ML20092N851
| ML20092N851 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 06/28/1984 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8407050128 | |
| Download: ML20092N851 (40) | |
Text
{{#Wiki_filter:e O WlSCORSin Electnc eaara cournur 231 W. MICHIGAN, P.o. BOX 2046. MILWAUKEE, WI 53201 June 28, 1984 Mr. J. G. Keppler, Regional Administrator Office of Inspection and Enforcement, Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glc.. Ellyn, Illinois 60137
Dear Mr. Keppler:
DOCKET NOS. 50-266 AND 50-301 SUBMITTAL OF QUALITY ASSURANCE PROGRAM DESCRIPTION POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 In accordance with the requirements of 10CFR50.54(a)(2), we are submitting the latest revision of Section 1.8 of our Final Safety Analysis Report which describes the Quality Assurance Program being implemented at Point Beach Nuclear Plant. The QA Program description was last submitted to you on June 10, 1983. Subsequent to that submittal a request for additional information was made in a letter to Mr. S. Burstein from Mr. C. E. Norelius dated April 27, 1984 and the specific items of concern were discussed with your staff on June 7, 1984. The purpose of this letter is to respond to those items as discussed in the June 7, 1984 meeting and to also discuss changes in the QA Program that have occurred since the June 10, 1983 submittal. We continue to believe that none of the changes discussed below reflect a reduction in our QA Program commitments as previously approved by the NRC. I. Changes of June 1983 The following provides a response and/or basis for the questioned changes as submitted on June 10, 1983: 1. Page 1.8-4, paragraph 3 (Revision 1 of June 1983) On April 1,1979, the Nuclear Power Department (NPD) was estab-lished. The Director of Quality Assurance and Technical Services was named as the Director of the NPD responsible for nuclear activities within the Company including quality assurance. On 1/1/82 the Director-NPD was made an Assistant-Vice President and subsequently on 1/1/83 became Vice President-NPD. During this period the Executive Vice President retained ultimate responsi-bility for the QA Program at PBNP although authority for day-to-day establishment of quality assurance policies, goals and objectives was delegated to the V1ce President-NPD, The Vice p\\ 8407050128 e40628 PDR ADOCK 05000266 l l P pon i %%. UJ. Natl 53
( Mr. J. G. Keppler June 28, 1984 President - NPD and the General Superintendent of QA (formerly the Superintendent of QA) have always had direct access to the Execu-tive Vice President in matters related to quality through peri-odic, scheduled formal briefings or informally as the ned arose. While the organization was changing there was essentially no change in the importance placed on QA matters, the independence and authority of the QA organization, or in regard to the QA organization's access to top management.
- 2.. Page 1.8-5, Paragraph 2 (Revision 1 of June 1983)
As stated in Item I.1 above, the Director of Quality Assurance and Technical Services (QATS) has become the Vice President-NPD and, also, due to the recent reorganization, the QA Committee is now responsible to the President. The concept of rotating the chair-manship from member to member was established to allow flexibility in administration of the QA Committee and to relieve some of the burden from the then, Director of QATS. The Chairman was selected by the Executive Vice President and was afforded direct access to the Executive Vice President in matters relating to the QA Com-mittee. (Effective May 9, 1984, the chairman is selected by, and reports to, the President.) In this respect, changing the chair-person has no affect on the authority, responsibility or visibil-ity of the QA Committee. It is also our intent that the QA Committee meet on a quarterly basis. We do not consider that this commitment has been changed, although we have attempted to incor-porate provisions for those few instances where a meeting cannot be held in a specific calendar quarter due to member unavaila-bility or other uncontrollable circumstances. As indicated in the above paragraph another recent change has occurred regarding the QA Committee. In addition to the committee reporting to the President, the committee structure has also been changed. The committee membership is now composed of company officers and with this change we believe will go increased upper management involvement and high level assessment of the QA Pro-gram. These changes are reflected as part of revision 2 (Page 1.8-5, Paragraph 2). 3 Page 1.8-6, Paragraph 1, Item 3 (Revision 1ofJune1983) This change reflects a significant increase in the scope of on-site auditing activity under the cognizance of the QA ;oordina-tor. Previously the QA Coordinator performed a generic monthly audit which was limited in scope and depth. The present audit program conducted by the QA Coordinator is more detailed and comprehensive and has resulted in a major increase in scope of coverage. Audits conducted under the congnizance of the QA Coor-dinator are generally technical in nature and are performed by personnel having requisite technical competence. Qualification of personnel performing technical audits is addressed in our response to Generic Letter 81-01. This item is an example of improvements which are being made in our QA Program to enhance its overall effectiveness.
Mr. J. G. Keppler June 28, 1984 4. Page 1.8-7, Paragraph 2, Item 1 (Revision 1 of June 1983) The method of distribution and maintenance of the Administrative Control, Policies and Procedures Manual (QA Volume I), and revi-sions thereto, is described in lower tier procedures. The wording in Section 1.8 was revised to remove some of the detail which is contained in these lower tier documents. Positive controls continue to be implemented to assure current revisions are distributed and used. Various methods of control such as return-receipt documents may be implemented. However we presently perform selected surveillance of controlled manuals to verify their currency. Based on our experience at Point Beach we believe this method is more effective than using return-receipt documents. 5. Page 1.8-7, Paragraph 2, Item 2 (Revision 1 of June 1983) The method of distribution and maintenance of the Quality Assur-ance and Reliability Manual for Materials, Repairs and Modifica-tions (QA Volume II), and revisions thereto, has not changed. Wording was revised in Section 1.8 to remove some of the details which are contained in other lower tier procedures or instruc-tions. Also as stated in Item I.1 above, authority for establishment of quality assurance policies, goals and objectives has been dele-gated to the Vice President-NPD although the President retains ultimate responsibility for the program. 6. Page 1.8-8, Paragraphs 182 (Revision 1 of June 1983) Table H.2-2 which was previously included in Appendix H to the PBNP FFDSAR was deleted from Section 1.8 since it was detail which is contained in implementing documents. (Inthiscase,QAVolumeII.) The control of the list has not changed and reference to the control-ling document is made in Section 1.8. Changes to the list are con-trolled and the content of the list reflects increases in quality assurance scope systems and equipment. Revision 2 of Section 1.8 clearly establishes the scope and basis for the referenced list. 7. Page 1.8-9, Paragraph 5 (Revision 1ofJune1983) This revision to Section 1.8 was made to more clearly describe the housekeeping controls at Point Beach and reflect the actual intent of our commitments (additional clarification has also been made in revision 2). In a literal sense the commitment to " daily" house-keeping inspections by the plant manager was not possible. He continues to give personal attention to housekeeping as well as receiving considerable assistance from on-site and off-site management personnel. In addition to routine inspections such as those for fire protection or radioactive contamination, management 3rovides almost continuous attention and inspections of house- <eeping. We believe the present format exceeds the intent of our original commitments to housekeeping,
f~ Mr. J. G. Keppler Jun] 28, 1984 8. Page 1.8-13, Paragraph 2 (Revision 1 of June 1983) The provisions of paragraph 6.2.2 and 6.3 of Appendix H were inadvertently omitted when revision 0 of Section 1.8 was estab-lished in July, 1982. This omission in Revision 1 was a carry-over from revision 0 and has been reincorporated as part of revision 2 (Page 1.8-13, Paragraph 2). 9. Page 1.8-14, Paragraph 2_ (Revision 1ofJune1983) [ The controlling mechanism for incoming quality assurance materials and equipment continues to be the Quality Assurance Release (QAR) e system. Typically all requirements of the purchase order, inclu-ding documentary evidence, are satisfied and a QAR number is assigned prior to the items release from the storeroom. Occasion- / ally, however, due t6sunique or exceptional circumstances it is necessary to install, or even place into service, an item prior to s completion of all the purchase order requirements. While these s ~# ^
- occurrences are 'quite rare we have had occasion to do so.
