ML20235Z529

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Forwards Rev 5 to App B of Updated FSAR & marked-up Rev 4 Reflecting All Changes Made Throughout Rev 5.Evaluation Has Determined That Changes Do Not Involve Any Reduction in Commitments
ML20235Z529
Person / Time
Site: Fort Saint Vrain Xcel Energy icon.png
Issue date: 07/21/1987
From: Robert Williams
PUBLIC SERVICE CO. OF COLORADO
To: Calvo J
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), Office of Nuclear Reactor Regulation
References
P-87261, NUDOCS 8707270321
Download: ML20235Z529 (135)


Text

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I OPublic Service ~ . . . . . .

Company of Colorado l July 21, 1987

' Fort St. Vrain Unit No. 1 P-87261 U.S. Nuclear Regulatcry Commission ATTN: Document Control Desk Washington, D.C. 20555 ATTN: Mr ' Jose A. Calvo Director, Project Directorate IV Docket No. 50-267

SUBJECT:

Fort St. Vrain Updated FSAR, Revision 5 Appendix B

REFERENCE:

PSC letter, R. O. Williams to J. A. Calvo, dated 7/21/87 (P-87256)

Gentlemen:

Enclosed for your information is a copy of Revision 5 to Appendix B of the Updated Final Safety Analysis Report for Fort St. Vrain (Enclosure 1). Also enclosed, for your convenience, is a marked up copy of Revision 4 which reflects all of the changes made throughout Revision 5 and evaluates their effect on previous commitments  ;

(Enclosure 2). Public Service Company of Colorado has evaluated these changes and has determined that they do not involve any reduction in commitments. Other changes which do involve a reduction in commitments are being transmitted for NRC approval under separate cover in the referenced letter, in accordance with the requirements of 10CFR50.54(a)(3).

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p ADOCK 05000267 PDR \

P-87261 July 21, 1987 If you have any cuestions regarding this submittal, please contact Mr. M. H. Holmes at (303) 480-6960.

Sincerely,

  • R. O. Williams, Jr.

Vice President, Nuclear Operations Fort St. Vrain Nuclear Generating Station R0W/PFM:bm Enclosures cc: Regional Administrator, Region IV Attention: Mr. J. E. Gagliardo, Chief Reactor Projects Branch Mr. R. E. Farrell Senior Resident Inspector Fort St. Vrain i

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ENCLOSURE 1 TO P-87261 l

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UPDATED FSAR Revision 5 B.5-1 B.5. QUALITY ASSURANCE PROGRAM FOR PLANT OPERATION It is the policy of Public Service Company of Colorado to use its '

best efforts to insure that the Fort St. Vrain Generating Station is maintained and operated in a manner that assures the highest practical degree of safety to the public and to its employees.

l The Vice President, Nuclear Operations is assigned the authority and responsibility within PSCo for all activities associated with engineering, procurement, operation, maintenance, modification and quality assurance of the Fort St. Vrain Generating Station. To ensure that all of these activities are performed in a manner consistent with the policy of PSCo, the Company has established and implemented a Quality Assurance Program to meet the requirements of 10CFR50, Appendix B and the applicable regulatory requirements (Ref.

5).

All personnel performing duties affecting quality including those of contractors, suppliers, and any other organization performing quality activities associated with the nuclear project are responsible for compliance with the directives established within the Quality Assurance Program.

The Public Service Company of Colorado policies and guidelines l for nuclear activities sets forth the commitment that the Company has l made to quality for operation of the Fort St. Vrain Nuclear Station.

l The organizational structure for accomplishing the quality functions is defined, as are individual responsibilities of persons involved in l quality activities and management. The PSCo policy document provides for development of procedures and instructions which will define in l detail the nature and extent of the quality effort to be carried out in each segment of plant operation, throughout the life of the plant.

The policy document provides for indoctrination and training of personnel performing activities affecting quality, and for biennial review of the effectiveness of the program by management and intermediate supervisory levels. The policy document commits the management of PSCo to compliance with the intent of 10CFR50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and other applicable regulations, codes and standards.

Policies require that the various aspects of plant operation are to be defined and controlled by written procedures which include the Technical Specifications issued with the operating license. Policies l also require that all maintenance and repair of the nuclear power plant is to be controlled to avoid violation of the conditions of the license and to preserve margins of safety provided in the original design and construction.

l Modifications to the plant are required to be controlled in accordance with written procedures which prescribe the responsibilities of the Production, Engineering, Licensing and Fuel and Quality Assurance personnel; which provide measures to control interfaces between those organizations involved in plant modifications and design control; and which define the methods to be

UPDATED FSAR R: vision 5 B.5-2 followed to initiate, design, aralyze, review, approve, install, inspect, test, and accept modifications to the plant.

In addition to specific policies and guidelines for organization, operation, training, maintenance and ' modifications, other policies and guidelines deal with procurement, construction, nuclear fuel, radiation protect *on, safety, security, emergency planning, fire prevention, startup and testing, environmental protu tion, and nuclear plant procedures. A listing of the current policies' and guidelines is given in Table B.5-1.

Although extensive changes have been made to the QA Program for operation as presented in Amendment 32 of the original FSAR Refs. 6, 16, 22, 23 and 24), the PSCo Quality Assurance program (see for Plant Operation is responsive to the scope and requirements of 10CFR50, Appendix B. The manner of compliance with each of the NRC QA Criteria is discussed in detail in the following paragraphs.

B.5.1. Organization B.5.1.1. Quality Assurance program Responsibility The Public Service Company of Colorado (PSCo) Vice President, l Nuclear Operations, has executive level responsibility for all FSV Generating Station engineering, operations, maintenance, modification, licensing and quality assurance activities. The Vice President has overall responsibility for the FSV Generating Station Quality Assurance Program. Direct responsibility for Quality Assurance Program definition, implementation and effectiveness has been delegated to the Manager, Quality Assurance who reports to the l Vice President, Nuclear Operations.

The Vice President maintains cognizance of the Program and evaluates its status and adequacy through review of monthly reports, meetings and/or audits. A complete management audit of the program is conducted under his cognizance biennially.

Disputes, arising from differences of opinion between divisions, which are not resolved by the responsible administrators, are referred to the Vice President for resolution.

B.5.1.2. Organizational Arrangements The management structure for the FSV Project is divided among four organizations as follows:

a) Nuclear Engineering Division, provides technical assistance, studies, analysis, engineering, design, construction management and general services in support of operation, modification and maintenance of the plant.

b) Nuclear Production Division, is responsible for the operation and maintenance of the Fort St. Vrain Facility.

t _________.____________________m

UPDATED FSAR l Revision 5 B.5-3 l

c) Nuclear Licensing and Fuels Division is responsible for nuclear licensing activities, fuel management and spent fuel management services, and functions as the central nuclear ,

licensing contact with the NRC.

l d) Quality Assurance Division, documents verifies implementation of the QA program responsibilities as discussed in Section B.5.1.3.

The corporate organization chart is shown in Figure 8.5-1. The organization charts for the Nuclear Engineering, Nuclear Licensing and Fuels and Nuclear Production Divisions are shown ir Figures 12.1-2, 12.1-3 and 12.1-4, respectively. The organization chart for the Quality Assurance Division is shown in Figure B.5-2.

B.5.1.3. Quality Assurance Division Responsibilities a) Manager, Quality Assurance The Manager, Quality Assurance reports to the Vice j President, Nuclear Operations, and is assigned everall responsibility for the FSV Quality Assurance Program adequacy, and implementation effectiveness. The Manager, QA has been assigned the necessary authority, resources and organizational freedom to manage the Quality Assurance Program; identify quality problems; initiate, recommend and provide solutions; and to verify implementation of solutions.

The Manager, Quality Assurance or his designated alternate, has the authority to order that work be stopped; when, in his opinion, maintenance, repair or modification work does not comply with the approved controlling documents. For operating activities, the Manager, Quality Assurance or his designated alternate has the authority to recommend that work stop. However, authority to stop work on operating activities remains with the Superintendent, Operations or the Senior Licensed Operator present, who will determine whether such stoppage would cause any violation of the Technical Specifications or other approved documents governing plant operations, or whether there are overriding considerations of safety involved.

Minimum qualifications required for the Manager, Quality Assurance are as shown in Table B.5-2. The Manager, Quality Assurance is responsible for:

1) The adequacy of the Quality Assurance Program and its implementing procedures, interpretation of Quality Assurance requirements and effectiveness of the Program's implementation.
2) The use of appropriate techniques to assure conformance of all activities effecting quality to the Program's requirements.

UPDATED FSAR Revision 5 B.5-4

3) The adequacy, clarity and appropriateness of all PSCo Quality Assurance related communications and ,

commitments directed to Regulatory' Agencies, Contractors and Suppliers.

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4) Appropriate exercising of the authority vested in the Quality Assuronce organization to cause the acceptance or rejection . ' work, materials and equipment based on conformance or nonconformance to approved engineering i or Code requirements. i
5) Apprising management of the Station's quality status by monthly reporting on quality activitias, trends and problems.
6) Assuring that effectiveness evaluation actions such as QA Program reviews, monitoring and audit techniques are employed to veri fy conformance to requirements of activities affecting quality, including activities involving contractors and suppliers.
7) Coordinating applicable activities of regulatory agencies such as audits, inspections or investigations with the affected organization manager (s).

l l b) QA Services Manager The QA Services Manager reports to the Manager, Quality-Assurance, and is responsible for Quality Engineering l activities, Quality Control inspection activities, and maintenance Quality Control. His organization is responsible for:

1) Preparation, coordination with affected organizations, submittal for required approval, and maintenance of "Q" Procedures in the Fort St. Vrain Administrative Procedures, and quality assurance services procedures necessary to implement the Quality Assurance Program.
2) Review of design Change Notices and Specifications for Station modifications to verify the appropriateness and conformance of specified requirements to applicable quality and code requirements.
3) Review of PSCo generated procurement documents for l items controlled by the QA Program to verify appropriateness of quality provisions.
4) Evaluation of supplier /centractor capabilities / data to verify qualification adequacy and maintaining an l " Approved Vendors List".
5) Preparation, review and approval of special process procedures required for specific applications.

___.___._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ - - - - - - _ - - _ - - - - - - - - - - - - - - - - - - - -- - - --- ' ~

l' UPDATED FSAR

' Revision 5 B.5-5

6) Preparation, coordination.with affected organizations, review and approval of QA inspection / monitoring plans ,

and proceduresL to- assure their adequacy, appropriateness and conformance to applicable L requirements.

7) Assuring performance of inspections necessary to verify conformance of procured items to prescribed I

requirements.

8) Review of Nonconformance Reports -to verify that appropriate quality considerations are applied to l dispositions and resolution of identified deficiencies.

'9) Assuring that required inspections' are performed by adequately trained and qualified personnel.

10) Assuring that all required inspection records resulting froin performed inspections are properly completed, legible and authenticated to qualify as objective evidence records.
11) Assuring review of modification, technical and work control documents for appropriateness of QA provisions and the performance of inspections necessary to verify conformance of completed work to specified requirements.

l-l c) QA Operations Manager The QA Operations Manager reports to the Manager, Quality Assurance, and is responsible for . quality assurance monitoring and audit-related activities. He is responsible for:

1) Preparation, coordination with affected. organizations, l submittal for required approval, and maintenance of "Q" l Procedures in the Fort St. Vrain Administrative

-l -Procedures, an<1 quality assurance operations procedures necessary to implement assigned Quality Assurance Program responsibilities.

2) Scheduling, coordinating and performing audits and monitoring actions to verify that FSV systems provided to assure conformance of work and activities to prescribed requirements are adequate and effective.
3) Administrating and coordinating all corrective action activities, including trend analysis and status keeping programs, to assure that conditions adverse to quality are promptly identified and co"rected.

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UPDATED FSAR Revision 5 B.5-6 l 4) Auditing of supplier Quality Assurance activities to verify adequacy and effectiveness when requested by the .

QA Services Manager.

l 5) Administrating and coordinating QA review of all new or l revised permanent FSV Procedures involving activities l controlled by the QA Program to verSfy their conformance to applicable quality requirements.

l 6) Coordination of QA Training activities and for providing training assistance to assure indoctrination l of quality assurance principles and procedures for l Nuclear Operations personnel.

I B.5.1.4. Nuclear Production Division, Quality Assurance Related Responsibilities In addition to responsibilities assigned by organization charter, and as discussed in section 12.1.1 through 12.1.3, the management personnel indicated here'n are also responsible for the following:

a) Manager, Nuclear Production The Manager, Nuclear Production reports to the Vice l President, Nuclear Operations, and is responsible for management of all Station operations. In quality-related areas, the Manager, Nuclear Production is responsible for:

1) Assuring Station operations, maintenance and modification installation activities conform to applicable FSAR, Technical Specification, Regulatory Code and Quality Assurance Program requirements.
2) Assuring that new or revised Station procedures affecting quality are compatible with the FSV Administrative Procedures Manual as described in Para.

l B.5.5.1. Procedures involving activities controlled by l the QA Program are provided to the QA Division for review and concurrence in regards to quality related aspects.

3) Assuring that Quality Assurance Division personnel have access to Station facilities, personnel and records as necessary for the performance of quality-related assignments.
4) Assuring that Managers in Nuclear Production provide timely responses to deficiency notifications and corrective actions to permit prompt close out of deficiency reports.

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UPDATED FSAR Revision 5 B.5-7 1 b) Station Manager The Station . Manager reports to the Manager, Nuclear Production and is responsible for the management of all l' production operations and maintenance activities, including:

l 1) Routine and emergency operation of the facility.

l 2) Mechanical and electrical maintenance activities, and l instrument maintenance and testing.

l 3) System evaluations, plant performance testing, and l plant modification reviews and associated testing.

l 4) Planning and scheduling of Nuclear Production

) l activities and Stores activities, which include l integration of inventory control and buying functions l to support maintenance and scheduled outage needs and l development of short and tong range plans in l coordination with other departments.

l l c) Technical / Administrative Services Manager The Technical / Administrative Services Manager reports to the Manager, Nuclear Production, and is responsible for plant security, all administrative services, plant engineering.

l computer services, Nuc? ear Material Management, controlled work procedure (CWP) coordination, and the Shift Technical l Advisors. The Technical / Administrative Services Manager j responsibilities also include:

l 1) Development and control of corrective and preventive l maintenance procedures, practices and activities, and l coordinating and monitoring the plant modification l process.

l 2) Technical engineering support for plant operation and l maintenance groups in the electrical and mechanical l maintenance areas.

l 3) Providing technical services in conjunction with l reactor maintenance activities, including l identification and resolution of reactor operational I problems, directing maintenance personnel performing '

l reactor maintenance, associated equipment l troubleshooting and repair, reactor related fuel {

l handling, and other reactor / reactor component J l associated support tasks.

l 4) Oversight to ensure the reactor is operated in l compliance with the Facility License, the Technical l Specifications, and other federal, state, and local l regulations, and controls the use of all Special l Nuclear Materials at Fort St. Vrain.

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lIf ' UPDATED FSAR Revision 5 B.5-8 l 5) Plant review of proposed design modifications to ensure i required operational, regulatory, training and l licensing reviews are factored into the design .

l proposals and their implementing procedures.

l d) Support Services Manager The Support Services Manager reports to the Manager, Nuclear l Production, and-is responsible for the Health Physics, and l Radiochemistry and Secondary (Water) Chemistry Programs.

l The Support Services Manager acts as the Radiation l Protection Manager, as specified in the Technical

-l Specifications, and as such, is responsible for all l radiation protection activities including the Radiological l Environmental Monitoring Program for the Station. The l Support Services Manager also is responsible for training l activities as required by ANSI N18.1-1971 and 10CFP.Eb l Appendix A, and Fort St. Vrain Training Program

) accreditation efforts. Training responsibilities include:

l 1) Training and qualification of nonlicensed operators,-

l licensed operators, and technical advisors.

l 2) Training and qualification of Health Physics personnel, l Radiochemistry personnel, Results personnel, l Maintenance personnel (Electrical and Mechanical )

l Chemistry personnel, and Training personnel.

l 3) Training of all personnel in subjects applicable to all l departments; (GET, First Aid, Fire Fighting, and l Emergency Response).

I B.5.1.5. Nuclear Engineering Division, Quality Assurance Related Responsibilities In addition to responsibilities assigned by organization charter, and as discussed in Section 12.1.5, the management personnel indicated herein are also responsible for the following:

a) Manager, Nuclear Engineering The Manager, Nuclear Engineering reports to the Vice l President, Nuclear Operations, and is responsible for FSV Project Engineering, Design Engineering, and plant modification / retrofit activities. In quality-related areas, he is responsible for:

1) Assuring implementation of design control measures, including independent reviews as required by the FSV Quality Assurance Program.
2) Assuring prior Engineering review and approval of all l controlled work packages for plant modifications.

UPDATED FSAR Revision 5 B.5-9

3) Assuring that Engineering procedures concerning activities affecting quality are compatible with the ,

FSV Administrative Procedures Manual as described in l Para. .B.5.5.1. Procedures involving activities l controlled by the QA Program are provided to the QA Division for review and concurrence in regards to quality related aspects.

4) Assuring that Quality Assurance Division personnel ~have  !

access to Engineering facilities, personnel and records as necessary for performance of quality-related assignments.

5) Assuring timely response to notifications of quality- ,

related deficiencies and problems; and implementation of prompt corrective action to permit closeout of deficiency reports.

6) Assuring that plant items and equipment are classified according to safety-related and Code requirements.
7) Assuring that the FSV quality-related records system is managed in a manner to assure accountability and retrievability of stored records.

I b) Nuclear Design Manager The Nuclear Design Manager reports to the Manager, Nuclear Engineering, and is responsible for electrical, mechanical and civil engineering activities related to nuclear projects including conceptual, preliminary and final design.

Responsibilities include preparation of cost estimates, l development of preliminary and final design, performance of l design analysis and design verification, development of l installation and test requirements, preparation of equipment specifications, administration of design contracts and procurement of material. The Nuclear Design Manager performs design, transient and system analysis related to l plant modifications and provides drafting and document l updating functions.

c) Nuclear Site Engineering Manager The Nuclear Site Engineering Manager reports to the Manager, Nuclear Engineering, and is responsible for the immediate engineering support required by plant operation, coordination of modification / construction activities and overall planning and scheduling activities for the Engineering Division. Responsibilities include preparation l of cost estimates, preliminary coordination / review of l nuclear purchase requisitions, development of preliminary and final designs, implementation of modification work, implementation of tne overall Engineering planning and scheJuling function and supervision / administration of

UPDATED FSAR Revision 5 B.5-10 l l

l construction work, including coordination and administration l l of outside contractor support implementing plant l modifications.

l d) Engineering Services Manager l The Engineering Services Manager reports to the Manager, l Nuclear Engineering, and is responsible for administration l of the FSV Records Center, including providing system l support and guidance in all aspects of collection, l maintenance, storage, retrieval, security, disposition, and l archival management of nuclear records and for planning, l coordination, and direction of information systems l development for the Nuclear Records Manageinent System. The

[ Engineering Services Manager is also responsible for l employee training programs, personnel records, administering j purchase orders and contracts, preparation of procedures, l and general clerical and secretarial support for the Nuclear l Engineering Division.

l B.5.1.6. Nuclear Licensing and Fuels Division, Quality Assurance Related Responsibilities In addition to responsibilities assigned by organization charter l and as discussed in Section 12.1.7, the management personnel I indicated herein are also responsible for the following:

a) hanager, Nuclear Licensing and Fuels The Manager, Nuclear Licensing and Fuels reports to the Vice l President, Nuclear Operations and is responsible for providing a central nuclear licensing and nuclear safety review organization to interface with the Nuclear Regulatory Commission for all Fort St. Vrain licensing matters. The l Manager, Nuclear Licensing and Fuels also is responsible for j administration of the nuclear fuel management and spent fuel management programs and special projects and analyses as may be required by executive management.

