ML20070R614

QA Program Description Changes,Reflecting Section 1.8 of FSAR

ML20070R614
Person / Time
Site:	Point Beach
Issue date:	03/26/1991
From:	WISCONSIN ELECTRIC POWER CO.
To:
Shared Package
ML20070R605	List: ML20070R603 ML20070R614
References
NUDOCS 9104010259
Download: ML20070R614 (28)

Text

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. l.8 OVAllTY ASSURANCE PROGRAM l

In accordar.cc with Paragraph 50.34 of 10 CFR 50 and 71.24 of 10 CFR 71, a Nuclear Quality Assurance Program description is provided by Wisconsin Electric Power Company (WE). This Program assures that the required manpower, procedtres, and management of Point Beach Nuclear Plant are directed toward satis'ying the Company objectives of providing safe and reliable structures, systems, and components; and complying with the provisions of 10 CFR 50, Appendix B " Quality Assurance Criteria for Nuclear Power Plants and fuel Reprocessing Plants"; 10 CFR 71, Subpart H " Quality Assurance for Packaging and Transportation of Radioactive Material"; and the applicable Sections of the ASME Boller and Pressure Vessel Code. This description is structured in accordance with the 18 criteria of Appendix B4 The following describes the quality assurance program established and imposed by the Company for application to the functional aspects of structures, systems, components, including the design, purchasing, construction, and fabrication, handling, storage, shipping, cleaning, installation, erection, int,oec tion, testing, operation, maintenance, refueling, repair, and modification of equipment considered significant to safety by the Company.

These structures, systems, and components may be classified as safety-related in that they prevent or mitigate the consequences of postulated accidents.

Others, as in the case of radioactive material packaging and fire protection, may be classified as QA-scope in that they could contribute to causing undue risk tc the health and safety of the public or loss of services should they fail or malfunction. Structures, systems, and components not classified as safety-related or QA-scope items are controlled as necessary to provide assurance of quality commensurate with the importance of the function (s) to be performed.

The principal objectives of the quality assurance program and the key functions and elements which it contains are not expected to change. However, circumstances may make advisable changes in the organization or -in the implementing detail necessary, and such changes will be made in accordance with established procedures. Changes in the quality assurance program description will also be submitted to the NRC as required by 10 CFR 50.54.

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4 The Point Beach Nuclear Plant Quality Assurance Program commits to the I guidance provided in ANSI N18.7-1976, except as specifically noted. Where exceptions are noted in the text of this section, the PBNP alternative system-is discussed. Commitment tn ANSI N18.7-1976 includes either complete or partial commitment to the following additional standards  ;

ANSI N18.1-1971 Selection _ and Training of Nuclear Power Plant i Personnel 1 ANSI N18.17-1973 Industrial Security for Nuclear Power Plants 3

ANSI N45.2.1-1973 Cleaning of fluid Systems and Associated Components

for Nuclear Power Plants.

ANSI N45.2.2-1972 Packaging, Shipping, Receiving, Storage and Handling of items for Nuclear Power Plants (During" the-Construction Phase)

ANSI N45.2.3-1973 Housekeeping During the Construction Phase of Nuclear Power Plants ANSI N45.2.4-1972 Installation, inspection, and Testing Requirements for instrumentation and_ Electric Equipment During the Construction of Nuclear Power Generating Stations ANSI N45.2.5-1974 Supplementary Quality Assurance _ Requirements for.

installation, inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants.

ANSI N45.2.6-1973 Qualification of Inspection, Examination, and Testing Personnel for the Construction Phase of Nuclear Power l Plants l

ANSI N45.2.8-1975 Supplementary Quality Assurance Requirements _ for Installation, 'Inspecti_on, and. Testing of Mechanical-Equipment and System 2 for the Construction Phase of Nuclear Power Plants-ANSI N45.2.9-1974 Requirements for Collection Storage, and Maintenance of Quality Assurance Records for Nuclear' Power Plants-ANSI N45.2.10-1973 Quality Assurance Terms and Definitions ANSI N45.2.ll-1974 Quality Assurance Requirements' for the Design of-Nuclear Power Plants ANSI N45.2.12, Requirements for Auditing of- Quality Assurme' .

Draft 4, Rev.2 Programs for Nuclear Power Plants 4

1.8-2 March 1991-

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ANSI N45.2.13-1976 Qualityy Assurance Requirements for- Control of l Procurement Items and Services for Nuclear Power Plants

! ANSI N45.2.23-1978 Qualification of Quality Assurance Program Audit Personnel For Nuclear Power Plants l ANSI N101.4-1972 Quality Assurance for Protective Coatings Applied.to Nuclear Facilities To the extent required by ANSI N18.7-1976 as hereinafter specifically. noted, Table _l.8-1 provides further .

PBNP hereby commits to the above standards.

! information regarding commitments to regulatory guides- and related standards.

1.8.1 ORGANIZATION .

l The authorities and responsibilities- of persons and organizations performing quality related activities are established, assigned, and documented in a formal system. Quality assurance and quality control' functions:are performed l by Company organizations (including .both on-site and off-site personnel)

except when the scope of specific projects dictate- the need _to ' engage contractors to perform specific services.or as otherwise-noted. ,

Those persons and organizations assigned such functions are given appropriate and sufficient authority- and organizational freedom to identify quality.

1 problems; veri fy implementation of the solutions; and' prevent further

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processing, delivery, installation, or use of nonconforming items until proper dispositioning has occurred.

- - The organizational structure and functional responsibility 1 assignments are.

