ML20079F132
| ML20079F132 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 01/13/1984 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Jay Collins, Harold Denton NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), Office of Nuclear Reactor Regulation |
| References | |
| KMLNRC-84-004, KMLNRC-84-4, NUDOCS 8401180114 | |
| Download: ML20079F132 (62) | |
Text
KANSAS GAS AND ELECTRIC COMPANY THE ELECTHeC COMPANY GLENN L KOESTER v<t per seof %f - mucos ae January 13, 1984 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. John T. Collins, Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 KMLNRC 84-004 Re:
Docket Nc. STN 50-482 Subj: Quality Assurance Program Changes Gentlemen:
10CFR50.55 requires that after March 11, 1983, each Corstruction Permit holder may change a previously accepted Quality Assurance Program description included in the Final Safety Analysis Report, provided the change does not reduce the commitment in the program previously accepted by the NRC.
Transmitted herewith are changed pages to the Wolf Creek Operating Quality Program described in the Wolf Creek Einal Safety Analysis Report. The attached material also describes for the above changes 1) the reason for the change, and 2)the basis for concluding that the change does not reduce the KG&E commitments in the Operating Quality Program previously accepted by the NRC.
This information will be for.aally incorporated into the new revision of the Wolf Creek Final Safety Analysis Report. The information is hereby incorporated into the Wolf Creek Generating Station, Unit No.1, Operating License Application.
Yours very truly, GLK:bb Attach cc: JHolonich (2), w/a WSchum, w/a f
)g8L 8401180114 840113 PDR ADOCK 05000482 A
PDR g
i 201 N. Market -Wichtta, Kansas - Mail Address: PO. Box 208 I Wichita, Kansas 67201 - Telephone: Area Code (316) 261-6451
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i OATH OF AFFIRMATION STATE OF KA';SAS
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COUNTY OF SEDGWICK )
i I, Glenn L. Koester, of lawful age, being duly sworn upon oath, do depose, state and affirm that I am Vice President - Nuclear of Kansas Gas and j
Electric Company, Wichita, Kansas, that I have signed the foregoing letter l
of transmittal, know the contents thereof, and that all statements contained therein are true.
KANSAS GAS AND ELECTRIC COMPANY By g
Glenn L.
Koester j
Vice President - Nuclear E.D. Prothro, Assistant Secretary I
i STATE OF KA'1SAS
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) SS:
COUNTY OF SEDCdICK )
BE IT REMEM3ERED that on this 13th day of January, 1984
-, - before me, Evelyn L. Fry, a Notary, personally appeared Glenn L. Koester, Vice President - Nuclear of Kansas Gas and Electric Company, Wichita, Kansas, who is personally known to me and who executed the foregoing instrument, i
and he duly acknowledged the execution of the same for. and on behalf of and as the act and deed of said corporation.
IN WITNESS WHEREOF, I have hereunto set my hand and affixed my seal the f(,1..[..cfate,, and year above written.
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. Commission expires on August 15, 1984.
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Attachment to KMLNRC 84-004 Revisions to the Final Safety Analysis Report Addendum and the reasons for the revisions are shown by numbered bars next to the modified text.
The numbers correspond to the reasons given below.
1.
Reason for Chance This change updates the organizational description and division of responsibility to be consistent with the revised organizational structure.
Basis for Concluding that the Revised Program Satisfies 10CFR50, Appendix B The revised organizational description provides delineation of the authority and duties of positions performing quality functions.
These organizational elements maintain sufficient authority and independence as required by Appendix B.
2.
Reason for Change This change is editorial and clears up a potential ambiguity in the text.
Basis for Concluding that the Revised Program Satisfies 10CFR50, Appendix B The text has been modified to more clearly describe the Wolf Creek Program.
No program changes have been made with regard to this text change.
3.
Reason for Change This change deletes potentially misleading and/or confusing text.
Basis for Concluding that the Revised Program Satisfies 10CFR50, Appendix B The text has been modified to more clearly describe the Wolf Creek Program.
The program has not been revised with regard to this text change.
4.
Reason for Change This change modifies the text to be consistent with portions of the FSAR which were previously revised.
Basis for Concluding that the Revised Program Satisfies 10CFR50, Appendix B fio program change has been made with regard to this text change.
5.
Reason for Chance The position of Director Quality is a new position created by the organiza-tional change. The experience requirements for this position are different from those of the position of f4anager Quality Assurance. The new requirements are consistent with the guidelines of AflSI/ANS 3.1-1978.
Basis for Concluding that the Revised Program Satisfies 10CFR50, Appendix B The change is consistent with the guidelines of ANSI /ANS 3.1-1978.
6.
Reason for Change The change was made to expand and clarify the description of the purpose of the Quality Program Manual.
Basis for Concluding that the Revised Program Satisfies 10CFR50, Appendix B No change was made to the program with regard to these text changes.
7.
Reason for Change In accordance with the organizational changes described above, the Director Quality is now responsible for equipment inspection.
Basis for Concluding that the Revised Program Satisfies 10CFR50, Appendix B Although the position responsible for implementation of this program has changed, the function of the program has not changed.
SNUPPS-WC CHAPTER 17.0 QUALITY ASSURANCE 17.2 QUALITY ASSURANCE DURING THE OPERATION PHASE 17.
2.0 INTRODUCTION
17.2.0.1 Scope This chapter of the FSAR sets forth the requirements for establishing and maintaining an operating quality program (OQP) for the Wolf Creek Generating Station (WCGS) during the operations phase.
The program provides control over activ-ities affecting quality as required by 10 CFE 50, Appendix B, and is structured to comply with NRC Regulatory Guide 1.33.
17.2.0.2 Corporate Policy The policy of Kansas Gas and Electric Company (KG&E) is to
- develop, implement, and maintain the OQP for the WCGS as l regulated by provisions of the Nuclear Regulatory Commission (NRC) operating license and amendments thereto.
The program is applied to those activities regarding structures, systems, and components necessary to assure:
1.
The integrity of the reactor coolant pressure boundary 2.
The capability to shut down and maintain the reactor in a safe shutdown condition 3.
The capability to prevent or mitigate the con-sequences of accidents which could result in offsite exposures comparable to the guideline exposures of 10 CFR 100.
17.2.0.3 Program Applicability _
The activities controlled by the OOP include preoperational le testing, startup testing, operations, maintenance, refueling and modifications.
Also controlled by the OQP are certain p construction completion activities such as component tests,g; flushing, and hydrostatic tests performed by the KG&E startup organization.
The extent of control over these activities as they affect quality is consistent with their importance to nuclear safety.
l Early implementation of the OOP is not intended to require l' l
activities to be performed earlier than would be the case if l
they were performed under the Design and Construction QA Program.
When structures, systems, or components are released a
by the construction forces to the KG&E startup organization, l
Rev. 11 17.2-1
SNUPPS-WC the KG&E startup forces, and subsequently the operating forces, will start out conducting their activities under the systems I,
of control which comprise the OQP.
3 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 OQP (e.g.
procurement and receipt inspection). l8 A description of the QA Program elements controlling these activities can be found in the appropriate section(s) of the SNUPPS QA Programs for Design and Construction Manual.
The construction organization providing the safety-related activ-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 interface between the con-struction organization (s) providing the activity and the using organization (s).
Included within the OQP are the development, control and use l, 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 orders and contracts and/or through audits.
17.2.0.4 Soecial 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 SNUPPS Standard Plant FSAR and Table
)
9.5-1, WC addenda.
l Environmental Controls See Section 13.5.2.2.8 Site Security See WCGS Physical Security Plan Rev. 11 17.2-2
SNUPPS-WC 17.2.1 ORGANIZATION l
17.2.1.1 Scope KG&E has established an organizational structure for quality assurance activities.
This section identifies the organiza-tional structure; management positions and responsibilities; and delegation of authority for the development, implementa-tion, and maintenance of the OQP.
KG&E shall retain respon-sibility for the establishment and execution of the OQP, I
although certain program activities may be delegated to others.
The organizational structure of KG&E's top manage-ment is shown in Figure 17.2-1.
The organizational structure responsible for implementing the OQP is shown in Figurele 17.2-2.
The organization of the WCGS staff and the Quality l1.
'1 organization will be shown in Figures 13.1-1 and 13.1-2, re-spectively.
17.2.1.2 President and Chairman of the Board The President and Chairman of the Board is responsible for promulgating quality assurance program requirements.
He has responsibility for quality assurance, engineering, procure-ment, construction, and operation of the WCGS.
He endorses KG&E's Quality Assurance policy statement and delegates the authority necessary to implement this policy.
He directs all KG&E employees who work in direct support of nuclear opera-l tions activities or interface with nuclear operations to l
comply with the OOP.
l, 17.2.1.2a Group Vice President - Technical Services The Group Vice President - Technical Services reports directly to the President and Chairman of the Board.
The duties and responsibilities of the Group Vice President - Technical Ser-vices include being in charge of all technical aspects of 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 policy.
He authorizes staffing of the QA Division, the WCGS, 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 WCGS 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. 11 17.2-3
SNUPPS-WC The Wolf Creek Project Director reports directly to the Vice President - Nuclear.
Also reporting to the Vice President-Nuclear are the Director Quality and various support services 18 functions.
The Vice President - Nuclear provides overall pro-gram direction on nuclear matters to several managers as shown in Figure 17.2-2.
i 17.2.1.3a Wolf Creek Project Director The Wolf Creek Project Director reports to the Vice President-Nuclear and has direct responsibility for construction, engi-neering and support for the Wolf Creek Generating Station, Unit No.
1.
The Wolf Creek Project Director provides day-to-day project direction to:
a.
Construction Manager b.
Director Nuclear Operations c.
Manager Nuclear Services d.
Manager Nuclear Plant Engineering e.
Plant Manager, and f.
Manager Startup The Vice President - Nuclear and the Wolf Creek Project Direc-tor together with the management personnel listed above func-tion as a team to accomplish the design, construction and startup of the Wolf Creek Generating Station.
17.2.1.3b Manager Nuclear Administrative Services i
The Manager Nuclear Administrative Services reports directly to the Vice President - Nuclear and is responsible for pro-viding staff human resource, administrative and technical assistance to the Vice President - Nuclear.
In addition, the Manager Administrative Services oversees department staffing efforts, aids in achieving social impact goals and provides I
guidance in application of policies to the work force.
The Nuclear Coordinators and Supervisor Project Planning and Controls report to the Manager Administrative Services.
17.2.1.3c Manager Management Systems The Manager Management Systems _ reports directly to the Vice President - Nuclear and is responsible for the Configuration Control, the Document Control and Records Management Programs.
Through these programs, he 1) defines and documents the plant configuration, 2) provides evaluation of changes and implemen-tation of changes to the plant configuration, 3) verifies in-corporation of approved changes and 4) provides configuration records to support plant operation.