Posi-tive control of these items is accomplished procedurally to ~m provide cation (justification for their use and to assure their identifi-cond!tional release). These controls also essure subsequent 'J-fulfillment of purchase order requirements and issuance of the QAR 1 number. These program enanpas have been more clearly addressed as part of revision 2 (page 1.0-14, paragraph 3). ~ 10. Page LO-16, Paragraph 4 (Revision 1ofJune1983) ~ l' ", The words in this paragraph, which address qualification of . inspection'end test personnel working for contractors, were y revised as part of revision 0 in July 1982. There was no intent ~ r' ', ~ at that time to change our commitment although we acknowledge that the words in Section 1.8, revision 1, convey a different perspec-tive' than those which were originally contained in Appendix H. Accordir, gly, the wording has been changed as part of revision 2 to emore accurately reflect the previous commitments. li Page '1.8-17, Paragraph 1 (Revision 1ofJune1983) g As discussed in item I.7 above, due to constraints in the Manager 'j - PBNP's availability, it is not possible for him to personally interview all plant personnel prior to employment, although 'whenever possible this is done. When conflicts occur plant policy m ' is so require interviews with other senior onsite managers. In any case, the final det(rmination of acceptability is based on the judgement of the Managet - P8NP whether throu interview or those of other senior managers. gh his personal In addition to this employment process,'the Manager - PBNP reviews individual experi-ence and qualifications prior to that individual assuming a position of authority under.the WE QA program. Clarification has been provided in revision 2 (Page 1.8-17, Paragraph 2).
- 12. Page 1.8-18, Paragraph 2 (Revision 1ofJune1983)
The change in this section was the deletion of a reference to ' c call-up cards as a methoti to control Measuring and Test Equipment JW.TE). As in previous responses, this was done to delete some of i j i
Mr. J. G. Keppler June 28, 1984 the detail which is contained in lower tier documents. At pre-sent, we continue the call-up card process, however, this method of control may be changed at a later date if a better method becomesavailable(suchasacomputer-basedsystem). We have made a change, as part of revision 2 (Page 1.8-18 Paragraph 3), to explicitly refer to " positive" control of MATE. 13. Page 1.8-19, Paragraph 3 (Revision 1ofJune1983) In this paragraph the word immediate was removed in favor of timely to better describe our practice. A literal rcading of immediate return could require the return of nonconforming ma-terial as soon as it is delivered. In fact, the process of receipt and verification of the QA documentation requires some verification period. This verification is accomplished on an expeditious basis and nonconforming materials are returned when necessary. Our commitment to return nonconforming materials has not changed. We have also made changes to this paragraph (and saragraph 4), as i part of revision 2, to reflect the evolution of t1e QA Program, and specifically, our implementation of formal provisions to control the identification and disposition of non-conforming or discrepant items. 14. Page 1.8-21 Paragraph 5 (Revision 1 of June 1983) The remote fire alarm for the records storage facility is audible and visible from a continuously manned guard station. Since this is the case we consicer the alarm to be continuously monitored. A change has been made to this paragraph, as part of revision 2, to explicitly describe this monitoring action. 15. Page 1.8 22. Paragraph 3 (Revision 1ofJune1983) The periodicity of audits conducted by the QA Coordinator or his designee was changed from monthly to quarterly to provide greater flexibility and quality in the audit process. When audits were conducted monthly, they were not as broad in scope as are the audits conducted currently. Every attempt is made to perform audits on a monthly schedule; however, flexibility must be main-tained to allow for schedular difficulties. Our conrnitment to QA audits has not been reduced, and in fact, as stated in item I.3 above, we believe a significant improvement in our on-site audit program has been made. The performance of Technical Specification audits under the cognizance of the Off-Site Review Connittee has also been ad-dressed as part of revision 2 (Page 1.8-22, Paragraph 3). II. Changes of June 1984 The following provides an explanation and/or basis for changes mado as revision 2 of June 1984:
n. 4 ~ $Mr. J. G.; Keppler ) ' June 28, 1984 Y N' p-5,< ^ g 3 h 1. General - On tw6 ochasi'ons.sinceiour last cubmittal, changes have been made'in the Company and NucleaP PoweF Department organiza-tions-as' depicted (in Figures 1.81 through-1.8-4: s s Ya.[0n January 1,$984 'the Nuctsat Erigfdering Section was split ~j' 1 _.L ~ into-two sections:' Nuclear Systems Engineering and Analysis - Section and. Nuclear Plant Engineering &> Regulation Section. .M -Eiiih;section.js headed by a General Superintendent. Also at this' time.the: Superintendent of QA became the General Superintendent of the'QA Section (Figures 1.8-2 and 1.8-4). C p, 3 n. - N .b., Effnetive May 9;'1984, the Vice President - Nuclear Power Dep'artifievit now reports to the Presidsnt (Figure 1.8-1). ~ ~. !,The organizationdl and title ~ changes are reflected throughout Section,1.8 as part of'this revis' ion. None of these changes c effect our quality assurance conmitments since the authority and y " independence.of the'Vice President-NPD and the Quality Assurance organization is not reduced;- T h ,,2; Page 1.8-1,-Paragrad 1 - 10CF.71, Appendix E, was changed to ,( 10CFR71, Subpart H, roflecting recent changes in regulation + ^nomencl ature.' ,\\ = n
- w Y
3'.. PagA l'.'8-1, Paragraph 1 " Appendix B" was added for clarity. .o 4. Page11.8-4, Paragraph 2..- The s'e'cond sentence in this paragraph =~ was relocated from page 1.8-5, P,aragraph;4. Also slight wording 1:f~ changes were madetto clarify the commitment. . b 5. Page 1.8-4, Paragraph.3 - See items I.1 and II.h above for explana- >~% k tion of. description changes. g x
- 6..Page 1.8-5,' Paragraph' 1 - Reflects chgnges in position title.
x ~ ,^..,
- 7. :Page' 1.8-G $ragraph 2 - See item I.2 above for explanation of l
changes in,tNe Quarity Assura'nce Committee. 1 8.S Page'1.8-6, Para raph 3 - Reflect's changes in organizational n. A ' title. - Also wor s were added 'to relate the verification of receDied.iteins to purchase document req 0irements. ,4
- 1. Y g -
1 y 1.' Page 1.8-7[ Paragraph 1 - Scope of this paragraph was expanded to 9 Lreflect other Quality Assurance.Section responsibilities, namely, a-v H .L' w auditing of off-site vendors and contract 6rs. .m Sh.g "10. PageN1.8-7, Paragraph 2 - Sin'e explanation as item II.2 above. ~ 2.- 6 y -17 ? 111,. Page 1.8-7, Paragraph' 2, Items 182 - See items I.4 and I.5 above -for the explanation of descript1.on changes. Also reflects posi-tion title: changes. a x, .o -12. Page 1.8-7, Paragraph 3 - Reflects changes in organization as discussed in Item II.1 above. (i.e. The, President is now ulti-w@D;
- mately-responsible -for; the QA Program and he receives regular title.
p a. 4 .rc ,5**j _ _ n C. _ _.__.___ s _ _ _,__,_ _ _
p Mr. J. G. Keppler June 28, 1984 briefings on quality assurance matters) 13. Page 1.8-8, Paragraph 1 - See item I.6 above for explanation of description changes.