.such that: (1) _ attainment of quality objectives is ' accomplished by-individuals. ,

assigned responsibility for. activities affecting q'uality or performing work to speci ficat ions, (2) audits verifying conformance to established quality requiremt.nts: are accomplished by those who. do not- have direct responsibility- t

- for performing Lthe work being verified, and (3) personnel in key quality:

assurance functions have -direct access to' responible ; management.

. The l education and experience: required-of individuals assigned to QA positions is dochwnted and = approved by management.

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, The operating organization is reflected in Figure 15.6.2-2 of the Technical Specifications. The organization for quality assurance is reflected in j Figures 1.8-1, 1.8-2, and 1.8-3. The Vice President-Nuclear Power Department, i who reports directly to the President - Wisconsin Electric Power Company, has been delegated the authority by the President to establish quality assurance policies, goals, and objectives as applicable to the Point Beach Nuclear Plant and the Nuclear Power Department although the President retains ultimate responsibility.

Manaaer - Nuclear Operations The Manager-Nuclear Operations is the senior company representative at the l plant facility and, as such, is in direct day-to-day control of all normal plant administration and technical operations, in matters related to quality assurance, the Manager remains cognizant through direct involvement and through input from veious sources including the Site Quality Assurance Group.

Manaaer - Ouality Assurance The Manager - Quality Assurance as the head of the Quality Assurance Sectinn reports to the Vice President - Nuclear Power Department and has responsibility for both " headquarters" quality assurance functions and various quality assurance activities at the site. The QA Section has staff located both in the corporate office and at the plant. The QA Section is divided into three groups (see Figure 1.8-3) with primary responsibilitiet summarized as follows:

Site Ouality Assurance Group

1. Perform quality assurance reviews of maintenance and modification documents. In regard to modifications this includes scoping for QA applicability of work to be performed.

2. Perform reviews of all NPD generated procurement documents. These reviews include scoping .for QA applicability and establishment of appropriate quality assurance requirements.

3. Verify conformance of received items to purchase document requirements through various activities including review of- documentary evidence of quality prior to release of the items (Section 1.8.7).

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4. Monitor performance of in-plant contractors through surveillances, s

. 5. Provido primary interface between plant groups and other department i

groups in matters related to quality assurance, j 6. Report to the Manager on matters involving quality assurance.

7. Assist plant groups in interpreting quality related codes, standards _ and l procedures.

i 8. Provide guidance and direction as necessary to in plant groups in regard to conformance to -NPD QA policies and procedures and performance of quality related functions, e.g. records administration, quality control.

. Quality Assurance Division

l. Implement the internal audit program to verify compliance to established quality assurance program requirements and satisfactory performance of quality activities. This includes audits of in-plant groups as well as off-site company organizations performing quality-related activities for-Point Beach. It also includes audits of the Technical Specifications which are performed under the cognizance of the Off-Site Review Committee. I

2. Perform quality assurance evaluations, audits, and surveys of vendors and contractors commensurate with the importance, complexity, and quality of the product or services provided.

3. Maintain lists of qualified suppliers including periodic review -of supplier performance. ,

4. Provide support to Point Beach for source verification of procured items.

5. Provide quality support to Point Beach for major projects under the scope ,

of the WE QA program.

6. Perform periodic surveillances of day-to-day. plant activities.

0A Technical Services /0A Administration

1. Maintain and control' issuance - of . quality assurance instructiont- and procedures manuals including the Nuclear -Power Department QA Policy Manual, Nuclear Power Department: QA Procedures Manual, and the QA Section:

Instructions Manual.

2. Coordinate and' perform QA indoctrination and training, as applicable. _-

3. Provide 111mited support to Point . Beach ' for nondestructive examination-services related to/ inservice inspection activities.--

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4. Perform tracking and trending of QAS internally identified deficiencies.

Tracking includes monitoring of open items and notifying appropriate management when items become delinquent.

Off-Site Review Committee The Of f-Si t e Review Committee (0SRC) is established in accordance with  ;

Technical Specifications, Section 15.6.5.2. The OSRC selectively reviews designated activit',es involving the operation of Point Beach Nuclear Plant including Technical Specification compliance. The committee's specified duties and functions are described in the PBNP Technical Specifications, Section 15.6.5.2.1.

In addition to the above, the OSRC is also tasked with the responsibility of assessing the adequacy and effectiveness of the Nuclear Power Department (NPD)

Quality Assurance Program. This is done in concert with their review functions as described above in addition to review of NPD QA policies, procedures and practices. Assessment of the program is also achieved through other means such as initiation of periodic audits.

1.8.2 QUAL.ITY ASSURANCE PROGRAM A quality assurance program is established and implemented in accordance with written policies, procedures, and instructions which comply with the requirements of 10 CFR 50 Appendix B and 10 CFR 71, Subpart H. The program is also applied to activities such as fire protection to a degree commensurate with Wisconsin Electric commitments. Specific QA Program applicability to fire protection and radioactive material packaging is defined in Tables 1.8-2 and 1.8-3, respectively. The Nuclear Power Department Quality Assurance Program is set forth in the NPD QA Policy Manual, the NPD QA Procedures Manual, the Nuclear Services (NS) Administration Manual, the QAS Instructions manual, and the PBNP Administrative Control Policies and Procedures Manual.

Control of the above manuals is as follows:

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1. Distribution and maintenance of the " Nuclear Power Department Ouality Assurance Policy Manual" and revisions thereto are controlled by the Quality Assurance Section. The policies in this manual are approved by I the Vice President - Nuclear Power Department, 1.8-6 March 1991 l

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2. Distribution and maintenance of the " Nuclear Power Department Quality  ;

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Assurance Procedures Manual" and revisions thereto are controlled by the l Quality Assurance Section. The manual procedures and subsequent i revisions are approved by the designated section manager within the  !

