ML20076J038
| ML20076J038 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 06/10/1983 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8306200267 | |
| Download: ML20076J038 (36) | |
Text
r l
i%sconsm Electrw rom couem 231 W. MICHIGAN, P.O. BOX 2046, MILWAUKEE, WI 53201 June 10, 1983 Mr.
J. G. Keppler, Regional Administrator Office of Inspection and Enforcement, Region III U.
S. NUCLEAR REGULATORY COMMISSION 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
DOCKET NOS. 50-266 AND 50-301 SUBMITTAL OF QUALITY ASSURANCE PROGRAM DESCRIPTION POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 In accordance with the requirements of 10 CFR 50.54 (a) (2),
we are submitting the latest revision of Section 1.8 of our Final Safety Analysis Report (FSAR) for Point Beach Nuclear Plant which describes the present Quality Assurance Program being implemented for Point Beach.
This section was last submitted to the NRC on July 22, 1982 as part of our overall FSAR submittal in accordance with 10 CFR 50.71(e).
Changes in the program description since that time are highlighted in the attachment and are discussed below.
None of the changes indicated are considered to reduce Quality Assurance Program commitments previously accepted by the NRC.
Many of the changes are editorial, provide clarification, or are made to reflect current organizational structure and titles.
Those changes that are believed to be somewhat substantive in nature are summarized as follows:
1.
Page 1.8-2, Paragraph 1 This change was made to reference the requirement for NRC acceptance of changes to the Quality Assurance Program description in accordance with 10 CFR 50.54 (a) (2).
2.
Page 1.8-4, Paragraph 3 Additional organizational charts have been added to better define the organizational structures and interfaces in regard to quality-related activities for Point Beach.
Specifically, charts have been added to more extensively depict the Nuclear Power Department and Quality Assurance Division organizations.
8306200267 830610 /
DR ADOCK 05000266 p$
PDR I
,b l
4 Mr. J.
G.
Keppler June 10, 1983 3.
Page 1.8-5, Paragraph 3 The Off-Site Review Committee, as established by Technical Specifications, reviews various quality-related activities.
No actual change has been made in the Committee nor their activities, however, a brief summary of Committee activities has been added to the description to more fully acknowledge their involve-ment in quality-related matters at Point Beach.
4.
Page 1.8-6, Paragraph 1, Item 3 This change was made to reflect increased activity by the QA Coordinator in regard to technical audits of plant groups and their respective implementation of procedures.
5.
Page 1.8-6, Paragraph 3, Item 2 This change was made to reflect increased activity by the Quality Assurance Division in regard to procurement of quality assurance items or services.
6.
Page 1.8-7, Paragraph 2 As described in this paragraph, the Quality Assurance Program is applied to activities including fire protection and radioactive material packaging.
This change was made to clarify this application and reference the tables which specifically define program applicability.
7.
Page 1.8-7, Paragraph 3 Table 1.8-4, in the form of a matrix presenting the relationship between the program-description and implementing procedures, was deleted.
Since the implementing procedures have become more numerous and are subjected to regular revision and changes, it is difficult to maintain the matrix up-to-date in this document.
Also, we believe that information of this detail is not necessary in the program description.
8.
Page 1.8-8, Paragraph 1 Table 1.8-5, which summarized systems and equipment considered important to safety, has been deleted from the program description.
This list continues to be included in the Quality Assurance and Reliability Manual L
4 0
t Mr. J. G.
Keppler June 10, 1983 for Materials, Repairs, and Modifications as presently referenced in the description.
As indicated for the matrix of implementing procedures, this list is also subject to periodic change making it somewhat difficult to maintain current in this document.
We again believe that information of this detail is not necessary in the program description.
9.
Page 1.8-11, Paragraph 3; Page 1.8-13, Paragraph 5 These changes were made to provide clarification and further detail regarding qualification of suppliers, contractors, or subcontractors.
10.
Page 1.8-14, Paragraph 1 This change was made to reflect increased activity by the Quality Assurance Division in regard to monitoring of contractors providing quality assurance services.
11.
Page 1.8-14, Paragraph 2 Controls have been developed to allow the installation of materials or equipment pending the issuance of a Quality Assurance Release (QAR) number.
The procedures, however, require that the reasons for allowing installation to proceed be justified and resolution of any respective problems must occur prior to the item being placed into operation.
This change addresses this practice.
12.
Page 1.8-18, Paragraph 2 Reference to the means of controlling calibration periods through use of call-up cards in the preventative maintenance system has been deleted from the description.
This system continues to be utilized for this purpose, however, we believe this level of detail is not required in the program description.
l 13.
Page 1.8-20, Paragraph 1 l
This change reflects increased controls being implemented by the Quality Assurance Division in regard to identifi-cation and disposition of nonconforming items or conditions.
14.
Table 1.8-1, Item 13 Commitment to Regulatory Guide 1.146, as described, was l
made in response to NRC Generic Letter 81-01.