- 14. Page 1.8-8, Paragraph 3, Item 3 - Words added to highl'ight the maintenance of training records,
- 15. Page 1.8-9, Paragraph 4 - Streamlined wording in first sentence by deleting extraneous words (i.e. deleted "more properly" preceding the word " controlled".)
- 16. Page 1.8-9, Paragraph 6 - See item I.7 above for explanation of description changes in regard to housekeeping.
- 17. Page 1.8-11, Paragraphs 2&3 - Reflects changes in organizational title.
- 18. Page 1.8-11, Paragraph 5 - Expanded scope of the second sentence to include " control" of procedures, instructions or drawings as well as their preparation and revision.
- 19. Page 1.8-13, Paragraph 2 - See item I.8 above for explanation of description changes regarding document control.
- 20. Page 1.8-13, Paragraph 4 - Reflects changes in organizational title.
21. Page 1.8-14, Paragraph 3 - See item I.9 above for explanation of description changes regarding control of purchased items.
- 22. Page 1.8-16, Paragraph 3 - Reflects changes in organizational title.
23. Page 1.8-17, Paragraph 1 - See item I.10 above for explanation of description changes regarding qualification of contractor inspec-tion and test personnel.
- 24. Page 1.8-17, Paragraph 2 - Changes " jobs" to " positions" to be consistent with remainder of paragraph. Also see item I.11 above for explanation of description changes regarding employment of plant personnel.
- 25. Page 1.8-17, Paragraph 3 - Reflects changes in organizational title.
-26. Page 1.8-18, Paragraph 1 - Added word " activity" for clarity.
- 27. Page 1.8-18, Paragraph 3 - Added words " positively controlled" for clarity. Also see item I.12 above for additional explanation.
- 28. Page-1.8-19, Paragraphs 3&4 - See item I.13 above for explanation of changes regarding nonconformance control.
29. Page 1.8-20, Paragraph 1 - Reflects changes in organizational
F. Mr. J. G. K:ppler June 28, 1984
- 30. Page 1.8-21, Paragraph 5 - See item I.14 above for explanation of description changes.
31. Page 1.8-22, Paragraph 3 - See item I.15 above for explanation of changes. Also reflects changes in organizational title. 32. Page 1.8-22, Paragraph 4 - Changed word " data" to "results" for clarity. 33. Table 1.8 Same explanation as item II.2 above. If you have any questions in regard to the above discussion or the attached information, please let us know. Very truly yours, 6 t C. W. Fay Vice President - N clear Power Attachment Copies to: NRC Resident Inspector NRC Document Control Desk Washington D.C. (original) i l' l 6 T + T --s
1.8 QUALITY ASSURANCE PROGRAM In accordance with Paragraph 50.34 of 10 CFR 50 and 71.24 of 10 CFR 71, a Nuclear Quality Assurance Program Description is herein provided by Wisconsin Electric Power Company (WE). This Program is to assure that the required manpower, procedures, and management of Point Beach Nuclear Plant ar'e directed toward satisfying the Company quality objectives of providing safe and reliable structures, systems, and components; and complying with the provisions of 10 CFR 50, Appendix B " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants"; 10 CFR 71, Subpart H " Quality Assurance Criteria for Shipping Packages for Radio-active Material"; and the applicable Sections of the ASME Boiler and Pressure Vessel Code. The program described is structured in accordance l with the outline of the 18 Criteria of Appendix B. The. following describes the quality assurance program established and imposed by the Company for application to the functional aspects of structures, systems, and components, including the design, purchasing, construction, and fabrication, handliag, storage, shipping, cleaning, installation,
- erection, inspection,
- testing, operation, maintaining, refueling, repair., and modification of equipment considered significant to safety by the Company.
These structures, systems, and components may be classified as safety-related in that they prevent or mitigate the consequences of postulated accidents, or as in~ the case of radioactive material packaging and fire protection, they may contribute to causing undue risk to the health and safety of '.h3 public or loss of services ( should they fail or malfunction. Structures, systems, and components not classified as safety-related items are controlled in accordance with the quality programs and applicable codes which are necessary to provide assurance of quality commensurate with the importance of the overall function (s) to be performed. Revision 1 June 1984 1.8-1 I
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 l . in the impicmenting detail necessary, and such changes will be made in accordance with established procedures. Changes in the quality assurance . program description will also be submitted to the NRC as required by 10 CFR 50.54. The Point Beach Nuclear Plant Quality Assurance Program commits to the guidance' provided in ANSI N18.7-1976, except as hereinafter specifically noted. Where exceptions are noted in the text of this section, the PBNP alternative system is discussed. Commitment to ANS N18.7-1976 includes either complete or partial commitment to the following additional standards: ANSI N18.1-1971 Selection and Training of Nuclear Power Plant Personnel ANSI N18.17-1973 Industrial Security for Nuclear Power Plants ANSI N45.2.1-1973 Cleaning of Fluid Systems and Associated Com ponents for Nuclear Power Plants. ANSI N45.2.2-1972 Packaging,
- Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants (During the Construction Phase)
ANSI N45.2.3-1973 Housekeeping During the Construction Phase of Nuclear Power Plants ANSI N45.2.4-1972-Installation, Inspection, ~and Testing Require ments for Instrumentation and Electric Equipment During the Construction of Nuclear Power Gen-erating Stations ANSI N45.2.5-1974 Supplementary Quality-Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants -ANSI N45.2.6-1973 Qualification of Inspection, Examination, and Testing Personnel for the Construction Phase of Nuclear Power Plants l -Revision 1 June 1983 1.8-2
ANSI N45.2.8-1975 Supplementary Quality Assurance Requirements for _ Installation, Inspection, and Testing of Mechanical Equipment and Systems for the Con-struction Phase of Nuclear Power Plants ANSI N45.2.9-1974 Requirements for Collection, Storage, and Main tenance of Quality Assurance Records for Nuclear Power Plants ANSI N45.2.10-1973 Quality Assurance Terms and Definitions ANSI N45.2.11-1974 Quality Assurance Requirements for the Design of Nuclear Power Plants ANSI N45.2.12, Requirements for Auditing of Quality Assurance Draft 4, Rev.2 Programs for Nuclear Power Plants ANSI N45.2.13-1976 Quality Assurance Requirements for Control of Procurement Items and Services for Nuclear Power Plants ANSI N101.4-1972 Quality Assurance for Protective Coatings Applied to Nuclear Facilities To the extent required by ANSI N18.7-1976 as hereinafter specifically noted, PBNP hereby commits to the above standards. Table 1.8-1 provides further.informatior, regarding commitments to regulatory guides and related standards. 1.8.1 ORGANIZATION The authorities and responsibilities of persons and organizations perform-ing quality related activites are established, assigned, and documented in a formal system. All quality assurance and quality control functions are performed by the Company QA organization (including both on-site and off-site personnel) except when the scope of specific projects indicate need to engage contractors to perform specific services. 1.8-3
