ML20082H198
| ML20082H198 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 04/07/1995 |
| From: | WISCONSIN ELECTRIC POWER CO. |
| To: | |
| Shared Package | |
| ML20082H196 | List: |
| References | |
| NUDOCS 9504140222 | |
| Download: ML20082H198 (33) | |
Text
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e ATTACHMENT 1 PROPOSED REVISIONS TO FSAR SECTION 1.8, "OUALITY ASSURANCE PROGRAM" The proposed changes to FSAR Section 1.8, " Quality Assurance Program," fit into four separate categories. A description and justification for the proposed changes are provided in the following sections.
Oraanizational Chances:
The Nuclear Power Business Unit (NPBU) is currently proposing changes in its organizational structure and responsibilities. The proposed changes would no longer require the Quality Assurance Section (QAS) to be responsible for certain day-to-day activities associated with procurement. Currently, the Site Quality Assurance Group is responsible for performing reviews of all NPBU procurement documents. They are responsible for verifying conformance of received items to purchase document requirements through various activities, including receipt inspections and the review of documentary evidence of quality prior to the release of these items for use at Point Beach Nuclear Plant. These proposed organizational changes would shift procurement responsibilities from the site Quality Assurance Group to a group, located onsite within the plant's line organization, reporting directly to the plant manager.
This proposed change can be characterized as a reduction in our current commitments in FSAR Section 1.8. However, we believe that this change is acceptable because QAS will be responsible for evaluating and verifying performance of procurement activities through periodic audits and surveillances. QAS will also continue to conduct audits and surveillances of suppliers and vendors as well as maintain the qualified supplier's list. We believe that the continued performance of these activities satisfy our commitment to the provisions of ANSI N45.2.12-1977, " Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants." These proposed changes will streamline NPBU procurement activities, enhancing productivity and quality.
In order to support these proposed organizational changes, the responsibilities of the Site Quality Assurance, Quality Verification, Quality Support, and Quality Technical Services groups will be performed by the new Quality Verification, Quality Supplier Services, Quality Support and NDE Services, and Quality Technical Services groups within the new organization. With the exception of three procurement-related responsibilities currently performed by the Site Quality Assurance group, all of the responsibilities described in FSAR Section 1.8.1, " Organization,"
will be performed by one of the four new groups. It should also be noted that some of the existing responsibilities were clarified and several new responsibilities were added for completeness.
Page 1 of 4 EBR4 ABBER 82888366 P PDR
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The three responsibilities currently performed by the Site Quality Assurance group that we propose to revise are as follows:
- Perform quality assurance reviews of maintenance and modification documents. In regard to modifications this includes scoping for QA applicability of the work to be performed.
- Perform reviews of all NPD generated procurement documents.
These reviews include scoping for QA applicability and establishment of appropriate quality assurance requirements.
- Verify conformance of received items to purchase requirements through various activities including review of documentary evidence of quality prior to release of the items.
The current requirements of the first item will be met through the performance of audits and surveillances of the modification process and the maintenance work request / corrective action process. These audits and surveillances will be performed as required by ANSI N45.2.12-1977. We believe that the intent of this current item will be satisfied through our commitment to this ANSI etandard.
The current requirements of the second and third items, as discussed earlier, will no longer be performed by members of QAS.
These responsibilities will be performed by a group, located onsite within the plant's line organization, that would report directly to the plant manager. QAS would be responsible for performing audits and surveillances of these activities, as required by ANSI N45.2.12-1977.
Figure 1.8-3, " Quality Assurance Section Organization," will be revised to reflect the new proposed organizational structure.
Figure 1.8-1 will alao be revised to reflect the correct organizational structure of Wisconsin Electric Power Company. i 1
Administrative Controls:
In an effort to reduce the number of different types of manuals and to standardize their distribution and maintenance processes, three new manuals have been issued to replace the QA Policy Manual, the QA Procedures Manual, the QAS Instructions Manual, the PBNP Administrative Control Policies and Procedures Manual, and the NP ,
Department Procedures Manual. The QA program is now described in l the NPD Administrative Manual, the NPD Procedures Manual, and the i NPD Organization Manual. This change is not a reduction in commitment because all of the QA policies and procedures have been l incorporated into the new manuals. References to any of the !
canceled manuals will be removed from FSAR Section 1.8. l Page 2 of 4
i s
Additionally, the distribution and maintenance of these manuals will no longer be performed by the Quality Assurance Section. The Nuclear Planning, Systems and Support Section is now responsible for the distribution and maintenance of the Administrative Manual and the organization Manual. The Nuclear Operations Section is now responsible for the distribution and maintenance of the Procedures Manual.
Although the Nuclear Planning, Systems and Support Section and the Nuclear Operations Section are responsible for the distribution and maintenance of these manuals, each individual policy, organizational description, and procedure is " owned" by a specific section or group within the business unit. Review and approval of any proposed revisions to these policies and procedures must be performed by the owner. Having this administrative control in place ensures that no revisions can be performed without the approval of the appropriate section or group. All of the QA policies, organizational descriptions, and procedures are owned by groups within QAS. Therefore, these proposed revisions do not remove any existing controls, they simply revise the distribution and maintenance requirements for the new manuals. We believe that these proposed revisions are not a reduction in commitment and are acceptable.
Technical Specifications' Audit Frecuencies:
In a letter dated January 24, 1995 as amended on February 24, 1995, Wisconsin Electric submitted Technical Specifications Change Request 176. This change request proposes to remove Quality Assurance audit frequencies from the Technical Specifications. In support of this change request, we propose to add a description of the affected Technical Specifications audits, along with their respective frequencies, to FSAR Section 1.8.18. None of the audit frequencies will be changed by this revision.