This l
i change reflects that commitment.
l l
l
Mr. J.
G. Keppler June 10, 1983 15.
Table 1.8-3 Clarification is being provided in the form of a footnote to address the applicability of design and test control to radioactive material packaging.
These criteria are not considered to be applicable to Wisconsin Electric activities, however, they are imposed upon contractors providing packaging and services.
If you have any questions on the attached information, please let us know.
Very truly yours, Vice President-Nuclear Power C. W. Fay Attachment Copies to NRC Resident Inspector NRC Document Control Desk, Washington, D. C.
(Original) l l
I
1.8 QUALITY ASSURANCE PROGRAM In accordance with Paragraph 50.34 of 10 CFR 50 and 71.24 of 10 CFR 71, a Nuclear Quality Assurance Program Description is herein provided by Wisconsin Electric Power Company (WE).
This Program is to assure that the required manpower, procedures, and management of Point Beach Nuclear Plant are directed toward satisfying the Company quality 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, Appendix E " Quality Assurance Criteria for Shipping Packages for Radio-active Material"; and the applicable Sections of the ASME Boiler and Pressure Vessel Code.
The program described is structured in accordance with the outline of the 18 Criteria of the Appendices.
The following describes the quality assurance program established and imposed by the Company' for application to the functional aspects of structures, systems, and components, including the design, purchasing, construction, and fabrication, handling, storage, shipping, cleaning, installation,
- erection, inspection, testing, operation, maintaining, refueling, repair, and modification of equipment considered significant to safety by the Company.
These structures, systems, and c'omponents may be classified as safety related in that they prevent or mitigate the consequences of postulated accidents, or as in the case of radioactive material packaging and fire protection, they may contribute to causing l
undue risk to 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 items are controlled in accordance with the quality programs and applicable codes which are necessary to provide assurance of quality commensurate with the importance of the overall function (s) to be performed.
l l
1.8-1
'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.
The Point Beach Nuclear Plant Quality Assurance Program commits to the guidance provided in ANSI N18.7-1976, except as hereinafter specifically noted.
Where exceptions are noted in the text of this section, the PBNP alternative system is discussed.
Commitment to ANS 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 Personnel ANSI N18.17-1973 Industrial Security for Nuclear Power Plants ANSI N45.1.1-1973 Cleaning of Fluid Systems and Associated Com-ponents 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 Require-ments for Instrumentation and Electric Equipment During the Construction of Nuclear Power Gen-erating 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 Plants Revision 1 June 1983 1.8-2 y.
ANSI N45.2.8-1975 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for the Con-struction Phase of Nuclear Power Plants ANSI N45.2.9-1974 Requirements for Collection, Storage, and Main-tenance of Quality Assurance Records for Nuclear Power Plants ANSI N45.2.10-1973 Quality Assurance Terms and Definitions ANSI N45.2.11-1974 Quality Assurance Requirements for the Design of Nuclear Power Plants ANSI N45.2.12, Requirements for Auditing of Quality Assurance
~
Draft 4, Rev.2 Programs for Nuclear Power Plants ANSI N45.2.13-1976 Quality Assurance Requirements for Control of Procurement Items and Services for Nuclear Power Plants 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, PBNP hereby commits to the above standards.
Table 1.8-1 provides further information regarding commitments to regulatory guides and related standards.
1.8.1 ORGANIZATION l
The authorities and responsibilities of persons and organizations perform-ing quality related activites are established, assigned, and documented in a formal system.
All quality assurance and quality control functions are performed by the Company QA organization (including both on-site and off-site personnel) except when the scope of specific projects indicate need to engage contractors to perform specific services.
l l
1.8-3
=,
Those persons and organizations assigned such functions are given appro-priate and sufficient authority and organizational freedom to identify quality problems; verify implementation of the solutions; and prevent further processing, delivery, installation, or use of nonconforming items until proper dispositioning has occurred.
The organizational structure and functional responsibility assignments are such that: (1) attainment of quality objectives is accomplished by individuals assigned responsibility for specifying quality or performing work to specifications, (2) audits verifying conformance to established quality requirements are accomplished by those who do not have direct responsibility for performing the work being verified, and (3) personnel in key quality assurance functions have direct access to responsible management.
The operating organization is reflected in Figure 15.6.2-2 of the Techni-cal Specifications.
The organization for quality assurance is reflected in Figures 1.8-1, 1.8-2, 1.8-3, and 1. 8-4.
The Vice President-Nuclear Power Department reports to an Executive Vice President.
The Vice President-Nuclear Power Department is responsible for establishing quality assurance policies, goals, and objectives.
Manager - Point Beach Nuclear Plant l
The Manager-Point Beach Nuclear Plant is the senior company representative l
at the plant facility and, as such, is in direct day-to-day control of all normal plant administrative, technical operations and quality assur-ance.
The Quality Assurance Coordinator reports to the Manager-Point Beach Nuclear Plant on quality related matters.
