ML20071P832
| ML20071P832 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 04/30/1983 |
| From: | KANSAS GAS & ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20071P822 | List: |
| References | |
| KMLNRC-83-063, KMLNRC-83-63, NUDOCS 8306080178 | |
| Download: ML20071P832 (27) | |
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Attachment to IG1LNRC 83-063 1.
Identification of Change Page 17. 2-2 Reason for Change This change was made to clarify the fact that operational organizations working under the Operating Quality Assurance Program will be performing work activities to support construction.
Basis for Concluding that the Revised Program Satisfies 10CFR50 Appendix B Both the SNUPPS Quality Assurance Program for Safety-Related Design and Construction activities and the Wolf Creek Operating Quality Assurance Program satisfy the requirements of Appendix B.
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l 830608017e 830606 DR ADOCK 05000482 PDR
SNUPPS-WC the KG&E startup forces, and subsequently the operating forces, will start out conducting their activities under the systems of control which comprise the OQAP, and thus the need to shift from the Design and Construction QA Program to the OQAP will be eliminated.
Construction organizations committed to the requirements of the Design and Construction QA Program may provide quality related activities to organization (s) committed to the require-ments of the OQAP (e.g. procurement and receipt inspection).
A description of the QA Program elements controlling these activities can be found in the appropriate section(s) of the SNU?PS QA Programs for Design and Construction Manual.
The construction organization providing the safety-related activ-i ity for the operations /startup applications shall assure that all personnel are qualified in accordance with the Design and Construction QA Program qualification requirements.
Both KG&E Construction and Operations shall be responsible for estab-lishing procedures to control the interf ace between the con-struction organization (s) providing the activity and the using organization (s).
Included within the OQAP are the development, control and use of computer code programs.
The Nuclear Plant Engineering
- Division, Nuclear Services
- Division, and the Plant Staff are responsible for the computer programs used internally.
Internal activities associated with verification, documen-
- tation, and use of computer programs, utilized in safety-related analyses, are accomplished in accordance with docu-mented procedures. ' Verification that the procedures are being followed and are effective in controlling computer program use is provided by internal audits by the QA Division.
Assurance that external organizations are controlling activities asso-ciated with computer programs used for safety-related analysis is provided through the supplier qualification
- process, through imposition of requirements in purchase orde rs and contracts and/or through audits.
17.2.0.4 Special Scope Programs In controlling activities to the extent consistent with their effect on safety, KG&E formally designates and applies se-lected quality requirements to fire protection, environmental control, and security.
Although not strictly safety-related, the applicable QA controls applied to these special scope programs are described as follows:
Fire Protection See Appendix 9.5A of the SUUPPS Standard Plant FSAR and Table
- 9. 5-1, WC adde nda.
Environmental Controls See Section 13.5.2.2.8 Site Security See UCGS Physical Security Plan Rev. 10 17.2-2 4/83
2.
Identification of Change Pages 17. 2-3 ( Sections 17.2.1. 2, 17.2.1.2a, 17.2.1.3),
- 17. 2-4 ( Sections 17. 2.1. 3a), 17. 2-Sa, 17.2-6, and 17. 2-8 (paragraph 1)
Figures 17.2-1 and 17.2-2 Reason for Change The revised.pages update the organizational description and titles of KG&E personnel.
Basis for Concluding that the Revised Program Satisfies 10CFR50 Appendix B The revised organization description provides delineation of the authority and duties of positions performing activities af fecting the. safety-related functions of structures, systems and components.
The organizational elements performing quality assurance functions maintain sufficient authority and independence as required by Appendix B.
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ss 17.2.1 ORGANIZATION y,
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c KG&E has estab1ishe'd), an organizational structdre for quality activities [-
This se ct, ion identifies the organiza-assurance
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tional structure; manag9 ment posit' ions and responsibilities; and delegation of author 2;tyrfor the development, implementa-tion, and maintenance 'of 'thhGQAP. _ KG&E ghall retain respon-sibility for the= establishment. and f e3ecution of-the OQAP, although certain program activi. ties' may be' delegated 'to othe rs. -
The organizational structure of KG&E's top manage-ment is shown-in Figure ;17.2-1 %_Toelorganizational structure g\\'
responsible for implementing l he? OQA.P is chown in Figure 17.2-2.
The organizaticn.of %rhe tWCGS staCf is shown in Figure 13.1-1.,
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x 17.2. 1.2 President and Chairman 'of the Board 1-s-
The President and Chairman of the Board is responsible, for
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promulgating quality assurance program requirements.
