ML20065U354

QA Program Plan for Facility

ML20065U354
Person / Time
Site:	Point Beach
Issue date:	06/02/1982
From:	WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:
Shared Package
ML20065U352	List: ML20065U350 ML20065U354
References
EQA-82-DEU-178, WCAP-9245, WCAP-9245-R06, WCAP-9245-R6, NUDOCS 8211040304
Download: ML20065U354 (25)

Text

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WCAP 9245 Revision 6 June 1982 Class 3 -

i NUCLEAR SERVICE DIVISION QUALITY ASSURANCE PROGRAM PLAN l

1 APPROVED: i 6!!/[8L PRODUCTASSURANCEMAN)GER 1

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! WESTINGHOUSE ELECTRIC CORPORATION Nuclear Energy Systems Nuclear Service Division P. O. Box 2728 Pittsburgh, PA 15230 i

i O B211040304 821027 PDR ADOCK 05000266 P PDR ..

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NSD QA PROGRAM PLAN TABLE OF CONTENTS 1

Effective Section Page Date 1 INTRODUCTION 1 6/82 1.1 Scope 1.2 Applicability 2 QUALITY ASSURANCE PROGRAM 3 6/82 2.1 General 2.2 Quali*.y Assurance Program Plan 2.3 Implementing Procedures 2.3.1 Division Operating Manual 2.3.2 Product Assurance Manual 2.3.3 Department Procedures /

, Instructions 2.3.4 Technical Procedures 2.4 Training and Indoctrination 2.5 Management Review 3 ORGANIZATION 7 6/82 3.1 General 3.2 Responsibility and Authority

3.3 Delegation of Quality Assurance i Function 4 DESIGN CONTROL 9 6/82 4.1 General 4.2 Design Process 4.3 Interface Control 4.4 Design Verification 11 O

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Effective Section Page Date 4.5 Design Review 4.6 Design Changes 4.6.1 Equipment Used in Field Services 4.6.2 NSSS Equipment 5 PROCUREMENT DOCUMENT CONTROL 14 6/82 5.1 General 5.2 Procurement Documents 5.3 Purchase Requisition Reauirements 5.3.1 Supplier Quality Assurance Program Requirements 5.3.2 Basic Technical Requirements 5.3.3 Documentation Requirements 5.3.4 Lower Tier Procurements 5.3.5 Source Inspection and Audit 5.4 Review of Supplier Submittals 6 INSTRUCTIONS, PROCEDURES, AND DRAWINGS 17 6/82 6.1 General 6.2 Control Methods 7 DOCUMENT CONTROL 18 6/82 7.1 General 7.2 Review of Contract Agreements 7.3 Drawing and Specification Control 7.4 Procedures and Instructions Control 8 CONTROL OF PURCHASED M!.TERIAL, EQUIPMENT, AND SERVICES 21 6/82 iii O

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Effective Section h Date 8.1 General 8.2 Control of Suppliers 8.2.1 Pre-Award Surveys and Selection 8.2.2 Supplier Surveillance 8.2.3 Quality Release 9 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS 25 6/82 9.1 General 9.2 Manufacturing Controls 9.3 Site Controls 10 CONTROL OF SPECIAL PROCESSES 26 6/82

! 10.1 General 10.2 NSD Processes, Equipment, and Personnel O 10.3 Supplier Control 11 INSPECTION 28 6/82 11.1 General 11.2 Inspection Planning 11.3 Inspection and Surveillance 11.3.1 Site Service Activities 11.4 Inservice Inspection 12 TEST CONTROL 31 6/82 12.1 General 12.2 Test Planning and Application

. 12.3 Documentation of Test Results i

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e O Effective Section Page Date 13 CONTROL OF MEASURING AND TEST EQUIPMENT 34 6/82 13.1 General 13.2 Supplier Control 13.3 Measuring and Test Equipment Control 14 HANDLING, STORAGE, AND SHIPPING 35 6/82 14.1 General 14.2 Purchased Equipment 14.3 Component Handling Equipment 15 INSPECTION TEST AND OPERATING STATUS 36 6/82 15.1 General 15.2 Procured Equipment and Material 15.3 Site Operations 16 NONCONFORMING ITEMS 38 6/82 16.1 General 16.2 Initiation, Control, and Disposition of Nonconformances i 16.3 Reinspection 16.4 Documentation of Nonconformar.ces 17 CORRECTIVE ACTION 40 6/82 17.1 General 17.2 Corrective Action Program 18 - QUALITY ASSURANCE RECORDS 42 6/82 18.1 General 18.2 Manufacturing and Service Quality Records 18.3 Site Records 18.4 Records Management v

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Effective Section Page Date 19 AUDITS 44 6/82 19.1 General 19.1.1 Productivity Center Quality Assurance Audits 19.1.2 NES Quality Assurance Audits 19.2 Audit Planning 19.3 Auditor Training 19.4 Audit Scope 19.5 Audit Reporting and Corrective Action 19.6 Customer Audits of NSD REFERENCES 48 6/82 APPENDICES A. Implementing Quality Assurance Program Procedures Listing.

B. NSD Quality Assurance Program Organization Chart and Department Function Description.

C. Water Reactor Divisions Organization Chart.

D. Quality Assurance Records Provided for Site Services.

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O Q NSD QUALITY ASSURANCE PROGRAM PLAN SECTICN i INTRODUCTION 1.1 SC0pE This Quality Assurance Program Plan (QAPP) describes the program used by the Westinghouse Nuclear Service Division (NSD) to assure that products and services meet customer, regulatory and Westinghouse requirements for quality, safety and reliability. This QAPP establishes the overall division policies related to assurance of quality in the division's work.

The NSD QAPP complies with the NRC Quality Assurance (QA) criteria, 10CFR50, Appendix B, and follows the regulatory position provided in associated NRC regulatory guides. It is consistent with requirements of ANSI N45.2, ANS 3.2/ ANSI N 18.7 and established Water Reactor Division (WRD) policies as they apply to NSD products and services. The QAPP is also consistent with ASME code requirements applicable to NSD services which are performed under ASME Section XI, and Section III. The major headings in the QAPP are the same as those in ANSI N45.2 for easy reference to the requirements of that standard.

1.2 APPLICABILITY The overall policies established by this program plan are applicable to activities affecting the quality, safety and reliability of NSD services, including service equipment, materials, and renewal parts. The 18 ANSI N45.2 criteria which are applicable to major NSD service activities are listed below. The criteria applicability differ by activities because of the work scope. Note that the applicability defined for a service activity refers to all organizations involved in the activity.

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j Major NSD Service Activities QAPP Section j Installation Advisory Services 2,3,7,11,14,16,17,19 Fueling Service 2,3,4,5,6,7,8,9,11,12,13,14, 15,16,17,18,19 Inspection Service 2,3,4,5,6,7,8,9,10,11,12,13, 14,15,16,17,18,19 Repair Service 2,3,4,5,6,7,8,9,10,11,12,13, 14,15,16,17,18,19 Standard Service Projects 2,3,4,5,6,7,8,9,10,11,12,13, 14,15,16,17,18,19 Major Modification Projects 2,3,4,6,7,8,9,10,11,12,13,14, 15,16,17,18,19 Renewal Parts 2,3,4,5,6,7,8,9,14,16,17,18,19 Startup Service 2,3,5,6,7,8,9,11,12,13,17,18,19 Component Handling 2,3,4,5,6,7,8,9,10,11,12,13, 14,16,17,18,19 Installation Paid Services 2,3,4,5,6,7,8,9,10,11,12,15, 14,15,16,17,18,19 Operating Plant Engineering Services 2,3,4,7,9,11,12,14,16,17,18,19 Managed Maintenance Support 2,3,4,6,7,9,18,19 9

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O V SECTIO'l 2 QUALITY ASSURANCE PROGRAM 2.1 GENERAL This section provides a general description of the NSD Quality Assurance Program and shows the relationship of the manuals and procedures which are used to document and implement the policies and provisions of the Quality Assurance Program.

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This section presents the basic policies on training and qualification of NSD personnel and describes the methods used for periodic assessment of the Quality Assurance Program.

2.2 QUALITY ASStfRANCE PROGRAM PLAN The QAPP provides the policies and general practices for a planned and disciplined approach to the achievement of the necessary quality, safety and reliability in NSD supplied products and services. The quality p assurance program applies to NSD activities to the extent described in d Section 1.2; the QAPP includes activities related to nuclear plant installation and to services performed in the operating plant phase. The purpose of the QAPP is to provide a program which assures that NSD will meet contractual quality requirements and regulatory requirements. It is further intended to provide a high level of customer satisfaction with NSD products and services important to plant operations regardless of l safety relatedness. The QAPP emphasizes the problem prevention aspects of quality assurance as the most economical approach in achieving quality.

i The QAPP defines the responsibilities and authorities of major NSD organizational units with respect to the Quality Assurance Program. The QAPP and its implementation is reviewed periodically with consideration of audit findings and other periodic management assessments and is I updated as necessary to incorporate new requirements, new scope of NSD business and to improve its effectiveness in achieving the objectives outlined in the preceding paragraph.