Editorial Chances:
There are numerous editorial changes proposed throughout FSAR Section 1.8. A description of each of these proposed editorial changes follows:
During a recent organizational change within Wisconsin Electric, the organizational title of " Nuclear Power Department" was changed to " Nuclear Power Business Unit." Throughout this section, " Nuclear Power Business Unit" or "NPBU" will replace
" Nuclear Power Department" or "NPD" to reflect this organizational change.
Page 3 of 4
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- We propose to change the term "QA scope" to " augmented quality."
Augmented quality is the appropriate classification, as defined in our QA program, for any structures, systems, and components that could contribute to causing undue risk to the health and safety of the public or loss of services should they fail or j malfunction. ;
- Page 1.8-4 is being revised to identify the reporting relationship for the Manager-Nuclear Operations. This person is in charge of the Nuclear Operations Section and reports to the l Vice President-NPBU. This proposed revision is being added for i completeness and is not the result of any organizational change.
- Page 1.8-4 is being revised to state that the Manager-Quality Assurance has the authority to stop work of both NPBU personnel I and contractors when quality deficiencies warrant such action. l This proposed revision is not a new job responsibility, but is l being added for completeness.
- Page 1.8-20 is being revised to state that the effective revision of SNT-TC-1A is in accordance with the latest version of the ISI ten-year plan. This information is being added for completeness and is not a change in current practice.
- Page 1.8-22 is being revised to identify that Work Orders, in addition to Maintenance Work Requests, are used to identify and control nonconforming items requiring repair or rework to be returned to a satisfactory condition. This proposed addition is being made simply to ensure that all of the applicable control processes are identified.
- Throughout this section, we propose to add the appropriate I revision year to each of the ANSI standards to which we are l committed. These proposed additions do not change any I commitments, they simply add clarifying information to the section.
Page 4 of 4
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1.8 OVALITY ASSURANCE PROGRAM i
In accordance with Paragraph 50.34 of 10 CFR 50 and 71.24 of 10 CFR 71, a NuclearQualityAssuranceProgramD{escriptionisprovidedbyWisconsin Electric Power Company (WE). This Program assures that the required manpower, procedures, and management of M@Mif6MB@hB]@lpif((PByg
}jjlsp]pj Point Beach Nuclear Plant are directed toward satisfying the Company i objectives of providing safe and reliable structures, systems, and components; and complying with the provisions of 10 CFR 50, Appendix B " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants"; 10 CFR 71, Subpart H " Quality Assurance for Packaging and Transportation of Radioactive Material"; and the applicable Sections of the ASME Boiler and. Pressure Vessel Code. This description is structured in accordance with the 18 criteria of Appendix B.
4 The following describes the quality assurance program established and imposed by the Company for application to the functional aspects of structures, j systems, components, including the design, purchasing, construction, and i fabrication, handling, storage, shipping, cleaning, installation, erection, inspection, testing, operation, maintenance, refueling, repair, and j modification of equipment considered significant to safety by the Company.
These structures, systems, and components may be classified as safety-related l(SR{ in that they prevent or mitigate the consequences of postulated accidents. Others, as in the case of radioactive material packaging, fire protection, and station blackout may be classified as QA secpelijsg6]iy psi {y[(AQ{ in that they could contribute to causing undue risk to the health and safety of the public or loss of services should they fail or malfunction. Structures, systems, and components not classified as safety-related or QA-seepe $ 5 Kd{ Q y iljjy items are controlled as necessary to provide assurance of quality commensurate with the importance of the function (s) to be performed. The principal objectives of the quality assurance program and' the key functions and elements which it contains are not expected to change. However, circumstances may make advisable changes in the organization or in the implementing detail necessary, and such changes will be made in accordance
- with established procedures. Changes in the quality assurance program description will also be submitted to the NRC as required by 10 CFR 50.54.
1.8-1 June 19932565lQf95 ) i
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e , , ! The Point Beach Nuclear Plant Quality Assurance Program commits to the l guidance provided in ANSI N18.7-1976, except as specifically noted. Where exceptions are noted in the text of this section, th: PS"P2f6 alternative system is discussed. Commitment to ANSI N18.7-1976 includes either complete l or partial commitment to the following additional standards: ANSI N18.1-1971 Selection and Training of Nuclear Power Plant Personnel ANSI N18.17-1973 Industrial Security for Nuclear Power Plants ANSI N45.2.1-1973 Cleaning of Fluid Systems and Associated Components ! for Nuclear Power Plants. ANSI N45.2.2-1972 Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants (During the Construction Phase) 4 ANSI N45.2.3-1973 Housekeeping During the Construction Phase of Nuclear Power Plants ANSI N45.2.4-1972 Installation, Inspection, and Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations ANSI N45.2.5-1974 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants ANSI N45.2.6-1973 Qualification of Inspection, Examination, and Testing Personnel for the Construction Phase of Nuclear Power Plants ANSI N45.2.8-1975 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants ANSI N45.2.9-1974 Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants ANSI N45.2.10-1973 Quality Assurance Terms and Definitions ANSI N45.2.ll-1974 Quality Assurance Requirements for the Design of Nuclear Power Plants ANSI N45.2.12-1977 Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants l 1.8-2 J= 1993jliin@995 ! l
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_i1 ANSI N45.2.13-1976 ~ Quality Assurance Requirements for Control of
- Procurement Items and Services for Nuclear Power
, P1 ants 1 ANSI N45.2.23-1978 Qualification of Quality Assurance Program Audit Personnel For Nuclear Power Plants ;
. ANSI N101.4-1972- Quality Assurance fee Protective Coatings Applied to Nuclear Facilities l l
c j To the extent required by ANSI N18.7-1976 as hereinafter specifically noted, P8NP M M hereby commits to the above standards. Table 1.8-1 provides ! further information regarding commitments to regulatory guides and related standards, i 1.8.1 ORGANIZATION The authorities and responsibilities of persons and organizations performing
- quality related activities are established, assigned, and documented in a formal system. . Quality assurance and quality control functions are performed
.by Company organizations (including both on-site-and off-site personnel)
I except when the scope of specific projects dictate the need to engage
- contractors to perform specific services or as otherwise noted.