He has V
responsibility. for quality assurance, engineering,, procure-
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ment, construction, and operation of the WCGS.
He endorses KG&E's Quality Assurance policy statemen$ and delegates (the authority necessary to implement this policy.
He directs all
.KG&E employees who work in direct support of nuclear opera-
.c tions activities or interface with nuclear? operationc to comply with theeOQAP.
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- 17. 2.1. 2a Group Vice President - TechnicalsServices p
w The Group Vice President - Technical Services reports directly
~ he dutie's and to the President. 'and Chairman of the : Board.
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responsibilities of:the Group Vice Presidentf Technical Sere vices include being in charge of all technical aspects of g'
Kansas Gas and Electric Company.
These technical aspects encompass operations, transmission and distribution, engineer-ing and construction.
This includes the ' construction - and' operation phases of WCGS.
17.2.1.3 Vice President - Nuclear The Vice President - Nuclear, under the direction of the Group Vice President Technical Services is responsible for the implementation of KG&E's Quality Assurance Policy and the Quality Assurance Programs which devolve from this ' pol' icy.
He authorizes staffing of the QA Division, the WCCS, and the engineering and services divisions 'which support the WCGS.
He is responsible for directing activities which support the design, construction, and operation of the UCGS and for coordinating supportive activities performed by other internal and external groups which are not under his direct administrative control.
He has corporate responsibility for the operation, physical control, and, security of the WCGS.
Rev. 10 17.2--3
-M) 4/83
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% +, ? q-s 17.'2.15.'3a NLclear Coordinator i 1
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Jt The Nuclehr. Coordinator reports directly to the Vice President-i Nuclear and"-'is* rQPonsible for providing administrative and L
2 assist' hdel to the Vice Prasident - Nuclear.
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Nuclear Coordinator is also the " contact person" for activ-A1 ities.involvingr the Institute of Nuclear Power Operations O
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h 17.2.1.h 41ana r Quality Assurance A
b f-The Manager Quality Assurance, who reports directly to the 7 i,Vige, Pres (dent - Nuclear, devotes full attention to QA matters.
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,Hecis h ofipossible for assuring the development and implementa-tion of t'he'-RQ AP.
The Manager Quality Assurance is respon-s a - sible-for staf fing, the QA Division and for assuring QA person-
' nel are adequately trained and experienced to perform their 1
assigned tasks.
He carries out the directives of the Quality
, Asstirance Committee and provides\\the Committee with informa-
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-tion related to the effectiveness of the OQAP.
His qualifi-cations include:
A bachelor degree in Engineering or related sciences, six years of_ prof:ssional level experience in Nucle-QualityVA'ssurance orUsix' years of supe rvisory experience ar plus two yea R oi Nuclect Quality Assurance experience.
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17.2.1.4.1 ( Manager Qual-ity Assurance (UCGS) 3
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The Manager Q43ity Assuran'ce (UCGS), who reports to the Mana-Jger Quality Assurance, dayotep, full attention to QA matters.
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He is responsible for varD fysing that an adequate QA program is developed and implementhd' for safdiy-related activities which occur at the WCGS.
Th'e g anager\\ Quality Assurance (WCGS) is assigned (work locati,onk toithe Wolf Creek site.
He maintains 1
a ' ataf f J and providesesthem with : technical and administrative direct! ion.
He is responsible' for establishing and implement-comprehensive, plant \\nt,e audit program.
The qualifi-ing a cations ot the Manage'r Quality Assurance (WCGS) are a Bache-13.
lor's Degree in Engineeringor related science and at the time of initial core loading or appointment to the position and will have four years experie'nce in the field of quality assur-ance or equivalent number Mf years of nuclear plant experience or combination of the two, it least one year shall be nuclear power plant quality assurance implementation experience.
J7.2.1.4.2 Quality Assurance Coordinator 3
The Quality Assurance Coordinator reports to the Manager Qual-ity Assurance and is responsible for verifying that an ade-quate QA xprogram is developed and implemented for safety-related activities which occur at the corporate office and g}
a other locations remote from the UCGS.
He maintains a staff
'Jnd provides them willi technical and administrative direction.
s N 'He is responsible for -establishing ar.d implementing a compre-
.hensive audit - piogram, for offsite activities of KG&E, and w(
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17.2.1.7.2 Startup Manager The Startup Manager reports. to the Director Nuclear Operations and is responsible for the overall directior and administra-tion of the. functions and activities required to conduct the WCGS startup program.