Those persons and organizations assigned such functions are given appro-priate and sufficient authority and organizational freedom to identify quality problems; verify implementation of the solutions; and prevent further processing, delivery, installation, or use of nonconforming items until proper dispositioning has occurred. The organizational structure and functional responsibility assignments are such that: (1) attainment of quality objectives is accomplished by individuals assigned responsibility for specifying quality or performing work to specifications, (2) audit:; verifying conformance to established quality requirements are accomplished by those who do not have direct responsibility for performing the work being verified, and (3) personnel in key. quality assurance functions have direct access to responsible management. The education and experience required of individuals assigned to QA positions is documented and approved by management. The operating organization is reflected in Figure 15.6.2-2 of the Techni-cal Specifications. The organization for quality assurance is reflected in Figures 1.8-1, 1.8-2, 1.8-3, and 1.8-4. The Vice President-Nuclear Power Department reports to the President. The Vice President-Nuclear Power Department has been delegated the authority to establish quality assurance policies, goals, and objectives'as applicable to the Point Beach Nuclear Plant and the Nuclear Power Department. The President retains ultimate responsibility. The Vice President - Nuclear Power Department has direct access to the President in this regard. Manager - Point Beach Nuclear Plant The Manager-Point Beach Nuclear Plant is the senior company representative at the plant facility and, as such, is in' direct day-to-day control of all normal plant administrative, technical operations and quality assur-ance. The Quality Assurance Coordinator reports to the Manager-Point Beach Nuclear Plant on quality-related matters. Quality Assurance Repre-sentatives report to the Quality Assurance Coordinator as members of the Quality, Standards & Records Organization as shown in Figure 1.8-3. The l QA Coordinator and the QA Representatives (including participation on the l Quality Standards, & Records Organization) are concurrent assignments. Revision 2 1.8-4 June 1984
General Superintendent of Quality Assurance l The General Superintendent of Qualtity Assurance reports to the Vice l President-Nuclear Power Department. He is responsible for integrating the various quality assurance programs within the company including i providing off-site quality assurance support for Point Beach. Quality Assurance Committee The Wisconsin Electric Quality Assurance Committee consists of Company officers and an outside consultant each designated by the President. The Quality Assurance committee assesses the adequacy and effectiveness.of the Quality Assurance Program by reviewing quality assurance policies, procedures, and practices and through periodic initiation of audits. The Chairman of the Committee is appointed by the President. The Committee meets on a ' periodic basis, normally quarterly, but no less than three times per year to review the status of quality-related activites. Off-Site Review Committee The Off-site Review Committee (OSRC) is established in accordance with Technical Specifications, Section 15.6.5.3. The OSRC selectively reviews designated activities involving the operation of Point Beach Nuclear Plant including Technical Specification Compliance. Specific duties and responsibilities are described in the plant Technical Specifications, Section 15.6.5.3. t General - Responsibilities The responsibilities of individuals or groups performing QA functions are documented and approved by management. General responsibilities are as follows: i QA Coordinator 1. Assist plant groups on matters dealing with quality, codes and standards interpretation, interpretation and applica-Revision 2 June 1984 1.8-5 t
tion of the in-plant quality assurance manuals, regulatory record keeping and regulatory inspection activities. 2. Administer the quality assurance and control aspects of ordering, storing, use, and documenting of quality assur-ance spare parts and equipment in the plant. 3. Perform technical audits of plant groups with respect to the adequacy and implementation of quality assurance pro-cedures and instructions and the adequacy of documentation (Section 1.8.18). QA Representative 1. Report to the QA Coordinator observed documentation or physical infractions of quality assurance procedures and instructions or suspected violations of Technical Specifi-cation, State and Federal codes or standards, and commit-ments to Regulatory Guide positions. 2. -Assist their respective group in conforming with the Operating Point Beach Nuclear Plant Administrative Control Policies & Procedures Manual. 3. Maintain and help coordinate the required storage of quality assurance records pertaining to their respective groups. Quality Assurance Section l 1. Review QA scope purchase documents to assure adequate quality l. requirements (Section 1.8.4) are established. 2. Verify conformance of received items to purchase document requirements through various activities including source verification, as. appropriate, and review documentary L evidence of quality for procured items prior to release of t.e items (Section 1.8.7). 3. Perform quality assurance evaluations of off-site vendors and contractors commensurate with the importance, complexity, and quantity of the product or services and assure vendor compliance with established requirements through audit and surveillance activities (Section 1.8.7). Revision 2 June 1984 1.8-6
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t 4. Perform audits of the quality assurance program as implemented on-site by Plant personnel and contractors (Section 1.8.18). Also audit off-site company organizations performing quality-related activities for Point Beach. 1.8.2 QUALITY ASSURANCE PROGRAM A quality assurance program is established and implemented in accordance with written policies, procedures, and instructions which comply with the requirements of 10 CFR 50 Appendix B and 10 CFR 71, Subpart H. The l program is also applied to activities such as fire protection to a degree commensurate wi.th Wisconsin Electric commitments. Specific QA Program applicability to fire protection and radioactive material packaging is addressed in Tables 1.8-2 and 1.8-3, respectively. The Point Beach Nuclear Plant Quality Assurance Program is set forth in the Administra-tive Control Policies and Procedures Manual (QA Volume I) and the Quality Assurance & Reliability Manual for Materials, Repairs and Modifications (QA Volume II). Control of the above manuals is as follows: 1. Distribution and maintenance of the Administrative Control l Policies & Procedures Manual (QA Volume I) and revisions there-to is controlled by Point Beach Nuclear Plant. The manual is reviewed and approved on-site by the plant organization. 2. Distribution and maintenance of the Quality Assurance and l Reliability Manual for Materials, Repairs and Modifications (QA Volume II) and revisions thereto is controlled by the General Superintendent of Quality Assurance. The Manual is reviewed and approved by the General Superintendent of Quality Assurance and the Vice President-Nuclear Power Department. Final responsibility for modifications, repairs, maintenance, and opera-
- tions, including the quality assurance
- program, lies with the President.
Management review of the status and adequacy of the quality assurance program is accomplished by at least semiannual review by the WE QA Committee (Section 1.8.1) and by regular briefings (at least l once every two months) with the President. Revision 2 June 1984 1.8-7 +m . ;g . ; 3 ; 3 ~ ; ; 3;
The quality assurance program applies to structures, systems and compon-ents (including expendable and consumable items which are used therein) which are considered important to safety from the standpoint of safety-related functions to be performed. The structures, systems and compon-ents considered important to safety are identified in the Quality Assurance & Reliability Manual for Materials, Repairs, and Modifications (QA Volume II). This list is consistant with requirements of the regulations as described in this FSAR, and also includes non safety-related systems and components requiring quality assurance coverage such as fire protection and radio-active material packaging. Positive controls are implemented to assure updating of the list as nec_ssary. The classification of a system or component as important to safety does not imply that the complete system, or all the components or component parts within that system, are important to safety. Those specific items within a system considered important to safety are also identified in QA Volume II. The program provides for indoctrination and training of personnel per-forming 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. 2. Personnel performing quality-related. activities are trained and qualified in the principles and techniques of the activity being performed. 3. . Appropriate training procedures are established and that records of training are maintained. Revision 2 June 1984 1.8-8 m_....