Those persons and organizations assigned such functions are given appropriate and sufficient authority and organizational freedom to identify quality problems; verify implementation of the solutions; and prevent further processing, delivery, installation, or use of nonconforming items until proper dispositioning has occurred. The organizational structure and functional responsibility assignments are such that: (1) attainment of quality objectives is accomplished by individuals , assigned responsibility for activities affecting quality or performing work to
-specifications, (2) audits verifying conformance to established quality . I requirements are accomplished by those who do not have-direct responsibility for performing the work being verified, and (3) personnel in key quality assurance functions have direct access to responsible management. The
- education and experience required of individuals assigned to QA positions is l
documented and approved by management. 1.8-3 J= 199@Hij95
l l The organization for quality assurance is reflected in Figures 1.8-1, 1.8-2, and 1.8-3. The Vice President-Nuclear Power 00p;rt=cntlBRjWiiRDj((, who reports directly to the President - Wisconsin Electric Power Company, has been < delegated the authority by the President to establish quality assurance policies, goals, and objectives as applicable to the Pcint S :ch Nuclear Pl:nt
- nd the Nuclear Power Ocp;rt=cnt B p @ sI[U Mt although the President retains ultimate responsibility.
Manaaer - Nuclear Ooerations TheManager-NuclearOperations?i(n]}@IjfltfiiNid]eE0fdiff6sgsiff@
}@$f82iR}il@j((Ey}$EffjMJ((QFjg@@id is the senior company representative at the plant facility and, as such, is in direct day-to-day control of all normal plant administration and technical operations. In matters related to quality assurance, the Manager remains cognizant through direct involvement and through input from various sources including the &Re Quality Assurance geeup jid[@.
Manaaer - Quality Assurance The Manager - Quality Assurance [ as the head of the Quality Assurance Section (QAS)? reports to the Vice President - Nuc4 ear Pcwcr Ocp;rtment hgBU and has responsibility for both " headquarters" quality assurance functions and various quality assurance activities at the site. 1pil@{ij'e}{QAs[@f]}$ijjj{@[i]
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, t0 in:crvie inspect'On ;ctivities. Off-Site Review Committee The Off-Site Review Committee (0SRC) is established in accordance with Technical Specifications, Section 15.6.5.2. The OSRC selectively reviews designated activities involving the operation of Point Beach Nuclear Plant including Technical Specification compliance. The committee's specified duties and functions are described in the PBNP Technical Specifications, Section 15.6.5.2.1. In dditien to the :beve, tJhe OSRC is also tasked with the responsibility of assessing the adequacy and effectiveness of the " le:r ";;r Dep:rt:::t (".a0) (R8QQualityAssuranceProgram. This is done in concert with their review , functions as described above in addition to review of NPD .N.PB.U QA policier, - procedures and practices. Assessment of the program.is also achieved through other means such as initiation of periodic audits. 1.8-8 4tme-1993Juli_i71_99_5 _ a
' ' ' ' " - ' - - " - ' ' - ' ' - ' - ' - - - ' " - ' + - - -~
.~ - . . - .
i 1 o e 1.8.2 QUALITY ASSURANCE PROGRAM
\
A quality assurance program is established and implemented in accordance with j written policies, procedures, and instructions which comply with the ) requirements of 10 CFR 50 Appendix B and 10 CFR 71, Subpart H. The program is also applied to activities such as fire protection to a degree commensurate 1 with Wisconsin Electric commitments. Specific QA Program applicability to fire protection, radioactive material packaging and station blackout is defined in Tables 1.8-2, 1.8-3 and 1.8-4, respectively. The Nuclear Pcuer Ocpart: cat NPBU Quality Assurance Program is set forth in the NPD QA Policy _- ~ l Adm_ini_st_H_il_n Manual, the NPD QA Procedures Manual (NP{s,--isd the QAS
- - l' 4nstructi=: NPOT6F inifi..-.._H6R j Manual ,}N0(:#, the PSNP Admini:trative Centrcl Policie: =d Procedure: M=u;1, =d the NP Ocpartment Procedure: M=u:1.
Control of the above manuals is as follows:
- 1. Distribution and maintenance of the " Nuclear Power Department Quam +y A::ur=ce Policy Ad_ilil_itN._._il_s
_ ~ Manual" and revisions thereto are ! ccatrolled piii[f6fiid by the Quality A::ur=ce SectionlNU61{sMTsglyp? 7n Sy-st~ems..- Vand..$.upp, r ,t --S,ection. The QA policies in S cti -e,6.0fof.- ._on
. . o.-- ;x-- this 1 manual are approved by the Vice President - Nuclear Pcwcr Ocpart: cat ,
1 _NP80.
- l i
l
- 2. Distribution and maintenance of the " Nuclear Power Department Procedures i Manual" and revisions thereto are ccatrolled _per.fo,g._d e by the Nuclear Pl=ning System: =d Support OpiFitT663 Section. The manual procedures 4
and subsequent revisions are approved by the designated section manager l within the Nuclear Pcwcr Ocpartment NPBU assigned primary responsibility I l
- for the procedure.
- 3. Distribution and maintenance of the " Nuclear Power Department Quality A::ur=ce Precedure: 0FiiK{ fat]6ij Manual" and revisions thereto are con-trolled by the Qualita" A::ur=ce Section5N0E.lii_EPlissTHEi y_lisi_tiiid.