Chapter 14.0 presents a description of the Startup Organization and delineates the Startup Mana-ger's responsibilities.
When the startup program has con-cluded, the Startup Organization will be dissolved.
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17.2.1.7.3 Manager Nuclear Training The Manager Nuclear Training reports to the Director Nuclear.
Operations and is responsible for the overall training activ-ities of the Nuclear Department.
He is responsible for insur-
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structor evaluation records with the Training Supervisor.
He is responsible for reviewing the content of trsining programs for technical completeness,and compliance with regulatory standards.
He is also - responsible for auditing the quality of on-site ' > training programs.
The Manager Nuclear Training is also responsible for tralhing programs for Corporate of fice personnel involved in support of WCGS during normal opera-tions, preparedness for response to off-normal incidents, and long-term recovery programs.
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r-SNUPPS-WC 17.2.1.8 Director - Purchasing Purchasing reports administrative 1y to the The Directoc Administration who reports to the 1.
Group Vice President President and Chairman of the Board.
The Director - Purchas-ing also has reporting responsibilities to the Group Vice Technical Services for materials, systems, compo-President nents and parts (not delegated to outside organizations) that are needed to support WCGS.
He is responsible for is.iuing purchase orde rs and contracts, for the commercial content of those documents, the financial / commercial qualification of vendors, and for processing invoices.
17.2.1.9 Quality Assurance Committee (QAC)
KG&E has established a Quality Assurance Committee (QAC).
The prime responsibility of this committee is to measure the ef fectiveness 'of SG&E's OQAP and initiate cnanges when war-ranted.
The permcnent members. of this Committee are the Vice President-Nuclear, Vice President-Engineering, Legal Counsel, Superintendent Production Fossil Plants and the Director Nuclear Operations.
In carrying out their responsibilities, the members of the
-Quality Assurance Committee shall utilize information received from internal audit reports; audit repcrts of other organiza-tions supplying services or materials which are important to safety; summaries of nonconformance reports, corrective action reports, and NPC I&E inspection reports and notices of viola-tion, if any.
The QAC'shall meet at least once during each calendar quarter.
The chairman of the committee is the Vice President-Nuclear, who may call additional meetings as necessary.
The committee
'will not concern itself with minor isolated QA problems but will take a broad overview of KG&E's OQAP and make decisons which will provide meaningful adjustments to the OQAP.
The committee will review deficiencies and will establish actions or affirm that adequate corrections are being made.
Notices of violation received from the NRC and responses made to the NRC which are qualitr related shall be reviewed by mem-bers of the QAC.
The Chairman will assign the responsibility for preparing reports to be sent to the NRC and will review and issue all such reports.
17.2.1.10 Safety Review Committees Safety review committees shall be established at the UCGS (the Plant Safety Review Committee) and at the KG&E General Office (the Nuclear Safety Review Committee) to provide independent review of _those items required by the WCGS Technical Specifi-cations.
Committee membership and duties are described in the Administrative Controls Section of the Technical Specifica-tions.
Rev. 10 17.2-6 4/83
y SNUPPS-WC 1.
Quality Assurance Policy The governing policy statement of the OQAP is approved by the u s.eside nt and Chairman of the Board (at the time of policy issuance, this individual was President and Chief Operating 1-Officer) and is contained in the Operating QA Manual.
2.
' Operating Quality Assurance Program Manual The OQAP Manual contains a
delineation of quality assurance requirements and assigned responsibilities.
The distribution of this manual und revisions thereto is pe rformed by the General Office QA Staff.
The Manager Qual-ity Assurance is responsible for the content of the manual and approves changes which are sub-mitted to the NRC for review and acceptance.
3.
Wolf Creek Project Policy Manual (WCPPM)
The UCPPM defines project policy relative to the management of the Wolf Creek Project.
Specific responsibilities and authorities are defined for the various individuals and organ-izations involved.
The manual also contains general procedures which are applicable to all KG&E personnel assigned to the project.
This manual and changes thereto are approved and issued by the Vice President-Nucle.1r.
4.
Procedures Manuals The WCGS Procedure Manuals and the KG&E Proce-dures Manual provide control for KG&E activ-g*
ities covered by the OQAP.
Table 17. 2-1 shows a listing of controlled procedure manuals.
These manuals contain mandatory requirements which must be implemcnted by responsible organizations and individuals.
Table-17.2-2 lists areas of OQAP implementing procedural cove rage and indicates the related criteria of 10 CFR 50, Appendix B,
covered by each area.
This listing represents general areas of procedural coverage.