Quality Assurance Repre-sentatives report to the Quality Assurance Coordinator as members of the Quality, Standards & Records Organization as shown in Figure 1.8-3.
The QA Coordinator and the QA Representatives (including participation on the Quality Standards, & Records Organization) are concurrent assignments.
Revision 1 June 1983 1.8-4
Superintendent of Quality Assurance The Superintendent of Qualtity Assurance reports to the Vice President-Nuclear Power Department.
He is responsible for integrating the various quality assurance programs within the company including providing off-site quality assurance support for Point Beach.
Quality Assurance Committee The Wisconsin Electric Quality Assurance Committee, consisting of manage-ment representatives from participating departments within Wisconsin Electric and a consultant, reviews and selectively audits quality assur-ance policies, procedures, and practices.
The Chairman of the Committee is appointed by the Executive Vice-President and may be rotated among Committee members at his prerogative.
The Committee meets periodically, normally on a quarterly basis, to review the status of quality related activites.
Off-Site Review Committee The Off-site Review Committee (OSRC) is established in accordance with Technical Specifications, Section 15.6.5.3.
The OSRC selectively reviews designated activities involving the operation of Point Beach Nuclear Plant including Technjcal Specification Compliance.
Specific duties and responsibilities are described in the plant Technical Specifications, Section 15.6.5.3.
Education and Experience The education and experience requirements of individuals assigned to QA positions are documented and are approved by management.
The respon-l sibilities of individuals or groups performing QA functions are documented
}
i and approved by management.
General responsibilities are as follows:
QA Coordinator 1.
Assist plant groups on matters dealing with quality, codes and standards interpretation, interpretation and applica-Revision 1 June 1983 1.8-5
tion of the in plant quality assurance manuals, regulatory records keeping and regulatory inspection activities.
2.
Administer the quality assurance and control aspects of ordering, storing, use, and documenting of quality assur-ance spare parts and equipment in the plant.
3.
Perform technical audits of plant groups with respect to the adequacy and implementation of quality assurance pro-cedures and instructions and the adequacy of documentation (Section 1.8.18).
QA Representative 1.
Report to the QA Coordinator observed documentation or physical infractions of quality assurance procedures and instructions or suspected violations of Technical Specifi-cation, State and Federal codes or standards, and commit-ments to Regulatory Guide positions.
l 2.
Assist their respective group in conforming with the Operating Point Beach Nuclear Plant Administrative Control Policies & Procedures Manual.
3.
Maintain and help coordinate the required storage of quality assurance records pertaining to their respective groups.
Quality Assurance Division 1.
Review QA scope purchase documents to assure adequate quality requirements (Section 1.8.4) are established.
2.
Verify the adequacy of received items thrcugh various activities including source verification, as appropriate, and review documentary evidence of quality for procured
(
items prior to release of the items (Section 1.8.7).
i 3.
Perform quality assurance evaluations of offsite vendors and contractors commensurate with the importance, complexity, and quantity of the product or services and assure vendor compliance l
with established requirements through audit and surveillance I
activities (Section 1.8.7).
Revision 1 June 1983 1.8-6
..y
..-,-r
4.
Perform audits of the quality assurance program as implemented on-site by Plant personnel and contractors (Section 1.8.18).
1.8.2 QUALITY 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, Appendix E.
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 addressed in Tables 1.8-2 and 1.8-3, respectively.
The Point Beach Nuclear Plant Quality Assurance Program is set forth in the Administra-tive Control Policies and Procedures Manual (QA Volume I) and the Quality Assurance & Reliability Manual for Materials, Repairs and Modifications (QA Volume II).
Control of the above manuals is as follows:
1.
Distribution of the Administrative Control Policies & Proced-ures Manual (QA Volume I) and revisions thereto is controlled by Point Beach Nuclear Plant.
The manual is reviewed and approved on-site by the plant organization.
2.
Distribution of the Quality Assurance and Reliability Manual for Materials, Repairs and Modifications (QA Volume II) and revisions thereto is controlled by the Superintendent of Qual-ity Assurance.
The Manual is reviewed and approved by the Superintendent of Quality Assurance and the Vice President-Nuclear Power Department.
Final responsibility for modifications, repairs, maintenance, and opera-tions, including the quality assurance program, lies with the Executive Vice President.
Management review of the status and adequacy of the quality assurance program is accomplished by at least semiannual review by the WE QA Committee (Section 1.8.1) and by regular briefings (at least once every two months) with the Executive Vice President.
Revision 1 June 1983 1.8-7
The quality assurance program applies to structures, systems and compon-ents (including expendable and consumable items which are used therein) which are considered important to safety from the standpoint of safety-related functions to be performed.
The structures, systems and compon-ents considered important to safety are identified in the Quality Assurance
& Reliability Manual for Materials, Repairs, and Modifications (QA Volume II).
The classification of a system or component as important to safety does not imply that the complete system, or all the components or component parts within that system, are important to safety.
Those specific items within a system consiaered important to safety are also identified in QA Volume II.