~. - -
J SQp{6htlSijti6n. The ==ual precedure: =d subsequcet revi:icn: arc cpproved by the designated cction manager within the Nuclear Pcwcr Ocp;rt==t =:igned primary rc pensibility for the Quality Procedurc . i
- 4. Distributien and ::intenance of the "PSNP Administrative Centrcl Pclicie:
1 Precedure: M=ual" =d revisien: theretc arc centrolled by the Nuc4eae 1.8-9 June 1993JyiG995 l
Op r:tica: S :tten. The :::::1 i: revi=:d :nd :ppr:ved en :ite by the pl:nt Org:niz:ti:n.
- 5. The QAS In:tr : tion: "::::1, :nd revision: ther te, :r: centrolled :nd
- ppr ved by the QAS ::: tion ::n:ger.
Final responsibility for modifications, repairs, maintenance, and operations, including the quality assurance program, lies with the President. Management review of the status and adequacy of the quality assurance program is accomplished by at least semiannual review by the Off-Site Review Committee (Section 1.8.1) and by periodic briefings with the President. The quality assurance program applies to structures, systems, components (including expendable and consumable items which are used therein) and services which are classified as QA-scope based upon the safety-related functions to be performed. QA-scope structures, systems and components are identified by various means. QA scoping is consistent with requirements of the regulations as described in this FSAR, and also includes non safety-related isgisshtid[(uility systems and components requiring quality assurance coverage such as fire protection, radioactive material packaging and station blackout. Positive controls are implemented to assure updating of the various means as necessary. The classification of a system or component as QA-scope does not imply that the complete system, or all the components or component parts within that system, are QA-scope. Those specific portions of systems considered to be QA-scope are also identified in appropriate documents. The program provides for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained. The indoctrination and training program is structured to assure that:
- 1. Personnel performing quality activities are instructed as to the purpose, scope and implementation of the quality-related manuals, procedures and instructions; and it is emphasized that these are mandatory requirements which must be implemented and enforced.
1.8-10 June 199Q6]i3)95
- j
- 5. Personnel performing quality-related activities are trained and qualified in the principles and techniques of the activity being performed.
1 3.. Appropriate training procedures are established and that records of training are maintained. 1 Section 5.2.10 of ANSI N18.7-1976 states that the provisions of ANSI N45.2.3-1973 shall be applied to those activities which are comparable in nature and l extent to related activities occurring during construction. Point Beach Nuclear Plant practices good housekeeping and cleanliness involving activities performed by plant and contractor personnel to maintain the necessary standard of cleanliness. Scheduled and documented daily-to-weekly surveys of potentially contaminated
, or radioactive areas are conducted by health physics personnel, followed by decontamination or radioactive cleanup as necessary. Surveys ensure cleanliness checks of even the least traveled areas. An additional program prev!de: thet his Operations shifts we assigned specific plant areas to patrol and clean up as a housekeeping duty. Man + RBU policy is that each person is responsible for cleanliness and good housekeeping in their own immediate work area. Final inspections of work areas following completion of work, including final internal inspections of pressure vessels, tanks, etc.,
are routinely completed by supervisory personnel. Such inspections are formally documented only in special cases when considered necessary; these normally being final inspections by plant supervisory personnel following work by outside contractors. Significant attention to housekeeping is provided by plant management on a periodic basis. Storage of items are controlled to established quality eueanee$sifitM and fire protection requirements. Access to safety-related equipment or radiation controlled areas is controlled by security regulations or defined health physics rules. 9 PBNP is committed to comply with OSHA regulations in the physical safety and environmental condition of work places. 1.8-11 J=c 1993)UpsM995
1.8.3 DESIGN CONTROL Procedures and practices are established and documented to assure that applicable regulatory requirements and design bases are correctly translated
- into design documents, such at specification and drawings, for work involving changes or additions to the original design of safety-related structures, systems, and components. .These measures include provisions to assure that appropriate quality standards are specified and included in the design documents and that deviations from such standards are controlled. The measures also include provisions to control selection and review for the suitability of application of materials, parts, equipment, and processes that-are essential to the safety-related function.
Procedures and practices are established and documented for the identification and control of design interfaces and for coordination among design organiza-tions. These include procedures among participating design organizations for the review, approval, release, distribution, and revision of design documents. The design control measures provide for verifying or checking the adequacy of design by design reviews, by alternate or simplified calculational methods, or by suitable testing programs performed by individuals or groups other than the originator. Where a test program is used to verify the adequacy of a specific design feature, provisions include suitable qualification testing of a prototype unit ; under the most adverse design conditions. Design control measures consider, as appropriate, reactor physics; stress, thermal, hydraulic, and accident analyses; compatibility of materials; accessibility for inservice inspection, maintenance and repair; and delineation of acceptance criteria for inspections and tests. l Changes to designs are subjected to commensurate design control measures. When a contemplated change is considered by appropriate management to be of sufficient scope as to be beyond the expertise of in-house personnel, these changes are reviewed by the organization that performed the original design, or other design organizations determined to be equally qualified. Design activities associated with modifications of safety-related structures, systems and components are accomplished in accordance with the provisions of Section 8 of ANSI N45.2.11-1974. 1.8-12 -June 1993