Provisions for proce-dure consolidation, separation, deletions, additions, or minor program changes do not permit including an absolute listing of implementing. procedures.
Table 17.2-3 lists QA Program commitments to Regulatory Guides and endorsed codes and standards.
Rev. 10 17.2-8 4/83
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,,,$,,,,,,,,[a FINAL SAFETY ANALYSIS REPORT AfslNiilHA T IWa l'lGilHE 17.2-2 KG6E Olumf1IZATIOt1 POlt titirl.1:AR OPEIMTIOtJS
3.
Identification of Change Pages 17.2-4 (Sections 17.2.1.4, 17.2.1.4.1, 17.2.1.4.2) and 17.2-4a Reason for Change These revised sections correct titles and incorporate a commitment made in response to an NRC Quality Assurance Branch question.
Basis for Concluding that the Revised Program Satisfies 10CFR50 Appendix B The commitment is unchanged and only titles of certain personnel needed to be corrected.
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SNUPPS-WC 17.2.1.3a Nuclear Coordinator The Nuclear Coordinator reports directly to the Vice President-Nuclear and is responsible for providing administrative and technical assistance to the Vice President - Nuclear.
The E
Nuclear Coordinator is also the " contact person" for activ-ities involving the Institute of Nuclear Power Operations (INPO).
17.2.1.4 Manager Quality Assurance The Manager Quality Assurance, who reports directly to the Vice President - Nuclear, devotes full attention to QA matters.
3-He is responsible for assuring the development and implementa-tion of the OQAP.
The Manager Quality Assurance is respon-sible for staffing the QA Division and for assuring QA person-nel are adequately trained and experienced to perform their assigned tasks.
He carries out the directives of the Quality Assurance Committee and provides the Committee with informa-tion related to the effectiveness of the OQAP.
His qualifi-cations include:
A bachelor degree in Engineering or related sciences, six years of professional level experience in Nucle-ar Quality Assurance or six years of supervisory experience
-plus two years of Nuclear Quality Assurance experience.
17.2.1.4.1 Manager Quality Assurance (UCGS)
The Manager Quality Assurance (WCGS), who reports to the Mana-gec Quality Assurance, devotes full attention to QA matters.
3, He is responsible for verifying that an adequate QA program is developed and implemented for safety-related activities which occur at the WCGS.
The Manager Quality Assurance (WCGS) is assigned [ work location) to the Wolf Creek site.
He maintains a staff and provides them with technical and administrative direction.
He is responsible for establishing and implement-ing a comprehensive plant site audit program.
The qualifi-cations of the Manager Quality Assurance (WCGS) are a Bache-l3, lor's Degree in Engineering or related science and at the time of initial core loading or appointment to the position and will have four years experience in the field of quality assur-ance or equivalent number of years of nuclear plant experience or combination of the two, at least one year chall be nuclear power plant quality assurance implementation experience.
17.2.1.4.2 Quality Assurance Coordinator 3.
The Quality Assurance Coordinator reports to the Manager Qual-ity Assurance and is responsiole for verifying that an ade-quate QA program is developed and implemented for safety-related. activities which occur at the corporate office and other locations remote from the UCGS.
He maintalas a staff and provides them with technical and administrative direction.
He is responsible for establishing and implementing a compre-hensive audit program for offsite activities of KG&E, and Rev. 19 17.2-4 4/83
SNUPPS-UC'
'KG&E's suppliers, consultants, and agents.
He coordinates quality. verification activities with other KG&E departments and with external QA-organizations.
The qualifications of' the - Quality Assurance Coordinator are.at least equivalent to those ' of.an Audit Team' Leader as. set out in KG&E's procedures.
17.2.1.4.3 Stop Work Authority The Manager Quality Assurance is authorized by the Vice President - Nuclear to stop work on ongoing quality activities which do not comply with' established requirements.
For onsite activities, this authority is delegated to the Manager Quality Assurance (WCGS) by the Manager Quality Assurance.
During the 1 3 operating phase, these.. personnel have the authority to stop j
unsatisfactory work during repair, maintenance, and refueling activities and the authority to recommend to the Plant Super-intendent stop work af fecting the. continuation of plant oper-t ation.
Other stop work. authority evolving from hold points, witness points, and mandatory reviews and approval will be delineated in. procedures.-
The continuation of an activity which'would preclude identification and' correction or increase the extent of the deficiency is subject t'o stop-work action by the Quality Assurance Division..