The program provides for indoctrination and training of personnel per-forming activities affecting cuality as necessary to assure that suitable proficiency is achieved and maintained.
The indoctrination and training program is structured to assure that:
1.
Personnel performing quality activities are instructed as to the purpose, scope and implementation of the quality related manuals, procedures and instructions; and it is emphasized that these are mandatory requirements which must be implemented and enforced.
2.
Personnel performing quality related activities are trained and qualified in the principles and techniques of the activity being performed.
s 3.
Appropriate training procedures are established.
Section 5.2.10 of ANSI N18.7-1976 states that the provisions of ANSI N45.2.3-1973 shall be applied to those activities which are compar-able in nature and extent to related activities occurring during construc-tion.
Revision 1 June 1983 1.8-8
1 Point Beach Nuclear Plant practices good housekeeping and cleanliness involving activities performed by plant and contractor personnel to maintain the necessary standard of cleanliness.
Scheduled and documented daily-to-weekly surveys of potentially contam-
-inated or radioactive areas conducted by health physics personnel, fol-lowed by decontamination or radioactive cleanup as necessary, ensure cleanliness checks of even the least traveled areas.
An additional l
program provides that Operations shifts are assigned specific plant areas to patrol and clean up as a housekeeping duty.
Plant policy endorses and enforces the concept that each person 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 inspec-tions of pressure vessels, tanks, etc., are routinely completed by super-visory 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 con-tractors.
Storage of items, combustible or otherwise, are more properly controlled to defined quality assurance or fire protection requirements.
Access to safety-related equipment or radiation controlled areas is more properly controlled by security regulations or defined health physics rules.
P8NP complies with OSHA regulations in the physical safety and environ-mental condition of work places.
Personal and detailed housekeeping inspections of portions of the plant are made frequently by the Manager-Point Beach Nuclear Plant with a complete and in-depth inspection of essentially the total plant on a weekly basis.
Revision 1 June 1983 1.8-9
1.8.3 DESIGN CONTROL Procedures and practices are established and documented to assure that applicable regulatory requirements and design bases are correctly trans-lated 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 materi'ls, parts, equip-a ment, and processes that are essential to the safety related function.
Procedures and practices are established and documented for the identi-fication and control of design interfaces and for coordination among design organizations.
These include procedures among participating design 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 alter-nate 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 a specific design l
feature, provisions include suitable qualification testing 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, maintenance and repair; and delineation of accept-ance criteria for inspections and tests.
l Further changes to designs are subjected to commensurate design control l
measures. When a contemplated change is considered by appropriate manage-ment to be of sufficient scope as to be beyond the expertise of in-house personnel, these changes are reviewed by the organization that performed the original design, or other design organizations determined to be l
equally qualified.
Section 5.2.7.2 of ANSI N18.7-1976 requires that Revision 1 June 1983 1.8-10
design activities associated with modifications of safety related struc-tures, systems and components be performed in accordance with the provis-ions of ANSI N45.2.11-1974.
Design activities associated with modifica-tions are accomplished in accordance with the provisions of Section 8 of ANSI N45.2.11-1974.
1.8.4 PROCUREMENT DOCUMENT CONTROL Procedures and practices are established and documented to provide assur-ance that applicable regulatory requirements, design bases, and other requirements which are necessary to assure adequate quality are included or referenced in the documents for procurement of materials, products, or services.
These measures are applied to spare and replacement parts and equipment, new materials and equipment and contracting of services.
Procedures require that procurement documents be prepared, reviewed, and approved in accordance with QA program requirements.
The Quality Assur-ance Division reviews procurement documents to ensure the inclusion of adequate quality criteria.
Records of the review are maintained to provide auditable documentation.
Procurement documents require suppliers, contractors, or subcontractors to implement quality assurance programs to the extent necessary.
The programs are reviewed by the QA Division, qualified contractors, or industry organizations such as the Coordinating Agency for Supplier Evaluation (CASE).
Concurrence with the adequacy of supplier programs is documented.
r Further details of the system for control of procurement documents is contained in Section 1.8.7.
1.8.5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS Activities affecting quality are prescribed by documented instructions, procedures or drawings appropriate to the work at hand with the work accomplished in accordance with these documents.
Measures have been established for the preparation and revision of procedures, instructions, or drawings and for control of these documents.
j Revision 1 June 1983 1.8-11 L
Instructions, procedures, and drawings are required to include appro-priate 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 forehand knowledge of the acceptance criteria may prejudice results.
The Supervisor is then reponsible to verify conformance.
To the extent applicable, as-built drawings and original equipment and system specifications establish acceptance criteria, sub-ject to improvements based upon operational experience.
When required, these instructions, procedures, and drawings provide methods for com-plying 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 Super-visor who holds a senior operators license.
As described in Section 15.6 of the Technical Specifications, Point Beach follows the above guidance for operating procedures.