9 Rev. 11 17.2-4
SNUPPS-WC 17.2.1.4 Director Quality The Director Quality reports directly to the Vice President -
Nuclear and devotes full attention to WCGS quality matters.
1 He is responsible for the development and for assuring imple-mentation of the OQP.
The Director Quality is responsible for staffing the QA Division and for assuring that QA and QC per-sonnel 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 implementation of the I'
OQP.
The qualification requirements for the Director Quality 2
position are:
A bachelor degree in Engineering or related sciences plus six years of professional level experience in 1r Nuclear Quality Assurance or six years of supervisory experi-ence plus two years of Nuclear Quality Assurance experience, or equivalent professional level experience in nuclear quality assurance including six years of supervisory / management experi-1 ence.
17.2.1.4.1 Manager Quality Assurance (WCGS)
The Manager Quality Assurance (WCGS),
who reports to the Director Quality, devotes full attention to QA matters.
Hel' 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-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 shall be nuclear power plant quality assurance implementation experience.
17.2,1.4.2 Manager Quality Assurance (Home Office) i The Me".ager Quality Assurance (Home Office) reports to the Director Quality and is responsible for verifying that an adequate QA program is developed and implemented for safety-related activities which occur at the corporate office and other locations remote from the WCGS.
He maintains 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 KG&E's suppliers, consultants, and agents.
He coordinates quality verification activities with other KG&E departments and with external QA organizations.
His qualifications are l,
e at a minimum equivalent to those of an Audit Team Leader as 2
set forth in KG&E's procedures.
Rev. 11 17.2-4a
4 SNUPPS-WC 17.2.1.4.2a Superintendent Quality Control The Superintendent Quality Control reports to the Director Quality and is responsible for the conduct of operating qual-3 ity control activities and personnel at WCGS.
17.2.1.4.3 Stop Work Authority The Director Quality is authorized by the Vice President -
l' Nuclear to stop work on ongoing quality activities which do not comply with established requirements.
For onsite activ-
- ities, this authority is delegated to the Manager Quality Assurance (WCGS) by the Director Quality.
During the lI operating phase, these personnel have the authority to stop unsatisfactory work during repair, maintenance, and refueling activities and the authority to recommend to the Plant Manager l8 stop work affecting the continuation of plant operation.
Other stop work authority evolving from hold points, witness points, and mandatory reviews and approval will be delineated i
in procedures.
The continuation of an activity which would preclude identification and correction or increase the extent of the deficiency is subject to stop-work action by the Qual-ity Assurance Division.
t
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l Rev. 11 l
17.2-4b w.-...
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SNUPPS-WC
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i 17.2.1.4.4 Quality Assurance Division Personnel Independence i
The authorities and duties of QA and QC personnel and other org anizations performing quality verification functions are clearly established in written procedures.
Such persons have sufficient authority and organizational freedom to identify I
quality problems; to initiate, recommend, or provide solu-tions; and to verify corrective action.
Assurance of quality by auditing, inspecting,
- checking, or otherwise verifying program activities is by personnel independent of the indi-vidual or y;roup -performing the specific activity.
17.2.1.5 Manager Nuclear Plant Engineering The Manager Nuclear Plant Engineering reports to the Vice President - Nuclear for overall program direction and to the Wolf Creek Project Director for day-to-d ly project direction.
He is responsible for station modifications, additions, engi-neering studies, and design reviews which are conducted at the general office or subcontracted by the general office to an outside organization.
17.2.1.6 Manager Nuclear Services The Manager Nuclear Services reports to the Vice President-i Nuclear for overall program direction and to the Wolf Creek Project Director for day-to-day project direction.
He is responsible for providing se rvices in the areas of licensing, fuels management, fuel procurement, and safety analysis.
He is responsible for home of fice support of the plant in nuclear engineering, chemistry, health
- physics, and environmental j
areas.
He is also responsible for processing and maintaining records for the KG&E general office.
i 17.2.1.7 Director Nuclear Operations The Director Nuclear Operations reports to the Vice President-Nuclear for overall program direction and to the Wolf Creek Project Director for day-to-day project direction.
He is responsible for the operations, training and startup depart-ments.
The Plant Manager and the Manager Startup report to the Director Nuclear Operations for overall program direction.
These two managers receive day-to-day project direction from j
the Wolf Creek Project Director.
The Director Nuclear Opera-
]
tions is also responsible for preparing those portions of the WCGS operating and maintenance budget not specifically assigned to other divisions.
17.2.1.7.1 Plant Manager The Plant Manager reports to the Director Nuclear Operations for overall program direction and to the Wolf Creek Project i
Director for day-to-day project direction.
He is responsible Rev. 11 17.2-5
SNUPPS-WC for the safe operation of the WCGS.
He controls plant activ-ities through supervisors as discussed in Section 13.1.
He has the prime responsibility for safe operation of the plant.
The plant staff, under the direction of the Plant Manager, develops detailed procedures and instructions for testing and operation of the station.
17.2.1.7.2 Startup Manager The Startup Manager reports to the Director Nuclear Operations for overall program direction and to the Wolf Creek Project Director for day-to-day project direction.
He is responsible for the overall direction and administration of the functions and activities required to conduct the WCGS startup program.
Chapter 14.0 presents a description of the Startup Organiza-tion and delineates the Startup Manager's responsibilities.
When the startup program has concluded, the Startup Organiza-tion will be dissolved.
17.2.1.7.3 Manager Nuclear Training The Manager Nuclear Training reports to the Project Manager l8 and is responsible for the ovarall training activities of the Nuclear Department.
He is responsible for insuring training staff qualifications, including reviewing instructor evalu-ation records with the Training Supervisor and Simulator Supervisor.
He is responsible for reviewing the content of training programs fo r technical completeness and compliance with regulatory standards.
He is also responsible for audit-ing the quality of on-site training programs.
The Manager Nuclear Training is also responsible for training programs for Corporate office personnel involved in support of WCGS during normal operations, preparedness for response to off normal incidents, and long-term recovery programs.
i I
I Rev. 11 17.2-Sa I
~__-,
SNUPPS-WC 17.2.1.8 Director - Purchasing The Director
- Purchasing reports administratively to the Administration who reports to the l
Group Vice President President and Chairman of the Board.
The Director - Purchas-ing also has reporting responsibilities to the Group Vice President - Technical Services for materials, systems, compo-nents and parts (not delegated to outside organizations) that are needed to support WCGS.
He is responsible for issuing purchase orders 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 of this Committee are the Vice l:
initiate changes when war-effectiveness of KG&E's OQP and ranted.
The permanent members i
President-Nuclear, Vice President-Engineering, Legal Counsel, Superintendent Production Fossil Plants and the Director Nuclear Operations.
1 In carrying out their responsibilities, the members of the Quality Assurance Committee shall utilize information received from internal audit reports; audit reports of other organiza-tions supplying services or materials which are important to 1
safety; summaries of nonconformance reports, corrective action reports, and NRC I&E inspection reports and notices of viola-l 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 quality problems l 2 but will take a broad overview of KG&E's OQP and make decisons which will provide meaningful adjustments to the OQP.
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 quality 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 WCGS (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. 11 17.2-6
SNUPPS-WC 17.2.2 QUALITY ASSURANCE PROGRAM j
17.2.2.1 Scope KG&E has established an OQP which controls activities affect-l 8 ing quality.
The program encompasses those quality activities necessary to support the operating phase of the WCGS.
The total OQP complies with 10 CFR 50, Appendix B,
" Quality Assur-l IA ance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" and generally follows the guidance of Regulatory Guide l1 1.33.
Several alternate methods of meeting Regulatory Guide 1.33 are described in this chapter and in Appendix 3A.
17.2.2.2 Identification of Safety-Related Items The scope and activity applicability of the OQP are described l t in Section 17.2.0.
Safety-related structures, systems, and components are identified in Table 3.2-1 of the Standard Plant FSAR.
This list includes structures, systems, and components identified as safety-related during the design and construc-tion phase and may be modified as required during operations, l
consistent with their importance to nuclear safety.
Table 3.2-1 is maintained current by the Manager Nuclear Services I
with changes to the table being approved by the Director 1
)
- Quality, Manager Nuclear Plant Engineering, and Director Nuclear Operations.
During the operational phase the OQP is the governing quality l l assurance program for safety-related structures,
- systems, components and consumables.
The programs identified under the
" Quality Assurance" heading of Table 3.2-1 are those utilized during the design and construction phase.
Should safety-related equipment or services be procured from
- Bechtel, Westinghouse, or others during the operating phase, quality assurance requirements will be determined and imposed in accordance with Sections 17.2.4 and 17.2.7.
17.2.2.2 Operating Quality Program Implementation i
The OOP shall be implemented at least 90 Csys prior to. fuel loading.
The OOP shall be implemented throughout the operat-ing life of the WCGS.
Special equipment, environmental condi-tions, skills, or processes will be provided as necessary - to demonstrate effective implementation of the OQP.
l 1,1 Implementation of the OQP by KG&E is directed towards assur-l g ance that operating phase activities and maintenance activ-ities are conducted under controlled conditions and in compli-ance with applicable regulatory requirements, including 10 CFR 50, Appendix B.
Management responsible for conducting safety-related activities shall be responsible for providing approved procedures prior to initiating the activity.
o Rev. 11 17.2-7
SNUPPS-WC l1 i
Commencing with the issuance of an operating license, changes to the quality program description in this chapter of the FSAR 11 shall be submitted to the NRC at least annually.
If any such change reduces the commitments previously made, NRC approval must be obtained prior to implementation.
17.2.2.4 Operating Quality Program Documentation lI Consistent with the schedule for accomplishing operations phase activities, the OQP shall be established and documented.
i 4
The OQP shall be documented as follows to meet program oojec-tives:
i i
l l
Rev. 11 17.2-7a
SNUPPS-WC 1.
Quality Policy I
The governing policy statement of the OOP is approved by the President and Chairman of the Board and is contained in the Quality Program h,J Manual.
2.
Quality Program Manual (QPM) lt The QPM contains a statement of scope, respon-sibility and authority, and a brief discussion g
of how KG&E implements each of the requirements of 10CFR50 Appendix B at and in support of the WCGS.
The introduction to the QPM includes a governing policy statement by the KG&E Presi-dent and Chairman of the Board.
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.
Procedurcs Manuals The WCGS Procedure Manuals and the KG&E Proce-dures Manual provide control for KG&E activ-ities covered by the OQP.
I, Table 17.2-1 shows a listing of controlled procedure manuals. l '
These manuals contain mandatory requirements which must be implemented by responsible organizations and individuals.
Table 17.2-2 lists areas of OQP implementing procedural cover-age 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 procedure con-solidation, separation, deletions, additions, or minor program changes do not permit including an absolute listing of imple-menting procedures.
Table 17.2-3 lists quality program commitments to Regulatory l'A Guides and endorsed codes and standards.