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2.3 IMPLEMENTING PROCEDURES NSD activities covered by this QAPP are conducted in accordance with documented procedures which require work performance in a controlled and disciplined manner. These procedures provide instructions to NSD personnel who, in the course of performing their assigned duties, engage in quality-related activities affecting services. The types of procedures and the responsibility for their issuance and maintenance are described below.

2.3.1 Division Operating Manual The top level procedures governing quality-related activities are contained in the division Operating Procedures Manual. The issuance and control of these procedures is the responsibility of Product Assurance, as defined by a division policy which also provides for involvement of affected disciplines in the procedure review process so that appropriate requirements and interfaces are recognized and defined. Product Assurance ,

is assigned the responsibility for ensuring that quality assurance requirements and the policy of the QAPP are reflected in the operating procedures.

Division Operating Manual Policy / Procedures are approved by the NSD General Manager.

2.3.2 Product Assurance Manual The Product Assurance Manual contains procedures which provide direction to Product Assurance personnel in conducting specific quality assurance activities. The procedures are approved by the Product Assurance Manager. Issuance of the Product Assurance Manual is the responsibility of the Product Assurance Department.

2.3.3 Department Procedures / Instructions While the above documents describe the NSD system of Quality Assurance controls, departments or groups within the departments issue and maintain procedures / instructions, as QA360/1Q8204 4

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( appropriate, to provide detailed information to their personnel in the performance of their work. These procedures /instruc-tions, which are approved by the department or group manager, are applicable to work performed within the department. The issuing organizations are responsible for ensuring that the procedures / instructions are consistent with the policy of the QAPP and division operating procedures. Audits by Product Assurance verify that such procedures / instructions are consistent with division level policies and procedures.

2.3.4 Technical Procedures For major operational activities involving service equipment, processes or materials, conducted either at support facilities or in the field, appropriate detailed technical procedures are used. These procedures provide operational parameters, operation sequence, equipment preparation and maintenance requirements, test conditions and field service requirements as appropriate. They also provide for integrated actions where p)

(, several departments are involved in the activity. Controls for issuance and use of technical procedures are discussed in Section 7.

2.4 TRAINING AND INDOCTRINATION Line managers are responsible for ensuring that their personnel are ade-quately indoctrinated and trained in the skills and disciplines necessary for them to carry out their functions in a manner to assure achievement of quality. This includes indoctrination in the overall quality program and training in the use of appropriate procedures, in the special skills including special processes and in technical specifications related to the work involved. Proficiency is maintained by on-the-job experience, periodic re-training and, where necessary, re-evaluation and re-certification.

Product Assurance is responsible for assisting the line managers with the indoctrination and training of NSD personnel in the provisions of the O

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l QAPP. Product Assurance is .esponsible for training its personnel in functional methods such as audits, quality engineering, inspections, surveillance of field services and in any special processes such as nondestructive examination. The department is also responsible for auditing the training of other NSD and subcontractor personnel in quality related areas.

2.5 MANAGEMENT REVIEW The NSD Quality Assurance Program is reviewed and results of the review provided to the Division General Manager and his staff with at least one review per year. The review is a management assessment of the effective-ness of the program including its compliance with applicable regulatory guides and ANSI standards. Effectiveness in providing for customer satisfaction regardless of safety relatedness is also considered. These reviews are accomplished by one or more of the following:

a. An assessment by the Product Assurance management including a review of quality problems and their underlying causes, analysis of trends, and reviews of other program assessment actions such as audits (internal and customer) and corrective action status. This assessment is presented in a written report to th'e General Manager and his staff for review and further action.

b. Audits or reviews which may be directed by the General Manager's str.ff to assess particular aspects of the program's effectiveness.

c. Corporate level QA audits.

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A Q SECTION 3 ORGANIZATION 3.1 GENERAL This section describes the major NSD organizational units and their responsibility and authority in regard to assuring quality of NSD products and services.

3.2 RESP 0NSIBILITY AND AUTHORITY The responsibility and authority of the major organizations and the scope of their work in regard to products and services is defined by department charters contained in the division operating manual. The charters are revised to remain current with the organizational changes. These charter responsibilities are summarized in Appendix B of this plan.

Managers of NSD functional departments and lower tier organizations are responsible for the achievement of quality in the services and functions assigned to their organizations. They are also responsible for conducting the operation of their organization in compliance with the applicable requirements of this QAPP.

The Product Assurance Department is responsible for assuring quality in the services and products of the division. For this reason the Product Assurance Manager, who has the overall responsibility for the Quality Assurance Program, reports directly to the Division General Manager.

This provides organizational freedom ind authority to plan and organize the program, to identify quality problems, to initiate corrective action, to verify that problems have actually been solved, to verify conformance.

of NSD activities to the Quality Assurance Program and to verify conformance of work to specified requirements. On field services at operating plants, on construction sites or otherwise as appropriate, the NSD Product Assurance Manager and/or his representatives will interface directly with the utility customer Quality Assurance mrnagement or NRC representatives on quality assurance matters.

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The Product Assurance Manager has the authority to enforce compliance ,

with the provisions of this QAPP and the implementing procedures, including the authority to disapprove drawings, specifications or other documents where quality requirements are not met. He also has the authority to stop work or to control further operations where significant conditions adverse to quality are identified and immediate corrective actions are required.

Qualification requirements for the NSD Product Assurance manager are:

o A bachelor's degree in Engineering or related technical area.

o Ten years engineering experience in design, quality assurance, or manufacturing.

o Five years experience in management.

o Ten years experience in the nuclear industry.

3.3 DELEGATION OF QUALITY ASSURANCE FUNCTION .

O When work related to installation or operating plant services is assigned to another Westinghouse division, the quality assurance organization responsible for that divisions' quality program is responsible for the assurance of the quality of that assigned work. Along with such delegation, determination is made that the division's quality assurance program extends appropriate controls over the work effort, under the applicable quality assurance program i.e. WCAP 8370 for NTD, SOD or manufacturing divisions of WRD and WCAP 7800 for NFD. For work that is subdivided, NSD Product Assurance provides any necessary additional quality assurance instructions and verifies that systems are in place to assure QA functions are properly performed during direct interfacing actions with the QA group, reviews or audits as appropriate.

For reference purposes, a chart portraying NSD organizational relation-ships with other W Water Reactor Divisions is shown in Appendix C.

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O y, SECTION 4 DESIGN CONTROL 4.1 GENERAL This section contains the provisions for controlling designs and changes to designs so that functional requirements, regulatory requirements, codes and standards are correctly incorporated into specifications, drawings, and procedures. NSD design activities apply primarily to service tooling and equipment and to service processes. In some cases, NSD may design parts used in the repair of items for Nuclear Steam Supply System (NSSS) components. In such cases, the designs are reviewed and approved by the division responsible for the component design. Design activities are governed by written procedures that provide necessary design control. The division operating manual contains procedures which provide methods for controlling design-related activities such as establishm*nt of functional specifications, review of customer requirements; selection of codes and standards; verification of the adequacy of design, design changes, design interfaces; and a description O

y/ of the interfaces with other W Water Reactor Divisions.

The design control provisions of this section may be waived for service equipment wr en such equipment is simple, will not be used on safety related systams and management review indicates waiver is appropriate.

Such waivers require approval of Service Engineering, Product Line (Service Operations or Steam Generator Services as appropriate) and Product Assurance management.

4.2 DESIGN PROCESS The design process normally starts with a functional specification initiated or approved by the NSD functional manager who has need for equipment er service tooling. The Service Engineering Department concurs-with the functional specification. The functional specification defines the functional requirements for the equipment, including technical, regulatory, maintenance, customer, etc., requirements. Service Engineering is responsible for the design and development of equipment, O

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systems, and services in a manner which will lead to high service reliability and which complies with the functional requirements.

Equipment specifications are prepared in accordance with a written procedure. The term " equipment specification" as used in this plan includes drawings and specifications which specify the functional and design configuration of an item for procurement, manufacturing, installation and operational purposes.

Technical design specifications may also be prepared for construction, fabrication of equipment or other site work which will be designed by other subcontractors such as architect engineers or constructors. In such cases, designs prepared by others as part of subcontracted work are reviewed and approved by Service Engineering. When specific delegation is documented between NSD and an NSSS design-responsible WRD organiza-tion, NSD may implement design changes in the field based on telephone or telegraph communcations with the responsible division, provided the change is processed through normal documentation routes in a parallel action.