For Maintenance, Instrumentation and Control, Reactor Engineering, and Chemistry and Health Physics procedures, approval is not required from the supervisor in charge of the shift for temporary 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 proced-ures, states in part, "... procedures shall include, as appropriate...(8)
Acceptance Criteria."
PBNP has determined through considerable exper-ience that the incorporation of acceptance criteria is not always advan-l tageous, as discussed herein.
l 1.8.6 DOCUMENT CONTROL Procedures and practices are established and documented to control the issuance of documents; such as maintenance and modification procedures; design specifications; design manufacturing, construction, and instal-lation drawings; procurement documents; manufacturing, inspection, and 1.8-12 t
testing instructions; test and operating procedures; and QA manuals, safety analysis reports, and related design criteria documents; including all changes thereto.
These include indentification of the group respon-sible for review, approval, and issuance of the documents.
For quality related documents, the review includes the adequacy of incorporation of quality requirements.
The procedures provide assurance that documents, including changes, are reviewed for adequacy and approved for use by authorized personnel and are distributed to and used at the location where 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.
Documents classified as QA records are subjected to the additional require-ments described in Section 1.8.17.
1.8.7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, 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 plant initiated purchase requisitions by the QA Coordinator or his designee and subsequently, QA scope requisitions are reviewed by the QA Division to verify incorpora-tion of appropriate quality requirements.
Additionally, all Nuclear Engineering Section initiated requisitions are reviewed by the QA Division.
The bases for selection of suppliers include previous experience, meeting the required qualifications of the contractor who erected the Plant on a i
" Turnkey" basis, or a pre-award evaluation of the proposed supplier's capabilities and qualifications.
Industry programs, such as those applied by the American Society of Mechanical Engineers (ASME) and the Coordinating Agency for Supplier Evaluation (CASE), are used as input or the basis for supplier qualification whenever appropriate.
Revision 1 June 1983 1.8-13
Control of purchased items includes provisions, as appropriate, for l
source evaluation and selection, objective evidence of quality furnished by the contractor or subcontractor, inspection at the source, and examina-tion of products at receipt.
These controls also include provisions for monitoring contractors 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 importance, complexity, and quantity of the product or services.
The requirements of ANSI N45.2.13-1976 are met for the procurement of components within the s' cope of Section 5.2.13 of ANSI N18.7-1976.
1Property "ANSI code" (as page type) with input value "ANSI N18.7-1976.</br></br>1" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..8.8 IDENTIFICATION AND CONTROL 0F MATERIALS, PARTS, AND COMPONENTS Procedures and practices are established and documented requiring identi-fication of materials, parts, and components, including partially fabri-cated assemblies, to prevent use of incorrect or defective items.
Identi-fication 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.
Identi-fication methods and locations are selected so as not to affect the function or quality of the item.
I These measures assure that identification is maintained by stock number, system identification, part number, or other appropriate means, either on Revision 1 June 1983 1.8-14 l-
the item or on records traceable to the item, as required during instal-lation and use.
These measures apply to Plant personnel and on-site con-tractors.
Procurement documents invoke appropriate requirements for identification and control of material during manufacture, including provisions for in process audits of the manufacturer's program which allow the licensee the option of auditing the vendor.
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 accortplished by qualified personnel using qualified procedures or process sheets in accordance with applicable codes and standards.
Verification of conformance is documented.
These measures require copies of qualifications to be on site during process performance whether by WE personnel or contractors.
Procurement docu-ments specify appropriate control requirements for processes performed off-site.
1.8.10 INSPECTION Procedures and practices are established and documented providing for appropriate inspection of activities affecting quality and to verify conformance with the documented instructions, procedures, drawings, or specifications for accomplishing the activity.
Inspection procedures, instructions, and checklists include the following, as applicable:
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.
1.8-15
Maintenance, replacement, or rework items are inspected in accordance with original inspection requirements or improved requirements based on operating experience.
Modified items are inspected by methods at least equivalent to the original inspection methods.
These measures provide for verification of conformance to be performed by appropriately qualified individuals other than those who performed the activity.
Quality control inspections may be performed by a workman's first line supervisor; however, quality assurance acceptance is not per-formed by the first line supervisor or anyone reporting to him.
Qualifi-cation of these individuals in accordance with appropriate requirements is documented.
Provisions for Code Authorized Inspection are included when required.
Examinations, measurements, 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 opera-tions where necessary to assure quality.
Storeroom personnel perform receiving inspection on procured materials as appropriate for the procure-ment 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 Coordinator or Division.
Procurement documents for materials or products, 1
for which direct inspection is impossible or disadvantageous, specify provisions for indirect control by monitoring processing methods, equip-ment, and personnel.
When control is inadequate without both inspection and process monitoring, provisions for both are included.
Mandatory hold points are specified and used where required.
Section 3.4.2. of ANSI N18.7-1976 states that personnel performing inspec-
- tion, 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 qualifi-cation 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 or work l
of contractors as inspection and test personnel.
1.8-16 l
i
All jobs at Point Beach have been evaluated to determine the minimum qualification requirements.
