ML20095A532

Rev 6 to QA Program Description for Design & Const of Facilities

ML20095A532
Person / Time
Site:	South Texas
Issue date:	04/02/1984
From:	HOUSTON LIGHTING & POWER CO.
To:
Shared Package
ML20095A525	List: ML20095A532 ST-HL-AE-1077, Forwards Rev 6 to QA Program Description for Design & Const Phase of Facilities.Changes Clarify Definition of Bechtel Div Quality Policies & Defines Responsibilities for Trend Analysis
References
NUDOCS 8408210503
Download: ML20095A532 (190)

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ST-HL-AE-1077

, 7 Attachment Page 1 of 4 I

Quality Assurance Program Description for the Design and Construction of the South Texas Project Revision 6 Principal Changes Part A, Houston Lighting & Power Company (HL&P QAPD)

Revision to define responsibilities for trend analysis:

Pages 26 and 27 have been revised to reflect the shift in responsibilities for performance of trend analysis. HL&P Quality Assurance has assumed full responsibility for the evaluation and trending of deficiencies identified by HL&P, BEC and ESI. This change in responsibilities is in response to the Construction Project Evalua-tion perfonned on the STP in 1983 and to allow a more comprehensive review through consolidation of the trend effort. Since all deficiency documents previously trended will continue to be trended, this revision does not reduce the comitments previously made in Revisions 4 and 5 of the QAPD.

' Revision to define organizational responsibility for the Chairman of the Incident Review Comittee (IRC).

Page 8 has been revised to clarify the organizational affiliation of the Chairman of the IRC. This clarification was made in response to NRC questions on Revision 4 of the QAPD (Ref. Corres. ST-HL-AE-1042). There is no reduction in comitment.

Revision to clarify HL&P position on application of SNT-TC-1A, 1980 requirements to qualification of NDE personnel.

Pages 22 and 23 have been revised to reflect that approved procedures shall be structured so that recomendations within SNT-TC-1 A,1980 ('shoulds') will be considered mandatory requirements ('shalls') for STP. This clarification compensates for the most significant changes between the 1980 edition and the 1975 edition of SNT-TC-1A to which HL&P was previously comitted. This clarification is in response to NRC questions concerning Revision 4 of the QAPD.

Additional justification as to the adequacy of HL&P's comitment to SNT-TC-1 A, 1980 is provided in the response submitted to the NRC questions on Revision 4 to the QAPD (Ref correspondence ST-HL-AE-1042). This change does not reduce the comitments made in Revision 4 and 5 of the QAPD.

• Revision to define reportability requirements for deficiencies identified during the startup phase prior to 0L.

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ST-HL-AE-1077 Attachment Page 2 of 4 Page 26 has been revised to state that approved procedures will require that significant deficiencies identified during the startup phase will be reported to HL&P executive management and the NRC in accordance with 10CFR50.55(e) and 10CFR21, when applicable. This change is submitted to alleviate ambiguity surrounding the inclusion of startup as part of the construction phase as expressed in the NRC questions on Revision 4 to the QAPD.

This clarification does not reduce commitments contained in Revisions 4 and 5 to the QAPD.

Revision to provide direction on documents to be trended.

Page 27 was revised to state that approved procedures will specify the specific deficiency documents to be trended. This change was made in response to the NRC questions on Revision 4 of the QAPD concerning trending of Deficiency Notices (DNs). DNs will be trended as designated in the approved trend analysis procedure. This revision does not reduce commitments contained in Revisions 4 and 5 of the QAPD.

Revision to clarify Level D storage requirements.

Table I-5 was revised to clarify access limits and posting requirements for Level D storage areas. This change was made to eliminate uncertainty in the posting requirements for access control for Level D storage areas. The statement in the QAPD, Revision 4 requiring Level D access controls consistent with Zone IV areas as defined by ANSI N45.2.3, i.e. nc personnel accountability, was revised to require posting of storage level designation only in Level D areas. No reduction in commitments contained in Revisiont 4 and 5 to the QAPD have been made.

Revision to describe organizational changes for training responsibilities.

Pages 3, 7,12 and Figure 1 have been revised to reflect the formation of a centralized Nuclear Training group to direct, coordinate and administer the STP Nuclear Training efforts. This change was made to maximize the use of available training resources and to minimize redundancy inherent in the use of separate, departmental training groups. No reduction in commitments previously contained in Revisions 4 and 5 of the QAPD have been made.

Revision to incorporate an additional organizational description.

Page 3 has been revised to describe the functions of the Vice President, Nuclear Engineering and Construction. This position description has been added to provide additional detailed information on Senior Management involvement in the engineering, licensing and construction phases of the South Texas Project.

There has been no reduction in commitments contained in revisions 4 and 5 of the QAPD.

Revision to clarify changes in organization titles and reporting functions.

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f' ST-HL-AE-1077 Attachment Page 3 of 4 Pages 7, 8 and 9 have been revised to reflect changes in title and/or reporting functions for various positions within the Engineering, Records Management, Construction and Procurement organizations. These changes were made to align the reporting relationships with actual practice. Since these clarifications do not represent responsibility changes in the applicable organizations, no reduction in comitment has been made.

Revision to clarify basic requirements for procurement activities.

Page 16 has been revised to incorporate ANSI N45.2.13 requirements related to extension of applicable requirements to lower tier subcontractors and suppliers and inclusion of provisions for control of nonconformances within procurement documents. This change provides additional detail or. HL&P's commitment to ANSI requirements and does not constitute a reduction in commitments previously contained in revisions 4 and 5 of the QAPD.

• Revision to clarify method utilized by HL&P QA to ensure quality requirements are met.

Page 22 has been revised to specify that assurance that special process control criteria are met is provided by HL&P QA through verification, i.e.,

audits, surveillances, inspections and document reviews. This change represents a more accurate statement of HL&P's methods of guaranteeing implementation of quality re';uirements and does not constitute a reduction in comitment.

Revision to incorporate procedural requirement for control of Inspection, Test and Operating Status Indicators.

Page 26 has been revised to incorporate the requirement of ANSI N45.2, Section 15 to provide procedural control of status indicators. This does not constitute a reduction in commitments previously contained in revisions 4 and 5 of the QAPD.

• Revision to incorporate additional Nonconformance approval.

Page 26 was revised to require signature for final closecut on nonconformance reports. This requiremer.t was incorporated from the HL&P Nuclear Quality Assurance Program Manual and does not constitute a reduction in comi tment.

Revision to clarify edition of NFPA Number 232 committed to.

Page 27 was revised to specify the edition of NFPA number 232 that will be met for a two-hour rated fire resistant file room. Revisions 4 and 5 of the QAPD did not specify an edition. This clarification does not constitute a reduction in commitment.

" Revision to clarify responsibilities for coordinating Westinghouse (W) disposition approval on nonconformances involving W_.

Page 26 has been revised to clarify that the organization responsible for providing a disposition NCRs written against W will obtain the necessary W concur-rence. This responsibility was formerly assigned to HL&P and has been revised to reflect actual practice. Since W concurrence is still obtained on NCRs issued to W, no reduction in commitment has occurred.

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ST-HL-AE-1077 Attachment Page 4 of 4 Part B, Bechtel QAPD for South Texas Project Revision to clarify a definition involving Division Quality Policies.

Page 4 of the Introduction has been revised to allow greater flexibility in modifying, deleting, or supplementing Division Quality Policies to meet the requirements of individual projects. No reduction in commitments contained in revisions 4 and 5 of the QAPD has been made.

" Revision to clarify Level D storage requirements.

Appendix A, Page A-4 was revised to clarify access limits and posting requirements for Level D storage areas. This change was made to eliminate uncertainty in the posting requirements for access control for Level D storage areas. The statement in the QAPD, Revision 4, requiring Level D access controls consistent with Zone IV areas as defined by ANSI N45.2.3, i.e. no personnel accountability, was revised to require posting of storage level designation only in Level D areas. No reduction in commitments contained in revisions 4 and 5 to the QAPD have been made.

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Part C, Ebasco Nuclear Quality Assurance Program for South Texas Project INTRODUCTION & SCOPE OF SERVICES

1.

Introduction:

a. Revised first paragraph to clearly distinguish the project-related manual from the Corporate Revision 11. Minor editorial change to clarify wording.

b. Added second paragraph to describe the manner in which South Texas project-related manuals are assigned as well as the terms for such assignment.

2. Scope of Services:

a. Revised first paragraph to indicate that procurement sections of ETR-1001 are not applicable to the Ebasco scope of services for the South Texas Project.

b. The second, third, fourth, and fifth paragraphs have been deleted since the Ebasco scope of services for the South Texas Project does not include procurement of any kind or subcontractint of safety-related services.

c. Revised sixth paragraph to clarify and to indicate that Ebasco may prepare drawings which are not design documents when authorized by design specifications.

d. Added paragraph to clarify differences in quality trend analysis responsibilities of Ebasco and the Client.

These changes have been made to delete references to ESI procurement or subcontract activities, to clarify ESI's role in trend analysis, to redefine ESI's activities related to control of drawings and to provide minor clarifications on the area of ESI's program manuals.

These changes do not reduce commitments previously made in revisions 4 and 5 of the QAPD.

TABLE OF CONTENTS Revision numbers and dates were changed to reficct applicable section revisions.

SECTION QA-I-1

1. Paragraph 1.0:

a. Deleted ANSI N45.2.13 and RG 1.123 as applicable requirements since procurement is not within Ebasco's scope of services for the South Texas Project.

b. Various editorial changes in wording for clarification purposes.

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2. Paragraph 4.2:

a. Deleted the Vendor Quality Assurance Department Procedures Manual since vendor quality assurance is not within Ebasco's scope of services for the South Texas Project,

b. Corrected titles of the pro;edures manuals as appropriate and indicated those procedures manuals which are project-specific.

c. Added Construction Maintenance Instructions as QA Program implementing documents.

3. Paragraph 4.3:

Deleted reference to Ebasco-purchased items since procurement is not within Ebasco's scope of project services.

4. Paragraph 4.4:

Entire paragraph deleted since procure.aent is not within Ebasco's scope of project services.

5. Paragraph 5.0:

Revised to clarify that the governing Quality Assurance Program Manual for the South Texas Project is the project-related manual rather than the Corporate manual (ETR-1001).

6. Paragraphs 6.1, 6.2, and 6.3:

Revised to indicate the auditing entities within the Ebasco organization which are applicable to the South Texas Project (i.e. Site Quality Assurance, Home Office Quality Assurance Engineering, and Management) and to reflect the scope of auditing responsibilities corresponding to each.

7. Table I-1.1:

a. Revised to reflect deletion of Manual Sections QA-I-5, QA-III-3, QA-III-4, and QA-III-5 that were applicable to procurement ard vendor-related activities which are not within Ebasco's scope of services for the South Texas Project.

b. Revised to indicate those 10CFR50 Appendix B criteria and ANSI N45.2 paragraphs which are not applicable to Ebasco's scope of services for the South Texas Project.

8. Tables I-1.2 and I-1.3:

Revised to reflect the deletion of procurement and vendor-related activities from Ebasco's scope of project services and to indicate new impicmenting procedures or revised procedure titles.

These changes have been made to delete references to ESI procurement and subcontract activities and to clarify responsibilities assigned to Home Office and site organizations. Other minor editorial changes have also been made for clarification purposes. No reduction in commitments contained in revisions 4 and 5 of the QAPD have been made.

l SECTION OA-I-2

1. Paragraph 2.3:

Revised to delete reference to the Procurement Division and corresponding Figure I-2.5.

2. Paragraph 3.1:

Revised to reflect title change.

3. Paragraph 3.1.1.1:

Revised to reflect only those responsibilities of the Manager Site Quality Assurance which are specific to the South Texas Project and to indicate authority delegated to the South Texas Project Quality Program Site Manager with regard to Site Quality Assurance and Site Quality Control procedures.

4. Paragraph 3.1.1.2:

Revised to be specific for the South Texas Project, to delete reference to vendor meetings, and to include authority delegated by the Chief Quality Assurance Engineer regarding Quality Assurance procedures.

5. Paragraph 3.1.1.2.1:

a. Deleted functions related to procurement and vendors.

b. Added Site Quality Assurance functional responsibilities which were not previously addressed and to clarify function descriptions to reflect project requirements and practices.

6. Paragraph 3.1.1.2.2:

a. Added "the Client or his designee" in lieu of " Engineering" in Subparagraph (c).

b. Added " procedures" in lieu of " Plans" for clarification in Subparagraph (g),

c. Deleted reference to work performed by contractors.

7. Paragraph 3.1.1.2.3:

Deleted reference to vendor / contractor records and added "...until turnover to the Client or his designee" to Subparagraph (b).

8. Paragraph 3.1.1.3:

Deleted Sulparagraph (c) which referred to supplier evaluation.

9. Paragraph 3.1.1.4:

a. Deleted references to manufacturers.

b. Added Subparagraph (d) to read as follows: " Qualification and certification of Ebasco NDE personnel."

10. Paragraph 3.1.2:

a. Added a description of the Site Welding Superintendent position and corresponding functional and reporting responsibilities.

b. Deleted all references to suppliers.

c. Added Materials Applications functional responsibilities which were not previously addressed and to clarify function descriptions to reflect project requirements and practices.

11. Paragraph 3.1.3:

Deleted entire paragraph since vendor quality assurance is not within Ebasco's scope of services for the South Texas Project.

12. Paragraph 3.1.5:

Renumbered as 3.1.4-and deleted reference to soils, concrete, and reinforcing steel testing services which are not within Ebasco's scope of services for the South Texas Project.

13. Paragraph 4.2.1:

Deleted paragraph in its entirety since the Manager of Construction Engineering has no functional responsibilities applicable to the South Texas Project.

14. Paragraph 4.3:

Revised to more appropriately describe the responsibilities of the Site Manager.

15. Paragraph 4.7:

Revised for purpose of clarification and to delete reference to Level III schedules.

16. Paragraph 4.10:

Deleted paragraph in its entirety since Ebasco's scope of project services does not include management of construction control functions.

17. Paragraph 4.13:

Renumbered as 4.12 and revised to reflect that the Safety Supervisor now reports directly to the Site Manager.

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18. Paragraph 4.14:

Renumbered as 4.13 and deleted reference to purchasing and material control.

19. " Paragraphs 4.15, 4.16, 4.17, and 5.0:

Deleted in their entirety since warehcasiag, purchasing, and subcontcacting are not within Ebasco's scope of project services.

20. Paragraph 6.0:

a. Renumbered as Paragraph 5.0.

b. New Paragraph 6.0 entitled " Organization Charts" was added to provide a listing of applicable organization charts and corresponding revision status of each.

21. Figure I-2.4:

Revised to reflect organization changes / deletions indicated in subparagraphs of Paragraph 4.0.

These changes have been made to delete references to activities which are no longer within ESI's scope of responsibilities on the STP, including procurement and subcontractor activities, references to soil, concrete and reinforcing steel testing services, management of construction control functions and warehousing. Organizational changes made include addition of a new description, deletion of positions with no functional responsibility on the STP and clarification of responsibilities at the ESI Home Office and STP site. Other minor editorial changes were made for clarification and readability purposes. These changes do not represent a reduction in commitments contained in revisions 4 and 5 of the QAPD.

SECTION QA-I-3

1. Paragraph 1.0 Revised to clarify that the governing document is the project related manual rather than the Corporate manual.

2. Paragraphs 2.0, 3.1, 3.3, 4.0, 5.0, 6.0, and 7.0:

Revised to limit discussion of personnel traininb and indoctrination to only those specific Ebasco organizations with responsibility for providing safety-related services to the South Texas Project.

3. Paragraph 3.2:

Deleted in its entirety since engineering, procurement, and licensing are not applicable to Ebasco's scope of services for the South Texas Project.

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4. Paragraph 8.0:

a. Revised heading to clarify subject of paragraph.

b. Deleted reference to a specific Site Quality Control procedure since there are a number of implementing procedures which address requirements fer the training, qualification, and certification of Site Quality Control inspection personnel.

c. Revised to clarify the manner in which training of Quality Control personnel is initiated, to clarify responsibility for maintenance of qualification records, and to clarify the manner in which the qualification records are audited.

These changes have been made to delete references to training activities involving organizations which do not have responsibilities within ESI's scope of work at the STP, including procurement, engineering and licensing.

Changes were made to focus on the responsibilities of those organizations involved in training and indoctrination activities for the STP and to provide clarification on training of Quality Control personnel. Minor editorial changes to revise a section heading and to enhance readability were made. No reduction in commitments was made.

SECTION QA-I-5 Section QA-1-5 'QA Evaluation of Suppliers / Contractors' was deleted in its entirety since Ebasco's scope of services for the South Texas Project does not include evaluation of suppliers and contractors. These activities are administered and performed by HL&P and BEC, as appropriate. This deletion does not represent a reduction in commitment.

SECTION QA-I-6

1. Paragraph 1.0:

Deleted second sentence since a project filing system is applicable only to those projects in which Ebasco is responsible for overall project management involving home office activities such as engineering, procurement, and licensing.

2. Paragraph 2.0:

Editorial changes including deletion of QA acronym and change of wording from ' owner' to ' client.'

3. Paragraph 3.0:

Deleted reference to the Ebasco Engineering and Procurement organizations.

4. Paragraph 4.1:

Deleted reference to procurement documents.

5. Paragraph.4.3:

Revised for clarification purposes.

6. Paragraph 4.5:

Editorial change to specify QA records.

7. Paragraph 4.7:

Revised to include as an acceptable alternative the use of authorized initials in conjunction with correcting or supplementing QA records.

8. Paragraph 4.8:

a. Revised Subparagraphs (a) and (f) for clarification purposes,

b. Deleted reference to manufacturing in Subparagraph (b).

9. Paragraph 5.1:

Former Paragraph 5.1 was deleted in its entirety since procurement is not within Ebasco's scope of project services.

10. Paragraph 5.2:

Renumbered as Paragraph 5.1 and revised second sentence to clarify responsibility for QA records maintenance and auditing.

11. Paragraphs 6.1.1 and 6.1.2:

Revised for clarification purposes.

12. Paragraph 6.1.3:

Revised to include provisions for verification that QA records received are legible.

13. Paragraphs 6.1.5, 6.2, 6.3, and 6.5:

Revised for clarification purposes.

14. Paragraph 7.0:

Editorial change to specify ' client' rather than ' owner.'

These changes have been made to delete references to activities which are not within ES1's scope of work at the STP including procurement, manufacturing and maintenance of a project filing system. Other changes provided clarification of various activities including responsibility for QA records maintenance and auditing, use of initials to authorize corrections or suppicments to records and verification of QA record legibility. Hinor editorial changes were also made. The changes do not reduce commitments made in previous revisions to the QAPD.

1

SECTION OA-III-l

1. Paragraph 2.4:

Deleted in its entirety since procurement is not within Ebasco's scope of project services.

2. Paragraph 3.1:

Editorial changes including deletion of ' Implementing' Instructions, procedures and drawings and addition of ' organization' following Site Quality Assurance.

3. Paragraph 3.2:

a. Renumbered as Paragraph 3.3.

b. Changed second sentence from "Ebasco Standards and Procedures Department" to the "Ebasco Engineering Development and Standards Department" to correctly indicate the title of the Ebasco organization responsible for the development of company instructions and procedures.

c. Inserted new Paragraph 3.2 to indicate the Ebasco organization with responsibility for development of company procedures such as Nuclear (N) procedures.

4. Paragraph 4.2:

Revised to provide an option for an organization responsible for issuance of certain documents to procedurally delegate to a second organization the authority for maintenance of historical files applicable to the documents and to include the addition of maintenance of instructions in historical files.

5. Paragraph 4.3:

This paragraph added to address distribution and control of site-generated field sketches, construction procedures, quality control procedures, and special process procedures.

6. Paragraph 5.0:

This paragraph added to address requirements for review and approval of changes to Ebasco documents. The content of this paragraph previously appeared in Manual Section QA-III-2.

These changes were made to define responsibilities for document control, which are now accomplished by BEC, and to delete reference to ESI procurement activities. Additions were made defining responsibilities for development of procedures and review and approval of changes to ESI documents. Clarifications were made on Departmental titles and the option for delegation of responsibility for historical file maintenance. Minor editorial changes were also made. None of the changes reduce commitments contained in revisions 4 and 5 of the QAPD.

SECTION QA-III-2 This entire Manual section has been revised to reflect that the Client or his designee has assumed responsibility for distribution and control of all project documents which were previously distributed and controlled by the Senior Resident Engineer or his designee (i.e. design documents, drawings, specifications, construction procedures, special process procedures, quality control procedures, and construction field sketches). Since the activities necessary to support the distribution and control of project documents are still performed, although under the direction of a different organization, no reduction in commitment has been made.

SECTION QA-III-3 Section QA-III-3, ' Procurement Document Control' was deleted in its entirety since Ebasco's scope of services for the South Texas Project does not include procurement document control. This does not reduce commitments made in revisions 4 and 5 of the QAPD.

SECTION QA-III-4 Section QA-III-4, ' Construction Site Procurement' was deleted in its entirety since Ebasco's scope of services for the South Texas Project does not include procurement. This does not reduce commitments contained in revisions 4 and 5 of the QAPD.

SECTION QA-III-5 Section QA-III-5, ' Supplier / Contractor Surveillance' was deleted in its entirety since Ebasco's scope of services for the South Texas Project does not include surveillance of suppliers or contractors. This does not reduce commitments contained in revisions 4 and 5 of the QAPD.

SECTION QA-III-6

1. Paragraph 1.0:

Deleted reference to nonconformances to site purchase order requirements.

2. Paragraph 2.0:

Former Paragraph 2.0 was deleted in its entirety since Ebasco's scope of project services does not include control and reporting of supplier nonconformances.

3. Paragraph 3.1:

Former Paragraph 3.1 was renumbered as 2.1 and revised to reflect that nonconformances may also be reported to Site Quality Control.

4. Paragraphs 3.4 and 3.5:

Former Paragraphs 3.4 and 3.5 were renumbered as 2.4 and 2.5 respectively and revised to clarify review and processing requirements for nonconformance reports.

5. Paragraph 2.6:

Revised to clarify that the Site Quality organization is responsible for audits and reinspections.

6. Paragraph 4.1:

Deleted in its entirety since Ebasco's scope of project services does not include procurement.

7. Paragraph 5.0:

Former Paragraph 5.0 was renumbered as 4.0 and revised to clarify processing and review of nonconformance reports.

8. Paragraph 5.1:

Clarification of organization responsibic for approval of standard repair procedures.

9. Paragraph 7.0:

Former Paragraph 7.0 was renumbered as 6.0 and revised to indicate changes in responsibility for South Texas Project quality trend analysis (i.e. the Client is responsible for the project-specific trend analysis and Ebasco responsibility is limited to its corporate trend analysis).

10. Paragraph 7.0:

/ddition of procedures to be used in maintenance of nonconformance reports.

These changes were made to delete references to ESI procurement activities.

Clarifications were made to descriptions of reporting, reviewing, and processing of nonconformances and approval of standard repair procedures.

Clarification was also made in the responsibility for trend analysis.

These changes do not reduce commitments previously contained in revisions 4 and 5 of the QAPD.

SECTION QA-III-7

1. Paragraph 2.2:

a. Subparagraph 2.2.5 renumbered as (e) and revised to delete reference to supplier's facility.

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b. Added Subparagraph (g) to include Site QA surveillances as a source from which a need for corrective action may be identified.

c. Minor editorial changes for clarification purposes.

2. Paragraph 2.6:

Revised to clarify that the Site QA organization is responsible for corrective action documentation. Minor editorial changes for clarification.

3. Paragraph 2.7:

Revised to clarify that paragraph pertains specifically to responses for programmatic deficiency documents such as audit findings and not to responses for documents identifying hardware deficiencies such as nonconformance reports.

4. Paragraph 3.2.2:

Former Paragraph 3.2.2 was deleted in its entirety since Ebasco's scope of project services does not include eveluations or audits of suppliers.

5. Paragraph 2.8:

Changed to specify that the Site QA organization is responsible for ensuring timely corrective action implementation.

6. Paragraph 2.9:

Minor editorial changes for clarification.

7. Paragraph 3.3:

Former Paragraph 3.3 was deleted in its entirety since Ebasco's scope of project services does not include review of supplier nonconformances.

8. Paragraph 4.0:

Change to clarify that the site QA organization is responsible for verification of corrective action implementation.

9. Parnpraph 5.0:

Revised to indicate changes in responsibility for South Texas Project quality trend analysis (i.e., the Client is responsible for the project-specific trend analysis and Ebasco responsibility is limited to its corporate trend analysis).

Changes were made to delete reference to ESI procurement activities.

Clarifications were made on the Site Quality Assurance responsibilities for corrective action documentation, monitoring and verification. Additional clarification was provided in the responsibilities for trend analysis.

Other minor changes were also made. No reduction in commitments were made as a result of these changes.

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SECTION QA-III-8

[ 1. Paragraph 2.0:

P a. Revised to clarify responsibilities of the Ebasco organizations g responsible for the control of special processes.

k b. Deleted all references to purchase orders and suppliers since the Ebasco scope of project services does not include procurement.

2. Paragraph 3.1:

Former Paragraph 3.1 was deleted in its entirety since the Ebasco scope of

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project services does not include procurement.

p 3. Paragraph 3.2:

a. Former Paragraph 3.2 was renumbered as 3.1, and revised and restructured for clarification purposes.

b. Reference to construction contractors has been deleted.

l These changes deleting references to ESI procurement activities and l providing clarification on special process responsibilities does not reduce

any commitments contained in revisions 4 and 5 of the QAPD.

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ll l SECTION QA-III-9 P 1. This entire Manual section has been revised, restructured, and expanded to

[ include descriptions of site audits by Home Office Quality Assurance F Engineering and management audits by the Management Audit Committee.

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2. Added new Paragraphs 3.4, 3.6, and 3.7 to reflect project requirements and actual practice pertaining to audit scheduling, the audit team, and audit R notification, respectively.

5 E 3. Revised Paragraphs 5.4 (renumbered as 3.5), 5.5 (renumbered as 3.8), 5.6 pi (renumbered as 3.9), and 5.7 (renumbered as 3.10) to reflect project

$ requirements and actual practice pertaining to audit planning, audit performance, audit reporting, and audit follow-up, respectively.

4. Deleted Paragraph 4.0 that addressed auditing of suppliers which is not f

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within Ebasco's scope of project services.

P 5. Added new paragraph 4.0 to describe the specific auditing functions 6- performed by the Management Audit Committee, Site Quality Assurance, and EL llome Office Quality Assurance Engineering.

F F These changes, made to clarify the responsibilities for various ESI Home n-Office and Site organizations responsible for the audit function, do not

g. reduce commitments previously made in revisions 4 and 5 of the QAPD.

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SECTION QA-III-10

1. Paragraph 2.1:

Revised Subparagraph (a) to clarify that Ebasco receives all items and appropriate documentation from the Client or his designee who is responsible for receiving incoming items directly from suppliers and vendors.

2. Paragraph 2.2:

Revised to specify that Site Quality Assurance is responsible for performance of reviews and audits.

3. Paragraph 3.1:

Revised to include stamping as an acceptable means of physically identifying items.

4. Paragraph 3.2:

Editorial change to include ' individual' prior to 'small items.'

These changes, made to clarify source of supplier / vendor documentation submitted to ESI, method of physical identification and other minor changes, do not result in a reduction in commitments.

SECTION QA III-ll

1. Paragraph 2.4:

Revised to specify that Site Quality Assurance is responsible for performance of reviews and audits.

2. Paragraph 3.1:

Deleted reference to purchase orders.

3. Paragraph 3.5:

Revised to clarify intent of requirement.

4. Paragraph 3.6:

Revised to more clearly define the type of item for which a sampling inspection program may be utilized.

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5. Paragraph 5.2:

Revised to change qualifications to certification and addition of ' records' in second sentence.

The above changes were made to delete references to ESI procurement responsibilities and provide additional clarification on the conduct of inspection activities. These changes do not reduce conmitments contained in revisions 4 and 5 of the QAPD.

SECTION QA-III-12

1. Paragraphs 2.1 and 2.2:

Revised to cicarly reficct project requirements for content of procedures related to test control and to clarify that Site Quality Assurance is responsible for the procedure review and comment.

2. Paragraph 2.3:

Revised to change ' procedures' to 'requirementu.'

3. Paragraph 2.4:

Revised to clarify that Site Quality Asnurance is responsible for the performance of reviews and audits.

The above changes, made to expand on and clarify test control procedural requirements and to clarify organizational resporsibilities, do not reduce commitments contained in revisions 4 and 5 of the QAPD.

SECTION QA-III-13 _

1. Paragraphs 2.4, 3.1, and 3.4:

Revised to clearly reflect project requirements for control of measuring and test equi.pment.

2. Paragraph 2.3 (g):

Change to clarify intent of sentence.

3. Paragraph 3.7:

Revised to clacify that Site Quality Assurance is responsible for reviews and audito.

These revisions which include changes to reflect project requirements and minor editorial clarifications do not reduce comnitments contained in revisions 4 and 5 of the QAPD.

SECTION QA-III-14

1. Paragraph 1.1:

Revised to clarify that Ebasco receives all items from the Client or his designee who is responsible for receiving incoming items directly from suppliers and vendors.

2. Paragraph 2.0:

Inserted new Paragraph 2.0 entitled " Responsibilities" which defines specific responsibilities of individual organizations implementing the requirements of this Manual section.

3. Paragraph 3.2:

Editorial change adding 'when applicable.'

4. Paragraph 4.2:

Revised heading to reflect paragraph content.

5. Paragraph 4.1:

Former Paragraph 4.1 was renumbered as 5.1 and revised to provide distinction between items stored in controlled storage environments and items protected in-place.

6. Paragraph 4.2.1:

a. Former Paragraph 4.2.1 was renumbered as 5.2 and, in definition of Level C storage, inserted " ventilation" in lieu of " equivalent" to be consistent with project requirements.

b. Editorial change to 5.2 (b), (c), (e), (g), and 5.3 to provide clarification.

c. Deleted second sentence of Subparagraph (d) and incorporated it in new Paragraph 2.1 (d).

d. Deleted Subparagraph (g) since it is specifically applicable to warehousing which is not within Ebasco's scope of project services.

7. Paragraph 5.1:

a. Former Paragraph 5.1 (a) was deleted since it is applicable only when Ebanco in responsibio for initini receiving of incoming items from vendors,

b. Incorporated the remainder of the paragraph into new Paragraph 2.3.

- - _ _ _ _ _ _ - _ _ . - _ - -___--_-_.-----_-_/

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8. Added new Paragraph 6.0 entitled " Records" which references requirements for records maintenance. I These' changes were made to delete activities which are not part of ESI's l scope of work and to provide both editorial clarifications and clarifications to be consistent with project requirements. These changes i do not reflect a reduction in commitments.

SECTION QA-III-15

1. Paragraph 2.1:

Revised to be consistent with project requirements relating to methods for maintaining item status.

2. Paragraph 2.2:

Revised to;give an example of status indicators.

3, Paragraph:33.5:

Revised to clarify that Site Quality Assurance is responsible for 'E performance of reviews and audits.

The above changes do not reflect a reduction in commitment.

-APPENDIX I 1.' Since Ebasco's scope cf project services does not include procurement, the following terms and corresponding definitions were deleted:

a. Audits (External) b.- Bidder

c. Ebasco Engineering Office id. Construction Contracts e .' Inquiry

.f. Purchase Orders y i

g .- Sour $eSurveillance q

h.. Supplier N ,

_ < .?h t

. . [

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c

, .4'

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y _

d ' N p4 - m - y-

2. Added or revised the following terms and definitions:

a. Audits (Internal)

b. Client or his Designee

c. Ebasco Home Office

d. Safety-Related Item

e. Service Some of the above definitions were changed to delete references to ESI procurement activities, clarify organizational responsibilities or provide editorial changes. New definitions were added to provide additional understanding of the Manual. These changes do not reduce commitments previously contained in revisions 4 and 5 of the QAPD.

APPENDIX II

1. Revised Note 7 to be consistent with project requirements and practices.

2. Deleted Notes 22 through 26, that were applicable to ANSI N45.2.13 which is not applicable to Ebasco's scope of project services.

3. Titles were added throughout specifying the applicable ANS1 Standard.

These changes do not reduce commitments contained in revisions 4 and 5 of the QAPD.

sios.s asvP> io.e2 P a e t _12_.o r I 9 ESA$CO SERVICES NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL S ECTION INCoRPORATEo MOU$ TON LIGHTING AND POWER COMPANY g_

SOUTH TEXA5 PROJECT d ELECTRIC GENERATING STATION UNITS 1 & 2

> navision 5 E

h , , ,,,,,,,, QUALITY ASSURANCE PROGRAM ue 3/26/M Procedure No. Title QCP-10.5 Inspection of Structural Steel Erection and Bolting QCP-10.6 Stud Welding Inspection QCP-10. 7 Miscellaneous Metal Fabrication Inspection QCP-10.8 Protective Coatings Inspection QCP-10. 9 General Inspection QCP-10.10 Soils Inspection QCP-10.11 Mechanical Equipment Installation Inspection QCP-10.12 Pipe Support Installation Inspection lR6 QCP-10.13 Mechanical Instrumentation Installation Inspection Q CP-10.14 System / Subsystem Walk-Down Inspection lR6 QCP-10.15 Electrical Equipment Installation Inspection QCP-10.16 Inspection of Electrical Raceways lR6 QCP-10.17 Electrical Cable Installation Inspection QCP-10.18 Electrical Cable Termination Inspection QCP-10.19 Inspection of Concrete Expansion Anchors, lR6 Rock Bolts, and Core Drilling l QCP-10. 20 Electrical Instrumentation Installation Inspection QCP-10.21 HVAC Duct / Hanger Installation Inspection QCP-10. 2 2 Receipt Inspection of ASME Section III and Other Safety-Related Equipment / Materials

J PART A f

HOUSTON LIGHTING AND POWER COMPANY QUALITY ASSURANCE PROGRAM DESCRIPTION 4

i SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION

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QUALITY. ASSURANCE DURING DESIGN AND CONSTRUCTION REVISION 6 i

DATE March 30, 1984 i

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HOUSTON LIGHTING & POWER COMPANY QUALITY ASSURANCE PROGRAM DESCRIPTION Table of Contents SECTION TITLE PAGE 1.0 Organization 2 2.0 Quality Assurance Program 10 3.0 Design Control 13 4.0 Procurement Document Control 15 5.0 Instruction, Procedures and Drawings 16 6.0 Document Control 17 7.0 Control of Purchased Material, Equipment and Services 18

-8.0 Identification and Control of Material, Parts and Components 20 9.0 Control of Special Processes 21 10.0 Inspection 22 11.0 Test. Control 23 12.0 Control of Measuring and

( Test Equipment 24 13.0 . Handling, Storage and Shipping 25

14.0 Inspection, Test and Operating Status 25

_ 15.0 Nonconforming Materials, Parts l or Components 26 l

L 16.0' ' Corrective Action 26 l

17.0 Quality Assurance Records 26 18.0 Audits 27 I

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, HOUSTON LIGHTING & POWER COMPANY QUALITY ASSURANCE PROGRAM DESCRIPTION List of Tables NUMBER TITLE 1 ANSI Standard and Regulatory Guide Compliance 2 .HL&P Manuals Used to Implement the Quality Assurance Program List of Figures NUMBER TITLE 1 South Texas Project Internal QA Relationship L

i-2 Lines of Communication HL&P & BEC/ Westinghouse (Contractors) e

QUALITY ASSURANCE PROGRAM DESCRIPTION South Texas Project Electric Generating Station Quality Assurance During Design and Construction Houston Lighting & Power Company (HL&P), as a licensee and as Project Manager for itself and the other owners, has quality assurance responsibility for design, engineering, procurement, fabrication, construction and operation associated with the South Texas Project Electric Generating Station (STP).

Although HL&P has delegated certain of its quality assurance authority to its contractors, it nevertheless retains the responsibility for the quality assurance program controlling all aspects of the STP. HL&P reviews and approves this QAPD and all changes thereto prior to implementation. Additionally, HL&P establishes quality assurance requirements for the project in a Project Quality Assurance Plan. The Project Quality Assurance Plan specifies requirements '

applicable to prime contractors and HL&P. The HL&P Quality Assurance staff monitors the performance of HL&P staff and contractors to assure compliance with the Project Quality Assurance Plan.