Equipment specifications and technical design specifications are reviewed by affected departments including Product Assurance and the initiator of the functional specification. Other Water Reactor Divisions may be included if appropriate. These reviews confirm that equipment specifica-tions meet functional specification requirements, conform to established engineering standards, meet the applicable code requirements, satisfy safety requirements and contain the necessary quality requirements, including acceptance criteria. Comments of the reviewers are evaluated and resolved prior to final approval of the equipment specification.

Results of the reviews, including resolution of comments, are documented.

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yi 4.3 INTERFACE CONTROL Within NSD, procedures provide for the coordination and control of interfaces. WRD interdivisional interfaces are defined by documented interface agreements which assign responsibility for review, comment, approval and revision of documents affecting design interfaces. This assures that design interfaces (e.g., between service tooling and NSSS components) are defined and considered in the design of service equipment.

4.4 DESIGN VERIFICATION Designs are verified by one or more of the following methods:

a. Checking of calculations and assumptions by a qualified engineer other than the one who performed the original calculations.

b. Alternate calculation methods by a qualified engineer other than the one who performed the original calculations.

c. Tests to verify adequacy of the design to perform under conditions specified for the design. Tests are controlled in accordance with Section 12 of this Program Plan.

The selection of design verification methods for a specific design is the responsibility of, and is documented by, the cognizant engineering manager.

4.5 DESIGN REVIEW Formal design reviews are conducted on important (i.e., safety relat;.

and high financial exposure) equipment or other items / activities of significant design complexity to consider ability to meet functional requirements, safety, reliability and practicality of fabrication,.

utilization and maintenance.

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The selection of the specific equipment to be reviewed and the scheduling of the reviews are based on many considerations including whether or not the equipment is of a new design, the importance of the item to safety, plant availability and performance and previous experience with the equipment or similar types of equipment. The responsibility for determining need for design review rests with Service Engineering with input from other departments.

The design reviews are conducted and documented in accordance with written procedures, which require assignment of responsibilities for action on open items and resolution of open items. Formal documented follow-up is required by the design review chairman.

4.6 DESIGN CHANGES 4.6.1 Equipment Used in Field Services Request for design change is initiated in accordance with established procedures by the NSD engineer recognizing the need for change.

Service Engineering is responsible for evaluating and executing design changes and for maintaining design descriptions current by incorporation of changes into drawings and specifications.

l NSD Product Assurance is responsible for reviewing design change procedures and for verifying by inspection or surveil-lance that equipment conforms to current design definition.

4.6.2 NSSS Equipment l Design changes to NSSS equipment at plant sites are defined by l

documents (e.g. Field Change Notices - (FCN's)) issued or I approved by NTD, or 500. Where unanticipated changes to existing equipment design is required during field activities, 1

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t NSD obtains concurrence of the customer and/or the responsible l

! design organization (other WRD divisions for W designed NSSS equipment).

For parts supplied to customers; provisions are made within procurement documents to obtain responsible design organization

! review of changes to assure parts interchangeability.

NSD's function is to provide on site technical advice and consultation to the customer for making recommended installations or modifications; or, via specific service contract, to provide installation or modification services.

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SECTION 5

' PROCUREMENT DOCUMENT CONTROL 5.1 GENERAL This section describes the policies used in generating and controlling procurement documents to ensure the incorporation of applicable technical and quality requirements into NSD procurement documents. These policies include provisions for independent reviews to assure that requirements are properly specified and for specifying the control requirements to the supplier.

5.2 PROCUREMENT DOCUMENTS Procurement actions are initiated by the cognizant NSD engineer by means of a purchase requisition. A quality assurance level is assigned to the purchase requisition in accordance with written criteria based on the effect of failure and other considerations. The purpose of the quality assurance level designation is to classify procurements for the requisitioner and the quality engineering reviewer, for appropriate selection of supplier Quality Assurance system requirements and for the proper application of supplier evaluation, surveillance and release for shipment controls. The higher quality level purchase requisitions on equipment, materials, and services to be used in perform'ng services in customer plants are reviewed and concurred with by Product Assurance prior to placing the purchase order. These reviews verify inclusion of appropriate quality requirements and check for clarity and completeness.

On other procurement documents (i.e. common commodities) where effect of any noncompliance would have minor significance and where costs are low and schedules not restrictive, this review may be accomplished after the fact.

l Changes to purchase orders are initiated by purchase requisition change notice and are handled in the same manner as the original purchase l requisition.

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Procurement actions for customer-ordered renewal parts are initiated by a purchase requisition written by NSD Material and Technical Services based on technical information from NTO or 500. Special quality codes are developed and verified where necessary by consultation with other divisions, and used to define quality requirements. NSD Product Assurance has the overall responsibility for the quality assurance control of contract ordering and procurement documents for renewal parts.

Product Assurance procedures require quality engineers to review renewal equipment purchase documents including requisitions, purchase orders and changes to insure that appropriate quality requirements and acceptance criteria are applied. This review also determines that the included technical requirements have been prepared by or reviewed with engineering personnel who are familiar with the design, so that renewal equipment similarity and compatibility to the original design is considered. NSD Product Assurance may delegate surveillance responsibility for the inspection and release of renewal parts to other divisions such as NTD or SOD, and assures through audits or joint surveillance, as appropriate, that other divisions fulfill the necessary quality requirements.

5.3 PURCHASE REQUISITION REQUIREMENTS Purchase requisitions or documents referenced within purchase requisitions for higher quality level items, include the following requirements, as applicable:

5.3.1 Supplier Quality Assurance Program Requirements The suppliar quality assurance program requirements for items or services procured.

5.3.2 Basic Technical Requirements Applicable provisions in procurement documents regarding (a) drawings, specifications, codes, and industrial standards with applicable revision dates; (b) test and inspection require-ments; and (c) special instructions and requirements for designing, fabricating, cleaning, erecting, packaging, handling, shipping, and if applicable, extended storage in the field.

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5.3.3 Documentation Requirements Procurement documentation requirements include provisions for the preparation, maintenance, and availability for review (or submittal) of records such as drawings; specifications; procedures; procurement documents; inspection and test records; personnel, procedure and equipment qualifications; material, chemical, and physical test results. Provisions are also made for supplier's reporting non-conformances to procurement requirements for WestinghcJse disposition. Where data is important, procurement documentation requirements also include provisions for instructions on record retention and disposi-tion. Records that are not to be submitted are required to be available for review.

5.3.4 Lower Tier Procurement This provision involves the extension of applicable require-ments of procurement documents to lower tier subcontractors and suppliers, primarily purchaser's access to facili1 ties and records.

5.3.5 Source Inspection and Audit This provision, where applicable, is to provide access to the plant facilities and records for source inspection and audit when the need for such inspection or audit has been determined by NSD.

5.4 REVIEW OF SUPPLIER SUBMITTALS Supplier submittals for review and approval of manufacturing, inspection, nondestructive examination (NDE), testing er documentation are reviewed jointly by the requisitioner and Product Assurance to determine that supplier's detailed plans for manufacture and inspection are consistent with purchase order requirements.

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SECTION 6 INSTRUCTIONS, PROCEDURES, AND DRAWINGS 6.1 GENERAL d Activities affecting quality of NSD service's' are carried out in accordance with written instructions, procedures, and drawings. This policy forms the basis of a controlled uW disciplined way of working to minimize errors and control variables which can compromi,se quality and/or increase costs.

6.2 CONTROL METHODS Written procedures and/or drawings are prepared to cover work done within the NSD scope. These procedures and drawings govern such activities as installation, refueling, in-service inspection, and modifications; and they provide assurance that activities affecting quality are performed in proper sequence and under controlled conditions and n e independently verified for acceptability against documented quan'.itative and qualita-n tive acceptance criteria to demonstrate satisfactory accomplishment.

Quality requirements are contained in documents such as equipment specifications, corporate process and material test specifications,*'.

drawings, purchase orders, and technical procedures (which include a equipment test procedures, equipment preparation and maintenance , ' ,

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NSD is responsible for the adequacy of drawings or procedures which -

i control the division's service work. When inputs such as drawfngs or process parameters are provided by suppliers or interfacing Water Reactor Divisions, NSD assures that they have been appropriately verified. ,

i Controls over issuance, approval, change,. and distribution of instructions, procedures, and drawings are covered under Section 7, Document Control.

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DOCUMENT CONTP.0L 7.1 GENERAL Activities which affect quality are governed by controlled documents ruch as equipment specifications, drawings, instructions, and procedures. NSD departments responsible for the preparation of these documents obtain review and approval by other NSDd 'epartments and/or other interfacing Water'Repctor Divisions in accordance with established procedures.

Comments are resolved prior to' approval and implementation of the documents. bocungntrevisionsarereviewedandapprovedbythesame organizations which pe(formed the c'riginal review and approval. For procedures used on field services, changes are made under controlled conditions, 'ar.d the original orgnization review may be made after change implementation.

7.2 REVIEW 0F CONTRACT AGREEMENT

• Proposals for contracts and contracts with customers are reviewed to identify quality requirements, and plans are initiated at the earliest stage so contract requirements will be met. Necessary inspection methods, inspection equipment, process control and surveillance plans are prepared to be ready when needed.