Rev. 11 i
17.2-8
SNUPPS-WC 17.2.2.6 OQP Verification of Imolementation i
Achievement of the requirements of the OQP shall be verified through independent and integral control activities.
The Quality Assurance Division under the Director Quality shall l' audit general office internal and interfacing quality activ-ities and shall conduct audits and surveillances of the operating plant.
These audits shall assure overall implemen-tation verification of the OQP.
Quality Assurance Division personnel will perform audit, surveillance and inspection of I,7 quality activities performed by the operating organization, consultants, suppliers, and other KG&E personnel.
17.2.2.7 Personnel Training and Qualification General indoctrination and training programs shall be provided for the general office and plant site personnel to assure that they are knowledgeable regarding quality procedures and re-quirements.
The requirements for training of WCGS personnel are described in Section 13.2.
The training of plant operat-ing personnel is the respensibility of the plant Training Supervisor.
Records of training shall be maintained to demon-strate compliance with the qualification requirements of 10 CFR 55 and ANSI N18.1/ANS-3.1,
" Selection and Training of Nuclear Power Plant Personnel".
KG&E personnel performing
- complex, unusual, or potentially hazardous work shall be instructed in special indoctrination or briefing sessions.
Emphasis shall be on special requirements for safety of per-sonnel, radiation control and protection, unique features of equipment and
- systems, operating constraints, and control requirements in effect during performance of work.
Where required by codes and standards, personnel are trained or qualified according to written procedures in the principles and techniques of performing specific activities described in sections 17.2.9, 17.2.10, and 17.2.11 of this chapter.
Training will be conducted in a time frame adequate to ellow personnel to prepare for their job responsibilities. Retrain-ing will be scheduled as necessary to assure adequate skills are maintained.
KG&E personnel assigned to perform special-ized work tasks or to augment the plant staff for major modi-fications and contractor personnel performing work onsite shall receive indoctrination in the following subjects as required prior to commencing work:
1.
Safety rules 2.
He:Alth-physics control and monitoring of radia-tion exposure i
eI Rev. 11 l
17.2-9 l
SNUPPS-WC 3.
Plant security rules 4.
Emergency provisions 5.
Applicable operating quality program requirements f' Rev. 11 17.2-10
SNUPPS-WC with new regulatory requirements.
Design changes are defined to mean 1) planned changes in the basic plant design which modify the plant response, general design criteria, and speci-fication requirements; and 2) the substitution of equivalent hardware or the substitution of nonsafety-related parts or components into safety-related components or systems.
Changes in the WCGS basic design shall be aimed at improving safety, performance, maintainability, reliability, or inspectability.
An engineering evaluation assures that these changes are con-sistent with the performance requirements specified in existing design documents.
Requests for design changes affecting safety-related struc-
- tures, systems, and components may originate with or be processed through the Manager Nuclear Plant Engineering.
responsibility l' Design changes engineered onsite shall be the of the Plant Manager.
Procedures shall specify requirements for the review and approval of design changes by the organizations or individuals that pe rfo rmed the original design, if appropriate.
Design control activities may be delegated to others provided they have access to background and technical information.
Design changes shall be communicated to appropriate plant personnel when such changes may affect the performance of their duties.
17.2.3.8 Design Review Committees Independent of the responsibilities of the design organiza-
- tion, the requirements of the Plant Safety Review Committee (PSRC) and the Nuclear Safety Review Committee (NSRC) as specified in the Administrative Controls Section of the Technical Specifications, shall be satisfied.
Design changes involving a modification or a creation of basic design cri-teria require a safety evaluation and review, ahd concurrence by the PSRC.
Design changes which involve the substitution of hardware require a safety evaluation by the PSRC and approval by the Plant Manager; however, those changes which involve an lt unreviewed safety question or change in Technical Specifica-tions also require a review and concurrence by the NSRC.
When design is performed by an outside organization, the Manager Nuclear Plant Engineering shall perform or coordinate a review of the design for operability, maintainability, inspectability, SAR commitment compatability, and design requirements imposed by plant equipment.
In addition, the Manager Nuclear Plant Engineering shall identify and control design interfaces and coordinate the design process between internal divisions and the outside organization (s).
When required, safety analyses which cons ide r the effect of the design as described in the design documents may be per-formed by KG&E or outside organizations.
These analyses shall i
provide the basis for the PSRC safety evaluations which are Rev. 11 17.2-14
SNUPPS-WC 17.2.4 PROCUREMENT DOCUMENT CONTROL 17.2.4.1 Scope Procurement document control applies to documents employed to procure safety-related materials,
- parts, components, and services required to modify, maintain, repair, test, inspect, or operate the WCGS.
KG&E shall control procurement docu-ments by written procedures which establish requirements and assign responsibility for measures to assure that applicable regulatory req ui rements,
design
- bases, and other require-ments necessary to assure quality are included in documents employed for the procurement of safety-related materials, parts, components, and services.
17.2.4.2 Procurement Responsibility Responsibility for procurement does not reside in a single group but is a joint effort of KG&E Nuclear divisions (WCGS
- staff, Nuclear Plant Engineering, and Nuclear Services),
Quality Assurance, and the Purchasing Department.
These groups have responsibility for technical
- content, quality requirements, and commercial provisions respectively.
17.2.4.3 Procedural Control Written procedures shall include controls, as applicable, for the preparation, content, review, approval, and processing of the following types of procurement documents:
1.
Purchase Requisitions 2.
Letters of Intent 3.
Purchase Orders and Contracts 17.2.4.4 Quality Classification Each item or service to be procured is evaluated by the pro-curement document originator to determine whether or not it performs a
safety-related function or involves activities which affect the function of safety-related materials, parts, or components and to appraise the importance of this function to plant or public safety.
For those cases where it is unclear if an individual piece (i.e.,
part of a safety-related structure, system, or component or service) is governed by I
the KG&E OQ P, an engineering evaluation shali be conducted. l The evaluation shall classify the safety relationship of the service or questionable component parts or items of safety-related structures, systems, or component 9 The evaluation shall be Rev. 11 17.2-16
SNUPPS-WC Reviews of purchasing documents by QA Division personnel shall verify that quality requirements are correctly stated, veri-fiable, and controllable; that acceptance / rejection criteria are included; and that the documents have been prepared, re-
- viewed, and approved in accordance with KG&E's operating quality program requirements.
1 i
17.2-18a
SNUPPS-WC 17.2.4.6 Purchase Requisitions Purchase Requisition forms shall be used to initiate the procurement of safety-related materials, parts, components'and services.
Procurements shall be initiated by Wolf Creek staff, Nuclear Plant Engineering, Nuclear Services, or Quality Assurance Division personnel.
l1 Purchase Requisitions shall include or invoke specifications, bills of material, drawings, catalog number, full description, or item identification as applicable.
Commercial items shall rely on proven design and utilize verification methods by the purchaser in lieu of supplier controls.
Purchase Requisitions for safety-related materials,
- parts, components, or services shall be reviewed by engineering per-sonnel (WCGS staff engineers, Nuclear Plant Engineering or Nuclear Services) and Quality Assurance Division personnel as 2
detailed in the administrative control procedures to verify that adequate technical and quality requirements, respectively have been specified, unless the procurement is a duplicate order invoking identical technical and quality requirements which have previously beer reviewed 'and' approved.
The reviews l 2.
for technical and quality requirements shall b3 by someone other than the originator of the requisition.
1 17.2.4.7 Letters of Intent Letters of Intent may be utilized with suppliers of materials, parts, components, and services for the purpose of reserving schedule space prior to the resolution of the requirements to be included in a purchase order or contract.
Letters of Intent shall specify that no quality-affecting activities shall begin until an approved purchase order or contract is executed; however, in the event a Letter of Intent is issued for the purpose of securing a binding agreement prior to the issuance of such documents, it shall specify the applicable quality and technical requirements.
Letters of Intent shall be reviewed by legal counsel and Nuclear Plant Engineering, approved by the Quality Assurance Division and issued by the l1 Purchasing Department.
If the contract is to be for nuclear fuel-related goods or services the Nuclear Services division shall perform the review instead of Nuclear Plant Engineering.
17.2.4.8 Purchase Orders and contracts Purchase Orders and Contracts are prepared and issued by the Purchasing Department, and establish for the vendors the technical and quality requirements which must be met.
These documents also~ establish the commercial conditions (cost,
- schedule, warranty, insurance, etc.)
for the procurement action.
Rev. 11
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17.2-19 i
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technical and quality requirements established by the Requi-Purchase orders and Contracts shall accurately reflect the sition.
If during negotiations with the vendor it becomes i
necessag or commercially desirable to change technical or quality requirements, such changes must be presented to the individuals who approved the original requirements for appro-val.
If the changes cannot be approved, a different vendor shall be selected.
l 17.2.4.9 Purchase Order Award During the WCGS operating life, procurements may be made with j
the following:
t 1.
Suppliers judged capable (prior to award) of providing items or services in accordance with procurement document requirements and a quality i
assurance program compatible with the item or service procured; 2.
Suppliers and others in possession of hardware manufactured prior to award and whose accepta-bility can be de termined by receiving inspec-3
- tion, an examination of quality verification I
documentation, or other suitable means; 3.
Suppliers of off-the-shelf or commercial-grade i
items able to be ordered solely on the basis of published specifications; and 4.
Outside organizations working under the KG&E OQP.
l, Regardless of the basis for the acceptability of the procure-ment source, prior to the issuance of a purchase order or execution of a contract, a verification of the supplier /
i outside organization acceptability shall be documented.
A purchase order or contract may be issued prior to an assess-ment of supplier capability, provided a prohibition on safety-related work is imposed and if the purchase order is made contingent upon becoming qualified.
Such suppliers shall be released to begin safety-related work when evaluated to be an acceptable procurement source.
The process by which suppliers l
(requiring a preaward evaluation) are judged a capable pro-curement source is described in Section 17.2.7.
17.2.4.10 Document Distribution 4~
To support the control of purchased materials (see 17.2.7) copies of purchase orders and other appropriate procurement documents shall be forwarded to the applicable receiving and j
l Rev. 11 i
17.2-20 k
1 i
1 SNUPPS-WC acceptance point.
Departments receiving or utilizing pro-l cured items or services shall establish measures to maintain and control procurement documents until the items or services
),
are received and accepted.
These documents shall include purchase orders, drawings and specifications, approved changes, and other related documents.
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17.2.4.11 Change Controls i
j Additions, modifications, exceptions, and other changes to procurement document quality and technical requirements shall require a review equivalent to that of the original document and approval by the originator or the originating division's i
approval authority.
Commercial consideration changes shall not require review and concurrence by the originator.
Procurement documents regarding safety-related materials, parent components, and piece parts shall specify, as a mini-i
- mum, the original technical requirements or those specified by a properly reviewed and approved revision.
Quality stan-dards imposed shall comply with applicable administrative 1
quality requirements consistent with the extent of the original control.