HL&P has contracted with Westinghouse Electric Corporation (Westinghouse) for the design, fabrication and quality assurance services for the nuclear steam supply system and with Bechtel Energy Corporation (BEC) for plant Design, procurement, engineering, construction management, quality assurance services and other related services, including quality assurance services for Westinghouse items upon receipt at the project site. HL&P has contracted with Ebasco Services, Inc. (ESI) for construction services including quality assurance and quality control for its scope of work. This quality assurance program description addresses the HL&P quality assurance program (Part A), the quality assurance program of BEC (Part B), and the quality assurance program of ESI (Part C). The Westinghouse quality assurance program is described in WCAP-8370, " Westinghouse Nuclear Energy System Divisions Quality Assurance Plan" and is not included in this program description.

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PART A HOUSTON LIGHTING & POWER COMPANY QUALITY ASSURANCE PROGRAM DESCRIPTION South Texas Project Electric Generating Station Quality Assurance During Design and Construction Houston Lighting & Power Company (HL&P), as a licensee and as Project Manager for itself and the other owners, has the Quality Assurance (QA) responsibility for design, engineering, procurement, fabrication, construction, preoperational testing and operation of the South Texas Project (STP) Electric Generating Station.

HL&P's Project Quality Assurance Plan requires that HL&P, its prime contractors, subcontractors and vendors comply with the criteria established by 10CFR50, Appendix B. It is the intent of HL&P to comply with ANSI N45.2 and the applicable daughter standards and implementing Regulatory Guides as indicated in Table 1. Furthermore, HL&P will assure through programmatic direction that the prime contractors and all their subcontractors and suppliers performing nuclear safety-related work comply with 10CFR50, Appendix B; ANSI N45.2, and the Regulatory Guides as referenced herein consistent with their scope of work.

Programmatic direction is defined as the role of the owner in establishing the program requirements and ensuring the adequacy of the Prime Design, Engineering and Construction Management Quality Assurance Program. The programmatic direction consists of review and approval of the system features initially and continued monitoring of those systems during implementation and further refinement or revision of the systems if the systems need strengthening. The assurance of compliance by first level nuclear safety-related suppliers and contractors will be accomplished through the Engineer / Construction Manager's review and approval of the supplier's/ contractor's Quality Assurance Program.

The system monitoring is achieved through audits and surveillances of work in l

progress.

The HL&P Quality Assurance Program is implemented in two phases: the design and construction phase as defined by the Project Quality Assurance Plan and the operational phase, including preoperational testing and startup, as defined by the Operational Quality Assurance Plan. The Project Quality Assurance Plan is described herein. The Operational Quality Assurance Plan is described in Chapter 17.2 of the FSAR.

The combination of these Quality Assurance programs augmented by definitive procedures provide HL&P with the assurance that its quality commitments are met, i

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I l 1.0 Organization 1.1 The organization chart shown in figure 1 illustrates: (a) groups within HL&P having quality responsibilities (engineering, procurement, construction) and b) Quality Assurance interdepartmental relationships for the South Texas Project.

1.2 The Project Quality Assurance Manager, South Texas Project, is responsible for providing the programmatic direction, and administe-ring policies, goals, objectives and methods which are described in the Project Quality Assurance Plan. The HL&P Executive Vice President, Nuclear Group, reviews and approves the Project Quality Assurance Plan and has ultimate responsibility for Quality Assurance activities. The Project Quality Assurance Plan interf aces with the Corporate Quality Assurance Program objectives by describing specific Quality Assurance controls to be established by HL&P and the prime contractors on the South Texas Project.

1.3 Two levels of control have been implemented by HL&P to monitor the effectiveness of the Quality Assurance Programs at the South Texas Project.

a. Corporate level control - Corporate level control is achieved through the direct involvement of the HL&P Executive Vice President, Nuclear Group, and corporate audits and vendor surveillance as described below. The Executive Vice President, Nuclear Group, regularly meets with QA management and receives reports on the status of the QA Programs to aid him in evaluating the overall effectiveness. Corporate QA audits and vendor surveillance are conducted under the direction of the Manager, Quality Assurance to evaluate the overall program effectiveness of HL&P Project Quality Assurance, Westinghouse and its suppliers. Corporate audits of the Architect Engineer / Construction Manager's activities may be performed as requested by the Project Quality Assurance Manager.

b. Project level control - Project level control is achieved through Project Quality Assurance Program approval and monitoring of the effectiveness of implementation by HL&P, prime contractors and subcontractors. The Project QA staff under the direction of the Project Quality Assurance Manager prepares the Project Quality Assurance Plan and reviews and approves the Project Quality Assurance Program for the Architect Engineer / Construction Manager. The monitoring is implemented by scheduled project audits performed by qualified auditors. Additional monitoring is accomplished by Project QA personnel performing unscheduled selected surveillance of in-process work. HL&P Project Quality Assurance also maintains the capability to perform inspection verifications of in-process or completed work if determined to be necessary by the Project Quality Assurance Manager. If necessary the inspections are performed by personnel qualified in accordance with ANSI N45.2.6.

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1.3.1 Vice President, Nuclear Engineering & Construction The Vice President, Nuclear Engineering.and Construction, is responsible for nuclear project management and the engineering, licensing, and construction of the nuclear plants. The Vice President, Nuclear Engineering and Construction, provides technical guidance and administrative direction to:

a. Manager, Nuclear Engineering

b. Manager, South Texas Project

c. Manager, Engineering Assurance The Vice President, Nuclear Engineering and Construction, reports to the Executive Vice President, Nuclear Group.

1.3.2 Manager, Quality Assurance The Manager Quality Assurance, has the authority and responsibility to identify, initiate, recommend, or provide solutions to quality related problems and verify the implementation and effectiveness of the solutions. He has the authority to "Stop Work" for cause in the design, construction and operation phase of the nuclear plant.

The minimum requirements established for this position are:

a) A college degree in a field of engineering or science, or equivalent experience, b) Familiarity with nuclear power generation facilities and the related operations, c) Knowledge of the industry's c,uality assurance standards and regulatory require:acnts.

d) Management experience and familicrity with HL&P corporate organizations.

The Manager, Quality Assurance, provides technical guidance and administrative direction to:

a) Project Quality Assurance Manager b) Support Quality Assurance Manager c) Operations Quality Acaurance Manager g

The Manager, Quality Assurance, reports to the Executive Vice President, Nuclear Group.

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1.3.3 Project Quality Assurance Manager, South Texas Project The Project Quality Assurance Manager, South Texas Project, has the responsibility to identify, initiate, recommend, or provide solutions and authority to solve quality related problems and to verify the implementation and effectiveness of the solutions. He has the authority to "Stop Work" for cause on any quality-related activity of the South Texas Proj ec t.

The Project Quality Assurance Manager, South Texas Project, must, as a minimum, have:

a) A college degree in a field of engineering or science, or equivalent experience.

b) Familiarity with nuclear power generation facilities

, and related operations, c) Knowledge of the QA standards and regulatory requirements, d) Management experience and familiarity with HL&P corporate organizations.

The major responsibilities of the Project Quality Assurance Manager, STP, are:

a) Develop and administer QA policies, goals, objectives, and methods which ensure the proper planning, development, implementation, coordination and administration of the Project Quality Assurance Plan, b) Provide programmatic direction on QA related matters to HL&P, and contractor management, and provide the primary interface with.NRC.

c) Direct the onsite audit and surveillance activities; direct audits /surveillances of the Engineer / Construction Manager's QA program implementation in the design office.

d) Coordinate activities relating to auditing and vendor surveillance in conjunction with the HL&P Support Quality Assurance Manager.

The Project Quality Assurance Manager reports on all quality assurance matters directly to the Manager, Quality Assurance.

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l.3.4 Support Quality Assurance Manager The Support Quality Assurance Manager is responsible for directing all HL&P corporate office auditing, vendor surveillance and technical services activities. He has the authority to "Stop Work" for cause on any quality-related activity of the South Texas Project.

The Support Quality Assurance Manager must, as a minimum, have:

a) A college degree in a field of engineering or science, or equivalent experience, b) Familiarity with nuclear power generation facilities and the related operations.

c) Knowledge of the industry QA standards and regulatory requirements, d) Management experience and familiarity with HL&P corporate organizations.

The major responsibilities of the Support Quality Assurance Manager are:

a) Directs the HL&P Corporate Quality Assurance Audit Program.

b) Directs the HL&P vendor surveillance program, c) Directs the HL&P Technical Services Group of the Support Division.

The Support Quality Assurance Manager reports on all quality assurance matters directly to the Manager, Quality

, Assurance.

1.3.5 Project Quality Assurance General Supervisor, Quality Engineering The Project Quality Assurance General Supervisor, Quality {

Engineering reports directly to the Project Quality

, Assurance Manager, South Texas Project. He is responsible l for technical direction and administrative guidance to the I

site Quality Engineering personnel, providing programmatic direction to prime contractors and interfacing with the NRC.

He has the authority to "Stop Work" for cause on any activity related to fabrication and construction.

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1.3.6 Supervisor, Quality Systems / Administration The Supervisor, Quality Systems /Adninistration reports directly to the Project Quality Assurance Manager, South Texas Project. He is responsible for providing technical direction and administrative guidance to the Quality Systems / Administration personnel; developing and administering the HL&P Project QA Plan; evaluating the Engineer / Construction Manager and Constructor QA programs; administering the HL&P STP QA personnel training and certification program; administrative control of HL&P STP project quality assurance procedures and providing mechanisms to correct the QA programs as necessary. He has the authority to "Stop Work" for cause on any activity related to fabrication or construction.

1.3.7 Supervisor, Quality Control The Supervisor, Quality Control reports directly to the Project Quality Assurance Manager, South Texas Project. He is responsible for technical direction and administrative guidance to the HL&P Quality Control personnel, coordinating inspection of selected fabrication and construction activities, ensuring proper nonconformance identification and assuring that the personnel performing inspections are properly certified. He has the authority to "Stop Work" for cause on any activity related to fabricacion or construction.

1.3.8 Project QA Supervisors, Quality Engineering The Project QA Supervisors, Quality Engineering report to the Project Quality Assurance General Supervisor, Quality Engineering. They are responsible for technical direction and administrative guidance to the HL&P Quality Engineering personnel in their respective discipline group; conducts

. audits of the construction manager and contractor activities, including QA; interface with NRC~during audits; identifying deficiencies; reviewing procedures applicable to their respective discipline; and providing programmatic direction to the prime contractor. They have authority to "Stop Work" for cause on any activity related to fabrication or construction.

1.3.9 Project QA Supervisor, Design / Procurement The Project QA Supervisor, Design / Procurement reports directly to the Project Quality Assurance Manager, South Texas Project. He is responsible for providing technical direction and administrative guidance to HL&P Design / Procurement Quality Assurance personnel, coordinating the resolutions of vendor problems identified by HL&P QA, coordinating with site QE personnel for input to vendor 6

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l surveillance / audit activities and providing programmatic direction to the Engineer / Construction Manager regarding l design control, vendor surveillance and auditing functions.

He has the authority to "Stop Work" for cause on any activity related to engineering, design, or procurement.

1.3.10 Manager, Nuclear Training The Manager, Nuclear Training reports to the Executive Vice President, Nuclear Group. He directs, coordinates and ,

j administers the STP nuclear training efforts and provides direction to the prime contractors relative to training.  !

The STPEGS Nuclear Training program includes the Quality Assurance Indoctrination for HL&P personnel associated with the safety-related activities for the South Texas Project.

1.3.11 Manager, South Texas Project The Manager, South Texas Project reports to the HL&P Vice-President, Nuclear Engineering and Construction. He has overall responsibility for the engineering, construction, procurement, cost, schedule, and startup of the South Texas Project. He has authority to "Stop Work" for cause in all activities of the project.

1.3.12 Manager, Support Services The Manager, Support Services reports to the Manager, South Texas Project. He is responsible for procurement, project control services, accounting, project administration, contract administration and records management services. He has the authority to "Stop Work" for cause in activities related to purchasing and expediting.

1.3.13 Manager, Engineering The Manager, Engineering reports to the Manager, South Texas Project. He directs project engineering personnel in the performance of the owner's review of the design and engineering work performed by the prime contractors. The Manager, Engineering ensures that adequate engineering planning, coordination of solutions to problems and work priorities are established by the prime contractor. He has the authority to "Stop Work" for cause in the engineering and design of all items.

1.3.14 Supervising Project Engineer, Site Engineering (

The Supervising Project Engineer, Site Engineering reports to the Manager, Engineering for technical direction. He

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also receives project direction from the Site Manager. He is responsible for coordinating the site engineering interface in the technical resolution of all site related 7

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engineering problems, reviewing field change requests, and site-initiated design change notices. He assists in the release and interpretation of design documents. He can recommend "Stop Work" for cause in the engineering and design for those items within his area of responsibility.

1.3.15 Supervising Engineer, Nuclear Licensing The Supervising Engineer, Nuclear Licensing reports to the Manager, South Texas Project for project direction and to the Manager, Nuclear Licensing for technical direction. He is responsible for overseeing, coordinating and administering the South Texas Project Licensing effort.

1.3.16 Nuclear Licensing Team Leader The Nuclear Licensing Team Leader reports to the Supervising Engineer, Nuclear Licensing. He is responsible for coordinating all regulatory activities related to the nuclear safety analysis and licensing of the South Texas Project. The Chairman of the IRC, while not necessarily the Nuclear Licensing Team Leader, is a duly qualified member of the Nuclear Licensing Department. Assignment of this responsibility will be specified in approved procedures.

1.3.17 Manager, Records Management and Information .,

Processing The Manager Supervisor, Records Management and Information Processing reports to the Manager, Support Services. He ,is responsible for managing the Records Management personnel and interfacing with the prime contractors and all project organizations with respect to the establishment of systems that control, collect, store and transfer records related to the South Texas Project.

1.3.18 Site Manager The Site Manager reports to the Manager, South Texas Proj ect. He is responsible for providing technical direction and administrative guidance to HL&P and its prime contractors in the area of construction, site purchasing, startup, construction control and reviewing documents, drawings and_ specifications related to construction. He also provides administrative guidance for HL&P site engineering. He has the authority to "Stop Work" for cause in all activities related to construction.

1.3.19 Startup Manager The Startup Manager reports to the Manager, STP, for project direction and to the Nuclear Plant Operations Plant Manager for technical direction. He is responsible for managing all 8

startup activities for the South Texas Project. He reviews and approves startup instructions, procedures and reports which assure conformance to design and safety requirements.

He reviews and recommends approval of construction and design changes identified during test program. He maintains a liaison with HL&P and prime contractors with respect to startup problems and support activities.

1.3.20 Startup Ceneral Supervisor Startup General Supervisor reports to the Startup Manager.

He works as directed by the Startup Manager and assists in the effective administration, control, and implementation of the test program.

1.3.21 Construction Superintendent, Nuclear Construction The Construction Superintendent, Nuclear Construction reports to the Site Manager. He is responsible for ensuring that the prime contractors comply with all contractual and construction requirements. He monitors the prime contractors construction in the areas of evaluating and analysis of construction plans and schedules, work methods, craft performance, staffing, equipment utilization and progress.

1.3.22 Supervising Site Engineer, Construction Support .

The Supervising Site Engineer, Construction Support reports ,

to the Supervising Project Engineer, Site Engineering. He is responsible for providing technical and administrative support to all HL&P Site Organization, and for monitoring the activities of the Prime Contractors' construction engineering groups.

1.3.23 Area Construction Supervisor (s)

The Area Construction Supervisor (s) reports to the Construction Superintendent, Nuclear Construction. They are a responsible for monitoring and surveillance of the prime contractor's construction activities, expediting the resolution and corrective actions of problems identified by 0A/QC and verifying that construction plaining includes requirements for inspection and testing.

1.3.24 Manager, Nuclear Purchasing The Manager, Nuclear Purchasing reports to the Manager, Suppert Services for project direction and to the Vice a President, Purchasing for technical direction. He is responsible for overall coordination and administration of t

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purchasing, contracts administration and subcontracting activities for the South Texas Project. He directs the development and implementation of procedures, vendor selection, contract negotiations and preparing purchase orders for those contracts administered by HL&P.

1.3.25 Project Purchasing Manager The Project Purchasing Manager reports to the Manager, Nuclear Purchasing. He is responsible for the implementation of a comprehensive Material Control Program and for proper procurement of permanent and temporary equipment, material and services for the South Texas Proj ect .

1.3.26 Project Contracts Manager The Project Contracts Manager reports to the Manager, Nuclear Purchasing. He is responsible for the overall coordination of the Project's contracting activities; for assuring the monitoring and auditing of Project contracts for compliance by the contracting parties; and for direct placement and administration of required contracts not within the scope of the Architect-Engineer / Construction Manager's contract.

1.4 The organizations or entities listed below may be delegated quality assurance authority within their scope of work.

ML&P has the responsibility to audit and monitor all of the below listed organizations' or entities' performance to assure that their quality programs provide sufficient authority and organizational freedom for personnel performing QA functions and that they are effectively implemented.

a) Houston Lighting & Power Company as a licensee and Project Manager for itself and the other owners has the overall responsibility for design, engineering, procurement, l

construction, operation and quality assurance activities.

Bechtel Energy Corporation and Westinghouse Electric Corporation have contractual responsibility to provide acceptable QA programs to HL&P. The contract provides HL&P the authority to audit and l nonitor BEC and Westinghouse performance to assure that the QA l programs provide for sufficient authority and organizational i

freedom to be effectively implemented. '

b) Bechtel Energy Corporation as the Architect / Engineer and Construction Manager provides HL&P with design, engineering, procurement, construction management and quality assurance

{ services, f c) Westinghouse Electric Corporation as the Nuclear Steam Supply J System (NSSS) supplier provides HL&P with the NSSS design, engineering, procurement, fabrication, and quality assurance l services.

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d) Ebasco Services Inc. as the Constructor shall provide HL&P with construction quality assurance and quality control services under the direction and as approved by the Construction Manager.

e) Consultants - HL&P utilizes the services of qualified consultants to assist in the performance of quality tasks.

Figure 2 illustrates how these companies interrelate with HL&P for the South Texas Project.

2.0 Quality Assurance Program 2.1 The HL&P Project Quality Assurance Program for the South Texas Project has been developed in accordance with the criteria of 10CFR50 Appendix B, ANSI N45.2 and Regulatory Guides as referenced herein, to provide programmatic direction on quality requirements for the prime contractors and subcontractors during design and construction.

2.2 The nuclear safety-related structures, systems and components covered by this program are listed in Section 3.2 of the FSAR. Westinghouse Electric Corporation provides quality assurance services for the items listed in Table 3.2.B-1 of the FSAR until delivery to the site. BEC and ESI provide quality assurance services for the items listed in Table 3.2.A-1 of the FSAR within the scope of their work. BEC provides quality assurance and quality control services for Westinghouse items (Table 3.2.B-1) upon receipt at the site until release for construction, after which ESI provides such services.

2.3 The HL&P Quality Assurance Program for the South Texas Project is described by the HL&P Project Quality Assurance Plan. The plan requires that written procedures, training and certification, issuance of specifications and drawings, and work and inspection planning be accomplished in advance of performing nuclear safety-related activities. HL&P Project Quality Assurance ensures through procedure reviews that this advance preparation is accomplished.

The Project Quality Assurance Plan for the South Texas Project has in the past been structured in accordance with the Regulatory Guides (RGs) and Industrial Standards that are addressed in the NRC publications " Guidance on QA Requirements During Design and Procurement Phase of Nuclear Power Plants," (The Gray Book) Revision 1, dated May 24, 1974 (WASH 1283) and " Guidance on QA Requirements During the Construction Phase of Nuclear Power Plants," (The Green Book) dated May 10, 1974 (WASH 1309). Presently the regulatory guides and standards listed on Table 1 are in effect for the South Texas Project.

2.4 The HL&P Plans and Procedures Manuals, which are used to implement the quality related activities for each major HL&P organization, are listed in Table 2. Verification that plans and procedures are properly implemented is accomplished by HL&P Quality Assurance through audits, surveillance, and regular management assessment of the Quality Assurance Program, 11

2.5 It is _the policy of HL&P, acting as a licensee and Project Manager for the other owners for the South Texas Project, to assure that the design, fabrication, construction, testing and operation of STP are in conformance with project specifications, procedures, codes and NRC regulations. It is the responsibility of each organization assigned to tlue STP to ensure that project procedural review methods include provisions to ensure that the requirements stated in this program description are incorporated into project procedures. The Project Quality Assurance Plan identifies activities and establishes requirements for procedures which identify, initiate and verify the resolution of nuclear safety-related quality problems. The implementing procedures call for the resolution of quality problems at the lowest possible authorized level. However, if a dispute is encountered in the resolution of a quality problem which cannot be resolved at lower levels, the Manager, Quality Assurance, presents the problem ultimately to the HL&P Executive Vice President, Nuclear Group, for resolution.

2.6 The HL&P Nuclear Training Department is responsible for conducting a (

quality oriented indoctrination program for new HL&P personnel who have quality-related functions. The EL&P Project Quality Assurance Plan requires that prior to performing activities affecting quality the personnel are trained, as necessary, in the applicable procedures.

The training provides a thorough understanding of the purpose, scope, policies, principles, and techniques of the specific procedures or instructions. When personnel perform special activities, a training and certification program is established and maintained. Refresher training is conducted as necessary to ensure that proficiency is maintained. Bechtel is required to establish a training program for Bechtel and administer the constructor's training program including refresher training, as necessary, to ensure proficiency is achieved and maintained. HL&P Quality Assurance audits and surveillances are performed to ensure compliance with these criteria.

2.7 The Project Quality assurance Manager is directly responsible for assuring effective implementation of the Quality Assurance program.

The qualifications for.this position are defined in Section 1.3.

2.8 The HL&P Project Quality Assurance Plan requires BEC to review and approve procedures which control nuclear safety-related construction activities. It is the responsibility of BEC's Project Quality Assurance to determine that the contractor's procedures require proper equipment, environment and other prerequisites to perform the associated activity. The implementation of these requirements is verified through audits and surveillance by HL&P, BEC and ESI Quality Assurance.

2.9 The results of the HL&P Quality Assurance audit and surveillance activities are presented in a periodic report to the HL&P Executive Vice President, Nuclear Group. Regular executive management review of these activities and the direct involvement of the HL&P Executive Vice President, Nuclear Group, assures that an objective program assessment of the South Texas Project Quality Assurance programs is being performed.

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HL&P Project Quality Assurance reviews and documents _ approval of the BEC Project Quality Program Manual (PQPM); and audits and surveillances are performed by HL&P Quality Assurance to ensure compliance with the BEC PQPM.

2.10 HL&P and BEC Project Quality Assurance will establish and document a program for transferring responsibilities and controls for quality-related activities from BEC to HL&P during phaseout of design / construction and plant turnover. This program will be implemented prior to preoperational testing. This program will be in accordance with and consistent with the requirements of this section and/or 17.2 of the FSAR.

2.11 HL&P is committed to maintaining the Quality Assurance Program Description as an effective and meaningful document to provide programmatic direction to HL&P and the prime contractors on the South Texas Project. When changes are proposed to the QAPD for HL&P or its prime contractors and those proposed changes reduce the commitments previously established in the QAPD, approval by the NRC will be obtained prior to implementation of the change (s).

2.12 When changes are made to the QAPD which alter the program for HL&P or its prime contractors and those changes do not reduce the commitments previously established in the QAPD, appropriate notification will be made to the NRC within 90 days of implementation.

3.0 Design Control HL&P has the overall responsibility for design and engineering of the South Texas Project and imposes the requirements of 10CFR50, Appendix B, Criterion III, Regulatory Guide 1.64 and ANSI N45.2.11 on the prime contractors and applicable subcontractors.

HL&P has assigned the authority to BEC and Westinghouse to perform the design, engineering and design verification.

HL&P, as appropriate, selects contractors / subcontractors to perform design related tasks. These tasks include but are not limited to the following:

New design Special design studies Design work outside the scope of prime contractors Changes to existing design performed by contractors no longer associated with the South Texas Project.

To be eligible to participate in design activities the contractor must be approved to assure he has the capability to perform the design or requested task in accordance with specified requirements. When a contractor has been selected, HL&P Manager, STP, or designee shall ensure that all appropriate design background information with which to perform the task is provided.

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HL&P Engineering performs reviews of selected elements of the completed design, design documents and specifications to ensure that contractual requirements are met.

The HL&P Manager, Engineering is responsibic for ensuring that project engineering activities are conducted in accordance with approved engineering procedures. The project engineering organization provides programmatic direction and overview of the engineering activities. The HL&P Project engineering activities are conducted in accordance with Project Engineering Procedures (PEP's) .

When HL&P has direct responsibility or assumes direct responsibility for conducting design activities, these activities will be conducted in accordance with the requirements of this section and/or the FSAR Section 17.2.3.

HL&P contractors are required to provide the following design control measures in their quality assurance programs:

A design control system is established to document the nethods of accomplishing and controlling essential design activities.

Design documents such as calculations, diagrams, specifications end drawings are prepared and records developed such that the final design is traceable to its sources.

Design activities, documents and interfaces are controlled to assure that applicable input such as design bases, regulatory requirements, codes and standards are incorporated into the final design.

Design input requirements, including design criteria, are documented and their selection reviewed and approved.

Design documents include an indication as to their importance to safety and shall specify the quality characteristics, including materials, parts, equipment and processes, that are essential to safety-related aspects of structures, systems, and components. Design documents also include, as appropriate, acceptance criteria for inspections and tests.

Design control measures are applied to safety-related items such as seismic, stress, thermal, hydraulic, radiation and accident analyses, as they apply to the development of design input or as they are used to analyze the design.

Safety-related designs, including Seismic Category I designs, are verified for adequacy and accuracy through independent objective review of design documents by individuals competent in the subject activity. This verification may include the use of alternate or simplified solution methods or qualification testing, as appropriate.

Design changes, including engineering, vendor and construction originated changes, are controlled in a manner commensurate with the control imposed on the original design.

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7 Document distribution is controlled such that all individuals using a design document or its results and/or conclusions for further design work can be notified if the document is revised or cancelled.

Design documentation includes evidence that design control requirements have been satisfied.

Errors and deficiencies in approved design documents, including design methods (such as computer codes), that could adversely affect safety-related structures, systems and components are documented; and action taken to assure that all errors and deficiencies are corrected.

Deviations from specified quality standards are identified and procedures are established to ensure their control.

An accurate definition of the quality classes, including systems designated as safety-related is provided.

HL&P Quality Assurance performs audits of HL&P, BEC and Westinghouse to ensure that design controls, requirements, specifications and documents are in accordance with the design control criteria.

In addition, HL&P Project Quality Assurance reviews selected quality / construction procedures to ensure that the quality requirements of the design specifications are incorporated. HL&P Project Quality Assurance also performs audits and surveillances to ensure that the work is accomplished in accordance with the design requirements and to ensure that field changes to the design are processed in accordance with the design control criteria.

4.0 Procurement Document Control To assure that nuclear safety-related items are purchased in a planned and controlled manner, the HL&P Project Quality Assurance Plan establishes basic requirements which are to be used by HL&P and prime contractors in preparing procurement procedures for the South Texas Project. BEC performs procurement activities for nuclear safety-related equipment, materials, and services, exclusive of the NSSS contract, which is performed by Westinghouse. BEC will approve any Ebasco nuclear safety-related procurements. BEC, and as appropriate, Ebasco verify through contract, vendor surveillance and audit that their suppliers comply with the established requirements.

When HL&P has direct responsibility or assumes direct responsibility for procurement activities, these activities will be conducted in accordance with the requirements of this section.

The basic requirements are:

Written procedures are established clearly delineating the sequence of actions to be accomplished in the preparation, review, approval, and control of procurement documents.

15 4

A review of the adequacy of quality requirements stated in procurement documents is performed by qualified personnel knowledgeable in the QA requirements. This review is to determine all quality requirements are correctly stated; they can be inspected and controlled; there are adequate acceptance and rejection criteria; and the procurement document has been prepared in accordance with QA Program requirements.

Documented evidence of the review and approval of procurement documents is provided and availabic for verification.

Procurement documents identify those quality e.ssurance requirements which must be complied with and described in the supplier's QA Program to meet 10CFR50, Appendix B; ANSI N45.2 and applicable ANSI standards and Regulatory Guides. This QA Program shall be reviewed for adequacy by qualified personnel knowledgeable in quality assurance.

Procurement documents contain or reference applicable design bases; technical requirements, including regulatory requirements; component and material identification; drawings; specifications; codes and industrial standards, including their revision status; tests and inspection requirements; and instructions for such activities as fabrication, cleaning, erecting, packaging, handling, shipping, storing and inspecting.

Procurement documents contain, as applicable, requirements which identify the documentation to be prepared, maintained, submitted and made available to the procuring agent for review and/or approval, such as drawings, specifications, procedures, inspection and test records, personnel and procedure qualifications and material and test reports.

Procurement documents contain, as required, provisions for extending applicable requirements to lower tier subcontractors and suppliers, including purchaser's access to facilities and records. (

Procurement documents contain provisions for control of nonconformances including 10CFR21 notification and for method of acceptance of the item or service.

Procurement documents contain the requirements for the retention, control, submittal and maintenance of records.

Procurement documents contain the procuring agency's right of access to Vendor's facilities and records for source inspection and audit.

Changes and/or revisions to procurement documents are subject to at least the same review and approval requirements as the original document.

Purchase documents for spare or replacement parts of safety-related structures, systems and components are reviewed for adequacy of quality requirements by qualified personnel knowledgeable in quality assurance. The review is to determine the adequacy of the quality assurance requirements and acceptance criteria relative to the original design.

16

The evaluation and selection of suppliers are determined by qualified personnel in accordance with written procedures acceptable to HL&P.

Procurement documents, records and changes thereto are collected, stored, maintained and retrievable in a systematic and controlled manner.

HL&P Engineering is responsible for review of selected BEC Procurement Specifications.

HL&P, BEC and, as appropriate, ESI Quality Assurance are responsible for performing audits and surveillances to verify that the requirements have been implemented and that they are effective.

5.0 Instructions, Procedures and Drawings The HL&P Project Quality Assurance Plan requires HL&P, the prime contractors and their suppliers to establish and implement a Quality Assurance Program which is in compliance with 10CFR50 Appendix B, ANSI N45.2 and applicable ANSI standards and Regulatory Guides. Each program is required to be effective in verifying that the defined activities are accomplished and documented in accordance with written procedures, instructions, and drawings and that they provide quantitative and qualitative acceptance criteria.

HL&P Project Quality Assurance reviews and approves the BEC South Texas Project Quality Assurance Program. To measure the effectiveness of the prime contractors' quality assurance programs, HL&P Project Quality Assurance has implemented a monitoring program consisting of audits and surveillances. HL&P Corporate Quality Assurance also audits HL&P Corporate organizations that perform functions for the South Texas Project, HL&P Project Quality Assurance and Westinghouse for compliance with their respective Quality Assurance Programs.

6.0 Document Control The HL&P Project Quality Assurance Plan and implementing procedures require that HL&P, the prime contractors and subcontractors implement a document control system for nuclear safety-related items for the South Texas Proj ec t. The established system ensures that design, engineering, procurement, fabrication, construction and QA/QC procedures, plans and changes thereto are reviewed and approved by procedurally authorized groups and that the documents are issued, maintained current and controlled by the use of controlled lists of document holders to ensure that superseded documents are replaced in a timely manner.

Measures are established and documented to control the issuance of documents, such as instructions, procedures and drawings, including changes thereto, which prescribe activities affecting quality. These measures assure that documents, including changes, are reviewed for technical adequacy and the inclusion of appropriate quality requirements, are approved for release by authorized personnel and are distributed to and used at the location where the prescribed activity is performed. Changes 17

to documents are reviewed and approved by the sane organizations that performed the original review and approval unless other organizations are specifically designated. The reviewing organizations have access to pertinent background information upon which to base their approval and shall have adequate understanding of the requirements and intent of the original document.

Those participating in an activity are made aware of and use proper and current instructions, procedures, drawings and engineering requirements for performing the activity. Participating organizations have procedures for control of the documents and changes thereto to preclude the possible use of outdated or inappropriate documents.

Document Control measures provide for:

Identification of individuals or organizations responsible for preparing, reviewing, approving and issuing docunents and revisions thereto; Identifying the proper documents to be used in performing the activity; Coordination and control of interface documents; Ascertaining that proper documents are being used; Establishing current and updated distribution lists; A listing identifying the current revision of instructions, procedures, specifications, drawings and procurement documents. The list is updated and distributed to predetermined responsible personnel.

HL&P, BEC and ESI Quality Assurance perform audits and surveillances to verify that document control systems are in place and effectively implemented.

7.0 Control of Purchased Material. Equipment and Services The HL&P Quality Assurance Plan and implementing procedures require that HL&P, prime contractors and subcontractors define and document the system and requirements for the control of nuclear safety-related purchased material, equipment and services.

Control and verification of supplier's activities during fabrication, inspection, testing and shipment of materials, equipment and components is planned and performed as early as possible, as required to assure conformance to the purchase order or contractual requirements. These procedures provide for:

Requiring the supplier to identify processes to be utilized in fulfilling procurement requirements.

Reviewing documents required to be submitted by the procurement requirements.

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Specifying the characteristics or processes to be witnessed, inspected or verified and accepted based upon the fabrication schedules; the method of surveillance and the extent of documentation required; and those responsible for implementing these procedures.

Audits, surveillance and/or inspections which verify that the supplier complies with the quality requirements of his QA program.

Control and verification of organizations performing services is accomplished by technical verification of data provided, surveillance and/or audit of the activity and review of objective evidence such as certifications, reports, etc.

The selection of suppliers is based on evaluation of their capability to provide items or services in accordance with the requirements of the procurement documents prior to award of contract.

Procurement source evaluation and selection measures are implemented by HL&P and BEC which provide for the identification of the organizational responsibilities for determining supplier capability.

Measures for evaluation and selection of procurement sources, and the results thereof, are documented and include one or more of (a) through (c) and also must include (d) below:

a. Evaluation of the supplier's history of providing an identical or similar product or service which performs satisfactorily in actual use. The supplier's history shall reflect current capability.

b. Supplier's current quality records supported by documented qualitative and quantitative information which can be objectively evaluated.

c. Supplier's technical and quality capability as determined by a direct evaluation of his facilities and personnel and the implementation of his approved quality assurance program,

d. Evaluation of bid documents including review for technical adequacy, quality assurance and commercial considerations.

Procurement of spare or replacement parts for safety-related structures, systems and components is subject to QA program controls, to codes and standards and to technical requirements at least equal to the invoked original technical requirements or any properly reviewed and approved revisions.

A Receipt inspection is planned and implemented to assure:

Timely inspection of items upon receipt.

The material, component or equipment is properly identified, and corresponds to the identification on the purchase document and receiving documentation.

Material, components, equipment and acceptance records satisfy the receiving inspection instructions prior to installation or use.

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, / '

Specified inspection, test and other records are accepted and available at the South Texas Project prior to installation or use where required unless otherwise authorized by conditional release.

Items accepted and released are identified as to their inspection status prior to forwarding them to a controlled storage area or releasing them for further work or installation.

Coordination of receipt inspection with vendor surveillance activities to verify the required vendor inspection has baea performed or a i waiver documanted. ,

Deficienciis if applicable have been resolved prior to shipment. l Supplier control and'use of Certificates of Conformance, when required by procurement documents, are evaluated by audits, vendor inspections or tests to ensure they are valid. The supplier's records shall include a description of those nonconformances from the procurement requirements dispositioned " accept as is" or " repair," including evidence of acceptance by the purchaser's engineering organization.

Site receiving inspection ensures that, for nuclear safety-related items received at the South Texas Project, there is accompanying documentation that indicates review and concurrence by the appropriate prime contractor or designee, that the item complies with established requirements or has an authorized waiver prior to shipment. BEC Quality Assurance audits and surveillances are performed to ensure compliance with these criteria.

HL&P Design Office Quality Assurance ensures by audits / surveillance of the AE/ construction manager's vendor surveillance function that source surveillance and inspection are performed in accordance with the quality assurance program. In addition, HL&P Quality Assurance performs audits and surveillances of activities commencing with receiving inspection at the site to ensure proper controls of purchased material and equipment are exercised and to ensure overall compliance.

8.0 Identification and Control of Material, Parts and Components The HL&P Project Quality Assurance Plan requires that prime contractors and suppliers establish written procedures for the identification and control of materials, parts and components including partially assembled components. Prime contractor's and supplier's procedures shall include the documented verification of correct identification of materials, components and subassemblies, and that the method of identification does not affect the function or quality of the item prior to release of the items for assembly or installation. These procedures must:

Establish controls to identify and control materials (including consumables), parts and components (including parti' ally fabricated subassemblies).