7.3 DRAWING AND SPECIFICATION CONTROL The release and distribution of approved drawings (except engineering sketches) and equipment specifications is controlled by a WRD system.

Drawings and equipment specifications are issued to central control groups from which distributions are made. Approved drawings are

... microfilmed and distributed to NSD satellite files. Since more than one 7 revision to a drawing may be applicable to dlfferent plants, a

.N ^ ~ computerized drawing contfo! system defines applicability. When a new or revised drawing is sent to the central control group, it is accompanied by an applicability form which is the input to the computer system.

( Orawing lists are issued to all satellite files and project offices

, quarterly, w'th p3rtial chancis lists issued more frequently. The

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/3 1 o procedure for drawing control requires pdrsonnel to determine applic-Q ability of a drawing by referral to the drawing lists. When it is t ' determined that drawings and specifications no longer have applicability at active work sites, copies are removed from workplace areas and destroyed.

Engineering sketches used for development test items, emergency service tooling, and noncritical plant applications are issued, controlled, and

, distributed in accordance with NSD procedures which require reviews and approvals.

Material's and Process Specifications are handled in a manner similar to equipment specifications except their review, approval, and distribution is controlled by the appropriate engineering group.

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7.4 PROCEOURES AND INSTRUCTIONS CONTROL Thv NSD Operating Manual and the Product Assurance Manual contain procedures describing review, approval, distribution, and revision of the other procedures contained within. Manuals are serialized and assigned to specific individuals or groups. The preparation of new or revised operating procedures is controlled by Product Assuranca. A dated table of contents giving procedure revision numbers is provided with each distribution of new and revised procedures made to each person or group assigned a manual; and manual holders are responsible for updating their manuals.

The control of department procedures and instructions is provided by master lists maintained under the responsibility of the department manager.

Technical procedures, which include equipment test procedures, equipment and process qualification procedures, equipment preparation and maintenance procedures, and field service procedures, are issued and controlled by the responsible department in accordance with division procedures. Review and approval by NSD Product Assurance is mandatory.

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Product Assurance review encompasses comparison to applicable contract and standard requirements, and explicit review for acceptance criteria, inspectability, and definition of inspection witness points for verification and certification actions. Product Assurance approved actions oa procedures and procedure changes are entered onto a log to provide a means for verification of procedure review, concurrence and release. Review by other NSD departments or other Water Reactor Divisions is required when the procedure contains technical matters affecting another discipline or involves actions within the assigned responsibilities of other departments / divisions. Technical procedure revisions are maintained under control by logs or listings maintained by the issuing department. Field changes to technicii procedures are categorized and controlled in accordance with division operating procedures which designate authorizations required for each category of change. Field changes are documented in the field as they are made, as part of the field service documentation package.

To assure that correct documents provide the basis for technical advice given to customers at installation sites, copies of documents which have been formally reviewed and transmitted to the customer or his agent are n;aintained in the official site office files. Copies of drawings, specifications, and equipment manuals not formally transmitted, but which are useful to provide additional supporting detail are kept separate from official site files.

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SECTION 8 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES 8.1 GENERAL This section describes the measures of the NSD Quality Assurance Program that assure items and services purchased by NSD conform to contractual, regulatory, and Westinghouse quality requirements.

I These measures include, as appropriate, source evaluation and selection, review of objective evidence of quality furnished by the supplier, inspection and audit at the source, and examination of the items upon delivery, and apply to procurements from Westinghouse Divisions as well as procurements from other suppliers. Product Assurance is responsible for planning and executing the actions necessary to assure that material, equipment, and services procured by NSD meet the specified requirements.

The quality supplier surveillance on renewal parts is normally delegated to NTD which also handles the actual procurement.

The provisions of this sectior, apply to procurement of material, equipoent, and services except for (a) standard off-the-shelf items (b) standard supplies or services of a non-complex nature, or considered non-critical with respect to quality of NSD services or equipment, (c) services of personnel where no special skills apply, and (d) development items which will not be used in providing custorrer services.

8.2 CONTROL OF SUPPLIERS 8.2.1 Pre-Award Surveys and Selection The suppliers of materials, equipment, and services for higher quality level items are evaluated prior to placement of a purchase order by personnel from Purchasing, the cognizant engineering groups, and Product Assurance if the supplier is not shown on the NSD Approved Cuppliers List, or on the Approved Suppliers List of another WRD organization.

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The evaluation includes considerations of historical quality performance data and survey reports to the extent these are applicable to the equipment or services being procured.

Deficiencies in the supplier's organization, systems, or procedures are resolved with the supplier's management prior to placing a purchase order, or actions are agreed upon which will lead to reso'lution before the deficient areas are involved in the procurement.

8.2.2 Supplier Surveillance Surveillance of suppliers is performed to obtain firsthand objective verification of compliance with specified requirements. The supplier is normally responsible for inspecting, testing, and otherwise controlling his product or services. The NSD representative assures that the supplier satisfactorily performs the inspections, tests, an:' other assurance / verification actions. Appropriate surveillance of suppliers during fabrication, inspection, testing, and shipment of equipment is planned in advance and is based on the requirements of the purchase order.

For complex equipment, ..lity surveillance planning is performed by the Produc, Assurance surveillance representative by (a) identifying those characteristics which are most important to quality and reliability, (b) noting specific supplier documents for review and points for witnessing, documentation, and acceptance of the equipment, and (c) providing for acceptance status indication by issued Quality Releases or other reports. Checklists for surveillance are prepared where needed, and special emphasis is placed on the aspects of manufacture and inspection that most directly affect the performance of the aquipment.

The frequency and scope of surveillance varies with the importance and complexity of the item or service, supplier performance, cost and schedule. For example, where cost and QA360/1Q8205 22

schedule requirements make rework or corrective action prohibitive or where supplier quality assurance capability warrants, more surveillance is provided and system audits are also performed in addition to the surveillance of product, processes, and documentation. This determination is made by Product Assurance in conjunction with input from the cognizant engineers.

During the visits the surveillance representative verifies that written instructions are kept current, and that information on supplier certificates is correct and based upon objective evidence. He also verifies that corrective action is imple-mented, where required, and that other necessary controls are effective. The representative informs the supplier in writing of the problems he discovers and obtains commitments to correct them. He brings these problems to the inimediate attention of the supplier's management and NSD management as required to obtain resolution. Surveillance activities, including supplier discrepancies and audit results, are documented by a trip renort issued to NSD management for each visit to a supplier.

For procurement involving design actions on the part of the supplier, the principal means of control is the requirement that suppliers submit drawings, specifications, and procedures to NSD for review or approval, as specified in procurement documents. Where appropriate, Product Assurance audits the supplier's design control system for adequacy.

l 8.2.3 Quality Release

( When the Product Assurance representative is satisfied that equipment meets purchase order requirements, he prepares a Quality Release form in accordance with a Product Assurance procedure and distributes copies to the supplier and cognizant Westinghouse personnel. Purchasing then notifies the supplier i

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that the equipment is released for shipment. The supplier forwards the Quality Release with the equipment to the destination specified by the purchase order.

The Quality Release is a certification document which provides for:

a. The specific identification of the procured item by purchase order number, appropriate item designation, and serial number,

b. Certification that the equipment meets requirements of the purchase order, drawings, and specifications.

c. Identification of any procurement requirements which may not have been met. These include requirements which have been deferred and that are to be accomplished at the sita, and dispositioned nonconformances to purchase order requirements. Approved Deviation Notices are listed on the Quality Release and copies attached to the Quality Release which accompanies the equipment when shipped.

8.2.4 Receiving Inspection Receiving inspecticn is performed on items as received.

Receiving inspection includes verifi::ation of receipt and conformance of supplier documents, item identity and freedom from shipping damage. Sampling methods are used, where applicable, to verify that item characteristics conform to requirements.

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O h SECTION 9 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS 9.1 GENERAL Procedures are established, where necessary, to identify materials, parts, and equipment to control the items used in services to nuclear power plants. Identification and co.itrol measures are applied to verify that items used for repairs and other plant services are made from specified materials and that thev conform to applicable drawings, specifications, or other technical requirements.

9.2 MANUFACTURING CONTROLS NSD requires suppliers to maintain a system of material control, which includes permanent markings or records traceable to materials, as required, to assure proper identification of materials, parts, and components and prevent misapplication. These requirements are specified by the cognizant engineer in the purchase documents by invoking Quality System Specifications O'CS-1, QCS-2 (Quality Control Specifications), QPR-3, QPR-4, or QPR-5 (Quality Program I

Requirements), or other material and parts control requirements as appropriate. The system includes elements for control of nonconforming items in accordance with Section 16.