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Identification of Change Page 17.2-7a Reason for Change Tite procedure for submitting Operating Quality Assurance Program changes has been revised to be consistent with the recent NRC rulemaking concerning changes to Quality Asstrance Programs.
Basis for Concluding that the Revised Program Satisfies 10CFR50 Appendix B Th? change was made in reaction to the recent NRC rule-making concerning changes to Quality Assurance Programs.
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SNUPPS-WC The WCGS design and construction activities preceding imple-mentation of the OQAP are governed by the Quality Assurance Program described in Section 17.1 of the Standard Plant PSAR and the Wolf Creek PSAR Addendum.
Commencing with the issuance of an operating license, changes to the OQAP shall be submitted to the NRC at least annually.
If any such caange reduces the commitments previously made, NRC' approval must be obtained prior to implementation.
17.2.2.4 OQAP Documentation Consistent with the schedule for accomplishing operations phase activities, the OQAP shall be established and docu-mented.
The OQAP shall be documented as follows to meet program objectives:
Rev. 10 17.2-7a 4/83
5.
Identification of Change Page 17.2-8 (paragraph 4)
Reason for Change The KG&E Procedures Manual provides control for some onsite as well as offsite activities.
Basis for Concluding that the Revised Program Satisfies 10CFR50 Appendix B Safety-related procedures incorporate applicable require-ments of Appendix B, irregardless of the manual in which they.are contained.
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SNUPPS-17C 1.
Quality Assurance Policy The governing policy statement of the OQAP is approved by the President and Chairman of the Board (at the time of policy issuance, this A-individual was President and Chief Operating Officer) and is contained in the Operating QA Manual.
2.
Operating Quality Assurance Program Manual The OQAP Manual contains a
delineation of quality assurance requirements and assigned responsibilities.
The distribution of this manual and revisions thereto is performed by the General Office QA Staff.
The Manager Qual-ity Assurance is responsible for the content of the manual and approves changes,nich are sub-mitted to the NRC for review and acceptance.
3.
Wolf Creek Project Policy Manual (WCPPM)
The WCPPM defines project policy relative to the management of the Wolf Creek Project.
Specific responsibilities and authorities are defined for the various individuals and organ-izations involved.
The manual also contains general procedures which are applicable to all KG&E personnel assigned to the project.
This manual and changes thereto are approved and issued by the Vice President-Nuclear.
4.
Procedures Manuals The WCGS Procedure Manuals and the KG&E Proce-dures Manual provide control for KG&E activ-ities covered by the OQAP.
g-Table 17. 2-1 shows a listing of controlled procedure manuals.
These manuals contain mandatory requirements which must be implemented by responsible organizations and-individuals.
Table 17.2-2 lists areas of OQAP implementing procedural coverage and indicates the related criteria of 10 CPR 50, Appendix B,
covered by each area.
This listing represents general areas of procedural coverage.
Provisions for proce-dure consolidation, separation, deletions, additions, or minor program -changes do not permit including an absolute listing of implementing procedures.
Table 17.2-3 lists QA Program commitments to Regulatory Guides and endorsed codes and standards.
Rev. 10 17.2-8 4/83
1 6.
Identification of Change Pages 17.2-35, 17.2-44, 17.2-45, and 17.2-46 Reason for Change This change provides additional information concerning the role of the Quality Control organization in the area of special processes.
Basis for Concluding -that the Revised Program Satisfies 10CFR50 Appendix B The revised pages incorporate a commitment made in response to an NRC Quality Assurance Branch question.
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SNUPPS-UC 17.2.9 CONTROL OF SPECIAL PROCESSES 17.2.9.1 Scope Special processes are those fabrications, tests, and final preparation processes which require the qualification of procedure, technique, and personnel and which are performed in accordance with applicable codes and standards.
Special processes normally require interim in-process controls in addition to final inspection to assure quality.
Special processes include such activities as welding, heat treating, nondestructive examination, application of coatings, and chemical cleaning and shall be accomplished under control-led conditions by qualified personnel in accordance with the technical requirements of applicable
- codes, standards, specifications, or other special requirements.
Procedures detailing special processes shall be qualified in accordance with applicable codes and standards or, where no appropriate standards exist, ro KG&E requirements.
The qualification of processes and personnel shall be documented and maintained.
17.2.9.2 Procedural Control Plant procedures shall prescribe the requirements for the qualification of KG&E procedures, personnel, and equipment.
The involvement of the QA organization in the control of special processes includes the review of plant procedures for 2
the adequate inclusion of quality requirements.
The QC orga-nization directly performs NDE, or perfo rms surveillances on the work of others who provide NDE services.