ProvidespecificidentificationandtraceabilityNontrolswhen required by codes, standards or specifications. /

20 i

Provide a method for identification and control of incorrect or defective items. This system includes verification and documentation prior to release for fabrication, assembling, shipping and installation.

BEC and ESI Quality Assurance verify that the above criteria are incorporated into the quality / construction procedures during the review / approval cycle and then follows up with audits and surveillances to verify compliance.

In addition, HL&P Quality Assurance performs audits and surveillances on prime contractors for evaluation of the conformance to identification and control criteria.

9.0 Control of Special Processes The HL&P Project Quality Assurance Plan requires that written procedures be established by prime contractors and subcontractors for the activities associated with all special processes. For special processes the qualification of personnel, procedures and equipment relating to specific codes, standards, specifications and contractual requirements shall be documented and maintained current.

Special Processes - special manufacturing processes, metallurgical, chemical, material cleaning, welding, plating and other processes where assurance of the process quality is dependent largely on the-inherent skill of the operator and cannot be assured by the inspection of articles alone.

Special processes for the South Texas Project include but are not limited to:

Welding Heat treating Cadwelding Nondestructive examination Chemical cleaning and flushing Coatings Organizational responsibilities are defined in procedures for qualification of special processes, equipment and personnel. These responsibilities will include the provision to assure that special processes are performed by qualified personnel using procedures qualified and approved in accordance with applicable codes, standards or other requirements.

21 4

- s Special processes are performed under controlled conditions by qualified personnel using procedures qualified and approved in accordance with applicable codes, standards or other requirements. For special processes not covered by existing codes or standards the specific equipment, personnel qualification and procedure qualification requirements are defined prior to application of the special' process.

Records are maintained for the qualification of procedures, equipment and personnel associated with special processes. Records are in sufficient detail to. clearly define the procedures, equipment or personnel being qualified; criteria or requireuents used for qualification;.and the individual approving the qualification.

HL&P Quality Assurance verifies that the special process control criteria 6 are met by BEC and ESI review and approval of special process procedures and their performance of audits and surveillances to ensure compliance.

HL&P will retain the capability with a quality control group to perfom, as directed by 'het PQAM, certain special process examinations' (NDE) during the inspection verification process. These examinations will be performed by personnel qualified in accordance with SNT-TC-1A-80 using cualified procedures approved by HL&P NDE Level III personnel. Instances of recommendations within SNT'-TC-1A-80 ('shoulds') will be considered 6-mandatory requirements ('shalls'). This exception will be reflected in approved implementing. procedures.

HL&P Quality Assuraa perfoms audits and surveillances of special process activities to ensure coapliance with all aspects of the Quality Assurance Program. / 5 '

10.0 Inspection The HL&P: Project Quality Assurance Plan requires the prime contractor for construction and subcontractors to establish and implement an inspection operation'whose activities are independent from the group performing the activities being inspected. The training, qualifications and

~ ,

certifications of inspectors include criteria from appropriate codes, standards and procedures. Inspector training shall be documented and kept current. Inspection activities relating to construction, fabrication, i

installation and testing are documented, kept current and identify all mandatory inspection hold and test points.and the criteria to be witnessed by authorized inspectors. Operations and it spections (including rework, replaced items) are performed in predetemined, documented sequences.

Deviations or deletions must be accomplished in accordance with approved and documented systems. Inspection procedures include all required inspection operations defined by the specificationa,, drawings, codes and s.tanda rd s . These procedures provide for the following: i

a. Identification of characteristics and activities to be inspected

b. A description of the method of inspection

c. Identification of the individuals or groups responsible for 'perfoming the inspection operation 22

[

i r a. s

d. Acceptance and rejection criteria

e. Identification of required procedures, drawings and specifications and revisions

f. Recording the identification of inspector and/or data recorder if applicable and the results of the inspection operation

g. Specifying necessary measuring and test cquipment including accuracy requirements and verification of calibration

h. Evaluation of inspection results Where direct inspections are impossible or disadvantageous, in-process monitoring is specified in the inspection procedures and both direct and in-process monitoring are used when control is inadequate without both.

All required procedures, specifications and drawings are made available to the inspectors prior to performing inspection. If mandatory inspection hold points are required beyond which work cannot proceed without the specific consent of the designated representative, the specific hold points will be indicated in appropriate documents. Inspection results are documented, evaluated and their acceptability determined by a responsible individual or group.

BEC and ESI Quality Assurance verify that inspection control criteria are complied with by review and approval of the inspection procedures and by audits and surveillances of inspections.

HL&P Quality Control may occasionally perform inspection verifications as deemed necessary by the Project Quality Assurance Manager.

HL&P, BEC and ESI Quality Assurance perform audits and surveillance of inspection activities to ensure compliance with all aspects of the quality assurance program.

The HL&P inspectors are trained and certified by a program conforning to ANSI N45.2.6 and as applicable, SNT-TC-1A-80. Instances of. recommendations within SNT-TC-1A-80 ('shoulds') will be considered mandatory requirements '

('shalls'). This exception will be reflected in approved implementing procedures.

11.0 Test control The HL&P Project Quality Assurance Plan requires that a test control l- program be developed and documented by the prime contractors and l contractors for tests that they are responsible for, which demonstrates that the facility performs in accordance with the South Texas Project l requirements and specifications. The training, certification of personnel, calibration and certification of test equipment, system or component status, environmental conditions, inspection hold points and configuration l

of the items to be tested are included in the procedures. Test results are documented, evaluated and the acceptance status determined by the

, authorized departments.

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• Test procedures or instructions provide for the following as required:

a. The inclusion of requirements and acceptance limits contained in applicable design and procurement documents

b. Instructions for performing the test

c. Test prerequisites such as calibrated instrumentation, adequate test equipment and instrumentation including their accuracy requirements, completeness of item to be tested, suitable and controlled environmental conditions and provisions for data collection and storage

d. Mandatory inspection hold points for witness by owner and the contractor's inspector (as required)

e. Acceptance and rejection criteria

f. Methods for documenting or recording test data and results g.

~

Provisions for assuring that ' test prerequisites have been met

h. Evaluation of results BEC and ESI Quality Assurance verify inclusion of adequate test control criteria by review and approval of test procedures. HL&P, BEC and ESI Quality Assurance perform audits and surveillance to verify that the controls are implemented and effective.

The test control activities are an example of a case in which HL&P Project Quality Assurance monitoring activities and the Operational Quality Assurance monitoring activities will interface and in some instances overlap. .HL&P Project Quality Assurance procedures will specifically define the responsibilities for this period.

12.0 Control of Measuring and Test Equipment The HL&P Project Quality Assurance Plan requires the establishment, documentation and implementation of a Measuring and Test Equipment Control System. The system is to include calibration techniques, accuracy, frequency and maintenance of all measuring instruments / test equipment used in the measuring, inspection and monitoring of nuclear safety-related items. Calibration and maintenance data shall be filed and kept current.

Calibration standards are to be traceable to nationally recognized standards where standards exist. If standards do not exist, the basis for calibration of the equipment shall be documented. If measuring or test equipment is found to be out of calibration, missing or lost, an investigation is required to be performed to determine the validity of the use of the instrument and whether measurements or tests are required to be reperformed. Reinspection when required will be documented.

Equipment is identified and traceable to the calibration test data and suitably marked to indicate calibration due date.

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Measuring'and~ test equipment is calibrated at specified intervals and based on the required accuracy, purpose, frequency of use, stability.

characteristics, and other conditions affecting the measurement.

Calibration of'this equipment is against standards that have an accuracy of at least four times the required accuracy of the equipment being calibrated, or when this'is not possible, have an accuracy that assures the equipment being calibrated will be within required tolerance and that the basis of acceptance is documented and authorized by responsible ~ management. t Calibrating standards will, when possible, have greater accuracy than standards being calibrated. Calibrating standards with the same accuracy may be used if they can be shown to be adequate for the requirements and the basis of acceptance is documented and authorized.by responsible management.

BEC and_ESI Quality Assurance review and approve calibration procedures to 4

ensure these criteria are incorporated. In addition, HL&P, BEC and ESI

_ Quality Assurance perform audits and surveillances to verify compliance.

i-

_In the conduct of its inspection verifications, as directed by the PQAM, HL&P Quality Control is req'uired to use measuring and test equipment of the appropriate accuracy level which is controlled by procedures meeting the requirements of this section.

13.0 Handling, Storage and Shipping The HL&P Project Quality Assurance Plan requires that for nuclear

+

safety-related items, written procedures be developed in accordance with design requirements, specifications and standards to control the cleaning, handling, storage,' packaging, shipping and preservation to preclude damage and deterioration by environmental conditions. The activities are to be i accomplished by appropriately trained and experienced personnel.

BEC and, as appropriate, ESI Quality Assurance review and approve quality construction procedures for receiving, handling, storage and cleaning to verify that the appropriate criteria of Regulatory Guide 1.38 and ANSI N45.2.2 are included. Periodic. audits and surveillances are conducted by HL&P, BEC and ESI Quality Assurance to verify compliance with the procedures.

14.0 Inspection, Test and Operating Status

'The HL&P Project Quality Assurance Plan requires that the prime contractor and construction contractors indicate the current inspection, test and j

operating status of nuclear safety-related items through the use of stamps, I

_ markings, tags or other suitable means. Procedures include the

. requirements for:

a. Controlling the application and removal of inspection status indicators such as tags, markings, labels and stamps

b. Documenting the status of nonconforming, inoperative, or malfunctioning structures, systems and components to prevent inadvertent use 25

c. Defining, controlling and documenting the use, application and removal (

gt of inspection tags, labels or markings which identify the status of inspections or tests performed and attest to the acceptability of the structure, system or component

d. Controlling the altering of the sequence of required tests, inspections and other operations.

BEC and ESI Quality Assurance reviews and approves these procedures and conduct periodic audits and surveillances to assure compliance. HL&P Quality Assurance also conducts audits and surveillances to assure compliance.

.15.0 Nonconforming Materials, Parts or Components The HL&P Project Quality Assurance Plan requires that HL&P maintains and the prime contractors' Quality Assurance Programs include a system which is documented by written procedures for the identification, segregation and disposition of nonconforming materials, parts and components. The procedures shall specify the preparation and handling of nonconformance documents, segregation requirements and which groups are responsible for review and disposition of the items. Documentation identifies the nonconforming item; describes the nonconformance, the disposition of the nonconformance and the inspection requirements; and includes signature approval of the disposition and final closecut. Nonconformances are l6 corrected or resolution determined prior to initiation of the preoperational test program on the item. Rework, repairs and rabsequent reinspection and tests are conducted in accordance with the original inspection and test requirements or accepted alternatives. These tests shall be performed in accordance with controlled procedures and contain mechanisms for providing information to the identifying group as to the disposition of the nonconformance. For NSSS items, the organization responsible for dispositioning of the nonconformance shall obtain 6 concurrence of the Westinghcuse Site Representative. HL&P Quality Assurance performs trend analysis of HL&P, BEC and ESI nonconformances.

Procedures are established by HL&P to report significant deficiencies during the design, construction and startup phase to HL&P' executive l6 management and to the Nuclear Regulatory Commission in accordance with 10CFR50.55(e) and 10CFR21 where applicable.

HL&P, BEC and ESI Quality Assurance perform periodic audits and surveillance to assure compliance.

16.0 Corrective Action The HL&P Project Quality Assurance Plan for the South Texas Project requires that a system be established and docunented by HL&P and the prime contractors which defines the responsibilities, authorities and methods used by specific groups involved in the evaluatien of nonconformances and trending to determine the need for corrective action. The system includes measures to identify the cause of significant conditions adverse to quality, measures to ensure that the root causes are corrected, and 26

( .

measures'to' ensure that timely action is taken. Follow-up is performed to

-ensure'the effectiveness of corrective action and that appropriate levels of management are-informed of the results. HL&P performs trend analysis of

'HL&P, BEC and ESI identified deficiencies to determine the need for 6 corrective action. Specific documents to be trended are identified in approved procedures. HL&P, BEC and ESI Quality Assurance perform audits and surveillances to assure compliance.

17.0 Quality Assurance Records The HL&P Project Quality Assurance Plan requires that a Quality Assurance record system be' developed by HL&P and the prime contractors for the South Texas Project. The record system provides evidence that activities relating to quality are defined,-implemented and that inspection and test

-documents contain a description of the type of observation, reference to nonconformance reports, evidence relating to status of observation, date and inspector identification.

Quality records shall include reviews, audits, reports, specifications, nonconformance reports, analyses, personnel and equipment qualification procedures.

.The HL&P Project Quality Assurance Plan requires that HL&P and prime contractors establish requirements to ensure that records generated during the design, procurement and construction are identifiable, retrievable and meet the requirements of 10CFR50, Appendix B and ANS1 N45.2.9 as endorsed by-Regulatory Guide 1.88.

As an alternative to the ANSI N45.2.9 storage requirements, records may be maintained for the South Texas Project in a two-hour rated fire resistant file room meeting NFPA No. 232-1975 including the following provisions: (

An-automatic fire suppression system and an early warning fire detection system is utilized.

Records are stored in fully enclosed metal cabinets Smoking and eating / drinking a.e prohibited within the records storage facility Work not directly associated with record storage or retrieval is prohibited within the records storage facility Ventilation, temperature and humidity control equipment is controlled where they penetrate fire barriers bounding the storage facility.

HL&P, BEC and ESl Quality Assurance perform audits and surveillances to assure compliance.

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f~

18.0 Audits The HL&P Project Quality Assurance Plan establishes the requirement that HL&P, prime contractors and subcontractors develop, document and implement audit activities which are structured in accordance with the requirements of ANSI N45.2.12 for the South Texas Project. As required by the ANS1 standard, results of audits are presented for review to management of the audited organization and, in the case of HL&P performed audits the HL&P Executive Vice President, Nuclear Croup. Where indicated HL&P performs follow-up action.

HL&P has the ultimate responsibility for the auditing of quality related activities on the project. HL&P Corporate audits are performed primarily on the HL&P Project Quality Assurance group, HL&P corporate organizations providing services to the project and Westinghouse. HL&P Project Quality Assurance is primarily responsibt for audits of the Engineer / Construction Manager, constructor, subcontractors and the HL&P Project team organizations. Cases may arise in which audits may be required by either the. Corporate or Project audit groups in the primary area of responsibility of the other group.

The prime contractors and subcontractors perform quality related audits of internal activities and suppliers of material, components and systems.

HL&P, BEC and ESI perform supplemental audits when required, based on such factors as significant changes in the Quality Assurance Program, results of trending programs or investigations into the root causes of problems.

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TABLE 1 ANSI STANDARD AND REGULATORY GUIDE COMPLIANCE The STP Quality Assurance Program complies with the following ANSI Standards and associated Regulatory Guides except as noted:

STANDARD TITLE ANSI N45.2-1971 Quality Assurance Program Require-R.G.1.28 (Rev. O, 6/72) ments for Nuclear Facilities ANSI N45.2.1-1973 Cleaning of Fluid Systems and R.G. 1.37 (Rev. O, 3/73) Associated Components During Con-(see Notes 8 through 10) struction Phase of Nuclear Power Plants ANSI N45.2.2-1972 Package, Shipping, Receiving, R.G. 1.38 (Rev. O, 3/73) Storage and Handling of Items of (see Notes 11 through 16) Nuclear Power Plants ANSI N45.2.3-1973 Housekeeping During the Con-R.G. 1.39 (Rev. O, 3/73) struction Phase of Nuclear Power (see Notes 17 and 18) Plants ANSI N45.2.4-1972 Installation, Inspection'and R.G. 1.30 (Rev. O, 8/72) Testing Requirements for (see Notes 19 and 20) Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations ANSI N45.2.5-1974 Supplementary Quality Assurance (see Notes 1 and 2) 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 Qualifications of Inspection.

R.G. 1.58 (Rev. O, 8/73) Examination and Testing Personnel As modified by positions C.5, for the Construction Phase of C.6, C.7, C.8 and C.10 of Nuclear Power Plants Rev. 1 (see Note 33)

ANSI N45.2.8-1975 Supplementary Quality Assurance Reg. 1.116 (6/76) Requirements for Installation, (see Notes 21 through 23) Inspection and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants Tabic l-1

- , _ . . . v. c-. . . , . . - ..-, .--_ -- _ . _ - , ___ _ -

, , , _ . , , 7

TABLE 1 ANSI STANDARD AND REGULATORY GUIDE COMPLIANCE (Continued)

ANSI N45.2.9-1974 Requirements for Collection, R.G. 1.88 (Rev. 2, 10/76) Storage and Maintenance of Quality (see Notes 24 through 26) Assurance Records for Nuclear Power Plants ANSI N45.2.10-1973 Quality Assurance Terms and R.G. 1,74 (Rev. O, 2/74) Definitions ANSI N45.2.ll-1974* Quality Assurance Requirements for R.G.1.64 (Rev. 2, 6/76) the Design of Nuclear Power Plants (see Notes 3 through 7)  ;

ANSI N45.2.12-1977 Requirements for Auditing of R.G. 1.144 (Rev. 1, 9/80) Quality Assurance Programs for (see Note 32) Nuclear Power Plants ANSI N45.2.13-1976 Quality Assurance Requirements for R.G.1.123 (10/76) Control of Procurement of Items and (see Notes 27 through 31) Services for Nuclear Power Plants ANSI N45.2.23-1978 Qualification of Quality Assurance R.G. 1.146 (Rev. O, 8/80) Program Audit Personnel for Nuclear Power Plants Exception Notes

1. ANSI N45.2.5-1974, Section 4.8, states " Pumped concrete must be sampled from the pump line discharge." In lieu of this statement, in-process strength samples of pumped concrete are taken at the delivery point.

Correlation tests of air content, slump, and temperature are performed to verify these plastic properties of the concrete at the placement point in accordance with the following frequency requirements:

a. A minimum of 2 correlation tests are performed for each pumped placement exceeding 200 cu. yds.

b. Otherwise, a minimum of 2 correlation tests per week are performed when any individual pumped placement during a week requires deliver; of more than one truckload of concrete.

c. During a week when a pumped placement exceeding 200 cu. yds. is made, the correlation tests performed on that placement will satisfy the weekly requirement for performing two correlation tests as specified in Item B above.

When any of the specified limits and tolerances on loss of air content, slump, or temperature are exceeded at the placement point, correlation tests setween the delivery point and placement point will be accomplished 1

for each 100 cu. yds. of concrete placed as long as limits and tolerances Table 1-2

TABLE 1 ANSI STANDARD AND REGULATORY CUIDE COMPLIANCE (Continued) are exceeded. If two consecutive tests are out of tolerance, corrective action will be implemented to adjust the limits for the concrete entering the pump intake so that no concrete from the subsequent trucks will enter

.the pump intake as long as the tolerances are exceeded.

" Correlation Tests," " Delivery Point," and "Placerent Point" are as defined in ANSI N45.2.5-1978, Section 1.4

2. -Samples and frequency for cadweld testing is in accordance with ACI-359/ASME Section III, Division 2, issued for trial use and comment in

~1973, including addenda 1 through 6, (see Sections 3.8.1.6.3 and 3.8.3.6.3 of the STP Final Safety Analysis Report).

• The following interpretations (Notes 3 through 7) of ANS1 N45.2.11-1974 and Regulatory Guide 1.64, Rev. 2-6/76, apply to HL&P, their contractors and consultants working under HL&P's. Quality Program.

3. .Section 3.1, Design Input Requirements, General. This section implies that Lall necessary design input (as listed in Section 3.2) should be available prior to the start of a design activity. In practice, certain design activities are initiated before the firm input requirements are available.

(For example, foundation designs prepared based on preliminary information or equipment sizes and mounting, embedded conduit run based on preliminary estimates of circuit requirements, etc.) The design phase QA program will be structured to ensure that all necessary design input is available before completion of final design of the work affected by the input, and that final design input is available for use in verification of the final design.

4 Section 4.1, Design Process, General. Paragraph 3 implies traceability back from final design to the source of design input. In practice, a literal interpretation of this is not always possible. For example, final design drawings do not identify the related calculations. This paragraph will be interpreted to mean that it shall be possible to relate the criteria used and analyses performed to the final design documents and that t record files will permit location of analyses supporting specific design output documents.

5. Section 4.2, Design Analyses. This section implies a requirement for

!- retention of all calculations. In principle, it is considered good practice for the responsible engineer or engineering organization to retain i all final calculations, and this will be done for all manual calculations l- covered by the program. However, for computer programs only documentation of the design input, assumptions made in the analyses, results obtained, and evidence of verification will be retained since permanent retention of all versions of all computer programs is not considered practical or

_ necessary if sufficient information is available for a competent individual l to verify the results using the input and assumptions.

i

! Table 1-3

TABLE 1 ANSI STANDARD AND REGULATORY CUIDE COMPLIANCE (continued)

6. Section 10, Records. In-process documentation, relating to checking and coordination of drawings (for example, check and coordination prints) or copies of marked-up specifications used to solicit comments shall be retained until the drawing or specification is approved and issued for use outside of Engineering. Such in-process documents will be available for review / audit until the document is approved, but may be discarded once the document has been approved. In the first sentence of the second paragraph the phrase " final design documents" shall mean those documents which are the latest revision that has been issued for use.

7. Regulatory Position, Section C-2: If, in an exceptional circumstance, the originators' immediate supervisor is the only technically qualified individual available, the design verification or checking will be conducted by the supervisor with the following provisions:

a. The other requirements of Regulatory Guide 1.64 will be met,

b. The justification will be individually documented and approved by the next level of supervision.

c. Quality Assurance audits will include review of the frequency and effectiveness of the use of the immediate supervisor to assure that this provision is used only in exceptional circumstances.

8. Section 2.1, Planning. The required planning is frequently performed on a generic basis for application to many installations on one or more projects. This results in standard procedures or plans for installation and inspection and testing which meet the requirements of the standard.

Individual plans for each item or system are not normally prepared unless the work operations are unique. However, standard procedures or plans will be reviewed for applicability in each case. Installation plans or procedures are also limited in scope to those actions or activities which are essential to maintain or achieve required quality. This is consistent with Section II, Paragraphs 2 and 3 of ANSI N45.2-1971 which provides for examination, measurement, or testing to assure quality or indirect control by monitoring of processing methods. However, final cleaning or flushing l activities will be performed in accordance with procedures specific to the system.

9. Section 4, Preinstallation Cleanliness. This section states, " Items should i

not be delivered to the point of installation site sooner than necessary unless the installed location is considered a better storage area." As an alternate to this requirement, items may be delivered to the installation site sooner than absolutely necessary when determined to be advantageous for other considerations, for example, reduced handling or easier access, i thereby reducing susceptibility to handling damage. In all such cases, equipment stored in place will be protected in accordance with Section 5 of ANSI N45.2.1.

l Table 1-4 9

L

TABLE 1 ANSI STANDARD AND REGULATORY GUIDE COMPLIANCE (continued)

10. Section 3.1.2, HL&P interprets the lighting level of 100 footcandles to be guidance. It is HL&P's normal practice that the lighting level for determining " metal clean" of accessible surfaces of piping and components is determined by the inspector. Typically he uses a standard two-cell flashlight supplemented by other lighting as he deems necessary.

11. Section 2.7, Classification of Items. The four-level classification system may not be used explicitly. However, the specific requirements for each classification as specified in the standard will be applied to the items suggested in each classification and for similar items.

Classification differing from Section 2.7 will be considered acceptable provided no degradation is assured; for example, electric motors designed for outside service may be stored in Level C area rather than a Level B.

12. Section 6.2, Storage Areas. Paragraph 6.2.1 requires control and limited access to storage areas. In lieu of and to amplify this paragraph, the following will be applied:

Access to storage areas for Levels A, B and C will be controlled by the individual (s) responsible for material storage. While the above areas will 6

be posted to limit access, other positive controls (other than that for the overall site area) or guards may not be provided. Level D areas will be posted with the storage level designation only.

13. Section 5.5, Correction of Nonconformances. This section provides for

" rework" and "use as is" dispositions for nonconforming items. As an alternate, the " repair" disposition (as defined in ANSI N45.2.10-1973) will also be used.

14. Section 6.2.4, Storage of Food and Associated Items. Controlled areas, within storage areas, will be established for the storage of food, drink, and salt tablets. These areas will be controlled through normal supervision and inspection.

15. In Section 8, the control of documentation and records shall be in accordance with Section 17 of this Program Description.

16. Appendix A 3.4.2, Inert Cas Blankets. There may be cases involving large or complex shapes for which an inert or dry air purge flow is provided rather than a static gas blanket in order to provide adequate protection due to difficulty of providing a leakproof barrier. In these cases a positive pressure purge flow may be utilized as an alternative to the leakproof barrier.

Table 1-5

TABLE 1 ANSI STANDARD AND REGULATORY GUIDE COMPLIANCE (continued)

17. Section 2.1, Planning. The required planning is frequently performed on a generic basis for application to many installations on one or more proj ec ts. This results in standard procedures or plans for installation and inspection and testing which meet the requirements of the standard.

Individual plans for each item or system are not normally prepared unless the work operations are unique. However, standard procedures or plans will be reviewed for applicability in each case. Installation plans or procedures are also limited in scope to those actions or activities which are essential to maintain or achieve required quality.

18. Alternative equivalent zone designations and requirements may be utilized to cover those situations not included in the subject standard; for example, situations in which shoe covers and/or coveralls are required but material accountability is not. In addition, zones might be combined into the next more restrictive category in order to reduce total number of zones.

19. Section 1.2, Applicability. The Standard is applied to the items and systems identified in Paragraph 1.1.1 and to additional systems depending on the nature and scope of the work to be performed and the importance of the item or service involved.

20. Section 2.1, Planning. The required planning is frequently performed on a generic basis for application to many installations on one or more projects. This results in standard procedures or plans for installation and inspection and testing which meet the requirements of the standard.

Individual plans for each item or system are not normally prepared unless the work operations are unique. However, standard procedures or plans will be reviewed for applicability in each case. Installation plans or procedures are also limited in scope to those actions or activities which are essential to maintain or achieve required quality.

21. Section 1.1, Scope. The term "important items" will be interpreted to apply to those activities or quality attributes of an item or service that could affect a nuclear safety-related characteristic. For example, if a barrier is required for leakage control, but serves no structural function, the leaktight characteristic would be considered "important," but appearance, dimensional requirements, and structural features would not necessarily be considered important; or if a pump casing is required for coolant boundary integrity, but the pump does not have to operate to provide for nuclear safety, those attributes which affect its operation would not be considered important from the standpoint of nuclear safety.

Section 2.1, Planning. The required planning is frequently performed on a generic basis for application to many installations on one or more projects. This results in standard procedures or plans for installation and inspection and testing which meet the requirements of the standard.

Table 1-6

TABLE 1 ANSI STANDARD AND REGULATORY GUIDE COMPLIANCE (continued)

Individual plans for each item or system are not normally prepared unless the work operations are unique. However, standard procedures or plans will be reviewed for applicability in each case. Installation plans or procedures are also limited in scope to those actions or activities which are essential to maintain or achieve required quality.

22. Section 3.3, Process and Procedures. The terms " installation site,"

" installation area," and " site" used in this standard shall be interpreted as follows:

a. " Installation site" or " site" will be interpreted the same as

" construction site." When applied to documents, these may be at the central office or work area document control station.

b. Installation area - Immediate proximity of location where work is to be performed.

23. Section 3.5(e), Site Conditions. This requirement will be applied only if subsequent correction of adjacent nonconformances could damage the item being installed.

Section 4.6, Care of Items. HL&P retains the authority and is the

" Responsible Organization" for temporary usage of equipment or facilities unless specific (i.e. on a case by case basis) or general authority is granted in writing to the Construction Manager's organization.

24. Section 1.4, Definitions. Quality Assurance Records - A document is considered completed when it has finished full processing and has been issued for use in design, procurement, construction, or manufacturing.

25. Section 1.4, Definitions. Authenticated Records - Those records which are clearly identified as a statement by the individual or organization holding responsibility. Handwritten signatures are not required if.the document or printout is clearly identified as a statement by the reporting individual oc organization.

26. For Appendix A, an installation shall be considered to be in an "as constructed" condition if it is installed within the tolerances established by Project Engineering indicated in the design output documents.

27. Section C.3 of the Regulatory Guide - A corrective action system may, depending upon complexity and/or importance to safety of the item or service provided, be imposed upon the supplier. When a corrective action system is imposed on a supplier, the applicable elements of Section 9.0 of the standard will be included and its implementation will be verified.

28. Section C.4 of the Regulatory Guide - Applicable information concerning the method (s) of acceptance of an item or service will be made available to receiving inspection personnel.

Table 1-7

TABLE 1 ANSI STANDARD AND REGULATORY GUIDE COMPLIANCE (continued)

29. Section 4.2.a of the Standard - When evaluation of a supplier is based solely on historical supplier data, these data will primarily include HL&P's or a prime contractor's records that have been accumulated in connection with previous procurement actions. Data that includes experience of users of identical or similar products of the prospective supplier and product operating experience will be used if they become available; however, such data are normally available only to those involved in plant operations.

30. Section 10.2.d. of the Standard - The requirements of this section are interpreted as follows: The person attesting to a certificate shall be an authorized and responsible employee of the supplier and shall be identified by the supplier.

31. HL&P's position relative to ANSI N45.2.13-1976, Section 10.2.f.,

Verification of the Validity of Supplier Certificates and the Effectiveness of the Certification System, is as follows: The verification of the validity of supplier certificates and the effectiveness of the certification system are accomplished as an integral part of the total supplier control and product acceptance program, and no separate HL&P system exists that addresses itself solely to such verification. The degree of verification required will depend upon the type of item or service and their safety importance. The means of verification may include source witness / hold points, source audits, and document reviews; independent inspections at the time of material receipt; user tests on selected commodities, such as concrete components; and tests after installation on selected components and systems. All of these means verify whether or not a supplier has fulfilled procurement document requirements and whether or not a certification system is effective.

32. ANSI N45.2.12-1977, Section 4.5.1 states, "The audited organization shall provide a follow-up report stating the corrective action taken and the date corrective action was completed." This implies that the auditad organization must provide the auditing organization with written notification detailing what corrective action was taken and when the corrective action was completed.

In actual practice, the audited organization will provide the auditing organization with documented corrective action including the date when the corrective action will be completed. The auditing organization will evaluate the corrective action response to determine if corrective action verification is necessary. If verification is necessary, the corrective action verification will be performed after the scheduled completion date and the results of the verification will be documented.

33. HL&P Vendor Surveillance shall comply with ANSI N45.2.6-1978 and R. G. 1.58 (Rev. 1, 9/80) only. Exception is taken to regulatory position C.1 for personnel who (1) approve preoperational, startup, and operational test Table 1-8

TABLE 1 ANSI STANDARD AND REGULATORY CUIDE COMPLIANCE (continued) results 'and (2) direct or supervise the conduct of individual preoperational, startup, and operational tests. These personnel will be qualified under the guidelines of ANSI N45.2.6-1978, rather than R. G. 1.8.

Table 1-9

TABLE 2 HL&P MANUALS USED TO IMPLEMENT THE QUALITY ASSURANCE PROGRAM Project Quality Assurance Plan Project Specific Quality Assurance Procedures Manual Support Division Quality Assurance Procedures Manual Project Engineering Procedures Manual Project Site Procedures Manual Project Licensing Procedures Manual Project Procurement Procedures Manual Project Management Procedures Manual Records Management Systems Procedures Manual 4

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FIGURE 2 LirJES OF COMMUNICATIOr1 If L&P and DECAVESTINGilOUSE (COrJ TRACTORSI

PART B BECHTEL ENERGY CORPORATION QUALITY ASSURANCE PROGRAM DESCRIPTION SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION QUALITY ASSURANCE DURING DESIGN AND CONSTRUCTION REVISION 6 DATE March 30, 1984

BECHTEL QUALETY ASSURAtlCE PROGRA!! DESCRIPT80:1 FOR SOUTH TEXAS PROJECT IllTRODUCTI0il The Bechtel Quality Assurance Progran Description used by the Bechtel Energy Corporation for the South Texas Project is described in the flRC approved Bechtel Topical Report BQ-TOP-1, Rev. 3A, Bechtel Quality Assurance Program for Nuclear Power Plants and the modifications and additions described below.

s Throughout the Program Description (Part B) where the Program Description states Themal Power Organization, it shall be construed as synonymous with Bechtel Power 'lanagement.

Throughout the Program Description (Part B) where Construction Quality Control is stated, it shall be construed that Project Quality Control reports to the Project Quality Assurance ;1anager.

SCOPE OF SERVICES Bechtel Energy Corporation is responsible for Engineering, Procurement and Construction llanagement activities at the South Texas Project. This activity includes receiving, storage, maintenance, receiving inspection and Quality Assurance functions. Bechtel Construction llanagement is responsible for management of the construction and quality assurance / quality control activities of the Constructor / Contractor (s). Construction !!anagement consists of planning, scheduling, monitoring and evaluating the Constructor /

Contractor (s) construction and quality assurance / quality control activities.

The construction, field engineering, and quality control activities defined in the topical will be the responsibility of the Constructor / Contractor (s). The Constructor / Contractor (s) will be responsible for submitting to 3echtel, for approval, a quality program which is consistent and compatible with the applicable sections of Bechtel's Topical Report.

The following is a description of the South Texas Project modifications to meet the scope of the project and client requirenents.

Introduction Page 4 -

item #5 Division Quality Policies - Guidance defining requirements and responsibilities I for accomplishing Quality Program functions which may be nodified, deleted by, l6 or supplemented with project documents to meet specific project /ouner require- I ments and the scope of the project. l Revision 6 Page 1 of 10

Section 1 - Organization o 1.5.4 Division Construction Managers of Division Construction provide technical and administrative direction to the Construction Department personnel. !!anagers of Division Construction are assisted by Construction ilanagers and Chief Construction Engineers, where assigned. Construction llanagers are responsible for the management and technical direction of assigned projects, and for assuring that construction projects are provided with appropriate personnel and are following prescribed division practices and procedures for conduct of construction activities.

o 1.6.1 Project Quality Assurance The project quality assurance program is directed by the Project Quality Assurance flanager who is responsible to assure that Quality Assurance or Quality Control actions listed below are accomplished in accordance with the requirements of the project:

1) Coordinate the functions of the project quality program, and serve as the focal point for project communication on natters relating to this program.

2) Coordinate project quality-related activities of Engineering, Procurement, Project Administration, Records Management System, and Construction. .'

3) Audit and surveillance of project quality-related functions and adherence to procedures. Advise management of the status of program implementation. Conduct prescheduled project audits and supplemental audits directed by the Project Quality Assurance 11anager.

4) Review Supplier and Constructor / Contractor (s) quality assurance program requirements in procurement documents, conditional releases of nonconfoming items at the construction site, and completed quality verification records packages prior to turnover to the client.

5) Concur with evaluation of recommended supplier's quality assurance program, in accordance with subsection 7.1. Evaluate supplier's Quality Programs for jobsite originated safety related purchases when determined necessary by the Project Quality Assurance llanager.

6) Take stopwork action when warranted.

7) Identify quality problems, initiate documented action leading to a solution, and verify implementation of solutions.

8) Review project plans and schedules for quality-related activities to assure timely and effective implementation of the quality assurance functions for the project.

Revision 6 Page 2 of 10

9) Provide periodic reports to the Division Quality Assurance llanager and Project 11anager evaluating the status of the project quality assurance program and advising of any problems requiring special attention.

10) Coordinate quality assurance functions within the project and with groups outside the division, such as 71&QS and Procurement Supplier Quality.

11) Assure that quality assurance related procedures and manuals prepared by or used for the project meet project quality progran requirements and initiate revisions when necessary.

12) Review, prior to use, Procurement Quality Surveillance Inspection plans and Quality Control instructions for clarity and the existence of the infomation described in Sections 7 and 10. In addition, evaluate the adequacy of selected plans and instructions by perfoming an in-depth review of:

a. Accuracy of translation of drawing and specification requirements.

b. Basis for determining inspection level and sequence.

c. Adequacy of inspection method.

This review provides assurance that the total quality program requirements inclusions are complete. Reviews of generic plans and instructions can be perfomed on a generic basis. In that case, the PQA:1 only verifies that the review of the generic plan or instructions has been perfomed.

13) Review and approve Constructor / Contractor (s) quality prograns.

14) Prepare quality assurance descriptions in Safety Analysis Reports.

15) Review ilonconfornance Reports and other quality problem related documents to determine trends, identify significant deficiencies, and recommend appropriate corrective action.