The Quality Assurance Division shall review and approve specifications and purchase requisitions to verify inclusion of proper quality standards.
Procurement documents covering safety-related spare parts shall impose standards consistent with those specified for the original equipment or those specified by a properly reviewed and approved revision.
A spare parts inventory shall be established using spare parts data report forms or equivalent, which describe the technical and quality require-i ments to be imposed.
These data report forms address documen-
{
- tation, inspection, storage levels, preventive maintenance, and applicable quality assurance manuals and may be used to 1
establish the requirements for reordering of identical spare parts.
The procurement of spare or replacement parts impor-i tant to safety will be subject to the quality program controls li
)
in effect at the time of the procurement.
I 17.2.4.12 Records Procurement records for materials, parts, and components will be maintained.
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Rev. 11 17.2-21
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17.2.5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS 17.2.5.1 Scope The quality activities associated with the operating phase shall be accomplished in accordance with documented instruc-tions, procedures, drawings, or checklists.
The degrees of control imposed shall be consistent with the relative impor-tance of the activity to nuclear safety.
The instruction shall specify the methods for complying with 10 CFR 50, Appendix B.
17.2.5.2 Preparation Requirements The KG&E OQP shall control activities affecting quality by l-providing measures for:
1.
The preparation of procedures, instructions, specifications,
- drawings, or checklists of a type appropriate to the activity and its importance to safety; 2.
The inclusion in these documents of quantita-tive and qualitative acceptance criteria for verifying that an activity has been satisfac-torily accomplished; 3.
The approval of these documents by responsible personnel prior to accomplishing an activity; i
and 4.
The use of approved
- drawings, procedures, l
instructions, or checklists to accomplish an activity.
17.2.5.3 Contractor controls Procurement documents shall require gutside organizations to have appropriate instructions, procedures, specifications, and drawings to meet the requirements of the OQP.
g 17.2.5.4 Operations Documents The WCGS staff and other responsible divisions shall provide written procedures and drawings as required for the operating phase.
These procedures shall prescribe those KG&E activities which affect the function of safety-related structures, systems, and components.
8 Rev. 11 17.2-22
SNUPPS-WC 17.2.5.5 Review and Approval The approval, issue, and control of the various implementing procedures, manual, and policy are as described in Sections 17.2.2 and 17.2.6.
Plant procedures affecting the function of safety-related structures, systems, and components shall be reviewed by the PSRC in accordance with the approved WCGS administrative procedures as part of their responsibility to assure that day-to-day operating activities are conducted safely.
Proposed procedure revisions which involve a change in the Technical Specifications or an unreviewed safety question shall be referred to the Nuclear Safety Review Committee by the PSRC following its review.
Tempo ra ry changes to proco-dures shall be controlled as described in the Technical Specifications.
Table 17.2-2 lists those types of activities under the control of the plant and other KG&E organizations procedures.
Proce-dures prepared fo r the KG&E procedures manual and administra-tive and inspection procedures for the WCGS Procedures Manual shall be reviewed by the Quality Assurance Division for ccm-pliance with OQP requirements.
l8 Rev. 11 17.2-23
SNUPPS-WC 17.2.6 DOCUMENT CONTROL 17.2.6.1 Scope Documents and their revisions which control activities affect-ing safety-related structures, systems, and components shall be
- prepared, reviewed by knowledgeable individuals, and approved by authorized personnel prior to release or issuing in accordance with written approved procedures.
Departments and organizations responsible for program imple-menting documents shall be required to provide and assure the necessary review and approval for instructions, procedures, specification, and drawings.
Reviews and approvals assure that issued documents include proper quality and technical requirements, and are correct for intended use.
Individuals or groups responsible for preparing, reviewing, and approving documents and revisions thereto shall be identified in written procedures.
Responsibility for performing controlled document distribution is shared by various divisions, including but not limited to Plant Operations, Quality Assurance, Procurement (see Sub-I section 17.2.4),
Nuclear Plant Engineering and Management Systems.
Management Systems is responsible for the overall project document control program.
17.2.6.2 Preparation Controls Documents describing the KG&E OQP shall be controlled to an lG extent which considers the document type, its importance to safety, and the intended use of the document.
Requirements l2 of the OQP shall be adhered to for the preparation, review, l'
- approval, and revision of procedures, instructions, or drawings.
The controls over the issuing of documents shall provide for the availability of documents at the point of use prior to commencing an activity and the prompt transmittal of approved changes for incorporation into subsequent revisions.
Measures shall be established to prevent the inadvertent use of super-seded documents.
Types of documents which shall be controlled include:
3.'
a.
Technical Specifications; b.
Design documents such as drawings, specifica-tions, calculations and analyses, and documents related to computer codes; c.
Nonconformance reports; Rev. 11 7
17.2-24
SNUPPS-WC e.
Instructions and Procedures for activities such as fabrication, construction, modifica-
- tion, installation,
- testing, inspection and operation; f.
As-built drawings; g.
Wolf Creek Project Policy Manual; h.
Wolf Creek Generating Station Procedures Manual (which includes administrative procedures);
i.
KG&E Procedures Manual; j.
FSAR; k.
Quality Program Manual; and 1
1.
Topical reports prepared by KG&E or prepared by others exclusively for KG&E's use.
Control of documents shall be defined by a method of contrcl consistent with the importance of the document.
Documents shall be identified and distribution lists shall identify document holders.
Acknowledgement of receipt of selected documents, incorporation of revisions, and control of obsolete documents shall be required of the document receiver or provided by the distributor.
In addition, the distributors of these documents shall maintain a master list of the docu-ments showing the effective revision date of each.
s:
1 Rev. 11 i
17.2-24a
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SNUPPS-WC 17.2.6.3 Change Control Changes to documents shall be reviewed and approved where practical by the same department,
- group, or organization that performed the original review and approval;
- however, KG&E may assume or delegate this responsibility.
Organiza-tions which review and approve documents shall have access to pertinent information and knowledge of the intent of the original document.
17.2.6.4 Distribution Control The Plant Manager shall be responsible for assuring the lI issuing of controlled documents generated or received onsite and for which plant personnel have the preparation and final approval or external interface responsibility.
Similarly, the j
Manager of Management Systems shall be responsible for assur-ing the issuing of controlled documents generated or received at the home office for which home office personnel have prep-l1 aration and final approval or external interface responsi-bility.
17.2.6.5 Proces_ sing and Retenti.on Controls Administrative procedures shall specify the requirements for 1
the processing and maintenance of records.
Procedures shall also be established to control the distribution of instruc-tions, procedures, and drawings governed by the OQP.
WCGS la staff and other KG&E organizations shall assure that current documents are distributed to and used at the location where the prescribed activity is performed.
Clearly identified controlled copies of documents shall be used to perform an activity.
lJ 17.2.6.6 Procedure Review The review by the Quality Assurance Division of procedures which apply to maintenance, modifications and inspections will verify that needed inspections, the responsibility for per-forming the inspections, and documentation of the inspection results are provided for.
The QA Division review will also verify that written procedures / instructions establish the inspection requirements, methods of inspection and acceptance criteria.
Rev. 11 17.2-25
SNUPPS-WC 17.2.7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES 17.2.7.1 Scope Materials, equipment, and services procured for the WCGS shall be required to conform to procurement documents as prescribed in Section 17.2.4.
Provisions, including written procedures shall be established to control quality activities associated with the procurement of material, equipment, and services including:
1.
The preparation, review, and change control of procurement documents as described in Section 17.2.4; 2.
Procurement source evaluation and selection; 3.
Bid evaluation and award; 4.
Verification activities ( su rveillance, inspec-
- tion, and audit) required by the purchaser; 5.
Control of nonconformances as described in Section 17.2.15; 6.
Corrective action rega rding procurement as described in Section 17.2.16; 7.
- Material, equipment, and service acceptance; 8.
Control of quality assurance records; 9.
Audits of the procurement program as described in Section 17.2.18.
17.2.7.2 Source Evaluation and Selection Provisions shall be
- made, as appropriate, for supplier evaluations which assess their capabilities prior to award by 1) source evaluation; 2) review for objective evidence of.
quality; or 3) a review of supplier history.
When evaluations are performed, the assessment of a supplier's capability shall be specific regarding the procured item, commodity, or service and the supplier's ability to provide the items or services in accordance with procurement document requirements.
The eval-uation which provides the bases for supplier selection shall be documented and filed.
Suppliers of hardware and services which are manufactured prior to award, considered an off-the-shelf item, or implemented under the KG&E OQP or surveillance l:
program may not require preaward source evaluation or audits to assure quality.
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Rev. 11 17.2-26
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SNUPPS-WC 17.2.7.3 Bid Evaluations and Award Quality Assurance Division, Nuclear Services, Nuclear Plant 1
Engineering, Purchasing and the WCGS staff, as appropriate, shall perform bid evaluations in accordance with procedures.
These organizations shall initiate and coordinate bid evalu-ation activities for those proposals received in response to procurement documents initiated by them.
Bids or proposals shall be evaluated by the originating organ-ization for conformance to procurement document requirements.
The Quality Assurance Division shall review proposals for conformance to quality requirements.
17.2.7.4 Bidder Exceotions to Purchase Requirements Exceptions to procurement document requirements requested by bidders shall be evaluated by the responsible organization (s).
Unacceptable conditions identified in bid evaluations shall be resolved, or if the bidder cannot or will not resolve the unacceptable condition, the bidder will be rejected and an-other bidder selected.
17.2.7.5 Preaward Meetings The Purchasing Department and the originating organization shall take steps to establish an understanding of the procure-ment document requirements with the supplier.
Meetings or other forms of communication may be held to establish the intent of KG&E in monitoring and evaluating supplier perfor-mance.
The depth and necessity of these activities is a function of the uniqueness, complexity, frequency of transac-tions with the same supplier, and past supplier performance.
KG&E hold and witness points shall be documented at this time if not already specified irt procurement documents.
17.2.7.6 Verification Planning Planning of verification activities to be employed for item or service acceptance shall begin during the purchase requisition or contract preparation and review stage.
The extent of the acceptance methods and associated verification activities will vary and be a function of the relative safety significance and complexity of the purchased item or service and the supplier's past performance.
Procedur?s will provide for the acceptance of simple, off-the-shelf items based exclusively on receiving inspection with no quality verification documentation require-ments.
Planning shall include a review of the established acceptance criteria and identified documentation.
Verifi-cation methods which may be employed include certifications (Certificates of Conformance and material certificates or test reports),
supplier surveillance, receiving inspection, and postinstallation tests established by KG&E.
Selected Rev. 11 17.2-28
SNUPPS-WC verification methods shall be indicated as inspections, exam-inations, tests, or documentation.
When post-installation testing is used for the acceptance of an item the QA Division shall review and approve the adminis-l t trative procedure which controls acceptance testing.