They also in-
[0 spect other special process activities conducted by the plant maintenance staff and contractors.
Special process equipment that may require periodic adjustment and whose performance cannot be verified through direct monitoring of appropriate parameters shall be subject to the controls described in Sec-tion 17. 2.12.
Qualification records shall be maintained cur-rent.
The Plant Superintendent shall be responsible for assuring that personnel pe rforming special processes are qua-lified and are employing qualified procedures.
Procedures shall also be established for recording evidence of acceptable accomplishments of special processes using qualified proce-
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dures, equipment, and personnel.
Plant and other responsible KG&E organization procedures shall also be established, as appropriate, to prescribe measures for the preparation, revi ew, ' and approval of procedures for the control of special processes.
Plant procedures shall address nondestructive examination (NDE) personnel, special process procedures, and inspection pe rsonnel qualification requira-ments.
Procedures detailing special processes prepared by KG&E engineering organizations shall receive an independent review to assure that quality requirements and acceptance criteria have been incorporated and recorded.
Rev. 10 17.2-35 4/83
T SNUPPS-WC
-17.2.12 CONTROL OF MEASURING AND TEST EQUIPMENT 17.2.12.1 Scope The - calibration and control program established at the UCGS shall. assure that tools,
- gauges, and instruments maintain their required accuracy.
The Plant Superintendent shall be responsible for assuring the program's establishment and implementation.
Test instrumentation shall be utilized by various organizations as required to perform tests or other special operations.
Each organization shall be responsible for assuring that the measuring and test equipment (M&TE) it employs has been properly calibrated.
Outside organizations and _other KG&E organizations employing M&TE in quality activities.at the
. CGS shall be required to implement a W
calibration and control program consistent with the require-
~
ments described herein.
- 17. 2.~ 12. 2 Procedural Control M&TE' utilized in activities.related to the operation of the WCGS shall be _ controlled in accordance with written proce-dures or instructions.
The procedures for the calibration and control cf M&TE shall address identification of the item y*
to be calibrated and test equipment, calibration techniques including acceptance tolerances, calibration frequencies, maintenance
- control, storage requirements and any special 6
instructions.
The equipment subject to these controls shall include measuring instruments, test instruments, tools, gaugas,
-reference standards, transfer standards, and nondestructive-test equipment employed in measuring, inspecting, and monitor-ing safety-related structures, systems, and components.
Per-manently installed process instrumentation is not included in this listing.
' Inspection, test, maintenance, repair, and other procedures shall include provisions to assure that M&TE employed in activities affecting quality are of the proper range, type, and. accuracy. to verify conformance to requirements and test parameters.
17.2.12.3 Program Requirements The calibration-and control program shall provide for:
1.
The assignment of specific calibration inter-valc for M&TE and calibration procedures which specify calibration methods and instrument accuracy requirements.
Interval selection shall be a function of the equipment type, inherent stability and reliability, intended
- use, required accuracy, and other conditions which may affect calibration.
Records shall be Rev. 10 17.2-44 4/83
SNUPPS-WC maintained to permit a determination of cali-bration intervals.
M&TE requiring periodic calibration will have a calibration label to indicate the due date of the next calibration.
6 This label will be attached to the instrument, or to its case where this is not practical.
A special calibration shall be performed when the accuracy of any M&TE is suspect.
2.
The unique identification of M&TE.
3.
The traceability to calibration test data.
4.
The traceability of reference standards to nationally recognized standards and the pe riodic revalidation of reference standards.
5.
The maintenance of recorN which indicate the status of each item of M&TE, maintenance his-tory, calibration results, anomalies, and most recent and next scheduled calibration dates.
A recall system shall be established to assure that equipment which is outside its calibra-tion interval is not used.
6.
The maintenance and control of M&TE not in use.
7.
Provisions to control purchase requirements and acceptance tests for M&TE sent out for calibra-tion and for new or replacement M&TE, including the requirements for accuracy, stability, and repeatability.
8.
The calibration of M&TE should be against a working standard having an accuracy of at least four times the specified tolerance of the M&TE.
When this is not practical, standards shall have an accuracy which assures that the equip-ment being calibrated will be within its re-quired tolerance.
Management review and ap-proval of calibration procedures provides authorization where any specific calibration
-ratio cannot be met or where calibrating stand-ards do not have greater accuracy than the M&TE being calibrated.
The controls stated above are also generally applicable to permanently installed process instrumentation.
The most 6
significant differences in the QA controls for the two differ-ent categories of instruments are:
1.