em-- Section 5.2.10 of ANSI N18.7-1976 states that the provisions of ANSI N45.2.3-1973 shall be applied to those activities which are compar-able in nature and extent to related activities occurring during construc-tion. Point Beach Nuclear Plant practices good housekeeping and cleanliness involving activities performed by plant and contractor personnel to maintain the necessary standard of cleanliness. Scheduled and documented daily-to-weekly surveys of potentially contam-inated or radioactive areas are conducted by health physics personnel, followed by decontamination or radioactive cleanup as necessary, ensure cleanliness checks. of even the least traveled areas. An additional program provides that Operations shifts are assigned specific plar.t areas to patrol and clean up as a housekeeping duty. Plant policy endorses and enforces the concept that each person is responsible for cleanliness and good housekeeping in their own immediate work area. Final inspections of work areas following completion of work, including final internal inspec-tions of pressure vessels, tanks, etc., are routinely completed by super-visory personnel. Such inspections are formally documented only in special cases when considered necessary; these normally being final inspections by plant supervisory personnel following work by outside con-tractors. Storage of items, combustible or otherwise, are ' controlled to defined l quality assurance or fire protection requirements. Access to safety-related equipment or radiation controlled areas is more properly con-trolled by security regulations or defined health physics rules. PBNP complies with OSHA regulations in the physical safety and environ-mental condition of work places. Significant attention to housekeeping is provided by plant management including frequent housekeeping inspections of portions of the plant by the Manager-Point Beach Nuclear Plant. This constitutes a complete and in-depth inspection of essentially the total plant on a weekly basis. Revision 2 June 1984 1.8-9
1.8.3 DESIGN CONTROL Procedures and practices are established and documented to assure that applicable regulatory requirements and design bases are correctly trans-lated 'into design documents, such as specification and drawings, for work involving changes or additions to the original design of safety-related structures, systems, and components. These measures include provisions to assure that appropriate quality standards are specified and included in the design documents and that deviations from such standards are controlled. The measures also include provisions to control selection and review for the suitability of application of materials, parts, equip-ment, and processes that are essential to the safety-related function. Procedures and practices are established and documented for the identi-fication and control of design interfaces and for coordination among design organizations. These incle,de procedures among participating c ! sign organizations for the review, approval, release, distribution, and revision of design documents. The design control measures provide for verifyirig or checking the adequacy of design by design reviews, by alter-nate or simplified calculational methods, or by suitable testing programs performed by individuals or groups other than the originator. Where a test program is used to verify the adequacy of a specific design feature, provisions include suitable qualification testing of a prototype unit under the most adverse design conditions. Design control measures consider, as appropriate, reactor physics; stress, thermal, hydraulic, and accident analyses; compatibility of materials; accessibility for inservice inspection, maintenance and repair; and delineation of accept-ance criteria for inspections and tests. Further changes to designs are subjected to commensurate design control measures. When a contemplated change is considered by appropriate manage-ment to be of sufficient scope as to be beyond the expertise of in-house personnel, these changes are reviewed by the organization that performed the original design, or other design organizations determined to be equally qualified. Section 5.2.7.2 of ANSI N18.7-1976 requires that Revision 1 June 1983 1.8-10 L
,n ' design activities associated with modifications of safety-related struc-tures, systems and components be performed in accordance with the provis- '. ions of' ANSI N45.2.11-1974. Design activities associated with modifica-tions are accomplished.in accordance with the provisions of Section 8 of
- ANSI N45.2.11-1974.
1.8.4 PROCUREMENT DOCUMENT CONTROL Procedures and practices are established and documented to provide assur-ance : that applicable regulatory requirements, design bases, and other requirements which are necessary to assure adequate quality are included or. referenced in the documents for procurement of materials, products, or services. These measures are applied to spare ano 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 requirements. The Quality Assur-ance Section reviews procurement documents to ensure the inclusion of l adequate quality criteria. Records of the review are maintained to provide auditable documentation. Procurement documents require suppliers, contractors, or subcontractors to implement quality assurance programs to the extent necessary. The programs are reviewed by the QA Section, qualified contractors, or l industry organizations such as the Coordinating Agency for Supplier Evaluation (CASE). Concurrence with the' adequacy 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 INSTRUCTION., PROCEDURES, AND DRAWINGS Activities affecting quaiity are prescribed by documented instructions, procedures or drawings appropriate to the work at hand with the work accomplished in accordance with these documents. Measures have been established for the preparation, revisiun, and control 'of procedures, l instructions, or drawings. Revision 2 June 1984 ) 1.8-11 )
Instructions, procedures, and drawings are required to include appro-priate quantitative or qualitt.tive acceptance criteria to ensure work has been satisfactorily accomplished. Supervisors may direct that data be taken without the data taker being cognizant of the acceptance criteria when it is considered that forehand knowledge of the acceptance criteria may prejudice results. The Supervisor is then reponsible to verify conformance. To the extent applicable, as-built drawings and original aquipment and system specifications establish acceptance criteria, sub-ject to improvements based upon operational experience. When required, these instructions, procedures, and drawings provide methods for com-plying with appropriate regulations. Section 5.2.2 of ANSI N18.7-1976 requires that temporary major procedure changes which do not change the intent of an approved procedure be approved by two members of the plant staff knowledgeable in the areas affected by the procedure. One of these individuals is to be the Duty-Shift Super-visor who holds a senior operators license. As described in Section 15.6 of the Technical Specifications, Point Beach follows the above guidance for operating procedures. For Maintenance, Instrumentation and Control, Reactor 'ingineering, and Chemistry and Health Physics procedures, approval is not required from the supervisor in charge of the shift for temporary changes. For a further description of the system for temporary changes, refer to Section 15.6.8 of the Technical Specifications. Section 5.3.2 of ANSI N18.7-1976, which discusses the content of proced-ures, states in part, "... procedures shall include, as appropriate...(8) Acceptance Criteria." PBNP has determined through considerable exper-ience that the incorporation of acceptance criteria is not always advan-tageous, as discussed herein.