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' UPDATED FSAR Revision 5 B.5-11 b) Nuclear Licensing Manager The Nuclear Licensing Manager reports to the Manager, Nuclear Licensing and Fuels and is responsible for nuclear licensing and safety activities. He maintains personal contact via telephone and correspondence with the NRC in connection with licensing developments involving both l parties. The Nuclear Licensing Manager responsibilities l- include:

l 1) Preparing safety evaluations in accordance with l 10CFR50.59, and preparing timely updates of the Final l Safety Analysis Report and the Technical l Specifications.

l 2) Preparing the annual 10CFR50.59 reports to the NRC.

l 3) Preparing environmental evaluations as required by FSV l Administrative Pro:edures.

l 4) Researching the basis for NRC regulations, determining l PSC's regulatory obligation, and coordinating the i actions of other PSC personnel in response to PSC's l regulatory obligations. '

l 5) Identifying and analyzing proposed and new NRC l regulations, and preparing uritten correspondence to I assist in fulfilling PSC's regulatory obligations, for l resolution of nuclear licensing issues, and in response l to NRC questions and concerns.

l 6) Coordinating interdivisional actions, programs, plans 1 and procedures required for PSC to respond to NRC l inquiries and written and verbal communications.

l 7) Identifying, administering, and controlling commitments I resulting from NRC initiatives.

c) Nuclear Fue.1 and Analysis Manager The Nuclear Fuel and Analysis Manager reports to the Manager, Nuclear Licensing and Fuels and is responsible for l nuclear fuel services, fuel engineering and design, fuel and l core consumables procurement, fuel fabrication, spent fuel l management, reactor core design and analyses, and nuclear l steam system performance computer codes. The Nuclear Fuel l and Analysis Manager responsibilities include:

l 1) Reactor core design and computerized plant transient l analysis, nuclear fuel engineering and design, control l rod management and post irradiation examination of fuel l elements and control rods.

UPDATED FSAR Revision _5 B 5-12 l 2) Procurement of nuclear fuel and core consumables, spent l -fuel disposal, fuel cost accounting and fuel related l contracts. ,

l 3) Liaison and coordination between PSC and Valley Pine  ;

1 Associates (VPA) concerning Fuel Fabrication Facility  ;

l operations and maintenance. l l 4) Preparation and dissemination of industry and l regulatory- data reports and preparation of the l divisional Operating Plans and capital expenditure l budgets.

l 5) Coordination of division training.

B.5.1.7. Other Organizations, Quality Assurance Related Re3 possibilities a) Other PSC Organizations

-l Other PSC organizations, including materials management; j energy, power plant and engineering services, which are involved in quality-related functions, are required to comply with the FSV Quality Assurance Program requirements that apply to their activities. This includes providing access for Quality Assurance Division personnel to their facilities, personnel and records, as necessary for performance of quality-related assignments.

b) Other Outside Organizations Work performed by other organizations outside PSCo must conform to PSCo Quality Assurance Program requirements as specified by procurement or contract documents.

B.5.2. Quality Assurance Programs B.S.2.1. Program Description The Quality Assurance Program for Plant Operations applies to those plant structures, systems and components which prevent or mitigate the consequences of postulated accidents which could cause undue risk to the health and safety of the public. The requirements of this program apply to activities which affect the safety-related functions of those structures, systems and components. Tables 1.4-1 and 1.4-2 identify the Class I and Safe Shutdown items covered by the QA Program. The systems, equipment and components are identified in more- detail on special lists and drawings for safety-related equipment maintained by the Nuclear Engineering Division (see Subsection B.5.2.7).

In addition to safety-related equipment, PSCo is committed to l apply portions of the QA Program for operation to the non safety-l related portions of the fire protection system, the plant security system, and packaging and transportation of radioactive materials.

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UPDATED FSAR Revision 5 B.5-13 l Delineation of QA Program requirements for these items is specified l in the FSV Administrative Procedures Manual. .

A designated identifier is added to the plant component data bases to indicate those fire protection and security components that cre not safety-related, but to which portions of the QA program apply.

The QA Program for operation is structured with three levels:

first level, quality control and inspection; second level, quality assurance monitoring; and third level, quality assurance auditing. A comparison of the functions for operational QA with those for Engineering and Construction QA is shown in Table B.5-3.

The Quality Assurance Program requires that the Quality Assurance Division identify and perform all quality assurance and/or quality control actions required to verify conformance of activities affecting quality to applicable requirements. Inspections of maintenance (including mechanical, electrical and results) work is l performed by the Maintenance Quality Control and/or QA/QC groups, I which report to the QA Services Manager. The arrangement assures the necessary freedom and independence required to perform that function effectively. Biennial audits are employed to verify conformance of l the Maintenance Quality Control and QA/QC groups' activities to applicable requirements.

B.S.2.2. Program Procedures Procedures describing the Quality Assurance Program are maintained in the FSV Administrative Procedures Manual. The "Q"-

series procedures serve as the Quality Assurance Manual and conform to the requirements of 10CFR50, Appendix B by providing an individual procedure to describe the FSV program for each of the 18 Criteria.

Compliance with the FSV Administrative Procedures Manual is mandatory I for all personnel assigned to nuclear project activities. Detailed procedures are provided, where required, by procedures subordinate to the FSV Administrative Procedures Manual (see Subsection A.S.2.10).

B.S.2.3. Program Monitoring and Evaluation The adequacy of the Quality Assurance Program, its conformance to requirements, and the effectiveness of its implementation is l monitored on a continuing basis by the Vice President, Nuclear j Operations, through the review of monthly reports, meetings, and audits performed by the Quality Assurance Division, audits performed by the Nuclear Facility Safety Committee, and audits performed by outside consultants. Additionally, a preplanned and documented management audit of the Quality Assurance Program is conducted under l the Vice President, Nuclear Operation's cognizance biennially.

B.S.2.4. Design Controls Design controls are implemented in accordance with those parts of the FSV Administrative Procedures Manual governing PSCo Engineering I

UPDATED.FSAR Revision 5 B.5 actions. A design control system is employed to authorize the creation and issuance of design documents and, to reflect as-built installations. Subcontracted design actions are controlled by .

procurement . document provisions and follow-through verification actions. All design outputs, whether internal or external, are reviewed by the Quality Assurance Division to verify and assure the inclusion of appruariate quality requirements. Biennial audits are employed to verify and document conformance of design controls to applicable requirements..

'B.5.2.5. Quality Assurance Standards, Codes and Regulatory Requirements Applicable requirements, codes and standards to which the Quality Assurance Program' conforms are listed in Table B.5-4.

B.S.2.6. Supply and Support Services Procurement documents developed to authorize the purchase of materials, parts, equipment or services are required to include applicable and appropriate quality' requirements. All documents i

[ l involving those items controlled by the QA Program are reviewed by the Quality Assurance Division to verify adequacy and appropriateness of the quality requirements. Inspections are performed at source or on the- delivered items, or contractor actions are monitored by qualified PSCo personnel to verify conformance to the purchase order L requirements.

1-B.S.2.7. FSV Safety-Related Items Safety-related items to which the Quality Assurance Program applies are those plant systems, structures, equipment and components which are identified by the FSAR, and as detailed and supplemented by applicable P&I, IB and IC drawings, E and E-1203 schematic diagrams, the Cable Tab and SR-6-2 and SR-6-8 lists to include the following:

a) Class I per FSAR Table 1.4-1.

. b) Safe shutdown components per FSAR Table 1.4-2.

c) Alternate Cooling Method (ACM) equipment.

l l d) Interface Circuits (IC) within the EQ Program.

1 B.S.2.8. Training Programs l-

!. l The FSV Training Program Procedures specify the training policies, procedures and documentation methods for Plant management, operations, maintenance and technical personnel. The Program 1 conforms to the applicable requirements of 10CFR19, 20, 50-Appendix B, 50-Appendix E, 55, 55-Appendix A, 73 (Ref. 5) and ANSI N18.1-1971 (see Section B.5.19.14 and Table B.5-4). The training is the I responsibility of the Superintendent of Training. Records documenting the scope, objectives and methods employed for each

UPDATED FSAR Revision 5 B.5-15 training session conducted are maintained on file.

B.5.2.9. Quality Assurance Training

  • In addition to training required for specific assignments, Plant supervisory and other key personnel responsible for operating or maintaining quality-related systems and equipment receive indoctrination and instruction in Quality Assurance. The training includes basic principles, 10CFR50 Appendix B, policy, and specific Quality Assurance procedures required to implement the QA Program.

l The QA Operations Manager is responsible for ensuring the l required quality assurance training is provided for Station personnel involved in nuclear activities.

The QA Program requires that:

l a) Indoctrination and training be provided to assure that personnel are instructed as to the purpose, scope and use of manuals, instructions, and procedures which pertain to l equipment or activities controlled by the QA Program; ar.d to assure that they are trained in the principles and techniques for the activity being performed, b) Contractors and Suppliers are made responsible for developing and implementing training programs for their personnel in accordance with procurement document requirements. The training programs must include QA indoctrination and training on technical aspects included in their scope of work. Training required to qualify their personnel to perform activities affecting quality must be conducted and documented c) Trainir.g in PSCo procedures is provided for Contractors who perform activities affecting quality, and for personnel who augment permanent PSCo Project staffs.

d) Personnel performing tasks for which certifications are required are so certified on the basis of the results of written examinations or demonstration of required proficiencies. Retraining and requalification are performed as required.

e) Records required to provide evidence of training and certifications are retained and maintained on file. The records indicate training session content, attendees, dates and results of the training sessions.

B.5.2.10 Work Procedures l All work involving activitier controlled by the QA Program is performed in accordance with approved procedures that prescribe the work to be performed. The procedures also indicate, as appropriate, the requirements for the use of special tools or equipment, certification requirements for personnel or equipment, required k_.____-._.____.__.__ _

E UPDATED FSAR Revision 5 B.5-16 environments, prerequisites, te st s ., inspections, data and documentation requirements. ,

.B . 5. 2 .11. FSAR Quality Assurance Program Changes The Manager, Quality Assurance is responsible for initiating appropriate action to document and submit any identified revisions that may be required to assure that the FSAR accurately reflects the

' Quality Program specifics currently being applied. Those changes to the QA program that do not reduce commitments in the program may be made without prior NRC approval. Hewever, those changes must be submitted to the NRC at least annually. Those changes that do reduce program commitments must be submitted to the NRC and be approved by the NRC before 'the changes may be implemented. The proposed j revisions are submitted to the Vice President, Nuclear Operations for approval prior to submittal to the NRC for review and approval (Reference 20).

B.S.3. Design Controls B.5.3.1. Description of Design A.tivities Design activities during the operational phase of the plant consist primarily of those actions required to change existing designs as necessary to accommodate required modifications.

B.5.3.2. Design Control Responsibility All _PSCo design actions are performed within, and are the responsibility of, the Nuclear Engineering Division, and are governed by Nuclear Engineering Division procedures. Subcontracted design tasks are authorized by procurement documents, in which requirements are included for compliance by the subcontractor, that are compatible with Nuclear Engineering Division procedures.

Procurement document reviews by the Quality Assurance Division assures -the inclusion of appropriate design control and other appropriate quality provisions.

B.5.3.3. Design Control System All design modifications designated for permanent change to FSV and'to be performed by PSCo are authorized and controlled by use of a Change Notice system. This system assures that required reviews and approvals are obtained prior to and on completion of the design task.

The Change Notice system includes provisions to ensure that the required research is performed to identify applicable codes, standards, or other requirements and assure their inclusion in the generated design documents; that required design interface coordination and verifications occur; and that the required reviews and approvals are obtained prior to release and distribution of the Change Notice l Temporary design modifications or configurations to FSV are l authorized and controlled by the use of the Tempora ry Configuration l Report (TCR) system. This system assures that engineering, EQ,

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UPDATED FSAR.

Revision 5 B.5-17 l environmental and safety evaluations are conducted' and approved prior l to implementing. the TCR. Those temporary modifications or ll Notice configurations system.to be made permanent are processed through the Change B. 5. 3. 4. - Design Control procedures Nuclear Engineering Division Procedures prescribe in detail the methods-and control measures to be applied to control of design modifications. .The Procedures include measures which provide i assurance.that:

a) Applicable regulatory requirements, FSAR design bases, codes, standards and quality . requirements are correctly incorporated into the drawings, specifications and other controlling documents, b) Naterials, parts, equipment and processes are reviewed and j

evaluated for. compatibility and suitability for use in structures, systems, equipment and components controlled by l the QA Program.

c) Design control measures required by 10CFR50, Appendix B, are applied to activities such as reactor physics; stress analysis;. thermal and hydraulic design and analysis; accident analysis; material selection and compatibility evaluation; evaluation of accessibility for in service

. inspection, maintenance and repair; delineation of acceptance . criteria for inspections and tests.

I d) For modifications of those items controlled by the QA l Program, the adequacy of. the design will be checked by design review; alternate analytical methods; or performance of tests.

e) Where performance test programs are used instead of other verification or checking process, to verify adequacy of a particular design or design feature, such testing shall be controlled to ensure that the test results are representative and directly support the design or design features.

f)' Individuals or groups verifying adequacy of design are not those who performed or supervised the original design.

UPDATED FSAR l Revision 5 B.5-18 l g) Design changes, including emergency changes, to items l- controlled by the QA Program are reviewed and approved by the same organizations that performed the original design or by organizations duly designated by PSCo having the necessary technical capabilities for the particular type of-work involved, h) Safety review or analysis is performed and documented.

1). For projects or changes that have an effect on the envi ronment an environmental review or evaluation is performed and documented (Ref. 21).

B.5.3.5. Verification of Design Design outputs are subjected to a design verification process performed by individuals other.tnan the original designer and other than the original designer's supervisor. If appropriate. -the services of qualifiec consultants are employed.

B.5.3.6. Design Quality Assurance Provisions l Design documents, associated with items controlled by the QA 1 Program, are required by Nuclear Engineering Division procedures to include applicable quality assurance requirements including l acceptance criteria. The design outputs are reviewed by the Quality Assurance Division to verify the inclusion of appropriate quality requirements.

B.S.3.7. Design Document Changes The- Change Notice System is employed to authorize permanent changes to new or existing design documents and requires the same processing and approvals as required for original design documents or changes processed by PSCo.

B.5.3.8. Materials, Parts and Component Selections Nuclear Engineering Division procedures require the selection of l materials, parts and required components for modification 1 applications controlled by the QA Program to conform to requirements equal to, or more stringent than, the original design requirements for the intended FSV application.

UPDATED FSAR Revision 5 B.5-19 B.5.3.9. Identification and Processing of Design Errors Any design errors identified after release of the Change Notice package are corrected by reissuing the affected Change Notice and affected design documents. In addition to correcting a design error, corrective action for significant or recurring design errors also includes determining the cause and instituting changes in the design process or procedures to prevent similiar types of errors from recurring.

B.5.4. Procurement Document Control B.5.4.1. Description of Procurement Activity The FSV Administrative Procedures Manual identifies quality requirements applicable to procurement actions and provides guidance in selection and inclusion of appropriate requirements on Purchase Requisitions. Quality requirements which are appropriate, but not included in the technical documents referenced by or included in the Purchase Requisition package, are added to the Purchase Requisition by use of Standard Quality Assurance Clauses specified by the Nuclear Engineering Division.

B.S.4.2. Purchase Requisition Review l Purchase Requisitions of items controlled by the QA Program are reviewed by the Quality Assurance Division to verify the adequacy and appropriateness of specified quality requirements. The reviews are performed to assure, as applicable, that:

a) Technical requirements are adequately defined and include acceptance and rejection criteria.

b) The specific 10CFR50, Appendix B, requirements are identified which must be described in the supplier's QA program.

c) The supplier's QA program is to be reviewed and approved by purchaser in advance.

d) Procurement documents:

1) Contain or reference identification and definition of the design basis technical requirements.
2) Identify the documentation to be prepared, and the requirements for submittal for review and approval, retention, or submittal to purchaser for permanent record.
3) Contain the purchaser's right of access to supplier's facilities and records for source inspection and audits.

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UPDATED FSAR Revision 5 B.5-20

4) Provide for spare or replacement parts of l ,

structures, systems and compenents controlled by .

l the QA Program to be subject to controls at least equivalent to those used for the original equipment.

5) Provide for any required hold, witness or source inspection points.

I B.5.4.3. Purchase Order Review 1 Purchase Orders are prepared by the Materials Management Department when negotiation / coordination with the potential supplier l has been completed. Purchase Orders for items controlled by the QA l Program are reviewed and approved by the Quality Assurance Division to assure that the quality provisions, as approved on the Purchase Requisition, have not been compromised. A :opy of the Purchase Order is retained for record purposes.

B.5.4.4. purchase Order Changes l Any revisions other than quantity, price, or terms of payment, to l issued Purchase Orders require the same processing and approvals as the original document.

B.5.5. Instruction, Procedures, and Drawings 8.5.5.1. FSV Procedures System The FSV Administrative Procedures Manual establishes the requirements for procedures affecting personnel assigned to work on nuclear project activities. Requirements are included for the procedure formats, content, authorized procedure types, reviews, approvals, distribution, change controls, revisions and precedence in the event of conflict. The FSV Administrative Procedures Manual and l subordinate procedures involving activities controlled by the QA l Program shall be reviewed and concurred with by the Quality Assurance Division to verify conformance to applicable quality l requirements. The procedure system conforms to the intent of Safety l Guide 33 (Ref. 7) and ANSI N18.7 (see Section B.5.19.15).

Figure B.5-3 shows procedures and groups of procedures, along with their overall relationships to the licensing documents. Further explanation of the operating procedures and emergency procedures is given in Section 12.3.

B.5.5.2. Work Control Procedures Each Change Notice package authorizing a modification or selected non-routine maintenance to the Plant, or any part thereof, requires the development of a Controlled Work Procedure. The Controlled Work Procedure details and sequences the work operations required to clearly instruct installation personnel how to proceed. Inspection points are included and appropriate acceptance criteria are either specified or referenced. The procedures require review by the

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ' - - - - - " - - - - - - - - - - - - - - - - - ^ - ' - " - - - - - - - - - -

UPDATED FSAR Revision 5 B.5-21 Quality Assurance Division to verify the appropriateness of quality provisions prior to their release.

l All maintenance, inspection and surveillance activities are performed to procedures authorized under controls imposed by the FSV Administrative Procedures Manual.

B.5.5.3. Technical Documents Controls assuring the conformance of design documents to applicable requirements, appreoriate reviews and approvals are addressed by Section B.5:3.

B.5.6. Document Control The description of document controls for FSV documents subject to control is provided by Subsections B.5.2, B.5.3, B.5.4 and B.5.5.

B 5.7. Control of Purchased Material, Equipment, and Services l B.5.7.1. Supplier Selection l Procedures require the evaluation of potential suppliers of items l controlled by the QA Program before the purchase order is approved.

The evaluations are performed by Quality Assurance Division personnel or by consultants. The evaluations serve to establish whether the supplier is capable of performing to the requirements of the pending procurement by reviewing records of recent past performance or by performing an onsite survey at the supplier's facility, or as specified in Section B.5.19.13. Such evaluations are documented and retained for record purposes. A listing is maintained of approved suppliers.

B.5.7.2. Supplier Control Procurement documents identify any required hold, witness or inspect.on points, appropriate for tie procurement, that are to be performed by the buyer. Quality Assurance personnel may perform monitoring actions or audits during the supplier's period of performance, if such action is deemed appropriate. Any such actions require the preparation and use of prescribed instructions or checklists, and documentation- of the results of the action. Such actions are normally employed if verification of the conformance of

, important characteristics or tests cannot be accomplished after l delivery of the item to the plant.

B.5.7.3. Receiving Inspection FSV Administrative Procedures require the performance of a l receiving inspection by the Quality Assurance Division for all items I controlled by .the- QA Program. The inspection involves the L examination of the delivered item (s), and documents specified for l delivery by the Purchase Order, to the extent necessary to determine I

that requirements of the Purchase Order have been satisfied. Pre-prepared checklists are employed to supplement Receiving Report l

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llPDATED FSAR' Revision i B.5-22 1

checks, when appropriate. Nonconforming items are documented and processed. on r.onconformance reports. Physical and Chemical ,

" Properties' Reports and other technical documents are reviewed by qualified personnel to verify conformance to specified requirements.

L.- B.5.8. Identification of Materials, Parts, and Components B . 5. 8. I'. Existing Items All installed materials, parts and components were identified by the r9sponsible contractors and accepted prior to initiation of plant operations.

S.5.8.2, Modification and Replacement Items

! All items contrelled by the QA Program procured as spares or for modification use are identified on receipt by tagging or other appropriate method by which traceability to the purchase order is q mairitained. Change Notice packages specify the identification designations for any assemblies created by the modification. A copy of the identification tag or Direct Charge Requisition identifying l the item, or reference to the purchase order, is included in the maintenance or modification work records package.

B.5.9. C,ontrol of Special Processas B.5.9.1. Procedures Procedures require that special processes be performed in accordance with qualified procedures by qualified -

personnel using qualified equipment. Procedures ' developed to satisfy needs identifica to date-for maintenance and modification activities are contained in the Quality Assurance Inspection, Welding and Maintenance Manuals. The procedures apply to welding, post-weld heat treat, cleaning, weld ' filler material control and nondestructive examinations. When required, procedures and equipment are qualified to requirements specified by applicable codes, standards and specifications. Nondestructive examination personnel are qualified to the requirements of SNT-TC-1A, American Society for Nondestructive Testing Recommended Practices (Ref. 8).