The areas considered during the evaluation included regulation, code and standard requirements, education and train-ing, work experience, and physical condition.
Applicants for jobs at Point Beach who do not meet the minimum requirements, or who do not pass a battery of preemployment aptitude tests are not considered for the position.
Additionally, prior to being hired, almost all plant personnel are interviewed by the Manager-Point Beach Nuclear Plant who makes the l
final determination of acceptability.
There is only one level of qualifi-cation at Point Beach, not three levels as indicated in ANSI N45.2.6-1973.
When the extent of the maintenance or modification is such that it must be performed by contract, the potential contractor's QA program is evalu-ated by the QA Division to determine its acceptability.
Included in the evaluation is consideration of the qualifications of inspection and test personnel.
In cases where it is determined that a contractor's organiza-tion 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 of SNT-TC-1A.
l Section 3.2 of ANSI N18.7-1976 requires that verification of conformance l
be performed by individuals other than those who performed or directly supervised the work.
It can be demonstrated that verification of con-formance is conducted in this manner at Point Beach.
Section 5.2.17 of ANSI N18.7-1976 requires inspections for modifications and non-routine maintenance be performed in a manner similar to that l
l associated with construction phase activities.
Modifications and non-routine maintenance for which outside contractors are utilized are per-formed in this manner.
Modifications and non-routine maintenance items within the capablities of the onsite operating organization are performed as routine maintenance.
Revision 1 June 1983 l
1.8-17
1.8.11 TEST CONTROL Procedures ano practices are established and documented to provide a pro-gram 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 in accordance with written test procedures which incorporate the requirements and acceptance limits (except as noted in Section 1.8.5) from applicable design docu-ments by appropriately trained and qualified personnel.
Test procedures include provisions for assuring that all prerequisites for the test have been met, that adequate test instrumentation is available and used, and the test is performed under suitable environmental conditions.
Test results are documented and evaluated to assure test requirements have been satisfied.
These measures require replacement or modified struc-tures, systems and components to be subjected to sufficient proof, preop-erational, and operational testing to demonstrate that they will perform satisfactorily in service.
1.8.12 CONTROL OF MEASURING AND TEST EQUIPMENT Procedures and practices are established and documented to assure that tools, gauges, instruments, and other measuring and testing devices used in activities affecting quality are properly indentified, controlled, calibrated, and adjusted at specific periods to maintain accuracy within necessary limits.
Calibration procedures specify standards to be used for performing the calibration; procedure preparation assures that stan-dards 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 condi-tions are noted.
1.8.13 HANDLING, STORAGE, AND SHIPPING Procedures and practices are established and documented to control the handling, storage, shipping, cleaning, and preservation of material and Revision 1 June 1983 1.8-18
equipment in accordance with work and inspection instructions by quali-fied individuals to prevent damage or deterioration and preclude loss of identification.
The measures include specification and use, when nec-essary, 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 include provisions for the identifica-tion of items which have satisfactorily passed required inspections and tests when necessary to preclude inadvertent bypassing of such inspec-tions and tests.
Procedural controls to perform operations out of sequence are included in QA Volume I.
These measures also include pro-visions for indicating nonconforming, inoperative, or malfunctioning components within a system to prevent inadvertent operation.
1.8.15 NONCONFORMING MATERIALS, PARTS, OR COMPONENTS Procedures and practices are established and documented to control mater-ials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation.
For purchased mater-fal, parts, or components, these measures may include timely return of l
nonconforming materials, parts, or components to the vendor for replace-ment with satisfactory items.
This obviates the needI for a complex nonconformance control system of reports, followup, and trending.
Maintenance request forms provide identification and control of noncon-forming items requiring repair or rework to be returned to satisfactory condition.
Where a safety related component is required to be temporar-ily 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 reauest piocedure.
This also obviates the need for a separate nonconformance control system of reports, followup, and trending.
Revision 1 June 1983 1.8-19
\\
The QA Division also has established provisions for documenting and dispo-sitioning nonconforming items or conditions, which are identified during inspection, surveillance or-auditing activities.
1.8.16 CORRECTIVE ACTION Procedures and practices are established and documented to assure that conditions adverse to quality; such as failures, malfunctions, deficien-cies, deviations, defective material, and equipment and nonconformances; are promptly identified and corrected.
In the case of significant condi-tions adverse to quality, these measures include assurance that the cause of the condition is determined and corrective action taken to preclude repetition.
These include provisions for identification of the signifi-cant condition adverse to quality, the cause of the condition and the corrective action taken to be documented and reported to appropriate levels of management.
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 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 per-formance, and materials analyses.
Also included are closely related data such as qualifications of personnel, procedures and equipment.
Inspec-tion and test records include, as a minimum, identity of the inspector or data recorder, the type of observation, the results and the accepta-bility, or action taken in connection with any deficiencies noted.
Records are required to be identifiable and retrievable.