9.3 SITE CONTROLS When materials, parts, and components become the responsibility of the plant owner, the owner is responsible for maintaining identification and control. When NSD has the responsibility for l

items at plant sites, as in performing plant services, NSD maintains identification and control in accordance with written procedures until the items are turned over to the plant owner or are removed from the plant site.

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SECTION 10 CONTROL OF SPECIAL PROCESSES 10.1 GENERAL NSD has established measures and procedures for maintaining control of special processes and equipment relating to supplied equipment and services. These means include the qualification of procedures, equipment, and personnel for processes such as welding, inspection, nondestructive examination, and other specially developed processes.

10.2 NSO PROCESSES, EQUIPMENT, AND PERSONNEL Requirements for control of special processes including the qualification of the process, equipment, and personnel are the responsibility of the cognizant NSD department. This responsibility includes the incorporation into technical specifications or procedures of requirements for qualifi-cation of special processes. NSD may also express this responsibility by explicit stipulation or reference to applicable codes and standards.

Written procedures are reviewed and concurred in by NSD Product Assurance. Where another Water Reactor Division originates a special process procedure, to be performed by NSD or by others under NSD technical direction, the cognizant NSD department and Product Assurance personnel review and comment on the adequacy of that procedure.

Concurrence of the cognizant NSD department and Product Assurance is required before the procedure is accepted by NSD.

Personnel performinq or interpreting results of nondestructive examina-tions are qualified and certified in accordance with SNT-TC-1A standards or others as applicable. Personnel responsible for performance of other special processes such as welding, in-service inspections, or repair operations at site operations are qualified for the prccess. Product Assurance releases special process test equipment and physical acceptance standards for shipment to field service sites, and audits, monitors, or inspects special processes at site operations to assure that the process is accomplished and controlled according to specified requirements.

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) Qualification status of procedures, processes, equipment, and personnel is documented and maintained by the responsible NSD department with review and concurrence by Product Assurance.

10.3 SUPPLIER CONTROL Requirements for control of special processes are specified to suppliers of material, equipment, and services in the procurement documents and implementation is verified in accordance with Section 8.0.

j Subcontractors using special processes at operating plant sites are I managed by applicable Product Line in accordance with the technical field service procedure approved by Product Assurance. Verification activities such as audits, monitoring, and inspection are the responsibility of Product Assurance.

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SECTION 11 INSPECTION 11.1 GENERAL Activities affecting quality of NSD products and services are inspected to verify conformance to applicable codes standards, instructions, drawings, specifications and contractual requirements. The primary responsibility for inspection rests with Product Assurance. The responsibility for inspection may be delegated to other Water Reactor Divisions, or to subcontractors, or to other NSD personnel. NSD Product Assurance is responsible for conducting sufficient surveillance and audit activities to assure that the delegated inspection activities are ef fective in verifying quality and that they are conducted by qualified personnel. The following criterion applies when other than Product Assurance personnel perform inspection work: Personnel performing verification activities must be qualified to perform the verifications, must be independent of those who perform the work, and must not report to the management directly responsible for performing the work.

Where it is clearly established that the customer is performing the work, O

under Westinghouse advisory services, as in FDR (Field Deficiency Report) repair or FCN (Field Change Notice) modifications, the customer has the responsibility for inspecting or verifying activities and completed work for compliance with specified requirements.

11.2 INSPECTION PLANNING Inspection of work performed by NSD is planned by Product Assurance.

Inspection plans are in the form of inspection procedures, instructions, checklists, or steps integrated into field work instructions as appropri-ate and includes inspection of modified or repaired items. The detail or depth of inspection by NSD varies with the complexity of equipment and/or operations, risks associated with crrors, and contractual requirements.

Inspection hold points or witness points are included in the inspection plans, service procedures, or in procurement documents on purchased items.

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Inspections are planned to provide early detection of unacceptable conditions (e.g. at the supplier's rather than at the plant site). Cost effectiveness and customer specified/ approved requirements are also considered in inspection planning.

11.3 INSPECTION AND SURVEILLANCE Product Assurance is responsible for conducting verification activities by inspection, surveillance, or audit, as appropriate, to assure that items and services conform to approved and documented procedures and requirements. This applies to preparations for site services at NSD headquarters locations as well as to the actual site service work. For field service work, the verification will consist of inspection, surveillance, or audit, in accordance with the inspection planning.

11.3.1 Site Service Activities The Product Assurance verification of site services provided by NSD is performed to determine compliance with technical field

.s service procedures, other applicable NSD procedures, and contract requirements. The inspection, surveillance, or audit effort typically encompasses the following:

a. Processes, process parameters, and tooling.

b. Receiving inspection and material traceability.

c. Material and tooling identification measures.

d. Personnel, equipment, and process qualification.

e. Special processes and NDE performance.

f. Instrument / equipment calibration and control.

g. Procurement actions for materials and services.

h. Nonconformance identification and control.

i. Shift log maintenance.

j. Procedure compliance.

k. Data, service results, documentation.

1. Documentation provided with service.

m. Satisfactory task completion and certification.

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11.4 INSERVICE INSPECTION Inservice Inspections are planned and performed in accordance with the provisions of Section XI of the ASME Boiler and Pressure Vessel Code.

The Inspection Service organization is responsible for this work, with reviews and audits of the work performed consistent with provisions stated throughout this Section (11), and further described in Appendix B.

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im SECTION 12 TEST CONTROL 12.1 GENERAL Testing required to demonstrate satisfactory performance of equipment and services is conducted in accordance with documented and controlled proce-dures. The following categories of testing are subject to this control:

a. Qualification Testing This applies to testing conducted to demonstrate the adequacy of a design for service equipment to perform in accordance with documented requirements. Qualification testing is conducted under conditions suitably simulating plant service environment. The qualification testing is completed prior to acceptance of the equipment or process for further procurement or implementing of the service.

b. Acceptance Testing U This applies to testing used to determine performance of an item prior to "in plant" use. This testing primarily applies to acceptance of items suppliec by vendors where the testing is specified in procurement documents or to testing conducted by NSD to verify that original or previously used equipment meets applicable specifications prior to use.

Testing of a developmental nature on service tooling (i.e., testing of design concepts or testing to select components or materials) is I

contrc11ed by Service Engineering through engineering follow and other methods appropriate to the particular test. The following sections are l not applicable to development testing unless the testing may be used to qualify or accept service equipment as may be the case in an emergency.

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o a NSD construction site personnel participate in equipment testing during plant preoperational and startup phases in an advisory capacity.

Guidance documents in the form of test procedures are provided to the customer describing Westinghouse recommended programs. The customer is responsible for preparation of the final test procedures and for control -

of the testing.

12.2 TEST PLANNING AND APPLICATION Service Engineering or Product Line may be responsible for testing to demonstrate satisfactory performance of a designed item or of a service process. For such tests, these groups establish planned test programs.

These programs are documented including written test procedures incorporating test requirements and acceptance criteria.

Requirements and acceptance criteria are stated by the organization responsible for the design of the item or process (in conformance wit' functional specification parameters) to establish a basis for determining acceptability of test results.

Procedures governing tests conducted by NSD include provisions for O

assuring that prerequisites for the given test have been met, that adequate instrumentation is available and used, and that necessary monitoring is performed. Prerequisites include such items as calibrated instrumentation, appropriate equipment, qualified personnel, condition of test equipment and the item to be tested, suitable environmental conditions, and provisions for data acquisition.

When tests are conducted by organizations other than NSD (e.g., NTD and Research and Development Labs), NSD prepares or approves the test prospectus. It is used by the testing organization to develop the test procedures which include the specified requirements. In such cases the test procedures are reviewed and approved by the NSD organization respon-sible for initiating the test. Product Assurance reviews and approves test procedures generated at NSD and at outside laboratories when such tests are used to qualify equipment or processes, or to accept equipment.

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( When the test is used to qualify equipment or tools to processes which will be used to modify or repair a customer's plant equipment, Product Assurance will approve the test procedure and will conduct surveillance of testing, including witness of specified steps of the test.

12.3 DOCUMENTATION OF TEST RESULTS Test results are documented and are evaluated by the Individuals or groups responsible for the design of the item under test. In critical or important tests such'as qualifications, independent review of test results may be conducted.

i Product Assurance reviews test documentation, including test results as appropriate, to assure that test requirements are being met and results are accurately documented. In qualification and acceptance testing, Product Assurance, with input from the cognizant engineer, reviews the test results against established criteria. Any deviations must be resolved with the cognizant engineer prior to Product Assurance release for further procurement or for plant services.

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SECTION 13 CONTROL OF MEASURING AND TEST EQUIPMENT 13.1 GENERAL Examination, meisuring, and test equipment used in activities affecting quality is controlled and calibrated at suitable intervals to assure that test and inspection results are accurate. Calibration is traceable to nationally recognized standards and documented according to written procedures thst specify conditions such as frequency, method of calibration, records to be maintained, and identification of equipment.