The implementing procedure shall be reviewed by the PSRC and approved by the Plant Manager.
Review of the test documenta-7 tion including data shall be performed by the QA Division.
17.2-28a
SNUPPS-WC 3.
Surveillance of critical manufacturing process-es 4.
Auditing supplier records to verify certifi-cation validity and the proper resolution of nonconformances.
17.2.7.8 Receiving Inspection Acceptance by receiving inspection will be utilized as a prime method of verification and will be utilized as the sole means of item acceptance when items are relatively simple and stan-dard in design and manufacture.
When other methods are util-ized, receiving inspection shall be employed to verify that items have not sustained damage due to handling, shipping, or storing.
Receiving inspection shall be performed by the QA Division in accordance with written procedures.
On complex or special 7
items other plant personnel may assist in performing receipt inspection.
These personnel shall be qualified in accordance with the controls described in Sections 17.2.10 and 17.2.11, as applicable.
In the event of a major modification, receiv-ing inspection may be delegated to an outside organization (s). l1 Receiving inspection activities shall include:
1.
Identifying materials,
- parts, and components and their status upon receipt by tagging or other acceptable means of identification or segregation and controlling items in receiving inspection hold areas separate from the storage facilities for accepted items.
Identification of items shall correspond to the identification noted in related purchase documents and receiv-ing documentation.
2.
Verification of items for their acceptance, including examination for shipping
- damage, correctness of identification, and specified quality documentation.
3.
Inspecting or, where appropriate, testing using approved procedures and calibrated
- tools, gauges, and measuring equipment for verifica-tion acceptance of items, including those from off-the-shelf suppliers.
Rev. 11 17.2-30 l
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SNUPPS-WC 1
l i
The acceptance of services is very much a function of the service pe rformed and may or may not involve QA Division personnel.
For example, if the service is for NDE, the QA I l
Division personnel will witness / inspect a portion of the work i
i as it is being performed, and will review the inspection reports prepared and turned over to KG&E as the basis for acceptance.
If the service is for engineering work the accept-
~
ance will be performed by KG&E engineering organizations based on their review of the design output documents produced.
If i
the service is in support of the QA Division, such as audit l 62 work, the acceptance will be based on a review of the audit report (s) produced.
The review will be made by KG&E QA Divi-l2 sion personnel.
17.2.7.11 Final Acceotance Final acceptance of items shall be by QA Division personnel. l7 The final acceptance of services shall be the responsibility i
of the originating organization.
Acceptance shall be docu-mented.
I 17.2.7.12 Record Retention Regarding the control of purchased material, equipment, and services, record retention shall be the responsibility of the involved organizations.
Specified inspection, test, and other reco rds shall be available at the plant prior to installation or use, l
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Rev. 11 17.2-32
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SNUPPS-WC 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 j
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, speci-fications, or other special requirements.
Procedures detail-ing special processes shall be qualified in accordance with applicable codes and standards or, where no appropriata stand-ards exist, to KG&E requirements.
The qualification of pro-cesses and personnel shall be documented and maintained.
17.2.9.2 Procedural Control i
Plant procedures shall prescribe the requirements for the qualification of KG&E procedures, personnel, and equipment.
The involvement of the QA Division in the control of special l 3,
processes includes the review of plant procedures for the adequate inclusion of quality requirements.
The QA Division surveillances on the work l 7,1 l
directly performs NDE, or performs of others who provide NDE services.
They also inspect other i
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 Section 17.2.12.
Qualification records shall be maintained current.
The Plant Manager shall be responsible for assuring that personnel i
performing special processes, excluding NDE, are qualified 4
and are employing qualified procedures.
Procedures shall also be established for recording evidence of acceptable accom-plishments of special processes using qualified procedures, equipment, and personnel.
Plant and other responsible KG&E organization procedures shall.
also be established, as appropriate, to prescribe measures for the preparation, review, and approval of procedures for - the i
control of special processes.
Plant procedures shall address I
nondestructive examination (NDE) personnel, special process procedures, and inspection personnel qualification require-ments.
Procedures detailing special processes prepared ' by KG&E engineering organizations shall receive an independent review to assure - that quality requirements and acceptance j
criteria have been incorporated and recorded, l
Rev. 11 17.2-35
'SNUPPS-WC 17.2.9.3 Control of outside Contractors Qualified outside organizations may be employed to perform special proceesee and shall be required to conform to the requirements described herein.
Special process procedures submitted by an outside organization (s) in accordance with procurement document requirements shall receive a technical review by the responsible engineering organization and a quality review by the Quality Assurance Division.
17.2.9.4 Records Control Qualification records of plant procedures detailing special processes and plant equipment, as appropriate, shall be maintained by the applicable plant organization.
Qualifica-tion records of plant personnel performing special processes shall be maintained under the direction of the Plant Manager. l l 17.2.9.5 Qualification of NDE Personnel Nondestructive examination personnel shall be qualified in accordance with procedures established per the requirements of i
the American Society for Nondestructive Testing Standard SNT-TC-1A.
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Rev. 11 17.2-36
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SNUPPS-WC 4.
Acceptance and rejection criteria 5.
Identifying required procedures, drawings and specifications, and revisions 6.
Recording inspector or data recorder and the results of the inspection operation 7.
Specifying necessary measuring and test equip-l ment, including accuracy requirements.
8.
Evaluation of the inspection results and the person performing the evaluation.
17.2.10.3 Process Monitoring Process monitoring of work activities, equipment, and person-nel shall be utilized as a control if inspection of processed items is impossible or disadvantageous.
Both inspection and process monitoring shall be provided when control is inade-quate without both.
A suitable level of confidence in structures,
- systems, or components on which maintenance or modifications have been performed may be attained by inspec-tion.
As appropriate, an augmented inspection program shall be implemented until such time as a suitable level of per-formance has been demonstrated.
Process mcnitoring of ongoing activities at the WCGS shall be intervals based on the status and safety importance of the at activities.
Guidelines shall be established to indicate the minimum frequency of process monitoring for each ongoing activity and to provide a basis for subsequent monitoring planning.
The monitoring of processes shall be performed to verify that quality affecting activities are being performed in accordance with documented instructions, procedures,
- drawings, and specification.
17.2.10.4 Inservice Inspection Required inservice inspection or process monitoring of struc-tures, systems, or components shall be planned and executed.
Inspection methods shall be established and executed to verify that the characteristics of an item continue to remain within specified limits.
The Manager Nuclear Plant Engineering or the Plant Manager l
shall be responsible for assuring the development of a
preservice and inservice (PSI /ISI) inspection program, proce-
- dures, and reference preservice and inservice examination plans; the updating of the reference plans'to reflect as-built e
conditions and the technical requireinents - of the applicable code edition and addenda; and the securing of inspection and consulting services.
[
Rev. 11 17.2-38 d
SNUPPS-WC The services of an outside organization may be secured for the conduct of PSI /ISI inspections.
The Plant Manager shall direct the performance of the inservice testing of pumps and valves as described in Section 17.2.11.
17.2.10.5 Acceptance The acceptance of an item shall be documented by authorized personnel.
Modification,
- repair, or replacement of items performed subsequent to final inspection shall require rein-spection or retest, as appropriate, to verify acceptability.
17.2.10.6 Qualification of Inspection Personnel KG&E personnel or personnel from outside organizations shall perform acceptance inspection activities and shall be quali-l1 fied within their respective areas of responsibility.
The assignment of plant acceptance inspection personnel shall be under the direction and control of the Quality Assurance y
Division.
Qualification of KG&E inspection personnel (Exclusive of NDE) shall not be limited by company position and shall be defined in levels of capability.
The number of levels established for each type of inspector shall be at least one but no more than three.
Inspection assignments shall be consistent with the certification of an individual.
Inspections associated with normal operations of the plant (such as routine maintenance, surveillance, and tests) shall be performed by individuals other than those who performed or directly supervised the work and may be within the same group, if the following controls are met:
1.
The quality of the work is demonstrated through a functional test when the activity involves breaching a pressure retaining item.
2.
Inspection procedures, and qualifications of inspection personnel are reviewed and found 7
acceptable by the QA Division prior to initi-ating the inspection.
17.2.10.7 Qualification of NDE Personnel Nondestructive examination functions shall be accomplished by plant personnel or outside organizations.
Personnel involved in the performance, evaluation, or supervision of nondestruc-tive examinations shall meet the qualification requirements specified in SNT-TC-1A.
The certification of nondestructive testing personnel shall be to one of three basic levels of qualification.
4 Rev. 11 17.2-39
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SNUPPS-WC 17.2.10.8 Qualification Program Responsibilities i
i Plant procedures and procurement documents shall prescribe the qualification requirements of inspectica personnel.
The
]
Quality Assurance Division shall be responsible for assuring l 1 l
that inspection personnel have received appropriate technical and quality training prior to their certification.
The Qual-l ity Assurance Division shall maintain documented evidence of qualifications of KG&E personnel performing plant acceptance 1
inspection functions.
The Quality Assurance Division shall I
j audit the personnel qualifications and verify the independence of all personnel performing inspections of safety-related or i
special scope equipment or services at or in support of the WCGS.
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Rev 11 17.2-40
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SNUPPS-C 17.2.11 TEST CONTROL 17.2.11.1 Scope Testing shall be performed at the WCGS to demonstrate that safety-related structures,
- systems, and components perform satisfactorily in service.
Test programs include preopera-tional tests, initial startup tests, surveillance tests, pump and valve tests, and special tests, including those associated with plant maintenance, modification, procedure
- changes, failure analysis, and the acceptance of purchased material.
17.2.11.2 Procedural Control Test programs shall be established by the Director Nuclear Operations to assure that testing demonstrates item or system performance.
Testing shall be performed in accordance with written procedures which incorporate or reference the require-ments and acceptance limits contained in applicable Technical Specifications, drawings, instructions, procurement documents, specifications, codes, standards, and regulatory requirements, Test program procedures shall control when a test is required and how it is to be performed.
Test administrative procedures, test procedures and checklists employed during tests shall include, as applicable, prerequi-site conditions; material and test equipment requirements; mandatory hold points; testing method instructions; limiting conditions and acceptance / rejection criteria; data collection method and test result approval requirements.
Where outside organizations are utilized for plant or plant-related tests, procurement document requirements shall impose test require-ments consistent with those described herein.
17.2.11.3 Personnel Qualifications Personnel within the various KG&E organizations or outside organizations shall perform testing activities, including implementing test procedures and the evaluation and reporting of test results.
The assignment of plant testing personnel shall be under the direction of the Startup Manager for pre-operational testing and the Plant Manager'for initial startup testing and post plant acceptance testing.
Qualified person-K nel outside the plant organizations may be employed to per-form testing activities.
Qualification of KG&E personnel shall be defined in levels of capability which are not limit-ing with regard to company position.
The number of levels established for each classification of test personnel shall be least one but not more than three.
Testing assignments at shall be consistent with the certification of an individual.