The field quality assurance program includes the capability to perfom:

o Receiving inspection of permanent plant uaterial and equipment.

o itaintenance and storage inspection of permanent plant equipment and material in Bechtel's custody, o Review of receiving and 3echtel QC docunentation.

o Surveillance inspection of work performed by Constructor /

Contractor (s). This inspection supplements the quality programs of the Constructor / Contractor (s) who have responsibility for their work and their quality verification.

Revision 6 Page 3 of 10

Surveillance inspection includes either selected physical inspection at prescribed hold points and observation or witness of inspections performed by the Constructor / Contractor (s):

o Reviewing quality control documentation.

o Reviewing Bechtel and/or Constructor / Contractor (s) quality documentation.

o Providing technical direction to testing laboratories and inspection Contractors.

o Reviewing supplier quality verification document packages for completeness and traceability to the item (s).

o Identifying quality problems, initiating action leading to solutions, and verifying implementation of solutions.

o Reviewing Constructor / Contractor (s) quality verification documents.

o Reinspection of Constructor / Contractor (s) completed work may be imposed as deemed necessary.

1.6.2 Project Engineering

3) Prepare specifications for Supplier and Constructor / Contractor (s)

Quality Assurance Program.

5) Review and approve the design changes and approve nonconformance dispositions.

6) Review drawings, procedures, test data, manuals and reports submitted to Engineering by suppliers and Constructor /

Contractor (s).

8) Provide support to Construction management relative to storage and maintenance of permanent plant equipaent.

1.6.3 Project Construction itanagement A Manager of Construction is assigned to each nuclear plant project involving construction or construction management assignment, and is responsible for the project field construction performance. The Manager of Construction is responsible for assuring that construction activities are performed in accordance with the design requirements as established by project engineering and other applicable requirements.

The project construction management organization is shown in Figure 11.

The Constructor / Contractor (s) are assigned first-level responsibility for the control of the quality of their work. Their performance is coordinated and monitored by the Bechtel field organization. The Bechtel Quality Assurance organization performs documented audits and surveillances and has the capability to perform surveillance inspection.

Revision 6 Page 4 of 10

In cases where the Constructor / Contractor (s) are responsible for quality verification inspection or other quality assurance functions, the contract documents incorporate the requirements for the Constructor / Contractor (s) quality assurance program. Constructor / Contractor (s) quality assurance and quality control personnel are required to have the appropriate authority, organizational freedom, and independence within their own organization.

Constructor / Contractor (s) program requirements are specified by incorporation of the requirements of Reg. Guide 1.28 (6/7/72) or the ASME Boiler and Pressure Vessel Code,Section III, as appropriate. In the event that the Constructor / Contractor (s) is unable to provide an acceptable program, Bechtel may assume quality verification inspection responsibilities or these may be contracted to another organization.

1.6.4 Project Procurement The Project Procurement Manager receives technical and administration direction from the ilanager, Division Procurement, LAPD through the llanager, Division Procurement, Houston and project direction from the designee Project Manager.

Section 3 - Design Control Page 30 - first paragraph:

In the case of proposed changes to the original design initiated at the construction site, the design changes shall be reviewed, accepted and documented by Bechtel Project Engineering. Acceptance of design changes by Bechtel Project Engineering is required prior to implementation. For design changes proposed by suppliers, acceptance of the design change by Project Engineering is required prior to shipaent of tne item to the jobsite.

- third paragraph:

Certain other detail design work described below may be performed by Bechtel Engineering. This work is not subject to design verification or checking described above. The nature and scope will vary with each Engineering discipline. Civil Engineering design affecting safety-related structures, systems, and components is limited to functions such as the design of form details for concrete placement and design of temporary supports for reinforcing and i

embedded steel. 91 thin Instrumentation and Electrical Engineering,

, these design functions include the preparation of isometric drawings l of electrical conduit and instrumentation tubing and the detailing and selection of hangers and supports. Within Piping Engineering, these design functions are normally linited to the preparation of isometric drawings and detailing of small (two-inch nominal and under) piping using sizes, material, routing and support criteria l provided by Engineering specifications. Sizing, separation, j instrument location, support criteria and standard designs are j developed by Bechtel Engineering within the program described above.

l l Revision 6 Page 5 of 10 i

- fourth paragraph:

Suppliers are not allowed to change Bechtel design requirements or Bechtel reviewed supplier design documents without obtaining approval by Bechtel Project Engineering. Construction site changes to engineering design are documented by means of change notices or change requests which require authorization by Project Engineering. Significant or unique changes are authorized individually; Project Engineering may give written authorization in the form of specifications or other instructions to field organizations to make routine changes. Field organizations have the authority to approve changes to design details in cases where the original design details were prepared by that field organization.

Section 4 - Procurement Document Control Page 32 - paragraph 3, item 1) through item 8) Page 33:

Replace the paragraph beginning "...The following describes the sequence of steps. .." with the following paragraph:

Appropriate project procedures provide details to accomplish the administrative actions in processing procurement documents in the design office and at the jobsite. .

Section 5 - Instructions, Procedures, and Drawings Page 34 - sixth paragraph:

Field organizations prepare other procedures when engineering documents require amplification to perfonn various discipline activities associated with fabrication, cleaning, erection, installation, test, repair, modification, etc., of items.

Section 6 - Document Control Page 35 - sixtn paragraph:

Changes made to approved design documents by Project Engineering or proposed by field organizations are reviewed and approved by Project Engineering in accordance with established procedures which provide that changes are reviewed in the same manner as the original issue.

Section 7 - Control of Purchased Material, Equipment & Services Page 37 item number 2):

2) Determination by Engineering and Quality Assurance that the supplier or Constructor / Contractor (s) quality 3rogram is capable of meeting the specified requirements. This may )e based on evaluations by Procurement .

Supplier Quality for manufacturing suppliers or Quality Assurance for  !

jobsite Constructor / Contractor (s), and field procurements. i l

Revision 6 Page 6 of 10

Section 14 - Inspection, Test, and Operating Status Page 50 - fourth paragraph:

Project Engineering and supervisory personnel are authorized to apply and recove identifying tags, markings, and labels on equipment in accordance with approved procedures. Quality Control personnel are the only ones authorized to direct application and removal of inspection status indicators. Bechtel, in cooperatitn with the plant owners' operating personnel, establishes a tagging procedure which delineates those authorized for applying and removing tags during preoperational testing phases.

Section 15 - Nonconforming Items Page 51 - paragraph 2 items 2, 3 and 5):

- paragraph 2 item 4 - Delete

2) Detemine interim disposition by field organizations.

3) Have Project Engineering approve dispositions.

5) Provide conditional release of nonconfaming itens upon approval of Quality Assurance.

- last paragraph:

The authority for disposition of nonconforming items follous the rules for approval of design changes described in Section 3 of this report.

Quality Assurance review! Sspositions to determine that; they are fully responsive to the conditions described in the nonconfomance report.

Quality Control is responsible for verification of rework and repair dispositions, applying inspection processes at least equivalent to that applied to the original work. " Repair" or "use as is" dispositions on nonconfomances to procurement requirements at a supplier's plant must be accepted by Project Engineering.

Page 52 - second paragraph: <

Monconfoming items discovered at final inspection which cannot be corrected by rework or completion of originally prescribed processing are required to be identified, tagged, and/or segregated. Discrepancies in work not yet submitted for final inspection which can be corrected by rework or completion of work processes are not considered to ba nonconformances. For con;truction work perfomed by Bechtel, no further work can proceed on the nonconforming itou until an approved disposition is implemented, unless a conditional release is approved by Quality Assurance. Suppliers, and Constructor / Contractor (s), as required by procurement docu.nents, apply similar procedures involving tneir quality assurance functions. Dechtel Procureinent Supplier Quality Representatives are instructed to withhold release for shipment until all nonconformances have been resolved or an interia disposition is approved by Project Engineering.

Revision 5 Page 7 of 10

The following is a modification of Appendix "A" of the topical which describes Bechtel's position on Regulatory Guide and ANSI standards:

o Reg. Guide 1.58 Rev. O, 8/73 Plus positions C.5, C.6, C.7, ANSI N45.2.6, 1973 C.8, and C.10 of Rev.1 o Reg. Guide 1.144 Rev. 1, 9/80 ANSI N45.2.12, 1977 Exception listed below o Reg. Guide 1.146 Rev. O, 8/30 ANSI N45.2.23,1978 Full Compliance - No exceptions Exception ANSI N45.2.12-1977, Section 4.5.1 states, "The audited organization shall provide a follow-up report statin corrective action was completed."gThis the implies corrective thataction taken and the audited the date organization must provide the auditing organization with written notification detailing what corrective action was taken and when the corrective action was completed.

In actual practice, the audited organization will provide the auditing organization with documented corrective action including the date when the corrective action will be completed. The auditing organization will evaluate the corrective action response to detennine if corrective action verification is necessary. If verification is necessary, the corrective action verification will be performed after the scheduled completion date and the result of the verification will be documented.

Appendix A Page A-4 -

item #2 -

second paragraph

" Access to storage areas for Levels A, B, and C will be controlled (

by the individual (s) responsible for material storage. While the above areas will be posted to limit access, other positive controls .6 (other than that for the overall site area) or guards may not be provided. Level D areas will be posted with the storage level designation only."

Revision 6 Page 8 of 10 9

t s

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Attachment A is a modified Table I to the topical which describes Bechtel's Quality Program Documents.

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Attachment A BECHTEL QUALITY PROGRAM DOCUMENTS ORIGINATING REVIEW F OR OA POLICY AUTMORl214G COCUMENT AUTMORITY Au0 pm0GR AM Rioulp tME wfS AprR0 vat CONTEwTS e SECMTEL QUALITY MANAGER OA-SPC" PREslotNT AhD POLititS AND PRott00RES FOR ASSUR ANCE MANUAL. C4L1tet OlVISt0 4 APPROPRIATE OVER ALL IECMTEL PROGRAM ASRE NUCLEAR QUALITY AS84)RANCE AUTMORIZIO CODE APPLICABLE TO ASME WORK C0tEP04E4TS (80Alb MANAGER 14SPtCTION AGENCY AWAE 111)

GUAlffY PROJE CT N/A Olvttl04 rR0tt0URES FOR C0tOUCTl4G ASSURANCE SUALiff ASSURANCE QUALITY ASSURANCE PROJECT QUALITY ASSURANCE PROCEDURES MARAGER MANAGER ACTIVITits (4Gitt EntnG OtslG44TED OfvlS 04 QU AttTY M AN AGE R DivlS104 01F1417104 0F RESPO451SILITit$

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Revision 6

Bechtel Power Corporation Engineers-Constructors 1574o Shady Grove Ros:1 Gaithersburg. Marylano 20760 301-258 3000 October 6, 1930 Mr. W. P. Haass, Chief Quality Assurance Branch U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Organizational Changes J QAS-80-301; File: 7.10

Dear Mr. Haass:

As directed in your August 15, 1977, acceptance letter of the Bechtel QA Topical Report, BQ-TOP-1, Rev. 2A, and subsequent to discussions with members of your staff, the following description of organizational changes within the Bechtel Power Corporation are submitted for your infomation.

~

The Ann Arbor area office of the San Francisco Power Division has been desig-

- nated the Ann Arbor Power Division in the Themal Power Organization. Like the other power divisions Ann Arbor will handle engineering and construc-tion work along with all the supporting activities associated with power division work.

Attached to this letter are organization charts showing the Ann Arbor Power Division's reporting relationship in the Bechtel Organization and a chart showing the reporting relationships within the Ann Arbor Power Division.

Additionally, an organi:ation change has been made in the Themal Power management group. The reporting relationship for the quality assurance func-tion within the Thermal Power Management function has been transferred from the Vice President, Planning and Quality Assurance to the Vice President responsible for the Procurement. Engineering, and Construction, Project Operations and Services functions. Themal Power Management.' These changes will be shown on a revised Themal Power Organization chart ' Figure 3 of BQ-TOP-1, Revision 3, which will be forwarded at a later date.

If you have any questions regarding these changes, please call me en (301) 258-3776.

Very truly yours,

=

i J. M. Amaral, Manager j

Division Quality Assurance JMA:vpw Attachment ,

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1 Mr. R. M. Collins i p Vice President, TPO .

Bechtel Power Corperation P.O. Box 3965 E San Francisco, CA 94119

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SUBJECT:

NRC ACCEPTANCE OF REVIiED BECHTEL TOPICAL REPORT ON QL%LITY ASSURANCE E 1 By letter of December 13, 1979. Bechtel Power Corporation submitted proposed Revis -

3 to its Topical Report, BQ-TOP-1. The submittal reflects proposed changes result [

" from our review of your March 17,1978; April 27,1979; and July 18, 1979 quality -

assurance topical report submittals and various clarifying discussions between our

- staffs. The revisions reflect organizational and programatic changes in the Bech i quality assurance effort.

E We find that the December 19, 1579 submittal of the topical report, as changed by - -

E Bechtel letter of October C,1930, describes an acceptable quality assurance progri I ' for the design, procurement, and construction acti'vities within the Bechtel Power Corporation scope of work for nuclear power plants. Therefore, your topical repor: -

= on quality assurance is acceptable, and you may implement it upon issuance. For tl P Bechtel Power Corporation quality assurance program description, applicants need or -

1 reference this topical report in Chapter 17 of licer.se applications. We do not pla "

b .

to rereview this topical report unless changes occur. .

E Should regulatory criteria or regulations change such that conclusions about this r topical report are invalidated, we will notify you. You will be given the cppor- '

m tunity to revise and resubmit it should you so desire. Programatic changes by Bechtel Power Corporation to this topical report are to be submitted to the NRC for

{ review prior to implementation. Organizational changes are to be submitted no late .

s than 30 days after announcement.

E Please replace our letter of August 19, 1977 shown in your topical, report with this letter, change the revision number to 3A, change the date to October 1930, and forw

" 36 copies to the NRC. Your submittal should point out.the changes by use of a blac

' bar in the margin where a change is made, and the revision number should be acjacen to the bar. In your transmittal letter, indicate to which plant (s) this report wil

[ be applicable.

I s

Should you have any questions regarding our review or if we can provide assistance, h

please contact Mr. Jack Spraul or me on (301) 492-7741.

- Sincer21y,

~

"0 ' Walter P. Haass, Chief .

Quality Assurance Branch g Division of Engineering E

Enclosure:

g_ Topical Reoort Evaluation

=_.

E

r

. Page 2 of 3 Tonical Report Evaluation Report Number: BQ-TOP-1, Revision 3A Report

Title:

Quality Assurance Program for Nuclear Power Plants Revision Date: October 1980 Originating Organization: Bechtel Power Corporation Reviewed By: Quality Assurance Branch .

SUMMARY

OF TOPICAL REPORT lopical report BQ-TOP-1, Revision 3A describes the quality assurance program

. which the Bechtel Power Corporation applies to those design, procurement, and construction activities involving safety-related structures, systems, and com-ponents of nuclear power plants within the Bechtel scope of work. BQ-TOP-1, Revision 3A commits Bechtel to comply with the requirements of Appendix B to 10 CFR Part 50 and to comply with the regulatory position provided by the NRC (with some exceptions which have been found acceptable by the NRC) in the following Regulatory Guides:

Reculatory Guide Date 1.28 6/72 1.30 8/72 l.37 3/73 1.38 3/73 1.39 3/73 1.58 8/73 1.64 6/76 1.74 2/74 1.88 ' 10/76 _.

1.94 4/76 1.116 6/76 1.123 10/76 ANSI N45.2.12 (D-3, R-4) 2/74 Bechtel Power Corporation has provided for our evaluation a detailed description of organizations and groups involved in implementing activities required by the quality assurance program and a delineation of duties, responsibilities, and authority of those organizations involved in the quality assurance program.

BQ-TOP-1, Revision 3A describes the measures used to carry out the Bechtel Power Corporation quality assurance program, and it describes how the applicable require-ments of Appendix B to 10 CFR Part.50 will be satisfied by the administration and implementation of these reasures.

SUMMARY

OF REGULATORY EVALUATION We have evaluated the quality assurance program and the organizations responsible for quality assurance functions as described in BQ-TOP-1, Ravision 3A. We find that quality assurance policy and direction originate at an ecceptably high

Page 3 of 3 2-management level and are effectively comunicated to other parts of the organiza-tion. Those perfoming quality assurance functions have responsibility and authority commensurate with their duties in implementing the quality assurance program. We also find that measures have been established, to be implemented by written procedures and instructions, which address each of the criteria of Appendix B in an acceptable manner.

Based on our review and evaluation of BQ-TOP-1, Revision 3A, we conclude that:

1. The organizations and persons perfoming quality assurance functions within Bechtel Power Corporation have the required independence and authority to effectively implement the quality assurance program without undue influence from those directly responsible for costs and schedules, and

2. The Bechtel Power Corporation quality assurance program contains the require-  :

ments and controls which, when properly implemented, comply with the require-ments of Appendix B to 10 CFR Part 50 and the applicable regulatory guides and standards contained in Chapter 17 of the NRC Standard Review Plan (NUREG-75/087 Revision 0).

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~ ~ ~

Page 1 of 3 Bechtel Power Corporation Ermirwers-Connru: tors 15740 Shady Grove Road Gaithersbur3. Maryland 20760 301- 258-3000 Decerter 2,1980 Mr. W. P. Haass, Chief Quality Assurance Branch U. S. Nuclear Regulatory Corr.ission Washington, DC 20555

Dear Mr. Naass:

Organizational Changes QAS-80-335 File: 7.10 Ref: Letter, J. M. Araral to. W. P. Haass dated October 6,1980, same subject As directed in your October 16, 1930 acceptance letter of the Bechtel QA Topical Report, BQ-TOP-1, Rev. 3A the following description of organiza-tional changes within the Bechtel Power Corporation (BPC) are subr::itted for your information.

As indicated in the referenced letter, the Thenral Power Organization of Bechtel Power Corporation has undergone a change with the addition of a Vice President over the Corporate Staff functions. We have since reinstated the position of the Manager of Quality Assurance. Therral Power Organization, as shown on the enclosed organization chart.

The prirrary responsibilities of the Manager of QA, TPO will be:

o Developrent and approval of TP0 quality policies o Provide guidance on quality policies to the BPC Divisions o Coordination of quality functions of organizations external to BPC, e.g., M&QS and Procurement

- o Evaluate the effectiveness of the divisions' Quality Assurance Programs and report the adequacy of it.plementation to Bechtel Power Corporation ranagement.

e G

_ . . _ _ . __ . . . .__ _ _ . __ _ _ ._ ]

Page 2 of 3 Bechtel Power Corporation Decerber 2,1980 Mr. W. P. Haass QAS-80-385

~

The aforementioned responsibilities were assigned previously, as indicated in Rev. 3A of BQ-TOP-1, to the Vice President, Planning and Quality Assurance - TPO.

The referenced letter discussed an organizational change within TP0 and comitted to forwarding an organizational chart showing these changes.

The enclosed chart satisfies that comitment also. The organizational changes described in this letter, as well as the referenced letter, will be reflected in the Bechtel QA Topical Report, BQ-TOP-1, whenever it is revised in the future. .

Should you have any questions regarding these changes, please call me at (301) 258-3776.

Very truly yours, J. M. Araral, Manager of Quality Assurance - TPO JPA/dkh Enclosure - Organization Chart bec: R. M. Collins C. W. Dick J. C. Kansal J. Milandin R. L. Patterson e

9

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1. c ,k UNITED STATES

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DE: 1 71930 .

t Mr. J. M. Amaral Manager of Quality Assurance, TP0 ,

Bechtel Power Corporation *

. 15740 Shady Grove Road Gaithersburg, MD 20760

SUBJECT:

CHANGES TO BQ-TOP-1 REVISION 3A We have reviewed your letter dated December 2,1980 concerning an organizational change within the Bechtel Power Corporation which affects the Bechtel Nuclear QA program. The program is described in Revision 3A of the Bechtel QA topical report BQ-TOP-1, "Bechtel Quality Assurance Program for Nuclear Power Plants," October 1930. Your letter indicates that the position of the Manager of Quality Assurance, Thermal Power Organization has been reinstated, reporting to the Operations Vice President. Your letter also lists the primary responsibilities of the Manager of Quality Assurance and provides an updated organization chart.

We believe the change should not reduce the effectiveness of Bechtel's QA program, and we find the change acceptable. We note your conraitment to incorporate the change into the topical report at the time of the next revision.

Sincerely, A / MW Walter P. Haass, Chief

j. Quality Assurance Branch Division of Engineering ,

l L ..

Page 1 of 3 Bechtel Power Corporation Engineers-Constructors Fstty Bead Street San Francrs:3. Cel.f omia ,-

usit Avaress: P o Bc 3ES. San Fran: sco CA 94119 June 3, 1982 Mr. W. P. Haass, Chief Quality Assurance Branch U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Organizational Changes

Dear Mr. Haass:

As directed by your October 1980 acceptance letter of Bechtel QA Topical Report BQ-TOP-1, Rev. 3A, and to confirm our dis-cussion on May 12, 1982, the following description of changes within the Procurament organization are submitted for your information.

As can be seen in the attached organization chart dated March 23, 1982, the Central Procurement organization has been restructured to include the equipment operations (formerly combined with field procurement) and information services groups. The supplier quality and expediting groups have been removed from Central Procurement and, along with the new com-modity advisors group, have been combined to form a new organi-zation identified as Supplier Performance. This restructuring of the Procurement organization was done to improve our effec-tiveness with suppliers; improve the interface between the supplier quality, expediting, and commodity advisors groups; and improve the quality of the Supplier Information System.

The Manager of Supplier Performance is responsible for management of the expediting, supplier quality, and commodity advisors groups, which provide functional guidance and assistance to all Bechtel divisions and projects. H2 is responsible for the formulatica of policies, methods, and standards to ensure con-sistency with overall Bechtel objectives. He is the primary Bechtel contact with vendors when generic or major vendor performance problems occur.

e e

Page 2 of 3 Bechtel Power Corporation Mr. Haass June 3, 1982 Page 2 Programmatically, the topical report is unchanged. The duties of the Manager of Supplier Quality remain unchanged.

The responsibility for control of supplier quality is lef t with the supplier quality manager in each of the divisions.

Project supplier quality supervisors who report to the respective division supplier quality managers are responsible for direction of project procurement surveillance inspection activities. Their duties include the preparation of shop inspection plans; direction and assignments to supplier quality representatives; initiation and coordination of supplier surveys and audits; and approval of surveillance inspection reports.

Mr. S. I. Heisler has been appointed Manager of Supplief Performance.

If you have any questions regarding the above, please call me on (415)768-7900. ,

Very truly yours,

. M. Amaral Manager of Quality Assurance Bechtel Power Corporation JMA/m:n Attachment 0

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$$181532 J.M. Amaral Manager of Quality Assurance Bechtel Power Corporation P.O. Box 3965 San Francisco, California 94119

Dear Mr. Amaral:

_In your letter dated June 3,1982. vo,u_,d_escribe _changts_itLEtcht=1's_,

J an F ra n ci s c oJ ro c u reme n t o rg a n i z a ti on_ht.lufdng_.t.ht_es t a b l ih.P" + cf a new oroanization identified as "Suppli_er P_erfo_qnqq." You indicate the reorganization was done to improve the Sechtel-supplier interface.

We have reviewed the procurement organizatien presented in your June 3.

1982 letter and find it_ acceptable.

Sin ce rely .

'f. g .h r An n' alter P. aass, Chief Quality Assurance Branch Division of Engineering a .

O r

• s PART C EBASCO. SERVICES INCORPORATED QUALITY ASSURANCE PROGRAM DESCRIPTION SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION QUALITY-ASSURANCE DURING DESIGN AND CONSTRUCTION REVISION 6 DATE March 30, 1984 i

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,,- e- , _ . , . . . . . .#.. .- , . . . _ . - , _ , . , , , . . - , _ , , _ . . ,__.r , _ , , , , . _ . , , ..y , _ _ , , ..-,_,v,._ _ _ _ _ , , . .y.m m., .r.-.._--

EBASCO NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL ETR-1001 e00 O'*:0 coa HOUSTON LIGHTING & POWER COMPANY ELECTRIC GENERATING STATION UNITS 1 & 2 1

UNITED STATES NUCLEAR REGULATORY COMMISSION W AsHINGToN. D. C. 20b55 ggy 12 B75 Mr. Leonard F. C. Reichle Vice President Ebasco Services Incorporated Two Rector Street New York, New York 10006

Dear Mr. Reichle:

We have reviewed and evaluated the Ebasco Services Incorporated (EBASCO)

Nuclear Quality Assurance Program Manual (Ebasco Report ETR-1001, Revision 0, March 14, 1975). We find that it describes an acceptable Quality Assurance Program for the design, procurement, and construction activities which are within the Ebasco scope of work for nuclear power plants.

For the Ebasco Quality Assurance Program, applicants need only reference this Topical Report in Section 17 of license applications. We do not intend to repeat our review of this Topical Report when it is referenced in an application.

Should regulatory criteria or regulations change such that our conclusions about this Topical Report are invalidated, we will notify you. You will be given the opportunity to revise and resubmit it should you so desire.

Please include a copy of this letter and our evaluation in each of the reports and resubmit 70 copies to the NRC.

Sincerely, Richard H. Vollmer, Chief Quality Assurance Branch Division of Reactor Licensing

Enclosure:

NRC Topical Report Evaluation of Ebasco Report EIR-1001,Rev. O, 3/14/ 75 qotuilO4 Q b 46

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TOPICAL REPORT EVALUATION Report Number: ETR-1001, Rev. O, Nonproprietary Report

Title:

Ebasco Nuclear Quality Assurance Program Report Date: March 14, 1975 Originating Organization: Ebasco Services Incorporated Reviewed By: Quality Assurance Branch

SUMMARY

OF TOPICAL REPORT Topical Report ETR-1001, Rev. O describes the Quality Assurance (QA)

Program which the Ebasco Services Incorporated (Ebasco) applies to those design, procurement, and construction activities involving safety related structures, systems, and components of nuclear power plants within the Ebasco scope of work. ETR-1001, Rev. O co=mits Ebasco to comply with the requirements of Appendix B to 10 CFR Part 50 and to follow the QA guidance provided by the NRC in:

1. " Guidance on Quality Assurance Requirements During Design and Procurement Phase of Nuclear Power Plants," WASH 1283, Rev. 1, May 24, 1974, and

2. " Guidance on Quality Assurance Requirements During the Construction Phase of Nuclear Power Plants," RASH 1309, May 10,1974.

Ebasco has provided for our evaluation a detailed organizational description of those individuals and groups involved in carrying out activities required by the QA Program and a delineation of duties, responsibilities, and authority of those organizational elements involved in the QA Program. ETR-1001, Rev. O contains a description of the measures used to carry out the Ebasco QA Program activities and describes how applicable requirements of Appendix B will be satisfied by the administration and implementation of these measures.

SU.TiARY OF REGULATORY EVALUATION We have evaluated the QA Program and the organizations responsible for QA functions as described in ETR-1001, Rev. O. We find that QA policy and direction originate at an acceptably high management level and are ef fectively co=municated to other parts of the organization.

Those performing QA functions have responsibility and authority commensurate with their duties in implementing the QA Program. We also find that measures have been establishec, to be implemented by written procedures and instructions, which address each of the criteria of Appendix B and demonstrate conformance with each criterion.

Based on our review and evaluation of ETR-1001, Rev. O we conclude that:

1. The organizations and persons performing QA functions within Ebasco have the required independence and authority to effectively carry out the QA Program without reservation or undue influence from those directly

2- ,

responsible for costs and schedules, and

2. The Ebasco QA Program contains the necessary requirements, procedures, and controls to demonstrate that quality-related activities will be conducted in accordance with the requirements of Appendix B to 10 CFR Part 50.

REGULATORY POSITION It is the staff's position that the Ebasco Nuclear Quality Assurance Program Manual (Ebasco Report ETR-1001, Revision 0, March 14,1975) is acceptable for use in the design,' procurement, and corstruction of nuclear power plants. The Topical Report can be ref erenced by report number in Section 17 of future Safety Analysis Reports.

d

l

/ .. ~ ..';

UNITED STATES

[%[j NUCLEAR REGULATORY COMMISSION WASMtNGTON. D C. 20555 7 ,

qg %uk;.9 u

1. ,j

.....- MAY I 71982 Mr. B. E. Tenzer, Director Materials Engineering and Quality Assurance Ebasco Services , Inc.

Two Rector Street New York, NY 10006 Deer Mr. Tenzer:

SUBJECT:

ACCEPTANCE OF REVISION 11 TO EB ASCO QUALITY ASSURANCE PROGRAM TOPICAL REPORT We have reviewed and evaluated Revision 11 to the Ebasco Topical Report, ETR-1001, submitted with your letter of February 22, 1982 and as modified in your letter of May 3,1982. Revision 11 reflects quality assurance pro-gram and editorial changes.

We find that this report describes a quality assurance program that meets the criteria in Appendix B to 10 CFR Part 50 and is therefore acceptable.

You may implement it upon issuance. For the Ebasco quality assurance pro-gram, you need only reference this topical report in Chapter 17 of license applications. We do not intend to repeat our review of this topical report when i.t is referenced in an application.

Should regulatory criteria or regulations change such that our conclusions about this topical report are invalidated, we will notify you. You will be given the opportunity to revise and resubmit it should you so desire. Pro-grammatic changes by Ebasco to this topical report are to be submitted to NRC for review prior to implementation. Organizational changes are to be submitted no later than 30 days after announcement.

Please include a copy of this letter in the report, renumber the report ETR-1001, Rev.11A, and transmit 40 copies to the NRC. In your transmit-tal letter, please indicate to which plants Revision 11A will be applicable.

Should you have any questions regarding our review or if we can provide assistance, please contact Mr. John Gilray on (301) 492-4730.

Sincerely, f //

alter P. Haass, Chief Quality Assurance Branch Division of Engineering

l l-ESASCO SERVICES INCORPORATED EBATO Two World Trade Center. New York. N Y.10048 STATEMENT OF AUTHORITY The management of Ebasco Services Incorporated recognizes the necessity for a comprehensive Quality Program for Nuclear Power Plants. Ebasco Company Procedure No.'N-21 establishes the basic organization, assigns authorities and responsibility for implementing the Quality Program, and establishes the requirement for a corporate Quality Assurance Manual.

Accordingly, this Manual represents Ebasco Quality Program policy. In this respect, it is to be used as a standard by personnel in all Ebasco Organizational Units.

The primary responsibility for overall implementation and administration of the Ebasco Quality Assurance Program rests with the Vice President Materials Engineering and Quality Assurance as delegated to him by the Executive Vice President - Operations. The Quality Program Committee has been established under the auspices of the Exectuve Vice President -

Operations, consisting of representatives of designated Vice Presidents.

The committee is permanent and its Chairman shall be the Vice President Materials Engineering and Quality Assurance.

fLos~w U Wallace III President April 24, 1981

• l

_ _ _ _ _ - _ _ _ . _ _ _ _ _ - _ _ _ ------------__]

EBASCO SERVICES IutgaPOR4TED FOREWORD

. This manual represents Ebasco Quality Program policy and requ,irements for the design and construction of neulear .poLwer stations under the jurisdiction or in accordance with the requirements of the United States Nuclear Regulatory Commission. In this respect, it is to be used as a standard by all Ebasco personnel.

The manual has been prepared by the Quality Assurance Engineering Department and approved by the Ebasco Quality Program Committee. The manual reflects official Ebasco policy and has been designed to meet the requirements of the United States Nuclear Regulatory Commission document 10 CFR 50, Appendix B (18 Quality Assurance Criteria), and American National Standards Institute docment N45.2, entitled Quality Assurance Program Requirements for Nuclear Power Plants.

The Ebasco Nuclear Quality Assurance Program Manual has been designed to meet the requirements of 10 CFR 50.34(7) for a quality assurance program descrip-tion. It will be incorporated into applicable portions of safety analysis reports by reference as provided by 10 CFR 50.32.

The primary responsibility for overall implementation and administration of the Eoasco Quality Program rests with the Vice President Materials Engineering and Quality Assurance as delegated to him by the Executive Vice President -

Operations. The Chief Quality Assurance Engineer is assigned the responsibi-lity and authority to enforce Ebasco Quality Program requirements and has the unqualified support of Corporate Management. His decisions may not be over-ridden by personnel in any division or department, except with the written consent of the Vice President Materials Engineering and Quality Assurance or the Executive Vice President - Operations.

The Chief Quality Assurance Engineer shall staff each project to the extent necessary to perform Quality Assurance tasks directly and audit departments other than his own in their perfocmance of tasks related to Quality Assurance.

The Chief Quality Assurance Engineer has the authority to require immediate correction of any non-conforming activity or condition to comply with Ebasco Quality Program requirements, or if necessary, to stop work until suitable corrective action has been taken or a satisfactory resolution reached.

l Recommendations or questions regarding the Quality Program or the manual shall be referred to the Chief Quality Assurance Engineer, who shall be responsible for resolution. The Ebasco Quality Program Committee is rer-ponsible for and has the authority to make and approve procedures for any changes to this manual.

l EB.lS C O SERYlCES

=c e a rca in o The Quality Program Coordinator, designated by the Chairman of the Ebasco Quality Program Committee, functions as the Committee's secretary and publishes to all manual holders an Updating Status Memorandum for the manual at least every six months. The Memorandum summarizes changes made to the manual during the preceding period. The Quality Program Coordinator also maintains a listing of individual pages in the manual which indicates the curcent issue or revision date of each page. Information from this list can be obtained by addressing inquiries to the Quality Program Coordi-nator at the Ebasco New York Office.

The manual is assigned by the Quality Program Coordinator to individuals as required for their exclusive use. However, it remains the property of Ebasco Services Incorporated and shall be returned upon request. It is loaned in confidence and upon the condition that neither it nor the infor-mation contained in it will be reproduced, copied or disclosed in whole or in part. The material herein is copyrighted and protected by the copyright laws.

Should any circumstance arise under which a holder no longer requires the manual for the specific purporse for which it was assigned, it shall be returned promptly to the Quality Program Coordinator. Nuclear Quality Assurance manuals shall not be transferred or loaned to any other indivi-dual, position, firm or corporation without the written euthorization of the Chairman of the Ebasco Quality Program Committee. The Quality Program Coordinator shall be informed promptly of any change in the mailing address of a manual holder.

Manual holders are responsible to maintain their copies in updated condition, including the proper insertion of new or revised sections as furnished and the destruction of all cancelled or superseded sections. Sections shall not be removed from manuals except as directed for revision or cancellation.

GP . E. 2C,w

<7 B E Tenzer Vice President Materials Engineering and Quality Assurance April 27, 1981

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h sios.s tsypi io.s Pact 1 or 2 ESA5CO SERVICE 5 NUCLEAR QUAUTY ASSURANCE PROGRAM MANUAL SECTION INCORPORATED HOUSTON UGHTING AND POWER COMPANY SOUTH TEXA5 PROJECT N ELECTRIC GENERATING STATION UNIT 51 & 2

> aEvisio 4 E

I

< INTRODUCTION & SCOPE OF SERVICES o*TE 3/26/84

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Introduction The Ebasco Quality Assurance Program to be used on the South Texas Project is described in this Manual. It is based on the Ebasco Nuclear Quality Assurance lR6 Program Manual, ETR-1001 Rev.11, which was accepted by the United States l Nuclear Regulatory Commission on May 17, 1982. ETR-1001 Rev. 11 represents Ebasco Quality Program policy and requirements for the design and construction of nuclear power stations under the jurisdiction of or in accordance with the requirements of the United States Nuclear Regulatory Ccmmission. In this respect, it is the standard which is used by all Ebasco personnel. Ebasco's lR6 commitment to Quality is confirmed in the " Statement of Authority" signed by the President of Eb'asco Services Incorporated.

This Manual, as modified for the South Texas Project, is assigned by the l Quality Program Coordinator via the Manager Site Quelity Assurance to l individuals as required for their exclusive use. However, it remains the l property of Ebasco Services Incorporated and shall be returned upon request. l It is loaned in confidence and upon the condition that neither it nor the lR6 information contained in it will be reproduced, copied, or disclosed in whole I or in part, except for its incorporation into applicable portions of Houston l I.ighting & Power Company safety analysis reports. Ihe material herein is I copyrighted and protected by the copyright laws. l Scope of Services Ebasco Services Incorporated's scope of services for the South Texas Project includes construction services as well as quality assurance and quality lR6 control appropriate to those services. The design and procurement sections of l ETR-1001 Rev.11 r.re not applicable to Ebasco Services Incorporated's scope of services. Those responsibilities are rassigned to the Client or his designee.