If other than national standards are used, the basis for calibration is documented.

13.2 SUPPLIER CONTROL Control of measuring and test equipment (e.g., micrometers, thread gages, vernier calipers, voltmeters, temperature recorders, etc.) is imposed upon suppliers of NSD through procurement documents. Monitoring of supplier's calibration and control systems is performed during surveillance activities and audits.

13.3 MEASURING AND TEST EQUIPMENT CONTROL The responsibility for the control of measuring and test equipment is placed upon the departments responsible for using and maintaining the equipment. Written calibration procedures are maintained by the individual departments. Personnel responsible for supervision or accomplishment of measuring and test activities at facility and site operations are required to verify performance with properly calibrated equipment in accordance with established procedures. Product Assurance audits or monitors the adequacy of and conformance to the procedures in order to provide the necessary independence and objectivity. Where measuring and test equipment is found to be out of control or out of calibration, items which have been measured or tested since the last known calibration are considered suspect and are placed under special controls until resolution is obtained. During preparation for specific field services measuring and test equipment used in providing the service is reviewed and released by Product Assurance prior to shipment to the .

plant site.

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SECTION 14 HANDLING, STORAGE, AND SHIPPING 14.1 GENERAL Handling, storage, and shipping activities for which NSO is responsible are conducted in accordance with documented instructions, procedures, and drawings as necessary to prevent damage and deterioration of items.

These instructions are developed by the responsible engineer or by suppliers where specified in the procurement documents. Conformance with the requirements is verified by Product Assurance.

14.2 PURCHASED EQUIPMENT In preparing the procurement documents, the cognizant engineer is responsible for including instructions or requirements for cleaning, coating, protective packaging, shipping, and storage of the items purchased. The amount of detail of the specified requirements is dependent on the sensitivity of the item to the environment during fabrication, shipping, and subsequent storage prior to use. General s controls are specified on complex items or rujor procurements by invoking the Quality Systems Specifications QCS-1, QCS-2, QPR-3, QPR-4 or QPR-5 and Administrative Specifications for Procurement as appropriate. The methods used by the supplier for packaging, handling, shipping, and storage are reviewed by the cognizant engineer. The supplier's procedures for control of the handling, storage, and shipping functions are evaluated during pre-award surveys and monitored during source surveillance as mentioned in Section 8.

14.3 COMPONENT HANDLING EQUIPMENT NSD provides equipment for the handling of certain NSSS components. The provisions of this QAPP apply to this equipment.

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SECTION 15 INSPECTION, TEST, AND OPERATING STATUS 15.1 GENERAL In addition to requirements for controlling identification and trace-ability of items as described in Section 9, NSD provides for maintenance of inspection, test, and operating status of items and services provided for use in nuclear power plants or in services. This control provides assurance that the acceptability status of items and services is known throughout manufacturing, installation, and operation phases, as appropriate, so that the items and services used at the nuclear site are complete and acceptable in accordance with quality requirements.

15.2 PROCURED EQUIPMENT AND MATERIAL NSD procurement quality requirements specify that suppliers shall establish procedures to indicate the inspection, test, and operating status of items being supplied.

The supplier's procedures and implementation are reviewed for adequacy during supplier's selection and are monitored for compliance during the surveillance activities.

15.3 SITE OPERATIONS Services performed at plant sites by NSD are carried out in accordance with written procedures which include requirements for appropriate inspections and tests. These procedures typically include sign-offs to indicate inspection, test, and operating status of the operations and means to prevent inadvertent operations or provide any necessary restric-tions in the use of service tooling. Examples of such field operations are modifications, repairs, refuelings, and inspection services.

NSD Product Assurance reviews the procedures to assure provisions are included for inspection, test, and operating status maintenance.

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I i Product Assurance monitors or audits the operations for compliance,

! including review of documents provided to customers which indicates the results and acceptability of service's. Product Assurance also implements

! those inspection status documenting requirements which are specified in f the technical procedures.

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SECTION 16 NONCONFORMING ITEMS 16.1 GENERAL Equipment, materials, or service activities which do not conform to documented requirements are identified and segregated (if feasible) to prevent use of these items or further activities which could be compromised by the nonconformance. Product Assurance is responsible for providing and assuring implementation of documented procedures and methods to assure positive identification of nonconforming products and services. Where work is performed for NSD by suppliers or other Water Reactor Divisions, Product Assurance has the responsibility to assure that equivalent policies and procedures are in place and implemented.

16.2 INITIATION, CONTROL, AND DISP 0SITION OF NONCONFORMANCES Product Assurance is responsible for providing procedures for the processing and disposition of nonconformances. These procedures require that nonconformances are documented on appropriate forms. The forms are Deviation Notices (DN's), Field Deficiency Reports (FDR's), and Nonconformance Reports (NR's).

Deviation Notices are used for reporting nonconformances discovered at NSD suppliers. Dispositions require the approval of the engineering organization responsible for the design or specification violated and concurrence by Product Assurance. Concurrence by Product Assurance signifies that the appropriate engineering organization disposition has been obtained and that any reinspections or special controls required to correct the nonconformance are specified.

Construction site personnel use Field Deficiency Reports for reporting no'n-conformar,ces at construction plant sites for equipment supplied by Water Reactor Divisions. Disposition is provided by the engineering departments of the supplying Water Reactor Division. Disposition information is provided to the customar by W site personnel in accordance with agreed-upon methods for specific sites. Product O

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/^T V Assurance conducts formal audits and reviews of each plant site office during the course of construction and startup activities to assure that nonconformances are properly documented by FDR and that the FDRs are i

handled in accordance with procedures.

Nonconformance Reports are internal NSD documents used to identify, disposition, and follow-t.p corrective actions for nonconformances within NSD or during plant service activities for which NSD is responsible. If the nonconformance involves NSSS equipment design, concurrence of the WRD division responsible for the design is obtained. Product Assurance reviews and concurs in the disposition of each Nonconformance Report, and where cumulative history shows trends indicative of the existance of basic problems, initiates corrective action.

16.3 REINSPECTION Nonconformances involving " rework" or " repair" require reinspection to verify conformance. Where rework to specifications is required, Product Assurance provides inspection instructions or assures that others provide d necessary inspection instructions. Inspection results are documented and related to the original nonconformance. Product Assurance determines acceptability of the inspection results prior to close out of the action.

16.4 DOCUMENTATION OF NONCONFORMANCES Records of nonconformances are maintained with the inspection records for the item involved to document the as-built condition. Product Assurance is responsible for verifying the existence of and adequacy of these records.

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SECTION 17 CORRECTIVE ACTION 17.1 GENERAL In addition to the immediate action required to disposition nonconformances, covered in Section 16, corrective actions to preclude recurrence of significant problems are required. Product Assurance is responsible for identifying areas requiring corrective action based on evaluation of problems identified from such sources as nonconformances, failures, malfunctions, and other deviations from requirements for which NSD is responsible. Problems are also identified from audit, inspection, and surveillance activities. Corrective action emphasizes determining and correcting of the underlying causes of the problem, especially for any recurring conditions, as a major element in reducing costs and improving reliability. Product Assurance has the authority to control work. until effective corrective action has been taken in situations where it judges that existing conditions may compromise the quality of NSD work.

17.2 CORRECTIVE ACTION PROGRAM The need for corrective action is formally con.municated to the organization responsible and to appropriate management. Corrective action needed in interfacing divisions is addressed to that division's Product Assurance management.

The co:rective action program, which is described by written procedures, requires the following:

a. Description of the problem (and cause if known).

b. Recommended corrective action.

c. Assignment of responsibility for corrective action.

d. Response by organization responsible for corrective action.

e. Periodic evaluation of the status and effectiveness of corrective action.

f. Monthly summary reports to NSD management as appropriate on the status and effectiveness of corrective action.

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Where immediate corrective action is judged to be necessary by the _

l cognizant service group or Product Assurance to prevent conditions 1 significantly adverse to quality, safety, or reliability, further operations may be placed on " hold" or conducted under specially l controlled conditions until corrective action is completed and verified i to be effective.  ;

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SECTION 18 QUALITY ASSURANCE RECORDS 18.1 GENERAL This section describes the NSD Quality Assurance program elements that assure generation and retention of required records as defined by the guidelines of ANSI N45.2.9. These records include the results of inspections, tests, audits, surveillance, material analyses, design reviews, and qualifications as appropriate.

Within NSD, written procedures ensure that adequate Quality Assurance records are prepared and maintained for functions within the NSD scope of activity. These activities include design, procurement, modification and repair of equipment, refueling, in-service inspection, etc.

The cognizant engineer performing design or planning an activity is responsible to include record requirements in the specifications, procurement documents, and instructions or procedures generated. Proce-dure review by Product Assurance includes review for record requirements.