B.5.9.2. Records j

A master file of qualified welder documents is maintained by the Quality Assurance Division. Nondestructive examination qualifications records are maintained by the Quality Assurance Division.  ;

B.5.10. Inspection I

-B.5.10.1. Maintenance Inspections Inspections to verify the conformance of work performed by the Maintenance Department (including mechanical, electrical and results) to applicable requirements is performed by Maintenance Quality

__i____.________

UPDATED FSAR Revision 5 B.5-23 l-Control and/or QA/QC . personnel who. report to the QA Services l Manager. The groups are assured the necessary independence and l: freedom to perform their assigned tasks. All inspections of items or ,

{' activities controlled by the QA Program are performed to approved written procedures. Inspection personnel are qualified to' the requirements of applicable regulatory requirements.

B.5.10.2. Inspections Other Than Maintenance

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Procedures require that all inspections _, other than maintenance type inspections, are performed.by the QA/QC unit of the Quality Assurance: Division. All persornel are qualified as required by applicable regulatory requirements.. Inspections are performed to written requirements, reviewed and approved by qualified personnel.

The documents include standardized forms, procurement document instructions, receiving report checklists, pre prepared checklists contained in the Quality Control Inspection Manual, or checklists

~ included in work control or operations procedures. The checklists E are required to provide for, as appropriate:

a) Identification of the characteristics to be inspected, b) Identification of personnel responsible for performing the inspection, l c) Acceptance-rejection criteria, d) Description of the method of inspection,

.e) Evidence of completion and verification of the inspection or l test operation.

l f) Signature or stamp of the inspector or data recorder, and the results of the inspection operation, g) Reference to use of applicable drawings or specifications, when required to perform the inspection.

B.5.11. Test Control B.5.11.1. Test Activities Testing activities are conducted on a continuing basis to satisfy Technical Specification requirements and, as appropriate, following modifications when specified by the Change Notice package, or following certain maintenance activities.

_ _ _ _ _ _ _ _ _ _ _ _ _ _ l

UPDATED FSAR-Revision 5 B.5-24 B.5.11.2. Test Procedures All _ testing is performed in accordance with approved procedures.

The procedures are required to incorporate or reference:

a) The requirements and acceptance limits contained in the applicable design or procurement documents, b) Instructions for performing the test, c) . Test prerequisites such as:

1) Instrumentation calibration requirements
2) Equipment requirements
3) personnel qualification, certification or License requirements
4) Completeness of item to be tested
5) Requirements pertaining to environmental or other conditions
6) Data documentation requirements d) Inspections or inspection hold points, e) Acceptance or rejections criteria, f) Method for documenting or recording test data and results, g) Provisions for indication
  • by a qualified individual as to acceptability of the evaluated results, l

B.5.12. Control of Measuring and Test Equipment B.5.12.1. Identification of Items Requiring Calibration Items requiring calibration are specified by the Technical Specification or by the FSV Administrative Procedures Manual. Each l instrument, tool, measuring device, and associated standard used to l perform the required calibration of these items is uniquely identified and placed on a scheduled program of inspection, test and recalibration.

B.5.12.2 Calibration Procedures Calibration and/or maintenance is performed to procedures provided by the item manufacturer; or when not available or applicable, to procedures developed and approved by the department responsible for the specific calibrations. Calibration procedures are required to provide the calibration technique to be employed, specific standards required, labeling or tagging requirements, provisions for recording calibration data and identification of the

UPDATED FSAR Revision 5 L

B.5-25 individual verifying the acceptability of the calibration results.

B.5.12.3. , Traceability of Standards

  • Procedures authorize the use of secondary and transfer standards traceable to the National Bureau of Standards; and, where not available, the use of standards not traceable to the National Bureau of Standards if the basis of calibration ^is otherwise acceptably documented by qualified individuals.

B.5.12.4. Calibration Accuracy I

-l Calibration data forms for instruments controlled by the QA

, l Program identify the accuracy requirements and the specific l

equipment or standard used for its calibration. Monitoring of calibration records verifies that instruments used for calibrations display sufficiently greater accuracy than the instruments being calibrated to assure compliance with accuracy requirements. Where instruments are found to be out of calibration by more than the allowable tolerances, an investigation is required to determine .the effect, if any, on the validity of previously made measurements or test data.

i B.5.13. Handling, Storage, and Shipping The FSV Administrative Procedures Manual includes requirements for the necessary controls during procurement, receiving, handling, i i storing maintenance and issuance of related spares, replacements, l modification materials and items controlled by the QA Program to prevent their deterioration. Quality Assurance monitoring actions serve to verify compliance with the procedures.

B.5.14. Inspection, Test, and Operating Status B.5.14.1. Status Identification Systems The FSV Administrative Procedures Manual establishes administratively, and operations and maintenance procedures establish specifically, the requirements for tagging, logging and displaying the status of plant equipment and systems. The system of status tagging serves to prevent operation or unauthorized adjustments which could endanger the safety of personnel or invalidate the results of tests already performed.

B.5.14.2. Status Identification of Materials, Parts, Components and Equipment Controls for identification of parts, components and equipment are prescribed in the detailed procedures for those activities described by Subsections B.S.8, B.S.9, B.5.10, B.5.12 and B.5.15.

B.5.14.3. Procedure Requirements for Operational Items The FSV Administrative Procedures Manual requires that the affected equipment or item (s) withdrawn from operational status be

UPDATED FSAR Revision 5 B.5-26.

tagged; and also that the associated power supplies, starters, switches and controls on the main control panel (s) be tagged to warn against operation. If appropriate, the power supplies are disconnected and so identified, to prevent inadvertent operation.

The tagging .is controlled by the Shift Supervisor by requiring that the serially numbered Clearance Cards, obtained only from the Control Room, be used for all tagging purposes. Records maintained in the Control Room enable the Reactor Operators and Shift Supervisor to determine, at any time, what equipment is currently on Clearance -

Cards.

Persons requiring clearances to perform work are required to sign the clearance before starting work. On completion of the work, the Shift Supervisor signs the clearance to acknowledge the work completion and removal of the status tags. Transfers of responsibilities for clearances from one individual to another are documented by written sign-offs. Work conformance to applicable requirements is verified by the Quality Assurance Division.

In compliance with NUREG-0737 (See Ref. 18), the operating condition / position of critical equipment is independently verified l upon ' return to- service following clearance conditions. FSV l Administrative procedures require independent verification that all l clearances are properly placed prior to beginning work ar.d properly l-removed when the work it completed. .The Shift Supervisor is l responsible for authorizion of testing to demonstrate functional l acceptability of equipment following maintenance, acknowledging test l results and returning the equipment to service.

B.5.15. Nonconforming Materials, Parts, or Components B.5.15.1. Documenting Nonconforming Items The FSV Administrative Procedures Manual requires that l nonconformances, other than maintenance rework, are documented on l nonconformance reports. Rework as a result of preventive or l corrective maintenance may result from a nonconformance report but is l routinely accomplished in accordance with maintenance implementing l procedures. Nonconforming items are tagged and, if practical, the l items are pla &J in a segregated area pending processing and

[ dispositioning of the report.

B.5.15.2. Processing of Nonconforming Items Nonconforming material processing assures that "use-as-is" or

" repair" dispositions, whether proposed by Maintenance or l Engineering, are properly evaluated as well as independently verified l by Engineering and receive documented approvals by Engineering and l

l Quality Assurance. This practice also assures the accomplishment of l any prescribed inspections to verify conformance of repairs to the l prescribed dispositions. " Return to vendor", " scrap" or " rework" l dispositions are accomplished in accordance with Administrative l Procedures.

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UPDATED FSAR Revision 5 B.5-27 B.S.16. Corrective Action B.5.16.1. FSV Corrective Action Systems .

The FSV Administrative Procedures Manual requires that conditions l adverse to quality, such as failures, malfunctions, deficiencies, l deviations, defective material or equipment, and nonconformances are l promptly. identified and corrected. For significant conditions l adverse to quality, root cause must be determined and corrective l actions provided to preclude recurrence. The Administrative l Procedures Manual describes the methods that are utilized by the I Nuclear Operations Divisions, including Quality Assurance Division, l to identify conditions adverse to quality. These methods are defined l in departmental procedures which provide for prompt identification l and resolution of conditions adverse to quality or safety.

B.5.16.2. Quality Trends Analysis and Reporting The Quality Assurance Division is responsible for accumulation of data and for the use of appropriate analytical techniques to identify and report FSV quality trends to plant management. Data l employed includes nonconformance reports (NCRs), Quality Deficiency l Reports (QDRs), Corrective Action Reports (CARS), monitoring and audit reports, and NRC I&E reports. The reports to management serve to indicate where trends are improving, indicating successful corrective actions, and where trends indicate deterioration and the need for additional or more effective efforts.

B.S.16.3. Reporting Any person identifying what may be an apparent violation of NRC regulations or significant potential safety hazard may document the condition and promptly submit a report to the appropriate Department. 6 Such reperts may take the form of Station Service Requests, Action Requests, or other nonconformance reports. The reports are promptly evaluated and appropriate action is initiated. A report may be made to the NRC if the condition is deemed reportable in accordance with the Regulations. In any case, the necessary corrective action is documented and followed up until completed.

B.5.17. Records B.S.17.1. FSV Operational Records System The FSV Administrative Procedures Manual requires that record requirements be established when procurement documents, work control, test and inspection procedures are developed and approved. QA reviews the documents to verify the adequacy and appropriateness of record provisions.

UPDATED FSAR Revision 5 B.5-28 B.5.17.2. Records Content Except in the case of record documents such as recorder charts, computer printouts, radiographs and similar documents, records generated and retained to provide objective evidence of conformance to specified requirements are required to contain the following information when applicable:

a) A description of the type of observation.

b) Evidence of completing and verifying an inspection, or test operation, c) The date and results of the inspection or test.

d) Information related to conditions adverse to quality.

e) Inspector or data recorder identification.

f) Evidence as to the acceptability of the results.

B.5.17.3. Records Accumulation, Identification and Retention Organizations generating records are responsible for verifying records completeness and accuracy, and for accumulation, organization, identification and transmittal to the Records Center in accordance with requirements specified by the FSV Administrative l Procedures Manual. A Records Retention Schedule serves as a records l checklist designating required quality assurance records. Received l records are reviewed, acknowledged, logged, indexed and the documents filed. Records Center controls assure records security from loss or deterioration and assure retrievability of retained documents for their prescribed retention periods.

B.S.18. Audits and Monitoring Activities B.5.18.1. FSV Audit and Monitoring System The FSV Administrative Procedures Manual requires the implementation of a comprehensive system of audits of all activities, procedures and instructions affecting quality of the Plant and its performance, including key suppliers and contractors, at least once each two years. The system of formal audits is supplemented by monitoring actions conducted on a continuing basis to verify conformance of on going work activities to applicable requirements. The monitoring system provides greater flexibility and earlier identification of situations which may be adverse to quality. j Monitoring results are evaluated and considered when developing audit i plans and checklists.

B.5.18.2. Audits I I

Audits are performed by the Quality Assurance Division using pre- i established procedures and checklists and are onducted by trained lead auditors with no direct responsibility for the areas audited. l

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UPDATED FSAR  !

Revistor. 5 B.5-29 l Audits are also performed under the cognizance of the Nuclear Facility Safety Committee in accordance with Technical Specification j requirements (also see Section 12.5.3.3).

Auditors and Lead Auditors are selected and qualified in accordance with ANSI N45.2.23-1978 (Refs. 12, 13 and 17).

B.5.18.3. Audit Results Audits are formally documented and distributed to affected l management, including the Vice President, Nuclear Operations. Audit findings are documented and reviewed with managers responsible for initiation of corrective action. Processing and follow through on any required corrective actions is accomplished through the corrective action system described by Subsection B.5.16. Follow-up audits are performed as deemed appropriate for evaluation of completed QA audits and QA monitoring results.

B.S.18.4. Monitoring Activities Quality Assurance personnel monitor compliance with the requirements of the documents which control plant operation, such as the _NRC licenses, FSAR, Technical Specifications, Administrative Procedures Manual, Operating Procedures, and other controlling documents. The monitoring functions are defined in the Quality Assurance Monitoring Manual which describes the pre planned instructions and checklists used in QA monitoring procedures.

Conditions adverse to quality identified by monitoring actions are processed by the corrective action system as described by Subsection B.5.16. Formal audit type summary reports are not issued for each monitoring action perfurmed.

B.5.19. Implementation, Wash-1283, -1284, and -1309 Except as modified in the sections which follow, ths PSCo QA Program for Plant Operations utilizes the guidance provided by NRC publications WASH-1283 (5-24-74), WASH-1284 (10-26-73) and WASH-1309 (5-10-74) (" rainbow" series) to the extent that these documents l provide practical guidelines for activities controlled by the QA l Program occurring during the operational phase of plant life (Refs.

9, 10 and 11).

The existing Operational QA Program does not address all of the detailed requirements set forth by the " rainbow books", considering the fact that information normally developed in the design and construction phase for present-day plants was not readily available for Fort St. Vrain Unit No. 1.

With respect to'the applicability of the " rainbow books" and the associated standards, it is impracticable to apply all of the requirements set forth by these documents to a plant for which important, and (in some respects) irreversible commitments were made several years before the current requirements were formulated. In this respect, the following sections summarize the scope and

UPDATED FSAR

. Revision 5 B.5-30 applicability of the various standards as well as specific exceptions-that will be taken in the application of the guidance of these ,

documents to the Operational QA Program at Fort St. Vrain (see Table-B.5-4).

l l 'B.5.19.1. ANSI- N45.2-1971 Quality Assurance Program Requirements L for Nuclear Power Plants (a) Scope and Applicability l

l The guidance provided by this standard and the associated Regulatory Guide 1.28 shall be~ applied in the Operational QA Program

, l to those activities affecting the aspects of operation of Fort St.

j Vrain Unit No. I controlled by the QA Program.

Where codes or standards are referenced, or are incorporated into the standard by reference, which are in conflict with original design commitments as set forth in the FSAR, the FSAR commitments shall govern. Later revisions of applicable codes and standards may be invoked specifically by the' design requirements where deemed appropriate, consistent with the overall commitment to maintain the plant-in an " equal to or better than" original condition.

(b) Specific Exceptions Quality Assurance Program (Section 2)

The- Quality Assurance Program describes the extent to which ANSI and other recognized standards will be' recognized and applied to Fort St. Vrain Unit No. 1.

Inspection (Section 11)

First Level inspection of routine maintenance activities has l been assigned to QA personnel in the QA Services Department.

Inspections for work other than routine maintenance, including activities which involve welding or nondestructive testing, are performed by QA/QC personnel. In any case, the program requires that inspection activities to verify quality of work shall be performed by persons other than those who performed the activity being inspected.

Handling, Storage and Shipping (Section 14) j For the most part, all items purchased for use during the operation of Fort St. Vrain Unit No. I will be stored indoors under normal (heated) warehouse conditions. For these items in general, no specific storage requirements are necessary. Those items which require special consideration are handled on an individual basis and requirements are established as a part of the procurement document requirements.

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UPDATED FSAR  ;

Revision 5 i B.5-31 B.5.19.2. ANSI N45.2.1-1973 Cleaning of Fluid Systems and  !

Associated Components During the Construction Phase of ,

Nuclear Power Plants (a) Scope and General Applicability Insofar as the requirements of N45.2.1 are directed primarily at contractor activity during construction, this standard cannot be applied directly to operational requirements.

The guidance provided by this standard and the associated l Regulatory Guide 1.37 shall be applied to maintenance, repair, and l modification activities controlled by the QA Program occurring during the operational phase of Fort St. Vrain Unit No. 1 to the extent that such activities are comparable in nature and degree to similar activities occurring during the design and construction phase.

l Where the scope of plant modification, maintenance or repair work is such as to make the guidelines contained in this standard practicable, the work shall be performed with consideration to the guidance provided.

Where codes, standards and specific design requirements are referenced, or are incorporated into the standard by reference, which are in conflict with original design commitments as set forth in the FSAR, the FSAR commitments shall govern. Later revisions of applicable codes and standa rds may be invoked specifically by the design requirements where deemed appropri ate., consistent with the overall commitment to maintain the plant in an " equal to or better than" ceiginal condition.

(b) Sjecific Exceptions General Requirements (Section 2)

Cleaning requirements for almost all maintenance, repair and modification work will be included as a part of the overall job requirements. In this respect, detailed cleaning procedures will not be prepared as separate documents, unless specified. Necessary requirements, consistent with the scope of the work, will be included as a part of the overall work instructions.

Criteria for Cleaning (Section 3)

For cleanliness classifications where the scope of plant modification work is such as to make application of the guidance provided by Section 3 of this standard practicable, the cleanliness classifications and requirements thereof shall be evaluated and applied, as appropriate, as a part of the overall work requirements. For most modification or maintenance work, however, involving only small portions or individual components of larger systems, it is not considered practicable to conduct ASTM E11-70 cleanliness tests. Appropriate cleanliness will be maintained during

' UPDATED FSAR Revision 5 B.5-32 the work and appropriate preoperational flushing will be conducted, consistent with the scope of the work performed and the original design requirements.

It should be noted that the cleanliness requirements and tests for cleanliness as specified by Classes A, B, C and D are not applicable directly to gas cooled reactors and primary coolant systems especially with reference to helium systems. In this respect, cleanliness requirements necessarily must be dictated by specific design requirements rather than the general criteria set forth by N45.2.1, Section 3. General cleanliness requirements will be defined by system and included in appropriate procedures by reference.

Maintenance of Installation Cleanliness (Section 6)

Access control requirements are established in accordance with N45.2.3. Access control into radiation areas is controlled by radiation work permits. Cleanroom requirements and associated access control are established as dictated by specific job requirements.

Pre-Operational Cleaning (Section 7)

For work which requires specific cleanliness levels, acceptance criteria for flushing shall be established as a part of 'the overall work requirements. Most modifications and maintenance work will involve only small portions of various systems and will be done under controlled conditions. As such, requirements for extensive cleaning and flushing will not be required.

Records (Section 9)

For normal repair, maintenance and modification work, cleaning requirements will be performed as a normal part of the overall work. Applicable records will be retained with the overall work records. Typically, such records as personnel qualification, calibration records, etc., are kept in files and will not be included as a part of specific job work records.

B.5.19.3. ANSI N45.2.2-1972 packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants (During the Construction Phase)

(a) Scope and Applicability i

l The guidance provided by this standard shall be applied to those packaging, shipping, receiving, storage and handling l activities associated with items controlled by the QA Program, to the extent that such activities are comparable in nature and degree to similar activities occurring during the construction phase.

UPDATED FSAR Revision 5 B.5-33 Where codes, standards and specific design requirements are referenced, or are incorporated into the standard by reference, which are 'in conflict with original design commitments as set forth in the .

FSAR,- the FSAR commitments shall govern. Later revisions of applicable codes and standards may be invoked specifically by the design requirements where deemed appropriate, consistent with the overall commitment to maintain the plant in an " equal to or better than" original condition.

(b) Specific Exceptions The Operational QA Program is not structured to meet the general requirements set forth by this standard. The program is l structured to identify equipment controlled by the QA Program and to associate that equipment with the various levels set forth by this standard. This classification, however, cannot be applied directly to individual spare parts or subassemblies of the parent equipment.

Due to difference in volume, complexity, inspectability, etc., the packaging, shipping, handling and storage requirements of spare parts and subassemblies will necessarily be different from the requirements ,

which may be imposed on the entire component or piece of parent equipment.

The majority of items purchased for an operating plant consist of components, subassemblies and individual spare parts which could be used in a multitude of different applications. Such items are purchased to the highest requirement of intended use, but it is not considered practicable to pre-classify or categorize individual parts by levels as required by Section 2.7 of this standard. _The volume and characteristics of purchases during the operational phase differ significantly from those purchases made during the design and construction phase, and storage facilities are considerably different. Almost all parts and components purchased in the operational phase will be stored indoors under normal warehouse conditions. Items that require special storage protection measures will be identified as a part of the purchasing document review requirements. Items that must be stored outdoors (equivalent of Level D) or items that must be stored in covered but unheated conditions (equivalent of Level C) will be evaluated on an individual case ba * . Shipping and packaging requirements for such items likewise will be handled in the purchase order documents, as appropriate.

B.5.19.4. ANSI N45.2.3-1973 Housekeeping During the Construction Phase of Nuclear Power Plants i (a) Scope and General Applicability l'

The guidance provided by this standard and the associated l Regulatory Guide 1.39 for control of housekeeping requirements shall be applied to work conditions and other applicable activities which l

could affect quality of important operational aspects of Fort St.

Vrain Unit No. 1, to the extent that such activities are comparable in nature and degree to similar activities occurring during the design and construction phase.