Requirements concerning records retention; such as duration, location, and assigned responsibility; are established to be consistent with applic-able regulatory requirements.
A record storage facility is used with controlled access to prevent destruction of records by fire, flooding, Revision 1 June 1983 1.8-20
l theft, and deterioration by environmental conditions, such as temperature i
or humidity.
In 1971, Point Beach recognized the need to improve its records manage-ment program in the area of preservation of records.
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 we.'e studied, and it was determined that the lower level of the Energy Information Center located on the plant grounds, offered an ideal j
location for a records storage facility.
This location was chosen as it was an area of minimum weight of combusti-bles and the building itself was fire resistant.
It was determined, based on the above factors, that a separate room would be constructed in the lower level of the Energy Information Center to provide further pro-tection.
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 alarm signal and a visible alarm which is monitored by the guard force.
Based on the analysis of the fire hazard present in the Energy Informa-l tion Center alarm system, and the sophisticated fire suppression system, l
it was decided that the requirement for a four-hour vault door was unneces-sa ry.
The entrance to the room is closed with a Class A 250 F labeled fire door.
In addition, the fire suppression system required an electri-cal supply, which led to the waiving of the requirement that walls could not be penetrated by electrical conduit.
The electrical supply for the l
r Revision 1 June 1983 i
1.8-21
room is brought into the room via a conduit through one of the walls 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 documented to provide a comprehensive system of planned and periodic audits to verify compli-ance 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 in plant QA program is audited periodically, j
normally quarterly, by the QA Coordinator or his designee and quarterly by the QA Division.
On-site and off-site contractor audits are timed as appropriate for the work scheduled.
Audit results are documented and reviewed by management personnel having responsibility in the area audited.
Audit reports are routed to manage-mentment 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 possible trends adverse to the effectiveness of the QA program, these data shall be 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 provisio, of proposed ANSI N45.2.12, Draft 4, Revision 2, dated January 1,1976, shall be used for audits performed to meet the requirements of Section 4.5.
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 technically qualified personnel, in lieu of quality assurance personnel, because of special technical competence which may be required to perform the review.
WE strongly endorses this position and has assigned certain review and g
Revision 1 June 1983 1.8-22
audit functions within the plant to technically qualified personnel in j
lieu of quality assurance personnel.
Sufficient audits are performed in accordance with the provisions of ANSI N45.2.12 to meet the requirements therein; however, the technical I
audits are not performed under ANSI N45.2.12 requirements.
f J
J l
I I
e i
i E
I l
l l
l 1
l l
l 1.8-23
TABLE 1.8-1 COMMITMENT TO REGULATORY GUIDES AND ANSI STANDARDS 1.
Regulatory Guide 1.8 (Safety Guide 8) dated March 10, 1971 Full commitment except that Point Beach commits to ANSI N18.1-1971 in lieu of the proposed ANSI N18.1 dated June 22, 1970.
2.
Regulatory Guide 1.28 (Safety Guide 28) dated June 7, 1972 ANSI N18.7-1976 states in part, "This standard fully and com-pletely 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.
Point Beach does, however, commit to the position of Regulatory Guide 1.28 to the extent of requiring its vendors to have qual-ity assurance programs which meet the appropriate requirements of ANSI N45.2-1971 as mentioned in Section 5.2.13.1 of ANSI N18.7-1976.
3Property "ANSI code" (as page type) with input value "ANSI N18.7-1976.</br></br>3" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
Regulatory Guide 1.30 (Safety Guide 30) dated August 11, 1972 Commitment to follow the position of Regulatory Gude 1.30, which endorses and supplements ANSI N45.2.4-1972, for activities occuring during the operational phase that are comparable in nature and extent to related activities during construction.
l 4.
Regulatory Guide 1.37 dated March 16, 1973 1
l 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 occurrin~g during con-struction.
TABLE 1.8-1 (Continued) 5.
Regulatory Guide 1.38, Revision 1, dated October 1976 Commitment to follow the position of Regulatory Guide 1.38, which endorses and supplements ANSI N45.2.2-1972, for activit-ies occurring during the operational phase that are comparable in nature and extent to related activiti5s occurring during construction.
6.
Regulatory Guide 1.39, Revision 1, dated October 1976 Commitment to follow the position of Regulatory Guide 1.39, which endorses and supplements ANSI N45.2.3-1973, for activit-ies occurring during the operational phase that are comparable in nature and extent to related activities occurring during construction except that Point Beach does not commit to the documentation requirements of ANSI N45.2.3-1973 and provides an
-alternative to the housekeeping zone requirements therein.
Description of these differences are provided in Section 1.8.2.4.
7.
Regulatory Guide 1.54 dated June 1973 Commitment to follow 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.
8.
Regulatory Guide 1.58 dated August 1973 Commitment to follow the position of Regulatory Guide 1.58, which l
endorses and supplements ANSI N45.2.6-1973, for activities occurring in the operational phase that are comparable in nature and extent to related activities during construction, except that Point Beach does not commit to the levels of qualification nor separate certifica-tion requirements of ANSI N45.2.6-1973.