I '.'8. 4 PROCUREMENT DOCUMENT CONTROL Procedures and practices are established and documented to provide assurance that applicable regulatory requirements, design bases, and other requirements which are necessary to assure adequate quality are verified during procurement and acceptance of materials, products, or services. These measures are applied to spare and replacement parts and equipment, new material, and equipment and contracting of services. Procedures require that procurement documents be prepared, reviewed, and approved in accordance with QA program requirement,. The Occlity M;urence Sectica review procurement document to en ure the inclu:ica cf cdequcte quclity criteric. Records of the review are maintained. Procurement documents require suppliers, contractors, or subcontractors to implement quality assurance programs to the extent necessary. The programs may be reviewed by the QA Section, qualified third party organizations such as the American Society of Mechanical Engineers (ASME), industry organizations such as the Nuclear Procurement Issues Committee (NVPIC) or joint utility groups. The evaluation and qualification of supplier programs is documented. Further details of the system for control of procurement documents is contained in Section 1.8.7. 1.8.5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS Activities affecting quality are prescribed by documented instructions, procedures or drawings appropriate to the work at hand with the work accomplished in accordance with these documents. Measures are established for the preparation, revision, and control of procedures, instructions, or drawings. Instructions, procedures, and drawings are required to include appropriate quantitative or qualitative acceptance criteria to ensure work has been ! satisfactorily accomplished. Supervisors may direct that data be taken without the data taker being cognizant of the acceptance criteria when it is considered that forehand knowledge of the acceptance criteria may prejudice results. The supervisor is then responsible for verifying conformance. To the j extent applicable, as-built drawings and original equipment and system 1.8-13 June 1993Jtinsil995 l 3 l _ _ _ _ _ _ _ _ _ _ _ _ l
specifications, subject to improvements resulting from operational experience and subject to the necessary design control, establish acceptance criteria. When required, these instructions, procedures, and drawings provide methods for complying with appropriate regulations. Section 5.2.2 of ANSI N18.7-1976 requires that temporary major procedure changes which do not change the intent of an approved procedure be approved by two members of the plant staff knowledgeable in the areas affected by the procedure. One of these individuals is to be the Duty Shift Superintendent who holds a senior operator's license. As described in Section 15.6 of the Technical Specifications, Nuclear Operations follows the above guidance for operating procedures. For Maintenance, Instrumentation and Control, Technical Services, Chemistry, and Health Physics procedures, approval is not required from the Duty Shift Superintendent for temporary changes. For a further description of the system for temporary changes, refer to Section 15.6.8 of the Technical Specifications. Section 5.2.15 of ANSI N18.7-1976 requires in part that plant procedures be reviewed no less frequently than every two years. Wisconsin Electric has determined that programmatic controls exist which are equivalent to, or are more effective in meeting the intent of the standard than the static, fixed biennial review process. The alternative method implements a performance-based process for assuring procedural adequacy by initiating procedure reviews, changes, or revisions based on new or revised source material. The revision controls do not consider age as a requirement for procedure reviews. The programs in place to accomplish the alternative commitment include: the modification program; the external operating experience review program, which includes industry experience as well as vendor technical information; the procedure feedback process; the condition reporting (corrective action) program, including its associated trending and analysis program; the Technical Specification revision process, and our QA audit program, as well as internal assessment programs and process improvement initiatives. The QA audit program is structured such that a random sampling of procedures is specifically audited every two years to determine the effectiveness of plant procedures. In addition, procedure effectiveness, as well as procedure usage, is evaluated during the performance of all scheduled audits and 1.8-14 February 1995 0
surveillances. This continued QA review will ensure that the procedure review program is being effectively implemented. The procedures program contains provisions to ensure that infrequently performed procedures, tests and evolutions (IPTE) are identified and contain appropriate administrative controls to ensure the plant's margin of safety is maintained. All plant safety-related procedures have been screened for IPTE considerations. Provisions shall be established to ensure that IPTE procedures are reviewed prior to use unless they have been reviewed or used within the previous two years. This alternative program does not apply to the emergency preparedness program which will continue to be reviewd every 12 months in accordance with 10 CFR 50.54(t); the security program which will continue to be reviewed every 12 months in accordance with 10 CFR 73.55(g)(4); the fire protection plan, which will continue to be reviewed every 24 months in accordance with Technical Specification requirements; nor the emergency operating and abnormal operating procedures, which will continue to be reviewed every two years. Section 5.3.2 of ANSI N18.7-1976, which discusses the content of procedures, states in part, "... procedures shall include, as appropriate...(8) Acceptance Criteria." We have determined that the incorporation of acceptance criteria is not always advantageous, as discussed herein. 1.8.6 DOCUMENT CONTROL Procedures and practices are established and documented to control the issuance and revision of documents, such as: maintenance and modification , procedures; design specifications; design, manufacturing, construction, and I installation drawings; procurement documents; manufacturing, inspection, and l testinginstructions;testandoperatingprocedures;QAEdEihMffitiivM I
~
pg'anistio@?shQfosiddfs manuals; safety analysis reports; and related design criteria documents. The procedures identify responsibility for review, approval, and issuance of the documents and associated changes. For quality 1 related documents, the review includes an assessment of applicable quality requirements. 1.8-15 June 1995
1
. . l The procedures provide assurance that documents, including changes, are reviewed for adequacy, approved for use by authorized personnel and l distributed to and used at the location where the prescribed activity is i performed prior to commencement of the activity. These include prompt issuance of changes and control of the obsolete or superseded documents to prevent inadvertent use. Controls, such as maintenance and distribution of indices, are also implemented to identify current revision of documents to be used. Document control procedures include provisions for determining responsibility for review of changes to documents.