UPDATED FSAR Revision 5 B.5-34 Where codes, standards and specific design requirements are referenced, or are incorporated into the standard by reference, which are in conflict with original design commitments as set forth in the '

FSAR, the FSAR commitments shall govern. Later revisions of applicable codes and standards may be invoked specifically by the design requirements where deemed appropriate, consistent with the overall commitment to maintain the plant in an " equal to or better I than" original condition. .

l (b) Specific Exceptions General Requirements (Section 2) l

The specified zone requirements contained in Section 2.1 l generally vill be adhered to, with the exception that the '

, reactor building generally will be controlled per Zone III ,

requirennts except for material accountability. There will '

be no specific material accountability for reactor building access unless specifically required by Health Physics. '

l Requirements (Section 3)

Fire protection and prevention equipment will be provided as set forth in the FSAR and as supplemented by requirements set forth by response to NRC Branch Technical Position 9.5-1 l

(Refs. 14 and 15). General housekeeping requirements are set forth by various zone designations. Specific requirements will be included as a part of the overall work instructions, as appropriate.

B.5.19.5. ANSI N45.2.4-1972 Installation, Inspection and Testing Requirements for Instrumentation and Electric Equipment During the Construction Phase of Nuclear Power Generating Stations (a) Scope and Applicability This standard was written for construction efforts of nuclear plants and, as such, the requirements set forth and the feasibility, both from an economical viewpoint and a practical viewpoint, are based on initial construction. As such, implementation of all the requirements of this standard for operating plants, considering the scale of plant modification versus initial construction, is not practicable.

The guidance provided by this standard and the associatied l Regulatory Guide 1.30 (Safety Guide 30) shall be applied to installation, inspection and testing of electrical equipment and l systems associated with onsite modification work occurring during the operational phase of Fort St. Vrain Unit No. 1, to the extent that such work is comparable in nature and degree to similar work occurring during the design and construction phase.

Where codes or standards are referenced, or are incorporated into the standard by reference, which are in conflict with original

_______ _ _ __ _-_ _ - a

UPDATED FSAR Revision 5 B.5-35 design commitments as set forth in the FSAR, the codes and standards may be invoked specifically by the design requirements where deemed

-appropriate, consistent with the overall commitment to maintain the ,

plant in an " equal to or better-than" original condition.

Where specific design requirements included in this standard or referenced codes and standards are in conflict with original design requirements set forth in the FSAR and other appropriate design documents, the original design requirements shall govern.

(b) Specific Exceptions Definitions (Section 1.4)

The definition of Class I and Class IE electrical equipment set forth by this standard does not conform to the equipment categories of Fort St. Vrain Unit No. 1.

Essential electrical items and Class I equipment lists upon which the Operational QA Program is based are described in the FSAR, and the scope and applicability of this standard necessarily shall be limited to these defined areas.

Procedures and Instructions (Section 2.3)

Appropriate requirements for installation, inspection and tests will be set forth by job specifications and work instructions developed as a part of the modification work package. It is not intended that separate procedures be established which specifically address'the various areas of this standard. However, in the development of the work package, consideration will be given to the areas outlined in Section 2.3, as appropriate.

Physical and Chemical Tests (Section 5.2.3)

Application of the guidance provided by the additional codes and standards listed in Appendix B will be considered to the extent that such codes and standards provide useful and practicable guidance for .the work being performed.

Commitment to the guidance of N45.2.4 shall not include commitment to the guidance of referenced standards.

Installation, Verification and Test (Sections 4.0, 5.0 and 6.0)

The requirements for installation and the associated inspections, verifications and tests are included in the work instructions as appropriate, consistent with the scope of the work and the importance to quality. In the development of the work instructions, consideration will De given to the guidance provided by Sections 4.0, 5.0 and 6.0 of this standard, and appropriate requirements will be

incorporated into the instructions. It is not intended that

! separate procedures be established which specifically l

UPDATED FSAR Revision 5 B.5-36 sddress all of the areas referenced.

Applicable Codes, Standards and Guides (Section 9.0)

See Regulatory Guide 1.30 (Safety Guide 30).

B.5.19.6. ANS1 N45.2.5-1974 Supplementary Quality Assurance Requirements for Installation, Inspection and Testing of Structural Concrete and Structural Steel During the Construction Paase of Nuclear Power Plants (a) Scope and Applicability This standard was written for construction efforts of nuclear plants and, as such, the requirements set forth and the feasibility, both from an economical viewpoint and a practical viewpoint, are based on the construction situation. As such, implementation of all the requirements of this standard for operating plants, considering the scale of plant modification versus initial construction, is not practicable.

The guidance provided by this standard and the associated l Regulatory Guide 1.94 shall be applied to activities controlled by l the QA Program involving concrete and structural steel work occurring during the operational phase of Fort St. Vrain Unit No. 1, to the extent that such activities are comparable in nature and degree to similar activities occurring during the design and construction phase.

Where codes and standards are referenced, or are incorporated into the standard by reference, which are in conflict with original design commitments as set forth in the FSAR, the commitments shall govern. Later revisions of applicable codes and standards may be invoked specifically by the design requirements where deemed appropriate, consistent with tb overall commitment to maintain the plant in an " equal to e better than" original condition.

Where specific design requirements 4r.cluded in this standard or referenced codes and standerda are in conflict with original design requirements set forth in the FSAR and other appropriate design documents, the original design requirements shall govern.

(b) Specific Exceptions Procedures and Instructions (Section 2.2)

Appropriate requirements for installation, inspection and tests will be set forth by job specifications and work instructions developed as a part of the n. codification work package. It is not intended that separate procedures be established which address specifically the various areas of this standard. However, in the development of the work package, consideration will be given to the areas outlined

. _ _ ____a

UPDATED FSAR Revision 5 B.5-37 in Section 2.2, as appropriate.

1 Calibration and Control (Section 2.5.2)

The requirements of control and calibration of measuring and test equipment set forth by this standard shall be applied l to all measuring and test equipment used by PSCo or their laboratories agents, test and contractors. Such requirements, however, will not be imposed on commercial batch plant facilities. Instrumentation at commercial batch plant facilities will be evaluated to determine that j sufficient accuracy can be obtained.

Qualification Tests (Section 3.2.1)

For small quantities of concrete involved in modification work, all concrete must be purchased from commercial concrete batch plants. For small quantities of concrete, it is unreasonable to expect commercial facilities to shut down normal operations to provide certified aggregate, cement, admixtures, fly ash, water, etc. In this respect, the qualification tests required by Table A for aggregate, cement, admixtures, fly ash and pozzolans, water and ice will not be required. Appropriate evaluations will be made to determine that good quality and generally acceptable materials are used. This evaluation, coupled with slump tests, air entrainment tests and concrete cylinder strengths, will provide adequate control and qualification of the concrete.

Design mixes consistent with, or equivalent to, original requirements will be specified and the results of the cylinder tests will be evaluated based on the acceptance criteria associated with the original design mix requirements.

ASTM A-36 steel will not require certifications except for that which is used in the building's main structural steel.

Main structural steel is that steel which is required in order for the building to maintain its integrity during design conditions.

Protection of Materials (Section 4.2)

The inspection requirements of Section 4.2 will not be performed unless specified, as the small quantities of concrete involved in modification work no doubt will be mixed using materials already in the batch plant bins.

Control of storage of materials would not be practicable.

Measuring,MixingandTransporting(Sectirn4.3}

If available, appropriate certifications shall be obtained from the concrete supplier which verify the adequacy of truck mixers per the requirements of ACI-304 and ASTM C-94.

UPDATED FSAR Revision 5 B.5-38 Where certifications are not available, two concrete test cylinders representing the first and last one-third of truck ,

mixer contents shall be taken for evaluation of the mixer truck, over and above the normal concrete cylinders taken to evaluate the in place concrete. The concrete batch plant facility shall be inspected to assure that appropriate controls are being exercised with reference to the inspection guidelines set forth by Section 4.3(1) and (2).

Replacement Preparation (Section 4.4)

Inspection of soils and earthwork will meet the general requirements set forth, with the qualification that the extent to which individual inspection requirements are met will depend upon the nature and scope of the work to be performed.

In-Process Tests on Concrete and Reinforcing Steel (Section 4.8)

Except for normal batch qualification tests (slump, air content, temperature and compressive strength) and initial reinforcing steel certifications, the in process tests required by Table B are pneralls applkable to the periodic control which must be exercised with reference to'long-term construction type programs. The in process test requirements of Table B are not considered applicable to short-term modification work as would be required under our Operational QA Program.

B.S.19.7. ANSI N45.2.6-1973 Qualification of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants (a) Scope and Applicability The guidance provided by this standard and the associated Regulatory Guide 1.58 shall be applied to inspection, examination j and testing activities associated with modification work controlled l by the QA Program and accomplished during the operational phase of Fort St. Vrain Unit No. 1, to the extent that such activities are comparable in nature and degree to similar activities that occurred during the design and construction phase. For maintenance and repair activities, it is intended that the onsite operating organization be qualified in accordance with the provisions of ANSI N18.1-1971.

Personnel performing inspection, examinations and testing activities during the operational phase would be qualified to ANSI N18.1-1971 or ANSI N45.2.6-1973 and QA experience for levels I, II and III should be interpreted to mean equivalent experience in construction, manufacturing, operation or installation activities.

Where codes, standards and specific design requirements are referenced, or are incorporated into the standard by reference, which are in conflict with original design commitments as set forth in the FSAR, the FSAR commitments shall govern. Later revisions of

UPDATED FSAR Revision 5 B.5-39 applicable codes and standards may be invoked specifically by the design requirements where deemed appropriate, consistent with the ,

overall commitment to maintain the plant in an " equal to or better than" original condition.

(b) Specific Exceptions This standard was written primarily for construction activitives, and in this respect -cannot be applied directly to operational activities in its entirety.

Qualifications (Section 3)

The following levels of capability for persons performing inspection or testing work are consistent with the requirements of the standard but have been revised slightly to reflect operational conditions.

Level I To be considered for certification, a candidate must satisfy the following requirements:

High school graduate or equivalent, plus:

(1) One (1) year of experience in quality assurance or engineering, design, operations, maintenance, inspection or testing of manufacturing, construction, operations and installation activities; OR (2) Demonstration of proficiency in the inspection discipline based on past performance, testing or job-related technical capabilities; AND (3) In addition to (a) or (b), successful completion of the basic Quality Assurance Indoctrination Program or equivalent specific training.

Level II To be considered for certification, a candidate must satisfy one of the following requirements:

(1) Graduate of a four year accredited engineering or science college or university, plus:

(a) Two (2) years experience in quality assurance or engineering, design, operations, maintenance, inspection or testing of power plants, or equivalent manufacturing, construction, operations or installation activities; OR (b) One (1) year experience and demonstration of proficiency by past performance, testing or job-

UPDATED FSAR.

' Revision 5' B.5-40

, related technical capabilities.

(2)~ High school graduate, or equivalent, plus:

(a). Four :(4). years of ' experience in quality assurance or engineering, design, operations, maintenance,-

inspection or testing of. power plant or equivalent manufacturing, construction, installation or operational activities; AN_D.

(b) Successful- completion' of the basic Quality Assurance Indoctrination Program or equivalent specific training.

Level III To be considered for certification, a candidate must satisfy one of.the following requirements:

(1) Graduate of a four-year accredited engineering. or.

science college or university, plus five (5) years experience in quality assurance or engineering, design, operations, maintenance, inspection, testing or supervision thereof of power plants, or equivalent manufacturing, design, construction, operation or installation activities'. At. least two (2) years of this experience should be associated with nuclear

. facilities'; or, if not, the individual shall have training sufficient to acquaint him thoroughly with the safety aspects and general quality assurance requirements of a nuclear facility; 0R _

(2) High school graduate, or equivalent, plus ten (10) years experience in general quality assurance 'or engineering, design, operations, maintenance, inspection, testing or supervision thereof of power plant, or equivalent manufacturing, design, construction, operation or installation activities. At J

1 east two (2) years of this experience should be i associated with nuclear facilities; or, if not, the individual shall have training sufficient to acquaint him thoroughly with the safety aspects and general quality assurance requirements of a nuclear facility, i

UPDATED FSAR-Revision 5' B.5-41 Specific Required Capabilities for Inspection, Examination and Testing Personnel (Section 3.2) ,

Each person certified to perform under the Levels designated l herein shall be physically capable of performing ' the-l' assigned task and should meet the following physical requirements:

(1) Natural or corrected near-distance visual acuity such that the applicant'.is capable'of reading J-1 letters on standard Jaeger's test . type chart for near-vision or equivalent test type; (2) Color vision; and (3) Other medical requirements for the physical demands of performing the required activities (such as heart and

. circulatory conditions).

l Personnel with physical restrictions shall be limited to l performance of only those tasks for which they are l physically capable.

Items (1), (2) and (3) will be met at the time of initial certification. Items (1) and (2) will be verified at least annually consistent with the decertification requirements.

The initial physical examination (Item (3)) will not be reverified unless there is an apparent need.

Quality Assurance Division personnel involved in non-destructive examination functions will be qualified to the requirements of SNT-TC-1A as appropriate. For work where the QA Division does not have properly qualified NDE personnel, personnel with proper qualifications will be obtained from outside sources. .

i B.5.19.8. ANSI N45.2.8 - Draft 3, Rev. 3., Apr. 1974 Supplementary Quality Assurance Requirements for Installation, Inspection and Testing of Mechanical Equipment and Systems for the Construction phase of Nuclear Power Plants (a) Scope and Applicability This standard was written for construction efforts of nuclear plants and, as such, the requirements set forth and the feasibility, both from an economicci viewpoint and a practical viewpoint, are based on the construction situation. As such, implementation of all the requirements of this standard for operating plants, considering the scale of plant modifications versus initial construction, is not practicable.

The guidance provided by this standard shall be applied to installation, inspection and testing of mechanical equipment and l systems controlled by the QA Program associated with onsite

UPDATED FSAR Revision 5 B.5-42

'l modification . work occurring during the operational phase of Fort St.

Vrain Unit No. 1, to the extent that such work is comparable in nature and degree to similar work occurring during the design and construction phase.

Where codes'or standards are referenced, or are incorporated into the standard by reference, which are in conflict with original design commitments set. forth in the- FSAR, the FSAR commitments shall govern. Later revisions of applicable codes and standards may be invoked specifically by the design requirements where deemed appropriate, consistent with the overall commitment to maintain the plant in an " equal to or better than" original condition.

Where specific desig? requirements included in this standard or referenced ccdes and standards are in conflict with original design requirements set forth .in- the FSAR and other appropriate design documents, the original design requirements shall govern.

(b) Specific Exceptions Procedures and Instructions (Section 2.2)

Appropriate requirements for installation, inspection and tests will be set forth by job specification and work instructions developed as a part of the modification work package. It is not intended that separate procedures be established which specifically address the various areas of this standard. However, in the development of the work  ;

package, consideration will be given to the areas outlined '

in Section 2.2, as appropriate.

Cleaning (Section 2.4)

Imple' mentation of ANSI N45.2.1 is specified by separate documentation. (See B.5.19.2)

Receiving, Storage and Handling (Section 2.5)

Implementation of ANSI N45.2.2 is specified by separate documentation. (See B.S.19.3)

Housekeeping (Section 2.6)

Implementation of ANSI N45.2.3 is specified by separate l- documentation. (See B.5.19.4)

Personnel Qualification (Section 2.7)

Implementation of ANSI N45.2.6 is specified by separate documentation. (See B.5.10.7)

UPDATED F5AR Revision 5 B.5-43 L

B.S.19.9. ANSI N45.2.9-1974 Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for-Nuclear Power Plants (a). Scope and Applicability The guidance provided by this standard and the associated Regulatory Guide 1.88 shall be applied to quality assurance records associated with operation of Fort St. Vrain Unit No. 1.

Those design, manufacturing, construction and operating records generated prior to implementation of this standard are not backfitted to the detailed requirements of this standard. All such records, however, are designated initially for lifetime storage.

Until specific review dictates otherwise, they will be stored in the permanent record storage facility. Appropriate record inoexes and filing systems permit reasonable identification and retrieval. The records are stored and preserved per the requirements of Section 5.0 of this standard.

(b) S l ecific Comments Safekeeping (Section 5.5)

The Records Storage Building is located at the plant site within the site access control fence. During off-duty hours the facility is kept locked and is monitored by regular guard patrols under the auspices of the plant security program.

Facility (Section 5.6)

A records storage building has been constructed onsite to provide for storage of records. This facility was constructed to provide adequate record protection to prevent destruction by fire, theft, flooding and vandalism.

B.5.19.10. ANSI N45.2.10-1973 Quality Assurance Terms and Definitions The quality assurance terms and definitions contained in this standard shall be used as guidance and applied as appropriate to the Operational QA Program for Fort St. Vrain Unit No.1.

There may be instances where existing procedures contain definitions that may not be in strict accordance with those provided by this standard. As existing procedures are revised, however, such definitions shall be evaluated to determine if the intent of definitions meets the intent of those provided by this standard.

UPDATED FSAR Revision 5 )'

8.5-44 B.5.19.11. ANSI N45.2.11-1974 Ouality Assurance Requirements for Design of Nuclear Power Plants The guidance provided by this standard and the associated l Regulatory Guide 1.64 Rev. 2 shall be applied to design activities l involving modification work controlled by the'QA Program and the revision or development of plant design documents occurring. during operation of Fort St. Vrain Unit No. 1.

Where codes, standards or design requirements are' referenced, or are incorporated into the standard by references, which are in conflict with original design commitments as set forth in the FSAR, the FSAR commitments shall govern. Later revisions of applicable codes and standards may be invoked specifically by the design requirements where deemed appropriate, consistent with the overall commitment to maintain the plant in an " equal to or better than" original condition.

Appropriate design controls have been implemented to control modification work and associated design activities to assure that all modification work meets, or exceeds, original design requirements.

B.S.19.12. ANSI N45.2.12-1974 Requirements for Auditing of Quality Assurance Programs for Nuclear Plants (a) Scope and Applicability Except as expressly modified below, the guidance provided by this standard shall be applied to the audit program identified by the Operational QA Program for Fort St. Vrain Unit No. 1.

(b) Specific Exceptions Audit Schedule (Section 3.4.2)

Due to the large scope of our QA Program and the audit areas defined, it is not practicable to audit the entire program on an annual basis. Our scheduling provides for applicable elements of the QA Program to be audited at least once every two (2)' years. QA monitoring activities serve to identify problem areas, and results of QA monitoring may be used to increase audit frequency or change audit schedules.

I Post-Audit Conference and Follow-up (Sections 4.3.3 and 4.5.1)

At the conclusion of the audit, a meeting is held with appropriate personnel of the audited organization to discuss audit findings. This meeting provides for presentation of audit findirqs and for discussion of these findings by the audited ceguization.

UPDATED FSAR Revision 5 B.5-45 Within thirty (30) days after this post audit conference, an l audit report is issued.

B.5.19.13.. ANSI N45.2.13 - Draft 3, Rev. 3, June 1975 Quality Assurance Requirements for Control of-Procurement of Items and Services for Nuclear Power Plants (a) Scope and Applicability To the extent that the information ~ set forth by this standard provides useful and practical guidelines for' purchasing l activities. associated with nuclear equipment, components, parts, materials and services, the guidance provided will be applied to such activities associated with the Fort St. Vrain Unit No. 1 Operational QA Program.

~ It . must be recognized, however, that equipment and components purchased during the' design and construction phase were not purchased on the basis of present-day standards, especially with reference to Seller qualification and Seller quality assurance programs. 'In this respect, replacement parts and spare parts for existing equipment often are limited to sole-source suppliers, some of whom may. not meet present-day qualification standards. Such replacement parts or spare parts are purchased to appropriate quality standards to maintain an equal to, or better than, condition but it is not considered practicable to backfit the requirements of the standards to all such sellers.

(b) Specific Exceptions Selection Measures (Section 4.2)

In addition to the methods outlined by subparagraphs 4.2.a.,

4.2.b. and 4.2.c., consideration must be given to products in which quality can be verified by receiving inspection, test or'other means. Evaluation of procurement sources for such items may be made on the basis of subparagraph 4.2.a.,

but on a much less restrictive basis.

Sole-source replacement part or spare part suppliers may have to be evaluated based on product performance and maintenance of an equal to, or better than, condition.

Conformance to Procurement Documents (Section 5.2)

Measures shall be established to assure the successful bid conforms to procurement document requirements. There will be no requirement, however, to document the bid evaluations.

Preaward Evaluation (Section 5.3)

The requirement and extent to which preaward evaluations are ~

performed will be subject to the conditions of Section 6.2.

__.._______________.__m

UPDATED FSAR.

Revision 5 B.5-46 Certificate of Conformance (Section 10.2)

The minimum criteria set forth are much too restrictive for general application of certification of conformance involving off-the-shelf items and many applications involving the purchase of simple spare parts. The requirements set forth by this section will be considered in purchasing activities to the extent that the guidance provided is useful and can be applied practicably to our purchasing activities.