All M&TE used for acceptance measurements or calibration of sa fety-related plant instrumen-tation must be ccatrolled under this section.
Only safety-related permanently installed pro-cess instrumentation must be so controlled.
Rev. 10 17.2-45 4/83
SNUPPS-WC 2.
Separate administrative procedures are used for M&TE and permanently installed process instru-mentation.
3.
Calibratio., and replacement of M&TE is docu-mented on calibration laboratory records.
Re-pair, maintenance, and replacement of pe rman-ently installed safety-related process instru-mentation is controlled by a " Work Request" procedure including calibration.
4.
M&TE where practical should be calibrated 4
against standards four times as accurate as the
(,
- M&TE being calibrated.
Permanently installed safety-related process instruments are cali-brated against M&TE which are at least as accur-ate as the accuracy required of the process instrumentation being calibrated in accordance with written and approved procedures.
5.
M&TE is tagged or labeled to show the due date for next calioration.
Pe rmanently installed safety-related instruments are uniquely iden-tified and records are maintained which indi-cate calibration dates and the due dates for the next inspection / calibration.
17.2.12.4 Calibration Controls Calibration shall be performed against certified equipment or reference or working standards having known relationships to nationally recognized standards.
Where no national standard exists, provisions shall bc established to document the basis for calibration.
Special calibration and control measures shall not apply to rule rs, tape measures, levels, and other devices if normal commercial practice affords adequate accuracy.
17.2.12.5 Nonconformance Controls M&TE found to be out of calibration shall require an investi-gation to evaluate the validity of previous measuring, test, inspection, and calibration results and the acceptability of impacted items.
Inves tiga tions shall be documented and shall evaluate the necessity of repeating original measurements, inspections, tests, or calibrations to establish the accept-ability of such items.
When the calibration history of an item shows it to be consistently out of calibration, the item shall be
- repaired, replaced, or the calibration interval modified.
17.2.12.6 Records Records of KG&E plant calibration activities shall be main-tained by the plant staff.
Rev. 10 17.2-46 4/83
7.
Identification of Change Page 17.2-53 Reason for Change This upda ted page clarifies the fact that a Corrective Acticn Report is not required for conditions identified that, re reportable to the NRC under the rules of 10CFR50.55(e), 10CFR21, or other regulations.
Basis for Concluding that the Revised Program Satisfies 10CFR50 Appendix B Several mechanisms are available for meeting the require-ments of Criteria XVI, " Corrective Action," of Appendix B.
These include the KG&E Corrective Action Report system as well as NRC reportability regulations such as 10CFR50.55(e) and 10CFR21.
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i SNUPPS-WC l
17.2.16 CORRECTIVE ACTION l
[
.17.2.16.1 Scope Corrective action control measures shall be established' to assure that conditions adverse to quality are promptly iden-
- tified, reported, and corrected to preclude recurrence.
Corrective action is necessary to correct omissions and' prob-lems in the OQAP..
Corrective actions associated with the
-resolution. of NCRs,
- audit, and surveillance findings. are processed in ' accordance with Sections 17.2.15 and 17. 2.18, respectively.
Significant conditions adverse to quality which impede the implementation or reduce the effectiveness of the program shall. be controlled by the ' measures described herein. These l
conditions shall be reported to appropriate management, eval-
- uated, and corrected.
.Significant adverse' conditions may include an isolated gross noncompliance with procedural requirements, a recurring condition for which past corrective action has been ineffective, significant adverse noncon-l formance trends, or significant OQAP deficiencies.
17.2.16.2~: Corrective Action Report (CAR)
Procedures shall provide instructions for identifying, report-l ing, and initiating corrective action to preclude recurrence.
of significant adverse conditions.
A Corrective Action Report l 7
(CAR) shall be employed to document significant adverse condi-tions and to initiate the corrective actions for these condi-l tions ' except' 'in-those instances when 10CFR21 reports, 10CFR-50.55(e) reports. or ' similar regulation required reports 'are 7.
prepared.
CARS shall~ be initiated by : the. Quality Assurance Division.
CARS are transmitted to the responsible KG&E manager.
The manager _ shall-identify the cause(s) of the deficiency, specify the-action (s) necessary to correct the condition (s) and prevent recurrence, and provide or initiate the corrective
-' action.
Nuclear Plant. Engineering, Nuclear Services or the WCGS staff, as appropriate, shall review all significant conditions r
. adve rse 'to quality which involve - de sign deficiencies or recommended - corrective actions which require design change.