Documents classified as QA records are subjected to the additional require-ments described in Section 1.8.17. 1.8.7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES Procedures and practices are established and documented to assure that purchased material, equipment and services conform to the procurement documents. These measures include review of all purchase requisitions by the Quclity A::urence Secticn. QA Occpc requisiticn: cre precc::cd by the Quclity A w wance Section to ensure incorporation of appropriate quality requirements. The bases for selection of suppliers may include previous experience, satisfying the required qualifications of the contractor who erected the plant, or a pre-award evaluation of the proposed supplier's capabilities and qualifications. Industry programs, such as those applied by ASME, NUPIC, or other established utility groups, are used as input or the basis for supplier qualification whenever appropriate. Control of purchased items includes provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the contractor or subcontractor, inspection at the source, and examination of products at receipt. These controls also include provisions for monitoring contractors providing services through performance of audits and surveillances, as necessary, to verify conformance with procurement requirements. These are performed by appropriately trained personnel in accordance with written procedures and instructions. 1.8-16 June 1992Jshifl99.5
..5.* Documentary evidence is required to be available prior to use of equipment. Procedures require assignment of a Quality Assurance Release (QAR) identi-fication number prior to placing th'e purchased items into service. These procedures require all documentation required by the purchase order to be available and satisfactory prior to issuance of the QAR. Measures are provided for monitoring the effectiveness of contractor control of quality consistent with the importance, complexity, and quality of the product or services. The requirements of ANSI ?'45.2.13-1976 are met for the procurement of components within the scope of Section 5.2.13 of ANSI N18.7-1976. 1.8.8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMP 0NENTS Procedures and practices are established and documented requiring identi-fication of materials, parts, and components, including partially fabricated assemblies, to prevent use of incorrect or defective items. Identification requirements are based on as-built drawings and specifications. Identification requirements for other than identical replacement items are determined during planning for the modification or addition. Identification methods and locations are selected so as not to affect the function or quality of the item. These measures assure that identification is maintained by stock number, system identification, part number, or other appropriate means, either on the item or on records traceable to the item, as required during installation and use. These measures apply to plant items as well as those provided by on-site contractors. Procurement documents invoke appropriate requirements for identification and l control of material during manufacture, including provisions for WE in-process audits of the manufacturer's program. l 1.8.9 CONTROL OF SPECIAL PROCESSES Procedures and oractices are established and documented to assure that special processes, such as welding, heat treating, and nondestructive examinations are 1.8-17 June 1993 1
1 . . . . '.' l l controlled and accomplished by qualified personnel using qualified procedures or process sheets in accordance with applicable codes and standards. { Verification of conformance is documented. These measures require copies of l qualifications to be on site during process performance whether by WE l personnel or contractors. Procurement documents specify appropriate control requirements for processes performed off-site. 1.8.10 INSPECTION l I Procedures and practices are established and documented providing for l appropriate inspection of activities affecting quality and to verify conformance with the documented instructions, procedures, drawings, or i specifications for accomplishing the activity. Inspection procedures, instructions, and checklists include the following, as applicable:
- 1. Identification of characteristics to be inspected. I
- 2. Identification of the individuals or groups responsible for performing the inspection operation.
1
- 3. Acceptance and rejection criteria. i l
- 4. The method of the inspection, i
- 5. Verification of completion and documentation of the inspection.
Maintenance, replacement, or rework items are inspected in accordance with original inspection requirements and criteria or improved requirements based on operating experience. Modified items are inspected by methods at least equivalent to the original inspection methods. These measures provide for verification of conformance to be performed by l certified individuals other than those who performed the activity. ; Certification of these individuals in accordance with appropriate requirements is documented. Provisions for Code Authorized Inspection are included when required. ! I 1.8-18 June 1993
l Examinations, measurements, or tests are performed for work operations where necessary. Procurement documents for materials or products specify examinations, measurements, or tests to be performed for each work operations where necessary to assure quality. Quality Msurance personnel pooform receiving inspeet4en Recsivin[inshedtion]s^peFf66ned on procured materials as appropriate per the procurement documents, specifications, procedures, and instructions. Procurement documents for materials or products, for which direct inspection is impossible or disadvantageous, specify provisions for indirect control by monitoring processing methods, equipment, and personnel. When control is inadequate without both inspection and process monitoring, provisions for both are included. Handatory hold points are specified and I used where required. Section 3.4.2. of ANSI N18.7-1976 states that personnel performing inspection, examination, and testing activities shall be qualified to ANSI N18.1-1971, or shall meet the requirements of ANSI N45.2.6-1973. With few exceptions, Point Beach personnel meet or exceed the qualification requirements of ANSI N18.1-1971, and are therefore qualified to perform plant inspection, examination, and testing activities. Those few exceptions are in job functions not discussed in ANSI N18.1-1971 and certain inspection and test personnel who work for contractors as discussed below. All positions at Point Beach have been evaluated to determine the minimum qualification requirements. The areas considered during the evaluation included regulation, code and standard requirements, education and training, work experience, and physical condition. Applicants for positions at Point Beach not meeting the minimum requirements, or not satisfying preemployment aptitude testing requirements are not considered for the position. Additionally, prior to employment, all plant personnel are interviewed by senior plant management and, in most cases, are interviewed by the Manager-Nuclear Operations. These individuals make the final determination of acceptability. There is only one level of qualification at Point Beach, not , three levels as indicated in ANSI N45.2.6-1973. When the extent of the maintenance or modification is such that it must be l performed by contract, the potential contractor's QA program is evaluated by the QA Section to determine its acceptability. Included in the evaluation is consideration of the qualifications of inspection and test personnel. In l l 1.8-19 June 1995 l l
,s .'
cases w ere it is determined that a contractor's crganization is suitably qualified in all other respects, including qualified personnel, a qualification and certification program which meets all the requirements of ANSI N45.2.6-1973 is not insisted upon. Implementation of the audit program assures qualification of such personnel. All nondestructive examination personnel are required to be qualified in j accordance with the appropriate sections and editions of ASNT Recommended Practice No. SNT-TC-1A. JJi{MQjlijsIfjy))]jiilg{S$3Cl!$fl@jjjj^cl@Ijijj E!E)Rili!!itIHfi!#E!!BM M EJBI8i M Xh! Section 3.2 of ANSI N18.7-1976 requires thet verification of conformance be L performed by individuals other than those performing or directlj su,nervising the work. Verification of conformance is conducted in this manner at Point Beach. l l Section 5.2.17 of ANSI N18.7-1976 requires inspections for modifications and j non-routine maintenance to be performed in a manner similar to that associated with construction phase activities. Modifications and non-routine maintenance for which outside contractors are used are performed in this manner. )' Modifications and non-routine maintenance items within the capabilities of the on-site operating organization are performed as a routine maintenance activity. 1.8.11 TEST CONTROL Procedures and practices are established and documented to provide a program of periodic testing and continuing surveillance to demonstrate that struc-tures, systems, and components continue to perform satisfactorily in service. The measures require tests to be performed by appropriately trained and qualified personnel in accordance with written test procedures which incorporate the requirements and acceptance limits (except as noted in Section 1.8.5) from applicable design documents. Test procedures include provisions for assuring that all prerequisites for the test have been met, l that adequate test instrumentation is available and used, and that the test is performed under suitable environmental conditions. Test results are docu-l mented and evaluated to assure test requirements have been satisfied. These measures require replacement or modified structures, systems and components to 1.8-20 June 1993Jussi1995
e . g .- .. >
' lie subjected to sufficient proof, preoperational, and operational testing to demonstrate that they will perform satisfactor'ily in service.
