ML20062D105

Revised Portion of QA Program for Design & Const Phase, Revision 1.Description of Qa/Qc Program to Be Implemented Upon Bechtel Assumption of Ae Responsibilities Will Be Submitted by 811211

ML20062D105
Person / Time
Site:	South Texas
Issue date:	10/29/1981
From:	Oprea G HOUSTON LIGHTING & POWER CO.
To:
Shared Package
ML20062D081	List: ML20062D077 ML20062D105
References
NUDOCS 8208050454
Download: ML20062D105 (12)

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. Organizational changes of a substantive nature will be reported to the NRC within 30 days of announcement.

3.0 Design Control HLSP has the overall responsibility for design and engineering of the South-Texas Project and imposes the requirements of 10CFR50, Appendix B, Criterion III, Regulatory Guide 1.64 (Rev. 2) and ANSI N45.2.11-74 on the prime contractors and applicable subcontractors.

f' HLSP has contracted with BSR and Westinghouse to perform the design, engineering and design verification. HLSP also utilizes the services  ;

of Bechtel Power Corporation to perform tasks,in support of these

• activities including review of engineering, design and construction activities and their associated records in order to " benchmark" project status, and to verify conformance with applicable requirements and i

. practices. Upon completio'n of review of specific design areas, HLSP may request Bechtel to complete or revise portions of such designs.

• Bechtel will execute all of the foregoing functions in accordance with l Bechtel Engineering- Department Procedures -(EDPs) listed on Table 1 at >

i Section 4.2.

HLSP Engineering performs reviews of selected elements of the completed-design, design documents and specifications to ensure that contractual requirements are met.

The HLSP Manager, Engineering is responsible for ensuring that project i engineering activities are conducted in accordance with approved engineering procedures. The project engineering organization provides programmatic direction and overview of the engineering activities. The HLSP project engineering activities are conducted in accordance with t~

Project Engineering Procedures (PEPS). These procedures are delineated in Table 1, Section 4.1.

When HLSP has direct responsibility or assumes direct responsibility for '

conducting design activities, these activities will be conducted in accordance with the requirements of this section and/or the FSAR Section 17.2.3.

HLSP contractors are' required to provide the following design control measures in their quality assurance programs:

a. A design control system is established to document the methods of accomplishing and controlling essential design activities.

b. Design documents such as calculations, diagrams, specifications, and drawings are prepared and records developed such that the '

final design is traceable to its sources.*

c. Design activities, documents and interfaces are controlled te assure that applicable input such as design bases, regulatory requirements, cedes, and standards are incorporated into the final design.

d. Design input requirements, including design criteria, are documented and their selection reviewed and approved.

8208050454 811124 PDR ADOCK 05000498 A PDR 12

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e. Design documents include an indication as to their importance to safety and shall specify the quality characteristics, in~cluding materials, parts, equipment and processes, that are essential to functions of structures, systems, and components. Design documents also include, as appropriate, acceptance criteria for inspections and tests.

f. Design control measures are applied to items such as seismic, stress, thermal, hydraulic, radiation, and accident analyses, as they n,

apply to the development of safety-related design input or as they are used to analyze the design.*  !

g. Safety-related and/or Seismic Category I designs _ are verified for adequacy and accuracy through independent objective review of design documents by individuals competent in the subject activity.

This verification may include the use of alternate or simplified solution methods or qualification testing, as appropriate.*

h. Design changes, including engineering, vendor, and construction originated changes, are controlled in a manner commensurate with the control imposed on the original design.

i. Document distribution is controlled such that all individuals using a design document or its results and/or conclusions for further design work can be notified if the document is revised or cancelled.

j. Design documentation includes evidence that design control requirements have been satisfied.

k. Errors and deficiencies in approved design documents, including' design methods (such as computer codes), that could adversely affect structures systems and components important to safety are documented; and action taken to assure that all errors and deficiencies are corrected.

1. Deviations from specified quality standards are identified and procedures are established to ensure their control.

HL6P Quality Assurance performs audits of HL6P, Bechtel, BGR, and #

Westinghouse to ensure that design controls, requirements, specifications and documents are in accordance with the design control criteria. These audits wi,11 include review of the frequency and effectiveness of the j use of supervisors as design verifiers.