8 Rev. 11 17.2-41
SNUPPS-WC A testing personnel procedure shall be established to assure test program activities are performed by qualified personnel.
Plant procedures and procurement documents shall prescribe the qualification requirements of testing personnel.
The Startup Manager and the Plant Manager shall be responsible for assur-ing that test personnel are qualified for certification during l l the test programs for which they have responsibility.
They shall insure documented evidence is available of qualifica-[I tions of personnel performing plant test functions.
17.2.11.4 Test Results Test results shall be documented, reviewed, and approved by qualified individuals or groups.
Equipment found to be defi-cient shall be identified in accordance with Section 17.2.14.
Surveillance test results which fail to meet the requirements and acceptance criteria shall be documented and reviewed in accordance with Section 17.2.15.
Deficiencies identified as nonconforming shall be reviewed in accordance with Section 17.2.15, 17.2.11.5 Test Evaluations Upon completion of system preoperational testing, the test results are submitted to the JTG for its review and subsequent recommendation for approval to the Startup Manager and Plant ig Manager.
I The results of special tests performed after fuel load shall 14 be reviewed by the PSRC. Proposed tests to be performed by the
'A Startup organization which involve an unreviewed safety ques-tion or change in the Technical Specifications shall be re-viewed by the NSRC prior to the test.
The NSRC shall review any test reports associated with such tests.
Test procedures parformed after fuel load are reviewed by qualified personnel l1 and the PSRC, and approved by the Plant Manager.
1:
17.2.11.6 Preoperational and Startuo Tests The Startup Manager shall be responsible for the administra-tion and conduct of the preoperational testing program.
The Plant Manager shall be responsible for the administration and lt conduct of the initial startup testing program and all post plant acceptance testing.
Test procedures employed during the preoperational and the initial startup test programs shall be prepared and approved under the requirements of the Wolf Creek administrative procedures.
Preoperational test procedures are reviewed by qualified personnel and the JTG, and approved by the Startup Manager.
Initial startup test procedures and post l$V plant acceptance test procedures are reviewed by qualified personnel and the PSRC, and approved by the Plant Manager. l4 Rev. 11 17.2-42
SNUPPS-WC 17.2.11.7 Systems Control At turnover of systems or portions of systems to the plant
- staff, the Plant Manager shall be responsible for their l8 operation.
During the period prior to the initiation of startup testing, to the extent practicable, the plant tech-nical and operating staff shall familiarize themselves with the f acility operation and verify by trial use that operating and emergency procedures are adequate.
17.2-42a
SNUPPS-WC 17.2.12 CONTROL OF MEASURING AND TEST EQUIPMENT l
17.2.12.1 Scope The calibration and control program established at the WCGS i
shall assure that tools,
- gauges, and instruments maintain their required accuracy.
The Plant Manayer shall be respon II sible for assuring the program's establishment and implementa-i tion.
Test instrumentation shall be utilized by various organizations as required to perform tests or other special operations.
Each organization shall be responsible for assur-2 ing 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 WCGS shall be required to implement a calibration and control program consistent with the requirements 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 procedures or instructions.
The procedures for the calibration and control of M&TE shall address identification of the item to be calibrated and test equipment, calibration techniques includ-ing acceptance tolerances, calibration frequencies, mainte-nance control, storage requirements and any special instruc-tions.
The equipment subject to these controls shall include measuring instruments, test instruments, tools, gauges, refer-ence standards, transfer standards, and nondestructive test equipment employed in measuring, inspecting, and monitoring safety-related structures,
- systems, and components.
Per-manently inscalled process instrumentation is not included in this listing.
Inspection, test, maintenance, repair, and other procedures shall include provisions to assure that MsTE 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-vals for M&TE and calibration procedures which specify calibration methods and instrument dCCuracy requirements.
Interval selection shall be a function of the equipment type, inherent stability end reliability, intended
- use, required accuracy, and other conditions which may af fect calibration.
Records shall be 1
Rev. 11 17.2-44
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.
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.
l 4.
The traceability of reference standards to nationally recognized standards and the periodic revalidation of reference standards.
5.
The maintenance of records 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.
l 8.
The calibration of M&TE should be against a l
working standard having an accuracy of at least j
four times the specified tolerance of the M&TE.
When this is not practical, standards shall l
have an accuracy which assures that the equip-ment being calibrated will be within its re-i quired tolerance.
Management review and ap-l 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 significant differences in the quality controls for the two lt different categories of_ instruments are:
1.
All M&TE used for acceptance measurements or I
calibration of safety-related plant instrumen-tation must be controlled under this section.
Only safety-related permanently installed pro-cess instrumentation mu::, t be so controlled.
Rev. 11 17.2-45
SNUPPS-WC i
17.2.13.4 Inspection The Plant Manager shall establish a program which identifies l 1 special handling tools and equipment and provides for routine maintenance and inspection in accordance with documented pro-cedures which specify appropriate acceptance criteria.
Rou-tine inspections performed by the plant organization shall h i
indicate the acceptability or nonconformance of equipment and rigging.
Periodic inspections shall be performed by the Quality Assurance Division and shall be supplemented by non-g destructive examinations and proof tests as delineated in procedures for items requiring special handling.
Personnel performing nondestructive examination and proof testing shall be qualified in accordance with the requirements of Sections 17.2.9 and 17.2.11, respectively.
17.2.13.5 Procurement Controls Procu:*ement documents and procedures shall address packaging requirements which afford protection from the possible degradation of quality during shipping, handling, or storing.
The packaging protection specified shall vary in degree a
consistent with the item's appropriate protection classifica-tion.
Similarly, the mode of transportation employed shall be consistent with the protection classification of items.
17.2.13.6 Radioactive Materials Measures shall also be established to control the shipping of licensed radioactive materials in accordance with 10 CFR 71.
17.2.13.7 Records Records shall be maintained to document activities regarding handling, shipping, and storing which affect quality.
1 l
l e
Rev. 11 17.2-48
I SNUPPS-WC 17.2.14 INSPECTION, TEST, AND OPERATING STATUS 17.2.14.1 Scope Safety-related and special scope items that are received,,1 stored, or installed at the WCGS shall be identified and con-trolled in accordance with documented procedures.
17.2.14.2 Item Status Identification Items received at or installed in the plant shall be identi-fled in accordance with procedures as to their inspection,
- test, and operating status.
Procedures shall control the application and removal of inspection and welding stamps and status indicators such as segregation, tags, markings, labels, and stamps.
In the event traceability is not available or
- lost, the item (s) shall be considered nonconforming and handled in accordance with Section 17.2.15.
Placement and removal of tags used to define the boundaries of systems or components turned over to the Startup organization are the responsibility of the Startup Manager.
Tagging used to control nonconforming items found during the Startup phase is also the responsibility of the Startop Manager.
Placement and removal of safety tags on installed equipment which has been turned over to Startup or Operations are the responsibility of the Operations Shift Supervisors.
These tags are used to prevent operation of equipment, protect workers and to protect plant equipment from damage.
Placement and removal of tags to identify and control unin-stalled, nonconforming items or materials subsequent to turn-over from construction are the responsibility of the Quality Assurance Di'Jision.
Items segregated and placed in quarantine I
are the responsibility of the plant organization.
Certified welders will be issued welder identification stamps by the Maintenance Supervisor.
Welds made in compliance with the ASME Code and other welds on items important to safety will be stamped.
17.2.14.3 Operating Status Plant procedures shall provide instructions relating to the operational status of safety-related structures, systems, and components, including temporary modifications.
Those proce-dures shall address:
Authorization for requesting that equip-ment be removed from service; checks which must be made before approving the request; approval of the action to remove the equipment from service; the actions necessary to isolate the i
equipment and responsibility for performing these actions; the actions necessary to return the equipment to its operating status and responsibility for these actions.
Equipment and Rev. 11 17.2-49
- _ _ ~ ~
l SNUPPS-WC i
17.2.15 NONCONFORMING MATERIAL, PARTS, OR COMPONENTS I
17.2.15.1 Scope lI Nonconformances identified under the KG&E OQP shall be con-trolled to prevent the inadvertent use of defective or inde-1 terminate materials,
- parts, and components and to identify documentation inadequacies, and reportable activities.
Non-l conformances, therefore, include material deficiencies, mal-functioning or inoperative structures, systems and components, i
and departures from specified procedural requirements.
Accord-ingly, measures shall be established regarding identification, documentation, status control, disposition, and notification of affected parties.
17.2.15.2 Nonconformance Controls l
Nonconformances shall be reviewed and
- accepted, re-j ected,
repaired, reworked, or conditionally released in accordance with documented procedures.
Repaired and reworked items shall be reinspected in accordance with the original inspection or test requirements or acceptable alternatives.
Reinspection results and operational data, gathered subsequent to repair or rework, are documented on nonconformance reports, inspection reports or other suitable type documents.
Measures shall be l8 established to conditionally release nonconforming items whose disposition is pending and an engineering evaluation indicates q
that further work or activity will not contribute adversely to I
the nonconformance or preclude identification and correction.
such dispositions shall be concurred in by the Quality Assur-f7
]
ance Division.
Nonconformances shall be controlled by report i
documentation, tagging, marking, logging, or physical segre-4 gation.
a Nonconformance documentation shall be processed in accordance with documented procedures and shall identify the specifics of the nonconformance.
Nonconformance documentation shall state the particular drawing, procedure, specification, or other requirement not met; shall record the disposition; and shall register the signature of an appropriate approval authority.
The WCGS staff, Nuclear Services, or Nuclear Plant Engineering, as applicable, shall be responsible for assuring the disposi-tion of Nonconformance Reports (NCRs).
Procedures shall prescribe the individuals or groups assigned the responsibility and authority to approve the disposition of nonconformances.
The disposition of nonconforming items shall be provided by the original design organization or by an equivalent organization which has access to the original design basis information.
Within KG&E this includes engineers within the Nuclear Plant Engineering, Nuclear ~ Services and Plant Staff organizations.
Rev. 11 17.2-50
SNUPPS-WC 17.2.15.3 Reporting Methods Under the KG&E OQP, NCRs, audit reports, work requests, sur-ll e
veillance reports, and licensee event reports may be employed to identify and control nonconformances.
Nonconformance logs may be utilized to identify and maintain the status of noncon-formance documents.
Nonconformance Reports document nonconforming materials, parts, or components and documentation inadequacies.
Licensee Event Reports, as required by Federal Regulations, shall be used to identify certain operating nonconformances.
Noncon-formance logs may be employed by the Quality Assurance Divi-ll sion during the initial test program, and, subsequent to plant modifications, to track nonconformances requiring resolution.
Nonconformances shall be reviewed for reporting applicability under 10 CFR 21.
17.2.15.4 Disposition Material nonconformance disposition categories are:
1.
"Use as is" or " acceptable" (including conditional releases) 2.