Description of these differ-ences are provided in Section 1.8.10.6.
TABLE 1.8-1 (Continued) 9.
Regulatory Guide 1.64 dated October 1973 Commitment to follow the position of Regulatory Guide 1.64, except that Point Beach commits to ANSI N45.2.11-1974 in lieu of Draft 3 Rev. 1 dated July 1973, for design activities associated with modif-ication 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 Commitment to follow the position of Regulatory Guide 1.88, which endorses and supplements ANSI N45.2.9-1974 and NFPA 232-1970.
Point Beach has determined that the existing records storage facility pro-vides a level of protection to the vital records at the plant which is equivalent to the requirements of Regulatory Guide 1.88.
Des-cription of the differences are provided in Section 1.8.17.5.
12.
Regulatory Guide 1.94 dated April 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.
j l
13.
Regulatory Guide 1.146 dated August 1980.
I Commitment to follow the position of Regulatory Guide 1.146, which endorses ANSI N45.2.23, for audits of in plant activities which are performed by Point Beach Nuclear Plant organizations.
14.
l Refer to Section 1.8.0 for details of the Point Beach commitment.
Revision 1 June 1983 l
TABLE 1.8-2 SUBSECTIONS OF SECTION 1.8 APPLICABLE TO THE FIRE PROTECTION PROGRAM Subject 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 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
TABLE 1.8-3 SUBSECTIONS OF SECTION 1.8 APPLICABLE TO SHIPPING PACKAGES FOR RADIOACTIVE MATERIALS (10 CFR 71, APPENDIX E)
Subject 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 Control of 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 Control
- 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 Point Beach Nuclear Plant personnel.
However, these activities are imposed on suppliers providing radioactive material packaging or associated services, as appropriate.
Revision 1 June 1983
3 8
9 1
enuJ t
r gp o
ne t
i D c
s 1
e as s
r he e
i cr t
c D
ro n
i ut e
v PS d
r i
e s
S T
e N
l r
g A
P n
n L
i t
o P
e t
n i
c a
e
&t R
i r
d c
A V
e n
ye E
p e tt L
O t
io NC n
rr OU i
uP IN r
c T
I l iI l
l l l l I i e
e ee AH
)
e 2
p Sr ZC t
u i
IA t
t S
F NE n
i 8
AD e
m G
t r
d m
RT n
et 1
o e
wn ON 1
i 1
s C
I d
oe YO e
i Pn e
D A
NP J
r s
t r
R P
Q A
A e
rr u
PO O
r aa g
MT B
P ep i
O l e F
E e
cD CEC l
c u
e RA iT t
i N
e EF n
V S
WR F
1 e
I OE O
ed PT vi N
N i s CI A
te I
I ur RE M
R cP TC I
e CN I
xe A
EA I
Ec t
LR C
iV t
t p
EU n
&e S
n e
D NS e
d d
g IA i
nn S
ri s
io NY os i e e
ri OT nr l
r et CI eP P
ir WU c
gt Q
c i
ns iV V
En H
o T
C IW 1
8 1
t i
t n
at n
s e
tn e
e e
d r
ne d
cn r
ri o
em n
io os t
mt e
vi u
i e c
nr t
rs g
I nr e
oa n
ei i
eP r
rp i
Sv F
S i
i e r
i e
D vD e
bD c
n p
a i
E u
L V
S
1 VICE PRESIDENT i
e 4
ADMINISTRATOR SPECIAL PROJECTS f
POINT BEACH NUCLEAR PLANT NUCLEAR ENGINEERING SECTION QUALITY ASSURANCE DIVISION AGER SUPERINTEE M MANAGER l
Quality Assurance Senior Engineer Coordinator 1
i Quality, Standards Nuclear Quality
& Records Organization Assurance Group (See Figure
- 1. 8-3)
(See Figure 1.8-4) l l
Figure 1.8-2.
NUCLEAR POWER DEPARTMENT ORGANIZATION l
June 1983 i
1
i
+
1 P
r j
QA COORDINATOR 1
l Quality Engineer a
i
)
i i
t 4
i i
QA Rep QA Rep QA Rep QA Rep Operations Maintenance Training I &C l
i i
QA.tep QA Rep QA Rep Chemistry Reactor ta H Sem.ces
& H.P.
Engineering _
I l
i l
PBNP QUALITY, STANDARDS Figure 1. 8-3. & RECORDS ORGANIZATION June 1983
a 1
SUPERINTENDENT b
i l
1 i
Procurement plans, Training Nuclear QA Fossil QA Construction QA/
l Quality Services
& NDE Group Group Group Fossil QC l
Group Group i
Senior Engineer i
Audits & Surveys Quality Quality Support Unit Engineerin9 Unit Unit I
i i
1 Figure 1.8-4.
QUALITY ASSURANCE DIVISION ORGANIZATION I
i June 1983
.I