18.2 MANUFACTURING AND SERVICE QUALITY RECORDS NSD requires its suppliers to maintain a records system that controls (a) the generation, (b) traceability to items, and (c) maintenance of records essential to demonstrating product / service quality. These requirements are specified by the NSD cognizant engineer in the purchase documents by invoking the Purchasing Department'NSD Administrative Specification or Quality Systems Specifications QCS-1, QCS-2, QPR-3, QPR-4, or QPR-5 as appropriate. Records are reviewed by NSD Quality Assurance personnel .t

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the supplier location in conjunction with activities described in Section 8. Copies of the records specified to be forwarded to Westinghouse in the purchase documents are reviewed and filed.

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NSD has established descriptions of standard data packages, including Quality Assurance records, which are provided to the customer as part of NSD services. The content of the typical data package is shown in Appendix 0.

18.3 SITE RECORDS Records are generated at the plant sites for services provided by NSD affecting quality in accordance with procedures and instructices for the i work. The records are audited by Product Assurance. Copies of records are provided to the plant owner for retention as required by contract.

18.4 RECORDS MANAGEMENT Product Assurance records are maintained in accordance with written procedures. Quality related. records generated by other NSD departments, including those at site offices are maintained in designated files in accordance with written procedures. Retirement to the corporate record repository to meet required retention and retrieval conditions is also defined by written procedures and Records Flow Schedules.

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i O SECTION 19 ,

AUDITS 19.1 GENERAL An audit program is maintained and implemented to verify adequacy of systems and procedures and compliance to such systems and procedures.

NSD conducts Quality Assurance audits of suocontractors, other Water Reactor Divisions performing work for which NSD has the prime responsibility, and internal divisional audits. These audits cover activities and areas which come under the provisions of this QAPP and the implementing procedures. The audits discussed herein may be supplemented by additional audits of NSD by other Westinghouse personnel. Additional audits fall into two categories: including audits by the NES Quality Assurance Committee:

19.1.1 NES Quality Assurance Audits The Westinghouse NES Quality Assurance Committee, which is made up of Quality Assurance managers of the NES Divisions, conducts audits of NSD and the other NES Divisions. The NES Quality Assurance Committee annually reviews the need for an audit.

The audits are formally planned, conducted, and reported to the NSD General Manager and the Vice President and General Manager of WRD.

Follow-up and reporting on corrective action is required.

Procedures for condt.cting and following up these audits are documented in the NES Quality Assurance Committee Manual.

19.2 AUDIT PLANNING Product Assurance is responsible for scheduling and planning Quality Assurance audits of NSD, its subcontractors, and other Water Reactor Divisions performing work for NSD. It has the responsibility to plan and conduct audits in those areas affecting the quality of NSD work. An overall QA program audit schedule is maintained by product Assurance to assure that activities affecting quality are, audited periodically. This O

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e schedule is up-dated during the year as necess ry, based on evidence from surveillance activities, customer audits, results of services, etc.

Audits are deleted, added, or audit dates revised based on management judgement. The schedules provide for re-audits when determined to be necessary to verify action taken to correct deficiencies.

AuditteamsconsistofpersonnIlwithappropriatetrainingandexperience 3 to evaluate the adequacy and implementation of policies, systems, and .,

procedures, and to evaluate products and services as appropriate. In '

order to preserve objectivity in the audits, teams include members having no direct responsibility for the area or activity being audited. ' ,

Audit plans are developed and documented in accordance with written procedures, including identification of team leaders, functional areas to be audited, schedule, and chacklists. Prior audit results of the area being audited are considered in the,sudit' plans to assure that previously -

deficient areas are rechecked. Likewise, consideration is given to y experience since the last audit, particularly in regard to deficiencies I

s and nonconformances.

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, 19.3 AUDITOR TRAINING Auditors receive training through seminars and lectures on audit standards and practices, by accompanying experienced auditors on visits to suppliers, and on the job practical Applicationi (developing checklists, conducting internal audits, preparing audit reports, responding to audit reports, and following up on corrective &ctions) with senior personnel. Training in such items as regulatory QA requirements, ANSI standards, and acceptable QA program practices is conducted. This training provides auditors with the knowledge to evaluate adequacy of systems and procedures as well as compliance to them.

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I 19.4 AUDIT SCOPE ,,"

(uditsareconductedtoevaluatecontrolofadtivitiesaffectingquality in a specific work area. Thepurpose}fstodetermir.e.thatthemethods, procedures, system or instructions.u:ed are adequate to control the quality of the product or service anc to determine that procedures are being complied witn. ,

Audits cover a specific organizat:onal unit or work area, including other divisions pernrming work for wMeh NSD is responsible.

Audits may incluca eva7aation of products and special processes to assure they conform to specified irawings, f specifications, codes, and standards.

These evaluations include, as appropriate, reinspection of products or examination of records such as inspec' tion reports, X-ray film, etc., to verify product quality. _ T'1ey also include evaluations of personnel qualifications and procedures used in special processes such as nondestructive testing and weldiiig.

19.5 AUDIT f.EPORTING AND CORRECTIVE ACTION ,

With4r. thirty days following An audit, the assigned Product Assurance representative prepares and distributes a written report of the audit.

The report may be in letter form. but must contain the following information as a minimum:

a. Description of the audit _ team, the audit perform (d, and the criteria used.

b. The audit findings.

c. The audit conclusions and where appropriate recommended corrective actions for deficiencie's found.

d. Any agreements made with' the audited organization to implement correctiva actione including a time schedule for such implementation.

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( ) The reports require that the audited organizations reply within thirty days following receipt of the audit report, identifying planned corrective actions for deficiencies and a schedule for implementing the corrective actions.

Product Assurance follow-up of the corrective actions is accomplished by an assigned internal audit coordinator and, as deemed necessary, by means of a Corrective Action Status Report and by re-audit of areas to determine that the corrective actions have been achieved. The Corrective Action Status Reports are distributed to the NSD General Manager and his staff. Product Assurance has the responsibility to determine that an indicated corrective action is effectively implemented.

19.6 EXTERNAL AUDITS OF NSD Product Assurance is responsible for coorcinating customer and/or regula-tory agency audits of NSD and acts as the primary interface with customer audit teams. Product Assurance is also responsible for assuring that responses to customer audits are transmitted within thirty days of audit O report receipt and for following up on any indicated corrective action.

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REFERENCES

1) WCAP 8370 " Water Reactor Divisions Quality Assurance Plan".

2) WCAP 7800 " Nuclear Fuel Division Quality Assorance Program Plan".

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APPENDIX A QUALITY ASSURANCE PROGRAM PROCEDURES

• 10CFR50 Appendix 8 ANSI N45.2 Criterib Section Imolementina Policy-Procedures 1 3 Division Charter ORGANIZATION Product Assurance Depa rtment Cha rter

• Service Operations Department Cha rter Service Engineering Department Charter Steam Cenerator Services Department Cha rter Division Controller Charter Availability improvement Department Charter 11 2 Quality Assurance Policy QUALITY ASSURANCE PROGRAM Training NSD Personnel in the Use of Policies, Procedures, or instructions Affecting Quality interface Agreements with Interact ing WRD's -

4 Product Assurance Department Procedures Program lli 4 Design Change Control i DESIGN CONTROL Drawing Control System l Control of Design Calculations Design Review Design Verification IV 5 Prepa.ation and Review of Purchase Requisitions PROCUREMENT DOCUMENT CONTROL and Change Notices Supplier Surveys, Evaluation, and Approval V 6 Divisional Operating Pnlicy-Procedure Program INSTRUCTIONS, PROCEDURES, Product Assurance Department Procedures Program AND DRAWINGS Functional Specification Control Preparation of Procedures for Service Activities VI 7 Design Change Control DOCUMENT CONTROL Record Control Drawing Control System Processing Field Change Notices within NSD Control of Fie ld Service Activities

• The procedures are listed by subJ act, for eEch of the 18 criteria, in approximate sequential order with their placement in the QA program manua ls. The listing provides a representative description of the procedures in use at any point in time; the procedures are constantly being evaluated and improved, with additions and deletions as required as part of the maintenance of the Quality Assurance program.