B.S.19.14. ANSI N18.1-1971 Selection and Training of Nuclear Power Plant Personnel and Regulatory Guide 1.8, September, 1975 The Fort St. Vrain Technical Specifications require that American National Standards Institute N18.1-1971, " Selection and Training of l Personnel for Nuclear Power Plants", shall be met for selecting and l training plant personnel (except for the Radiation Protection Manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975) and for retraining requirements for those persons on the staff.

B.5.19.15. ANSI N18.7-1972 Administrative Controls for Nuclear Power Plants The Operational QA Program for Fort St. Vrain Unit No. 1 is intended to be responsive to the guidance provided by this standard.

l Where codes or standards are referenced, or are incorporated into the standard by reference, which are in conflict with original design commitments as set forth in the FSAR, the FSAR commitments shall govern. Later revisions of applicable codes and standards may be invoked specifically by the design requirements where deemed appropriate, consistent with the overall commitment to maintain the plant in an " equal to or better than" original condition. Specific requirements of the Fort St. Vrain Technical Specifications differ in some respects from the requirements of this standard. Where differences do occur, the Technical Specifications shall govern.

p' UPDATED FSAR Revision 5 Table B.5-1 Page 1 of 2 POLICIES AND GUIDELINES FOR ELECTRIC'PRODUCTI F NUCLEAR ACTIVITIES l 1'. General Policy Statement

2. Organization Policy
3. Quality Assurance Policy
4. Nuclear Engineering Policy
5. Procurement Policy
6. Construction Policy
7. Nuclear Operations Policy
8. Maintenance Policy
9. Safety Policy
10. Physical Protection Policy
11. Documentation Policy
12. Training Policy
13. Nuclear Emergency Planning Policy
14. Fire Prevention / Protection Policy
15. Nuclear Plant Startup and Testing Policy
16. Environmental Protection Policy
17. Nuclear Plant Procedures
18. Fitness for Duty Policy l 19. Communications Policy l 20. Commitment Control Policy l 21. Industry Group Participation Policy 1 22. -Management Tour Policy ,

l 23. Planning and Scheduling Policy l 24. Managerial Competencies I

UPDATED FSAR Revision 5 Table B.5-1 Page 2 of 2 POLICIES AND GUIDELINES FOR ELECTRIC PRODUCTION ~ NUCLEAR ACTIVITIES l 25. Prioritizing Work for Nuclear Organization Policy l 26. NRC Relationship for Compliance with Regulations, Orders, and l Commitments Policy l 27. NRC Relationship for Proposed New or Amended Regulations or l Commitments Policy l 28. Environmental Qualification of Electric Equipment (EQ) Policy

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5 NINIMUM QUALIFICATIONS FOR MANAGER, QUALITY ASSURANCE

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1. EDUCATION:

College Degree, preferably in the technical _ sciences araa, or.

equivalent in experience and technical training.

2. GENERAL' EXPERIENCE: (Professional Level)

Five to eight years. experience.in a responsible position that '

includes coordination, direction and supervision of personnel, equipment and materials. Experience in handling diverse projects preferred. Should have a working knowledge and und8rstanding of plant design and cperation and an

, understandingof constructi>n practices.

i 7i ,

3. -QtJALITY ASSURANCE EXPERIENCE AND TRAINING:

di. hg Experience of two;to five years in ' quality assurance or related activities. Expe'rienceishould preferably include work with codes and/or,;staddards;.and the application of codes, . standards and/or regulatory requirements to construction, industrial or opera',ional, requirements.

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4. DIRECT EXPERIENCES g.

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Two years experience in dircct supervision of quality assurance

. activities. c

5. FORMAL TRAINING:

ervisory training preferred. Basic QA Basic and advanced indoctr(nation and fun sup'damental training in QA techniques or the 4 \;

equivalsnt iii expertene.

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UPDATED FSAR Revision 5 Table B.5-3 (Page 1 of 2)

THREE LEVEL QUALITY ASSURANCE PROGRAM FOR PLANT OPERATION '

EXPLANATION OF FIRST, SECOND ANO THIRD LEVEL QA RESPONSIBILITIES L

Engineering & Construction Nuclear Fuel Procurement Operation

a. First Level - Quality a. First Level - Inspection Control & Inspection The First Level, which Personnel at this level are constitutes the Quality charged with the Control and Inspection _ rescansibility for direct

-function, is performed by inisection, witnessing and nuclear _ fuel fabricators, sign-off, attesting that equipment manufacturers, work has been performed at and construction contractors, each stage in accordance Such manufacturers are with the quality

, generally expected to have requirements of the separate Quality Control controlling documents.

organizations, which are Inspection and quality l charged with direct control is performed inspection and sign-off by Maintenance Quality l attesting that quality Control personnel and/or l requirements have been met QA/QC personnel.

at each stage of manufacture or construction.

b. Second Level - Quality b. Second Level - Quality

' Assurance Surveillance Assurance Monitoring The Second Level, which This function is performed constitutes the Quality by Quality Assurance Assurance Surveillance personnel as appropriate function, is performed by for the work involved. The the prime contractor, a documents which control the major design contractor, testing, operation, the construction manager, maintenance, and or the owner's QA personnel, modification are prepared as appropriate for the work for review and approval by involved. The drawings and this level, for use by docanents that control the First Level personnel.

design, fabrication, construction and installation Second Level QA is are prepared at this level, responsible for assuring for use by the First Level that all controlling contractors. During the documents for operation design phase of the project, include appropriate quality Second Level QA is requirements. During responsible for assuring operation, Second Level QA that specifications, is responsible for drawings, and purchase monitoring the work to

' UPDATED FSAR Revision 5 Table B.5-3 (Page 2 of 2)

THREE LEVEL QUALITY AS_SURANCE PROGRAM FOR PLANT OPERATION ,

EXPLANATION OF FIRST, SECOND AND THIRD LEVEL QA RESPONSIBILITIES Engineering & Construction Nuclear Fuel Procurerrent Operation documents include assure that QC and appropriate quality inspection programs are requirements. During the being carried out and that fabrication and construction the quality requirements phase of the project, are being met.

Second Level QA is responsible for maintaining surveillance of the manufacturing and l construction work to' assure that contractor Quality Control and Inspectior.

programs are, in fact, being carried out and that the quality requirements are, in fact, being met.

c. Third Level - Quality c. Third Level _ Quality Assurance Audit Assurance Audit The Third Level, which This function is performed constitutes the Quality by, or under the direction Assurcnce Audit function, of, high-level management.

is performed by the owner, Persons performing these the owner's representative, audits are generally not or the prime contractcr. involved in the day-to-day In either caso, these audits Inspection or Quality are carried out by or under Assurance monitoring the direction of high-level functions. Audits will management. Persons normally be performed by, performing these audits or under the direction of, are generally not involved the Manager, Quality in the day-to-day Assurance.

Irspection, Quality Control or Surveillance functions.

UPDATED F5AR Revision 5 Table B.5-4 (Page'l of 2)

ANSI' STANDARDS AND REGULATORY DOCUMENT _S APPLICABLE TO FSV OPERATI0j4S QA PROGRAM a) Final Safety Analysis Report - Appendix B (Amendment 32) b) FSV Technical Specifications c) USNRC Quality Assurance Criteria for Nuclear Power Plants, 10CFR50, Appendix B d) WASH-1283, Guidance on Quality Assurance Requirements During Design and Procurement Phase of Nuclear Power Plants P.evision 1, dated 5/14/74 e) WASH-1284, Guidance on Quality Assurance Requirements During the Operations Phase of Nuclear Power Plants, dated 10/26/73 f) WASH-1309, Guidance on Quality Assurance Requirements During the Construction Phase of Nuclear Power Plants, dtted 5/10/74 g) N45.2-1971, Quality Assurance Program Requirements for Nuclear Power Plants (Standard) and Regulatory Guide L28, June 7, 1972.

h) N45.2.1-1973, Cleaning of Fluid Systems and Associated Components During the Construction Phase of Nuclear Power Plants (Standard) ano Regulatory Guide 1.37, March 16, 1973.

1) N45.2.2-1972, Packaging, Shipping, Receiving, Storage, and Handling of items for Nuclear Power Plants (During the Construction Phase) (Standard) and Regulatory Guide 1.38, March 16, 1973.

j) N45.2.3-1973, Housekeeping during the Construction Phase of Nuclear Power Plants (standard) and Regulatory Guide 1.39, March 16, 1973. <

k) N45.2.4-1972, Supplementary Quality Assurance Requirements for Installation, Inspection and Testing of Instrumentation and Electric Equipment During the Construction of Nuclear Power l Generating Stations (Standard IEEE) and Safety Guide 30, August 11, 1972.

1) N45.2.5-1974, Supplementary Quality Assurance Requirements for

! Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power '

l Plants (Standard) and Regulatory Guide 1.94, Rev. 1, April 1976. )

i m) N45.2.6-1973, Qualifications of Inspection, Examination and i Testing Personnel for the Construction Phase of Nuclear Power )

Plants (Standard) and Regulatory Guide 1.58, August 1973. j i

i 1

L - --._____-____________ _ __ _ _

UPDATED FSAR-Revision 5 Table B.5-4 (Page 2 of 2)

ANSI STANDARDS AND REGUUTORY-DOCUMENTS APPLICABLE TO FSV OPERATIONS QA PROGRAM ,

n) N45.2.8, Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants (Draft 3, Rev. 3, April 1974) o) N45.2.9-1974, Requirements for Collection, Storage and Maintenance af Quality Assurance Records for Nuclear Power Plants (Standard) p) N45.2.10-1973, Quality Assurance Terms and Definitions (Standard) j and Regulatory Guide 1.74, February.1974, q) N45.2.11-1974, Quality Assurance Requirements for Design of Nuclear Power Plants and Regulatory Guide 1.64, Revision 2, June 1976.

r) N45.2.12-1974, Requirements for Auditing of Quality Assurance Programs for Nuclesr Power Plants (Standard) s) N45.2.13, Quality Assurance Requirements for Control of Procurement of Equipment, Materials and Services for Nuclear Power Plants (Drar c 3, Rev. 3, June 1975) t) American National Standards Institute Standard ANSI N18.7-1972, Administrative Controls for Nuclear Power Plant Personnel and l Safety Guide 33 (See Ref 7).

u) American National Standards institute Standard ANSI N18.1-1971, Selection and Training of Nuclear Power Plant Personnel, and Regulatory Guide 1.8, September 1975.

v) N45.2.23-1978, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants (Standard) and Regulatory l Guide 1.146, August,1980 (see Refs.12 and 13).

w) Regulatory Guide 1.21, Revision 1, June 1974 (Reference 19).

x) Regulatory Guide 4.1, Revision 1, April 1975 (Reference 19).

NOTE: Documents referenced above from d) through x) inclusive do not apply in their entirety. Specific exceptions to these documents are set forth in Section B.5.19.

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Quality Assurance Program For Plant Operation

I UPDATED FSAR Revision 5 8.6-1 B.6. REFERENCES FOR APPENDIX B

1. Final Safety Analysis Report for the Fort St. Vrain Nuclear Generating Station, as revised through Amendment 32.
2. NRC letter dated May 9, 1975, Division of Reactor Licensing to Walker (PSC);

Subject:

Additional information on PSC QA Program for Operation.

3. PSC letter dated June 23, 1975, Walker to Giambusso (NRC);

Subject:

FSAR Amendment 31.

4. PSC letter dated October 31, 1975, Walker to Clark (NRC);

Subject:

FSAR Amendment 32.

5. Code of Federal Regulations, Title 10, Part 19 (10CFR19); Part 20 (10CFR20); Part 50 (10CFR50); Part 55 (10CFR55); Part 73 (10CFR73).
6. PSC letter dated March 4,1982 (P-81085), Brey to Seyfrit (NRC);

Subject:

Changes to QA Program as described in the FSAR (10CFR50.59).

l 7. Quality Assurance Program Requirements (Operation), USNRC Safety l Guide 33, November 1972, (endorsing ANSI N18.7-1972).

8. American Society for Nondestructive Testing Recommended Practice No. SNT-TC-1A.
9. Guidance on Quality Assurance Requirements During Design and Procurement Phase of Nuclear Power Plants, WASH-1283, Revision 1, May 24, 1974.
10. Guidance on Quality Assurance Requirements During the Operations Phase of Nuclear Power Plants, WASH-1284, October 26, 1973.
11. Guidance on Quality Assurance Requirements During the Construction Phase of Nuclear Power Plants, WASH-1309, May 10, 1974.
12. NRC letter dated May 1, 1981 (redated for transmittal to PSC January 5, 1982) (G-82008), Eisenhut (NRC) to Holders of Construction Permits;

Subject:

Qualification of Inspection, Examination and Testing and Audit Personnel (Generic Letter 81-01).

13. PSC Letter dated February 3, 1982 (P-82042), Lee to Eisenhut (NRC);

Subject:

Qualification of Inspection, Examination and Testing and Audit Personnel.

14. PSC letter dated October 13, 1978 (P-78167), Fuller to Gammill (NRC);

Subject:

Evaluation of Fire Protection Provisions (Branch Technical Position 9.5-1).

UPDATED FSAR Revision 5' B.6-2

15. PSC letter dated November 13,1978(P-78182),FullertoGammill (NRC);

Subject:

Evaluation of Fire Protection Provisions (Branch ,

Technical Position 9.5-1).

16. NRC letter dated June 12, 1981 (G-81107), Seidle (NRC) to Millen;

Subject:

NRC I&E Inspection 81-10, QA Program.

17. Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants, ANSI N45.2.23-1978.
18. PSC letter dated June 16, 1982 (P-82188), Warembourg to Collins (NRC);

Subject:

NUREG-0737.

19. NRC letter dated November 23, 1983 (G-83429), Wagner (NRC) to Lee;

Subject:

Technical Specifications Amendment 37.

20. NRC letter dated January 24, 1983 (G-83060), Taylor to Distribution;

Subject:

Final Rulemaking: Reporting of Changes to QA Programs

21. NRC letter dated August 10, 1983 (G-83301), Wagner (NRC) to Lee;

Subject:

Technical Specifications Amendment 35.

22. PSC letter dated June 27, 1984 (P-84185), Gahm to Johnson (NRC);

Subject:

FSAR Appendix B.

23. NRC letted dated August 10,1984 (G-84282), Johnson (NRC) to Lee;

Subject:

Approval of Revision 1 of the Quality Assurance Program for Plant Operation, Appendix B, FSV FSAR.

24. PSC letter dated September 28, 1984 (P-84369), Lee to Director of Nuclear Reactor Regulation;

Subject:

Fort St. Vrain Updated FSAR Revision 2, Appendix B.

..______m_ . . _ .-___- _ _ _ _ _,._._ _ _ ._ _

4 \' .

ENCLOSURE 2 TO P-87261

r l

f 1 Enclosure 2 to P-87261 CHANGE APPENDIX B APPENDIX B NO. SECTION (REV.4) DESCRIPTION OF CHANGE COMMITMENT EVALUATION 1 B.5 Corrected titles and No Effect B.5.1.1 organization charts.

B.5.1.3 Deleted all management B.5.1.4 positions below the B.5.1.5 Department Manager level B.5.1.6 and incorporated specific B.5.2.3 responsibilities into those B.5.2.8 of the specific manager B.5.2.11 responsible.

B.5.18.3 2 B.5 Deleted " Assurance". No Effect 3 B.5 Deleted " Safety Related" Increased B.5.1.3.b)3) entirely or changed to Commitment 8.5.1 3.c)5) " controlled by the QA l B.5.1.4.a)2) Program". l B.5.1.5.a)2) l I B.5.1.5.a)3) l l B.5.2.2 l l B.5.2.6 l l B.5.2.9.a) l l B.5.2.10  !  !

B.5.3.4.b) l l B.5.3.4.d) l l B.5.3.4.g) l l B.5.3.6 l l B.5.3.8 l l B.5.4.2 l l B.5.4.2.d)4) l l B.5.4.3 l 1 B.5.4.4 l l B.5.5.1 l l B.5.5.2 l l B.5.7.1 l l B.5.7.3 I I B.5.8.2 l l B.5.10.1 l l B.5.12.1 l l B.5.12.4 l 1 B.5.13 l l B.5.19 l l B.5.19.1 l l B.5.19.2.a) l l B.S.19.3.a) l l B.5.19.3.b) l I Enclosure 2 to P-87261 CHANGE APPENDIX B APPENDIX B NO. SECTION (REV.4) DESCRIPTION OF CHANGE COMMITMENT EVALUATION 3 B.5.19.5.a) Deleted'" Safety Related" Increased (cont.) B.5.19.6.a) entirely or changed to Commitment B.5.19.7.a) " controlled by the QA l B.S.19.8.a) Program". ]

B.5.19.11 l l B.5.19.13 l l 4 B.5.1.2.d) Changcd " verifies" No Effect to " documents".

5 B.5.1.3.b)4) Changed " Approved Supplier No Effect Listing" to " Approved Vendors List".

6 B.5.1.3.c)4) Deleted QA Operations No Effect Manager coordinating follow-up to NRC Inspection Reports.

7 B.5.1.5.a)2) Added " Controlled Work No Effect Packages for . . .".

8 B.5.1.7.a) Changed " Purchasing and Increased B.5.4.3 Stores" to " Material Commitment Management". Added " Energy, Power Plant and Engineering Services".

9 B.5.2.1 Added "non safety-related Increased portions of the . ." Commitment added " Delineation of QA Program requirements for these items is specified in the FSV Administrative Procedures Manual".

10 B.5.2,1 Added QA/QC. No Effect B.S.10.1 B.5.19.1.b)

Table B.5-3 11 B.5.2.7.d) Added " Interface Circuits Increased (IC) within the EQ Program." Commitment

Enclosure 2 to P-87261 CHANGE APPENDIX B APPENDIX B NO. SECTION (REV.4) DESCRIPTION OF CHANGE COMMITMENT EVALUATION 12 B.S.2.8 Changed "PSCo" to "FSV". No Effect Changed " Program Administrative Manual" to " Procedures".

13 B.5.2.9 Changed "providing" to No Effect B.5.2.9.a) " ensuring the". Changed "to" to "is provided for".

Changed "is" to "be".

14 B.5.3.3 Added description for Increased Temporary Configurations. Commitment 15 B.5.4.4 Added "other than quantity, No Effect price, or terms of payment,".

16 B.5.5.1 Changed " Regulatory Guide No Effect B.6 (Ref. 7) 1.33" to " Safety Guide 33".

Table B.5-4.t) 17 B.5.8.2 Added ", or reference to the No Effect purchase order,".

18 B.5.12.4 Changed " cards" to " forms". No Effect 19 B.5.14.3 Deleted exceptions to Increased independent verifications Commitment for return of clearances.

20 B.5.15.1 Reworded to more accurately No Effect describe NCR use.

21 B.S.15.2 Added " independently Increased verified". Added " Return Commitment ,

to vendor", " Scrap", or

" rework" dispositions are accomplished in accordance with administrative procedures.

22 B.5.16.1 Reworded to reflect No Effect corrective action system for all of Nuclear Operations, not just QA.

23 B.5.16.2 Added " Quality Deficiency No Effect Reports (QDR's)". Chanced

" Requests" to " Reports".

Enclosure 2 to P-87261 CHANGE APPENDIX B APPENDIX B NO. SECTION (REV.4) DESCRIPTION OF CHANGE COMMITMENT EVALUATION 24 B.5.17.3 Added "A Records Retention No Effect Schedule serves as a records checklist designating records".

Added " reviewed".

25 B.5.18.2 Changed "by" to "under the No Effect cognizance of".

26 B.5.19.5.a) Added "(Safety Guide 30)". No Effect Table B.5-4.k) Changed " Regulatory Guide 1.30" to " Safety Guide 30".

27 B.5.19.7.b) Added "be physically capable No Effect of performing the assigned task and should". Added

" Personnel with physical restrictions shall be limited to. performance of only those tasks for which they are physically capable."

28 B.5.19.11 Added "Rev. 2 No Effect 29 B.5.19.12.b) Deleted exception to " Audit Increased d Process (Section 4.3.2)". Commitment 30 B.S.19.12.b Deleted "to the Manager, No Effect Quality Assurance for approval and forwarding to the audited organization and to the Vice President, Electric Production."

j; 31 B.5.19.14 Changed "used as a scide" Increased l to " met". Deleted Commitment

" replacement".

32 B.5.19.15 Corrected typo No Effect f " incorporated".

33 Table B.5-1 Added new policies. No Effect 34 Table B.5-4 Added dates. No Effect 35 Figure B.5-3 Updated document tree for No Effect Procedures.