In addition HL6P Project Quality Assurance reviews quality / construction procedures to ensure that the quality requirements of the design specifications are incorporated. HL6P Project Quality Assurance also performs impicmentation reviews to ensure that the work is accomplished in accordance with the design requirements and to ensure that field changes to the des:;n are processed in accordance with the design control' criteria.

With respect to work performed by Bechtel Power Corporation, these ,

design control measures are subject to the interpretation set  ;

forth in Notes 4 through 8 of Table 2.

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4.0 Procurement Document Control To assure that nuclear safety-related items are purchased in a planned and controlled manner, the HLSP Project Quality Assurance Plan establishes basic requirements which are to be used by HLGP in preparing procurement procedures for the South Texas Project. B6R performs procurement activities for nuclear safety-related 13

Table 1 Plan / Procedures used to Implement Quality Assurance for the Major Activities 10CFR50 App. B 4.1 Project Engineering Procedures Criterion PEP - I Introduction P

II Manual Provisions i _

III Scope l

, IV Definitions

-01 Preparation and Control of Project Engineering VI i Procedures J

-02 Document Receipt G Handling N/A

-03 Engineering Signature Authority III

-04 Reference Document Library N/A

-05 Performance of Owner's Reviews III

-06 Design Change Request N/A

-07 (deleted) Design Document Distribution List N/A

-08 Engineering Action Item Tracking N/A

-09 Transmittal of Owner's Review Comments to Ext. N/A Organizations

-10 Project Engineering Organization 5 Responsibilities I

-11 Reporting Design and Construction Deficiencies XV,XVI to NRC

-12 Handling FSAR Change Notices II

-13 Review of ';RC Inspection and Enforcement Bulletins II Circulars

-14 Designation G Handling of Confidential Security N/A Docu ents

-15 Preparation of Purchase Authorizations (IP) N/A

-16 Engineering Activity for the Procurement of Spare IV,VII Parts Table 1-4

e Table 1 Plan / Procedures used to Implement Quality Assurance for the Major Activities 10CFR50 App. B 4.1 Project Engineering Procedures Criterion

-17 Preparation of NSSS Contract Modification Approval N/A p- (IP)

-18 Preparation and Control of Specifications III,IV

-19 Processing Supplier Deviation Requests (IP) III,IV

-20 Document Change Notice control (IP) VI,III

-21 Design Verification (IP) _ III

-22 Personnel Training (IP) II Note: (IP) indicates procedure is in preparation and not yet issued for use.

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l Table 1-5

t Table 1 Plan / Procedures used to Implement Quality Assurance for the Major Activities 4.2 Bechtel, Los Angeles Power Division 10CFRS0 App. B Engineering Department Procedures Criterion EDP-1.7 Engineering Department Procedures Preparation V p- and Con +.rol EDP-1.10 Division and Project Engineering Department V Procedures Preparation and Control EDP-2.7 Engineering Department I EDP-2.10 Engineering Management I EDP-2.13 Project Engineering Team Organization and I Responsibilities EDP-2.16 Project Design Group Functions I EDP-3.4 Scope of Services and Division of Responsibility N/A EDP-3.7 Project Material Assignment Schedule N/A EDP-3.10 Engineering Planning and Control N/A EDP-3.13 Processing and Control of Contract Changes N/A EDP-3.19 Trend Program N/A EDP-3.22 Cost Estinating Assistance Request N/A EDP-4.1 Design Criteria III EDP-4.2 Generic Engineering Documents III EDP-4.4 Design Standards and References for Project N/A Libraries l

EDP-4.7 Bechtel Manuals N/A EDP-4.13 Project Scope Book N/A EDP-4.16 Engineering Studies and Reports N/A EDP-4.20 Abstracts for Engineering Department Reports N/A g and Studies i EDP-4.21 Preparation and Control of Environmental Reports N/A EDP-4.22 Preparation and Control of SAR II l Table 1-Sa ,

1 Table 1 l l

Plan / Procedures used to Implement Quality Assurance for the Major Activities 4.2 Bechtel, Los Angeles Power Division 10CFR50 App. B Engineering Department Procedures Criterion I

EDP-4.23 SAR Change Control II EDP-4.24 Environmental Report Change Control N/A EDP-4.25 Design Interface Control III EDP-4.26 Interdisciplinary Design Review III,VI III  ;