- 1. 8. 6 -
DOCUMENT CONTROL Procedures and practices are established and documented to control the issuance of documents; such as maintenance and modification procedures; design specifications; design, manufacturing, construction, and instal-lation drawings; procurement documents; manufacturing, inspection, and 1.8-12
4 testing. instructions;' test and operating procedures; and QA manuals, safety analysis reports, and related design' criteria documents; including all changes thereto.: These include indentification of the group respon-sible for review, approval, and issuance of the documents. For quality -related documents, the review includes the adequacy of incorporation of quality-requirements. The. procedures provide assurance. that documents, including changes, are reviewed 'for adequacy and approved for use by authorized personnel and are' distributed to and used at the location where the prescribed activity is: perfonned 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 distribu-tion of indices, are also implemented to identify the current revision 1 of a document required to be used. These provisions are also used as 3 basis for auditing the document control system. Document control pro- [ cedures include provisions for determining the appropriate group for _ reviewing changes to documents. F Documents classified as QA records are subjected to the additional require-ments described in'Section 1.8.17. i P
- 1. 8. 7 -
CONTROL OF ' PURCHASED MATERIAL, EQUIPMENT, AND SERVICES 2 - Procedures and practices are ' established and documented to assure that purchased material, equipment and services conform.to the procurement ~ idocuments. These measures include-review of all plant! initiated purchase requisitions by the QA Coordinator' or his designee and subsequently, QA - scope requisitions are reviewed by' the QA Section' to verify incorpora-l tion of appropriate quality requirements. Additionally, all requisitions -initiated by Nuclear Engineering are reviewed by the QA Section. l The bases for-selection of suppliers include previous experience, meeting the required qualifications of the contractor who erected the Plant on a " Turnkey" basis, or a pre-award evaluation of the proposed supplier's capabilities and qualifications. Industry programs, such as those applied i - by the' American Society of Mechanical. Engineers (ASME) and the Coordinating i Revision 2 June 1984 1.8-13 i
Agency for Supplier Evaluation (CASE), 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 examina-tion of products at receipt. These controls also include provisions for . monitoring contractors providing services through performance of audits and surveillances, as necessary, to verify conformance with procurement requirements. These are performed by appropriately trained personnel in accordance with written procedures and instructions. Normal procedures require assignment of a Quality Assurance Release (QAR) [ identification number prior to placing purchased items into service. These procedures require that all documentory evidence required by the purchase order be available and satisfactory prior to issuance of the QAR. For those few exceptions,,here items are placed in service prior to issuance ;of the QAR number, procedural controls in the form of a ( " conditional' release" system are in place to assure these items are ap-propriately controlled. Measures are provided for monitoring the effective-ness of contractor control of quality consistent with the importance, complexity, and quantity of the product or services. The. requirements of ANSI N45.2.13-1976 are met for the procurement of components within the scope of Section 5.2.13 of ANSI.N18.7-1976. 1.8.8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS Procedures and practices are established and documented requiring identi- - fication of materials, parts, and components, including partially fabri-cated assemblies, to prevent use of incorrect or defective items. Identi-fication requirements are based on as-built drawings and specifications. Identification requirements for other than identical replacement items are determined during planning for the modification or addition. Identi-fication methods and locations are selected so as not to affect the function or quality of the item. Revision 2 June 1984 1.8-14
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 instal-lation and use. These measures apply to plant personnel and on-site con-tractors. Procurement documents invoke appropriate requirements for identification and control of material during manufacture, including provisions for in-process audits of the manufacturer's program which allow the licensee the option of auditing the vendor. 1.8.9 CONTROL OF SPECIAL PROCESSES Procedures and practices are established and documented to assure that special processes, such as welding, heat treating, and nondestructive examinations are controlled and 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. qualifications to be on site during process performance whether by WE personnel or contractors. Procurement docu-ments specify appropriate control requirements for processes performed off-site. 1.8.10 INSPECTION i Procedures and practices are established and documented providing for appropriate inspection of activities affecting quality and to verify conformance with the documented instructions, procedures, drawings, or I specifications for accomplishing the activity. Inspection procedures, instructions, and checklists include the following, as applicable: 1. Identification of characteristics to be inspected. 2. Identification of the individuals or groups responsible for performing the inspection operation. 3. Acceptance and rejection criteria. 4. The method of the inspection. l 5. Verification of completion and documentation of the inspection. 1.8-15
i Maintenance, replacement, or rework items are inspected in accordance F I with original inspection requirements or improved requirements based on l operating' experience. Modified items are inspected by methods at least I equivalent to the origin 21 inspection methods. } ~ i ' Thesp measures ' provide for verification of conformance to be performed by appnerriately - qualified individuals other than those who performed the j Tactivity. Quality control inspections may be performed by a workman's [ 'first line supervisor; however,-quality assurance acceptance is not per-f formed by the first line supervisor or anyone reporting to him. Qualifi-l cation - of ~ these individuals in accordance with appropriate requirements f . is documented. Provisions for Code Authorized Inspection are included [ when required.. [ 1 > Examinations, measurements, or tests are performed for work operations l where necessary. Procurement documents for materials or products specify I examinations, measurements, or tests to be performed for each work opera-i - tiens. where 'necessary, to assure quality. Storeroom personnel perform i receiving. inspection on procured materials _ as appropriate per the pro- .i curement. documents, specifications, procedures,. and instructions. Storeroom personnel are-knowledgeable of. the requirements of the quality [ assurance program. Questions regarding quality assurance are referred to i ~ the QA Coordinator or QA Section.- Procurement documents for materials or l 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 l
- inspection ~ and process monitoring, provisions' for 'both are included.
i . Mandatory hold points are specified and used where' required. -s Section 3.4.2. of ANSI N18.7-1976 states that personnel performing . inspection, examination, and testing activities shall be qualified to I ANSI'N18.1-1971, or" shall meet the requirements of ANSI N45.2.6-1973. - -With few exceptions, Point Beach personnel meet or exceed the qualifi-cation requirements of ANSI N18.1-1971, and are therefore qualified to ( _ perform plant. inspection, examination, and testing activities. Those few L l' ? L Revision 1 June 1984 l 1.8-16 l l-o ~ ..__._.._. _ _ _.. _ _ _ _ _ _. _ _, _ J
(- I exceptions are in job functions not discussed in ANSI N18.1-1971 and cer- ) tain inspection and test personnel who work for contractors as dis-cussed below. -All positions at Point Beach have been evaluated to determine the minimum l qualification requirements. The areas considered during the evaluation included regulation, code and standard requirements, education and train-ing, work experience, and physical condition. Applicants for positions l at Point Beach who do not meet the minimum requirements, or who do not pass a battery of preemployment aptitude tests are not considered for the i position. Additionally, prior to employment, all plant personnel are interviewed by senior plant management and in most cases are interviewed by the Manager-Point Beach Nuclear Plant who makes the final determina-tion 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 performed by contract, the potential contractor's QA program is evalu-ated by the QA Section to determine its acceptability. Included in the l evaluation is consideration of the qualifications of inspection and test I personnel. In cases where it is determined that a contractor's organiza-tion is suitably qualified in all other respects, including qualified personnel, a qualification and certification program which meets all the requirements of ANSI N45.2.6-1973 is not insisted upon. Implementation of the audit program assures qualification of such personnel. All nondestructive examination personnel are required to be qualified in accordance with the appropriate sections of SNT-TC-1A. Section 3.2 of ANSI N18.7-1976 requires that verification of conformance be performed by individuals other than those who performed or directly supervised the work. It can be demonstrated that verification of con-formance is conducted in this manner at Point Beach. Section 5.2.17 of ANSI N18.7-1976 requires inspections for modifications Revision 2 June 1984 1.8-17