In such cases the appropriate engineering organization shall be responsible for cause identification and recomr:;ending corrective action.
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Rev. 10 17.2-53 4/83
r-4 8.
Identification of Change Table 17.2-1 Reason for Change The table was revised to provide ' a~better definition of the review and approval cycle for the various types of procedures contained in the Wolf Creek Generating Station Procedure Manuals.
Basis for Concluding that the Revised Program Satisfies 10CFR50 Appendix B Appendix B requirements for establishing and executing a review / authorization cycle for procedures have not been changed.
This cycle varies depending on the type of procedure.
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'IABLE 17.2-1 CONTROLLED PROCEDURE MANUAIS Identification Description Approval Wolf Creek Project A manual consisting of All mctions of this mnual Policy Manual-policies and general proce-will be reviewed and dures which have appli-ccanented upon by the Divi-cability to all project sion Heads.
personnel. 'Ihese documents establish specific responsi-Approval and issuance of bilities and authority of this manual and changes the individuals and organ-thereto will be by the Vica izations involved with the President-Nuclear.
project, and establish canon methods for activities performed by the nuclear divisions i
which nust be uniform.
Wolf Creek Generating
& multi-volum set of For the Operations organization, Station Procedure Manuals pro dures prepared all safety-related procedures by the plant staff with and all revisions thereto shall the aid of the other be revieaed by the ICGS Plant
. SNUPPS utility, the Icad Safety Review Ccmnittee (PSRC)
A/E, and the NSSS supplier.
or a subco mittee thereof. Final These procedures are approval of all procedures divided into teo areas, and revisions to the Operating i
Operations and Startup.
Organization procedures are The Oparations section of made at the apprcpriate mnage-the Station Manual are ment level as outlined in the controlled, issued and administrative procedures.. For approved in accordance the Startup organization, all with the applicable pro-procedures and charges thereto 6
cedural controls under are approved by the Joint Test I
the direction of the Group (J10) and the appropriate Plant Superintendent. 'Ihe management level in accordance Startup section of the with the applicable administra-Station Manual is con-tive procedures.
trolled, issued and approved in accordance QA personnel will revied the with the applicable pro-administrative and inspection cedural controls uMer procedures contained in this the direction of the manual and any revisions or Startup Manager. 'Ihese changes thereto.
procedures implemnt the requirem nt specified in the 00AM, where required, i
regarding WCGS internal i
and external interfacing
.of cperating quality activities. 'Ihese manuals include administrative con-trols for the coMuct of an
,)
Pev. 10 4/83
s TABLE 17.2-1 (IXfrIOLLED PROCEDURE MANUAIS Identification Description Apprwal Wolf Creek Project A manual consisting of All sections of this manual Policy Manual policies and general proce-will be revieded and dures whidt have appli-comented upon by the Divi-cability to all project sion Heads.
personnel. mese (bcuments establish specific responsi-Approval and issuanoa of bilities and authority of this manual ard dianges the individuals and organ-thereto will be by the Vice izations involved with the Presidant-!bclear.
project, and establish common methods for activities performed by the nuclear divisions which nust be uniform.
Wolf Creek Gemratig A nulti-volum set of For the Op3 rations Organization, Station Procedure Manuals proce3ures prepared all safety-relatM procedures by the plant staff with and all revisions thereto shall the aid of the other be revieaed by the WCGS Plant SNUPPS utility, the IcM Safety Review Comtittee (PSRC)
A/E, and the NSSS supplier.
or a subcomiittee thereof. Final mese procedures are approval of all procedures divided into two areas, and revisions to the Operating Oparations and Startup.
Organization procedures are me Operations section of nude at the apprcpriate manage-the Station Manual are ment level as outlined in the controlled, issued and administrative procedures. For app: oval in accordance the Startup Organization, all with the applicable pro-preoperational test procedures, 6'
cedural controls undar administrative procalures, and l
the direction of the dianges thereto are approved by l
Plant Superintendent. The the Joint Test Group (JIG) and l
Startup section of the the apprcpriate nanagenent level Station Manual is con-in accordance with the applicable trolled, issued and administrative procedures, approved in accordanca with the applicable pro-QA personnel will review the cedural controls undar administrative and inspection j
the direction of the procalares cortained in this Startup Manager. Wesa manual and any revisions or l
procelures implenent the chages thereto.
requirement spacified in i
the OQAM, where requtred, regarding WCGS internal ard external interfacing of operating quality l
activities. mese nunuals include administrative con-l trols for tk conduct of an Fev. 11
._