" Reject" or "not acceptable, repeat" 3.
" Rework" in accordance with documented proce-dures 4.
" Repair" in accordance with documented proce-dures.
17.2.15.5 Procurement Controls Plant and other KG&E organization procedures shall prescribe measures for the control and disposition of KG&E purchased items and services identified by outside organizations as nonconforming.
Procurement documents specify those noncon-formances which shall be submitted to KG&E for approval of the recommended disposition.
Actions taken in response to these nonconformances shall require documentation and shall be forwarded to KG&E along with the hardware and accompanying quality verification documentation.
Plant personnel shall approve the recommended disposition of nonconformances relating to plant initiated hardware and services procure-ments.
The technical support staff shall be responsible for assuring the processing of these supplier-recommended disposi-tions.
Similarly, other KG&E or outside organizations shall approve or be requested to approve dispositions of noncon-formances regarding procurements they initiate.
An approved Rev. 11 17.2-51
=
SNUPPS-WC disposition of a nonconformance which allows a reduction in the requirements of a safety-related structure, system, or l,
component shall be treated as a design change and, therefore, subject to the appropriate controls prescribed in Section 17.2.3.
i i
17.2.15.6 ReDortable Nonconformances i
Results of investigations, recommendations, and event sum-maries regarding violations, deviations, and reportable events which are reported to the NRC in writing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, shall be reviewed by the PSRC and NSRC.
17.2.15.7 Trend Analysis Nonconformance reports shall be analyzed by the Quality Assur-ance Division for identification of potential unsatisfactory quality trends.
The results of these analyses shall be re-i ported to management.
Significant adverse trends shall be handled in accordance with section 17.2.16.
i 4
i Rev. 11 17.2-52 f
.e,
,-,-~m
SNUPPS-WC 17.2.16 CORR 5CT1'Vs ACTION 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 OQP.
Corrective actions associated with the l :
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 conditions shall be reported to appropriate management, eval-l
- uated, and corrected.
Significant adve rse conditions may include an isolated gross noncompliance with procedural requirements, a recurring condition for which past corrective action has been ineffective, significant adverse noncon-formance trends, or significant OQP deficiencies.
lt 17.2.16.2 Corrective Action Report (CAR)
Procedures shall provide instructions for identifying, report-ing, and initiating corrective action to preclude recurrence of significant adverse conditions.
A Corrective Action Report (CAR) shall be employed to document significant adverse condi-tions and to initiate the corrective actions for these condi-tions except in those instances when 10CFR21 reports, 10CFR-50.55(e) reports or similar regulation required reports are 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 adverse to quality which involve design deficiencies or recommended corrective actions which require design change.
In such cases the appropriate engineering organization shall be responsible for cause identification and recommending corrective action.
Rev. 11 17.2-53
SNUPPS-WC 17.2.17 QUALITY ASSURANCE RECORDS 17.2.17.1 Scope A records system governing the collection, storage, and main-tenance of records shall be established by KG&E and shall be in compliance with the standards and regulations identified in Table 17.2-3.
At a minimum, the records system shall apply to operating phase records associated with OQP governed activi-ties when' records are required to either demonstrate compli-41 ance with licensing commitment or finished documentary evi-dence of the quality of items and activities affecting quality.
All such records shall be considered QA records and shall be legible, complete, adequately identifiable to the item or activity involved and readily retrievable.
Quality Assurance records include but are not limited to oper-l2 ating logs; maintenance and modification procedures and in-spection results; reportable occurrences; results of monitor-ing and reviews; inspections,
- tests, audits, and material analyses; qualification of personnel, procedures, and equip-ment; records required by Technical Specifications; and other documentation including drawings, specifications, procurement I
documents, nonconformance documentation, corrective action reports, procedures, and calibration procedures and reports required to demonstrate compliance with license commitments.
1 17.2.17.2 Fesponsibilities A records system shall be established by the plant and other I s KG&E organizations and shall be controlled in accordance with written _ procedures.
Implementing procedures shall address 11 records administration; receipt of records; storage, preser-vation, and safekeeping of records; record retrieval; and the disposition of records in accordance with requirements identi-a fied in Table 17.2-3.
The Manager Nuclear Services is responsible for assuring the handling and maintenance of Quality Assurance records generated, received, and stored at the home office.
The Plant Manager shall provide for the 18 administration of the Quality Assurance record system at the WCGS.
The Quality Assurance Division shall audit the home office and the WCGS Quality Assurance record storage systems la to verify their effectiveness.
17.2.17.3 Records Index The requirements for records administration shall specify that Quality Assurance records be listed in an index.
The index shall be established prior to the receipt of records and shall indicate the location of records.
Distributing and handling I>
Rev. 11 17.2-55
SNUPPS-WC 17.2.18 AUDITS 17.2.18.1 Scope A comprehensive audit program in compliance with ANSI N45.2.12 shall be established and implemented by KG&E to verify inter-nal and external quality activity compliance with the OQP. The l8 audit program shall assure that applicable elements of the program have been developed, documented, and are being effec-tively implemented and shall provide for reporting and review-U.g audit results by appropriate levels of management. The audit system is described in manuals and procedures.
Non-conformances and program deficiencies shal.1 be identified and corrective action chall be verified.
The KG&E audit system shall include the performance of audits and surveillances.
Audits determine, through investigation, the adequacy of and adherence to established procedures, instructions, specifications,
- codee, and other applicable contractual and licensing requirements and the effectiveness of implementation.
Surveillances are narrow scope investiga-tions which include direct observation of activities affect-ing quality.
Surveillances shall be conducted by QA Division i
personnel who may or may not be Lead Auditors, and may or may not include entrance and exit meetings.
Surveillance activi-ties are planned, ccnducted, documented, reported, followed-up, and closed out in accordance with written procedures.
17.2.18.2 Responsibilities The Quality Assurance Division shall establish a program which p
provides for the qualification and training of audit and sur-veillance personnel.
The Director Quality shall be responsible for assuring the18 implementation of a comprehensive system of planned audits to verify compliance with the 00P.
The Quality Assurance Divi-lll sion has sufficient authority and organizational freedom to e
schedule and perform both internal and external audits, and has the organizational responsibility to measure and assure the overall effectiveness of the OOP.
The Quality Assurance Division is independent of the economic pressures of produc-tion.
The Director Quality has direct access to the Vice President - Nuclear for resolution of any areas in question.
l :L The Manager Quality Assurance (WCGS) is responsible for assur-ing that the OQP is being effectively implemented for onsite 2
operating activities and shall direct full attention to this(
effort.
He reports on the program effectiveness directly to l 1 the Director Quality.
A communication 8
Rev. 11 17.2-58
SNUPPS-WC path shall exist between the Manager Quality Assurance (WCGS) h and the Plant Manager, thus providing a direct path to inform 1 management regarding conditions affecting quality.
The Manager Quality Assurance (Home Office) is responsible for assuring that the operating quality program is effectively I
implemented for offsite safety-related and special scope activities and directs full attention to their effort.
He reports on the program effectiveness directly to the Director Quality.
A communication channel shall exist between the Manager Quality Assurance (Home Office) and the Nuclear Department home office management staff thus providing a direct path to inform them of conditions adversely affecting quality.
Rev. 11 17.2-58a
SNUPPS-WC 17.2.18.3 Auditor Qualifications Audits shall be performed by qualified personnel.
Auditors s
shall be trained individuals certified to meet internally designated personnel qualifications which assure his capabil-ity to direct an audit, perform an audit, report audit find-ings, and to evaluate corrective action.
Other personnel may assist auditors in the conduct of audits, namely, technical specialists, management representatives, or auditors in train-ing.
Such personnel selected for auditing assignments shall have training or experience commensurate with the
- scope, complexity, or special nature of the activities to be audited.
Personnel performing audits shall have no direct responsibil-ity for the area audited.
The auditor training program shall provide appropriate general orientation and specific training which develop competence for performing audits.
Training records shall provide a history of auditor training, evalua-
- tions, recommendations, qualification certifications, and retraining.
Personnel in the Quality Assurance Division shall be qualified as auditors in accordance with the requirements prescribed in the operating quality program.
Auditor qualification require-l3 ments shall include education or professional status, previous work experience and training, training received through KG&E, on-the-job performance and participation in audits as a
trainee, and other performance factors applicable to auditing not defined by procedure.
The qualification and certification l1 of auditors shall be based on an evaluation of these factors by the Quality Assurance Division. The maintenance of profi-l i,1 ciency by auditors shall be accomplished by regular and active participation in the audit process or training, and a review of program, codes, standards, procedures, and other document revisions related to the OOP and program auditing.
The is ' 1 l
certification period shall not be finite.
An auditor's qual-ification may be rescinded.
The failure to maintain profi-ciency in the audit process shall be basis for revoking the qualification certification.
In such cases, requalification shall be required.
17.2.18.4 Audit Planning I
The audit system shall include internal and external audits.
The system shall be planned, documented, and conducted to assure coverage of the applicable elements of the OOP, and lt overall coordination and scheduling of audit activities.
The Quality Assurance Division shall review the OQP audit program F annually to assure audits are being accomplished in accordance t
with the requirements described herein.
I a
Rev. 11 j
17.2-59
SNUPPS-WC Audits shall be conducted using written plans in accordance with Quality Assurance Division procedures.
The procedures require evaluation of work
- areas, activities, processes, goods, services, and the review of documents and records for quality-related practices, procedures, and instructions to determine the effectiveness of the implementation of the OQP l1 and compliance to 10 CFR 50, Appendix B.
The audit plan shall identi fy the audit scope, the requirements, the applicable documents, the schedule, and the written procedures or check-lists as appropriate.
The audit plan and any necessary refer-ence documents shall be avallable to the audit team members.
17.2.18.5 Audit Frecuency Internal audits shall be conducted by the Quality Assurance Division and shall be performed with a frequency commensurate with their safety significance.
An audit of safety-related functions shall be completed in accordance with formal audit schedules within a period of two (2) years.
Each element of the OQP, such as design control and document control, and each ]/
area of plant operations shall be audited.
Supplementary to the biennial requirement to audit all safety-related functions, the following program elements shall be audited at the indicated frequencies:
1.
The results of actions taken to correct defi-ciencies that affect nuclear safety and occur in facility equipment, structures, systems, or method of operation at least once per six months.
2.
The conformance of facility operation to provisions contained within the Technical Specifications and applicable license condi-tions - at least once per 12 months.
3.
The pe rfo rmance, training, and qualifications of the facility staff at least once per 12 months.
Audits shall also be conducted when (1) cignificant changes are made in functional areas of the operating quality program, l#M such as significant reorganization or procedure revisions; or
+
(2) when it is suspected that the quality of the item is in jeopardy due to deficiencies in the quality assurance program; or (3) when a systematic, independent assessment of program effectiveness is considered necessary; or (4) when necessary to verify implementation of required corrective action.