and non-routine maintenance be performed in a manner similar to that associated with construction phase activities. Modifications and non-routine maintenance for which outside contractors are utilized are per-formed in this manner. Modifications and non-routine maintenance items within the capablities of the onsite operating organization are performed as a routine maintenance activity. l 1.8.11 TEST CONTROL Procedures and practices are established and documented to provide a pro-gram of periodic testing and continuing surveillance to demonstrate that structures, systems, and components continue to perform satisfactorily in service. The measures require tests to be performed in accordance with written test procedures which incorporate the requirements and acceptance limits (except as noted in Section 1.8.5) from applicable design docu-ments by appropriately trained and qualified personnel. Test procedures include provisions for assuring that all prerequisites for the test have been met, that adequate test instrumentation is available and used, and the test is performed under suitable environmental conditions. Test l results are documented and evaluated to assure test requirements have been satisfied. These measures require replacement or modified struc-tures, systems and components to be subjected to sufficient proof, preop-erational, and operational testing to demonstrate that they will perform satisfactorily in service. 1.8.12 CONTROL OF MEASURING AND TEST EQUIPMENT f ositively controlled procedures and practices are established and doc-l umented to assure that tools, gauges, instruments, and other measuring and testing devices used in activities affecting quality are properly indentified, controlled, calibrated, and adjusted at specific periods to maintain accuracy within necessary limits. Calibration procedures specify standards to be used for performing the calibration; procedure preparation assures that 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. Revision 2 June 1984 1.8-18
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 equipment in accordance with work' and inspection instructions by quali-fied individuals to prevent damage or deterioration and preclude loss of identification. The measures include specification and use, when nec-essary, of special protective.invironments, 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 I suitable means, the status of inspections and tests to be performed upon individual items. These measures include provisions for the identifica-1 tion of items which have satisfactorily passed required inspections and tests when necessary to preclude inadvertent bypassing of such inspec-tions and tests. Procedural controls to perform operations out of sequence are included in QA Volume I. These measures also include pro-visions for indicating nonconforming, inoperative, or malfunctioning components within a system to prevent inadvertent operation. 1.8.15 NONCONFORMING MATERIALS, PARTS, OR COMP 0NENTS Procedures and practices are established and documented to control mater-ials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation. For purchased mater-ial, parts, or components, these measures may include timely return of nonconforming materials, parts, or components to the vendor for replace-ment with satisfactory items. Formal nonconformance control systems are in place to assure control and disposition of nonconforming items including adherence to 10CFR21 as necessary. Maintenance request forms provide identification and control of noncon-forming items requiring repair or rework to be returned to satisfactory condition. Where a safety-related component is required to be temporar-ily or permanently changed, such that it no longer complies with the original and approved design, such changes, with required approvals, are made via the approved modification request procedure. l Revision 1 1.8-19 June 1983
The QA Section has established provisions for documenting and dispo-l sitioning nonconforming items or conditions, which are identified during inspection, surveillance or auditing activities. 1.8.16 CORRECTIVE ACTION Procedures and practices are established and documented to assure that conditions adverse to quality; such as failures, malfunctions, deficien-cies, deviations, defective material, and equipment and nonconformances; are promptly identified and corrected. In the case of significant condi-tions adverse to quality, these measures include assurance that the cause of the condition is determined and corrective action taken to preclude repetition. These include provisions for identification of the signifi-cant condition adverse to quality, the cause of the condition and the corrective action taken to be documented and reported to appropriate levels of management. Provisions are included for followup reviews to verify proper implementation of corrective actions and to close out the corrective action documentation. 1.8.17 QUALITY ASSURANCE RECORDS Procedures and practices are established and documented to assure that sufficient records are generated and maintained to furnish evidence of activities affecting quality. Where practicable the guidelines of ANSI N45.2.9-1974 apply. The records consist of at least operating logs and the resulcs of reviews, inspections, tests, monitoring, work per-formance, and materials analyses. Also included are closely related data such as qualifications of personnel, procedures and equipment. Inspec-tion and test records include, as a minimum, identity of the inspector or data recorder, the type of observation, the results and the accepta-bility, or action taken in connection with any deficiencies noted. Records are required to be identifiable and retrievable. Requirements concerning records retention; such as duration, location, and assigned responsibility; are established to be consistent with applic-able regulatory requirements. A record storage facility is used with controlled access to prevent destruction of records by fire, flooding, Revision 2 June 1984 1.8-20
theft, and deterioration by environmental conditions, such as temperature or humidity.- In 1971, Point Beach recognized the need to improve its records manage-ment program in the area of preservation of records. In the absence of any guidance in the form of regulatory guides or national standards, it was decided.to generally follow the requirements of NFPA 232-1970. The requirements of NFPA 232-1970 were reviewed in light of importance of the records being stored and the risk of destruction of the records. It was determined that the records being stored required positive protection as many were irreplaceable. Possible locations for records storage i facility were studied, and it was determined that the lower level of the Energy Information Center located on the plant grounds, offered an ideal location for a records storage facility. This location was chosen as it was an area of minimum weight of combusti-bles and the building itself was fire resistant. It was determined, based on the above factors, that a separate room would be constructed in the lower level of the Energy Information Center to provide further pro-tection. The room was built to meet Wisconsin Administrative Code requirements for four-hour construction, and was treated to minimize the risk of water infiltration. In addition, the room was equipped 'with an inert gas fire suppression system which is automatically triggered by smoke or heat. Triggering of the fire suppression system also activates an alarm signal and a visible alarm which can be observed from a continuously manned guard station. Based on the analysis of the fire hazard present in the Energy Informa-tion Center alarm system, and the sophisticated fire suppression system, it was decided that the requirement for a four-hour vault door was unneces-sary. The entrance to the room is closed with a Class A 250 F labeled fire door. In addition, the fire suppression system required an electri-cal supply, which led to the waiving of the requirement that walls could ~ not be penetrated by electrical conduit. The electrical supply for the Revision 2 1.8-21 June 1984