}

UPDATCD FSAR Revision 4 B.5-1 B.5. QUALITY ASSURANCE PROGRAM FOR PLANT OPERATION It is the policy of Public Service Company of Colorado to use its best efforts to insure that the Fort St. Vrain Generating Station is maintained and operated in a manner that assures the highest practical degree of safety to the public and to its employees.

g l The Vice President, E':" " M r"-- T:;; ._d .. . w.ns l t: "'.. ".... M , Nuclear Operations \ is assigned the authority and responsibility within PSCo for all activities associated with engineering, procurement, operation, maintenance, modification and quality assurance of the Fort St. Vrain Generating Station. To ensure that all of these activities are performed in a manner consistent with the policy of PSCo, the Company has established and implemented a Quality Assurance Program to meet the requirements of 10CFR50, Appendix 8 and the applicable regulatory requirements (Ref.

5).

All personnel performing duties affecting quality including those of contractors, suppliers, and any other organization performing quality activities associated with the nuclear project are responsible for compliance with the directives established within the Quality Assurance Program.

The Public Service Company of Colorado policies and guidelines

@ for [';.tMc- M S: 2 nuclear activities sets forth the commitment GP that the Company has made to quality a,w e***ee for operation of the Fort St. Vrain Nuclear Station. The organizational structure for LP accomplishing the quality ameneaee functions is defined, as are individual responsibilities of persons involved in quality assurance activities and management. The PSCo policy document provides for development of procedures and instructions which will define in

@ detail the nature and extent of*huality . neem m e effort to be carried out in each segment of plant operation, throughout the life of the plant. The policy document provides for indoctrination and training of personnel performing activities affecting quality, and for biennial review of the effectiveness of the program by management and intermediate supervisory levels. The policy document commits the management of PSco to compliance with the intent of 10CFR50, Appendix B, Quality- Assurance Criteria for Nuclear Power Plants and other applicable regulations, codes and standards.

Policies require that the various aspects of plant operation are to be defined and controlled by written procedures which include the Technical Specifications issued with the operating license. Policies LP also require that all n':r:';.d maintenance and repair of the nuclear power plant is to be controlled to avoid violation of the conditions of the license and to preserve margins of safety provided in the original design and construction.

'.% plant are (f Modifications to the : "" r - :' ; ..J r........ .'

required to be controlled in accordance with written procedures which prescribe the responsibilities of the Production, Engineering, Licensing and Fuel and Quality Assurance personnel; which provide measures to control interf aces between those organizations involved

__ __T _? _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _

UPCATED FSAR Revision 4 B.5-2 in plant modifications and design control; and which define the q.

methods to be followed to initiate, design, analyze, review, approve, )-

install, inspect, test, and accept modifications to the plant.

In addition.to specific policies and guidelines for organization, operation, training, maintenance and modifications, other policies and guidelines deal with procurement, construction, nuclear fuel, radiation protection, safety, security, emergency planning, fire prevention, startup and testing, environmental prutection, and nuclear plant procedures. A listing of the current policies and guidelines is given in Table B.5-1.

Although extensive changes have been made to the QA Program for operation as presented in Amendment 32 of the original FSAR (see Refs. 6, 16, 22, 23 and 24), the PSCo Quality Assurance program for Plant Operation is responsive to the scope and requirements of 10CFR50, Appendix 8. The manner of compliance with each of the NRC QA Criteria is discussed in detail in the following paragraphs.

B.5.1. Organization B.5.1.1. Quality Assurance program Responsibility

@ The Public Service Company of Colorado (PSCo) Vice President, uglm opultwr m- " o-i. A, has executive level responsibility operations, for all FSV maintenance, Generating Station engineering, 4 modification, licensing and quality assurance activities. The Vice President has overall responsibility for the FSV Generating Station p

)- for Quality Quality Assurance Program. Direct responsibility Assurance Program definition, implementation and effectiveness has been celegated to the Managn, Quality Assurance who reports to the

': "-- ke4+on,Nud m vfu d e -

@ Vice President, T ::

The Vice President maintains cognizance of the Program and evaluates its status and adequacy through review of monthly reports, mewtings and/or audits. A complete management audit of the program is conducted under his cognizance biennially.

Disputes, arising from differences of opinion between divisions, which are n.ot resolved by the responsible administrators, are referred to the Vice President for resolution.

B.S.I.2. Organizational Arrangements The management structure for the FSV Project is divided among four organizations as follows:

a) Nuclear Engineering Division, provides technical assistance, studies, analysis, engineering, design, construction management and general services in support of operation, modification ar.d maintenance of the plant.

b) Nuclear Production Division, is responsible for the operation and maintenance of the Fort St. Vrain Facility, f

i

_ - _ . _ - _ - _ - - - - _ _ _ _ _ _ _ - _ _ _ _ ._ _ _ s

misu nm Revision 4 B.5-3 l

l' c) Nuclear Licensing and Fuels Division is responsible for nuclear licensing activities, fuel management and spent fuel management services, and functions as the central nuclear licensing contact with the NRC.

O d) Quality Assurance Division, ' implementation i of the QA program responsibilities as discussed in Section 8.5.1.3.

The corporate organization chart is shown in Figure 8.5-1. The l organization charts for the Nuclear Engineering, Nuclear Licensing

-l and Fuels and Nuclear Production Divisions are shown in Figures 12.1-2, 12.1-3 and 12.1-4, respectively. The organization chart for the Quality Assurance Division is shown in Figure 8.5-2.

B.5.1.3. Quality Assurance Division Responsibilities a) Manager, Quality Assurance The Manager, Quality Assurance reports to the Vice

()(gmieu C/udw' cas President,W::t for ': '-the i FSV Quality Assurance Program

t6en, and is assigned overall responsibility adequacy, and implementation effectiveness. The Mananer, QA has been assigned the necessary authority, resources and organizational freedom to manage the Quality Assurance Program; identify quality problems; initiate, recommend and provide solutions, and to veri fy implementation of solutions.

The Manager, Quality Assurance or his designated alternate, has the authority to order that work be stopped; when, in his opinion, maintenance, repair or modification work does not comply with the approved controlling documerAs. For operating activities, the Manager, Quality Assur&nce or his designated alternate has the authority to recommend that work stop. However, authority to stop work on operating activities remains with the Superintendent, Operations or the Senior Licensed Operator present, who will determine whether such stoppage would cause any violation of the Technical Specifications or other approved documents governing plant operations, or whether there are overriding considerations of safety involved.

Minimum qualifications required for the Manager, Quality Assurance are as shown in Table B.5-2. The Manager, Quality Assurance is responsible for:

1) The adecuacy of the Quality Assurance Pr ogram and its implementing procedures, interpretation of Quality Assurance requirements and effectiveness of the Program's implementation.
2) The use of appropriate techniques to assure conformance of all activities affecting quality to the Program's requirements.

l

,# j

UPDATED FSAR Revision 4 B.5-4

3) The adequacy, clarity and appropriateness of all PSCo related communications and 3J Quality Assurance commitments directed to Regulatory Agencies,

. Contractors and Suppliers.

4) Appropriate exercising of the authority vested in the Quality Assurance organization to cause the acceptance or rejection of work, materials and equipment based on conformance or nonconformance to approved engineering or Code requirements.
5) Apprising management of the Station's quality status by monthly reporting on quality activities, trends and problems.
6) Assuring that effectiveness evaluation actions such as QA Program reviews, monitoring and audit techniques are employed to veri fy conformance to requirements of s

activities affecting quality, including activities involving contractors and suppliers.

7) Coordinating applicable activities of regulatory agencies such as audits, inspections or investigations with the affected organization manager (s).

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I b/ QA Services Manager The QA Services Manager reports to the Manager,' Quality l

Assurance, and is responsible for Quality Engineering w>4 e s, G cval, h l ud a J inspection activities, and maintenance Quality Control. His J organization is responsible for:

1) Preparation, coordination with affected organizations, submittal for required approval, and maintenance of "Q" Procedures in the Fort St. Vrain Administrative Procedures, and quality assurance services procedures necessary to implement the Quality Assurance Program.
2) Review of design Change Notices and Specifications for Station modifications to verify the appropriateness and conformance of specified requirements to applicable quality and code requirements.
3) Review of PSCo generated procurement documents for n':L :'---' items < to verify appropriateness of (i) aw,e,1 a y.g&..s quality provisions.

N

7-._____ '

UPDATED FSAR Revision 4 B.5-5 l

4) Evaluation of supplier / contractor capabilities / data to verify qualification adequacy and maintaining an

" Approved L;;' t Lf :t";" .

@ /ta d o r= s LiS4 Preparation, review and approval of special process 5) procedures required for specific applications.

6) Preparation, coordination with affecteh organizations, review and approval of QA inspection / monitoring plans assure their adequacy, and procedures to appropriateness and conformance to applicable requirements.
7) Assuring performance of inspections necessary to verify of procured items to prescribed conformance requirements.
8) Review of Nonconformance Reports ,to verify that appropriate quality considerations are applied to dispositions and resolution of identified deficiencies.
9) Assuring that required inspections are performed by adequately trained and qualified personnel.
10) Assuring that all required inspection records resulting from performed inspections are properly completed, legible and authenticated to qualify as objective evidence records.
11) Assuring review of modification, technical and work control documents for appropriateness of QA provisions and the performance of inspections necessary to verify ~

conformance of completed work to specified requirements.

l Subervisor. 0A Engineering 4

The ervisor, QA Engineering reports to the QA Ser s is responsible for QA Engineering act es.

l Manager, l e) OA/0C Suoervisor The QA/QC Supervisor reports o e QA Services Manager, and l d testing activities.

is responsible for QA/QC i ctio l f) Maintenance QC S - visor The Ma nance QC Supervisor reports to the Q rvices Mar r and is responsible for maintaining and superv ing aintenance QC activities.

t 1

..~

UPDATED FSAR Revision 4 8.5-6

)./

l C p) QA Operations Manager -

. The QA Operations Manager reports to the Manager, Quality Assurance, and is responsible for cuality assurance l

monitoring and audit-related activities. He is responsible for:

@ 1) Preparation, coordination with affected organizatiovis, ,,4,,k#"/"" '

gubmittal for required approval, and maintenance of r,,4 n.vrn.a h nis4,4.v. h=.l { dual i ty assurance operations procedures necessary to  !

Assurance Program I implement assigned Quality responsibilities. I 1

2) Scheduling, coordinating and performing audits and monitoring actions to verify that FSV systems provided j to assure conformance of work and activities to prescribed requirements are adequate and effective.
3) Administrating and coordinating all corrective action activities, including trend analysis and status keeping programs, to assure that conditions adverse to quality are promptly identified and corrected.

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V/) Auditing of supplier Quality Assurance activities to verify adequacy and effectiveness when requested by the QA Services Manager.

(f) Administrating and coordinating QA review of all.new or revised permanent _FSV Procedures involving w4eep

-" activities + to verify their conformance to (J c,Jren.2 6 3

meApha~pp'licablequalityrequirements.

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l Supervisor, QA Technical Support l . upervisor, QA Technical Support, reports to A Manager and is responsible for correct ction, Operat safety related procedure iew and QA g status kee Training activit .

I i) Supervisor, CA Auditia f

The Super r, QA Auditing reports to th erations nd is responsible for auditing and mc ring Mana

. vities and QA Clerical activities.

Revision 4 B.5-7 B.5.1.4. Nuclear Production Division, Quality Assurance Related Responsibilities In addition to responsibilities assigned by organization charter, and as discussed in section 12.1.1 through 12.1.3, the menagement personnel indicated herein are also responsible for the following:

a) Manager, Nuclear Production The Manager, Nuclear Production reports to the Vice h h esident, !?;ff*:* N *'r , and is responsible In quality-related for management of all Station operations.

areas, the Manager, Nuclear Production is responsible for:

Station operations, maintenance and

1) Assuring modification installation activities conform to applicable FSAR, Technical Specification, Regulatory Code and Quality Assurance Program requirements.

Assuring that new or revised Station procedures

2) compatible with the FSV affecting auality are Administrative Procedures Manual as described in :!;nd Para.

B.5.5.1. Procedures involving r #r'r m

(@ h ^*"e4'3_ A ** b r y activities} are provided and concurrence in regards to the QA Division to quality related aspects. for review

3) Assuring that Quality Assurance Division personnel have access to Station facilities, personnel and records as necessary for the performance of quality-related {

assignments.

4) Assuring that Managers in Nuclear Production provide timely responses to deficiency notifications and corrective actions to permit prompt close out of deficiency reports.

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I h) / Station Manager The Station Manager reports to the Manager, Nuclear a1 Production and is responsible for the management of all production operations and maintenance activities) ncW.nh'# \ ,M

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1. Routine and emergency operation of the facility.
2. Mechanical and electrical maintenance activities and instrument maintenance and testing.
3. System evaluations, plant performance testing, and plant modification reviews and associated testing.
4. Planning and scheduling of Nuclear Production activities and Stores activities, which include integration of inventory control and buying functions to support maintenance and scheduled outage needs and development of short and long range ,

)

plans in coordination with other departments.

i

\

UPDATED FSAR Revision 4 8.5-8 I l

Superintendent, Ooerations l

The Superintendent, Operations, reports to the Stati anager and is responsible for plant operation.

l f) S ft Suoervisor l The Shift Supervisors report to the Super tendent, '

j Opera ens, and are responsible for routine an emergency operati of the facility. Shift Superviso may act in l

l behalf o other, supervisors if they are unavai able.

l g) Suoerintene t, Maintenance The Superint ent, Maintenance, repe s to the Station l

Manager, and responsible for 1 mechanical and l

electrical maint ance activities.

l h) Superintendent, Nuc ar Betterment, nqineering l

The Superintendent, lear Be erment Engineering, reports j to the Station Manager, nd i responsible for instrument maintenance and testing.

l i) Supervisor, Results Engin ing n l The Supervisor, Re ts gineering, reports to the ,

l Superintendent, Nucl r Bette ent Engineering, and is l

responsible for pl ,t modifica on review and testing, and plant performance sting.

I j) Instrumentation and Controls Suoervis s The Instrum tation and Controls Supe isors report to the l Superinten nt, Nuclear Betterment En eering, and are responsib for instrumentation and contro maintenance and testing.

I k) Shift upervisor, Administration I

Th Shif t Supervisor, Administration, reports to he Station M ager and is responsible for plant scheduling a stores ctivities.

I 1

Maintenance Supervisors The Maintenance Supervisors report to the Superintend t, l

Maintenance, and are responsible for the coercination f mechanical and electrical maintenance activities.

, 7 Revision a B.5-9 l

l

' ' ;;, , , A n t. , ?:.nn N , h % &- rd Ste es_

l Superintendent, Planning, Scheduling and Stores, reo Station Manager and is responsible for plan and l

to t scheduli of Nuclear Production activitie nd stores l

l activities.

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, ~~ . n-The Supervisor, Star orts to the erintendent, l responsible for Planning, Scheduli nd Stor and l

integration - o nventory contr buying functions to l

j support m enance and sched needs. The Superv r, Stores, also coo nates wit departments l

I t sure timely orderin parts and equip t.

l . !_; n ':r- o':-- M ad ' ":i_'.'ag The Superv r, Planning and Scheduling, reports the l

i Superin ent, Planning, Scheduling and Stores, an is l reso ible for developing short and long range plans n dination with other departments.

l l g f) Technical / Administrative Services Manager The Technical / Administrative Services Manager reports to the ba/ l Manager, Nuclear Production, and is responsible for plant security, all administrative services, plant engineering, Wuclear Material Management, controlled work procedure (CWP)h/mio *d l

coordination, and the Shift Technical Advisors. A %/v4 w.m rs *,.-y e re pres:t:1. +,m uso ,2as ta., : qe +ruaa . ,,4 e p l a) ("n= N -- i.., b m...s.: R. %;; C.,,,...-n;--

Superintendent, Technical Services Engineering repor j to tn echnical/ Administrative Services Manager, is l responsi for Plant Engineering, Nuclear terials l Management, trolled work procedure (CWP) r w, computer services, and pl licensing activities.

l l r) !_,..;'::c. *:.oe .. , ._ g ' ,

l The Supervisor, Plant neering, reports to the Superintendent, Technic Serv s Engineering, and is l

responsible for sup ising the elopment and control of l

corrective and pr ntive maintenance ocedures, practices  ;

l l and activitie and coordinating and m itoring the plant j modificatic recess. The Supervisor, Pla Engineering, also S' evises and provides necessary dai technical I

l eng ering support for plant operation and maintenance I ups.

l l

n .

farerf

1. Development and control of corrective and preventive maintenance procedures, practices and activities, and coordinating and monitoring the plant modification process.
2. Technical engineering support for plant operation and maintenance groups in the electrical and mechanical maintenance areas.
3. Providing technical services in conjunction with reactor maintenance activities, including identification.and resolution of reactor operational prcblems, directing Maintenance personnel performing reactor maintenance, associated equipment troubleshooting and repair, reactor related fuel handling, and other reactor / reactor component associated support tasks.
4. Oversight to ensure the reactor is operated in compliance with the Facility License. the Technical Specifications, and other federal, state, and local regulations, and controls the use of all Special Nuclear Materials at Fort St. Vrain.
5. Plant review of proposed design modifications to ensure required operational, regulating, training and licensing reviews are factored into the design proposals and their implementing procedures.

I

__w- __ ___-_ -

UPDATED FSAR f Revision 4 B 5-10 l  :;- . ....~,, a .m:..: n <r-- 9}

Supervisor, Technical Services, reports to the

-l

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'Sup intendent. Technical Services Engineering, a is l respo ible for supervising a' technical gr p that l problems, identif .and resolves reactor operational l

ensures t reactor is operated in compli ce with the l

l Facility Li se, the Technical Specification , and other j federal, sta and_ local regulations, an ontrols the use l

of all Special lear Materials at For.t . Vrain.

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The Supervisor, Reac r Mai enance, reports to the

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Superintendent, Technical Ser ces Engineering, and ntenance personnel performing is l

responsible for directing l

reactor maintenance, asso t equipment troubleshooting and repair, reactor r ated uel handling, and other l

j Reactor / Reactor compen associat support tasks.

l  :) L ....., ^ n.,."-:or The Securi Supervisor re rts to the Technical /Ac. istrative Services Man er, and is l

responsibi for performance of all act s required to in l

assure s urity of the plant. ,

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l ) r. ,.::n, "rr'::- 0:: r: ts e Supervisor, Nuclear Documents, reports o the I

Technical / Administrative Services Manager, an is l

responsible for plant clerical activities.

1 I d/) Support Services Manager Jee A Huki - a. m V , 3 )

The Support Services Manacer reports to the Manager, Nuclear sponsible for the Health Physics,

.' Production, Radiochemistry, and _xp:-f:r; '":r-) C'--'

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and Secondary -(Water) Chemistry Programs: The Support Services Managr. acts as the Radiation Protection Manager, as specified in the Technical Specifications, ,and as such, is responsible for all radiation protection activities including ..the '. Radiological Envicenmentel -Monitoring Program for the station. The Support Services Panager also is rescensible for training activities as requiredL'by ANSI N18.1 - 1971 and 10CFR55 Appendix A, and. Fort St.

Vrain Training , Program accreditation efforts. . Training responsibilities'inciyde:

' 1, Training _ ,and qualification of nonlicensed operators,.

licensed operators, and technical advisors. <

3 2.-((Trainingm and qualification' of ' Health Physics personnel, i, Resul tsl personnel , . Maintenance personnel (Electrical and Mechanical),' Chemistry personnel, and Training personnel.

Ti aining of 'all personnel in' subjects applicable.to all I

3.

depanments; (GET, First' Aid, Fire Fighting and Emergency-Response).'

I i

i

UpCATED FSAR l

Revision 4 B.5-11 Superviser, Radiochemistry l

he Supervisor, Radiochemistry, reports to the Sustry art l

vices Manager, and is responsible for all radioch l

ac vities.

Sucervi r, Chemistry l z) l The Super isor, Chemistry, reports to th upport Services Manager, an is responsible for plant che. stry activities.

aa) Superintendent, raining l

The Superintendent Training, eports to the Support l d is resp sible for coordinating Services Manager, l

training activities requir d by ANSI 18.1 - 1971 and 10CFR55 Appendix A.

l bb) Sucervisor, Coerator Train The Supervisor, Oper tor raining, reports to the l is responsible for the l

Superintendent of Tra ing, an and qual fication nonlicensed operators, l training l

licensed operators, nd technical visors.

l cc) Sucervisor, Tech cal Training The Supervis , Technical Training, reports to the l

Superintend of Training, and is res nsible for tne l

j training a qualifications of Health Phy cs Technicians, I

Results Te nicians, Maintenance personnel, e ctricians and l

chemistry personnel.

l dd) Superv or, Trainino Suoport The Supervisor, Training Support, reports o the l

Su rintendent of Training, and is responsible r the l

aining of all personnel in subjects applicable all l

]

epartments; (GET, First Aid, Fire Fighting, and Emer ncy l Response). The Supervisor, Training Support, is so I

responsible for the accreditation efforts for the Fort t.

j Vrain station.