Nuclear Power Department assigned primary responsibility for the Quality i Procedures. l t

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3. Distribution and maintenance of the "PBNP Administrative Control Policies  ;

& Procedures Manual" and revisions thereto are controlled by the Nuclear- '

s Operations Section. - The manual is reviewed and approved on-site by the  !

plant organization, f i

4. The NS- Administration Manual, the QAS Instructions manual, and revisions ,

thereto are controlled and approved by the respective section manager, t

i Final responsibility for modifications, repairs, maintenance, and operations, licluding the quality assurance program, lies with the President. -Management  ;

review of the status and adequacy of the quality assurance _ program is accomplished by at least' semiannual review by the Off-Site Review Committee I (Section 1.8.1) and by regular briefingt et least once every two months) with  ;

the President.

fi The quality assurance -program applies to- structures, systems,-components ,

j (including expendable and consumable items which are used therein) and services which are ciassified as QA-scope based upon the safety-related- l ,

functions--to be- performed. QA-scope structures.- systems _ and components are ,

identified by various means. QA scoping is consistent-.with requirements of i the regulations as described in this FSAR, and also includes - non safety-related systems and components requiring quality- assurance. coverage such as fire protection and radioactive material packaging'.  : Positive . controls are '

implemented to assure updating of the various means as necessary. . }

s The classification of a system or component as = QA-scope:does not : imply that. '

the complete system, - or all the components or, component parts within that-_

l system, are QA-scope. Those specific portions of systems considered to be QA-scope are also. identified.in-appropriate documents.

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The program provides for indoctrination and training of perennel performing

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. activities affecting quality as necessary to assure that suitable proficiency -l

is achieved and maintained. The indoctrination and training program is structured to assure that

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1. Personnel performing quality activities are instructed as to.the purpose, I scope and implementation of the quality-related manuals, procedures-and instructions; and it is emphasized that these are mandatory _ requirements which must be implementH and enforced.  !

2. Personnel performing quality-related activities are trained and' qualified l in the principles and techniques of the activity ing performed.

3. Appropriate training procedures are established and that records of training are maintained, i ,

t Section 5.2.10 of ANSI N18.7-1976 states that the provisions of ANSI N45.2.3- l 1973 shall be applied to those-activities which are comparable in nature and  !

extent to related activities occurring during construction. Point . Beach -  :

Nrlear Plant practices good housekeeping and cleanliness. involving' activities f performed by plant and contractor personnel to maintain the necessary standard l

of cleanliness. '[

I Scheduled and documented' daily-to-weekly surveys of potentially contaminated or radioactive areas are conducted by health' physics personnel, followed by decontamination or radioactive . cleanup -as necessary. . Surveys ensure cleanliness checks of even the least traveled areas. 'An additional program provides that Operations . shif ts are - assigned - specific plant areas ' to - patrol-and clean up as a housekeeping duty, Plant policy is that each personr is responsible for cleanliness and good housekeeping in their own immediate work area. Final inspections of work areas following completion of ' work, including final internal . inspections of pressure vessels, . tanks, etc., are . routinely -

completed by supervisory personnel. Such inspections are formally documented only in special cases when considered necessary; these normally being final inspections by plant supervisory personnel- following work' by outside .

contractors.

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Storage of' items are controlled to established quality assurance and fire

! protection requirements. Access to safety-related equipment or radiation j controlled areas is controlled by security regulations or defined health p'nysics rules. ,

1 PBNp is committed to comply with OSHA regulations in the physical safety and-enviro' mental condition of work places. J Significant attotton to housekeeping is provided by plant management on a periodic basis.

1.8.3 DESIGN CONTROL Procedures and practices are established and documented to assure that applicable regulatory requirements and design bases are correctly translated-into design documents, such as specification and drawings, for work-involving changes or additions to the original design of safety-related structures, systems, and components. These measures include provisions to assure that appropriate quality- standards are specified and included in the design documents and that deviations from such standards are controlled, The measures also include provisions to _ control selection and review for the suitability of application of materials, parts, equipment, and processes that are essential to the safety-related function.

l Proc.dures and practices are established _and documented.for the identification and control of design interfaces and . for coordination among design organizations. These include procedures among participating design l organizations for the review, approval, release, distribution, and revision of design documents. The design control measures provide for verifying or checking the adequacy of design by design reviews, by alternate or simplified calculational methods, or by suitable testing programs performed by individuals or groups other than the originator.

Where a - test program is used to- verify' the adequacy of a1 specific -design feature, provisions -include suitable' qualification t6 sting of 'a prototype unit-under the most adverse design conditions.- Design control measures consider, as appropriate, reactor physics; stress, thermal, hydraulic, and accident analyses; compatibility of _ materials;_ accessibility- for -inservice inspection, 1.8-9 March 1991--

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maintenance and repair; and delineation of acceptance criteria for inspections l and tests.  !

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Changes to designs are subjected to commensurate design control measures.  !

