subject to the following:
Section 4.4.4 of ANSI N45.2.12-1977 requires the audit report to include an evaluation statement regarding the effectiveness of the O
quality assurance program elements that were audited. Since the audit by its very nature is an evaluation of the quality assurance program effectiveness, the audit report itself is considered to be an evaluation of the quality assurance program effectiveness.
O Therefore, this section of the Standard is revised to read "A Sumary of Audit Results."
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QUALITY ASSURANCE PROGRAM DESCRIPTION II.1-29 APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" D
II.1.17 REGULATORY GUIDE 1.146, (Auaust 1980)
" Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants" Supply System Position The Supply System will implement the Regulatory Position of Regula-tory Guide 1.146, (August 1980) and the requirements in the endorsed 3
standard ANSI N45.2.23-1978.
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' O APPENDIX II II.2 " POSITION STATEMENTS FOR WNP-1/4"
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II.3-1 APPENDIX II II.3 " POSITION STATEMENTS FOR WNP-3/5" O
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10 This section will be developed at a latef date.
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