The remainder of ETR-1001 Rev.11 has been modified as appropriate for the l South Texas Project and approved in accordance with applicable Company l Procedures. l l

Although Section QA-III-1, " Instructions, Procedures, and Drawings," contains lR6 certain requirements relating to control of drawings, the Client or his I designee is the Architect / Engineer and will issue all design drawings. Ebasco l may, however, from time to time, initiate drawings.which are not design I documents, when authorized by specifications issued by the Client or his I designee. l

._ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ - . - _ _ _ _ - - - _ _ _ _ - - - _ . _ _ _ _ _ _ _ _ . . _ _J

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.i ... ist ,.i o.n .c 2 o, 2 ESASCO SERVICES HUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCORPORATED HOU$ TON LIGHTING AND POWER COMPANY SOUTH TEXA5 PROJECT

{ ELECTRIC GENERATING STATION UNITS 1 & 2 4 nay, 3/26/84 l

.. d......... INTRODUCTION & SCOPE OF SERVICES

(

Ebacco performs quality trend analysis on a corporate basis as described in l Sections QA-I-1, QA-III-6, QA-III-7, and QA-III-9 of this Manual. This trend I analysis is a corporate-wide compilation and analysis of quality data l generated by the Quality Assurance organization in conjunction with the lR6 various projects on which Ebasco is perf orming nuclear safety-related l activities and is not related to the specific South Texas Project trend I analysis program. The ' Client is responsible for the performance of quality l trend analysis specific to the South Texas Project. l

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4 sios.s isres so.or pace.1 or 2 EBASCO SERVICE 5 HUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCORPORATED HOL1 TON LIGHTING AteD POWER COMPANY ,

SOUTH TEXA5 PROJECT 1 I

> ELECTRIC GENERATING STATION UNITS 1 & 2 RE vi sio N 7

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v TABLE OF CONTENTS o*TE 3/26/84 PART I - General Section Title Rev. No. Date QA-I-l Quality Assurance Program ,

5 3/26/84 QA-I-2 OrganizationandResponsibilities 5 3/26/84 QA-I-3 Personnel Indoctrination and Training Program in Quality Assurance 3 3/26/84 i

QA-I-4 Deleted (not applicable)

QA-I-5 Deleted (not a'pplic'ble) a QA-I-6 Quality Assurance Records 3 3/26/84

+

PART II - Engineering Offices

• 1*

Deleted'(not applicable).

9 PART III - Construction Site Section Title a Rev. No. Date QA-III-l Instructions, Procedures, and Drawings 3 3/26/84

+ i QA-III-2 Document Centrol 4 3/26/84 QA-III-3 Deleted (not applicable)

QA-III-4 Deleted (not applicable)

QA-III-5 Deleted (not applicable) i QA-III-6 Nonconformances 3 3/26/84 QA-III-7 Corrective Action 3 3/26/84 QA-III-8 Control of Special Processes 4 3/26/84 QA-III-9 4 Quality Assurar.ce Audits 4 '3/26/84 f

1 O

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w .. .. . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

l I

sios.s isT p io.s2 pace 2 or 2 EnASCo SERVICE 5 HUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCORPORATED HOUSTON LIGHTING AND POWE8t COMPANY SOUTH TEYAS PROJECT N ELECTRIC GENERAT.dG STATION UNITS 1 & 2 7

> R c VISION b

TABLE OF CONTENTS caTE 3/26/84 v

PART III - Construction Site (Cont'd)

Section Title Rev. No. Date QA-III-10 Identification and Control of Items 2 3/26/84 QA-III-11 Inspection 4 3/26/84 QA-III-12 Test Control 3 3/26/84 QA-III-13 Control of Measuring and Testing

. Equipment 3 3/26/84 Q A-III-14 Control of Receiving, Handling, and Storage 4 3/26/84 QA-III-15 Inspection, Test, and operating Status 2 3/26/84 Appendix I Terms and Definitions 2 3/26/84 Appendix II Ebasco Exceptions to US Nuclear Regulatory Guides and ANSI Standards Indicated in Section QA-I-1 3 3/26/84 i

l sios.s isTm io s pace 1 or 19 EBASCO SERVICE 5 HUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INComPoRATED HOU5 TON LIGHTING AND POWER COMPANY gg_7_y SOUTH TEXA5 PROJECT N ELECTRIC GENERATING STATION UNIT 51 & 2 ac vision. 5 g

I h QUALITY ASSURANCE PROGRAM o*TE 3/26/84

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v 1.0 SCOPE

'Ihe purpose of this Section is to describe the Quality Assurance Program of Ebasco Services Incorporated and its applicability to safety-related activities and services performed by Ebasco in the construction of South Texas Project. This program has been designed to meet the applicable requirements of the United States Nuclear Regulatory Commission 18 Quality Assurance Criteria of 10CFR50, Appendix B. It has also been designed to meet the regulatory position of the following US NRC Regulatory Guides and ANSI Standards, with exceptions and clarifications as stated in Appendix II of this Manual:

Standard Title ANSI N45.2-1971 Quality Assurance Program R.C.1.28 (Rev. O, 6/72) Requirements for Nuclear Power Plants ANSI N45.2.1-1973 Cleaning of Fluid Systems and  !

R.C.1.37 (Rev. O, 3/73) Associated Components During (See Appendix II Notes 3 through 5) Construction Phase of Nuclear Power Plants ANSI N4 5.2.2-1972 Packaging, Shipping, Receiving, R.G. 1.38 (Rev. O, 3/73) Storage, and Handling of Items (See Appendix II Notes 6 through 11) for Nuclear Power Plants (During the Construction Phase)

ANSI N45.2.3-1973 Housekeeping During the R.G.1.39 (Rev. O, 3/73) Construction Phase of Nuclear (See Appendix II Notes 12 and 13) Power Plants ANSI N45.2.4-1972 Installation, Inspection, and R.G.1.30 (Rev. O, 8/72) Testing Requirements for (See Appendix II Notes 14 and 15) Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations ANSI N45.2.5-1974 Supplementary Quality Assurance (See Appendix II Notes 1 and 2) Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants l

_ -- . '.-----__ __.--. a

sios.s istp> io.s2 pa c e _2__.o r 19 EBA5CO SERVICES HUCLEAR QUAUTY ASSURANCE PROGRAM MANUAL SECTION INCoRPOR ATED HOU$ TON LIGHTING AND POWER COMPANY g_g SOUTH TEXA5 PROJECT ELECTRIC GENERATING STATION UNITS 1 & 2 n c v,s,o N $

E QUALITY ASSURANCE PROGRAM oave 3/26/84

...c .......

Standard Title ANSI N45.2.6-1973 Qualifications of Inspection, R.G.1.58 (Rev. O, 8/73) Examination, and Testing Plus Positions C.5, C.6, C.7, Personnel for the Construction C.8, and C.10 of Rev.1 Phase of Nuclear Power Plants ANSI N45.2.8-1975 Supplementary Quality Assurance R.G. 1.116 (6/76) Requirements for Installation, (See Appendix II Notes 16 through 18) 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, R .G. 1. 8 8 ( Re v. 2, 10/76) and Maintenance of Quality Assurance (See Appendix II Notes 19 through 21) Records for Nuclear Power Plants ANSI N45.2.10-1973 Quality Assurance Terms and R.G.1.74 (Rev. O, 2/74) Definitions ANSI N45.2.12-1977 Requirements f or Auditing of Quality R.G. 1.144 (Rev. 1, 9/80) Assurance Programs for Nuclear Power (See Appendix II Note 22) Plants lR6 i

ANSI N45.2.23-1978 Qualification of Quality Assurance R.G. 1.14 6 (Rev. O, 8 /80) Program Audit Personnel for Nuclear Power Plants Table I-1.1 provides a matrix which shcws the sections of the Ebasco Nuclear Quality Assurance Program Manual that correspond to the requirements of 10CFR50, Appendix B and US NRC Regulatory Guide 1.28, Rev. O. The Ebasco Quality Assurance Program is comprised of: The Ebasco Nuclear Quality Assurance Program Manual, written corporate policies, procedures, departmental instructions, and drawings related to quality. Table I-1.2 provides a matrix of the principal implementing procedures as they relate to 10CFR50, Appendix B lR6 criteria. Table I-1.3 is a listing of these procedures by title. The l principal implementing procedures are not necessarily limited to those indicated in the matrix. Implementing procedures will be issued for South Texas Project use as the need for specific procedures arises due to changes in lR6 scope of Ebasco safety-related activities.

sios.s isTm so.sz pace 3 o, 19 ESASCO SERVICE 5 NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INComeOR ATED HOUSTON LIGHTING AND POWER COMPANY 94 7_1

, SOUTH TEXA5 PROJECT

< ELECTRIC GENERATING STATION UNIT 51 & 2

> R E V1510 N 5

b

. .I............ QUALITY ASSURANCE PROGRAM DATE

. V l The Ebasco Nuclear Quality Assurance Program Manual has been designed to meet I the requirements of 10CFR50.34 (7) for a quality assurance program It will be incorporated into applicable portions of Houston lR6 description.

Lighting & Power Company safety analysis reports in whole or by reference as l provided by 10CFR50.32.

The Ebasco Quality Program for the South Texas Project ic in force at the Ebasco Home Office and Construction operations. The Ebasco Home Office is an lR6 organized unit where project-related support functions are performed. l Construction Operations encompass those activities related to the construction of the nuclear power station. Ebasco's responsibility for lR6 implementing the Ebasco Quality Program shall begin at the commencement of activities affecting quality and shall end with the turnover of completed systems to the Client or his designee. lR6 Definitions pertaining to the Ebasco Quality Program are listed in Appendix I of this Manual.

2. 0 QUALITY ASSURANCE ENGINEERING The Ebasco Quality Assurance Engineering Department is responsible for establishing new, and updating existing, quality assurance requirements.

In addition, this department is responsible to administer and enforce the implementation of the Ebasco Quality Assurance Manual.

3.0 QUALITY PROGRAM COMMITTEE 3.1 The Ebasco Quality Program Committee is responsible for and has authority to make and approve procedures for any changes to this Manual.

This committee is comprised of representatives of the Materials Engineering and Quality Assurance, Engineering, Construction, Projects, Purchasing, Consulting Engineering, Advanced Technology, and Plant Operations and Betterment Departments; and of Envirosphere Company. .

These representatives are appointed by the Vice President of the respective department.

The Vice President Materials Engineering and Quality Assurance is designated by the Executive Vice President Operations as the Chairman of the Quality Program Committee. A member of Quality Assurance Engineering Department shall be designated by the Chairman as Quality Program Coordinator, who shall function as the Quality Program Committee's secretary and be a member of the Committee.

The Chief Quality Assurance Engineer is designated by the Vice President Fkterials Engineering and Quality Assurance as a permanent representative of the Materials Engineering and Quality Assurance Department on the Quality Program Committee.

m es.stsreiio.s pace 4 or 19 EBA5CO SERVICE 5 NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCORPORATED HOUSTON UGHTINC AND POWER COMPANY OA-I-1 SOUTH TEXA5 PROJECT I ELECTRIC GENERATING STATION UNITS 1 & 2 navision 5 g

D"c 3/26/84 k . ..... ........ QUALITY ASSURANCE PROGRAM The Committee shall be responsible for and shall have authority to make any changes to the policies and procedures of the Ebasco Quality Program. All changes or revisions to the Ebasco Quality Program shall be processed through the Quality Program Committee by the Quality Program Co ordinator.

3.2 Ebasco Quality Program Procedures document the various significant activities of the Quality Program that are the direct responsibility of the Quality Program Committee or the Quality Program Coordinator. These procedures include but are not limited to the following:

3.2.1 Quality Program Procedure No. 4 entitled, QUALITY PROGRAM COORDINATOR - DESCRIPTION OF POSITION, DUTIES, RESPONSIBILITIES. ,

3.2.2 Quality Program Procedure No. 5 entitled, DEVIATING EBASCO PROJECT-RELATED QUALITY ASSURANCE PROGRAMS FROM THE EBASCO NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL. This provides for control of such deviations by rcquiring execution of an authorization form involving approval of specified authorities to assure, among other things, that safety and/or quality will not be sacrificed.

3.2.3 Quality Program Procedure No. 6 entitled, ASSIGNMENT, DISTRIBUTION AND 00NIROL OF THE EBASCO NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL.

3.2.4 Quality Program Procedure No. 7 entitled, REVISIONS TO THE EBASCO NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL.

4.0 GENERAL 4.1 Section QA-I-2 of this Manual describes the organizational structure, functional responsibilities, levels of authority, and lines of internal and external communication for management, direction, and execution of the Ebasco Quality Assurance Program. By the Statement of Authority at the front of this Manual, Ebasco's President mandates the company-wide use of this Manual and its supporting documents which make up the Ebasco Quality Program.

4.2 It shall be the responsibility of each Ebasco department and the individual personnel of that department to adhere to the requirements of this Program. Section QA-III-l of this Manual requires these departments to develop and control instructions, procedures, and/or drawings which describe the manner in which activities affecting quality are to be accomplished. When documented evidence is required for the satisfactory performance of these activities, checklists, forms, and/or other appropriate means shall provide this evidence. The documents which contain the procedures listed in Table 1-1.3 and are used to implement the Ebasco QA Program are:

sim.s tsTri m.82 Pact 5 or 19 ESA$CO SERVICES NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCORPORATEo NOU$ TON UGHTING AND POWER COMPANY OA-I-l

, SOUTH TEXA5 PROJECT

< ELECTRIC GENERATING STATION UNITS 1 & 2

> R E Vi $lO N 5 QUALITY ASSURANCE PROGRAM care 3/26/84

.. .. n ........

4.2.1 Quality Assurance Engineering Department -

Quality Assurance Procedures Manual for South Texas Project l l

4.2.2 Quality Assurance Engineering Department - lR6 Site Quality Assurance Procedures Manual for Scuth Texas Project l 1

4.2.3 Quality Program Procedures Manual l 4.2.4 Company Procedures Manual - Nuclear i

4.2.5 Quality Assurance Engineering Department - l Site Quality Control Procedures Manual for South Texas Project l l

4.2.6 Quality Assurance Engineering Department - l Site Quality Assurance Instructions Manual for South Texas Project l l

4.2.7 Construction Department Procedures Manual - lR6 Administrative Site Procedures for South Texas Project l l

4.2.8 Construction Department Procedures Manual - l Construction Site Procedures for South Texas Project l l

4.2.9 Construction Department Procedures Manual - l Construction Maintenance Instructions for South Texas Project l The above-listed manuals may also contain departmental working procedures which do not describe activities affecting quality and therefore are not governed by the requirements of this Manual. Furthetc. ore, certain implementing procedures may require changes in order to suit unique client requirements; such procedures for the South Texas Project will be lR6 included in a project manual of procedures and/or a site manual. In this case, the changed procedure shall be designated a Project Procedure.

These procedures will be subject to controls similar to those applicable to the original documents.

4.3 In addition to the requirements of Section QA-III-l of this Manuel and Paragraph 4.2 above, Section QA-III-8 of this Manual further assures control .over quality-related activities by requiring that special processes shall be performed in accordance with written qualified procedures, and that they shall be performed only by qualified personnel. All qualifications shall be in accordance with applicable codes, standards, specifications, and other requirements as applicable.

The Ebasco Quality Program provides for the verification of quality requirements throagh written policies, procedures, and instructions for the performance of inspections and tests. These inspections and tests are performed on services provided by Ebasco. All inspections shall be lR6 performed by individuals other than those who performed the activity.

lR6 ,

t = . _ _ _ _ _ _ _ . . _ _ _ _ _ _

sios.s istm ss.sz nace 6 or 19 EBASCO SERVICES HUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCORPORATED HOU$TCN LIGHTING AND POWER COMPANY OA-T

^ ' -1

, SOUTH TEXAS PROJECT

< ELECTRIC GENERATING STATICN UNITS 1 & 2 5 o u , ,, ,, ,, u , QUALITY ASSURANCE PROGRAM e 3/26/84 5.0 INDOCTRINATION AND TRAINING Section QA-I-3 of this Manual provides for the company-wide indoctrination and training of Ebasco personnel engaged in activities subject to the requirements of the Ebasco Quality Assurance Program. The objectives of the training pregram are to familiarize applicable Ebasco persennel with this Quality Assurance Program Manual and the implementing procedures identified in lR6 Table I-1.3. Overall responsibility for training as delineated in QA-I-3 rests with the Quality Assurance Engineering Department.

6.0 REVIEW OF QUALITY PROGRAM ADEQUACY 6.1 The adequacy of the Ebasco Quality Program is reviewed on a regular basis. The determination of program adequacy is based on audit results and trend analyses. Section QA-III-9 of this Manual provides for the performance and follow-up of audits by Site Quality Assurance and Home l Office Quality Assurance Engineering and of management audits of the l Materials Applications and Quality Assurance functions. !6 R

6.2 Audits performed by Home Office Quality Assurance Engineering are l designed to evaluate the Quality Program ef fectiveness on a project basis. When corrective action is necessary, re-audits are scheduled to assure implementation of corrective action. Section QA-III-9 of this l Manual defines review activities and :eports involved in the auditing I function. l lR6 6.3 Information on audits performed by Home Office Quality Assurance l Engineering and Site Quality Assurance shall be submitted to the Quality l Assurance Engineering Supervisor of Auditing. He shall make an analysis l of the available quality data with respect to quality trends and report the result at least semi-annually to the appropriate executive lesel of managtment for review end assessment in accordance with Quality Assurance Engineering Procedure QA-D.3. The Vice President of Matarials Engineering and Quality Assurance shall be reuponsible for initiating the implementation of any changes or corrective action deemed necessary to improve the ef fectivenass of the Ebasco Quality Assurance Program.

1

st os.s (sin io.e2 Pace 7 or 19 EBA5CO SERVICES NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCORPORATED HOUSTON LIGHTING AND POWER COMPANY QA-I-1

, SOUTH TEXA5 PROJECT g ELECTRIC GENERATING STATION UNITS 1 & 2 5

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E QUALITY ASSURANCE FROGRAM DATE 3/26/84

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TABLE I-1.1 MATRIX OF COMPLIANCE TO US NRC 10CFR50 APPENDIX B AND ANSI N45.2 10CFR50 ANSI N45.2 Ebasco Nuclear Quality Appendix B Criteria Pa ra graph Assurance Program Manual Section I 3 QA-I-2 II 2 QA-I-1, QA-I-3 III 4 Not Applicable to Ebasco STP l Work Scope l lR6 IV 5 Not Applicable to Ebasco STP l Work Scope l l

l V 6 QA-III-1 VI 7 QA-III-2 VII 8 Not Applicable to Ebasco STP l26 Work Scope l VIII 9 QA-III-10 IX 10 QA-III-8 X -

11 QA-III-11 lR6 XI 12 QA-III-12 XII 13 QA-III-13 XIII 14 QA-III-14 XIV 15 QA-III-15 XV 16 QA-III-6 XVI 17 QA-III-7 XVII 18 QA-I-6 XVIII 19 QA-III-9 l

l APPftOVAL h TABLE I-l.2 I

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Necleer Control Assurance Assurance Constructton Procedures Proarse 3m (cf.) I y3 (N-) Procedures Instructtone (QA-)

Crt-tertem *recedures (QCP-) (QAI-) Procedures (ASP-) (CSP-) (Ot t-) Pro:eduree E 4I RO

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-001 -2 7 I -21 -1.1 *

-14,-34 -4 through -7 5 11 -24 -2.1. -2. 2, -003.-012.-017.-018 -C.3 -S.I.-S.23 l

-6.3 T -23 -6.1.-6.3 -002,-005,-017 -C. I .-C.2,-S.2 3 -1,-7.-11 -1 through

-12.-14 -100 (as Z applicable)

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m =hy VIII -9.1 t hrough -13.3 -S.12 through -S.16 -5,-32 25,-38,

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Q O2

'8 5 (as applicable) -S.18.-S.21.-S.22

-14.1.-I1.2 N

el ~

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g C' C II -9.1,-9.3, -014 -015 -S.14 farough -S.20 -11.-81 g _g C q

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stos.s isTri sz s2 Pact 9 or 19 ESASCO SERVICES NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCoRPoRATc0 HOUSTON LIGHTING AND POWER COMPANY SOUTH TEXA5 PROJECT OA-I-1 d ELECTRIC GENERATING STATION UNITS 1 & 2 na visiou 5 QUALITY ASSURANCE PROGRAM oare 3/26/84 TABLE I-1.3 PRINCIPAL IMPLEMENTING PROCEDLitES Procedure No. Title N-21 Nuclear Quality Program Authorization and Implementation N-23 Reporting a Defect / Noncompliance to the NRC N-24 Ebasco Management Quality Assurance Audit Committe e QA-G.1 Preparation and Control of Quality Assurance Engineering Department Procedures QA-G.2 Control and Distribution of Project-Related Manuals QA-G.3 Qualification of QA Audit Personnel QA-C.3.1 Qualification of Inspection, Examination and Testing Personnel QA-G.4 Quality Assurance Engineering Records lR6 QA-D.3 Determination and Analysis of Quality Trends QA-D.4 Resolution of External Audit Findings lR6 QA-D.5.2 Site Audit Procedure lR6 QA-S-1 Planning of Site Quality Assurance Engineering Activities Q A-S-2 General Audit Procedure QA-S-3 Processing of Quality Assurance Engineering Audit Reports Q A-S-4 Quality Assurance Records Audit

l stos.s asym io.s2 ,4cc 10 ,, 19 EBASCO SERVICES HUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCORPORATEo HOUSTON LIGHTING AND POWER COMPANY SOUTH TEXAS PROJECT QA-I-l N ELECTRIC GENERATING $TATION UNITS 1 & 2 5 R E VISIO N 3/26/84 I. ............p.

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QUALITY ASSURANCE PROGRAM caTE Procedure No. Title QA-S-5 Material Receipt Audit QA-S-6 Material and Component Storage Audit lR6 QA-S-8 Calibration and Cage Control Audit Q A-S-9 Document Control Audit lR6 QA-S-11 System Turnover Audit QA-S-12 Civil Activities Audit QA-S-13 Structural Steel Audit QA-S-14 Reinforcing Steel Audit QA-S-15 Protective Coating Audi t Q A-S-16 Welding Material Control Audit QA-S-17 Welding Qualification Audit QA-S-18 Mechanical and Welding Activities Audit QA-S-19 Nondestructive Examination Audit Q A-S-20 Radiographic Review Audit QA-S-21 Electrical Activities Audit QA-S-22 Instrumentation Activities Audit QA-S-23 Quality Assurance Instructions QP-4 Quality Program Coordinator - Description of Position, Duties, Responsibilities QP-5 Deviating Ebasco Project-Related Quality Assurance Programs from the Ebasco Nuclear Quality Assurance Program Manual l

I

sace.sisTn c.s2 pace 11 or 19 1

EBASCO SERVICES HUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCORPORATED  !

HOUSTON LIGHTING AND POWER COMPANY j gg_7,y

, SOUTH TEXA5 PROJECT j ELECTRIC GENERATING STATION UNITS 1 & 2 '

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< ...uom...p............... QUALITY ASSURANCE PROGRAM D^rc 3/26/84 Procedure No. Title QP-6 Assignment, Distribution and Control of the Ebasco Nuclear Quality Assurance Program Manual QP-7 Revisions to the Ebasco Nuclear Quality Assurance Program Manual lR6 QCP-1.1 Quality Control Organization and Responsibilities QCP-2.1 Indoctrination, Training and Qualification of Quality Control Personnel to ANSI N45.2.6 Requirements QCP-2.2 Indoctrination, Training and Qualification of Quality Control Personnel to ASME Section III, Division 2 Requirements l QCP-6.1 Preparation, Review and Approval of Quality Control Procedures QCP-6.2 Document Control QCP-6.3 Quality Control Review of Incoming Revisions /

Changes to Bechtel Specifications and Procedures QCP-9.1 Weld Inspection Piping ASME lR6 I

QCP-9.3 Inspection of Post Weld Heat Treatment QCP-9.4 Verification of Weld Filler Material Control QCP-9.5 Weld Inspection ( AWS)

QCP-10.1 Cadweld Inspection QCP-10.2 Preplacement Concrete Inspection QCP-10. 3 Concrete Placement Inspections QCP-10.4 Pos t-Placement Concrete Inspection 9

st oo.s ist Pi io.e Pact 13 or 19 ERASCO SERVICES HUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCoRPORATEo HOU$ TON LIGHTING AND POWER COMPANY OA-I-1 SOUTH TEXAS PROJECT I ELECTRIC GENERATING STATION UNITS 1 & 2 navisio n 5 g

I. QUALITY ASSURANCE FROGRAM DATE 3/26/84

.........,77...............

Procedure No. Tit 1e QCP-10.23 Waterstop/ Joint Filler / Sealer Material Inspection lR6 QCP-10.24 Grouting Inspection QCP-10. 25 Inspection of Bending and Fabrication of lR6 Reinforcing Steel QCP-10. 2 7 Modification / Removal Control Procedure QCP-10.28 Control of Inspection Stamps lR6 QCP-11.1 Hydrostatic and Pneumatic Pressure Test Inspection QCP-12.1 Calibration and Control of Measuring and Test Equipment Q CP-13.1 Storage and Maintenance Inspection / Verification QCP-13.2 Verification of Rigging and Handling Activities QCP-13. 3 Housekeeping Inspections QCP-14.1 Status Control QCP-15.1 Identification and Control of Discrepancies and Nonconforming Conditions QCP-15. 2 Stop Work Order QCP-15.3 Control and Processing of Transition Phase Deficiencies and Conditions QCP-16.1 Corrective Action QCP-17.1 Quality Assurance Records QCP-17.2 Preparation, Issuance, and Control of ASME lR6 Nameplates / Data Reports I

M o,M stos.s tsim s2.e2 ..cc ESASCO SERVICES NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCORPORATED HOUSTON LIGHTING AND POWER COMPANY QA-I-1 SOUTH TEXAS PROJECT I ELECTRIC GENERATING STATION UNITS 1 & 2 5 RE Vl5loN l

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QUALITY ASSURANCE PROGRAM onye 3/26/84 Procedure No. Title QAI-001 Site QA Organization and Responsibilities QAI-002 Preparation, Review, Distribution and Control of Supplements to Quality Assurance Procedures QAI-003 Indoctrination, Training, Qualification, and Certification of Site Quality Assurance Audit Pe rsonnel QAI-004 Issuance and Processing of Nonconformance Reports QAI-005 Review and Approval of Quality Control and Construction Procedures QAI-006 Audit of Ebasco Site Organization by the Client, Bechtel, Ebasco Home Office, Code or Regulatory Agency QAI-007 Reportable Deficiencies lR6 QAI-010 Site Quality Assurance Records QAI-Cll Management Corrective Action and Stop Work Authority QAI-012 General Surveillance Instruction QAI-013 Preparation, Conducting, Documenting and Logging of Audits QAI-014 Quality Assurance Review of Radiogra phs QAI-015 Procedure for the Calibration and Oper tion of the Radiographic Densitometer QAI-016 Control of Site Quality Records QAI-017 QA Review of Incoming Revisions to Bechtel and Houston Lighting and Power QA Program Documents j

sios-s istri io.ez nace 15 ,,19 EBA5CO SERVICES HUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION tNCoRPORATEo NOU5 TON LIGHTING AND POWER COMPANY QA-I-l SOUTH TEXA5 PROJECT N ELECTRIC GENERATING STATION UNITS 1 & 2 5

> R E VI SIO N E

3/26/84 I

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QUALITYASSURANCEPdOCRAM care Procedure No. Title QAI-018 Quality Assurance Indoctrination and Training lR6 Program QAI-019 Safety-Related Documentation Turnover Packages ASP-1 Preparation of Site Procedures ASP-2 Organization and Responsibility ASP-3 Material Requisition lR6 ASP-4 Heavy Handling and Rigging ASP-5 Material Control ASP-6 Document Control ASP-7 Field Change Notice Procedure lR6 ASP-8 Preparation and Transmittal of Quality Assurance Records ASP-9 Construction Turnover / Release for Test l lR6 ASP-ll Field Change Request l ASP-12 Development of Construction Field Sketches ASP-14 Impact Review of Bechtel/HL&P Issued Documents ASP-15 Stop Work Procedure ASP-16 Corrective Actions ASP-32 Maintenance of Construction Equipment ASP-33 Nonconf ormance s ASP-34 Indoctrination and Training ASP-82 Fire Prevention and Fire Protection

16 19 sios. istpi io.e2 poac ESASCO SERVICES HUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION iNcommonATED NOUSTON LIGHTING AND POWER COMPANY QA-I-l SOUTH TEXA5 PROJECT d ELECTRIC GENERATING STATION UNITS 1 & 2 5

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QUALITY ASSURANCE PROGRAM o yg 3/26/84 v

Procedure No. Title CSP-1 Excavation and Backfill CSP-2 Installation of Permanent Electrical and Mechanical Plant Equipment CSP-3 control of Lifting Apparatus CSP-4 Concrete Placement CSP-5 HVAC Duct and Housing Leak Testing CSP-6 Installation of HVAC Hangers CSP-7 Pipe Support Installation CSP-8 Cable Terminations and Splices CSP-9 Installation of Duct and Duct Accessories .

CSP-10 Erection and Boltup of Structural Steel CSP-11 Storing, Installation, Cadwelding, Fabrication and Modification of Rebar CSP-12 General Instructions for Housekeeping During Construction CSP-13 Concrete Core Drilling CSP-14 Control of Material for Temporary Construction CSP-15 Installation of Special Doors CSP-16 Piping Installation Procedure CSP-17 Hydrostatic and Pneumatic Testing

l paog 17 19 st os.s isv ei io.s or EsASCo SERVICE 5 HUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCORPORATED HOUSTON UGHTING AND POWER COMPANY QA-I-l SOUTH TEXAS PROJECT I ELECTRIC GENERATING STATION UNITS 1 & 2 5

> R E VI SIO N E

!. M M..,n4.....g.....a........ QUALITY ASSURANCE PROGRAM one 3/20/84 Procedure No. Title CSP-18 Soil Test Fill Procedure CSP-19 Safety and Non-Safety Related Cable Pulling lR6 CSP-20 Construction Survey Activities CSP-21 Field Preparation and Coating of Surfaces Outside the Reactor Containment Building CSP-22 Valve / Pump Work CSP-23 Water Flushing, Lube Oil Flushing, and Chemical Cleaning CSP-24 Reactor Coolant Pump Volute Final Setting CSP-25 Temporary Equipment Site Tagging Procedure CSP-26 Reactor Vessel Final Setting CSP-27 Steam Generator Final Setting CSP-29 Reactor Vessels Internels Handling and Assembly CSP-30 Field Preparation and Coating of Surfaces Inside the Reactor Containment Building CSP-31 Piping System Cleanliness CSP-32 Insulation Resistance Testing lR6 CSP-34 Control and Verification of Survey Equipment CSP-35 Installation of Post-Tensioning Trumplate Assemblies anc' Sheathing CSP-36 Data Collection to Support Geotechnical Monitoring Program 6.-,,,,,, . - -

slos.s isT P) 10.02 PocE or ESA$CO $ERVICES HUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCORPORATED HOUSTON LIGHTING AND power COMPANY QA-I-1 SOUTH TEXAS PROJECT 5

f ELECTRIC GENERATING STATION UNIT 51 & 2 MM QUALITY ASSURANCE PROGRAM o ,g 3/26/64

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Procedure No. Title CSP-37 Crane and Hoist had Testing CSP-38 Equipment or Component Interchange CSP-39 Vendor's ASME Code Data Plate Modification CSP-40 EE580 Cable Raceway and Tray Tracking CSP-41 Installation of Expansion Type Anchors CSP-43 Installation of Electrical Raceways Installation of Electrical Penetration Assemblies lR6 CSP-44 CSP-47 Instrumentation and Controls Installation CSP-48 Instrumentation Tubing and Supports Fabrication lR6 and Installation CSP-49 Permanent Plant Equipment Site Tagging Procedure CSP-54 Field Fabrication of Miscellaneous Metal CSP-55 Field Fabrication of Reinforcing Steel CSP-57 Shop Fabrication of ASME Section III Parts, 1 Appurtenances, Piping Subassemblies and Component lR6 Supports l CSP-60 Rigging for Setting Steam Generator CSP-61 Rigging for Setting Pressurizer CSP-62 Rigging for Setting Reactor Vessel CSP-63 Rigging for Setting Unit #2 Reactor Head CSP-64 Rigging for Setting Unit #2 Reactor Internals CSP-65 Rigging for Setting Unit #2 Polar Crane

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ESASCO SERVICE 5 NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION incomPomATEo MOU$ TON LIGHTING AND POWER COMPANY QA-I-l SOUTH TEXA5 PROJECT d ELECTRIC GENERATING STATION UNITS 1 & 2 5 Re vl51C N I s QUALITY ASSURANCE IROGRAM care UNU

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Procedure No. Title CSP-81 Welder Qualification CSP-8 2 AWS Dl.1 Structural Welding CSP-83 Ceneral ANSI B31.1 Welding Requirements for Piping and Hangers CSP-84 General ASME Section III Welding Requirements for Piping and Hangers CSP-85 Post Weld Heat Treatment CSP-86 Repairs of ASME Section III and ANSI B31.1 Piping and Components CSP-87 Welding Procedure Specification Qualification CSP-88 Weld Filler Material Control CSP-89 Field Welding and Repair of Aluminum Bronze ECW [ Essential Cooling Water) Piping CSP-90 Welding Documentation CSP-91 Issuance and control of Purge Dams CSP-92 control of Aluminum Bronze Material for Backing Rings and Welder Qualification Coupons CSP-93 control of Weld Filler Material For Non-Permanent Plant Maintenance CSP-94 Maintenance, Calibration and Repair Program for Dimetrics Automatic Welding Equipment CSP-95 General Welding Requirements for HVAC CSP-96 Request for NDE lR6 CMI-l Caring and Maintenance of Permanent Plant Items l

l sim.s ist ei io.e pace 1 er13 ESA5CO SERVICE 5 HUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCORPORATED NOU$ TON UGHTING AND POWER COMPANY OA-I-2 SOUTH TEXA5 PROJECT N ELECTRIC GENERATING $TATION UNITS 15, 2 ac vision 5 ,

ORGANIZATION AND RESPONSIBILITIES carc 3/26/84 1.0 SCOPE This Section of the Manual describes the organizational structure, functional responsibilities, levels of authority, and lines of internal and external communication for management, direction, and execution of the Ebasco Quality Program. It is recognized that quality assurance is an interdisciplinary function and not the sole domain of a single quality assurance group; for that reason, this section of the Manual includes organizational and functional descriptions of several departments in addition to that department whose sole function is quality assurance.

2.0 CENERAL 2.1 The Ebasco Operations organization consists of four independent quality-related principal divisions headed respectively by the Senior Vice Presidents of Engineering and Construction, Consulting Engineering, and Projects and Procurement, and the Vice President Materials Engineering and Quality Assurance. Each of these officers of the company reports to Ebasco's President and Chief Executive Officer through the Executive Vice President Operations. Reporting to the Senior Vice, President Engineering and Construction are the Vice President Engineering and Vice President Construction. Reporting to the Senior Vice President Consulting Engineering are the President of Envirosphere Company, the Vice President Plant Operations and Betterment, and the Vice President Consulting Engineering. Reporting to the Senior Vice President Projects and Procurement is the Vice President Procurement.

A fif th quality-related principal division is headed by the Executive Vice President of Advanced Technology and Special Projects who reports directly to Ebasco's President. Reporting to the Executive Vice President Advanced Technology and Special Projects is the Vice President Advanced Technology.

2.2 Representatives of the Senior Vice President Projects and Procurement; of the Vice Presidents Engineering, Construction, Procurement, Plant Operations and Betterment, Consulting Engineering, and Materials Engineering and Quality Assurance; and of the President of Envirosphere Company comprise the operations organization representatives of the Quality Program Committee, which is responsible for Ebasco Quality Assurance policy. Also included on this Committee is a representative of the Vice President Advanced Technology. This is shown diagramatically by Figure I-2.1 at the end of this Section.

2.3 The divisions or departments most directly involved in the implementation of the quality assurance program for fabrication and l

sios.s este to.es pace 2 or U

ESASCO SERVICES NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL $ECTION WCORPoR ATED HOU$ TON LIGHTING AND POWER COMPANY QA-I-2 a SOUTH TEXA5 PROJECT

ELECTRIC GENERATING STATION UNITS 1 & 2 5 O

RE Vi slo N ORGANIZATION AND RESPONSIBILITIES care _ 3/26/84

. .f.............

installation are Materials Engineering and Quality Assurance, and lR6 Construction. The organizational structures of these are shown in l Figures I-2.2 and I-2.4 at the end of this Section. The Construction Department provides overall contractual administration of a project, coordinating the efforts of involved departments and serving as a line of communication between Ebasco and its Clients. The Consulting Engineering, Plant Operations and Betterment, and Advanced Technology Departments are involved in the implementation of Quality Program requirements through the supplemental services they provide.