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UPCATED FSAR Revision 4 B.5-12 B.5.1.5. Nuclear Engineering Division, Quality Assurance Related 9l Responsib111 ties In addition to responsibilities assigned by organization charter, personnel and as discussed in Section 12.1.5, the management indicated herein are also responsible for the following:

a) Manager, Nucher Engineering The Nuclear reports to the Vice

@ Manager,I6 President, G " #" M,Eng'ineering-and is_n,responsible for FSV project Engreering. De21gn Engineering, and plant j modi fication/rttrofit activities. In quality-related areas, he is responsible fcr:

1) Assuring implementation of design control measures, including independent reviews as required by the FSV Quality Assurance Program.

Assuring prior Engineering review and approval of 211 (f (7 2) c,4nel wA Av.</,,@ju D'21, 2-- f Plant modifications.

Assuring that Engineering procedures cor:erning 3) activities affecting quality are compatible with the FSV Administrative Procedures Manual as described in

~ Para. B.5.5.1. Procedures involving " ' "

-d f' unN Hel I ^c 3

acTivitiesvare provided to the QA Division for review L

/j 7 and concurrence in regards to quality related aspects.

86 Q ' ,/

4) Assuring that Quality Assurance Division personnel have access to Engineering facilities, personnel and records as necessary for performance of quality-related assignments.
5) Assuring timely response to notifications of quality-related deficiencies and problems; and implementation of prompt corrective action to permit closeout of deficiency reports.
6) Assuring that plant items and equipment are classified according to safety-related and Code requirements.
7) Assuring that the FSV quality-related records system is managed in a manner to assure accountability and retrievability of stored records.

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W9mu eW4 Revision 8 B.5-13 ef a n.a w at y a *, l dn:

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a., a w 4,,,y esef* ,4*~+ ef l k[ Muclear Design Manager

.The nuclear Design Manager reports to the Manager, Nuclear Eng:noering, and is responsible for. electrical, mechanical and civil engineering activities reisted to nuclear projects h including conceptual, preliminary and. final estimate design.

_s,,[

Responsibilities include preparation of cost development of preliminary and final design,fpreparattun of equipment specifications, adinia.istration of design contracts and procurement of material. The Nuclear Design Manager performs design, transient and system ane. lysis related to updating plant modifications and  ;: '-- 3 document

~ + 4 m g f,, d% r . Pr*4*> dE=Mg a'd l g/) Nuclea" Site Engineering Manager The Ntclear Site Engineering Manager reports to the Manager, Nuclea,e Engineering, and is responsible for the immediate l

engineering support required by plant operation, coercination of modification / construction activities activities for One and overell planning and scheduling

- 3 Engineering Division. Responsibilities include preparation

)

of , cost estu.iates.y development of preliminary and final coe pa; meun:.,[w,rbd a prg,,, er. / designs, implementation of modification work,' implementation -

,, Iu,,,, ,' of the overall Engineering planning and scheduling function and supervision / administration of construction work).a M.qcair4 A a I a : ,,. . . M. n a; sh.h se,% nyrd wi <~ t

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4 I f' Supervisor, Records Center The cervisor, Records Center, reports to the Engineerir l Services ager, and is responsible for providin tem aspects of ection, support an idance in all maintenance, storag , etrieval, security position, and archival management o clear Re s. The Supervisor, g Records Center, also plans, c tes and directs records and information system av ament of the Records Management System.

I g) .Suoervisor, ear Projects i Th .nree Supervisors, Nuclear Projects report to the l

clear Cesign Manager, and are responsible for electric 1,

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D. Engineering Services Manager

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The Engineering Services Manager reports to the Manager, Nuclear Engineering, and is responsible for administration of. the FSV Records Center, ~ including ~providing system support and guidance' in all~ aspects of collection, maintenance,'scorage, retrieval, security, disposition, and archival management of nuclear records and for planning, coordination, and direction of information systems development for the Nuclear Records Management System. The Engineering Services Manager is also responsible for employee training programs, personnel records, administering purchase orders and contracts, preparation of procedures,-and gene.ral clerical and secretarial support for the Nuclear Engineering Division.

0

- - . _ . - - - _ - - - - _. _ f% -

1 I 1 1 1

! UPDATED FSAR L Revision 4 l B.5-14 1'

mechanical and civil engineering activities relate to el uclear projects. The Supervisors, Nuclear Projects ovide l

j d ign inputs, design analysis, design verification develop l

  • pro rement, installation and test requirements, d provide draft g and document update functions, j h) Suoervis Nuclear Site Engineering I I

J The two Sup visors, Nuclear Site Engin ring report to the Nuclear Site ineering Manager, and re responsible for  ;

l coordination o timely on-site ineering support in l

response to pla operational ds. The Supervisors, Nuclear Site Engi ering also dminister on going site l

engineering activitie which ar eing performed to comply' 1 with Nuclear Regula ry ommission requirements and l

commitments, and conduct minary coordination / review of all nuclear purchase requi ions.

l 1) _Suoervisor, Nuclear Co tructi The Nuclear Const etion Coordina r reports to the Nuclear l Site Engineerin Manager, and is responsible for the coordination nd administration o outside contractor support impi .enting plant modification directed by the Nuclear En neering Division, y l j) Supervi , Site Engineering Support L l The Supervisor, Site Engineering Support report to the l N lear Site Engineering Manager, and is responsibi for l anning and scheduling Nuclear Engineering Divis n l

activities as;ociated with Fort St. Vrain.

B.5.1.6. Nuclear Licensing and Fuels Division, Quality Assurance Related Responsibilities l In addition to responsibilities assigned by organization charter i and as discussed in Section 12.1.7, the management personnel indicated herein are also responsible for the following:

a) Manager, Nuclear Licensing and Fuels

([ TheManager,NuclearLgegnsingandFuelsreportstotheVice President, E ' # * #' M*"a and is responsible for providing a central nuclear licensing and nuclear safety review organization to interface with the Nuclear Regulatory 7 ^

Commission for all Fort St. Vrain licensing matters. The h respah b Manager, Nuclear Licensing and Fuels also  % end m:mW+ *$Y / c -- ~ # the nuclear fuel managements and spent fuel management programs and special projects and analyses as may be required by executive management.

_ - _ - _ _ _ _ _ _ _ _  ?

Up0ATED FSAR Revision 4 B.5-15 b) Nuclear Licensing Manager The Nuclear Licensing Manager reports to the Manager, i Nuclear Licensing and Fuels and is responsible for nuclear licensing He maintains personal contact via telephone l o#)d f

and safety activities.

and correspondence with the NRC in connection with' licensing developments involving both parties, f2-  ; 1. . ,.'.; :.:' __...ns

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uvcle+A- L:t' y Awa ss. e i m :6:lJre in c/4 c. ', Qrs Una.eL - wl-c) Nuclear Fuel and Ana' gis Manager The Nuclear Fuel ud Analysis Manager reports to the Manager, Nucisar Litwring and Fuels and is responsible for nuclear fuel servim,4eekeeKw fuel engineering and design, g fuel and core consvuoles procurement, and fuel fabrication, "r ': ':: -..,..... .. '.. spent fuel management,1 reactor '

core design .and analyses,

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'r and nuclear steam system performance computer i,sme . see h s**i -

Codes &c dock fvd nl A-J,7;; na p v.gm.LI.k inud *-(p y Oinervi mr Eiria=- ' f ; ; ; , , ,,

[,, y , , . . . 'n-e Supervisor, Nuclear Licensing - Engineering reports to th Nuclear Licensing Manager and is responsible or prep ing safety evaluations in support of change timely tices initias d by Nuclear Projects and for prepari updates f the Final Safety Analysis Report. e prepares correspond ce in response to NRC questions an concerns.

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-rd^=5 The Supervisor, N ear Licensing-Oper ions reports to the Nuclear Licensing Man er and is resp sible for preparing safety evaluations in upport of c nge notices by Nuclear Site Engineering and.for eparing timely updates of the Technical Specifications. pr ares the annual 10CFR50.59 reports to the NRC.

O E;; M :_r, S:'::: " ;' ' T ;:i _ f The Supervisor, Nuclear el Analysi reports to the Nuclear Fuel and Analysis Mana r and is res nsible for reactor (

core design and p nt transient ana is,ment nuclear fuel ]

engineering and de gn, control rod man and post -

irradiation exami tion of fuel elements and ntrol rods.

g} e : " : r , %_1. . . .,

The Super isor, Nuclear Fuels reports to the Nuc g;$r Fuel and Anal sis Manager and is responsible for tne p roc. ement of n ear fuel and core consumables, spent fuel dis sal, fue cost accounting and fuel related contracts. He is 1so re pensible for the preparation and dissemination f l

7_- _-

4' E$.

[jkser 1)

Preparing safety evaluations in accordance with 10CFR50.59, and preparing timely updates of the Final Safety Analysis Report and the. Technical Specification.

2)- Preparing the annual 10CFR50.59 reports.to the NRC.

Preparing environmental evaluations .as required by FSV I 3)

Administrative Procedures.

4) Researching the basis for NRC regulations, determining PSC's l

regulatory obligation, and coordinating the actions of other PSC personnel in response to PSC's regulatory obligations.

5) Identifying and- analyzing proposed and new.NRC regulations and preparing written correspondence to assist in fulfilling PSC's regulatory obligations, .for resolution ' of. nuclear licensing issues, and in response to NRC questions:and concerns.

interdivisional actions, programs, plans and

6) Coordinating procedures required for PSC to respond Eto NRC inquiries and written and vercal communications.

Identifying, administering, and controlling commitments

! 7) resulting from NRC initiatives.

9

_p

gygerf

1. Reactor core design and computerized plant transient analysis, nuclear fuel engineering and cesign, control rod management and post irradiation examination of fuel elements and control rods.
2. Procurement of nuclear fuel and core consumables, spent fuel disposal, fuel cost accounting and fuel related contracts.
3. Liaison and coordination between'PSC and Valley Pine Associates (VPA) concerning Fuel Fabrication Facility operations and maintenance.
4. Preparation and dissemination of industry and regulatory data reports and preparation of the divisional operating plans and capital expenditure budgets.
5. Coordination of division training.

I

UPDATED FSAR Revision 4 8.5-16

, ustry and regulatory data rep (t"ts and preparation of div ional Operating Plans and capital expenditure budg s.

h) - " i .. - 6 Co..u u vooroinitor The Nuclear 1 Contract Coordinator reports to e Nuclear Fuel and Analys Manager and is responsible fe monitoring Valley Pine Ass iates (VPA) fuel fabricat n operations.

Through his day-to- presence at VPA, he ovides liaison the Company and V concerning Fuel and coordination betw Fabrication Facility op ations and main nance.

vuru n uar h i)- u" A ~ L L.....my reports to the Nuclear The Nuclear Licensing Coor ha Licensing Manager and is respcq ble for researching the basis for NRC regulations, e ining PSC's regulatory obligations, and coordinati the actions of other PSC personnel in response to P 's regul cry obligations. The Nuclear Licensing Coordi or also iden fies and analyzes proposed and new NRC regulations, a prepares written correspondence to as st in fulfilling SC's regulatory obligations and th resolution of nuclear ensing issues.

":S u uo. m nC Cum u;o.ar D _

censing NRC Coordinator reports to t Nuclear &

The Nuclear Licensing nager and is responsible for coordination inter-division actions, programs, plans, and procedures re fred for PS o respond to NRC inquiries and written and v bal commu cations. The Nuclear Licensing NRC Coordinator so ide ifies, administers., and controls commitments result 1 f m NRC initiatives.

B.5.1.7l -Other Organizations. Quality Assurance Related Responsib111 ties a) Other PSC Organizations m k,;J. n ayo,s.M O

  • q ,llw a N N A

& Oth h ' PSC organizations, including N-:M W g =d Storat, 6 fan %

functions, are Jm&,

which are involved in quality-related required to comply with the FSV Quality Assurance Program requirements that apply to their activities. This includes providing access for Quality Assurance Division personnel to their facilities, personnel and records, as necessary for perf'ormance of quality-related assignments, b) Other Outside Organizations Work performed by other organizations outside PSCo must conform to PSCo Quality Assurance Program requirements as specified by procurement or contract documents.

UPCATED F5AR Revision 4 B.5-17 i

l B.S.2. Quality Assurance Programs B.S.2.1. Program Description The Quality Assurance Program for Plant Operations applies to those plant structures, systems and components which prevent or mitigate the consequences of postulated accidents which could cause undue risk to the health and safety of the public. The requirements of this program apply to activities which affect the safety-related functions of those structures, systems and components. Tables 1.4-1 and 1.4-2 identify the Class I and Safe Shutdown items covered by the QA Program. The systems, ' equipment and compatients are identified in more detail on special lists and drawings for safety-related equipment maintained by the Nuclear Engineering Division (see Subsection B.5.2.7). g-i,,s.~ r In addition to safety-related equipment, PSCo is also committed to apply portions of the QA Program for operation to the ffi re

@- l protection system, the plant security system, and packaging and

<r j transportation of radioactive materials. h//nede q O /npeemmmd.p. <M in A ** s. % u steuH :n Ds F u W :~s M k AnhJ.,~s*

l A designated identifier is added to the plant component data j bases to indicate those fire protection and security components t*1at l are not safety-related, but to which portions of the QA program l apply.

The QA Program for operation is structured with three levels:

first level, quality control and inspection; second level, quality assurance monitoring; and third level, quality assurance auditing. A comparison of the functions for operational QA with those for Engineering and Construction QA is shown in Table 8.5-3.

The Quality Assurance Program requires that the Quality Assurance Division identify and perform all quality assurance and/or quality control actions required to veri fy conformance of activities affecting quality to applicable requirements. Inspections of ._

maintenance (including mechanical, electrical and results) work is gIy. g performed by the Maintenance Quality Controlfgroupf which reports to the QA Services Manager. The arrangement assures the necessary freedom and. independence required to perform that function

. effectively. Biennial audits are employed to verify conformance of the Maintenance Quality Control group 3 activities to applicable requirements, u A/ac B.5.2.2. Procram Procedures Procedures describing the Quality Assurance Program are maintained in the FSV Administrative Procedures Manual. The "Q"-

series procedures serve as the Quality Assurance Manual and conform to the requirements of 10CFR50, Appendix B by providing an individual procedure to describe the FSV program for each of the 18 Criteria.

Compliance with the FSV Administrative Procedures Manual is mandatory for all personnel assigned to nuclear project activities.a M ame*as g

L M ; ., _ ' ::'n, .'...: ' u .. Detailed procedures are provided, e

i UPDATED FSAR l Revision 4 B.5-18 where required, by precedures subordinate to the FSV Administrative Procedures Manual (see Subsection B.5.2.10).

1 B.5!2.3. Progran Monitorino and Evaluation l

The adequacy of the Quality Assurance Program, its conformance to requirements., and the effectiveness of its implementation is the Vice President, Geowne*h*

@ monitored on a continuing basis by l Soedee46en, through the review of monthly reports, meetings, and audits performed by the Quality Assurance Division, audits performed by the Nuclear Facility Safety Committee, and audits performed by outside consultants. Additionally, a preplanned and documented management audit of the Quality Assurance Program is conducted under the Vice President, C' ::M : M __J--': cognizance biennially. ,

@ avceu. otuk a ' {

B.S.2.4. Design Controls Design controls are implemented in accordance with those parts of the FSV Administrative Procedures Manual governing PSCo Engineering ,

actions. A design control system is employed to authorize the creation and issuance of design documents and, to reflect as-built installations. Subcontracted design actions are controlled by procurement document provisions and follow-through verification actions. All design outputs, whether internal or external, are

.vviewed by the Quality Assurance Division to verify and assure the P inclusion of appropriate quality requirements. Biennial audits are employed to verify and document conformance of design controls to b applicable requirements.

B.S.2.5. Quality Assurance Standards, Codes and Regulatory Requirements Applicable requirements, codes and standards to which the Quality Assurance Program conforms are listed in Table B.5-4 B.5.2.6. Supply and Support Services Procurement documents developed to authorize the purchase of materials, parts, equipment or services are required include

@7 embat./ h N-applicable and appropriate quality requirements. All documents involving " ' ~ itemstare reviewed by the Quality Assurance to 4 k+ F Division to verify adequacy and appropriateness of the quality requirements. Inspections are performed at source or on the delivered items, or contractor actions are monitored by qualified PSCo personnel to veri fy conformance to the purchase order requirements.

B.5.2.7. FSV Safety-Related Items Safety-related items to which the Quality Assurance Program applies are those Plant systems, structures, equipment and components which are identified by the FSAR, and as detailed and supplemented by applicable P&I, IB and IC drawings, E and E-1203 schematic diagrams, the Cable Tab and SR-6-2 and SR-6-8 lists to include the following:

_ - _ ~ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -

% UBOAVED BSA@

Revision 4 8.5-19 a) Class I per FSAR Table 1.4-1.

b) Safe shutdown components per FSAR Table 1.4-2.

c) Alternate Cooling (Method (ACM) equipment.s c.) w.% ne ca enp .

2n k,/.sa. C+c AH G Q)

B.S.2.8. Trainino Procrams

'" '~ "'"'t " f t n t f ;: E d speciffs the cD' The MGe Training h ;;r=

for Plant training policies, prccedures and documentation methods management, operations, maintenance and technical personnel. The Program conforms to the applicable requirements of 10CFR19, 20, 50-Appendix B, 50-Appendix E, 55, 55-Appendix A, 73 (Ref. 5) and ANSI The training is N18.1-1971 (see Section B.5.19.14 and Table 8.5-4).Records documenting

() the responsibility of the Training e :1 ! ar.

the scope, objectives and met ods employed _for each training session conducted are maintained on file. 4pele.A g B 5.2.9. Quality Assurance Traini,nj In addition to training required for specific assignments, Plant supervisory and other key personnel responsible for operating or maintaining quality-related systems and equipment receive indoctrination and instruction in Quality Assurance. The training includes basic principles, 10CFR50 Appendix B, policy, and specific Quality Assurance procedures required to implement the QA Program.

The QA Operations Manager is responsible for g required

@) quality assurance training A ( Station personnel involved in nuclear activities, k pwJel /n, The QA Program requires that:

is h a) Indoctrination and training M provided to assure that personnel are instructed as to the purpose, scope and use of manuals, instructions. and erecedures which pertain to 3

' n -.l... equipment or activities *; and to assure that
  1. p W'l '3 b e-U %ej I

they are trained in the principles and techniques for the activity being performed.

Contractors and Suppliers are made responsible for b) developing and implementing training programs for their personnel in accordance with procurement document l requirements. The training programs must include QA

]

indoctrination and training on technical aspects included in .

their scope of work. Training required to qualify their I I

personnel to perform activities affecting quality must be conducted and documented. )

c) Training in PSco procedures is provided for Contractors who perform activities affecting quality, and for personnel who augment permanent PSCo Project staffs.

d) Personnel performing tasks for which certifications are required are so certified on the basis of the results of i

I

UPDATED FSAR Revision 4 8.5-20 written examinations or demonstration of required proficiencies. Retraining and requalification are performed as required.

e) Records required to provide evidence of training and certifications are retained and maintained on file. The records indicate training session content, attendees, dates and results of the training sessions.

0.5.2.10 Work procedures 4,houd if% GA kpm

'^ h activities ^1s performed in h All work involving ,

accordance with approved procedures that prescribe the work to be performed. The procedures also indicate, as appropriate, the requirements for the use of special tools or equipment, certification requirements for personnel or equipment, required environments, prerequisites, tests, inspections, data and documentation requirements.

8.5.2.11. FSAR Quality Assurance Program Changes The Manager, Quality Assurance is responsible for initiating p,ppropriate action to document and submit any identified revisions that may be required to assure that the FSAR accurately reflects the Quality Program specifics currently being applied. Those changes to the QA program that do not reduce commitments in the program may be made without prior NRC approval. However, those changes must be &

submitted to the NRC at least annually. Those changes that do reduce program commitments must be submitted to the NRC and be approved by the NRC before the changes may be implemented. The proposed

  1. ' M # Id (h revisions are submitted to the Vice President, c'-*- "--i--'-

for approval prior to submittal to the NRC for review and approval -

(Reference 20).

B.5.7. Design Controls 8.5.3.1. Description of Design Activities Design activities during the operational phase of the plant consist primarily of those actions required to change existing

~

designs as necessary to accommodate required modifications.

B.S.3.2. Desfon Control Responsibility All P3Co design actions are performed within, ard are the responsibility of, the Nuclear Engineering Division, and are governed by Nuclear Engineering Division procedures. Subcontracted design tasks are authorized by procurement documents, in which requirements are included for compliance by the subcontractor, that are compatible with Nuclear Engineering Division procedures.