, 1.8.12 CONTROL OF MEASURING AND TEST EQUIPMENT Controlled procedures and practices are established and documented to assure p that tools, gauges, instruments, and other measuring and testing devices used in activities affecting quality are properly identified, controlled, calibrated, and adjusted at specific intervals to maintain accuracy within I necessary limits. Calibration procedures specify standards to be used for performing the calibration. Procedures require that standards used have greater accuracy than the item being calibrated. These measures provide for identification of the equipment and associated records and appropriate ; corrective action when out-of-calibration conditions are noted. i 1.8.13 HANDLING, STORAGE, AND SHIPPING Procedures and practices are established and documented to control the handling, storage, shipping, cleaning, and preservation of material and i equipment by qualified individuals in.accordance with work and inspection instructions to prevent damage or deterioration and preclude loss of identification. The measures include specification and use, when necessary, ) of special protective environments, such as inert gas atmosphere, specific moisture content, and temperature levels. 1.8.14 INSPECTION, TEST, AND OPERATING STATUS Procedures and practices are established and documented to indicate by suitable means, the status of inspections and tests to be performed upon individual items. These measures include provisions for the identification of items which have satisfactorily passed required inspections and tests when ; necessary to preclude inadvertent bypassing of such inspections and tests. Procedural controls to perform operations out of sequence are established. These measures also include provisions for indicating nonconforming, l inoperative, or malfunctioning components within a system to prevent inadvertent operation. 1.8-21 June 1993 4
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1 1.8.15 NONCONFORMING MATERIALS, PARTS, OR COMPONENTS Procedures and practices are established and documented to control materials, parts and components, or quality activities which do not conform to established requirements. To prevent the inadvertent use or installation of-purchased material, parts, or components, these measures may include timely return of nonconforming materials, parts, or components to the vendor for replacement with satisfactory items. Formal nonconformance control systems are in place to assure control and disposition of nonconforming items or activities including adherence to 10CFR21 as necessary. Maintenance Work Requests EWk]g@i@ identify and control nonconforming items requiring repair or rework to be returned to satisfactory condition. Where a safety-related component is required to be temporarily or permanently changed, such that it no longer complies with the original and approved design, such changes, with required approvals, are made via the approved ' modification request procedure. The N h r P:=r Og:rt=nt MBli has established provisions for documenting and dispositioning nonconforming items or conditions, which are identified l during inspection, surveillance or auditing activities. 1.8.16 CORRECTIVE ACTION Proceduros and practices are established and documented to assure that conditions adverse to quality; such as failures, malfunctions, deficiencies, I deviations, defective material, and equipment and nonconformances; are ; promptly identified and corrected. In the case of significant conditions i adverse to quality, these measures include assurance that the cause of the condition is determined and corrective action taken to preclude recurrence. These include provisions for identification of the significant condition adverse to quality, the cause of the condition and the corrective action taken which is documented and reported to appropriate levels of management. Provisions are included for follow-up reviews to verify proper implementation of corrective actions and to close out the corrective action documentation. l 1.8-22 J= '993JUni3995
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1.8.17 QUALITY ASSURANCE RECORDS Procedures and practices are established and documented to assure that sufficient records are generated and maintained to furnish evidence of ) activities affecting quality. Where practicable, the guidelines of I ANSI N45.2.9-1974 apply. The records consist of at least operating logs and the results of reviews, inspections, tests, monitoring, work performance, and materials analyses. Also included are closely related data such as qualifica-tions of personnel, procedures and equipment. Inspection and test records include, as a minimum, identity of the inspector or data recorder, the type of observation, the results and the acceptability, or action taken in connection ! with any deficiencies noted. Records are identifiable and retrievable. Requirements concerning records retention, such as duration, location, and assigned responsibility, are established to be consistent with applicable regulatory requirements. Radiographs, with the exception of those associated with ASME Section XI components or systems (to be retained for the service life of the component or systems), are retained as non-permanent records for a minimum of ten years after the date of the radiograph. In either case, associated radiographic review records are permanently retained and provide necessary weld quality / acceptance information. In 1971, Wisconsin Electric recognized the need to improve its records manage- I ment program in the area of preservation of records for Point Beach. In the ; absence of any guidance in the form of regulatory guides or national stan-dards, it was decided to generally follow the requirements of NFPA 232-1970. The requirements of NFPA 232-1970 were reviewed in light of importance of the i records being stored and the risk of destruction of the records. It was determined that the records being stored required positive protection as many were irreplaceable. Possible locations for records storage facility were studied, and it was determined that the lower level of the Point Beach Energy l Center located on the plant grounds, offered an ideal location for a records i storage facility. This location was chosen since it was an area of minimum weight of combusti-bles and the building itself was fire resistant. It was determined, based on 1.8-23 June 1993
. ,6 * . the ab ve factors, that a separate room would be constructed in the lower level of the Point Beach Energy Center to provide further protection. The room was built to meet Wisconsin Administrative Code requirements for four-hour construction, and was treated to minimize the risk of water infiltration. In addition, the room was equipped with an inert gas fire suppression system which is automatically triggered by smoke or heat. Triggering of the fire suppression system also activates an alarm signal and a visible alarm which can be observed from a continuously manned guard station. Based on the analysis of the fire hazard present in the Point Beach Energy Center, the alarm system, and the sophisticated fire suppression system, it was decided that the requirement for a four-hour vault door was unnecessary. The entrance to the room is closed with a Class A 250 F labeled fire door. In addition, the fire suppression system required an electrical supply, which led to the waiving of the requirement that walls could not be penetrated by electrical conduit. The electrical supply for room is brought into the room via a conduit through one of the walls and ceiling which has been installed to minimize the risk of fire passing through the wall via this penetration. 1.8.18 AUDITS Procedures and practices have been established and documented to provide a comprehensive system of planned and periodic audits to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program. Audits are performed in accordance with written procedures or checklists by appropriately trained personnel not having direct responsibilities in the areas being audited. The QA program is audited periodically, by the QA Section. The QA Section also performs audits under the cognizance of the Off- ) Site Review Committee as required by PBNP Technical Specification 15.6. On-site and off-site contractor audits are scheduled commensurate with the work's importance to plant safety and reliability and are timed as appropriate for I the work scheduled. 1.8-24 June 1993 m .