EDP-4.27 Design Verification EDP-4.28 Project Q-List III EDP-4.31 Symbols for Identification of Q-Listed Items III EDP-4.33 On-Project Design Review III,VI EDP-4.34 Off-Project Design Review (Design Control Check III,VI List and Design Review Notice)

EDP-4.36 Standard Computer Programs III EDP-4.37 Design Calculations III EDP-4.40 Release of Engineering Calculations to Client N/A EDP-4.46 Project Drawings V,VI EDP-4.47 Drawing Change Notice V,VI EDP-4.48 Standard Drafting Procedure N/A EDP-4.49 Project Specifications III,IV EDP-4.52 Project Adaption of Thermal Power Organization II,IV,VI Standard Technical Specification EDP-4.55 Project Material Requisitions IV EDP-4.58 Specifying and Reviewing Supplier Engineering and II,IV Quality Verification Documentation EDP-4.60 Processing Corrective Action Requests XVI Table 1-5b

1 Table 1 Plan / Procedures used to Implement Quality Assurance for the Major Activities 4.2 Bechtel, Los Angeles Power Division 10CFR50 App. B Engineering Department Procedures Criterion EDP-4.61 Nonconformance Reports (NCR) XV EDP-4.62 Field Change Request (FCR) III,V,VI EDP-4.63 Supplier Deviation Disposition Requests III EDP-4.64 Review of Supplier Audit, Survey, and Inspection VII,XVIII Reports EDP-4.65 Design Deficiency Processing .

III,XV EDP-4.66 Substantial Safety Hazard and Significant Deficiency III,XV Reporting (Deficiency Evaluation Report)

EDP-4.74 Experience Feedback N/A EDP-4.77 Plant Data Book N/A EDP-4.79 Control of Nuclear Plant Security Systems VI Documentation EDP-5.1 Communications Control N/A EDP-5.10 Project Engineering Procedures Manual II EDP-5.13 Control Logs VI EDP-5.15 Design Drawing Control V,VI EDP-5.16 Supplier Document Control VI,Il EDP-5.17 Control and Processing of Computer Aided Drafting N/A EDP-5.19 Computer Program Use and Control N/A EDP-5.25 Project Master Distribution Schedule N/A EDP-5.31 Project Record Retention Procesqing XVII EDP-5.32 Nuclear Project Records Management (Design Office) III, XVII EDP-5.34 Project Quality Program Indoctrination and Training II EDP-5.37 Microfilming N/A Table 1-5c

Table 1 Plan / Procedures used to Implement Quality Assurance for the Major Activities 4.2 Bechtel, Los Angeles Power Division 10CFR50 App. B Engineering Department Procedures Criterion EDP-6.5 Bid Evaluation IV I

EDP-6.10 Supplier Quality Assurance Program Selection IV and Evaluation EDP-7.3 Consultant Service Agreements and Consultant N/A Invoices EDP-7.9 Attendance at Technical Meetings by Engineering N/A Personnel ,

Table 1-5d

TABLE 2 ANSI STANDARD AND REGULATORY GUIDE COMPLIANCE (Continued)

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ANSI N45.2.10-1973 Quality Assurance Terms and R.G. 1.74 (Rev. 0,2/74) Definitions ANSI N45.2.11-1974 Quality Assuran: e Requirements for R.G. 1.64 (Rev. 2,6/76)

• the Design of NL' clear Power Plants (see Notes 4 thru 8) l ANSI N45.2.12 Requirements for Auditing of Quality I (Draft 3, P.ev. 4, 2/74) Assurance Programs for Nuclear Power (see Note 3) Plants l ANSI N45.2.13 Quality Assuran'ce Requirements for (Draft 2, Rev. 4, 4/74) Control of Procurement of Items and Services for Nuclear Power Plants ANSI N101.4-1972 Quality Assurance Requirements for R.G. 1.54 (Rev. 0,6/73) Protective Coatings Applied to Water Cooled Nuclear Power Plants Exception Notes

1. ANSI N45.2.5-1974, Section 4.8, states " Pumped concrete must be sampled from the pump line discharge." In lieu of this statement, in-process strength samples of pumped concrete are taken at the delivery point. Correlation tests of air content, slump, and temperature are performed to verify these plastic properties of the concrete at the placement point in accordance with the following frequency requirements.