room is brought into the room via a conduit through one of the walls which has been installed to minimize the risk of fire passing through the wall via this penetration. 1.8.18 AUDITS Procedures and practices have been established and documented to provide a comprehensive system of planned and periodic audits to verify compli-ance with all aspects of the quality assurance program and to determine the effectiveness of the program. Audits are performed in accordance with written procedures or checklists by appropriately trained personnel not having direct responsibilities in the areas being audited. The in-plant QA program is audited periodically, normally quarterly, by the QA Coordinator or his designee and quarterly by the QA Section. The QA Section also performs audits under the cogni-zance of the Off-Site Review Committee as required by Technical Specifi-cation-15.6. On-site and off-site contractor audits are timed as appropriate for the work scheduled. Audit results are documented and reviewed by management personnel having responsibility in the area audited. Audit reports are routed to manage-mentment responsible for correcting any unsatisfactory items noted. Follow-up action, including reaudit of deficient areas, is taken when indicated. When follow-up audits reveal repetitive occurrences.which reflect possible trends adverse to the effectiveness of the QA program, these results shall be reported to the appropriate management level to l effect corrective action. In a footnote to Section 4.5 of ANSI N18.7-1976, it is stated that the provisions of proposed ANSI N45.2.12, Draft 4, Revision 2, dated January 1,1976, shall be used for audits performed to meet the requirements of Section 4.5. Section 3.2 of ANSI N18.7-1976 recognizes that quality assurance is an interdisciplinary function and that advantages may accrue from having reviews of certain plant functions performed by technically qualified personnel, in lieu of quality assurance personnel, because of special technical competence which may be required to perform the review. WE strongly endorses this position and has assigned certain review and Revision 2 1.8-22 June 1984
t audit. functions within th'e plant to technically qualified personnel in lieu of quality assurance personnel. Sufficient audits are' performed in accordance with the provisions of i ANSI N4512.12 to meet the requirements therein; however, the technical l audits are not performed under ANSI N45.2.12 requirements. i I l' so, i L t t i i i s r 1.8-23
y s- - - s ,3 s TABLE 1.8-1 / ~ 2 COMMITMENT 10REGULATORYGUIDESANDANSISTANDARDS l ~1. .Begulato yE'huide'1.8(SafetyGuide8)datedMarch 10, 1971 "?' n 7, p'~ Full comitment except that Point Beach comits to ANSI N18.1-1971 in lieu of the proposed ANSI'N18.1 dated June 22, 1970. 22," : Regulatory G'uide 1.28 (Safety Guide 28) dated June 7,1972 e ANSI N18.7-1976 states in part, "This standard fully and com ,f pletely describes the general requirements and guidelines of ANSI N45.2-1971 as those requirements, and guidelines ...q , apply during the operational phase of plant life." As such, comitmeist to ANSI N18.7-1976 for Point Beach obviates the need
- [-
to-connit to Regulatory Guide 1.28 which endorses ANSI N45.2-1971. ,7-i.:-[ Point Beach does, however, comit to the position of Regulatory Guide 1.28 to the extent of requiring its vendors to have qual- ^~ ity assurance programs which meet the appropriate requirements a of ANSI N45.2-1971 as mentioned in Section 5.2.13.1 of ANSI-N18.7-1976. ' N _ ".,- 3, Regulatory Guide 1.30 (Safety Guide 30) dated August 11, 1972 3 ~. ~ M.- Comitmenp to, follow the ' position of Regulatory Gude 1.30, m, which endorses and supplements ANSI N45.2.4-1972, for activities Q occuring during the ' operational phase that are comparable in Y nature and ', extent to related activities during construction. ,m ~. i ,f 4,_4.% Regulatory Guidef.'37 dated March 16, 1973 l ,. e Comitment5 o follow the p~ sition of Regulatory Guide 1.37, t o whichendorse.Modsuhp1'ementsANSIN45.2.1-1973, for activities occurring during the operational phase that are comparable in u nature ind extent to related activities occurring during con-struction. 'h ~%
( [.Q f l>l_ g ? % %.-lcy.:{'c. K (,.l* LjT;: f.L.l l ?.Q.-Lr.~..i' ') l..,,. TABLE 1.8-1 (Continued) 5. Regulatory Guide 1.38, Revision 1, dated October 1976 Comitment to follow the position of Regulatory Guide 1.38, which endorses and supplements ANSI N45.2.2-1972, for activit-ies occurring during the operational phase that are comparable in nature and extent to related activities occurring during construction. 6. Regulatory Guide 1.39, Revision 1, dated October 1976 Comitment to follow the position of Regulatory Guide 1.39, which endorses and supplements ANSI N45.2.3-1973, for activit-ies occurring during the operational phase that are comparable in nature and extent to related activities occurring during construction except that Point Beach does not comit to the documentation requirements of ANSI N45.2.3-1973 and provides an alternative to the housekeeping zone requirements therein. Description of these differences are provided in Section 1.8.2.4. 7. Regulatory Guide 1.54 dated June 1973 Comitment to follow the position of Regulatory Guide 1.54, which endorses and supplements ANSI N101.4-1972, for activities occurring during the operational phase that are comparable in nature and extent to related activities occurring during construction. 8. Regulatory Guide 1.58 dated August 1973 Comitment to follow the position of Regulatory Guide 1.58, which endorses and supplements ANSI N45.2.6-1973, for activities occurring in the operational phase that are comparable in nature and extent to related activities during construction, except that Point Beach does not cormiit to the levels of qualification nor separate certifica-tion requirements of ANSI N45.2.6-1973. Description of these differ-ences are provided in Section 1.8.10.6.
y r w E\\ o-e a ~ 'T TABLE 1.8-1 (Continued) ~ c Nw N 9.- Regulatory' Guide 1.64 dated October 1973 ~ N. n Comit' ment to follst the position of Regulatory Guide 1.64, except that. Point Beackcom,its to ANSI N45.2.11-1974 in lieu of Draft 3 Rev.'1.da,te'dJuly31$73',for'designactivitiesassociatedwithmodif-icatfon of safety-reisted3tructures, systems and components. i a t - 3; x s g - '~~ ~ 0.' Regulatory Guide P.74 dated February 197,4[ 1 s' # f Full' cominitment. 3 N '11. Regulatory Guide-1.88, Revision 1, dated December 1975 ,' \\ 3, s Comitment to follosi the pitio.n of; Regulatory Guide 1.88, which 4 endor:es and supplecents ANSI N45.,24-{074 and..NFPA 232-1970. Point Beach \\ has determine,d that $he exis, ting recorc3 storage facility pro- ~ 47 s s vides a level of protection ~.to. the.v,itsi records.at the plant which y it[ equivalent to th& requirements of Regulatory' Guide 1.88. Des-e cription of the differencrs are provided'in Section,1.8.17.5. s t 3 Gu W Regulatory,x;ide 1.94 dated Aprf r 1976 12., c .c s-f e Comitment to follow' the position of ~ Re,gulatory Guide 1.94, which i endorses and suppl'ene)1ts ANSI N4GPl.'S-1974, for ' activities occurring during the operational phase that are comparable in nature and n., . extent'to related activities occurring during construction. ':c 'g,.. g s s- '13. fegulatory Guide"1.;145 dated August 1980. t w u - E. 7 P 'N , j - Commitment to follow the position 6f Regulatory Guide 1.146, which ~. endorses ANSI H45.2.23, for audits of in-plant activities which are perfofmed on Point Beach Nuclear Plant organizations. .) r
- 14. AsI18.7-1976
. -g Referr.,to Secticin 1.8.0 for details of' the Point Beach comitment. m g E 4 g Re' vision 1 June 1983 ~ .. m 33 ,1) .. _ _ _. -,. N. _.___,__,...,__,6-___--__,____.._-,.. ,__.m. _, -.-- - ~_-
E TABLE 1.8-2 -SUBSECTIONS OF SECTION 1.8 APPLICABLE T0.THE FIRE PROTECTION PROGRAM Subject Subsection Administrative and Organizational 1.8.1, 1.8.2 Design and Procurement Document Controls 1.8.3, 1.8.4 Instructions, Procedures and Drawings 1.8.5
- Control off Purchased Materials, 1.8.7, 1.8.10 Equipment and Services Inspection 1.8.10 Test and Test Control 1.8.11 Inspection, Test and Operating Status 1.8.14 Nonconforming Items 1.8.15 i
Corrective Action 1.8.16 Records-1.8.17 Audits 1.8.1, 1.8.18 k e
TABLE 1.8-3 SUBSECTIONS OF SECTION 1.8 APPLICABLE TO SHIPPING PACKAGES FOR RADI0 ACTIVE MATERIALS (10 CFR 71, SUBPART H) l l Subject Subsection Organization 1.8.1 . Quality Assurance Program 1.8.2 Design Control
- not applicable Procurement Document Control 1.8.4 Instructions, Procedures and Drawings 1.8.5 Document Control 1.8.6 Control of Purchased Material, 1.8.7 Equipment and Services Identification and Control of 1.8.8 Materials-Parts and Components Control.of Special Processes 1.8.9 Inspection-1.8.10 Test Control
- not applicable Control of Measuring and Test-Equipment 1.8.12
' Handling, Storage and Shipping 1.8.13 Inspection, Test and Operating Status 1.8.14 Nonconforming Materials, Parts or Components 1.8.15 Corrective Action 1.8.16 Quality Assurance Records-1.8.17 Audits 1.8.18 Design and testing. control are activities which are not normally performed - by_ Point Beach Nuclear Plant personnel. However, these activities are imposed on suppliers providing radioactive material packaging or associated services, as appropriate. Revision 2 June 1984
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v_ _ __ __- - - -_.__ VICE PRESIDENT Administrator Special Projects NUCLEAR SYSTEMS ENGINEERING POINT BEACH NUCLEAR PLANT QUALITY ASSURANCE SECTION & REGULATION SECTION & ANALYSIS SECTION General Superintendent Manager General Superintendent General Superintendent Quality Assurance Superintendent Coordinator Quality, Standards Nuclear Quality & Records Organization Assurance Division (See Figure 1.8-3) (See rigure 1.8-4) Figure 1. 8-2 NUCLEAR POWER DEPARTMENT ORGANIZATION June 1984
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