When a contemplated change is considered by appropriate management to be of  !

sufficient scope as to be beyond the expertise of in-house personnel, these l 1

changes are reviewed by the organization that performed the original design,- l or other design organizations determined to be equally qualified. Design j activities associated with modifications of safety-related structures, systems  !

and components are accomplished in accordance with the provisions of Section 8 I of ANSI N45.7.ll-1974, 1.8.4 PROCUREMENT DOCUMENT CONTROL f l

i Procedures and practices are established-and documented to provide assurance l

that applicable regulatory requirements, design bases, and other requirements which art necessary to assure adequate quality are verified during procurement and acceptance of- materials, products, or services. These measures are  !

applied to spare and replacement parts and equipment, new material, and- [

, equipment and contracting of services. Procedures require that procurement  !

documents be prepared, reviewed, and approved 'in accordance with QA program l requirements. The Quality Assurance Section reviews procurement documents to f

ensure the inclusion of adequate quality criteria. Records _of the review are j maintained. [

Procurement documents require suppliers, contractors, or subcontractors- to - I implement quality assurance programs to- the extent necessary. $The .' programs j may be reviewed by the QA Section, qualified third party organizations such as  !

the American Society of Mechanical Engineers (ASME),Jindustry organizations _

f such as the Nuclear Procurement Issues Committee (NVPIC) or joint utility'  ;

groups._ The evaluation and qualification of _ supplier programs is -documented._ i Further details of the system for control of. procurement documents is 4 contained in Section'l.8.7. ,

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1.8.5 INSTRUC110NS, PROCEDURES, AND DRAWINGS Activities affecting quality are prescribed by documented instructions,

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procedures or drawings appropriate to the work at hand with the work I accomplished in accordance with these documents. Measures are established for the preparation, revision, and control of procedures, instructions, or drawings.

Instructions, procedures, and drawings are required to include appropriate quantitative or qualitative acceptance criteria to ensure work has been satisfactorily accomplished. Supervisors may direct that data be taken without the data taker being cognizant of the acceptance criteria when it is considered that forehend knowledge of the acceptance criteria may prejudice results. The sapervisor is then reponsible for verifying conformance. To the extent applicable, as-built drawings and original equipment and system specifications, subject to improvements resulting from operational experience and subject to the necessary design control, establish acceptance criteria.

When required, these instructions, procedures, and drawings provide methods for complying with appropriate regulations.

Section 5.2.2 of ANSI N18.7-1976 requires that temporary major procedure changes which do not change the intent of an approved procedure be approved by two members of the plant staff knowledgeable in the areas affected by the procedure. One of these individuals is to be the Duty Shift Superintendent who holds a senior operator's license. As described in Section 15.6 of the Technical Specifications, Nuclear Operations follows the above guidance for operating procedures. For Maintenance, Instrumentation and Control, Technical Services Chemistry, and Health Physics procedures, approval is not required from the Duty Shift Superintendent for tempocary changes. For a further description of the system for temporary changes, refer to Section 15.6.8 of the Technical Specifications.

Section 5.3.2 of ANSI N18.7-1976, which discusses the content of procedures,.

states in part, "... procedures shall include, as appropriate...(8) Acceptance Criteria." We have determined that the incorporatio1 of acceptance criteria j is not always advantageous, as discussed herein.

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l l'. 8. 6 DOCUMENT CON 1ROL Procedures and practices are established and documented to control the issuance and revision of documents, such as: maintenance and modification procedures; design specifications; design, manufocturing, construction, and installation drawings; procurement documents; manufacturing, inspection, and testing instructions; test and opnrating procedures; QA- manuals; safety analysis reports; and related design criteria documents. The procedures identify responsibility for review, approval, and issuance of the documents and associated changes. For quality related documents, the review includes an assessment of applicable quality requirements.

The procedures provide assurance that documents, including changes, are reviewed for adequacy, approved for use by authorized personnel and distributed to and used at the location *re the prescribed activity is performed prior to commencement of the activity. These include prompt issuance of changes and control of the obsolete or superseded documents to prevent inadvertent use. Controls, such as maintenance and distribution of indices, are also implemented to identify current revision of documents to be used. Document control procedures include provisions for determining responsibility for review of changes to documents.

Documents classified as QA records are subjected to the additional require-ments described in Section 1.8.17.

l 1.8.7 CONTROL OF PURCHASED MATERIAL, CQUIPMENT, AND SERVICES Procedures and practices are established and documented to assure that purchased material, equipment and services conform to the procurement documents. These measures include review of all purchase requisitions by the Quality Assurance Section. QA scope requisitions are processed by the Quality Assurance Section to ensure incorporation of appropriate quality requirements.

The bases for selection of suppliers 'may include previous experience, l

satisfying the required qualifications of the contractor who erected the plant, or a pre-award evaluation of the proposed supplier's capabilities and qualifications. Industry programs, such as those applied by ASME, NUPIC, or 1

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, other established 1tility groups, are used as input or the bast i for supilier qualifica .on when?ver app *opriato.

Control of purchased items includes provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the contractor or subcontractor, inspection at the source, and examination of products at receipt. These controls also include provisions for monitoring cont ractors providing services through performance of audits and surveillances, as necessary, to verify conformance with procurement requirements. These are performed by appropriately trained personnel in accordance with written procedures and instructions.

Documentary evidence is required to be available prior to use of equipment.

Procedures require assignment of a Quality Assurance Release (QAR) identi-fication number prior to placing the purchased items into service. These ,

procedures require all documentation required by the purchase order to be available and satisfactory prior to issuance of the QAR. Measures are' provided for monitoring the effectiveness of contractor control of quality consistent with the importaq;e, complexity, and quality of the product or services.

The requirements of ANSI N45.2.13-1976 are met for the procurement of

-components within the scope of Section 5.2.13 of ANSI N18.7-1976.

I 1.8.8 IDENTIFICATION AND CONTROL 0F MATE.ilALS, PARTS, AND COMPONENTS Procedures and practices are established and documented requirino identi-fication of materials, parts, and components, including partially fabricated assemblies, to prevent use of' incorrect or defective items. Identif' cation requirements are based on as-built drawings and specifications.

Identification requirements for other than identical replacement items are determined during planning for the modification or addition. Identification methods and locations are selected so as not to affect _the function or quality of the item.