The responsiblities of each department of the Ebasco Organization for quality assurance requirements applied to Nuclear Power Stations are -

described herein.

3.0 MATERIALS ENGINEERING AND QUALITY ASSURANCE 3.1 Primary responsibility for Quality Assurance rests with the Vice President Materials Engineering and Quality Assurance who reports directly to the Executive Vice President Operations. Qualification requirements for the position of Vice President Materials Engineering and Quality Assurance are: Bachelor of Science Degree in Engineering; 10 to 15 years of experience in quality-related work or equivalent experience in the engineering or construction of a nuclear power plant, including at least 10 years experience in responsible managerial project positions; thorough knowledge of the Ebasco Quality Assurance Program. The Materials Engineering and Quality Assurance Unit is comprised of the f ollowing organizations, each of which contributes directly to the implementation of the Quality Program (see Figure I-2.2):

a) Quality Assurance Engineering b) Materials Applications c) Vendor Quality Assurance d) Quality Assurance Consulting Engineer lR6 e) Materials Engineering laboratory 3.1.1 Quality Assurance Engineering is administered by the Chief Quality Assurance Engineer who reports to the Vice President Materials Engineering and Quality Assurance. Qualification requirements for the position Chief Quality Assurance Engineer are:

Bachelor of Science Degree in Engineering; 10-15 years of experience in quality-related work or equivalent experience in the engineering

sios.s isten m.e Pace 3 or 13 ESA5CO SERVICE 5 HUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION eNCoRPORATEo NOUSTON LIGHTING AND POWER COMPANY gg.7_7 SOUTH TEXAS PROJECT d ELECTRIC GENERATING STATION UNITS 1 & 2 nevisiou 5

, ,,, ,,,, ORGANIZATION AND RESPONSIBILITIES DATE 3/26/84 or construction of a Nuclear Power Plant, including at least 5 years experience in responsible managerial project positions; thorough knowledge of the Ebasco Quality Assurance Program. The Quality Assurance Engineering Department is responsible to plan implementation of, evaluate, monitor, and enforce the Ebasco Quality Program. His responsibility is carried out by five functional subdivisions:

a) Project Quality Assurance Engineering b) Site Quality Assurance / Quality Control c) Site Quality Program d) Quality Assurance Specialists, which provide various other quality-related services and functions e) Nondestructive Examination (NDE) Quality Assurance Managers, Supervisors, and Specialists in charge of the subdivisions report directly or through other supervisors to the Chief Quality As surance Engineer. Engineers and Specialists are then assigned to specific projects from these subdivisions. The Quality Assurance Engineering Organization is shown in Figures 1-2.6 and I-2.7 at the end of this Section.

3.1.1.1 Site Quality Assurance - The Manager Site Quality Assurance, who reports to the Orief Quality Assurance Engineer in New York, is responsible for the development, I maintenance, and current status of Site Quality Assurance l Procedures, for providing technical assistance and guidance I to subordinate Quality Assurance Site Supervisors and staff, l and for distribution and control of quality assurance I manuals, as well as changes thereto, for the South Texas lR6 Project. (See Figures I-2.2 and I-2.6.) The Manager Site  !

Quality Assurance has delegated authority to the Quality l Program Site Manager on the preparation, review, approval, l and distribution control of Site Quality Control procedures I and project-related supplements to the Site Quality Assurance l Procedures. l 3.1.1.2 Site Quality Program - A Quality Program Site Manager is assigned to the construction site on a resident IR6 basis for the purpose of overall planning, direction, and

SlW S ISTM 10.(2 PAGE OF l EBA$CO $ERVICES HUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCORPORATEo MOU$ TON UGHTING AND POWER COMPANY QA-I-2

, SOUTH TEXA5 PROJECT 4 El.ECTRIC GENERATING STATION UNITS 1 & 2 5 REVI$lON I k ORGANIZATION AND RESPONSIBILITIES oaTE 3/26/84

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implementation of the Ebasco Nuclear Quality Program Manual.

The Quality Program Site Manager, who reports to the Chief Quality Assurance Engineer in New York, is subordinate to no individual on site and has the independent authority to identify site quality-related problems, to initiate or recommend solutions, to control existing nonconformances, to verify implementation of approved dispositions, to direct efforts to obtain ASME Certificates of Authorization for Ebasco as may be required for the South Texas Project, to represent Ebasco Quality Assurance Engineering with regard to South Texas Project activities, such as Client or his designee and/or Ebasco meetings, Client or his designee lR6 audits, management audits, and, when necessary, to stop work. He is responsible to assure that all personnel working for him are qualified for their espective positions and properly trained. The Chief Quality Assurance Engineer has l delegated authority to the Quality Program Site Manager on l the preparation, review, approval, and distribution control lR6 of project-related supplements to the applicable Quality l Assurance Procedures. The Site Quality Program function is I divided into three groups: Quality Assurance, Quality l Control, and Quality Records, each reporting through a respective supervisor to the Quality Program Site Manager.

(See Figure I-2.6.)

3.1.1. 2.1 Site Quality Assurance - A Quality lR6 Assurance Site Supervisor and staff of engineers and representatives are assigned the following functions:

a) Review and audit quality-related site construction and engineering activities and records on a continuing basis.

b) Perform audits and surveillances of lR6 construction forces for adherence to prescribed approved procedures.

lR6 c) Review and advise on Quality Control procedures and construction lR6 procedures for compliance with this l Manual and code and regulatory requirements. When necessary, the Quality Assurance Site Supervisor may request the Manager Site Quality Assurance to assist in the review of Quality Control procedures. lR6

sios.s ist pi io.ez pact 5 ,, D ESASCO SERVICES NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCORPORATED NOUSTON LIGHTING AND POWER COMPANY QA-I-2 SOUTH TEXAS PROJECT N ELECTRIC GENERATING STATION UNIT 51 & 2 5

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ORGANIZATION AND RESPONSIBILITIES oave 3/26/84 d) Generate records of all reviews and lR6 audits performed.

e) Review all radiographic film for site-related nondestructive examination.

f) Audit records and documentation prior lR6 to turnover to the Client.

g) Develop and implement Quality Assurance Instructions and l project-related supplements to Site l Quality Assurance Procedures and l implement applicable Site Quality l Assurance Procedures. l lR6 h) On-site distribution of those Quality l Assurance procedures which are issued l and controlled by the Manager Site l Quality Assurance or his designee. l l

i) The Quality Assurance Site Supervisor has stop work authority.

3.1.1. 2. 2 Site Quality Control - A Quality Control Site Supervisor and staff of engineers and inspectors are assigned the following functions consistent with the scope of work assigned to Ebasco:

a) Planning and performance of inspection activities during the construction phase.

b) Identifying and initiating correction of nonconforming conditions to requirements indicated by drawings, specifications, codes, or procedures, and performance of reinspection to verify corrective action taken.

b I stpe.s tsT Pt 2.82 Pact or EaASCO SEnvlCES NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION

$NCoRPoRATED HOUSTON UGHTING AND POWER COMPANY QA-I-2 SOUTH TEXA5 PROJECT d ELECTRIC GENERATING STATION UNITS 1 a, 2 5

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I h ORGANIZATION AND RESPONSIBILITIES oare 3/26/84

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c) Establishing and enforcing quality control documentation and inspection requirements based upon specifications, codes, standards, and drawings as established by the lR6 Client or his designee. I d) Performance or monitoring of site NDE, soils, and concrete testing activities, e) Assisting in organizing and administering training seminars as required to assure proper level of training, and engaging in the certification of Quality Control personnel to the required level of qualification.

f) Identification and control of the quality status of items.

g) Development and implementation of applicable Quality Control procedures, and generation of lR6 inspection reports covering mandatory inspection activities at the construction site.

h) Ihe Quality Control Site Supervisor has stop work authority.

The Site Quality Control Group will only be responsible for first-level Quality Control activities for safety-related items and services being perf ormed by Ebasco's forces. lR6 3.1.1. 2. 3 Site Quality Records - A Quality Records Supervisor and staff of specialists are assigned the following functions:

a) Develop, establish, and implement a system for the collection, storage, and maintenance of quality assurance records at the project construction site.

sace.s tsten io.e pace 7 Or 13 EBASCO SERVICES HUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCORPORATED HOU$ TON UGHTING AND POWER COMPANY QA-I-2 50UTH TEXA5 PROJECT I ELECTRIC GENERATING STATION UNITS 1 & 2 5

> Re vision

& ORGANIZATION AND RESPONSIBILITIES oATE 3/26/84 b) Responsible for review for complete; ness, control, storage, preservation, and safekeeping of site-generated quality assurance l records until turnover to the Client lR6 or his designee. I c) Establisheent and implementation of a records indexing system to permit proper traceability and retrieval.

d) Establishment of a procedure for access to the records storage area, and removal and retrieval of quality records.

3.1.1.3 Quality Assurance Specialists - Quality Assurance Engineering has several specialty groups responsible f or the following activities which are performed in ,accordance with Quality Assurance procedures: lR6 a) Perforcance of In-service Inspection.

b) Qualification and certification of personnel as required by applicable codes or standards.

c) Development of Quality Assurance standards and procedures.

d) Review, evaluation, and sunmarization of Code and Regulatory quality assurance requirements.

lR6 e) Conducting Quality Assurance education, both internal and external to Quality Assurance Engineering, f) Interdepartmental auditing of all individuals or groups responsible for activities covered by the Quality Program.

g) Development of quality assurance records programs.

h) Development of Quality Assurance Programs for Power Plant Operations.

sico.s isTm c.e2 pacc 8 or 13 ESA5CO SERVICES NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION 8HCoRRoRATEo MOUSTON LIGHTING AND POWER COMPANY QA-I-2 SOUTH TEXA5 PROJECT d ELECTRIC GENERATING STATION UNITS 1 & 2 5 ORGANIZATION AND RESIONSIBILITIES . 3/26/84 3.1.1.4 Nondestructive Examination Quality Assurance - This group, under the Assistant Gief Quality Assurance Engineer in charge of In-service Inspection and Nondestructive Examination, provides expertise with regard to conducting various forms of NDE and includes the following functions:

a) Establish and/or interpret NDE requirements and acceptance criteria for fabricated and erected equipment as required, b) Review and comment on NDE procedures and radiographic films submitted by site I construction forces, and/or the Client or his I designee. lR6 I

c) Advise site construction forces as to proper NDE l procedures, applications, techniques, equipment, and qualifications.

d) Qualification and certification of Ebasco NDE lR6 personnel. l 3.1.1.5 Radiation Safety - Ebasco's Corporate Radiation Safety Officer reports to the Chief Quality Assurance Engineer. He is responsible for auditing and enforcing the Ebasco procedures for radiation safety.

3.1.2 Materials Applications, under the supervision of the Gief Haterials Applications Engineer, includes two subdivisions:

Materials Applications Engineering and Welding Engineering. A Project Materials Applications Engineer and Project Weldirg Engineer are assigned to the South Texas Project. 'Ihese positions may be l assigned to the same individual if properly qualified. A Site l Welding Superintendent, who reports to the Chief Haterial lR6 Applications Engineer in New York, is assigned to the construction l site and is resposible for the direction, supervision, and l administration of a site welding operations staff. Quality-related l activities of Haterials Applications personnel include the following:

a) Develop material and welding specifications.

b) Develop and qualify welding procedures and fabrication techniques for use by Ebasco site construction forces. lR6

sics.s tsrei to o2 pace 9 o,13 ESA5CO SERVICES NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION

• CC"'0"'TEC HOU$ TON UGHTlWG AND P0wER COMPANY QA-I-2

, SOUTH TEXA5 PROJECT

< ELECTRIC GENERATING STATION UNITS 1 & 2 RE ve ssoN 5

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.....m.,p................ ORGANIZATION AND RESPONSIBILITIES oate 3/26/84 c) Prepare site welding operations implementation procedures lR6 for Ebasco site construction forces. l d) Advise Ebasco Construction management as to the development and application of advanced welding techniques which would enhance quality.

e) Prepare Process Data Checklists which provide l comprehensive requirements for welding process and l procedure selection. lR6 l

f) Review specifications and drawings provided by the Client l or his designee for compliance with applicable codes and l regulatory requirements for proper selection of materials, weld procedures, and joint details.

l g) Supervise the welder performance testing program at the lR6 construction site to assure that all code and regulatory l requirements have been met.

lR6 h) Provide technical assistance as required to resolve problems at the construction site in the areas of IR6 welding. materials, heat treatment, and other related areas.

1) Provide technical assistance concerning material properties under service conditions involving stress, radiation, temperature, corrosive media, etc, to determine capability of specific materials to perform in such environments.

j) Review, monitor, and provide recommendations for l upgrading of Ebasco welder training programs and welder l assignment practices. l l 1

(

k) Prepare and monitor site filler material control l procedures. lR6 l

1) Supervise and direct testing and applied research l programs required to resolve site construction materials I and welding problems. l l

l 3.1.3 The Quality Assurance Consulting Engineer reports to the Vice l President Materials Engineering cod Quality Assurance. He is responsible for conducting audits of the Ebasco Quality Assurance function to determine and report its compliance with the Ebasco Quality Program requirements.

l l

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sin.s tsrei no.or pace 10 o, 13 ESA5CO SERVICE 5 HUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCoRPom ATED HOUSTON LIGHTING AND POWER COMPANY QA-I-2 SOUTH TEXA5 PROJECT d ELECTRIC GENERATING STATION UNITS 1 & 2 5

> aevisiou ORGANIZATION AND RESPONSIBILITIES cart 3/26/84

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3.1.4 The Materials Engineering Laboratory perf orms field nondestructive examination services at the construction site. lR6 The Laboratory is administered by a Manager who reports to the Vice President Materials Engineering and Quality Assurance.

4.0 CONSTRUCTION Primary responsibility for construction rests with the Vice President of Construction (see Figure I-2.4). The Construction Department has the prime responsibility for the perf ormance of quality construction.

4.1 The Ebasco Construction Manager reports to the Vice President of Construction and is responsible for overall supervision and coordination of all construction activities and services. The Ebasco Construction Manager has stop work authority.

4.2 The Manager of Construction Services reports to the Vice President of Construction and is responsible for general supervision of Construction Department Cyality Program activities and of the Construction Engineering Group.

lR6 4.3 The Site Manager reports to the Ebasco Construction Manager. The Site Manager has the responsibility for the direction and coordination of IR6 all on-site activities related to construction. The Site Manager has I stop work authority.

l 4.4 The Project Superintendent reports to the Site Manager and is j responsible for performing general site supervision of construction in l accordance with drawings, specifications, and contractual obligations.

The Project Superintendent has stop work authority.

4.5 The Unit Superintendents report to the Project Superintendent.

Each Unit Superintendent is individually responsible for the Ebasco construction operations and activities within his assigned unit of the plant. The Unit Superintendents have stop work authority.

4.6 The Assistant Superintendents report to the Unit Superintendents.

) The Assistant Superintendents will manage all phases of construction l

within disciplines assigned, including field engineering and cost i control, to assure that the work accomplished is coepleted within the budget and in accordance with all applicable installation specifications. (R6 l

l

sim.s tsven io.or poor 11 or 13 ESA5CO SERVICES NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INcon Pom ATEC HOU5 TON LIGHTING AND POWER COMPANY QA-I-2 SOUTH TEXA5 PROJECT I ELECTRIC GENERATING STATION UNITS 1 & 2

> 5 acvisiou ORGANIZATION AND RESIONSIBILITIES ears 3/26/84

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4.7 The Discipline Superintendents report to the Assistant Superintendents. Each Discipline Superintendent will direct, coordinate, and monitor all work performance within the assigned discipline to assure l that work proceeds in accordance with approved plans, specifications, and lR6 the Quality Assurance Program. l 4.8 The Labor Relations Representative reports to the Site Manager. The Labor Relations Representative is conversant with the general provisions of the Project Stabilizatien Agreement. The Labor Relations Representative participates in settlement of local labor disputes, assists in preparation for arbitration proceedings related to operations at the site, and advises the Project Superintendent on local labor relation matters.

4.9 The Senior Resident Engineer reports to the Site Hansger and is responsible for administering, coordinating, and supervising all Site Construction Engineering and technical activities, for interpretation of design documents and specifications, and for furnishing assistance to Ebasco site personnel as required. The Senior Resident Engineer has stop work authority.

lR6 4.10 The Construction Indirects Superintendent reports to the Project Superintendent. The Construction Indirects Superintendent is responsible for the direction of all support craf t forces on the project, and the supply, maintenance, and repair of major project construction equipment.

The Construction Indirects Superintendent has stop work authority.

4.11 The Construction Services Manager reports to the Site Manager and will be responsible for providing and establishing adequate and efficient security, safety, and training and development programs.

4.12 The Safety Supervisor reports to the Site Manager. The Safety lR6 Supervisor is responsible for establishing and enforcing the site safety and industrial hygiene programs in accordance with established policy and all federal and state regulations, as well as any other criteria necessary to insure the safety of site personnel.

4.13 The Administrative Manager reports to the Site Manager. The Administrative Manager is responsible for providing the necessary accounting, timekeeping, and computer support, as required to support the lR6 construction effort.

lR6 l

sios.sistp n.sz pace 12 ,,13 EBASCO SERVICES NUCLEAP QUALITY ASSURANCE PROGRAM MANUAL SECTION mcompon ATco MOU$ TON LIGHTING AND POWER COMPANY QA-I-2 SOUTH TEXA5 PROJECT I ELECTRIC GENERATING STATION UNITS 1 & 2 5 g newsios _

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ORGANIZATION AND RESPONSIBILITIES oare 3/26/84 4.14 The Outlying Facilities Superintendent reports to the Project Superintendent and is responsible for supervising and coordinating in an efficient manner all construction activities of all the outlying plant facilities, including the Diesel Generating Building in Unit I and Unit 2. The Outlying Facilities Superintendent has stop work authority.

4.15 The Site Welding Superintendent reports to the Chief Materials l Applications Engineer or his designee. Ihe Site Welding Superintendent lR6 receives his day-to-day and technical direction from the Materials l Applications Department in New York.

4.16 The System Completion Superintendent reports to the Project Superintendent and is responsible for systems completion. He ensures construction progress in support of systems completion. This includes coordination of all prestart-up planning and scheduling, and conducting construction test efforts.

4.17 The Second Shift Superintendent reports to the Project Superintendent and is responsible for performing general site supervision of construction in accordance with drawings, specifications, and contractual obligations for all activities performed on the second shift. The Second Shift Superintendent has stop work authority.

lR6 5.0 INTERFACE Interf ace, as applicable, is so illustrated by Figure I-2.9 at the end of this Section and is explained by appropriate and applicable South Texas Project documents.

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6.0 ORGANIZATION CHARTS I i

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! PERSONNEL INDOCTRINATION AND TRAINING DATE 3NM I PROGRAM IN QUALITY ASSURANCE cmr,...u p ....... ..... ..

1.0 SCOPE This Section describes the program for indoctrination and training of Ebasco personnel engaged in activities affecting quality with respect to the requirements of this Manual and its supporting principal implementing lR6 procedures. Ebasco personnel shall be indoctrinated and trained, as necessary, to assure that proficiency is achieved and maintained in those parts of the Quality Assurance Program as it applies to the individual's responsibility.

2.0 GENERAL The Indoctrination and Training Program is a combined effort of the Ebasco l organizations implementing any portion of this Manual and its principal lR6 implementing procedures, and the Quality Assurance organization. The l Construction, Materials Applications, and Quality Assurance organizations are l responsible to schedule, indoctrinate, and train their personnel, and to record this indoctrination and training, unless otherwise denoted by project con:mitments.

3.0 PROGRAM REQUIREMENTS 3.1 Written lessons shall contain the substance of the indoctrination lR6 and training program. These lessons shall address one or more quality-related topics, to achieve one or more stated educational objectives. The training will be conducted by trained supervisors or their designees within the Construction and Materials Applications l organizations, and by a Quality Assurance Education Specialist or I designee when the need arises. A Quality Assurance Education Specialist I will be responsible for training the selected instructors within the IR6 other Ebasco organizations in methods of conducting required quality l assurance training. l l

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s ce.s tstpi to.s2 PAGE oF 3 i EBASCO SERVICES HUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION twcomponATEo HOUSTON LIGHTING AND POWER COMPANY QA-I-3 SOUTH TEXA5 PROJECT i ELECTRIC GENERATING STATION UNITS 1 & 2 3

> R E VisiO N

{ PERSONNEL INDOCTRINATION AND TRAINING DATE 3/26/84

% c..a n .u p . ............. PROGRAM IN QUALITY ASSURANCE 3.2 For Construction, Quality Assurance, and Materials Applications, l training lessons ara maintained by each organization respectively. l The training lessons relate to activities the personnel shall be l pe rforming . For Construction and Materials Applications, a responsible l person within the respective organization shall determine the training l requirements for each individual based on that individual's assigned l responsibilities and past experience. Within the Quality Assurance lR6 l

organization, a Quality Assurance Education Specialist shall be l responsible for determination of an individual's training requirements l based upon that individual's assigned responsibilities and past l experience, ar applicable. Training lessons are updated, when required, I and reflect any changes in the program. Copies of these training lessons I shall be kept on file by the respective organization. Quality-a f fected I training will reflect project requirements.

4.0 RECORDS ,

l Individual training files for personnel in the Construction, Quality l Assurance, and Materials Applications organizations receiving indoctrination lR6 and training in accordance with this program's requirements shall be l r maintained by each affected organization. These records will indicate, as l applicable, the subject matter, the training received, attendance date, time duration, instructor, and special qualifications or restrictions, if any.

5.0 SCHEDULING Scheduling training of applicable organization personnel will be coordinated l with a Quality Assurance Education Specialist where necessary. As new lR6 personnel are added to the South Texas Project within an organization, l appropriate indoctrination and training sessions will be scheduled based on the requirements of this Manual.

6.0 PROGRAM UPDATING This indoctrination and training program is subject to continuous development f

to broaden and improve its effectiveness. A Quality Assurance Education l Specialist will hold periodic discussions with those groups involved with the l training program to coordinate recommendations for updating. A Quality lR6 Assurance Education Specialist is responsible for updating the program for the l Qus11ty Assurance organization. l 4

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{ ELECTRIL GENERATING STATION UNITS 1 & 2 R E VI SIO N 3

E PERSONNEL INDOCTRINATION AND TRAINING DATE 3/26/84

% ..dw .u . . p........... PROGRAM IN QUALITY ASSURANCE 7.0 ADMINISTRATION 7.1 The Quality Assurance Engineering Quality Resource and Training l Management Group shall have overall responsibility for administrating the lR6 quality assurance training program. It shall provide technical expertise l for developing necessary programs and review existing programs for currency.

7.2 Management of each Ebasco organization is responsible to assure that I the appropriate personnel attend the training program (s) for which they l are scheduled. l l

8.0 TRAINING, QUALIFICATION, AND CERTIFICATION OF QUALITY CONTROL PERSONNEL l l

Training, qualification, and certification of Site Quality Control inspection I personnel shall be in accordance with written procedures. The Quality Control l Site Supervisor shall coordinate with a Quality Assurance Education Specialist lR6 regarding the training, qualification, and certification of Quality Control l personnel. Qualification records for all Quality Control personnel assigned l to the South Texas Project site shall be maintained by a Quality Assurance l Education Specialist at the site. These records will be audited initially by l the Chief Quality Assurance Engineer, or his designee, for compliance with the l qualification requirements and tnereaf ter on an annual basis by auditors from l the Site Quality Assurance organization. Any deficiencies detected shall be l reported in writing by the Quality Assurance Site Supervisor, or his designee, l to the Quality Control Site Supervisor for resolution. Pending resolution of the deficiency, the individual shall be restrained from performing any Quality Control activities.

9.0 AUDITS Audits of indoctrination and training activities shall be performed to assure compliance with this Program. Such audits shall be performed in accordance with the requirements of Section QA-III-9 of this Manual.

sios.s esim to or pace 1 or 4 EBASCO SERVICES NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCORPORATED HOU$ TON LIGHTING AND POWER COMPANY SOUTH TEXA5 PROJECT QA-I-6 -

I ELECTRIC GENERATING STATION UNITS 1 & 2

> Re vision 3

QUALITY ASSURANCE RECORDS DATE

....,n..g,...............

1.0 SCOPE This Section covers the requirements and guidelines for the collection, filing, storage, disposition, and maintenance of lifetime and nonpermanent quality assurance records associated with the construction and maintenance of nuclear power plants. lR6 2.0 RESPONSIBILITY It shall be the responsibility of Ebasco to maintain quality assurance (QA) lR6 records in accordance with the requirements of this Section until such time as those records are turned over to the Client or his designee for permanent lR6 storage. The HL&P STP - RMS Site Records Center is the principal and final records repository. All QA records shall be accessible to the Client or his lR6 designee until such time as they are turned over to the Client or his designee. l 3.0 QUALITY ASSURANCE RE(X)RDS SYSTEM Each organization within Ebasco (including but not limited to the Construction lR6 and Quality Assurance organizations) that participates in the generation, I collection, filing, storage, disposition, or maintenance of quality assurance records shall establish a written quality assurance record system applicable to the function (s) perf ormed by that organization. These written procedures shall provide that each completed quality assurance record shall be transmitted by the organization generating the records to the Ebasco Site Quality Records group for final review and transmittal to the Client or his designee. This system shall be implemented and enforced in accordance with the requirements of the following paragraphs that apply to the function (s) of that organization.

4.0 GENERATION OF QUALITY ASSURANCE RE(X)RDS 4.1 The QA records to be generated shall be specified in the applicable design specifications, construction, maintenance, test, or inspection lR6 procedures, and other documents as necessary.

4.2 All QA records shall be dated and signed or otherwise authenticated.

4.3 QA records shall be indexed. The indexing system shall include as a lR6 minimum:

4.3.1 QA records retention times (retention period begins on date of satisfactory operation of items).

. I

sios.s istm so.e pace 2 or 4 ESA5CO SERVICE 5 NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL S ECTIO N INCompOMATEo HOUSTON UGHTING AND POWER COMPANY OA-I-6 SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION UNIT 51 & 2

, vis,ou 3 E

I QUALITY ASSURANCE RECORDS DATE 3/26/84

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4.3.2 location of storage area.

4.3.3 Location of QA records within storage area. lR6 4.4 All QA records shall be distributed and handled in accordance with written instructions.

4.5 There shall be sufficient information in the QA records to permit identification between the records and the item (s) or activity to which it applies. identification of QA records may be by purchase order lR6 number, system, or any means that permits accurate traceability.

4.6 All QA records shall be classified as " lifetime" or " nonpermanent."

4.7 When QA records are corrected or supplemented they shall be reviewed or approved by the organization that originated the records. All corrections and supplements shall bear dates and authorized signatures or initials. lR6 4.8 Inspection and test records shall contain the following, as applicable:

a) The type of observation. l lR6 b) Evidence of completing and verifying an inspection or test I operation.

c) The date and results of the inspection or test.

d) Information related to nonconformances.

e) Inspector or data recorder identification.

f) Evidence of the acceptability of the results. lR6 5.0 RECEIPT OF OUALITY ASSURANCE RECORDS lR6 5.1 A system shall be established for receipt of QA records at the Site which shall include:

5.1.1 A checklist designating the required QA records.

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sios.s istp> so.or ecoc 3 or 4 EBASCO SERYlCE5 NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCoRPoR ATED HOUSTON UGHTING AND POWER COMPANY OA-14 SOUTH TEXA5 PROJECT I ELECTRIC GENERATING STATION UNITS 1 & 2 g nevisio N __ 3 k QUALITY ASSURANCE RECORDS o*TE 3/26/84 5.1.2 A record of QA records received.

5.1.3 Written procedures for receipt and inspection of incoming Site QA records.

These quality assurance records shall be maintained by Site Quality l Records and audited by Site Quality Assurance to assure that they are lR6 maintained properly until turned over to the Client or his designee. l 5.2 The system described in Paragraph 5.1 shall permit an accurate assessment of the status of the QA records during the receiving process.

6.0 TEMPORARY STORAGE, PRESERVATION, AND SAFEKEEPING 6.1 QA records shall be stored in accordance with a written procedure which shall require or include the following: l l

6.1.1 Description of storage facility, if other than a dual IR6 facility. l l

6.1.2 Description of filing system to be used. l 6.1.3 Method for verifying that QA records received are in agreement with transmittal documents and pre-established records checklist and that the QA records are legible. lR6 6.1.4 Rules governing access to files.

6.1.4.1 A list shall be generated designating those personnel who shall have access to the files.

6.1.5 Method for maintaining control of QA records removed from l storage. Such method shall provide for signing out of QA records lR6 removed from storage or other appropriate means of maintaining l control of the records removed. l 6.1.6 Method of filing supplemental information and disposing of obsolete QA records. Supplemental information shall be filed with the original documents whenever practical.

6.2 A custodian (or custodians) shall be designated to implement the lR6 requirements of Paragraph 6.1.

, I

._ _ l

slM.s tsTP110.02 PAGE 4 or 4 ESA5CO SERVICES NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INcomPomATEo HOUSTON UGHTING AND POWER COMPANY SOUTH TEXA5 PROJECT OA-I-6 I ELECTRIC GENERATING STATION UNITS 1 & 2

> 3 R E VI SIO N 2

I

< .... .. N.o , g ....... ........ QUALITY ASSURANCE RECORDS DATE 3/26/84 6.3 QA records may be stored within a temporary storage facility if they lR6 are protected from damage and loss. This shall include: l 6.3.1 Storage within fire-resistant cabinets with a four-hour Underwriters' rating or a satisfactory alternative.

6.3.2 Protection from condensation.

6.3.3 Disallowance of loose documents. Records shall be attached to binders, placed in folders, or similarly maintained.

6.3.4 Specially processed QA records such as radiographs, lR6 microfilm, etc, shall be stored and protected in accordance with the manufacturer's recommendations.

6.4 A satisfactory alternative to the requirements of Paragraph 6.3 is maintenance of duplicate QA records stored in a separate remote location.

6.5 Audits shall be performed by Site Quality Assurance to assure the l effectiveness of the storage system, and shall include: lR6 I

6.5.1 Verification that logged-in QA records are available in their l proper location and in good condition.

6.5.2 Audit results shall be documented and discrepancies shall be

! reaudited to assure their correction.

I 6.6 The storage systems shall provide for accurate retrieval of QA records without undue delay.

7.0 DISPOSITION OF QA RECORDS l

l Upon transfer of QA records, the Client or his designee shall acknowledge in lR6 writing the receipt of the particular QA records.

1

pace 3 stos.s isTm io ez or EBASCO SERVICES NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCompoRATED HOU$ TON LIGHTING AND POWER COMPANY QA-III-l SDUTH TEXAS PROJECT I ELECTRIC GENERATING STATION UNITS 1 & 2 3

> RE VI SIO N MM INSTRUCTIONS, PROCEDURES, AND DRAWINGS on,c DUM

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1.0 SCOPE Activities affecting quality perf ormed at the construction site shall be described in written instructions, procedures, or drawings that have been developed in accordance with the requirements of this Section. Departmental procedures which describe the manner in which activities affecting quality are to be accomplished are part of the Ebasco Quality Program.

2.0 RESPONSIBILITIES 2.1 Where the Ebasco Nuclear Quality Assurance Manual designates an individual or organization with the responsibility of performing quality-related functions at the construction site, such functions shall be pe.rormed in accordance with written instructions, procedures, or drawings that have been developed by the organization performing the function. These instructions, procedures, and drawings shall establish the manner of performing the activity in accordance with the requirements of the Ebasco Nuclear Quality Assurance Program Manual and of the organization performing the activity.

2.2 When documented evidence is required for the satisfactory perf ormance of particular activities, checklists, forms, and/or other appropriate means shall be utilized to provide this evidence. Such documents shall be signed and dated by the party perf orming the activity.

2.3 Ebasco procedures, instructions, or drawings describing activities affecting quality which are qualitative or quantitative in nature (ie, inspections or tests) shall contain or reference criteria for determining that such activities have been satisfactorily accomplished.

lR6 3.0 DEVELOPMENT OF INSTRUCTIONS, PROCEDURES, AND DRAWINGS 3.1 Instructions, procedures, or drawings for activities affecting l quality at the construction site shall be developed by the Construction lR6 and Site Quality Assurance organizations for their respective l quality-related functions. The Ebasco Nuclear Quality Assurance Program Manual shall be used as a guideline for their development. In addition, all Site Quality Control Procedures shall include at least the following:

a) Identification of characteristics to be inspected.

b) Identification of the individuals or groups responsible for performing the inspection operation.

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st os.s isre> io.o2 **cc 2 ,, 3 EBASCO SERVICES MUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCoRPORArto MOU$ TON UGHTING AND POWER COMPANY QA-III --I SOUTH TEXAS PROJECT d ELECTRIC GENERATING STATION UNITS 1 & 2

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INSTRUCTIONS, PROCEDURES, AND DRAWINGS care 3/26/84 c) Acceptance and rejection criteria.

d) A description of the method of inspection.

e) Verification of completion and certification of inspection.

f) A record of the results of the inspection operation.

3.2 The Ebasco Engineering Development and Standards Department shall l develop company instructions and procedures of categories, such as l Nuclear (N), pertaining to quality-related functions. lR6 1

3.3 Individual departments / disciplines shall be responsible for the I development of their own intradepartmental/ discipline instructions, procedures, or drawings that establish the methods for performing quality-related functions. The Ebasco Engineering Development and lR6 Standards Department will provide, upon request, guidance and assistance l in developing the documents.

3.4 If so requested by a department, Quality Assurance Engineering shall act in an advisory capacity during the preparation of internal Ebasco procedures.

3.5 All procedures, instructions, and drawings for activities affecting quality shall be identified, dated, and shall provide authorized signature (s) of approval.

3.6 To assure that all Ebasco Quality Control and Construction procedures and instructions comply with this manual, site-specific requirements, and applicable codes and regulatory requirements, they shall be submitted for review and acceptance to Ebasco Site Quality Assurance prior to implementation. When required by the Contract, Quality Assurance, Quality Control, Special Process, and Construction Procedures and instructions shall also be submitted to the Client or his designee for acceptance prior to implementation.

4.0 DISTRIBUTION AND CONTROL 4.1 Each Ebasco department shall be responsible for maintaining and enforcing a written system for the distribution and control of that organization's instructions, procedures, and drawings (other than design; ie, rigging drawings) for activities affecting quality. This system shall provide for at least the following:

3 3 6100.6 (ST P) 10.82 PAGE OF EBA5CO SERVICES HUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCORPORATED HOUSTON UGHTING AND POWER COMPANY QA-III-l SOUTH TEXAS PROJECT I ELECTRIC GENERATING STATION UNITS 1 & 2 3

> R E VI SIO N 3/26/84

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INSTRUCTIONS, PROCEDURES , AND DRAWINGS o,,,

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4.1.1 Copies of these documents and revisions thereto shall be distributed to all appropriate department personnel in a timely manner.

4.1.2 Outdated and/or superseded documents shall either be collected or shall be clearly marked as superseded to avoid inadvertent use.

4.1.3 A file of the latest revision of these documents shall be maintained. Such a file shall be readily available to all affected personnel.

4.1.4 A log of the documents shall be maintained. The log shall indicate as a minimum:

a) Title of document.

b) Document identification number.

c) latest revision number and date of document presently in use.