A. A minimum of 2 correlation tests are performed for each pumped placement exceeding 200 cu. yds.

B. Otherwise, a minimum of 2 correlation tests per week are performed when any individual pumped placement during a week requires delivery of more than one truckload of concrete.

C. During a week when a pumped placement exceeding 200 cu. yds. is made, the correlation tests performed on that placement will satisfy the weekly requirement for performing two correlation tests as specified in Item B above.

When any of the specified limits and tolerances on loss of air content, slump, or temperature are exceeded at the placement point, correlation tests between the delivery point and placement point will be acccmplished for each 100 cu. yds. of concrete placed as long as limits and tolerances are exceeded. If two consecutive tests are out of tolerance, corrective action will be implemented Table 2-2

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TABLE 2 I

ANSI STANDARD AND REGULATORY GUIDE COMPLIANCE F

(Continued) to adjust the limits for the concrete entering the pump intake so that no concrete from the subsequent trucks will enter the pump p intake as long as the tolerances are exceeded.

" Correlation Tests," " Delivery Point," and " Placement Point" are as defined in ANSI N45.2.5-1978, Section 1.4.

2. Samples and frequency for cadweld testing is in accordance with l

ACI-359/ASME Section III, Division 2, issued for trial use and comment in 1973, including addenda 1 through 6, (see Sections 3.8.1.6.3 and 3.8.3.6.3 of the STP Final Safety Analysis Report) .

3. If a work activity and contract is for a two-month period or less, an audit is not necessary when a facility preaward audit has been conducted.

• The following interpretations of ANSI N45.2.11-1974 and Regulatory Guide 1 1.64, Rev. 2-6/76, apply to work performed by Bechtel Power Corporation. j l

4. Section 3.1, Design Input Requirements, General. This section  ;

implies that all necessary design input (as listed in Section 3.2) {

should be available prior to the start of a design activity. In j practice, certain design-activities are initiated before the firm e

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input requirements are available. (For example, foundation designs l prepared based on preliminary information or equipment sizes and I mounting, embedded conduit run based on preliminary estimates of ,

circuit requirements, etc.) The design phase QA program will be l structured to ensure that all necessary design input is available  ;

before completion of final design of the work affected by the input, and that final design input is available for use in verification of - l the final design. i

5. Section 4.a, Design Process, General. Paragraph 3 implies trace- l ability back from final design to the source of design input. In practice, a literal interpretation of this is not always possible.

For example, final design drawings do not identify the related cal-culations. This paragraph will be interpreted to mean that it shall be possible to relate the criteria used and analyses performed to the final design documents and that record files will permit location of analyses supporting specific design output documents.

6. Section 4.2, Design Analyses. This section implies a requirement for retention of all calculations. .In principle, it is considered good practice for the responsible engineer or engineering organization to retain all final calculations, and this will be done for all manual calculations covered by the program. However, for computer programs only documentation of the design input, assumptions made in the analyses, results obtained, and evidence of verification will be

_ retained since permanent retention of all versions of all computer Table 2-3

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ANSI STANDARD AND REGULATORY GUIDE COM (Continued) 4~!

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programs is not considered practical or necessary if sufficient information is available for a competent individ

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? the results using the input and assumptions ual to verify

7. Section 10, Records.

j and coordination of drawings (for example, check a

prints) or copies of marked-up specifications used toonsolicit c

shall be retained until issued for use outside of Engineering. the drawing or specification is approv ents

.and i  :

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I may be discarded once the documentved, hasbutbeen sentence of the second paragraph the phrase "pproved. In the first final design documents" shall mean those documents which are the late been issued for use.

8.

Regulatory Position, Section C-2:

.{ the originators' immediate supervisor is the only techniIf, cally qualified in an e individual available, the design verification or checking will be conducted by the supervisor with the following provisions:

a.

The other requirements of Regulatory Guide 1.64 will be met

b. .

{ The justification for having the design verification or i documented and approved by the nextchecking con i level of supervision.

I c.

. Quality Assurance audits will include review of the frequ

~l and to effectiveness assure that of the use of the immediate supervisor

circumstances. this provision is used only in expectional 4

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Table 2-4

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