1 QA36Q/1Q8204 A-1

APPENDlX A (Cantinuid)

QUALITY ASSURANCE PROGRAM PROCEDURES 10CFR50 Appendix B ANSI N45.2 Criteria Section Implementina Poliev-Procedures Vil 8 Renewal Parts Procurement CONTROL OF PURCHASED MATERIAL, Supplier Surveillance EQUIPMENT, AND SERVICES Customer Surveillance of NSO Suppliers Control of Nonconforming Material Vill 9 Identification and Control or Material, Pa rt s, IDENTiflCATION AND CONTROL OF MATERIAL, and Components PARTS, AND COMPONENTS Ma te ria l Control IX 10 Qualification of Special Processes CONTROL OF SPECIAL PROCESSES Maintenance of Personnel Qualification Records - Nondestructive Examination Review of NDE Procedures Qualification of Personnel for Specia l Processes Other than NDE X 11 anspection and Test Control INSPECTION Control of Field Service Activities XI 12 Preparation of Procedures for Testing Equipment TEST CONTROL Inspection and Test Control Xil 13 Calibration and Control or Measuring and Test CONTROL OF PEASURING AND TEST EQUIPMENT Equipment Xill 14 Handling, Storage, and Shipping Policy HANDLING, STORAGE, AND SHIPPING XIV 15 Inspection, Test, and operating Status INSPECTION, TEST, AND OPERATING STATUS QA36Q/1Q8205 A-2 O O O -

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1 i APPENDIX A (Continued)

QUAlllY ASSURANCE PROCRAM PROCEDURES 10CFR50 Appendix 6 ANSI M45.2 i Criteria Section leolementino Policy-Procedures XV 16 Reporting Significant Deficiencies NONCONFORMING MATERIALS, PARTS, I nt ra-D ivi s iona l Field Deficiency Reporting OR COMPONENTS Procedure Operating Plant Deficiency Report Cont ro l of Nonconformances nn NSD Material and Equipment at Plant Sites Disposition of Site Quality Documentation Deficiencies Control of Nonconforming Material XVI 17 Operating Plant Deficiency Reporting CORRECTIVE ACTION Internal Corrective Action Corrective Actiort Folicy 4

3 4 XVil 18 Records Management 2 QUALITY ASSURANCE RECORDS Maintenance of Personnel Qualification Records -

Nondestructive Examination l

, XVill 19 Audit Policy i AUDITS External Audits of NSD Internal Audits of NSD

! Quality Assurance Audits of Suppliers i

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1. 4 O APPENDIX B NUCLEAR SERVICE DIVISION QUALITY ASSURANCE PRGGRAM ORGANIZATION NUCLEAR SERVICE DIVISION GENERAL MANAGER STEAM GENERATOR SERVICE SERVICE OPERATIONS AVAILABILITY SERVICES ENGINEERING DEPARTMENT IMPROVEMENT DEPARTMENT DEPARTMENT CEPARTENT I

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O PRODUCT CONTROLLER l ASSURANCE DEPARTMENT '

, DEPARTMENT PURCHASING DRAFTING DEPARTMENT DEPARTMENT e

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APPENDIX B DESCRIPTION OF THE FUNCTIONS OF DEPARTMENTS WITHIN THE NUCLEAR SERVICE DIVISION Product Assurance Department The basic function of the Product Assurance Department is to assure the establishment of necessary NSD policies, procedures and controls to comply with Westinghouse, regulatory, customer and divisional policies and standards related to reliability, quality and safety of equipment and services. Product Assurance verifies implementation of policies, procedures and controls for NSD equipment and services. The department also provides inspection and surveillance services as well as other quality assurance services to utility customers.

There are five groups within NSD Product Assurance Department reporting to the Product Assurance Manager. These groups are Engineering Quality Assurance, Product Assurance Services, Operations Quality Assurance, Material Control and Information and Record Systems. The major functional responsibilities of these groups are described below.

The Engineering Quality Assurance Group 1) performs a quality engineering function for the desian and development of new service processes and equipment; 2) maintains N;D QA Program Manuals and division procedures, including interface agreements between Water Reactors Divisions; 3) coordinates the Internal Audit. Program; 4) maintains NDE qualifications for NSD personnel per requirements of SNT-TC-1A; 5) maintains a Corrective Action Program; 6) provides certification and training of personnel performing NDE examinations; 7) maintains a capability for service process and service equipment reliability analysis.

The Product Assurance Services Group 1) maintains a (A services product line;

2) provides quality assurance support to construction sites and personnel stationed at operating plants; 3) coordin ues customer audits; and 4) performs quality engineering functions for renewal parts service.

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O d The Operations Quality Assurance Group 1) provides quality assurance support of NSD services to operating plants; 2) responsible for the quality assurance work on NSD activities under ASME B&PV Code; 3) provides the QA input to NSD proposals; 4) reviews incoming orders; 5) control of procurement actions related to Field Services; 6) reviews and approves procedures for Field Services and for the Field Surveillance.

The Materials Control Group 1) performs evaluations of QA Programs of prospective vendors; 2) provides vendor surveillance, including release of equipment; 3) performs receipt inspection of equipment and raterials to be used in code work; 4) maintains proper identification and storage of code items; 5) releases material to be used at applicable sites.

The Information and Records Systems Group 1) coordination of QA training; 2) provide support for the Quality Circle Program; 3) responsible for receipt and maintenance of records packages generated during code work at various sites;

4) administer the divisional records management program.

(Q Service Operations Department The basic function of the Service Operations Department is to manage and execute Nuclear Service Division activities and services at utility plant sites for plants in operation and provide generic procedures for startup and advisory services for equipment testing and cther preoperational and startup activities. The department also provides mechanical and electrical services to customers during installation, startup and operational phases. They manage

, the NSD Waltz Mill ard Spartansburg Service Center activities, including functions of maintaining tools, equipment and trained crews of service personnel to execute services at operating plants. They also manage a renewal parts service for customers.

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l Steam Generator Service Department The basic function of the Steam Generator Services Department is to coordinate ,

the performance of NSD activities and services on steam generators of Nuclear Power Plants at the Utility Operating Site.

Service Engineering Department The function of the Service Engineering Department is to provide engineering and service tooling (processes and equipment) for the repair maintenance and service of NSSS and related equipment. In addition, the department is respon-sible for the field implementatica of major steam generator modifications and implementation of programs for major plant upgrading projects.

Control 1er's Department The basic function of the Controller's Department is to establish and manage a financial system that will be utilized by Division management for Division operations.

Availability Improvement Department The functions of the Availability Improvement Department include coordination with other WRD activities to take a lead role in improving customer communication; increasing Westinghouse involvement in outage planning and dealing with incipient licensing issues; and in working with customers to optimize methods of plant availability improvement.

Drafting The basic function of 701 support drafting is to provide drafting services for the Division.

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Purchasing l 1

j The purchasing department functions to provide all necessary interface actions required between Suppliers and NSD requisitioners in-procurement, expediting 2

and delivery of required products, materials and services.

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' C)

V APPENDIX C WESTINGHOUSE WATER REACTORS DIVISIONS ORGANIZATION CHART W POUER' IVSTE!!S ,

00!TA4Y NUCLEA't Efi[RGY SYSTEMS

. WATER REACTOR O! VISIONS es.q NUCLEAR C0tTE RCI AL titJCLE"*R STFATEGIC flUCLEAR fiUCLEAR W NtlCLEAR OPEPATIOf45 TECH:;0 LOGY OrERAllOris FUEL SERVICE INTERN U10';?.L DIVISIC?! DIVISIO'I Div!SID'I DIVISION DIVIS!C!! DIYlSIC*l3 Mote 1 ffUCLEAR ELECII'0- SPECIALIY C0tF0:4ENTS SIPATEGIC , l'ECHN!! CAL PETALS OlVISION PESOURCES DIVIS10ft DIVISION Note 1: The ftSD QA Program is applicable to the Operating Plant Service Grouo in W Nuclear Belgium unich functions as an ::SD Regional Service Grcup.

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0 cj t APPENDIX D QUALITY ASSURANCE RECORDS PROVIDED FOR SITE SERVICES The following types of documents shall be included in the site service documenation package, where they apply. (See Table 1 of this Appendix for typical application.)

1. Technical procedure.

2. Technical procedure modifications (such as Field Change Notices).

3. Statement of personnel qualifications for personnel performing special processes (including NDE).

4. Quality Releases or Certificates of Conformance for:

a. Materials and parts supplied by Westinghouse (for safety-related items).

b. Items consumed in service (weld rods, lubricants, dye penetrant materials). Material certificates may be used as an alternate to Quality Releases or Certificate of Conformance for these items.

v> 5. Calibration certificates for instruments, measuring tools, and standards.*

6. Lifting / handling equipment load test certificate.

7. NDE results.

8. Process data (e.g., equipment alignment data, number of process runs, location of service performed in reactor).

9. Nonconformance reports.

10. Owner's Data Report (e.g. , Form N-3, N-5, NIS-1, or Quality Release).

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• 0nly when specifically requested by customer, otherwise instruments bear calibration tags to demonstrate calibration.

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APPENDIX D TABLE 1 NSD SERVICE TYPICAL SERVICE DOCUMENTATION Fueling Service 1,2,3,4,5,6,8,9 Inspection Service 1, 2, 3, 4, 5, 7, 10 Repair Service, 1, 2, 3, 4, 5, 7, 8, 9, 10 Service Projects, and (Item 10 applies only where Service Engineering pressure-boundary components are provided.)

Startup Service 3, S Component Handling 4, 7 Installation Paid Services 1,2,3,4,5,8 Note: The numbers in this column are keyed to the documentation listing of Appendix D, page D-1.

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