4.2 A historical file of all revisions and changes to instructions, l procedures, and drawings shall be maintained by the organization I responsible for such documents or as may be described in the applicable l procedures. l l

4.3 All approved Ebasco site-generated field sketches, construction l procc-dures, quality control procedures, and special process procedures I shall be transmitted to the Client or his designee for distribution and I control in accordance with Section QA-III-2 of this Manual. l lR6 5.0 CHANGES TO DOCUMENTS l l

Changes to Ebasco documents shall be reviewed and approved by the same I organization responsible for the original document when those changes affect l the original reviewer, unless delegated in writing by the originating I organization to another responsible organizatitu. The reviewing organization I shall have access to pertinent background information upon which to base their I approval and shall have adequate understanding of the requirements and intent I of the original document. l

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M 6m.,N a..u , pp u.u n.s,.u . DOCUMENT CONTROL care 3/26/84 1.0 SCOPE l

1 his Section of the Manual establishes the requirements for the control of all l project documents used by Ebasco which have an effect on quality-related I activities. Rese requirements apply to those documents such as l

specifications and drawings, as well as site instructions and site procedures, l which control or direct activities affecting quality. l l

2.0 RESPONSIBILITIES l

l 2.1 he corresponding Department Heads or their designees shall be l responsible for furnishing the Client or his designee with the latest of l all Ebasco site-generated field sketches, construction procedures, l quality control procedures, and special process procedures. l l

2.2 he Client or his designee shall be responsible for the distribution l and control of all construction site design documents, drawings, l specifications, construction procedures, quality control procedures, and l special process procedures. l lR6 2.3 The Quality Assurance Site Supervisor or his designee shall be l responsible f or the distribution and control of site generated quality l assurance procedures and instructions.

l l

3.0 ISSUANCE OF CDNTROLLED DOCUMENTS l l

3.1 Establishment of Document Control Stations l 1

3.1.1 Document control stations shall be established and maintained l by the Client or his designee. l l

3.1.2 Requests by Ebasco for the establishment of new or deletion l of existing document control stations for the distribution of l i

controlled documents shall be submitted by the corresponding l I Department Head, Unit Superintendents, or Project Superintendent to l the Client or his designee. l l

3.1. 3 Requests by Ebasco for additions or deletions of documents l issued to an established document control station shall be submitted l l to the Client or his designee. l l

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{ ELECTRIC GENERATING STATION UNITS 1 & 2 R E VISIO N 4

E i DOCUMENT CONTROL oaTE 3/26/84

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3.2 Design Documents, Drawings, and Specifications l I

3.2.1 'Ihe Client or his designee shall furnish, distribute, and I control all design documents, drawings, and specifications to the l established document control stations in accordance with the l Client's or his designee's written procedures, l I

3.2.2 Ebasco prepared field sketches shall be transmitted by the l Senior Resident Engineer to the Client or his designee for l distribution to the established document control stations by the l Client or his designee. l l

3.2.3 Ebasco personnel shall use during their work activities the l latest design documents, drawings, and specifications as provided by I the Client or his designee at the appropriate document control l stations and comply with the approved Ebasco site document control l procedure. l l

3.3 Ebasco Intradepartmental/ Discipline Instructions and Procedures l lR6 3.3.1 Intradepartmental/ Discipline instructions and procedures l shall be issued and controlled in accordance with Section QA-III-l l of this Manual. l l

3.3.2 Quality Assurance procedures describing auditing l responsibilities of Site Quality Assurance shall be distributed l and controlled at the construction site in " book" form. A master l file shall be maintained of all procedures and revisions. A l master list shall be maintained indicating each person or l organization to whom a book of procedures has been issued. New or l revised procedures will be issued to each holder of a procedure l

" book". A receipt system shall be used which requires written I acknowledgment of distributed procedures, l I

3.4 Ebasco Site-Generated Procedures and Instructions l l

Ebasco site-generated construction, special process, and quality l control procedures and instructions shall be transmitted to the l Client or his designee for distribution to the established document l control stations. l

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! ELECTRIC GENERATING STATION UNIT $ 1 & 2

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3.5 Field Change Requests l l

3.5.1 A Field Change Request shall be submitted to the Senior 1 Resident Engineer from applicable site personnel whenever conditions l arise which may warrant consideration by the Client or his designee l of a change in the specified design. l l

3.5.2 The Senior Resident Engineer shall submit the proposed Field l Change Request to the Client or his designee for evaluation, l disposition, distribution, and control by the Client or his designee l in accordance with the Client's or his designee's written procedures. l l

3.6 Field Change Notice l l

3.6.1 A " Field Change Notice" shall be generated by the Senior l Resident Engineer as is allowed by the design specification and l shall be approved, issued, and controlled by the Senior Resident l Engineer in accordance with approved site procedures. l l

3.6.2 A Field Change Notice (FCN) is to provide construction with a lR6 method of documenting conditions (not tolerances) that are within I criteria allowed by the applicable specifications. An FCN shall not l be used in lieu of a Nonconformance Report (NCR) or a Field Change l Request (FCR). l 1

4.0 CHANCES TO DOCUMENTS l l

Changes to Ebasco documents shall be distributed in the same manner as the l original document. Revised documents shall be controlled in accordance with l the requirements of this Section and/or written procedures in order to avoid I inadvertent use of outdated documents. l I

5.0 QUALITY ASSURANCE RECORDS l l

Quality Assurance records shall be maintained by Site Quality Records which l shall be audited by Site Quality Assurance to assure that they are maintained l properly. l 1

5.1 The system for control and retrieval of Quality Assurance records at I the site shall be in accordance with Section QA-I-6 of this Manual. l

68 09 5 (STP) 10.92 4 4 POGE OF EsASCO SERVICES HUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCORPORATED HOU5 TON LIGHTING AND POWER COMPANY QA-III-2 SOUTH TEXA5 PROJECT d ELECTRIC GENERATING STATION UNITS 1 & 2 4 R E VI SIO N gh DOCUMENT CONTROL o,yg 3/26/84

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6.0 AUDITS l l

Ebasco Site Quality Assurance shall audit the Client's or his designee's lR6 control and distribution of Ebasco generated construction, special process, l and quality control procedures and irstructions in accordance with the l requirements of Section QA-III-9 of this Manual. l

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NONCONFORMANCES care 3/26/84 1.0 SCOPE This Section establishes the requirements for the identification, control, and disposition of items or services found to be in nonconformance with the applicable requirements at the construction site. All activities described in lR6 this Section shall be performed in accordance with written instructions and/or procedures.

lR6

2. 0 CONSTRUCTION SITE NON00NFORMANCES 2.1 Nonconformances at the construction site may be detected by Ebasco Site Quality Control, Site Quality Assurance, or Construction. All nonconformances detected shall be reported to the Quality Assurance Site Supervisor and/or the Quality Control Site Supervisor or their designees. lR6 2.2 Quality Control procedures shall require that all nonconforming items shall be clearly marked or tagged as nonconforming and shall be segregated when possible.

2.3 The Quality Assurance Site Supervisor, the Quality Control Site Supervisor, or their designees shall document nonconformances detected by or reported to them by issuing a South Texas Project Site l Nonconformance Report. A preliminary assessment of the severity of the I nonconformance shall be made in accordsnee with Company Procedure N-23 or l approved site procedure. The final responsibility for evaluation of all l nonconformances for possible reportability rests with the Client or his l designee. lR6 I

, 2.4 The Nonconformance Report shall then be reviewed and processed in l l accordance with Paragraph 4.0 below. l l

2.5 Af ter processing of the Nonconformance Report , the Quality Assurance l l Site Supervisor or his designee shall distribute copies of the reviewed

! and evaluated report in accordance with internal Site Quality Assurance procedures.

2.6 The Quality Assurance Site Supervisor and the Quality Control Site Supervisor or their designees from the Site Quality Assurance lR6 organization shall verify by audits, reinspections, or other appropriate I means that the necessary corrective actions are taken.

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l M...u..p ....... ........ NONCONFORMANCES care 3/26/84 3.0 REINSPECTION lR6 3.1 For nonconformances detected at the construction site, the Quality Control Site Supervisor or his designee shall assure that reinspection is performed on all items and services reported as nonconforming.

Reinspection shall be performed in accordance with the requirements of the governing Code (s) and in accordance with requirements at least as stringent as those by which the nonconformance was detected. He shall document the satisfactory correction or resolution of all nonconformances on the dispositioned Nonconformance Report. This documentation shall provide sufficient detailed information for as-built records.

3.1.3 Nonconformances not corrected in accordance with the requirements of the approved disposition to the Nonconformance lR6 Report shall not be accepted by Site Quality Control. Items or services shall not be accepted by Site Quality Control until such time as the appropriate corrective action has been accomplished.

, 4.0 REVIEW OF NON00NFORMANCE REPORTS 4.1 Upon receipt or initiation of a Nonconformance Report, the Quality Assurance Site Supervisor or his designee from the Site Quality Assurance l organization shall perform the following functions in accordance with QA l procedures and/or instructions: l l

4.1.1 Log-in the report and record a unique identifying number on l the report. l l

l 4.1.2 Route the report to the Senior Resident Engineer or his l designee who shall review the report, and, where necessary, contact l the Client or his designee to discuss the suitability of the l recommended disposition. l I

lR6 4.1.3 Receive the report with Ebasco Resident Engineering's l recommended disposition documented thereon and review it for l concurrence. l l 1 l 4.1.4 When required, transmit the report to the Client or his l l designee for evaluation of the disposition of the nonconformance. I l Dispositions for all nonconformances to the design specifications or I other documents originally requiring review and approval of the l

Client or his designee, must have the review and approval of l l the Client or his designee prior to implementation unless otherwise l

! permitted by approved procedures. l i

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sios.s astri c.sa pace 3 ,, 4 ESASCO SERVICES NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCORPORATED HOU5 TON LIGHTING AND POWER COMPANY QA-III-6 SOUTH TEXA5 PROJECT I ELECTRIC GENERATING STATION UNITS 1 & 2 3 R E VI SIO N MM

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NON00NFORMANCES oare 3/26/84 4.2 Cognizant Engineer (s) shall review and evaluate the Nonconformance l Report, decide on the suitability of the recommended disposition, and l make appropriate entries on the report. The report shall then be l returned to the Quality Assurance Site Supervisor or his designee. l l

4.3 Upon receipt of the reviewed and evaluated Nonconformance Report, I the Quality Assurance Site Supervisor or his designee shall log-in lR6 results of the review and distribute copies of the report as necessary l in accordance with approved procedures. l l

4.4 The Quality Assurance Site Supervisor or his designee shall maintain l on file, copies of all open Nonconformance Reports generated in l accordance with the requirements of this Section. l

5. 0 DEFICIENCY NOTICES 5.1 Deficiencies in the quality of items and services detected at the construction site which can be corrected by reworking or by standard repair procedures (approved by the Client or his designee) during the lR6 normal course of construction shall be documented on a Deficiency l Notice. Copies of all Deficiency Notices shall be transmitted to the Quality Control Site Supervisor or his designee who will initiate Nonconformance Reports based on information given in the Deficiency Notices when he determinec that this action is necessary. In this case, the Deficiency Notice becomes a part of the Nonconformance Report and only the Nonconformance Report is required to be resolved.

l 5.2 Items discovered to be out-of-tolerance or not to specification at routine checkpoints of an inspection process shall not be considered as a nonconformance, provided:

a) The condition is corrected prior to acceptance of the work.

b) The work does not proceed beyond the checkpoint until the correction is made, c) The out-of-tolerance condition does not reflect on work previously accepted.

d) No violation of procedure or Code is evident.

Damage which would affect the integrity of an item shall be classified as a nonconformance and processed accordingly.

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l M NONCONFORMANCES care 3/26/84

...........f............m 5.3 he processing of Deficiency Notices chall be detailed in approved Site Quality Control procedures.

6.0 TREND ANALYSIS OF NONCDNFORMANCE REPORTS AND DEFICIENCY NOTICES l l

6.1 Ebasco 's Corporate Trending l 1

Copies of Nonconformance Reports from the sources mentioned above l shall be submitted to the Quality Assurance Engineering Supervisor I of Auditing. The Quality Assurance Engineering Supervisor of l Auditing subsequently receives the Nonconformance Report and makes l an analysis of the available quality assurance data with respect to l quality trends. The trend analysis and distribution of subsequent lR6 reports shall be made in accordance with the requirements of Quality l Assurance Procedure QA-D.3. I I

6.2 Client 's Trending l l

, Copies of Nonconformance Reports (NCR's) and Deficiency Notices l l (DN's) from the sources mentioned above shall be transmitted to the l

Client 's Quality Systems / Administration (QS/A). The Client's QS/A l l

is responsible for the South Texas Project Trend Program activity in l accordance with their procedure (s). l 7.0 RE CORDS l Nonconformance Reports shall be maintained in accordance with Section QA-I-6 of this Manual and/or approved Site Quality Assurance Instructions. lR6 l

l l

csos.s isvei ts es pace 1 4 or EBASCO SERVICE 5 NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCoRPoRATEo HOUSTON UGNTING AND POWER COMPANY QA-III-7 SOUTH TEXAS PROJECT d ELECTRIC GENERATING STATION UNITS 1 & 2 3 REvfSION E

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1.0 SCOPE This Section establishes the requirements for the identification, analysis, and implementation of corrective action for safety-related items and services. The Section applies to activities perf ormed at the construction site.

2.0 GENERAL 2.1 Corrective action shall be required for identified and documented nonconformance(s) associated with safety-related items and services.

2.2 The need for corrective action may be identified f rom the following sources :

a) Inspection activities perf ormed by Site Quality Control, b) Site Quality Records document reviews. l l

c) Quality Assurance audits performed by the Quality Assurance l organization in accordance with Section QA-III-9 of this Manual. l I

d) Audits of Ebasco performed by the Client or his designee or l regulatory bodies. l lR6 e) Nonconformances detected at '.he construction site as described l in Section QA-III-6 of this Manual. l l

f) Audits of the Quality Assurance and Materials Applications l organizations performed by the Management Audit Committee. l l

g) Surveillances performed by Site Quality Assurance. l 2.3 Determination and review of corrective action items shall be made as early as possible in order to preclude the possible repetition of deficiencies.

2.4 During the review of all corrective action items, consideration shall be given to the training of personnel if it is determined that this was a cause of the deficiency.

2.5 Dissemination of corrective action information to responsible individuals shall be performed in a minimum length of time.

1 sim.s tsT A to.82 PAGE or ESA5CO SERVICES HUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION mconPon ATEo MOU$ TON LIGHTING AND POWER COMPANY QA-III-7 SOUTH TEXA5 PROJECT f ELECTRIC GENERATING STATION UNITS 1 & 2 3 CORRECTIVE ACTION oars 3/26/d4

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2.6 At the discretion of the Quality Assurance Site Supervisor or his designee from the Site Quality Assurance organization, for corrective lR6 action items identified per Paragraph 3.2 of this Section, a corrective action document may be issued. This document shall be used when deficiencies detected are not isolated cases and when they are of l sufficient magnitude to warrant a documented supervisory review in l accordance with approved Quality Assurance procedures or instructions. l This document goes.beyond the standard audit action response required by lR6 audit reports. l l

2.7 For programmatic deficiencies detected by Site Quality Assurance, I the maximum length of time for corrective action response shall be 20 working days from the receipt of notice of deficiency or nonconformance.

The maximum implementation time shall be 20 working days from the acceptance of corrective action response, unless otherwise approved by the Chief Quality Assurance Engineer or his designee from the Quality Assurance Engineerfr.3 3epartment.

2.8 It shall be thc responsibility of the Quality Assurance Site Supervisor or his designee from the Site Quality Assurance organization lR6 to assure that all required corrective action is implemented in a timely manner.

2.9 A preliminary assessment of the severity of deficiencies and I nonconformances detected shall be made in accordance with Company l Procedure N-23 or approved site procedures. The final responsibility for l evaluation of all nonconformances for possible reportability rests with lR6 the Client or his designee. Reporting of nonconformances in accordance l with 10CFR50.55e and its subsequent evaluation will be the responsibility I of the Client or his designee. l 3.0 DETERMINATION AND IMPLEMENTATION METHODS 3.1 Nonconformance Reports Generated at the Construction Site 3.1.1 Site Quality Control shall perform direct inspection of activities at the construction site as required by Section QA-III-ll of this Manual.

3.1.2 Nonconformances noted during these inspection activities shall be documented on a Nonconformance Report in accordance with Section QA-III-6 of this Manual. Site Quality Control shall verify that the corrective action which has been stipulated on the completed form is implemented. Site Quality Control shall maintain a log of all required corrective action and shall review this periodically to assure the resolution of deficiencies and implementation of required corrective action.

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, SOUTH TEXA5 PROJECT

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> R E VI SIO N CORRECTIVE ACTION onre 3/26/84

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3.2 Site Quality Assurance Audits Site Quality Assurance shall perf orm audits of activities perf ormed lR6 at the construction site as required by Section QA-III-9 of this Manual. Site Quality Assurance shall also perf orm follow up action as described in Section QA-III-9 to assure that corrective action, if required, has been accomplished. If disagreement about the type or effectiveness of corrective action exists, the problem shall be reviewed by successively higher levels of management until satisfactory resolution is obtained.

lR6 3.3 Client or His Designee, or Regulatory Agency Audits Audits of construction site activities may be performed by the client or his designee and/or appropriate regulatory agencies. If corrective action is required as a result of one of these audits, the Quality Assurance Site Supervisor or his designee from the Quality Assurance organization shall be responsible for obtaining a lR6 response from the cognizant individual (s) for submittal to the auditing body.

4.0 FINAL VERIFICATION OF CORRECTIVE ACTION IMPLEMENTATION In addition to his other duties, overall responsibility for verification of the implementation of required corrective action rests with the Quality Assurance Site Supervisor or his designee f rom the Quality Assurance organization. He shall be responsible for performing this verification for lR6 all items indicated in Paragraph 3.0 above, and shall assure that the corrective action is implemented and in a timely manner. In the event that there is a disagreement between those individuals who detect a deficiency and those responsible for the function found to be deficient, the Quality Assurance Site Supervisor shall contact successively higher levels of management as necessary until resolution is obtained.

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stos.s isToi to az pace 4 ,, 4 ESA$CO SERVICES NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION i INCORPoRATEo NOU$ TON LIGHTING AND POWER COMPANY QA-III-7 I SOUTH TEXAS PROJECT '

N ELECTRIC GENERATING STATION UNITS 1 &

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> R E VI SI O N (DRRECTIVE ACTION oarg 3/26/84

5. 0 DETERMINATION AND ANALYSIS OF QUALITY TRENDS 5.1 Ebasco's Corporate Trending lR6 In order to prevent the recurrence of quality problems, Ebasco has developed a method for the determination and analysis of quality IR6 trends. Copies of audit reports and Nonconformance Reports (or other appropriate documentation) mentioned above shall be submitted to the Quality Assurance Engineering Supervisor of Auditing. ne lR6 Quality Assurance Engineering Supervisor of Auditing subsequently l 1 receives all reports and makes an analysis of the available Quality i Assurance data with respect to quality trends. He trend analysis and distribution of subsequent reports shall be made in accordance 1 with Quality Assurance Procedure QA-D.3. l l l

5.2 Client's Trending l i l

Copies of Nonconformance Reports (NG's), Quality Finding Reports lR6 ,

(QFR's), and Management Corrective Action Requests (MCAR's) shall be I transmitted by the Site Quality Assuranet organization to the l Client's Quality Systems / Administration (QS/A). The Client's QS/A l is responsible for the South Texas Project Trend Program activity in l accordance with their procedure (s). l

sios.s tsrei io ez occc 1

• 3 EBASCO SERVICES NUCLEAR QUAUTY ASSURANCE PROGRAM MANUAL SECTION INCORPORATED MOU5 TON UGHTING AND POWER COMPANY QA-III-8 SOUTH TEXA5 PROJECT I ELECTRIC GENERATING STATION UNITS 1 & 2

> 4 R E V1510 N Mh CONTROL OF SPECIAL PROCESSES oave 3/26/84

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1.0 SCOPE Ris Section of the Quality Assurance Manual establishes the requirements for the control of special processes at the construction site. Included herein are provisions for the establishment of critical process parameters, qualification of the processes, and training and qualification of personnel who perf orm the functions covered by this Section.

2.0 RESPONSIBILITIES l l

2.1 he Quality Assurance organization shall be responsible for the I fo11owing: l l

2.1.1 Developing and implementing Site Quality Control procedures I and for qualifying personnel to perf orm inspection of special l processes. l I

2.1.2 Providing technical assistance for procedure review and I development as required. l I

2.1. 3 Qualifying personnel performing nondestructive examination. l I

2.1. 4 Performance of audits in accordance with Section QA-III-9 of l this Manual to assure conformance to the requirements of this l Section. lR6 l

2.2 ne Materials Applications organization shall be responsible for the l following: l I

a) Development and qualification of welding procedures. I l

b) Providing technical assistance for procedure review and l development as required by Site Quality Assurance and Site  !

Quality Control. I I

c) Qualification of welders and welding operators. l I

d) Development of heat treating procedures. I 1

2.3 he Construction organization shall be responsible for the following: I I

2.3.1 Implementing welding and heat treating procedures. l

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2.3.2 Developing and implementing procedures for other activities I classified as special processes (eg, cadwelding, chemical I cleaning, flushing) and f or qualifying personnel to perform I those functions. l lR6 2.4 *Ihe Ebasco Site NDE laboratory, an extension of the Materials l Ecgineering Laboratory, is responsible for developing and implementing l nondestructive examination procedures. l 1

3.0 METHODS FOR CONTROL OF SPECIAL PROCESSES lR6 3.1 Site Special Process Procedures 3.1.1 Nondestructive examination procedures used at the l construction site shall be developed by the Site NDE laboratory and l shall be reviewed and accepted by the Quality Assurance Site l Supervisor or his designee, to assure compliance to the requirements i of all applicable codes and standards, as a minimum. Confo eance to l these procedures and qualification requirements shall be ve n fied l through audits and surveillances perf ormed by Site Quality Assurance. l I

3.1.2 All welding procedures used at the construction site shall be l prepared by the New York Materials Applications organization. The l weld procedures test material shall be prepared either at the home I office or the construction site according to instructions for l qualification provided by the New York Materials Applications I organization. R6 3.1.3 construction procedures for site implementation of welding l and heat treating requirements shall be developed by the Site l Welding Superintendent or his designee. l I

3.1.4 All velders installing safety-related components shall be l qualified according to appropriate codes and standards. Welder l qualification shall be performed by the Site Welding Superintendent l or his designee. Verification of conformance to procedure and l operator qualification requirements shall be performed in accordance I with site procedures by Site Welding Superintendent (or his I designee) surveillance, Site Quality Control inspection, and/or Site l Quality Assurance audit and surveillance functions. l

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(X)NTROL OF SPECIAL PROCESSES carc DNM 3.1.5 All Construction procedures for site implementation of l requirements for welding, heat treating, and other special processes I shall be reviewed and accepted by the Quality Assurance Site l Supervisor or his designee. All comments resulting from such l reviews shall be resolved prior to procedure implementation. R6 4.0 RE CORDS l l

Records pertaining to this Section shall be maintained in accordance with l Section QA-I-6 of this Manual. l

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1.0 SCOPE Quality-related activities at the construction site and Ebasco home office are l independently audited by the Quality Assurance organization. This Section l establishes the requirements and guidelines f or the preparation, perf ormance, lR6 reporting, and follow-up of quality assurance audits as performed by Site l Quality Assurance, home of fice Quality Assurance Engineering, and the Ebasco l Hanagement Audit Committee. l 2.0 RESPONSIBILITIES 2.1 The Ebasco Quality Assurance Site Supervisor or his designee f rom the Site Quality Assurance organization shall assign qualified Site l Quality Assurance personnel to perform audits of construction site l activities. l I

2.2 The Quality Assurance Engineering Supervisor of Auditing shall l assign qualified Quality Assurance personnel to perf orm home office l audits of Ebasco site activities. lR6 1

2.3 A committee chaired by the Quality Assurance Consulting Engineer l shall conduct audits of the Ebasco Materials Applications and Quality l Assurance organizations at the home office. l l

3. 0 CENERAL REQUIREMENTS FOR AUDITS PERFORMED BY THE QUALITY ASSURANCE l ORGANIZATION l 3.1 Audit Personnel 3.1.1 Audit personnel shall be independent of direct responsibility for performance of the activity being audited.

3.1.2 Audit personnel shall be qualified to perf orm quality assurance audits based on experience and training as described in IR6 Quality Assurance Procedure QA-C.3. l 3.2 Training and Orientation 3.2.1 Audit personnel shall have experience and training or orientation to assure their competence for performing audits. The competence of personnel to perf orm audits shall be developed by one or more of the following metnods:

a) Providing personnel with working knowledge of appropriate regulatory documents, practices, codes, and standards.

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b) Training or orientation in general and specialized methods of planning and performing audits.

c) On-the-job training under direct supervision of a Lead lR6 Audi t o r. l 3.2.2 The requirements for training and orientation of auditors shall be in accordance with Quality Assurance procedures. lR6 3.3 Proficiency of Auditors 3.3.1 Auditors performing audits shall maintain their proficiency through one or more of the following methods:

a) Regular, actf e participation in the audit process, b) Review and study of codes, standards, and procedures ,

related to Quality Assurance Programs and program auditing.

c) Participation in orientation or training programs.

3.3.2 Ihe Chief Quality Assurance Engineer or his designee shall evaluate auditors in accordance with Quality Assurance lR6

. Procedure QA-C.3 to assure that the auditors are maintaining their l proficiency.

3.4 Scheduling of Audits l l

3.4.1 Audits shall be initiated as early in the life of-the project I or activity as practicable in order to assure timely implementation l of the applicable Quality Assurance Program requirements, and to l assure ef fective quality assurance during construction activities. l lR6 3.4.2 Audits shall be regularly scheduled on the basis of the I status and safety importance of the activities to assure conformance I to the Ebasco Nuclear Quality Assurance Program. Applicable l elements of the Quality Assurance Program shall be audited at least I annually or once within the life of the activity, whichever is I shorte r. I 3.4.3 Supplemental audits shall be conducted when:

a) Significant changes in the Quality Assurance Program are made.

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QUALITY ASSURANCE AUDITS one 3/26/84 b) There is evidence of significant noncompliance to the Quality Assurance Program.

c) An assessment of the effectiveness of the Quality Assurance Program is requested.

d) It is necessary to verify implementation of corrective "Q action.

e) It is considered necessary by the Quality Program Site Manager.

3.5 Planning of Audits lR6 Preparation for audits shall include the development of a written audit plan of standard format which shall include or identify the lR6 following: l a) Audit scope.

b) Requirements and applicable documents. lR6 c) Activities to be audited.

d) Organization to be audited. i lR6 e) Tentative audit schedule. l f) Approved written proccdures and/or checklists which assure that the organization will be audited to the extent necessary. These procedures ar.d/or checklists shall provide for verifying corrective action of deficiencies identified in previous lR6 audits. Audit procedures and/or checklists may be developed as part of a general audit program and need not be unique for each audit.

3.6 ne Audit Team l l

3.6.1 The audit shall be performed by one or more individuals. A l qualified lead Auditor shall be established as the Team Leader for lR6 audits when teams are comprised of two or more auditors. The Team l Leader shall be responsible for: l l

a) Orientation of the team. l I

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b) Assuring communication between the team and the 4 organization being audited. l 1

c) Coordinating the preparation and issuance of audit I reports. l I

d) Establishing the pace of the audit. l I

3.6.2 The Team leader shall assure that the team is prepared prior i to perf orming the audit. Information such as appropriate lR6 procedures, manuals and prior audit reports shall be made available l to the team members. Each auditor shall be provided with any I appropriate audit planc, procedures, or checklists necessary to l perf orming the audit. I I

3.7 Audit Notification l l

The organization to be audited shall be notified of a scheduled I audit and the scope of the audit. Such notification shall be given I a reasonable time before the audit is to be performed. l 3.8 Audit Performance 3.8.1 Checklists and/or written procedures prepared during audit planning shall be used to conduct the audit.

l 3.8.2 An informal pre-sudit conference shall be arranged at the l audit site in order to confirm audit scope and discuss the audit l plan. IR6 1

3.8.3 A post-audit conference shall be conducted to: l l

a) Inform those audited of the audit results. l l

b) Assure understanding of audit results. I 3.9 Reporting of Audit Results 3.9.1 An audit report shall be compiled and shall be signed by the lR6 audit Team le ider. The audit report shall provide: l a) Des cription of the audit scope, b) Identification of the auditors.

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c) Persons contacted.

d) A summary of the audit results, including an evaluation statement regarding the effectiveness of the Quality Assurance Program elements which were audited.

e) Detailed description of Quality Assurance Program l deficiencies and causes thereof where possible. lR6 l

f) Recommendations for correcting program deficiencies or l improving the Quality Assurance Program, if possible.

3.9.2 'Ihe audit report shall be issued in a timely manner as lR6 defined in the applicable Quality Ascurance procedure. l ,

i 3.10 Audit Follow-Up 3.10.1 A response to the audit report shall be prepared by the l responsible individual and submitted within the required time l period as established in the audit report. The response shall IR6 state the corrective action taken or to be taken, and the date of l completion. The audit Team Leader or at ;her qualified Lead l Auditor shall review the response for acceptance. As necessary, I subsequent responses may be required to verify completion of corrective action.

3.10.2 Follow-up action shall be perf ormed by a qualified Lead lR6 Auditor to: l a) Assure that the written reply to the audit report is received.

b) Assure that corrective action is identified and scheduled for each program deficiency. l lR6 c) Confirm that deficiencies are resolved and corrective l action, when necessary, is accomplished.

3.10.3 Follow-up action may be accomplished through written communication, re-audit, or other appropriate means.

3.10.4 Follow-up action taken shall be documented on the audit lR6 report. l

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3.11 Trend Analysis of Audit Reports 3.11.1 The Quality Assurance Engineering Supervisor of Auditing l shall make an analysis of the available quality data (such as the l audit reports mentioned above) with respect to quality trends, and I report the result of the analysis. Distribution of the trend l analysis reports shall be made in accordance with the requirements I of Quality Assurance Procedure QA-D.3. l l

4.0 SPECIFIC AUDIT REQUIREMENTS l l

4.1 Management Audits l l

4.1.1 A committee chaired by the Quality Assurance Consulting l Engineer is responsible for conducting audits of Ebasco Materials l Applications and Quality Assurance functions to determine l compliance with the Ebasco Quality Assurance Program requirements. l This committee is made up of personnel not in the Quality Assurance l organization and who are qualified in accordance with criteria l denoted in Ebasco Nuclear Procedure N-24. These audits will also l include evaluating quality assurance policy effectiveness and I assuring that appropriate implementing procedures are available and lR6 are being complied with. l l

4.1.2 This auditing shall be accomplished on an annual basis in l accordance with the requirements of Ebasco Nuclear Procedure N-24. l The management audit committee shall be comprised of at least two l qualified representatives from either the Construction or l Engineering Departments, and the QA Consulting Engineer. Each I committee representative shall be appointed by the respective l Vice President; however, no committee member can be directly l engaged in any policy-making or administrative phase of the Ebasco l Quality Assurance Program, but shall be knowledgeable in the I general area of quality assurance. The committee shall be directly l responsible to the Vice President Materials Engineering and Quality l Assurance. l l

4.1.3 The committee shall prepare an audit report for each audit I perf o rmed . This report shall be submitted directly to the Vice l President Materials Engineering and Quality Assurance, with copies l to other appropriste parties. I

$109.6 (STP) $2 82 PAGE 7 OF 0 ESASCO SERVICE 5 HUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCoRPoR ATED HOU5 TON UGHTING AND POWER COMPANY QA-III-9 SOUTH TEXA5 PROJECT

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4.1.4 The Vice President Materials Engineering and Quality l Assurance shall be responsible for informing the concerned Ebasco l management of the results of the audits performed by the committee. l He shall also be responsible for initiating the implementation of I any changes or corrective action deemed necessary to improve the I effectiveness of the Ebasco Nuclear Quality Assurance Program. l I

4.2 Audits by the Quality Assurance Organization IR6 1

4.2.1 Site Quality Assurance shall audit the various l quality-related activities perf ormed by Ebasco organizations on the l construction site in accordance with the requirements of this l Section and applicable Site Quality Assurance procedules and l instructions. I i

4.2.2 Training and qualification records for Site Quality Control l personnel shall be audited in accordance with Section QA-I-3, Paragraph 8.0, of this Manual.

4.2.3 Quality Assurance auditors shall have the authority to reject lR6 items, services, or work for nonconformance to the specification, drawing, or quality control requirements.

4.2.4 Home office Quality Assurance Engineering will conduct periodic audits and evaluations of the construction site in accordance with this Manual and Quality Assurance Procedure QA-D.5.2. lR6 5.0 AUDIT RECORDS 5.1 Records generated during audit preparation, perf ormance, or follow-up shall be retained for all audits in accordance with the applicable requirements of Section QA-I-6 of this Manual and/or approved lR6 Quality Assurance procedures. Such' records shall include: l a) Audit plans and checklists.

b) Audit reports.

c) Written replies to audit reports.

d) Status of required corrective action.

e) Other documents which support audit findings and corrective action as appropriate.

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5.2 Records of training and experience of auditors shall be maintained for all personnel who are performing audits or who have previously perf ormed audits. These shall be retained for the same period of time as required for the audit reports with which the auditors are associated.

Maintenance and retention shall be in accordance with Quality Assurance lR6 Procedure QA-G.3. l

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IDENTIFICATION AND CONTROL OF ITEMS care 3/2 W 1.0 SCOPE 1.1 This Section establishes the requirements for the identification and control of safety-related items at the construction site.

1.2 The activities described herein shall be perf ormed in accordance with written instructions, procedures, and/or drawings that have been developed and accepted in accordance with the requirements of Section QA-III-1 of this Manual.

2. 0 RESPONSIBILITIES 2.1 Site Quality Control shall be responsible to perf orm the following functions in accordance with written procedures:

a) Assure that items received f rom the Client or his designee l at the construction site are properly identified and are lR6 accompanied by appropriate documentation traceable to the items. l b) Assure that all items shall be physically identified in accordance with Paragraph 3.0 below and appropriate written procedures, c) Assure that identification of items shall be transferred to inspection and test records and as-built documents in a manner sufficient to provide the required traceability.

d) Assure that items are handled and stored in accordance with the requirements of Section QA-III-14 of this Manual so as to maintain identification.

2.2 The Quality Assurance Site Supervisor or his designee f rom the Site IR6 Quality Assurance organization shall be responsible for the performance l of reviews and audits in accordance with Section QA-III-9 of this Manual to assure compliance to the requirements of this Section.

3. 0 CENERAL 3.1 Documented Quality Control procedures require that items shall be physically identified by any of the following means:

a) Stenciled or etched markings b) Strip markings

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c) Imprinted tape d) Tagging e) Stamping lR6 f) Color-coding g) Records traceable to the items I

h) Procedural control

1) Other appropriate means in accordance with approved Site Quality Control procedures 3.2 When it is impractical to physically identify individual small lR6 items, these may be identified as to heat numbers, batch, lot, or specification by applying markings to bags, bins, tanks, or other suitable containers.

3.3 Identification of items shall provide the required degree of traceability to pertinent documents.

3.4 All markings shall be clear, unambiguous, and indelible and shall not affect the function of the item when applied.

3.5 When an item is subdivided, markings shall be transferred to each part of the item.

3.6 Markings shall not be obliterated or hidden by surf ace treatment or coatings unleam other means of identificatien is .ubstituted.

4.0 RECORDS Records pertaining to this Section shall be maintained in accordance with Section QA-I-6 of this Manual, t

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INSPECTION onre 3/26/84 1.0 SCOPE This Section establishes the requirements for the inspection of safety-related items and services at the construction site as necessary to assure compliance with documented instructions, procedures, specifications, drawings, codes, and regulatory requirements.

2.0 RESPONSIBILITIES 2.1 Site Quality Control shall be responsible for the following:

a) Development of written procedures for the inspection of safety-related items and services which list the required inspection activities when existing inspection documents such as standard specifications and drawings do not provide an adequate basis for inspection.

b) Submittal of inspection procedures to Ebasco Site Quality Assurance for review and acceptance in accordance with Section QA-III-1 of this Manual.

c) Preparation of reports for all inspections made.

d) Approval processing of inspection procedures and revisions thereto.

2.2 Site Quality Control shall be responsible for performing inspection activities. in accordance with appropriate inspection documents.

2.3 Qualification of inspection personnel shall be in accordance with applicable Quality Assurance procedures and Paragraph 4.0 herein.

2.4 The Quality Assurance Site Supervisor or his designee from the Site IR6 Quality Assurance organization shall be responsible for the performance l of reviews and audits in accordance with Section QA-III-9 of this Manual to the extent necessary to assure compliance with the requirements of this Section.

3.0 CENERAL 3.1 Inspection documents shall be prepared based upon the quality requirements contained in specifications, quality control documents lR6 and procedures, and applicable codes and standards.

4

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3.2 If mandatory inspection hold points are required, the specific hold points shall be indicated on the inspection documents.

3.3 Inspection documents shall specify or reference as a minimum the activities to be perf ormed, acceptance criteria, by whom activities are performed, and the sequence in which the activities are to be performed.

3.4 Where mandatory inspection hold points are indicated on inspection documents or procedures, work may continue beyond a hold point only with the written approval of the Quality Control Site Supervisor or his qualified designee.

3.5 Inspection reports shall indicate the acceptability status of the lR6 items or services inspected with respect to meeting the applicable l quality requirements.

3.6 When inspections are to be performed by use of a sampling program (ie, to determine the acceptability of a group of like-items based upon l the results of an inspection of a representative number of items from the lR6 group), the sample size shall be identified on the inspection documents. I Justification for this sampling shall be based upon recognized standard construction practices and successful past experience, as well as the complexity and function of the activity, item, or service to be inspected.

4.0 TRAINING AND QUALIFICATION OF INSPECTION PERSONNEL 4.1 Inspection personnel shall have experien.e and training to assure their competenea for performing inspection. "he competence of personnel to perform inspections shall be developed by une or more of the following methods:

a) Providing personnel with working knowledge of appropriate regulatory documents, practices, codes, and standards.

b) Training or orientation in general and specialized methods of planning and performing inspections.

c) On-the-job training under direct supervision of an experienced, qualified inspector.

i 9

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4.2 The requirements for training and qualification of inspectors shall be in accordance with applicable Quality Assurance procedures, and qualification of inspectors shall be based upon consideration of the following:

a) Records of education and experience.

b) Test results, where applicable.

c) Results of capability determination.

4.3 Site Quality Control shall be responsible for scheduling and coordinating training for quality control personnel in advance of implementation of the applicable inspection documents. This training shall be conducted in sufficient detail and with sufficient frequency to assure that the personnel responsible for the inspection fully understand the requirements contained in the applicable inspection documents.

4.4 Inspectors performing inspections shall maintain their proficiency through one or more of the following methods:

a) Regular, active participation in the inspection process, b) Review and study of codes, standards, and procedures related to Quality Assurance Programs and program inspection.

4.5 The Chief Quality Assurance Engineer or his designee shall periodically evaluate inspectors in accordance with applicable Quality Assurance procedures to assure that the inspectors are maintaining their proficiency.

5. 0 RECO RDS 5.1 All inspection documents shall be maintained in accordance with Section QA-I-6 of this Manual.

5.2 Records of training, experience, and certification of inspectors lR6 shall be maintained for all personnel who are performing inspection or who have previously perf ormed inspections. These records shall be lR6 retained for the same period of time as required for the inspection reports with which the inspectors are associated.

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TEST CONTROL care 3/26/84 1.0 SCOPE 1.1 This Section describes the system employed at the construction site which assures that tests required to demcnstrate that items will perform satisfactorily in service are identified and documented. The requirements of this Section apply to all phases of the testing program at the construction site including but not limited to: functional testing, proof testing, acceptance testing, and operational testing.

1.2 These tests shall be performed in accordance with written test procedures which include or reference the requirements and acceptance limits contained in applicable design documents.

2.0 RESPONSIBILITIES 2.1 Site Quality Control procedures shall provide for the following:

a) Assuring that all prerequisites for the given test have been met.

b) Use of trained personnel to witness tests. l I

c) Identification of test equipment and the item to be tested. l I

d) Checking the condition of test equipment and the item to be I tested. lR6 I

e) Use of devices calibrated in accordance with Section QA-III-13 l of this Manual for the performance of tests. l I

f) Performance of tests under proper environmental conditions; I eg, cleanliness. l g) Documentation of test results.

h) Acceptance criteria for test requirements. l lR6 2.2 Site Quality Assurance shall review and comment on the written l procedures for tests covered by this Section. All comments shall be resolved prior to implementation of the procedures. These test procedures shall be reviewed in accordance with Site Quality Assurance l procedures and/or instructions for the inclusion of: l lR6 a) Provisions for assuring that all test prerequisites have been l met. I b) Identification of items to be tested.

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c) Identification of calibrated devices or equipment to be used l during testing. l l

d) Provisions for checking condition of test equipment and item to lR6 be tested. l I

e) Proper environmental conditions under which test is to be l performed. l f) Test methods.

g) Operations to be perf ormed, h) Inclusion of, or reference to, acceptance criteria. lR6 i) Data to be recorded.

j) Requirements for qualified and/or certified personnel.

2.3 Test reports shall be reviewed and signed-of f by Ebasco Quality Control in accordance with procedure requirements to assure that test lR6 requirements have been satisfied.

2.4 The Quality Assurance Site Supervisor or his designee from the Site lR6 Quality Assurance organization shall be responsible for the performance l of reviews and audits in accordance with Section QA-III-9 of this Manual to the extent necessary to assure compliance to the requirements of this Section.

3.0 RECORDS All records pertaining to this Section shall be maintained in accordance with Section QA-1-6 of this Manual.

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1.0 SCOPE 1.1 This Section describes the requirements for control, calibration, adjustment, and maintenance of measuring and testing devices used at the construction site for performing tests and inspections of safety-related items. These devices shall be calibrated and adjusted at specified, predetermined intervals using equipment having known valid relationships to nationally recognized standards.

1.2 The activities described herein shall be performed in accordance with written instructions, procedures, and /or drawings that have been developed and accepted in accordance with the requirements of Section QA-III-l of this Manual.

2. 0 RESPONSIBILITIES Site Quality Control shall be responsible for performance of the following: lR6 2.1 Establish a list which includes the measuring and testing devices to be calibrated and the f requency of calibration of these devices. The method and interval of calibration shall be based on the type of device, stability characteristics, required accuracy, and other conditions affecting measurement control.

2.2 Assure that the measuring and testing devices used are of the proper range, type, and accuracy to verify conformance to established requirements.

2.3 Maintain a master calibration file for each measuring and testing device which includes at least the following information:

a) Name of device.

b) Device serial and/or identification number, c) Frequency of calibration.

d) Date of last calibration.

e) Name of party perf orming last calibration.

f) Due date for next calibration.

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i g) Condition of device at time of calibration and results of lR6 calibration. I h) Standard used for calibration.

1) Applicable calibration procedure.

2.4 Assure that all measuring and testing devices are marked with the l identification number and when possible with calibration due dates. When lR6 this marking is not possible, alternative methods of tracing the device l to its calibration due date (such as color-coding) shall be employed. l 2.5 Assure that all measuring and testing devices are calibrated in accordance with the requirements of this Section and that the required documentation is provided.

2.6 Develop and maintain a system for issuance, collection, and return of all measuring and testing devices. This system shall provide for the identification of personnel withdrawing devices, methods for issuing devices, and methods for the collection and/or return of devices at prescribed calibration times or as otherwise required.

3.0 CENERAL 3.1 The standard of calibration shall be traceable to national l standards. If no national standards exist, the basis for calibration lR6 l shall be documented and traceable to the equipment manufacturer's l recommended standards. l 3.2 Heasuring and test equipment (H&TE) shall be calibrated against working standards having tolerances not greater than one fourth (1/4) the tolerance of the H&TE. Tolerances greater than one fourth (1/4) shall be

, acceptable when limited by the state of the art. Reference standards j shall be calibrated against higher-level standards of closer tolerance.

l i

For projects with Preliminary Safety Analysis Reports docketed on or before October 19, 1977, M&TE shall be calibrated against working l standards having tolerances not greater than the tolerance of the M&TE.

l Reference standards shall be calibrated against higher-level standards of j closer tolerance.

3.3 Methods shall be employed to assure proper handling, storage, and care of the H&TE in order to maintain its required accuracy.

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f slos.s isTM 10.82 DO G E _3._ __, o , 3 E5ASCO SERVICE 5 HUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCoRPoMATED HOU$ TON LIGHTING AND POWER COMPANY QA-III-13 SOUTH TEXA5 PROJECT ELECTRIC GENERATING STATION UNITS 1 & 2 3

{ CONTROL OF MEASURING D^'E 3/26/84 I c . . . . . . . . ,p . . . . .. c a . . . . . AND TESTING EQUIPMENT 3.4 Any M&TE found to be out of calibration shall be recalibrated. When M&TE is found to be out of calibration, damaged, lost, or stolen, an evaluation shall be made to ascertain the validity of previous inspection or test results and the acceptability of components inspected and/or tested since the last calibration check. When it is necessary to assure the acceptability of suspect items, the original required inspections and/or tests shall be repeated using properly calibrated equipment.

Suspect items on which a questionable device was used shall be listed on lR6 the Nonconformance Report (NCR) or Deficiency Notice (DN), as applicable.

3.5 If any of the M&TE is consistently fcund to be out of calibration, it shall be repaired or replaced.

3.6 Inspection and test reports shall include identification of M&TE used to perform the inspections and/or tests.

3.7 The Quality Assurance Site Supervisor or his designee from the Site lR6 Quality Assurance organization shall be responsible for the performance l of reviews and audits in accordance with Section QA-III-9 of this Manual to the extent necessary to assure compliance with the requirements of this Section.

4.0 RECORDS Records pertaining to this Section shall be maintained in accordance with Section QA-I-6 of this Manual.

sios.s isrei to.s2 pace 1 or 5 EBASCO SERVICE 5 NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCORPORATEo HOUSTON UGHTING AND POWER COMPANY QA-III-14 SOUTH TEXAS PROJECT

{ ELECTRIC GENERATING STATION UNITS 1 & 2 4 E CONTROL OF RECEIVING,

c. ..... ........

HANDLINC, AND STORAGE o^TE 1.0 SCOPE 1.1 This Section describes the methods employed during receiving, handling, storage, and installation to assure that all safety-related items received by Ebasco at the construction site will be usable when I needed. Rese requirements apply to both items received by Ebasco from IR6 the Client or his designee and Ebasco site-f abricated subassemblies which I require temporary storage before assembly or installation. They also apply to both on-site and off-site facilities which are used for the storage of items under control of the construction forces.

1.2 The activities described herein shall be performed in accordance with written instructions, procedures, and/or drawings that have been developed and accepted in accordance with the requirements of Section QA-III-1 of this Manual.

1.3 The storage of safety-related items maintained in facilities under the direct control of the Client or his designee is excluded from the scope of this Manual.

I 2.0 RESPONSIBILITIES I I

2.1 ne Ebasco Construction organization shall be responsible for the l following: l l

a) Performance of receiving, handling, storage, maintenance, and I cleaning activities in accordance with specifications provided I i by the Client or his designee and/or code requirements, l l I b) Development of methods for special handling (of f-loading) in I accordance with manufacturer's recommendations and/or lR6 specifications provided by the Client or his designee. l I

l c) Establishing storage areas to meet levels as briefly described l below: l I

1) Invel A - Indoor, controlled environment. l l 1 l 2) Imvel B - Indoor, heated and ventilation controlled. l l

3) Level C - Indoor or equivalent, ventilation controlled, l I

l 4) 14 vel D - Outdoor. l

sios.s isTm u.e2 pace 2 or 5 ESASCO SERVICES NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCORPORATED HOUSTON LIGHTING AND POWER COMPANY SOUTH TEXAS PROJECT QA-III-14 d ELECTRIC GENERATING STATION UNITS 1 & 2

> 4 R E Vi $lO N E CONTROL OF RECEIVING, HANDLING, AND STORAGE ^'E 3/26/84

'c .... .a.u yj.. .............

d) Development of general storage plans which list types of items I and their intended storage locations and levels. Such plans I shall be prepared prior to receipt of items from the Client or l his designee.

l l

2.2 Ebasco Site Quality Control shall be responsible for the following: l l

a) Qualification of personnel performing inspection functions l applicable to receiving, handling, and storage. l 1

b) Assigning qualified quality control personnel for performance of l inspection and/or surveillance of receiving, handling, storage, l maintenance, and cleaning activities. l l

c) Performing and documenting inspection and/or surveillance l activities in accordance with approved checklists to verify that lR6 receiving, handling, storage, maintenance, and cleaning l activities, as described in Paragraph 2.1 above, are perf ormed I in accordance with project requirements. l I

d) Establishing and implementing methods for rejection of l nonconforming items which provide adequate means of identifying l the item as nonconforming and physically segregating the item l where practical. When segregation is not practical, a status l type indicator shall be used. Application and removal of l status type indicators shall be by Quality Control personnel l only.

l l

2.3 Ebasco Site Quality Assurance shall be responsible for the l l performance of audits in accordance with Section QA-III-9 of this Manual l to the extent necessary to assure compliance to the requirements of this l

Section. I i

2.4 The Client or his designee is responsible for procurement and initial receiving inspection of all safety-related items. However, if lR6 requested in writing by the Client or his designee to perform initial receiving inspection of safety-related items upon their arrival at the j job site, Ebasco will conduct a complete program that covers the full l parameters of this Section. Otherwise, Ebasco shall conduct a receiving lR6 l inspection program as is applicable and in accordance with approved site l procedures.

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(13.S (STM 10.82 PAGE OF E8ASCO SERVICES NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCORPOR ATED HOUSTON LIGHTING AND POWER COMPANY QA-III-14 SOUTH TEXA5 PROJECT i ELECTRIC GENERATING STATION UNITS 1 & 2 4

> R E VI SIO N 2 CONTROL OF RECEIVING, I

N HANDLING, AND STORAGE ATE

. ..ro m .,7y . ..... .......

3.0 RECEIVING INSPECTION 3.1 Safety-related items utilized for f abrication, erection, installation, or modification shall be subjected to receiving inspection to assure conformance to the requirements of the applicable drawings, specifications, and other documents as required. Where source inspection is not performed, receiving inspection at site for acceptability will be pe rfo rmed .

l 3.2 Inspection Requirements lR6 i

Receiving inspection procedures shall be prepared by the Quality l Control Site Supervisor or his designee in accordance with the requirements cf this Manual. These procedures shall provide instructions and checklists for perf orming receiving inspection and shall include at least the following activities:

a) Documentation review to assure that the documentation package has been received and that a signed " Release for Shipment" form accompanies the items received, when applicable. lR6 b) Visual examination.

c) Marking and tagging for traceability.

I d) Testing when specified.

e) Preparation for storage.

4.0 HANDLING 4.1 Handling practices applied to safety-related items shall assure

! minimum possibility for damage or loss of environmental protection.

4.2 Inspection Requirements lR6 Site Quality Control Procedures shall provide for at least the following:

l a) Review of handling requirements for safety-related items.

b) Performance of appropriate inspections to assure that handling operations have not jeopardized item integrity, i

i I

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4 5 SlW.S (STPi c.92 DAGE or ESASCO SERVICES HUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCoRPoMATEo MOU5 TON LIGHTING AND POWER COMPANY QA-III-14 SOUTH TEXAS PROJECT d ELECTRIC GENERATING STATION UNITS 1 & 2 4 CONTROL OF RECEIVING, h

i. -

V HANDLING, AND STORAGE care

............,y...m......

5.0 STORAGE AND IN-PLACE PROTECTION l l

5.1 All safety-related items shall be stored in locations and storage l 1evels as outlined below except for those items released f rom storage and l placed in their permanent locations which shall be cared for, maintained, l and inspected in accordance with design specifications and the applicable l approved procedures. In place protection in permanent location is l permitted for large items such as equipment, provided that the permanent lR6 location is ready for the item installation. If the permanent location l does not af ford the required level of protection, additional protection l shall be provided to prevent degradation of the item. For in place l protection purposes, a permanent location shall be considered to be l within the room and/or immediate vicinity in which the item is to be l permanently installed. l I

5.2 Inspection Recuirements l Site Quality Control procedures shall provide fc; at least the following:

a) Monitoring of the storage levels listed below:

1) Level A - Indoor, controlled environment.

2) Level B - Indoor, heated and ventilation controlled.

3) Level C - Indoor or equivalent, ventilation controlled. lR6

4) Level D - Outdoor, b) Honitoring raintenance of storage areas to control such items as lR6 the following

1) Physical condition of storage area.

2) Access to storage area.

3) Fire protection.

4) Prohibited materials. .

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68 09.6 (STM 10.82 PAGE OF ESASCO SERVICES MUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCORPoRATro HOUSTON LIGHTING AND POWER COMPANY QA-III-14 SOUTH TEXA5 PROJECT I ELECTRIC GENERATING STATION UNITS 1 & 2 4

> 3 R E VI SIO N 2 CONTROL OF RECEIVING, I HANDLING, AND STORAGE DATE

< ....+.-,g.................

c) Inspection of stored items and items protected in place to lR6 assure their integrity.

d) Verification of general storage plans which list types of it ms IR6 and their intended storage locations and levels. l e) Monitoring of storage areas to maintain proper segregation of materials. Items shall retain an appropriate identification for IR6 retrievability and inventory control, as applicable to the nature and use of the material.

f) Monitoring of provisions for preservation of items, as required lR6 by special conditions.

I g) Verification that the withdrawal of any component, assembly, I system, or materials from the Client's or his designee's lR6 warehouse or storage areas shall be by the Requisition for i Stored Items completed by the responsible supervisor or his I designated representative. Ihe request shall identify the material and applicable references to a drawing or specification.

lR6 5.3 The Client or his designee shall be responsible for the establishment of storage levels, maintenance, and any other applicable handling and storage requirements. The Ebasco Construction organization lR6 is responsible for developing and implementing procedures addressing these requirements.

I 6.0 RECORDS l lR6 Records pertaining to this Section shall be maintained in accordance with l Section QA-1-6 of this Manual. l

1 2 68 00-6 tSTPI C.82 PAGE or ERASCO SERVICES NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCORPoRATEo NOUSTON LIGHTING AND POWER COMPANY QA-III-15 SOUTH TEXA5 PROJECT d ELECTRIC GENERATING STATION UNITS 1 & 2 2

> aa vision 3/26/84 Mh ........

INSPECTION, TEST, AND OPERATING STATUS o,,,

.... % ... p ...c 1.0 SCOPE 1.1 This Section establishes requirements for identifying and documenting the status of inspections and tests performed on safety-related items at the construction site and the statas of the readiness of these items for initial operation.

1.2 The activities described herein shall be performed in accordance with written instructions, procedures, and/or drawings that have been developed and accepted in accordance with the requirements of Section QA-III-1 of this Manual. Procedures and instructions shall include identification and authority of the individuals or groups responsible for application and removal of status indicators.

2. 0 RESPONSIBILITIES Site Quality Control shall be respunsible for the following:

2.1 Develop and implement a system for maintaining the status of l safety-related items through the use of status indicators such as lR6 physical location and tags, markings, work travelers, stamps, or l inspection records. This system shall provide for the identification and I maintenance of the status of inspections and tests performed on these items throughout fabrication, installation, and erection. This system lR6 shall provide methods which assure that only items that have passed the required inspections and tests are used, installed, or operated. Where physical tagging is either impractical or insufficient, procedural control or other appropriate means for maintaining item status shall be employed.

2.2 Control and maintain a log of the issuance and removal of status (R6 indicators such as tags. l l

2.3 Develop and im^lement plans for the witnessing and documenting the

! results of inspections and tests.

2.4 Provide methods for assuring that all required inspections and tests are performed (checklists, travelers, etc).

2.5 Develop and implement a system for marking and tagging to indicate the initial operating status of safety-related items which are in test ,

rework, or other initial operating status, so as to prevent inadvertent operation.

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• sios.s isTP c er Fact 2 o, 2 ESASCO SERVICE 5 NUCLEAR QUALITY ASSURANCE PROGRAM Mn4UAL SECTION INCORPORATED HOU$ TON UGHTING AND POWER COMPANY QA-III-15 SOUTH TEXA5 PROJECT

{ ELECTRIC GENERATING L'ATION UNIT 51 & 2 2 E

i M INSPECTION, TEST, AND OPERATING STATUS care 3/26/84

< c...ro m , p . .... ..... .

2.6 Develop and implement a system for marking and tagging of all safety-related items during preoperational testing. This system shall provide for maintaining records of status indicators placed on boundaries 1 or within systems turned over to the Client or his designee.

l 2.7 Maintain a log containing entries of all systems turned over from t construction forces for preoperational testing. This log shall be i maintained for quality status reference.

3.0 GENERAL 3.1 Quality Control procedures shall require that inspection and test status be maintained by the use of status indicators such as tags, markings, travelers, stamps, inspection records, work sequence plans, or ,

other appropr'iate means. '

3.2 The progress of f abrication, installation, erection, inspection, and test shall be entered on appropriate documents. Provisions shall be made for updating these documents to reflect current conditions.

P 3.3 ' Nonconforming safety-related items shall be clearly identified and marked and shall be processed in accordance with Section QA-III-6 of this Manual.

3.4 Records of tests and inspection results shall be prepared and maintained in an orderly and systematic manner.

3.5 The Quality Assurance Site Supervisor or his designee from the Site lR6 Quality Assurance organization shall be responsible for the performance l of reviews and audits in accordance with Section QA-III-9 of this Manual to the extent necessary to assure compliance to the requirements of this Section.

4.0 RE CORDS Records pertaining to this Section shall be maintained in accordance with Section QA-I-6 of this Manual.

4 k

sics.s istri tr.e pace 1 or 3

ESA5CO SERVICES NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCoMPoRATEo HOUSTON LIGHTING AND POWER COMPANY Appendix I SOUTH TEX A5 PROJECT I ELECTRIC GENERATING STATION UNITS 1 & 2 2 R E VISI O N b

TERMS AND DEFINITIONS care 3/26/84 This Appendix contains certain terms and their definitions used in this Manual that are important to the uniform understanding of the Manual and its application. Where a term is used to convey a different intent than that related herein, clarification must be provided at the point of application:

ACTIVITIES AFFECTING QUALITY (Quality-related activities) - Activities affecting the quality of safety-related items, including designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, and testing.

AUDIT - A planned and documented activity performed in accordance with written procedures or checklists to verify, by examination and evaluation of objective evidence, that applicable elements of a quality assurance program have been developed, documented, and effectively implemented in accordance with applicable regulatory documents, guidelines, or requirements. An audit does not include surveillance or inspection for the purpose of process control or product acceptance.

, lR6 AUDITS (INTERNAL) - Audits performed by Ebasco personnel on those Ebesco organizations that are governed by the Ebasco Quality Assurance Program. l CLIENT OR HIS DESIGNEE " Client" is defined as Houston Lighting and Power lR6 Company and "his designee" as Bechtel Energy Corporation. l l

CDNSTRUCTION OPERATION - Activities related to construction of a nuclear power station.

EBASCO HOME OFFICE - Office where project support and related functions are l performed at Ebasco, New York. lR6 l

INSPECTION - A phase of quality control which by means of examination, observation, or measurement determines the conformance of items or services to predetermined quality requirements.

INSTRUCTIONS - Written descriptions of activities to be performed, including l

job specifications, work instructions, shop construction drawings, job l tickets, planning sheets, operating or procedure manuals, test procedures, or l other written forms, to assure that the activity is adequately described.

ITD! - Any level of unit assembly, including structure, system, subsystem, component , part , or material.

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sim.s tsrps so.e pace 2 ,, 3 EtASCO SERVICES NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION mecmpon Arco MOU$ TON UGHTING AND POWER COMPANY Appendix I SOUTH TEXAS PROJECT I ELECTRIC GENERATING STATION UNITS 1 & 2 2

> at vision Mh a..v e.n.n y ....sss.s,.nna TERMS AND DEFINITIONS o vg 3/26/M NON00NFORMANCE - A deficiency in characteristic, documentation, or procedure which renders the quality of an item or service unacceptable. Items discovered to be out-of-tolerance of specification at routine checkpoints of an inspection process shall not be considered as a nonconformance, provided:

a) The conditions are corrected prior to acceptance of the work.

b) The work does not proceed beyond the checkpoint until the correction is made.

c) The condition does not affect work previously accepted.

d) No violation of procedure or Code is evident.

lR6 QUALITY ASSURANCE (QA) RECORDS - are those records which furnish documentary evidence of the quality of items and of activities affecting quality. A document is considered a quality assurance record when the document has been completed. QA records may be either the original or a reproduced copy.

QA RECORDS (LIFETIME) - are those records which meet one or more of the following criteria:

a) Those which would La a significant value in demonstrating capability for proper functioning of safety-related items.

b) Those which would be of significant value in maintaining, reworking, repairing, replacing, or modifying the item.

c) Those which would be of significont value in determining the cause of an accident or malfunction of an item, d) Those which provide required baseline data for in-service inspection.

QA RECORDS (NONPERMANENT) - are those records which meet all of the following criteria:

a) Those of no significant value in demonstrating capability for safe operation.

b) Those of no significant value in maintaining, reuorking, repairing, replacing, or modifyi.ig the item.

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stos.s tsim u.ez pace 3 ,, 3 EBASCO SERVICE 5 NUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION INCORPoRAfto HOU5 TON UGHTING AND POWER COMPANY Appendix I SOUTH TEXA5 PROJECT

{ ELECTRIC GENERATING STATION UNITS 1 & 2 2 2

3/26/84 1

< .M/N

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TERMS AND DEFINITIONS oare c) 'Ihose of no significant value in determining the cause of malfunction of an item.

d) Those which do not provide baseline data for in service inspection.

QUALITY TREND - A consistent reporting of conformance or nonconformance with applicable criteria attributed to a specific organizational unit.

SAFETY-RELATED ITEM - A'ny item designated by the Client or his designee, in l accordance with the guidelines established by the Licensing Department of the lR6 Client or his designee, to be Safety Class 1, 2, 3, Seismic Category I, or l electrical Class IE and any other items as designated by the Licensing Department and indicated as safety-related in the PSAR or FSAR. lR6 SERVICE - Performance of nuclear safety-related activities such as lR6 f abrication, inspection, nondestructive examination, installation, and test.

lR6 SPECIAL PROCESS - A special process is a fabrication, testing, or inspection operation whose correct performance is governed by parameters established during qualification testing for the operation, eg, welding and nondestructive testing.

lR6 j

I 0 sim.s isTm so.s2 occc or EBASCO SERVICES HUCLEAR QUALITY ASSURANCE PROGRAM MANUAL SECTION mcompoR ATED MOU$ TON LIGHTING AND POWER COMPANY Appendix II SOUTH TEXA5 PROJECT N ELECTRIC GENERATING STATION UNITS 1 & 2 3 h EBASCO EXCEPTIONS TO US NUCLEAR 3/26/84 a

I gc.... g

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REGULATORY GUIDES AND ANSI STANDARDS INDICATED IN SECTION QA-I-I D*TE EXCEPTIONS TO ANSI N45.2.5-1974: lR6

1. ANSI N4 5.2.2-2974, Section 4.8, states " Pumped concrete must be sampled f rom the pump line discharge." In lieu of this statement, in process strength samples of pumped concrete are taken at the delivery point.

Correlation tests of air content, slump, and temperature are performed to verify these plastic properties of the concrete at the placement point in accordance with the following frequency requirements:

A. A minimum of two correlation tests are performed for each pumped placement exceeding 200 cu. yds.

B. Otherwise, a minimum of two correlation tests per week are perforced when any individual pumped placement during a week requires delivery of more than one truckload of concrete.

C. During a week when a pumped placement exceeding 200 cu. yds. is made, the correlation tests performed on that placement will satisfy the weekly requirement for performing two correlation tests as specified in Item B above.

When any of the specified limits and tolerances on loss of air content, slump, or temperature are exceeded at the placement point, correlation tests between the delivery point and placement point will be accomplished for each 100 cu. yds. of concrete placed as long as limits and tolerances are exceeded. If two consecutive tests are out of tolerance, corrective action will be implemented to adjust the limits for the concrete entering the pump intake so that no concrete from the subsequent trucks will enter the pump intake as long as the tolerances are exceeded.

" Correlation Testing," " Delivery Point," and " Placement Point" are as defined in ANSI N45.2.5-1978, Section 1.4.

2. Samples and frequency for cadweld testing is in accordance with ACI-359-ASME Section III, Division 2, issued for trial use and comment in 1973, including Addenda 1 through 6 (see Sections 3.8.1.6.3 and 3.8.3.6.'3 of the South Texas Project Final Safety Analysis Report).

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sios.sistni c.s pace 2 ,, 6 EEASCO SERVICES HUCLEAR QUALITY A55URANCE PROGRAM MANUAL SECTION

'"CC""C" A T E D HOUSTON LIGHTING AND power COMPANY Appendix II

, SOUTH TEXA5 PROJECT

< ELECTRIC GENERATING STATION UNITS 1 & 2

"'**'" 3 h EBASCO EXCEPTIONS TO US NUCLEAR g

a

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REGULATORY CUIDES AND ANSI STANDARDS INDICATED IN SECTION QA-I-1 D""

3/26/84 EXCEPTIONS TO ANSI N45.2.1-1973: lR6

3. Section 2.1, Planning. The required planning is frequently performed on a generic basis for application to many installations on one or more projects. This results in standard procedures or plans for installation and inspection and testing which meet the requirements of the standard.

Individual plans for each item or system are not normally prepared unless the work operations are unique. However, standard procedures or plans will be reviewed for appifcability in each case. Installation plans or procedures are also limited in scope to those actions or activities which are essential to maintain or achieve required quality. This is consistent with Section 2, Paragraphs 2 and 3, of ANSI N45.2-1971 which provides for examination, measurement, or testing to assure quality or indirect control by monitoring of processing methods. However, final cleaning or flushing activities will be performed in accordance with procedures specific to the system.

4 Section 4, Pre-Installation Cleanness. This section states, " Items should not be delivered to the point of installation site sooner than necessary unless the installation location is considered a better storage a rea. " As an alternate to this requirement items may be delivered to the installation site sooner then absolutely necessary when determined to be advantageous for other considerations, for example, reduced handling or easier access, thereby reducing susceptibility to handling damage. In .

all such cases, equipment stored in place will be protected in accordar.ce with Section 5 of ANSI N45.2.1-1973.

5. Section 3.1.2, cleanness Classifications - Class B. Ebasco interprets the lighting level of 100 footcandles to be guidance. It is Ebasco's normal practice that the lighting level for determining " metal clean" of accessible surfaces of piping and components is determined by the inspector. Typically he uses a standard two-cell **1ashlight supplemented by other lighting as he deems necessary.

EXCEPTIONS TO ANSI N45.2.2-1972: lR6

6. Section 2.7, Classification of Items. The four-level classification system may not be used explicitly. However, the specific requirements for each classification as specified in the standard will be applied to the items suggested in each classification and for similar items.

Classification differing from Section 2.7 will be considered acceptabic provided no degradation is assured; for example, electric motors designed for outside service may be stored in Level C area rather than a Level B.

stos.s est m so.s 3 6 acce or EsAsco services NUCLEAR QUAUTY AS$URANCE PROGRAM MANUAL $ECTION mcomponavao NOU$ TON LIGHTING AND POWER COMPANY Appendix II

, SOUTH TEXA5 PROJECT

< ELECTRIC GENERATING STATION UNITS 1 & 2

""**'" 3 h EBASCO EXCEPTIONS TO US NUCLEAR a

% ..gg

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REGULATORY GUIDES AND ANSI STANDARDS INDICATED IN SECTION QA-I-1 D*"

3/26/84

7. Section 6.2, Storage Areas. Paragraph 6.2.1 requires control and limited access to storage areas. In lieu of and to amplify this paragraph, the following will be applied:

" Access to storage areas for Levels A, B, and C will be controlled by the individual (s) responsible for material storage. While the above l areas will be posted to limit access, other positive controls (other than lR6 that for the overall site area) or guards may not be provided. Level D l areas will be posted with the storage level designation only." l

8. Section 5.5, Correction of Nonconformances. This section provides for

" rework" and "use-as-is" dispositions for nonconforming items. As an alternate, the " repair" disposition (as defined in ANSI N45.2.10-1973) will also be used.

9. Section 6.2.4, Storage of Food and Associated Items. Controlled areas, within storage areas, will be established for the storage of food, drink, and salt tablets. These areas will be controlled through normal supervision and inspection.

10. In Section 8, the control of documentation and records shall be in accordance with Section QA-I-6 of the Ebasco QA Program Manual for the South Texas Project.

11. Appendix A3.4.2, Inert cas Blankets. There may be cases involving large or complex shapes for which an inert or dry air purge flow is provided rather than a static gas blanket in order to provide adequate protection due to difficulty of providing a leakproof barrier. In these cases a positive pressure purge flow may be utilized as an alternative to the leakproof barrier.

EXCEPTIONS TO ANSI N45.2.3-1973: lR6

12. Section 2.1, Planning. The required planning is frequently performed on a generic basis for application to many installations on one or more projects. This results in standard procedures or plans for installation and inspection and testing which meet the requirements of the standard.

Individual plans for each item or system are not normally prepared unless the work operations are unique. However, standard procedures or plans will be reviewed for upplicability in each case. Installation plans or procedures are also limited in scope to those actions or activities which are essential to maintain or achieve required quality.

4 or 6 stos.sisTPI C es pact EsASCO SERVICES HUCLEAR QUALITY A55URANCE PROGRAM MANUAL $ECTION tucomponATro NOU$ TON UGHTING AND POWER COMPANY Appendix II SOUTH TEXA5 PROJECT

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REGULATORY GUIDES AND ANSI STANDARDS INDICATED IN SECTION QA-I-1

• • 3/26/84

13. Alternative equivalent zone designations and requirements may be utilized to cover those situations not included in the subject standard; for example, situations in which shoe covers and/or coveralls are required but material accountability is not. In addition, zones might be combined into the next more restrictive category in order to reduce total number of zones.

EXCEPTIONS TO ANSI N45.2.4-1972: lR6

14. Section 1.2, Applicability. The standard is applied to the items and systems identified in Paragraph 1.1.1 and to additional systems depending on the nature and scope of the work to be performed and the importance of the item or service involved.

15. Section 2.1, Planning. The required planning is f requently perf ormed on a generic basis for application to many installations on one or more projects. This results in standard procedures or plans for installation and inspections and testing which meet the requirements of the standard.

Individual plans for each item or system are not normally prepared unless the work operations are unique. However, standard procedures or plans will be reviewed for applicability in each case. Installation plans or procedures are also limited in scope to those actions or activities which are essential to maintain or achieve required quality.

EXCEPTIONS TO ANSI N45.2.8-1975: lR6

16. Section 1.1, Scope. The term "important items" will be interpreted to apply to those activities or quality attributes of an item or service that could affect a nuclear safety-related characteristic. For example ,

if a barrier is required for leakage control, but serves no structural function, the leaktight characteristic would be considered "important,"

but appearance, dimensional requirements, and structural features would not necessarily be considered important; or if a pump casing is required for coolant boundary integrity, but the pump does not have to operate to provide for nuclear safety, those attributes which affect its operation would not be considered important from the standpoint of nuclear safety.

Section 2.1, Planning. The required planning is frequently performed on a generic basis for application to many installations on one or more projects. This results in standard procedures or plans for installation and inspection and testing which meet the requirements of the standard.

Individual plans for each item or system are not normally prepared unless the work operations are unique. However, standard procedures or plans will be reviewed for applicability in each case. Installation plans or procedures are also limited in scope to those actions or activities which are essential to maintain or achieve required quality.

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17. Section 3.3, Processes and Procedures. The terms " installation site,"

" installation area," and " site" used in this standard shall be interpreted as follows:

a) " Installation site" or " site" will be interpreted the same as

" construction site. " When applied to documents, these may be at the central office or work area document control station.

b) Installation area - Immediate proximity of location where work is to be performed.

18. Section 3.5(e), Site conditions. This requirement will be applied only if subsequent correction of adjacent nonconformances could damage the item being installed.

Section 4.6, Care of Items. HL&P retains the authority and is the

" Responsible Organization" for temporary usage of equipment or facilities unless specific (ie, on a case-by-case basis) or general authority is granted in writing to the Construction Manager's organization.

EXCEPTIONS TO ANSI N45.2.9-1974: lR6

19. Section 1.4, Definitions. Quality Assurance Records - A document is considered complete when it has finished full processing and has been issued for use in design, procurement, construction, or manufacturing.

20 Section 1.4, Definitions. Authenticated Records - Those records which are clearly identified as a statement by the individual or organization holding responsibility. Ihndwritten signatures are not required if the document or printout is clearly identified as a statement by the reporting individual or organization.

21. For Appendix A, an installation shall be considered to be in an "as constructed" condition if it is installed within the tolerances established by Project Engineering indicated in the design output documents.

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22. ANSI N45.2.12-1977, Section 4.5.1, states, "The audited organization shall provide a follow-up report stating the corrective action taken and the date corrective action was completed." This implies that the audited organization must provide the auditing organization with written notification detailing what corrective action was taken and when the corrective action was completed.

In actual practice, the audited organization will provide the auditing organization with documented corrective action including the date when the corrective action will be completed. The auditing organization will evaluate the corrective action response to determine if corrective action verification is necessary. If verification is necessary, the corrective action verification will be performed af ter the scheduled completion date and the result of the verification will be documented.

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