Procurement document reviews by the Quality Assurance Division assures the inclusion of appropriate design control and other appropriate quality provisions. l I

l l

u ---- ---_----- - - - ---_._ _ _j

UFCATED FSAR Revision 4 R.5-21 B.5.3.3. Design Control System All design modifications designated for permanent change to FSV and to be performed by PSCo are authorized and controlled by use of a Change Notice system. This system assures that required reviews and approvals are obtained prior.to and on completien of the design task.

The Change Notice system- includes provisions to ensure that the required research is performed to identify applicable codes, standards, or other requirements and assure their inclusion in the generated design documents; that required design interface coordination and verifications occur; and that the required reviews and approvals are obtained prior to release and distribution of the Change Notice.

Ol'f we,.l 1 .m g ,l B.5.3.4. Design Control procedures Nuclear Engineering Division Procedures prescribe in detail the methods and control measures to be applied to control of design modifications. The Procedures include measures which provide assurance that:

a) Applicable regulatory requirements, FSAR design bases, codes, standards and quality requirements are correctly incorporated into the drawings, specifications and other controlling documents.

b) Materials, parts, equipment and processes are reviewed and

@. evaluated for compatibility and suitability for use in

' t 1 ..J structures, systems, equipment and componentsg A M I,J gAnaAp .

c) Design control measures required by 10CFR50, Appendix B, are applied to activities such as reactor physics; stress analysis; thermal and hydraulic design and analysis; accident analysis; material selection and compatibility evaluation; evaluation of accessibility for in-service inspection, maintenance and repair; delineation of acceptance criteria for inspections and tests.

of 4ese ikm- u.h ad t y #~ M tk 'm (f d) For ,

_.____ modifications the adequacy of the design will be checked by design review; alternate analytical methods; or performance of tests.

e) Where performance test programs are used instead of other verification or checking process, to verify adequacy of a particular design or design feature, such testing shall be controlled to ensure that the test results are representative and directly support the design or design features.

f) Individuals or groups verifying adequacy of design are not those who performed or supervised the original design.

in asJi, g) L .' - ., . . . ad besign changes, s /. ., 4, .ind emergency

@ changes _ "" ---- : f n,  :' nd ?:-- : ""--"-4+" -4 E-

. . m

UPDATED FSAR-Revision 4-B.5 i 4, L cmkottdi k en Ampm

---'--'g-- '

j

nz; are reviewed and approved by'the same organizations that performed the original design or by organizations duly designated by PSCo having the necessary

, technical' capabilities for the particular- type of work involved.

e i h) Safety review or analysis is performed and documented.

i) For projects or changes that have an effect on the environment an environmental review or evaluation is performed and documented (Ref. 21).

B.S.3.5. Verification of Design  ;

i Design outputs are subjected to a design verification process performed by individuals other than the. original designer and other  ;

than the original designer's supervisor. If appropriate, the services of qualified consultants are employed.

I B.5.3.6. Desion Quality Assurance Provisions .

3

@ ;__.. _. ..lb.'b "

q

.3 _ b bh " "" "._ & M D *

[d/wA 4 . whe//ed4 >

. , _ _ _ _ _ . - ,, 3 are required .by Nuclear Engineering Division procedures to include applicable quality assurance requirements including- acceptance

($ criteria.d" ' t - '":d design outputs are reviewed by the Quality '

Assurance Division to verify the inclusion of appropriate quality.  ;

requirements, i B.5.3.7. Design Document Changes The Change Notice System .is employed to authorize permanent changes to new or existing design documents and requires the same processing and approvals as required for original design documents or changes processed by PSCo.

B.5.3,8. Materials, parts and Component Selections

_ [j Nuclear Engineering Division procedures require the selection of r - 's materi_als, parts' and components required for 4.ada';  :' r d  !

6ad 'S M J modification applications

  • to conform to requirements equal to, or Qeby*f more stringent than, the original design requirements for the intended FSV application. j B.5.3.9. Identification and Processing of Design Errors Any design errors identified after release of the Change Notice package are corrected by reissuing the affected Change Notice and affected design documents. In addition to correcting a design error, corrective action for significant or recurring design errors also includes determining the cause and instituting changes in'the design process or procedures to prevent similiar types of errors from recurring.

UPDATED FSAR Revision 4 B.5-23 B.5.4. Procurement Document Control B.5.4.1. Description of Procurement Activity The FSV Administrative Procedures Manual identifies quality requirements applicable to procurement actions and provides guidance in selection and inclusion of appropriate requirements on Purchase Requisitions. Quality requirements which are appropriate, but not included in the technical documents referenced by or included in the Purchase Requisition package, are added to the Purchase Requisition by use of Standard Quality Assurance Clauses specified by the Nuclear Engineering Division.

B.5.4.2. Purchase Requisition Review

"' ' ' afik aebsHdla #s dA h*r ~

Purchase Requisitions ^are reviewed by the Quality

@ Assurance Division to verify the adequacy and appropriateness of specified quality requirements. The reviews are performed to assure, as applicable, that:

a) Technical requirements are adeouately defined and include acceptance and rejection criteria.

b) The specific 10CFR50, Appendix B, requirements are identified which must be described in the supplier's QA program, c) The supplier's QA program is to be reviewed and approved by purchaser in advance.

d) Procurement documents:

1) Contain or reference identification and definition of the design basis -te'chnical requirements.
2) Identify the documentation to be prepared, and the requirements for submittal for review and approval, retention, or submittal to purchaser for permanent reccrd.
3) Contain the purchaser's right of access to supplier's facilities and records for source inspection and audits.

=

4) Provide for spare or replacement parts of M A+ maassagi structures, systems anc components + to be hhstlal 63 d4 kay a subject to controls at least equivalent to those used for the original equipment.
5) Provide for any required hold, witness or source inspection points.

l l

r m________________._ _ _ . _ _ _ _ . _ _

  • J UPDATED FSAR Revision 4 l B.5-24 l 1

l B.5.4.3. Purchase Order Review i j Purchase Orders are prepared by the M/en*da m+u

'-""- 3eme,,J Aphm/

i negotiation / coordination with the potential __suppiier hasrt when been ( ;  !

@ completed. M t - '"" Purchase Ordersg are reviewed and approvedl <* ** dd 4 by the Quality Assurance Division to assure that the quality AT*'

provisions, as approved on the Purchase Requisition, have not been compromised. A copy of the Purchase Order is retained for record purposes. i B.5.4.4. purchase Order Changes g Any revisionsf to 2

ne se,. isp, sue  % , r.,u. ,Zn___j d ...'..,  % *fPurchase hy~~f Orders require the same processing and approvals as the original document.

B.5.5. Instruction. Procedures, and Drawings B.5.5.1. FSV Procedures System The FSV Administrative Procedures Manual establishes the requirements for procedures affecting personnel assigned to work on nuclear project activities. Requirements are included for the procedure formats, content, authorized proceaure types, reviews, approvals, distribution, the event of conflict. The FSVchange controls,Procedures Administrative revisions and precedence Manual and in[,,4.<hb (f) subordinate procedures involving ._'_ , n'n _d activitiestshall be W %"yaf reviewed and concurred with by the Quality Assurance Division to verify conformance to applicable quality requirements. The procedure g system conforms to the intent of "..,_M ANSI N18.7 (see Section B.5.19.15). %; Guide %33 (Ref.

7) and Figure B.5-3 shows procedures and groups of procedures, along with their overall relationships to the licensing documents. Further explanation of the operating procedures and emergency procedures is given in Section 12.3.

B.5.5.2. Work Control Procedures Each Change' Notice package authorizing a modification or selected non-routine maintenance to the Plant, or any part thereof, requires the development of a Controlled Work Procedure. The Controlled Work Procedure details and sequences the work operations required to clearly instruct installation personnel how to proceed. Inspection points are included and appropriate acceptance criteria are either specified or referenced. The procedures require review by the Quality Assurance Division to verify the appropriateness of quality provisions prior to their release.

(9 All i s .J .._2 maintenance, inspection and surveillance activities are performed to procedures authorized under controls imposed by the FSV Administrative Procedures Manual.

N_______-___________ _

T.

UPDATED FSAR Revision 4 B.5-25 B.5.5.3. Technical Documents Controls assuring the conformance of design documents to applicable requirements, appropriate reviews and approvals are addressed by Section B.5.3.

B.S.6. Document Control The description of dec cent controls for FSV documents subject to control is provided by Subsections 5.5.2, 8.5.3, B.S.4 and B.5.5.

B.5.7. Control of Purchased Naterial, Equipment, and Services B.S.7.1. Supolier Selection A

m Procedures require the evaluation of potential suopliers of

    • : ' t i n.d items *before the purchase order is approved. The
  1. %* evaluations are performed by Quality Assurance Division personnel or by consultants. The evaluations serve to establish whether the supplier is capable of performing to the requirements of the pending procurement by reviewing records of recent past performance or by performing an onsite survey at the supolier's facility, or as specified in Section B.5.19.13. Such evaluations are documented and retained for record purposes. .A listing is maintained of approved suppliers.

B.5.7.2. Supplier Control Procurement documents identi fy any required hold, witness or inspection points, appropriate for the procurement, that are to be performed by the buyer. Quality Assurance personnel may perform monitoring actions or audits during the supplier's period of performance, if such action is deemed appropriate. Any such actions require the preparation and use of prescribed instructions or checklists, and documentation of the results of the action. Such actions are normally employed if verification of the conformance of important characteristics or tests cannot be accomplished after delivery of the item to the plant.

B.S.7.3. Receiving Inspection

@ FSV Administrative Procedures require the performance of a

^N receiving inspection by the Quality Assurance Division for all e.bde/43 A -* t M m d itemsr The inspection involves the examination of the bl 4"p*~- delivered item (s), and documents specified for delivery by the Purchase Order, to the extent necessary to determine that requirements of the Purchase Order have been satisfied. Pre prepared checklists are employed to supplement Receiving Report checks, when appropriate. Nonconforming items are documented and processed on nonconformance reports. Physical and Chemical Properties Reports and other technical documents are reviewed by qualified personnel to l verify conformance to specified requirements.

i

,_u

UPDATED FSAR Revision 4 B.5-26 B.5.8. Identification of Materials, Parts, and Components B.5.8.1.

Existing Items All installed materials, parts and components were identified by the responsible contractors and accepted prior to initiation of plant operations.

B.5.8.2. Modification and Replacement Items usad Q h o n*r=~-

(3) All ' ' 1., .. L -.i items ^ procured as spares or for modification use'are identified on receipt by tagging or other appropriate method by which traceability to the purchase order is maintained. Change Notice packages specify the identification designations for any assemblies created by the modification. A copy of the identification i in h tagorDirectChargeRequisitionidentifyingtheitemf*s_

the maintenance or modification work records package. ta= *included Ae ,w B.5.9. Control of Special proecesses B.5.9.1. Procedures Procedures require that special processes be performed in accordance with qualified procedures by qualified personnel using qualified equipment. Procedures developed to satisfy needs identified to date for maintenance and modification activities are Quality Assurance Inspection, Welding and contained in the Maintenance Manuals. The procedures apply to welding, post-weld heat treat, cleaning, weld filler material control and nondestructive examinations: When required, procedures and equipment are qualified to requirements specified by applicable codes, standards and specifications. Nondestructive examination personnel are qualified to the requirements of SNT-TC-1A, American Society for Nondestructive Testing Recommended Practices (Ref. 8).

B.5.9.2. Records A master file of qualified welder documents is maintained by the Quality Assurance Division. Nondestructive examination qualification ~s records are maintained by the Quality Assurance Division.

B.5.10. Inspection l B.5.10.1. Maintenance Inspections l

l Inspections to verify the conformance of work performed by the

@ Q toMaintenance Department applicable (including requirements is mechanical, performed byelectrical and results)

Maintenance Quality srlferO/Ac Control # personnel _ " - '" "' :::':- ' ' . "2 c : :: U '^y c__ m e.--- '- -

who report;( to the QA Services Manager. The group is assured the necessary independence and freedom to perform g their assigned tasks. All s.hfanyweeSewed inspections *are performed to approved written procedures. Inspection personnel are qualified to the requirements of applicable regulatory requirements. I dh;I5 upktid +k b A*T

_ ~~

UPDATED FSAR Revision 4 B.5-27 B.5.10.2. Inspections Other Than Maintenance Procedures require that all inspections, other than maintenance type inspections, are performed by the QA/QC unit of the Quality Assurance Division. All personnel are qualified as required by applicable regulatory requirements. Inspections are' performed to written requirements, reviewed and approved by qualified personnel.

The documents include standardized forms, procurement document instructions, receiving report checklists, pre prepared checklists contained in the Quality Control Inspection Manual, or checklists included in work control or operations procedures. The checklists are required to provide for, as appropriate:

a) Identification of the characteristics to be inspected, b) Identification of personnel responsible for performing the inspection, c) Acceptance-rejection criteria, d) Description of the method of inspection, e) Evidence of completion and verification of the inspection or test operation, f) Signature or stamp of the inspector or data recorder, and the results of the inspection operation, g) Reference to use of applicable drawings or specifications, when required to perform the inspection.

B.5.11. Test Control B.S.11.1. Test Activities Testing activities are conducted on a continuing basis to satisfy Technical Specification requirements and, as appropriate, following modifications when specified by the Change Notice package,  !

or following certain maintenance activities.

B.5.11.2. Test Procedures All testing is performed in accordance with approved procedures.

The procedures are required to incorporate or reference:

a) The requirements and acceptance limits contained in the applicable design or procurement documents, b) Instructions for performing the test, c) Test prerequisites such as:

1) Instrumentation calibration requirements
2) Equipment requirements

UPDATED FSAR Revision 4 B.5-28

3) Personnel qualification, certification or License '

requirements

' 4) Completeness of item to be tested

5) Requirements pertaining .to environmental or other conditions
6) Data documentation requirements d) Inspections or inspection hold points, e) Acceptance or rejections criteria, f) Method for documenting or recording test data and results, g) Provisions for indication by a qualified individual as to acceptability of the evaluated results.

B.S.12. Control of Measurino and Test Equipment B.5.12.1. Identification of Items Requirino Calibration Items requiring calibration are specified by the . Technical Specification or by the FSV Administrative Procedures Manual. Each ,

h i trument

' n, 2tool, measuring device, and associated standard used w kh Vb g yI y up,de d program items is uniquely identified and placed on a scheduled g i+ of inspection,

)

test and recalibration.

B.5.12.2. Calibration Procedures Calibration and/or maintenance is performed to procedures provided by the item manufacturer; or when not available or applicable, to procedures developed and approved by the department responsible for the specific calibrations. Calibration procedures are required to provide the calibration technique to be employed, specific standards required, labeling or tagging requirements, provisions for recording calibration data and identification of the individual verifying the acceptability of the calibration results.

B.5.12.3. Traceability of Standards Procedures authorize the use of secondary and transfer standards traceable to the National Bureau of Standards; and, where not available, the use of standards not traceable to the National Bureau of Standards if the basis of calibration is otherwise acceptably documented by qualified individuals.

B.5.12.4. Calibration Accuracy g te.h,nd Q ha. c4 4*pm

@@ Calibration data geAle, for

  • p---2 " instruments ^ identify the accuracy requirements and the specific equipment or standard used for its calibration. Monitoring of calibration records verifies that instruments used for calibrations display sufficiently greater accuracy than the instruments being calibrated to assure compliance

UPDATED FSAR Revision 4 B.5-29 with accuracy requirements. Where instruments are found to be out of calibration by more than the allowable tolerances, an investigation is required to determine the effect, if any, on the.' validity of previously made measurements or test data.

B.S.13. Handling, Storage, and Shipping

-The FSV Administrative Procedures Manual includes requirements Qjg] for the necessary controls during procurement, receiving, handling, g storing maintenance and issuance of " ' n, - _ nj spares, y ;B " replacements, modification katerials and* deems to prevent their

[ deterioration. Quality Assurance monitoring actions serve to verify compliance with the procedures.

B.5.14. Inspection, Test, and C;,erating Status B.5.14.1. Status Identification Systems The FSV Administrative Procedures Manual establishes administratively, and operations and maintenance procedures establish specifically, the requirements for tagging, logging and displaying the status of plant equipment and systems. The system of status tagging serves to prevent operation or unauthorized adjustments which could endanger the safety of personnel or invalidate the results of tests already performed.

B.5.14.2. Status Identification of Materials, parts, Components and Equipment i

Controls for identification of parts, components and equipment-are prescribed in the detailed procedures for those activities described by Subsections B.5.8, B.5.9, B.5.10, B.S.12 and B.5.15.

B.5.14.3. procedure Requirements for Operational Items The FSV Administrative Procedures Manual requires that the affected equipment or item (s) withdrawn from operational status be tagged; and also that the associated power supplies, starters, switches and controls on the main control panel (s) be tagged to warn

^

against operation. If appropriate, the power supplies are disconnected and so identified, to prevent inadvertent operation.

The tagging is controlled by the Shift Supervisor by requiring that the serially numoered Clearance Cards, obstined only from the Control Room, be used for all tagging purposes. Records maintained in the Control Room enable the Reactor Operators and Shift Supervisor to determine, at any time, what equipment is currently on Clearance Cards.

Persons requiring clearances to perform work are required to sign the clearance before starting work. On completion of the work, the Shift Supervisor signs the clearance to acknowledge. the work completion and removal of the status tags. Transfers of r9sponsibilities for clearances from one individual to another arz documented by written sign-offs. Work conformance to applicable requirements is verified by the Quality Assurance Division.

I 2 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _-

UPDATED FSAR Revision 4 B 5-30 In compliance with NUREG-0737 (See Ref. 18), the operating condition / position of critical equipment is independently verified upon return to service following .2, ..s.

clearance conditions. " ' ' ;'

a

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B.5.16.2. Quality Trends Analysis and Reporting The Quality Assurance Division is responsible for accumulation of data and for the use of appropriate analytical techniques to identify and report FSV quality trends to Plant management. Data

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Sferf*8 FSV Administrative procedures require independent verification that all clearances are properly placed prior toThe beginning work and Shift Supervisor is properly removed when the work is completed.

i responsible for authorization of testing to demonstrate functional acceptability of equipment following maintenance, acknowledging test results and returning the equipment to service.

B.5.15.1 Documenting Nonconforming Items Srcre #9 requires the The FSV administrative Procedures Manual rework, are nonconformances, other than maintenance documented on nonconformance reports. Rework as afrom resulta of preventive or corrective maintenance may result nonconformance report but is routinely accomplished procedures.

in accordance with maintenance implementing Nonconforming items are tagged and, if practical, the items are placed in a segregated area pending processing and dispositioning of the report, f,,fe r f#/0 B.5.15.2 Processino of Nonconforming Items Nonconforming material processing assures that "use-as-is" or " repair" dispositions, whether proposed by Maintenance or Engineering, are properly evaluated as well as independently verified by Engineering and receive cocumented approvals by Engineering and Quality Assurance.

This practice also assures the accomplishment of any prescribed inspections to verify conformance

" Return of repairs to vendor", to

" scrap" the prescribed dispositions.

or " rework" dispositions are accomplished in accordance with administrative procedures.

B.5.16.1 FSV Corrective Action Systems Lerf //

requires that The FSV Administrative Procedures Manual such as failures, quality, conditions adverse to deficiencies, deviations, defective material malfunctions, or equipment, and nonconformances are promptly identified and corrected. For significant conditions adverse to quality, root cause must be determined and corrective recurrence. The actions provided to preclude Administrative Procedures Manual describes the methods that are utilized by the Nuclear Operations Divisions, including adverse Quality Assurance Division, to identify conditions defined in departmental to cua!ity. These methods are procecures shich provide for prompt identification and resolution of conditions adverse to quality or safety.

- ~- - ~ - ~ - - - - - - _ _ _ _ _ __

7 ___ _ __

UPDATED FSAR Revision 4-B.5 n t k %ft: m 9 .J. cca,e 6 employed includes nonconformance reports (NCRs),6 Corrective Action i 4pk amaneses (CARS), monitoring and audit reports, and NRC I&E reports.

The reports to management serve to indicate where trends are-improving, indicating successful corrective actions, and where trends indicate deterioration and the need for additional or more effective efforts.

B.5.16.3. Reporting Any person identifying what may be an apparent violation of NRC regulations or significant potential safety . hazard may document the condition and promptly submit a report to the appropriate Department.

Such reports may take the form of Station Service Requests, Action Requests, or other nonconformance reports. The' reports are promptly-evaluated and appropriate action is initiated. A report may be made to the NRC if the condition is deemed reportable in accordance with the Regulations. In any case, the 'necessary corrective ' action is documented and followed up until completed.

B.S.17. