ML20134P123

Rev 8 to QA Program Description During Design & Const

ML20134P123
Person / Time
Site:	South Texas
Issue date:	11/02/1984
From:	HOUSTON LIGHTING & POWER CO.
To:
Shared Package
ML20134P108	List: ML20134P123 ML20134P133 ST-HL-AE-1146, Forwards Rev 8 to QA Program Description During Design & Const & Rev 9 to Nuclear QA Program Manual
References
NUDOCS 8509060141
Download: ML20134P123 (52)

Text

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l PART A HOUSTON LIGHTING AND POWER COMPANY QUALITY ASSURANCE PROGRAM DESCRIPTION SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION QUALITY ASSURANCE DURING DESIGN AND CONSTRUCTION REVISION 8 DATE November 2, 1984 8

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HOUSTON LIGHTING & POWER COMPANY QUALITY ASSURANCE PROGRAM DESCRIPTION Table of Contents SECTION TITLE PAGE 1.0 Organization 5 ,

2.0 Quality Assurance Program 15 3.0 Design Control 18 4.0 Procurement Document Control 20 5.0 Instruction, Procedures and Drawings 22 6.0 Document Control 22 7.0 Control of Purchased Material, 23 Equipment and Services 8.0 Identification and Control of 25 Material, Parts and Components 9.0 Control of Special Processes 26 10.0 Inspection 27 11.0 Test Control 29 a

12.0 Control of Measuring and 29 Test Equipment 13.0 Handling, Storage and Shipping 30 14.0 Inspection, Test and Operating Status 31 4

15.0 Nonconforming Materials, Parts 31 or Components 16.0 Corrective Action 32 17.0 Quality Assurance Records 32 18.0 Audits 33 j

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• HOUSTON LIGHTING & POWER COMPANY QUALITY ASSURANCE PROGRAM DESCRIPTION -

List of Tables

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NUMBER TITLE 1 ANSI' Standard and Regulatory Guide Compliance 2 HL&P Manuals Used to Implement the Quality Assurance Program 4

List of Figures NUMBER TITLE 1 South Texas Project Internal QA Relationship 2 Lines of Communication f HL&P & BEC/ Westinghouse (Contractors)

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O I s 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 t~e n responsibility for the quality assur-ance 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, cor.struction 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 assur-ance 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 qual'ty 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 l QUALITY ASSURANCE PROGRAM DESCRIPTION South Texas Project Electric Generating Station Quality Assurance During Design and Construction O

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 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 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.

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

1.2 The Project Quality Assurance Manager, South Texas Project, is respon-sible for providing the programmatic direction, and administering 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 interfaces with the Corporate Quality Assurance Program objectives 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 Presi-dent, 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 activ-ities may be performed as requested by the Project Quality Assurance Manager.

b. Project level control - Project level control is achieved through Project Quality Assurar.cc 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 Program Manual for the Architect Engineer / Construction Manager.

The monitoring is implemented by scheduled Project audits per-formed by qualified auditors. Additional monitoring is accom-plished 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 in-spections are performed by personnel qualified in accordance with ANSI N45.2.6.

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1.4 Executive Vice President, Nuclear Gro_u_p_

The Executive Vice President, Nuclear Group, is responsible for management of nuclear projects and operating nuclear plants and for all nuclear activities within HL&P related to design, engineering, construction, operation, and quality assurance. The Executive Vice President, Nuclear Group, provides technical guidance and administra- "

tive direction to:

a. Vice President, Nuclear Engineering and Construction

b. Vice President, Nuclear Plant Operations (Description of responsibilities is contained in Chapter 17.2, FSAR)

c. Manager, Nuclear Training

d. Manager, Ouality Assurance The Executive Vice President, Nuclear Group, reports to the Chairman of the Board and Chief Executive Officer.

1.5 Vice President, Nuclear Engineering & Construction The Vice President, Nuclear Engineering and Construction, is responsi-ble for nuclear project management and the engineering, construction, and licensing of the nuclear plants. The Vice President, Nuclear Engineering and Construction, provides technical guidance and adminis-trative direction to:

a. General Manager, Nuclear Engineering

b. Manager, South Texas Project

c. Manager, Nuclear Licensing l5

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

1.5.1 Manager, South Texas Project TheManager,SouthTexasProjecj..reportstotheHL&PVice President, Nuclear Engineering crid 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.

1.5.2 Deputy Project Manager The Deputy Project Manager reports to the Manager, South Texas Project. He has the overall responsibility for all 6

design and construction activities for the South Texas Project. The Deputy Project Manager is responsible for direction or delegation of authority to the Startup Manager and the Site Manager; and through the Site Manager to the Site Construction Manager, and Site Support Services l RS Manager. He has the authority to "Stop Work" for cause in all activities related to design and construction of the South Texas Project.

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1.5.3 Site Manager The Site Manager reports to the Deputy Project Manager. He is responsible for providing technical direction and admin-istrative guidance to HL&P and its prime contractors in the area of construction, construction control and reviewing documents, drawings and specifications related to con-struction. He has the authority to "Stop Work" for cause in all activities related to construction.

1.5.4 Site Support Services Manager The Site Support Services Manager reports to the Site Manager. He provides project direction to Site Purchasing, Site Contracts, Site Accounting, Sita Security, Site Records Management, and Material Control personnel. The role of the HL&P Material Control personnel is nonitoring of Bechtel's comprehensive Material Control Program.

1.5.5 Site Construction Manager g The Site Construction Manager 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.

1.5.6 Principal Engineer, Site R8 The Principal Engineer, Site reports to the Deputy Project Manager for project direction and to the Manager, Engineering for technical direction. He is responsible for coordinating the site engineering interface in the technical resolution of all site related engineering problems, reviewing field change requests, site-initiated design change notices, and for monitoring the activities of the

! prime contractor's construction engineering groups. He l assists in the release and interpretation of design l

. documents. He can recommend "Stop Work" for cause in the l engineering and design for those items within his area of 1 responsibility.

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. 1 1.5.7 Supervising Project Engineers, Site M

The Supervising Project Engineers, Site receive technical direction from the Principal Engineer, Site; the Supervising Project Engineer, Special Projects also receives project direction from the Principal Engineer, Site. The Supervising Project Engineer, Construction Support receives project direction from the Site Construction Manager. The '

Supervising Project Engineer, Startup reports to the Startup Manager for project direction. The Supervising Project Engineers, Site direct the efforts of the Site Project Engineering organization in the performance of the owner's ,

review of design and engineering work performed by the prime contractors.

1.5.8 Construction Superintendents (Unit 1, Unit 2, Startup)

The Construction Superintendents report to the Site g Construction Manager. They are responsible for monitoring and surveillance of the prime contractor's construction activities, expediting the resolution and corrective actions of problems identified by QA/QC and verifying that construction planning includes requirements for inspection and testing. The Startup Superintendent interfaces with the Startup Manager to assure the proper construction turnover of systems.

1.5.9 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 engi-neering 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.

1.5.10 Supervising Engineer, STP Licensing The Supervising Engineer, STP Licensing, reports to the l@

Manager, Engineering 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. The Chairman of g the IRC, while not necessarily the Supervising Engineer, STP Licensing, is a duly qualified member of the Nuclear Licensing Department. Assignment of this responsibility will be specified in approved procedures.

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1.5.11 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.

1.5.12 Manager, Records Management and Information Processing The Manager, Records Management and Information Processing reports to the Manager, Support Services. The Manager, RMIP 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.

1.5.13 Manager, Nuclear Purchasing The Manager, Nuclear Purchasing reports to the Manager, Support Services for project direction and to the Vice President, Purchasing for technical direction. He is responsible for overall coordination and administration of purchasing, contracts administration and subcontracting activities for the South Texas Project. He directs the development and implementation of procedures, vendor se-lection, contract negotiations and preparing purchase orders for those contracts administered by HL&P.

1.5.14 Project Purchasing Manager The Project Purchasing Manager reports to the Manager, Nuclear Purchasing. He-is responsible for the proper procurement of permanent and temporary equipment and materi-al for Stores operations of the South Texas Project.

1.5.15 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.

1.5.16 General Manager, Nuclear Engineering The General Manager, Nuclear Engineering reports to the Vice President, Nuclear Engineering and Construction. He pro-vides technical direction and administrative direction to:

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a. Manager, Nuclear Fuel R8 l

b. Manager, Nuclear Services and is responsible for assuring that departmental activities adhere to accepted and approved standards of HL&P, State and )

Federal regulations.

1.5.17 Manager, Nuclear Fuel The Manager, Nuclear Fuel reports to the General Manager, '

Nuclear Engineering. On request from the STP Project Team, the Manager, Nuclear Fuel, supplies nuclear fuel related support to the STP Project Team. (NOTE: All other Nuclear Fuel Department quality activities are described in Chapter 17.2 of the FSAR.)

1.5.18 Manager, Nuclear Services The Manager, Nuclear Services reports to the General Manag-er, Nuclear Engineering. He is responsible for directing project personnel in the performance of an owner's review of selected analyses performed by others.

1.5.19 Manager, Nuclear Licensing The Manager, Nuclear Licensing reports to the Vice R8 President, Nuclear Engineering and Construction. He is responsible for the planning, coordination, direction, and control of the Nuclear Licensing Department activities, and for providing technical direction, as necessary, to ensure that STP licensing activities are accomplished in an effective and timely manner consistent with HL&P policy.

1.5.20 Manager, Engineering Assurance The Manager, Engineering Assurance reports to the Vice President, Nuclear Engineering and Construction. He is responsible for the planning, scheduling, and execution of appropriate independent technical reviews of HL&P Project and Contractor Engineering activities.

1.6 Manager, Nuclear Training The Manager, Nuclear Training reports to the Executive Vice President, Nuclear Group. He directs, coordinates and administers the STP nuclear training efforts and provides direction to the prime contrac-tors 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.

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1.7 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 quality assurance standards and regulatory requirements.

d) Management experience and familiarity 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 Assurance Manager (The responsibilities of the Operations Quality Assurance Manager are described in Chapter 17.2, FSAR.)

The Manager, Quality Assurance, reports to the Executive Vice Presi-dent, Nuclear Group.

1.7.1 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 during the design and

, construction phase of the South Texas Project.

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

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

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b) Familiarity with nuclear power generation facilities and related operations.

c) Knowledge of the QA standards and regulatory requirements. l d) Management experience and familiarity with HL&P c 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 Engi-neer/ 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.

1.7.2 Project Quality Assurance General Supervisor, Quality Engineering The Project Quality Assurance General Supervisor, Quality Engineering reports directly to the Project Quality Assur-ante Manager, South Texas Project. He is responsible for tec',1 cal direction and administrative guidance to the 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 quality related activity during the design and construction phase of the South Texas Project at the site.

1.7.3 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 12

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I personnel in their respective discipline group; conducts audits of the construction manager and contractor activ-

! ities, including QA; interface with NRC during audits;

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identifying deficiencies;-reviewing procedures applicable to-their respective discipline; and providing programmatic i direction to the prime contractor. They have authority to L

'"Stop Work" for cause on any quality related activity during the design and construction phase of the South Texas Prcject 4

at the site.

e .1.7.4 . Supervisor, Quality Systems / Administration I

The Supervisor, Quality. Systems / Administration reports

! directly to the Project Quality Assurance Manager South

! . Texas Project. He is responsible for providing technical i direction and administrative guidance to the Quality Sys-

! tems/ Administration personnel; developing and administering

i. the HL&P Project QA Plan; evaluating the Engi-neer/ Construction Manager and Constructor-QA programs; administering the HL&P STP QA personnel training and certi-j fication program; cdministrative 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 quality related activity i

during the design and construction phase of the South Texas Project at the site.-

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1.7.5 Supervisor, Quality Control

! The Supervisor, Quality Control reports directly to the Project Quality Assurance Manager, South Texas Project. He <

(l is responsible for technical direction and administrative guidance to the HL&P Quality Control personnel, coordinating inspection of. selected fabrication and con-

, struction activities, ensuring proper nonconformance identi-o fication and assuring that the personnel performing in-

! spections are properly certified. He has the authority to j "Stop Work" for cause on any quality related activity during the design and construction phase at the South Texas Project

at the site.

I Project QA Supervisor, Design / Procurement 1.7.6 i

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 De- ..

! sign / Procurement Quality Assurance personnel, coordinating

[ the resolutions of vendor problems identified by HL&P QA,4 coordinating with site QE personnel for input to vendor 13

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surveillance / audit activities and providing programmatic direction to the Engineer / Construction Manager regarding design control, vendor surveillance and auditing functions. l He has the authority to "Stop Work" for cause on any quality l related activity during the design and construction phase of l the South Texas Project at the Design office. l J

1.7.7 Support Quality Assurance Manager The Support Quality Assurance Manager is responsible for directing all HL&P corporate office auditing, vendor surveillance and vendor evaluation 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.

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c) Knowledge of the industry QA standards and regulatory requirements.

Management experience and familiarity with HL&P d) 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 group, c) Directs the HL&P Vendor Evaluation group.

The Support Quality Assurance Manager reports on all quality assurance matters directly to the Manager, Quality Assur-ance.

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

HL&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 W effectively implemented.

a) Houston Lighting & Power Company as a licensee and Project Manager for itself and the other owners has the overall respon-sibility for design, engineering, procurement, construction, operation and quality assurance activities. Bechtel Energy Corporation and Westinghouse Electric Corporation have contractu-al responsibility to provide acceptable QA programs to HL&P. The contract provides HL&P the authority to audit and monitor BEC and Westinghouse performance to assure that the QA programs provide for sufficient authority and organizational freedom to be effec-tively implemented, b) Bechtel Energy Corporation as the Architect / Engineer and Con-struction Manager provides HL&P with design, engineering, pro-curement, construction management and quality assurance services.

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

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 contrac-tors 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 15

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l Table 3.2.A-1 of the FSAR within the scope of their work. BEC pro-

vides quality assurance and quality control services for Westinghouse

' items (Table 3.2.B-1) upon receipt at the site until release for i construction, after which ESI provides such services.

l 12.3 The HL&P Quality Assurance Program for the South Texas Project is described by the HL&P Project Quality Assurance Plan. The plan <

4 requires that written procedures, training and certification, issuance t . of specifications and drawings, and work and inspection planning be i accomplished in advance of performing nuclear safety-related activ-

.ities. 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 publica-

tions " 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 Con-struction Phase of Nuclear Power Plants," (The Green Book) dated May l 10,1974 (WASH 1309). Presently the regulatory guides and standards listed on Table 1 are in effect for the South Texas Project.

i 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 proper-li ly implemented is accomplished by HL&P Ouality Assurance through

audits, surveillance, and regular management assessment of the Quality

] Assurance Program.

5 2.5 It is the' policy of HL&P, acting as a licensee and Project Manager for j the other owners for the South Texas Project, to assure that the l design,. fabrication, construction, testing and operation of STP are in l conformance with Project specifications, procedures, codes and NRC l regulations. It is the responsibility of each organization assigned I to the STP to ensure that Project procedural review methods include i provisions to ensure that the requirements stated in this program i' description are incorporated into Project procedures. The Project Quality Assurance Plan identifies activities and establishes require-

ments for procedures which identify, initiate and verify the resolu-tion of nuclear safety-related quality problems.- The implementing l 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 l levels, the Manager. Quality Assurance, presents the problem ultimate-ly to the HL&P Executive Vice President, Nuclear Group, for resolu-3 tion.

! 2.6. The HL&P Nuclear Training Department is responsible for conducting a quality oriented indoctrination program for new HL&P personnel who i have quality-related functions. The HL&P Project Quality Assurance i Plan requires that prior to performing activities affecting quality the personnel are trained, as necessary, in the applicable procedures.

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The training provides a thorough unuerstanding 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 Assur-ance to determine that the contractor's procedures require proper equipment, environment and other prerequisites to perform the associ-ated activity. The implementation of these requirements is verified through audits and surveillance by HL&P, BEC and ESI Quality Assur-ance.

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 4 President, Nuclear Group, assures that an objective program assessment of the South Texas Project Quality Assurance programs is being per-

formed.

HL&P Project Quality Assurance reviews and documents approval of the BEC Project Quality Program Manual (PQPM); and audits and surveil-lances 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 quali-ty-related activities from BEC to HL&P during phasecut of design /-

construction and plant turnover. This program will be implemented prior to preoperational testing. This program will be in accordance i

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 De-scription as an effective and meaningful document to provide program-matic 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 previ-i ously established in the QAPD, approval by the NRC will be obtained prior to implementation of the change (s).

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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, Criteri-on III, Regulatory Guide 1.64 and ANSI N45.2.ll 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 associ-ated 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.

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

The HL&P Manager, Engineering is responsible for ensuring that Project engineering activities are conducted in accordance with approved engineer-ing 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 accor-dance with the requirements of this section and/or the FSAR Section 17.2.3.

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1 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 methods of accomplishing and controlling essential design activities.

Design documents such as calculations, diagrams, specifications and 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 orig-inated changes, are controlled in a manner commensurate with the control imposed on the original design.

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 require-ments have been satisfied.

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

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Deviations from specified quality standards are identified and proce-dures 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 c 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 accom-plished 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 Westing-house. BEC will approve any Ebasco nuclear safety-related procurements.

BEC, and as appropriate, Ebasco verify through contract, vendor surveil-lance and audit that their suppliers comply with the established require-ments.

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.

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 docu-ments is provided and available for verification.

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Procurement documents identify those quality assurance 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, pac.kaging, 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 nonconfor-mances 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 detennine the adequacy of the quality assurance requirements and acceptance criteria relative to the origi-nal design.

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.

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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 j 1

The HL&P Project Quality Assurance Plan requires HL&P, the prime contrac-tors and their suppliers to establish and implement a Quality Assurance  ;

Program which is in compliance with 10CFR50 Appendix B, ANSI N45.2 and J 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 writter, 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 i prime contractors' quality assurance programs, HL&P Project Quality Assur- l ance has implemented a monitoring program consisting of audits and surveil-lances. HL&P Project Quality Assurance also audits HL&P Corporate organi- R8 i zations that perform functions for the South Texas Project. Additionally, '

HL&P Corporate Quality Assurar.ce audits 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 -

ect. 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 docu-ments, 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 ap-proved for release by authorized personnel and are distributed to and used at the location where the prescribed activity is performed. Changes to documents are reviewed and approved by the same organizations that per-formed 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.

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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 prepar-ing, reviewing, approving and issuing documents and revisions thereto; Identifying the proper documents to be used in performing the activi-ty;

• 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, proce-dures, 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 imple-mented.

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 confor-mance to the purchase order or contractual requirements. These procedures provide for:

Requiring the supplier to identify processes to be utilized in ful-filling procurement requirements.

Reviewing documents required to be submitted by the procurement requirements.

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.

23 1

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 accom-plished by technical verification of data provided, surveillance and/or audit of the activity and review of objective evidence such as certifica-tions, 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 hre 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 receiv-ing documentation.

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

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

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

• Coordination of receipt inspection with vendor surveillance activities to verify the required vendor inspection has been performed or a j J

waiver documented.

• Deficiencies if applicable have been resolved prior to shipment.

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 descrip-tion of those nonconformances from the procurement requirements disposi-tioned " 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 surveil-lance and inspection are performed in accordance with the quality assurance program. In addition, HL&P Quality Assurance performs audits and surveil-lances 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 compo-nents. 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 asserably or installation. These procedures must:

• Establish controls to identify and control materials (including consumables), parts and components (including partially fabricated subassemblies).

Provide specific identification and traceability controls when required by codes, standards or specifications.

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 installa-tion.

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c '

i ,

All safety related items and materials shall be controlled by one or more of the following:

1 Uniquely identified and traceable.

Physically marked - items are not traceable but are readily retriev-able.

Physically identified as to type and user tested.

• Identifiable as to type, by some physical characteristic or other administrative control.

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

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 quali-fication of personnel, procedures and equipment relating to specific codes, standards, specifications and contractual requirements shall be documented and maintained current.

I Special Processes - special manufacturing processes, metallurgical, chemi-

! cal, material cleaning, welding, plating and other. processes where assur-ance of the process quality is dependent largely on the inherent skill of the operator and cannot be assured by the inspection of articles alone.

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

Welding Heat treating Cadwelding Nondestructive examination Chemical cleaning and flushing

. Coatings 26

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.

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, person-nel qualification and procedure qualification requirements are defined prior to application of the special process.

Records are maintained for the qualification of procedures, equipment and i personnel associated with special processes. Records are in sufficient

' detail to clearly define the procedures, equipment or personnel being qualified; criteria or requireme ts used for qualification; and the indi-vidual approving the qualification.

HL&P Quality Assurance verifies that the special process control criteria

are met by BEC and ESI review and approval of special process procedures and their performance of audits and surveillances to ensure compliance.

to HL&P directedwill byretain the capability the PQAM, certain specialwith aprocess quality examinations control group (NDE) perform, during the as inspection verification process. These examinations will be performed by j personnel qualified in accordance with SNT-TC-1A-80 using qualified proce-dures approved by HL&P NDE Level III personnel. Instances of recommenda-tions within SNT-TC-1A-80 ('shoulds') will be considered mandatory require-ments('shalls'). This exception will be reflected in approved implement-i ing procedures.

HL&P Quality Assurance performs audits and surveillances of special process activities to ensure compliance with all aspects of the Quality Assurance Program.

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 certifica-

tions of inspectors include criteria from appropriate codes, standards and procedures. Inspector training shall be documented and kept current.

Inspection activities relating to construction, fabrication, installation and testing are documented, kept current and identify all mandatory in-spection hold and test points and the criteria to be witnessed by au-thorized inspectors. Operations and inspections (including rework, re-placed items) are performed in predetermined, documented sequences.

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o .

l Deviations or deletions must be accomplished in accordance with approved i il and documented systems. Inspection procedures include all required in- '

spection operations defined by the specifications, drawings, codes and standards. These procedures provide for the following:

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 performing j the inspection operation

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 i g. Specifying necessary measuring and test equipment including accuracy requirements and verification of calibration I h. Evaluation of inspection results Where direct inspections are impossible or disadvantageous, in-process j monitoring is specified in the inspection procedures and both direct and in-prccess monitoring are used when control is inadequate without both. ,

4 All required procedures, specifications and drawings are made available to the inspectors prior to performing inspection. If mandatory inspection i hold points are required beyond which work cannot proceed without the 7

specific consent of the designated representative, the specific hold points will be indicated in appropriate documents. Inspection results are docu-mented, 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.

l HL&P Quality Control may oce.asionally perform inspection verifications as .

deemed necessary by the Project Quality Assurance Manager, i

i HL&P, BEC and ESI Quality Assurance perform audits and surveillance of

inspection activities to ensure compliance with all aspects of the quality l assurance program.

The HL&P inspectors are trained and certified by a program conforming to i 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.

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11.0 Test Control The HL&P Project Quality Assurance Plan requires that a test control program be developed and documented by the prime contractors and contrac-tors for tests that they are responsible for, which demonstrates that the facility performs in accordance with the South Texas Project requirements and specifications. Preoperational testing and start-up testing require- -

ments are established by the Operational Quality Assurance Plan, as de-scribed in Chapter 17.2 of the FSAR. The training, certification of personnel, calibration and certification of test equipment, system or component status, environmental conditions, inspection hold points and configuration 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.

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 environ-mental conditions and provisions for data collection and storage

d. Mandatory inspection hold points for witness by Owner and the contrac-tor'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 i

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 Assur-ance 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, docu-mentation and implementation of a Measuring and Test Equipment Control 29

O .

System. The system is to include calibration techniques, accuracy, fre-quency 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 stan-dards 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 inves- -

tigation 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.

Measuring and test equipment is calibrated at specified intervals and based on the required accuracy, purpose, frequency of use, stability charac-teristics, 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 cali-brated will be within required tolerance and that the basis of acceptance is documented and authorized by responsible management.

Calibrating standards will, whbn 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 manage-ment.

BEC and ESI Quality Assurance review and approve calibration procedures to ensure these criteria are incorporated. In addition, HL&P, BEC and ESI Quality Assurance perform audits and surveillances to verify compliance.

In the conduct of its inspection verifications, as directed by the PQAN, HL&P Quality Control is required 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 safe-ty-related items, written procedures be developed in accordance with design requirements, specifications and standards to control the cleaning, hand-ling, storage, packaging, shipping and preservation to preclude damage and deterioration by environmental conditions. The activities are to be accomplished by appropriateiy 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 proce-dures.

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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 operating status of nuclear safety-related items through the use of stamps, markings, tags or other suitable means. Procedures include the require-ments for:

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

b. Documenting the status of nonconforming, inoperative, or malfunction-ing structures, systems and components to prevent inadvertent use

c. Defining, controlling and documenting the use, application and removal 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, inspec-tions 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 compli-ance.

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 proce-dures shall specify the preparation and handling of nonconformance docu-ments, 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 corrected or resolu-tion determined prior to initiation of the preoperational test program on the item. Rework, repairs and subsequent 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 noncon-formance shall obtain concurrence of the Westinghouse Site Representative.

HL&P Quality Assurance performs trend analysis of HL&P, BEC and ESI noncon-formances. Procedures are established by HL&P to report significant deficiencies during the design, construction and startup phase to HL&P executive management and to the Nuclear Regulatory Commission in accordance with 10CFR50.55(e) and 10CFR21 where applicable.

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

16.0 Corrective Action The HL&P Project Quality Assurance Plan for the South Texas Project re-quires that a system be established and documented by HL&P and the prime m contractors which defines the responsibilities, authorities and methods used by specific groups involved in the evaluation of nonconfonnances and trending to determine the need for corrective action. The system includes measures to identify the cause of significant conditions adverse to quali-ty, measures to ensure that the root causes are corrected, and 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 correc-tive action. General categories of documents to be trended are: Noncon-formance Reports; Corrective Action Reports; Deficiency Notices; and Audit Deficiency Reports. Specific documents to be trended, and the frequency of trending, 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 relat-ing 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 ANSI 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-hcur rated fire resistant file room meeting NFPA No. 232-1975 including the following provisions:

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

Records are stored in fully enclosed metal cabinets 32

Smoking and eating / drinking are 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 ESI Quality Assurance perform audits and surveillances to assure compliance.

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 ANSI 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 I Executive Vice President, Nuclear Group. 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 g on the HL&P Project Quality Assurance group, and Westinghouse. HL&P Project Quality Assurance is primarily responsible for audits of the Engineer / Construction Manager, constructor, subcontractors, HL&P Project team organizations, and the HL&P corporate organizations providing services to the Project. 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 i

Table 1-1 l I

l I

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 place-ment 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 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/or tolerances pertaining to air content, slump, or temperature are exceeded at the placement point, corre-lation tests between the delivery point and placement point will be accom-plished for each 100 cu. yds of concrete placed as long as limits and Table 1-2

TABLE 1 ANSI STANDARD AND REGULATORY GUIDE COMPLIANCE l (Continued) tolerances are exceeded. If two consecutive tests are out of tolerance, corrective action will be imple'nented 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 " 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 STP Final Safety Analysis Report).

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

3. Section 3.1, Design Input Requirements, General. This section implies that all 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 finn 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 crite-ria used and analyses performed to the final design documents and that 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 prac-tice for the responsible enginesr or engineering organization to retain all final calculations, and this will be done for all manual calculations covered by the program. However, for computer programs only documentation i of the design input, assumptions made in the analyses, results obtained, and evidence of verification will be retained since permanent retention of l

all versions of all computer programs is not considered practical or necessary if sufficient information is available for a competent individual to verify the results using the input and assumptions.

l l

l Table 1-3 l

l 1

' l TABLE 1 l ANSI STANDARD AND REGULATORY GUIDE 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 indi-vidual 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 proj-ects. 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 proce-dures 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 ectivities will be performed in accordance with procedures specific to the system.

9. Section 4, Preinstallation Cleanliness. This section states, " Items should not be delivered to the point of. installation site sooner than ne, ssary 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, thereby reducing susceptibility to handling u mage. In all such cases, equipment stored in place will be protected in accordance with Section 5 of ANSI N45.2.1.

4 Table 1-4

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 de-termining " metal clean" of accessible surfaces of piping and components is ~

determined by the inspector. Typically he uses a standard two-cell flash-light 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 ro uirements for each classification as specified in the standard will be apclied 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 examole, 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 tc 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 storage. While the above areas will 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 5.0, 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 super-vision and inspection.

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

16. Appendix A 3.4.2, Inert Gas 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

1

)

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-ects. 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 euch case. Installation plans or proce-dures 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 exam-ple, 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 proj-ects. 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 proce-dures 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 appear-ance, dimensional requirements, and structural features would not neces-sarily 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 r.ct 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 proj-ects. This results in standard procedures or plans for installation and inspection and testing which meet the requirements of the standard.

l Table 1-6 i

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 ir each case. Installation plans or proce-dures 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 " con-struction site." When applied to documents, these may be at the central office or work area document control station.

b. Installation area - Imediate 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 "Respon-sible 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 or organization.

26. For Appendix A, an installation shall be considered to be in an "as con-structed" 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

3 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 re:ards that have been accumulated in "

connection with previous procurement actions. Data that includes experi-ence of users of identical or similar products of the prospective supplier and product operating axperience 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., Verifica-tion 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 sys-tems. 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 audited orga-nization 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 corrcctive 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) in its entirety.

Table 1-8

~ _ _

TABLE 2 HL&P MANUALS USED TO IMPLEMENT THE l QUALITY ASSURANCE PROGRAM  !

l Project Quality Assurance Plan l Project Specific Quality Assurance Procedures Manual q Support Division Quality Assurance Procedures Manual Project Engineering Procedures Manual Project Site Procedures Manual Project Licensing Procedures Manual Project Procurement Procedures Manu&l Project Management Procedures Manual Records Management Systems Procedures Manual J

4 i

I k

Table 2-1 l

NOTE 1 14 E mecutive vice ,

Presutent, Nuclear Group .

l 15 l 16 l 1.7 i

s Vice Presilent.

Nucicar Eng.neering Manaq't. Manager,

& Construct.on uclear Tra.nene Ouahty Assurance l

l 1 5.16 l 1 s t9 151 l 1570 l 1.71 y7y General Menacer. Ltanager. L'anacer, South Tevas Prmect

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l 1518 j l 1.7.3 175 l

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) Nuclear Services Supervising Qua' sty Eng.neering S.te Engmeer. E ng.neer.

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=.........

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- - - -- TECHNICAL DIRECTION ONLY

---

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PART B BECHTEL ENERGY CORPORATION QUALITY ASSURANCE PROGRAM DESCRIPTION SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION QUALITY ASSURANCE DURING DESIGN AND CONSTRUCTION REVISION 8 i

DATE November ?, 1984 l

7 i

i e

I I

i y . ~ - -, , -- y y

e Explanation of Attached Correspondence:

a) J. M. Amaral (BPC) to J. M. Taylor (NRC), dated June 7, 1984;

Subject:

Organizational Changes l Note: This reorganization has no effect on the South Texas Project.

The letter is being included for continuity, but the referenced organization charts have been intentionally omitted, b) J. M. Amaral (BPC) to G. T. Ankrum (NRC), dated August 15, 1984;

Subject:

Organization Changes c) J. N. Grace (NRC) to J. M. Amaral (BPC), dated August 28, 1984;

Subject:

NRC Acceptance of (above) Organizational Changes Letters a) and b) above were submitted by Bechtcl Power Corporation to amend BQ-TOP-1, Revision 3A to accurately reflect changes to the Bechtel group of companies and the restructuring of the Bechtel Power Corporation.

Letter c) above is the NRC acceptance of the proposed changes.

i QAPD 1/1000/BSN

t Bechtel Power Corporation Engmeers--Constructors Fifty Scale Street gp

- San Francisco. Cahfornia West Address: P O. Box 3965. San Francisc . CA June 7,1984 i

[ *

+

NLL@

Mr. James M. Taylor Deputy Director Office of Inspection & Inforcement U.S. Nuclear Regulatory Cosumission Washington, D.C. 20555

Subject:

Bechtel QA Topical Report BQ-TOP-1, Rev. 3A

Dear Mr. Taylor:

As directed by your October 1980 acceptance letter of Bechtel QA Topical Report BQ-TOP-1, Rev. 3A, I am submitting for your information a short description of changes made to restructure the organization of the Bechtel group of companies.

Bechtel Group, Inc., and its operating companies, including the Bechtel Power Corporation (BPC), were restructured as of May 21, 1984. As a result of this organizational change, a new construction-only subsidiary, Bechtel Construction, Inc. (BCI), and its subsidiary, Bechtel Constructors Corpora-tion (BECC), have assumed the responsibility for performing the domestic direct hire work and construction management work of all the divisions. All construction employees located at U.S. jobsites will be transferred to those

companies as well as U.S. permanent office employees in the construction departments, field procurement organizations, and labor relations and safety organization.

We would like to emphasize that the introduction of BCI and BECC will not involve any change in the Bechtel management or personnel now engaged on our projects, and all of the existing operating and reporting relationships will remain the same. The restructuring will result in no programmatic changes.

Attached is a copy of the organizational charts that reflect the BCI and BECC change.

Very truly yours, PY John M. Amaral Corporate Manager of Quality Assurance Bechtel Power Corporation cc: Mr. G. T. Ankrum Mr. J. T. Collins sc:9

[

' A .: ; .;.4 Bechtel Power Cor tion . -

w/o Enewesuers ~.-- m bcct S. A. Bernsen ~'-

OE R. Nelsen w/o 8 .  :

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. J. V. Morowski w/o sen Franceco, cantornie L. '.

Weu Aseress: P O aos 396s sen Francoc8.cA 94119 . _

August 15, 1984 h -

Mr. G. T. Ankrum l- '

Nuclear Regulatory Consissica (NRC) -

U.S. NRC Office of Inspection & Inforcement ,

Washington D.C. 20555 {-- .-

\ _ . . .

1.

Subject:

Bechtel Power Conoration Organizational Changes ... . ..

oc . . . . .

Dear Ted:

F;.6... --.- ",

As directed by your October 1980 acceptance letter of Bechtel VA Topical Report BQ-TOP-1, Aev. 3A, I am submitting for your information a short description of changes made to restructure the organization of the 8echtel Power Corporation. This letter will confine our telephone conversation of August 13 and H. 0. Reinsch's briefing to the Nuclear Regulatory Commission.

The Bechtel Power Corporation has been restructured to consolidate the four power divisions into two major regional operations, the Western Power Divi-sion and the Eastern Power Division. The Eastern Power Division will consist of the former Ann Arbor and Gaithersburg power divisions, with l' Gaithersburg being the new headquarters and Ann Arbor becoming an area office. Similarly, the Western Power Division will combine the former San Francisco and Los Angeles power divisions, with Los Angeles being'the head-quarters and San Francisco becoming an area office. Bechtel Power s Hauston area office will become a project office. The enclosed Management Memo dated August 6,1984, describes these changes in more detail.

No quality assurance progrannatic changes are anticipated at the project level because of the morganization. Because this is a major restructuring i

of the Bechtel Power Corporation, many of the details have yet to be worked out and it is anticipated that it will be some time before all of the many necessary changes are finalized. We will keep you advised of any signif t-cant organizational changes that take place as a msult of this reorgant-l zation, especially programmatic changes that may occur. We will submit copies of our new organization charts to you when they are available,

~

r%trulydours,L J. M. Amaral .

Conovate Manager of Quality Assurance i i

Bechtel Power Corporation JMA/mb cc: Mr. R. C. Haynes Mr. J. P. O'Reilly Mr. J. G. Collins Mr. J. B. Martin Mr. J. G. Spraul Mr. J. M. Taylor en

- ~.~) ~ \

1. jno* n?,'o,, UNITED STATES - ' f) { >

l

, NUCLEAR REGULATORY COMMISSI wasMm0 ton. D. C. 20088

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.  % . .w. . . - AUG 181964 N

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Jocket No. 99900500

• 7 s l

/

Mr. John M. Amaral /

Corporate Manager of Quality Assurance "

Bechtel Power Corporation ~~

j P.O. Box 3965  ;

San Francisco, CA 94119

Dear Mr. Amaral:

In your letter to Mr. James M. Taylor dated June 7,1984, you describe changes to the organization of the Bechtel group of companies, i.e., the femation of Bechtel Construction, Inc. (BCI) and Bechtel Constructors Corporation (BECC).

You state that BCI and BECC are responsible for perfoming the domestic direct hire work and constructicn management work of all the divisions and that all stateside construction eployees and some permanent office employees in other organizations will be transferred to these corporations. You provide organiza- We tien charts that reflect the reorganization as attachments to your letter.

uncerstand that, in acditicn to being the Corporate Manager of Quality Assurance for the Bechtel Power Corporation (BPC), you also fill the positions of Manager We of Quality Assurance cf BCI and SECC shewn en Figures 3 and 4 of your letter.

also uncerstar.c that Mr. h. Reinsch is the BPC President, the BCI President, and tne SECC Presicent.

We note that the Quality Assurance Manager of each of the Power Divisions and tne Ecutten Area Office is shcwn on the organization charts as part of the ECI/SECC organizations. However, we understand that these managers continue their responsibilities for cuality anurance throughout their respective divisions as cescribed in 80-T09-1, "Eechtel Quality Assurance Program for hciear Pcwer Plants." We also understand that, except for the organization changes describec in your Jure 7 letter, the quality assurance programs de-scrited in 90-709-1 are applied to safety-related nuclear activities performed by the Bechtel Power Corporation.

15, 1984, you describe a Ir. ycur letteroftoBPC.

restructuring Mr. G. T. Ankrum dated AugustYou state that BPC has been restructur the four power divisions into two major regional operations, the Western Power Division and the Eastern Power Division, that the Eastern Power Division will consist of the foriner Ann Arbor and Gaithersburg power divisions, that the Western Power Division will combine the fomer San Francisco and Los Angeles pcwer -divisions, and that Bechtel Power's Houston area office will become a project office. You inoicate that no cuality assurance progrannatic changes are anticipated at the project level because of the reorganization and that it will be some time before all of the changes are finalized. We understand that you will keep us acvised of any significant organizational changes that take place as a result of this reorganization, especially prograrinatic changes tnat may occur and that you will submit copies of new organization charts when they are available.

v,. v :, .. . ,- . . . .ir wwm . u. un ... . . .

. . 1

~

l 1

U Mr. John M. Amaral We wish to be advised if our understandings are incorrect or if there is any change which would make them incorrect.

Based on the understandings stated above, we fine the infonnation presented in your June 7 and August 15, 1984 letters acceptable with respect to quality assurance activities described in BQ-TOP-1. Please issue the infont.ation described in your letters, together with this letter, to all holders of the approved tcpical report. Also, the inforr.ation should be incorporated into BQ-TOP-1 at the time of the next revision.

If you have any questions on the above, contact Jack Spraul of the Quality Assurance Branch en (301) 492-4530.

Sincerely, vi

J. Nelson Grace, Director Division of Quality Assurance.

. Safeguards, and Inspection Programs Office of Inspection and Enforcement

PART C r

EBASCO SERVICES INCORPORATED.

QUALITY ASSURANCE PROGRAM DESCRIPTION SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION QUALITY ASSURANCE DURING DESIGN AND CONSTRUCTION REVISION 8 1

! DATE November 2, 1984 i

s j

l-

. . . .. . .-. . . --