The NSRC shall review audit reports of onsite audits.
The QAC t
I l
Rev. 11 17.2-60
_~
SNUPPS-WC I
shall also periodically review the onsite audit program as developed by the Quality Assurance Division to assure that audits are being performed in accordance with the requirements of the OQP.
Appropriate levels of management will be pro-l8 vided copies of internal and external audit reports.
17.2.18.6 Supplier Audits External audits shall generally be conducted by the Quality Assurance Division as a measure for the evaluation of procure-ment sources and as a postaward source verification of con-formance to procurement documents.
Audits conducted by other organiza tions,
including other utilities or A/Es, may be employed as a means of postaward source verification in lieu of KG&E performed audits and may not audit specific items furnished to KG&E.
Off-the-shelf iteme whose fulfillment of the technical and quality requi reme nts are accepted by receiving inspection are exempt from the audit program.
Similarly, other items which are not off-the-shelf but are relatively simple and standard in design and manufacture may not require pos taward source verification audits to assure their quality.
Applicable elements of suppliers' quality assurance programs shall be audited (postaward) on a frequency that is based upon the status and importance to safety of the activities being performed.
Audits are generally initiated when sufficient work is in progress to determine whether the organization is complying with the established quality provisions.
Subsequent contracts or contract modifications which significantly on-i large the scope of activities by the same supplier shall be considered in establishing audit requirements.
Supplementary to or in lieu of audits, annual evaluations of suppliers may be performed which take into
- account, as applicable, (1) the review of supplier furnished documents i
such as certificates of conformance, nonconformance notices, j
and corrective actions; (2) results of previous source verifications, audits, and receiving inspections; (3) ope ra t-t ing experience of identical or similar products furnished by the same supplier; and (4) results of audits from other sources.
17.2.18.7 Audit Team Composition An audit team consists of one or more qualified persons.
A qualified auditor shall be appointed audit team leader.
The audit team leader shall be responsible for the written plans, I'
checklists, team orientation, audit notification, preaudit conference, audit performance, postaudit conference, report-
- ing, reco rds,
and iollow-up activity to assure corrective Rev. 11 17.2-61
i TABLE 17.2-1 03NTROLLED PROCEDURE MANUALS Identification Description Approval Wolf Creek Project A manual consisting of All sections of this manual Policy Manual policies and general proce-will be reviewed and dures whidi have appli-ccznmented upon by the Divi-cability to all project sion Heads.
personnel. These 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 Vice izations involved with the President-Nuclear.
project, and establish ccamon methods for activities performed by the nuclear divisions which must be uniform.
Wolf Creek Generating A multi-volume set of For the Operations Organization, Station Procedure Manuals procedures prcpared all safety-related procedures by the plant staff with and all revisions thereto shall the aid of the other be reviewed by the WCGS Plant SLVPPS utility, the Lead Safety Review Ccamittee (PSRC)
A/E, and the USSS supplier.
or a subccumittee thereof. Final These procedures are approval of all procedures divided into two areas, and revisions to the Operating q
Operations and Startup.
Organization procedures are The Operations section of made at the appropriate manage-1 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-preoperational test procedures, cedural controls under administrative procedures, and the direction of the cilanges thereto are approved by Plant Manager. The lI the Joint Test Group (JIG) and Startup section of the the apprcpriate management level Station Manual is con-in accordance with the applicable trolled, issued and administrative procedures.
approved in accordance with the applicable pro-QA personnel will review the cedural controls under administrative and inspection the direction of the procedures contained in this Startup Manager. Them manual and any revisions or procedures inplement the changes thereto.
requirenent specified in the OQM, where requiral, l*
regarding NCGS internal and external interfacing of operating quality activities. These manuals l
include administrative con-I trols for the conduct of an l
l Rev. 11 l
l
.~..
TABLE 17.2-la CONTIOLLED PROCEDURE RVIUALS Identification Description Approval Wolf Creek Generating efficient and orderly Station Procedure Manuals preoperational and start-up (cont'd) test program as well as the plant cperating procedures.
KG&E Procedures Manual A Manual consisting of All safety-related procedures a set of procedures within this manual and all revi-prcpared by various sions thereto shall y prepared responsible KG&E by the responsible division divisions. These pro-or function and shall receive cedures are approval a quality review by the Quality by the various Assurance Division. Final division heads and approval of all safety-related serve to inplement the procedures and revisions to this requirerents specifial manual is by the responsible in the OQM regarding li division head and the Director i
off-site and on-site Quality.
quality activities of the Divisions which support the startup and oper-ation of the ICGS.
Rev. 11
SNUPPS-WC TABLE 17.2-2
!l OQP IMPLEMENTItG PIK)CEDURAL GNERAGE ACTIVITY 10 CFR 50, APPENDIX B Station Operations (incuding nuclear fuel I, II, V, VI nunagenent and station operations, maintenance and nodification control)
Preparation, Review, Approval, and Revision I, II & VI of OCAP Manuals Preparation, Revies, Approval, and Revision II, V & VI of Implenunting Procedures Personnel Indoctrinations, Trauung and II Qualification Design Control (including control of design III criteria, performance of design review and verification, and control of design interfaces) 4 Preparation, Review, Approval, and Revision III, IV & V of Specifications Preparation, Review, Approval, and Revision III & V of Drawings Preparation, Ibvi.ew, Approval, and Revision III & IV i
of Requisitions Preparation, Ibview, Approval, and Revision III of Engineering Service Agreenunts Design Change Control III Preparation, Review, Approval, and Revision IV of Contracts Document Control VI Bid Requests and Evaluation VII a
e Rev. 11
1 SNUPPS-WC TABLE 17.2-2 (sheet 2)
OQP IMPLEMENTING PRXEDURAI, CT)VERME
}'
i ACTIVITY 10 CFR 50, APPEBOLX B Supplier Evaluation, Selection, and Control VII (including procurement change controls)
Material Control (including receipt, identi-VIII & XIII fication, handling, storage, and shipping)
Special Process Controls IX Inspection Controls X & XII Test Control XI & XII Inspection, Test, and Operating Status XIV Nonconformance and Corrective Action XV & XVI Controls Receipt, Storage and Transfer of Records XVII Quality Program Audits and Evaluations II & XVIII Auditor Training and Qualifications XVIII 0
SNUPPS-WC TABLE 17.2-3 QUALITY PROGRN4 00t@!ITIMENTS '10 REGULNIORY lI GUIDES AND ENDORSED CODES AND STANDARDS REGULATORY GUIDE ENDORSED STANDARD /CDDE 1.8,*
" Personnel Selection and Training" ANS 3.1 - 1978 (Rev. 2, 2/79) 1.26,*
" Quality Group Classifications and None Standards for Water, Steam-and Radioactive-Waste-Containing Components of Nuclear Power Plants (Rev. 3, 2/76) 1.29,*
" Seismic Design Classification" None (Rev. 3, 9/78) 1.30,*
" Quality Assurance Requirments ANSI N45.2.4 - 1972 for the Installation, Inspection, and Testing of Instrumentation
]
and Electrical Equipment" (Rev. O, 8/72) 1.33,*
" Quality Assurance Program ANSI N18.7 - 1976/ANS-3.2 Requirements (Operation)"
(Rev. 2, 2/78) 1.37,
" Quality Assurance Requirements ANSI N45.2.1 - 1973 for Cleaning of Fluid Systems and Associated Components of Watr-Cooled Nuclear Power Plants" (Rev. O, 3/73) 1.38,*
" Quality Assurance Requirements ANSI N45.2.2 - 1972 for Packaging, Shipping, Receiving, Storage, and Handling of Items for Water-Cooled Nuclear Power Plants" (Rev. 2, 5/77) 1.39,*
"flousekeeping Requirements for ANSI N45.2.3 - 1973 Water-Cooled Nuclear Power Plants" (Rev. 2, 9/77) 1.58,*
" Qualification of Nuclear Power ANSI N45.2.6 - 1978 Plant Inspection, Examination, and Testing Personnel" (Rev. 1, 9/80) i 1.64,
" Quality Assurance Requirements ANSI N45.2.11 - 1974 fer the Design of Nuclear Power Plants" (Rev. 2, 6/76)
Rev. 11
""'!r'E"'
WOLF CREEK GENERATING STATION k'
CHAIRMAt4 0F THE DOARD UNIT NO.1 FINAL SAFETY ANALYSIS REPORT FIGURE 17.2-2 VICE E IDENT KG&E ORGAllIZATIO!1 FOR TECHNICAL SERVICES tJUCLEAR OPERATIOt1S VICE PFESIDENT NUCLEAR PROJECT DIRECTOR DIRECTOR NUCLEAR DIRECTOR CPERATlCNS QUALITY MANAGER MANAGER MANAGER MANAGER FA> CLEAR PLANT NUCLEAR MANAGEMENT ADMINISTRATIVE ENGINEERING SERVICES SYSTEMS SERVICES SUPT.
MANAGER MANAGER QUALITY QUALITY CUALITY l
l l
l CONTROL ASSURAtCE ASSURAtCE (Home Office)
(WCGS)
+
STCRTUP PLANT FLUlO
~
RAD /ENVIR
~
CONTRCL
~
COORDINATOR DOCUMENT NUCLEAR MANAGER MANAGER
~
ENGINEERING SYSTEMS ASSESSMENT WCGS WCGS HOME Or ICE WCGS CFF ICE r
l LICENSir4G 1 RECORDS HUMAN DPERA TINC QUAll'( ASSUR-QUALfTY ASSUR-l ELECIRlCAL MANAGEMENT RESOURCES STAFF AtCE SUTF
'JCE STAFF SYSTEMS l
MANAGER PLANT STAFF
~
ENGINEERING ENGINEERING C0t4F IGUH A f l0N PLANNING SAF E T Y PROJECT NLTLEAR (see Figure VRQlNING 13 1-1)
MANAGEMENT
& CONTRCIS iCOMPUTER AND
~~
C0tt.tUNICA t :ONS NUCLEAR FUEL SYSTEMS ENGRG ENGINEERING KEY FACILITIES STAFF (URANIUM l
~ ADMINISTRATIVE DIRECTICN ENGINEERING
~
PROCIEEMENT l
FOR MATTER 10F AN ltt?EDI ATE NATURE, THE VICE PRESIDENT -
AND ANALYSIS AND COST ANALYSIS)l NUCLEAR CCif tUNICATES DIRECTLY WITH THE PRESIDENT AND CHAIRMAN OF THE BOARD NUCLEAR PLAttT EtGINEER ING REPORTS TO:
~
SITE
- VICE PRESIDENT - NUCLE AR FOR OVERALL PROGRAM DIRECil0N PLANNING &
' PROJECT DIRECTOR FOR DAY-TO-DAY PROJECT ClRECTION
~
ADMINISTRATION
+ PROJECT DIRECTOR FOR PROJECT COORDINATION
.lNICLEARDESIGNj