These measures assure that identification is maintained .by stock number, system identification, part number, or other appropriate means, either on the 1.8-13 March 1991 l

item or on records traceabh to the item, as required during installation and i >

use. These measures apply to plant items as well as those provided by on-site 4 contractors.

i- Procurement documents invoke appropriate requirements for identification and

! control of material during manufacture, including provisions for WE in-process auc'ts of the manufacturer's program.

4 1.8.9 CONTROL OF SPECIAL PROCESSES -

Procedures and practices are established and documented to assure that special processes, such as welding, heat treating ~, and nondestructive examinations are controlled and accomplished by qualified personnel using qualified procedures or process sheets in accord ece with applicable codes and standards.

Verification of conformance is -documented. . These measures require copies -of -

qualifications to be on site during . process perfoonance whether by WF personnel or contractors. Procurement documents specify appropriate control-requirements for pr.ocesses performed off-site. -

1.8.10 INSPECTION Procedures and practices are established and - documented providing for_

c appropriate Mspection of activities affecting - quality; ano to ver fy a conformance with the documented instructions, procedures, ~ drawings, or i

specifications for. accomplishing the activity. -Inspection procedures, instructions, and checklicts include the following, as applicable:

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1. Identification of characteristics to be inspected..-

2. Identification .of - the . individuals or groups responsible - for performing the ' inspection operation.--

3. Acceptance and rejection criteria.-

4. The method of the inspection.

5. Verification of completion and documentation of the inspection, p Maintenance, replacement, or rework ' items are inspected in ' accordanr:- with original inspection ~ requirements and. criteria or improved-require-ments based on operating experience. Hodified-items are inspected by methodsLat least equivalent to the original-inspection methods.

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i These measures provide for- verification - of conformance to be performed' by appropriately _ qualified individuals other than those who -performed the activity. Qualification of- these individuals in accordance with appropriate '

requirements is documented. Provisions for Code Authorized Inspection are included when required.

Examinations, nmsurements, or tests are performed for work operations where -

necessary. Procurement documents for materials or products specify examinations, measurements, or tests to be performed for each work operations where necessary to assure quality. Storeroom personnel perform receiving inspection on procured materials as appropriate per the procurement documents, specifications, procedures, and instructions. Storeroom personnel are knowledgeable of the requirements of the quality assurance program. Questions-regarding quality assurance are referred to the QA Section. Procurement' documents' for materials or pro 6 cts, for which direct inspection is impossible or disadvantageous, specify provisions- for indirect control by monitorin; "

proeming methods, equipment, and personnel. When control is _ inadequate-without both inspection and. process monitoring, provisions for.-both are <

ind uded, Mandatory hold points are.specified and used where required.

Section 3.4.2 of ANSI N10.7-1976 states that personnel performing . inspection, examination, and testing activities shall be qualified to ANSI N18.1-1971, or shall meet the requirements of ANSI N45.2.6-1973. With few exceptions, Point Beach personnel meet or exceed the qualification = requirements of ANSI N18.'1-1971, and are therefore qualified to perform . plant- inspection, examination,

-and testing activities. -Those few exceptions .are in- job-' functions not discussed in ANSI N18.1-1971 and certain inspection andL test personnel whos work for contractors as discussed below.

All positions at Point Beach have- been evaluated to determine :the minimum-qualification requirements. The .are'as considered aur'ing the evaluation-included regulation,- code and standard requirements, education and- training, work experience, and = physical condition. Applicants for-' positions: at Point u Beach not meeting the minimum requirements, or not satisfying _ preemployment '

aptitude testing requirements tare not considered for the position.

Additionally, prior to employment, - all plant personnel are interviewed - by senior plant management and, in most : cases, are interviewed by the Manager--

Nuclear -Operat. ions. These individuals make the final determination of 1.8-15~ March'1991

't acceptability. There is only one level of qualification at Point Beach, not three levels as indicated in ANSI N45.2.6-1973, hen the extent of the maintenance or modification is such that it must be

)- performed by contract, the potential- contractor's QA program is evaluated by j the QA Section to determine its acceptability, included in the evaluation is i consideration of the qualifications of inspection and test persont 21. In cases where it is determined-- that a contractor's organization is suitably qualified in all other respects, including qualified personnel,- a qualification and. certification program which meets all the requirements of-ANSI N45.2.6-1973 is not insisted upon. Implementation of the audit program -

assures qualification of such personnel. ,

All nondestructive examination personnel are required to be qualified in accordance with the appropriate sections and editions of ASNT Recommended Practice No. SNT-TC-1A.

Section 3.2 of ANSI N18.7-1976 requires that verification of- conformance be performed by individuals other -than those performing or_ directly supervising the work. Verification of conformance is conducted -in this manner at Point Beach.

Section 5.2.17 of ANSI N18.7-1976 requires inspections forl modifications and non-routine maintenance to be performed in a-manner similar to that associated with construction phase activities. Modifications and non-routine maintenance for which outside contractors -are used are . performed in- this manner. -

Modifications and non-routine-maintenance items within-the capablities of the onsite operating organization are performed as a~-routine maintenance activity.

1.8.11 TEST CONTROL Procedures and practices are established and documented to provide a; program of periodic testing and continuing- surveillance _to demonstrate -that-structures, systems, and components continue to perform satisfactorily in service. The measures require tests to be performed by appropriately trained I

and qualified personnel in accordance with written test procedures which incorporate the requirements and acceptance limits (except as noted in.Section 1.8.5) .from applicable design documents. Test pro-cedures include provisions 1.8-16 March 1991

l for assuring that all prerequisites for the test have been met, that adequate test instrumentation is available and - used, and that. the test is ' performed under suitable environmental con-ditions. Test results are documented and evaluated to assure test requirements have been satisfied. These measures require replacement or modified structures, systems and components to be subjected to sufficient proof, preoperational, and operational testing to demonstrate that they will perform satisfactorily in :;ervice.

1.8.12 CONTROL 0F MEASURING AND TEST EQUIPMENT Controlled procedures and practices are established and clocumented to assure  ;

that tools, gauges. instruments, and other measuring and testing devices-used. t in activities affecting quality are properly identified, control. led, calibrated, and adjusted at specific intervals to maintain accuracy within necessary limits. Calibration procedures specify standards to be -used for performing the calibration. Procedures require _ that standards used have greater accuracy than the item being calibrated. These measures provide for-identification of the equipment and associated records and appropriate ~

corrective action when out-of-calibration conditEns are noted.

1.8.13 HANDLING, STORAGE, AND SHIPPING Procedures and practicce are' established and- documented to: control; the handling, storage, shipping, cleaning, and preservation of material and equipment by quali/ied individuals in~ accordance with work and inspection-instructions to prevent damage or deterioration- and preclude . loss _.of identification. The measures include _ specification and use, 'when necessary,

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q of special protective ~ environments,- such - as inert gas atmosphere, specific.

moisture content, and temperature levels.

1.8.14 INSPECTION, TEST, AND OPERATING STATUS Procedures and practices are established' and documented -to indicate by suitable means, the status of ' inspections and tests to be performed upon individual items. . These measures ineade provisions for~ the identificatien'of items which have satisfactorily- passed required: inspections and- tests when necessary to preclude inadvertent bypassing - of such' inspections and tests.

Procedural controls to- perform operations out of- sequence are established.

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I2 These measures also include provisions for indicating nonconforming, inoperative, or malfunctioning components within a system to prevent-inadvertent operation. '

l.8.15 NONCONFORMING MATERIALS, PARTS, OR COMPONENTS Procedures and practices are established and documented to control materials,-

parts and components, or quality activities which do not conform to-established requirement:;. To prevent the inadvertent use or installation of purchased material, parts, or components, these measures may include timely return of nonconforming materials, parts, or components to the vendor for replacement with satisfactory items. Formal nonconformance control ; systems are in place to assure - control and disposition of nonconforming -items or-activities including adherence =to 10CFR21 as necessary.-

Maintenance Work Requests identify and control nonconforming items requiring repair or rework to be returned to satisfactory condition. Where a; safety-related component is required to be temporarily -or permanently changed, such that it no longer complies with the original and approved design, such changes, with required approvals, 'are made via the approved modification request procedure.

The Nuclear Power Department has established provisions for documenting and:

dispositioning nonconforming items or conditions, which are identified during-inspection, surveillance or auditing activities.

4 1.8.16 CORRECTIVE ACTION Procedures and practices are established and' documented to assure that conditions adverse to quality; such ae failures, malfunctions,- deficiencies, deviations,. defective . material, and equipment and - nonconformances;' are promptly identified and corrected. -In the case of 'significant conditions adverse to quality, these measures include assurance that the cause of the condition is - determined and corrective action taken - to preclude ^ recurrence.

These include provisions for identification of the significant condition adverse to quality, the cause of the condition and the corrective--action-taken-which is documented and reported to ' appropriate levels of management.- 4 1.8-18 March 1991'

, Provisions are included for followup reviews to verify proper ' implementation of corrective actions and to close out the corrective action documentation.

1.8.17 QUALITY ASSURANCE RECORDS Procedures and practices are established and documented .to assure that sufficient records are generated and maintained to -furnish evidence of I activities affecting quality. Where practicable, the guidelines ~ of ANSI N45.2.9-1974 apply. The records consist of at_least operating logs and the results of reviews, inspections, tests, monitoring, work performance, and materials analyses. Also in:luded are_ closely related data such as qualifications of personnel, procedures and equipment. inspection and test records include, as a minimum, identity of the inspector or data recorder, the

-l typa of observation, the results and the acceptability, or action taken in i connection with any deficiencies noted. Records are identifiable and retrievable.

i Requirements concerning records retention, such as duration, location, _and assigned responsibility, are established to be consistent. with applicable-regulatory requirements. Radiographs, with the exception-of those associated with ASME Section -XI components or_ systems (to -be retained for the service life of the component or systems), are retained as non-permanent records for a minimum of ten years after the date -of the radiograph.

In either case, associated radiographic _ review records are permanently retained and provide necessary-weld quality / acceptance information.

In -1971, Wisconsin Electric recognized the need to improve-its records manage-ment program in- the area of. preservation -of records - for Point Beach. in the-absence of any guidance in the form of- regulatory guides or - national standards, it- was decided- to generally _ follow the requirements of NFPA 232-

~

1970.

The requirements of NFPA 232-1970 were reviewed-in light of importance--of the records being: stored and the risk of destruction- of the records.- It= was determined that the records being stored required positive protection as many were. irreplaceable. Possible locations for records storage facility _ were studied, and it wb determined that the: lower level of-the-Point Beach Energy 1.8-19 March'1991

1

)

j Center located on the plant grounds, offered an ideal location for a recoras _

storage facility. l l

This location was chosen since it was an area of minimum weight of combusti-bles and the building itself was~ fire resistant. It was determined, based on the above factori, that a separate room would be constructed in the lower level of the Point Beach Energy Center to provide further protection.

The room was built to meet Wisconsin Administrative Code requirements for four-hour construction, and was treated to minimize the risk of water infiltration. In addition, the room was equipped with an inert gas ': fire suppression system 'which is automatically triggered by smoke or heat.

Triggering of the fire suppression system also activates an alam signal and a visible alarm which can be observed from a continuously me...ed guard _ station. ,

t Based on the analysis of the fire hazard present- in the Point Beach Energy Center, the alarm system, and the sophisticated fire suppression system, .it-~

was decided that the requirement for a- four-hour vault door was unnecessary.

The entrance to the room is closed with a Class A' fire door. In addition, the- l fire suppression system: required;an electrical supply, _w hich led to the waiving of the requirement that' walls could not be penetrated by electrical conduit. The electrical' supply for room is brought into the room via a-conduit through one of = the -walls. and ceiling which has :been installed- to minimize the risk of fire passing through:the wall via this penetration.

1.8.18 AUDITS Procedures and practices have been established and documen'ted' to' provide a' comprehensive system of planned and periodic audits to verify compliance with all aspects of the quality --assurance program and to determine -the

~

effectiveness of the program.

Audits are performed in accordance with written procedures .or checklists by appropriately ' trained personnel not having direct _ -responsibilities in -the areas being audited. The QA program is audited periodically, by the QA-Section. The QA Section also performs audits under the cognizance of the Off-Site Review Committee as required by PBNP Technical _ Specification 15.6.

On-site and off-site contractor audits are scheduled commensurate with the work's 1.8-20 March 1991

,, importance to plant safety and reliability and are timed as appropriate for the work scheduled.

Whrre practical, audits are conducted using performance-based techniques.

As an example, periodic operational readiness assessments of safety-related plant systems may be conducted using vertical-slice audit techniques.

Audit results are documented and reviewed by management personnel having responsibility in the area audited. Audit reports are routed to management responsible for correcting any unsatisfactory items noted. Follow-up action, including reaudit of deficient areas, is taken when indicated. When follow-up audits reveal repetitive occurrences which reflect possibi. trends adverse to the effectiveness of the QA program, these results are reported to the appropriate management level to effect corrective action.

in a footnote to Section 4.5 of ANSI N18.7-1976, it is stated that the provisions of proposed ANSI N45.2.12, Draf t 4, Revision 2, dated January 1, 1976, shall be used for audits performed to meet the requirements of Section 4.5. Sufficient audits are performed, by the QA Section, in accordance with the provisions of ANSI N45.2.12 to meet the requirements of Section 4.5 of ANSI N18.7-1976. Also, internal audits performed by the -QA Section are led by individuals certified as Lead Auditors in accordance with the requirements of ANSI N45.2.23. It should be noted that Section 3.2 of ANSI N18.7-1976 recognizes that quality assurance is an interdisciplinary function and that advantages may accrue from having reviews of certain plant functions performed by individuals other than quality assurance personnel. WE strongly endorses this position. Typically, the QA Section assigns l technically competent quality- assurance personnel to perform audits, however l when necessary, QA personnel are supplemented with other technically qualified WE and/or contractor personnel. Audits are sometimes_ supplemented _by-l surveillances of quality related activities. Surveillances are performed by qualified individuals, although not necessarily certified as lead auditors.

In addition, certair, review functions may be assigned to technically qualified individuals in lieu of quality assurance pe;sonnel.

I 1.8-21 March 1991

l ,

e' TABLE 1.8-1 i

COMMITMENT TO REGULATORY GUIDES AND ANSI STANDARDS-

1. Regulatory Guide 1.8 (Safety Guide 8) dated March 10, 1971

'r Full commitment except_ that - Wisconsin Electric- commits to ANSI N18.1-1971 in lieu of the proposed ANSI N18.1. dated . June 22, 3 1970.  ;

2. Regulatory Guide 1.28_(Safety Guide 28)'. dated June 7,'1972 l 1

i ANSI N18.7-1976 states- in part, "This: standard fully and completely.

describes the general requirements:and guidelines of ANSI N45.2-1971  ;

~

as those requirements, and guidelines apply during the: operational:

phase. of plant life." As such,- commitment to_- ANSI N18.7-1976. for Point Beach obviates -the need to commit ._to Regulatory Guide 1.28 which endorses ANSI N45.2-1971.

Wisconsin Electric does,-:however, : commit- to the position of ,

Regulatory Guide 1.28-to the-extent of requiring its vendors to have quality assurance- programs which meet the ' appropriate requirements.

of ANSI N45.2-1971 as mentioned in ' Section : 5.2.13.1 of ' ANSI N18 .

1976.-

3. Regulatory Guide 1,30 (Safety Guide 30) dated August' 11,:1972(

Commitment to-. follow the- position of Regulatory Guide 11.30, which _

4 endorses and supplements- ANSI N45.2.4-1972,; for - activities ;occuring  !

during. the operational phase- that are comparable in nature .'and-l extent to related activities during construction.-

l l

March 1991 T T' P-w e-g rmyo ----e_-g. g w w_- sp g r emep,$g .ts se s y=,p.ut.tJ9- m.y g ppq ypig- tt-'e.,g-.'r>9mogg r

4+  ;

TABLE 1.8-1 (Continued)

4. Regulatory Guide 1.37 dated March 16, 1973  ;

Commitment to follow the position of- Regulatory Guide 1.37, which endorses and supplements ANSI N45.2.1-1973, for activities occurring ,

during the operational phase that-- are comparable in nature and extent to related activities occurring during construction. .

5. Regulatory Guide 1.38, Revision 1, dated October 1976 i

Commitment to follow the position of Regulatory Guide 1.38, which endorses and supplements ANSI N45.2.2e1972, for activities occurring during- the operational- phase that are comp:rable in __ nature and extent to related activities occurring during construction.

6. Regulatory Guide 1.39, Revision 1, dated October _1976 Commitment to follow the position .of Regulatory Guide 'l.39, which endorses and supplements ANSI N45.2.3-1973, for' activities occurring _

during the operational phase that;- are . comparable ' in= nature and extent to related activities _occurr_ing ' during -construction except that Wisconsin Electric does not commit' to the . documentation requirements of ANSI N45.2.3-1973;and:provides.an alternative to:the housekeeping zone ' requirements therein. Descriptions of 'these -

differences are provided in Section 1.8.2. .

-3

- 7. Regulator.y Guide 1.-54 dated -June 1973 Commitment to fol7ow the position- of Regulatory Guide 1.54, which endorses and supplements ANSI N101.4-1972, for-activities. occurring-during the operational phase that_- are comparable -in nature- and -

extent to related: activities occurring-during construction.

' March 1991

-u_._______._m-_.m_u__u_-_____w

- -l

. 1

}

TABLE 1.8-1-(Continued)

8. Regulatory Guide 1.58 dated August 1973 Commitment to follow the position of Regulatory Guide 1.58, .which endorses and supplements ANSI N45.2.6-1973, for activities occurring in the operational phase that are compart.ble-in _ nature and extent to-related activities during construction, except that. Wisconsin-Electric does not commit to the levels of' qualification nor separate  !

certification requirements of = ANSI N45.2.6-1973. Descriptions of- '

these differentes are provided in'Section 1.8.10.

^

9. Regulatory Guide 1.64 dated October 1973 i Commitment to follow the -position of' Regulatory Guide 1.64, except that Wisconsin Electric commits' to ANSI N45.2.ll-1974 in lieu of I Draft 3 Rev. I dated July '1973, for: design _ activities- associated: .

4 with modification of safety-related' structures, systems- and

components.

10. Regulatory Guide 1,74 dated February-1974 -

Full commitment.

! 11. Regulatory Guide 1.88, Revision 1, dated December 1975 i

i Commitment to follow - the position of L Regulatory Guide 11.88, which endorses and supplements Ai4SI- N45.2.9-1974 and- NFPA-232-1970.

Wisconsin Electric has determined that'the existing records storage' s facility provides a level of protection to the vital ' records: at!the 4 plant which is equivalent to the ~ requirements - of Regulatory l Guide 1.88. Description of ' the differences are provided in Section 1.8.17. The Point Beach- policy for the retention of -

radiographs -and associated review ' records- .is outilned in Section 1.8.17.

I .

t i

March 1991 i

s Y

r ~+ -, , . ~ - - + - - -. w v,,.----,*,,-s

TABLE 1.8-1 (Continued)

12. Regulatory Guide 1,94 dated Apri! 1976 Commitment to follow the position of Regulatory Guide 1.94, which endorses and supplements ANSI N45.2.5-1974, for activities occurring during the operational phase that are comparable in nature and extent to related activities occurring during construction.

13. Regulatory Guide 1.146 dated August 1980.

Commitment to follow the position of Regulatory Guide 1.146, which endorses ANSI N45.2.23, for internal audits performed by the Quality Assurance Section (QAS),

14. ANSI 18.7-1976 Refer to Section 1.8,0 .for details of the Wisconsin Electric commitment.

March 1991

/

TABLE 1.8-2 SUBSECTIONS OF SECTION 1.8 APPLICABLE TO THE FIRE PROTECTION PROGRAM Subiect Subsection Administrative and Organizational 1.8.1, 1.8.2 Design and Procurement Document Controls 1.8.3, 1.8.4 Instructions, Procedures and Drawings 1.8.5 Document Control 1.8.6 Control of Purchased Materials, 1.8.7, 1.8.10 Equipment and Services inspection .

1.8.10 Test and Test Control 1.8.11 Inspection, Test and Operating Status 1.8.14 Nonconforming items 1.8.15 Corrective Action 1.8.16 Records 1.8.17 Audits 1.8.1, 1.8.18 March 1991 l

I

TABLE 1.8-3 SUBSECTIONS OF SECTION 1.8 APPLICABLE TO SHIPPING PACKAGES FOR RADI0 ACTIVE MATERIALS (10 CFR 71. SUBPART Hi Subiect Subsection Organization 1.8.1 Quality Assurance Program 1.8.2 Design Control *not applicable Procurement Document Control 1.8.4 Instructions, Procedures and Drawings 1.8.5 Document Control 1.8.6 Contro) sf Purchased Material, 1.8.7 Equipment and Services Identification 'and Control of 1.8.8 Materials, Parts and Components ,

Control of Special Processes 1.8.9 Inspection 1.8.10 Test Co;, trol *not applicable Control of Measuring and Test Equipment 1.8.12 Handling, Storage and Shipping 1.8.13 Inspection, Test and Operating Status 1.8.14-Nonconforming Materials, Parts or Components 1.8.15 Corrective Action 1.8.16 Quality Assurance Records 1.8.17 Audits 1.8.18 Design and testing control are activities which are not normally performed by Nuclear Operations personnel. However, these activities are imposed on suppliers providing radioactive material packagir.; or associated services, as appropriate.

l March 1991

i

._ WISCONSIN ELECTRIC POWER COMPANY!

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ORGANIZATIONS WITH OUALITY ASSURANCE -

INTERFACE TO POINT BEACH NUCLEAR PLANT e

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CHRlRMAN OF THE BORR0 i 1

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PRESIDENT ,

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VICE PRESIDENT

-1 VICE PRESIDENT VICE PRESIDENT S h NUCLEAR POWER ' OPERRf DNS'

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DIRECTOR- 10lRECTOR ENGINEER NG & DIRECTOR . - PURCHR$1NG-CONSTRUC 10N ENVIRONMENTAL RNO STORES-

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