'Wberep'ractical,auditsareconductedusingperformance-basedtechniques.
As an example, periodic operational readiness assessments of safety-related plant systems may be conducted using vertical-slice audit techniques.- Audit results are documented and reviewed by management personnel having responsibility in the area audited. Audit reports are routed to management responsible for correcting any unsatisfactory items noted. Follow-up action, including reaudit of deficient areas, is taken when indicated. When follow-up audits reveal repetitive occurrences which reflect possible trends adverse to , the effectiveness of the QA program, these results are reported to the appropriate management level to effect corrective action. Sufficient audits are performed, by the QA Section, in accordance with the provisionsofANSIN45.2.123917 to meet the requirements of Section 4.5 of ANSI N18.7-1976. Also, internal audits performed by the QA Section are led by ! individuals certified as Lead Auditors in accordance with the requirements of ANSIN45.2.2339Z8. It should be noted that Section 3.2 of ANSI N18.7-1976 recognizes that quality assurance is an interdisciplinary function and that advantages may accrue from having reviews of certain plant functions performed by individuals other than quality assurance personnel. WE strongly endorses this position. Ty;Hc:lly, Qhe QA Section assigns jiili;fj@l@ technically , competent quality assurance personnel to perform audits, however! when necc=yla5f5flife, QA personnel are supplemented with other technically qualified WE and/or contractor personnel. Audits are sometimes supplemented by surveillances of quality related activities. Surveillances are performed by qualified individuals, although not necessarily certified as lead auditors. In addition, certain review functions may be assigned to technically qualified individuals in lieu of quality assurance personnel. IEsif611Mi#iIsidit!D3shfiffaO!IthD8EIs6EsiIgsigittggfiggsfi Esffi M Iitit O hd1Eit E ffikaihE!3i! REIECWif5tsiiECifsfisillMiIfif!BiWi?if619MENi!DisB3M!i thillsiheica1[SisdifjEit16ss;iddiiS1;iEili1^e;111e6siiQs6sdiljjWgst liist%6EssligieE
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- 12. Regulatory Guide 1.94 dated April 1976 Commitment to follow the position of Regulatory Guide 1.94, which endorses and supplements ANSI N45.2.5-1974, for activities occurring during the operational phase that are comparable in nature and extent to related activities occurring during construction.
- 13. Regulatory Guide 1.146 dated August 1980.
Commitment to follow the position of Regulatory Guide 1.146, which endorses ANSI N45.2.23fl978, for internal audits performed by the Quality Assurance Section (QAS). ,
- 14. ANSI 18.7-1976 Refer to Section 1.8.0 for details of the Wisconsin Electric commitment.
I I I t Page 4 of 4 June 1991)pp{i1995
4 3, , **; # ' i- . .. 4 . WlSCONSIN ELECTRIC POWER COMPANY ORGANIZATIONS WITH QUALITY ASSURANCE PROGRAM INTERFACE WITH THE NUCLEAR POWER BUSINESS UNIT CHAIRMAN OF THE BOARD PRESIDENT OFF-SITE SENIOR VP REVIEW CORPORATE COMMITTEE CENTER CE WCE VICE DIRECTOR PRESIDENT INFORMATION FOSL NUC R FINANCE RESOURCES OPERATIONS POWER TREASURER MANAGER. RISK MANAGEMENT I PRINCIPAL. l LAB ENVIRONMENTAL FIRE PROTl CORPORATE ) DRAFTING SERVICES RISK RECORDS SERVICES l MANAGEMENT 1 I 1 l
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i l QUALITY ASSURANCE SECTION ORGANIZKTION 1 l QUAUTY. , ASSURANCE 'l SECTION 4 MANAGER 1 QUALITY QUAUTY QUAUTY
,QUAUTY SUPPUER TECHNICAL SUPPORT &
SERVICES VERIFICATION SERVICES NDE SERVICES SR. PROJECT SR. PROJECT PROJECT SR. PROJECT ENGINEER , ENGINEER ENGINEER ENGINEER l QUAUTY ASSURANCE ENG/ SPEC / TECH SUPERVISOR NDE QUAUTY *QUAUTY QUAUTY ASSURANCE ASSURANCE ASSURANCE ENG/ SPEC / TECH ENG/ SPEC / TECH ENG/ SPEC /rECH NDE LEVEL lil AND TECHNICIANS l l 1
' Personnel located both on-Site at PBNPand off-Site at the Corporate offices.
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* * * * ' *
- Figure 1.8-3 June 1995 l l
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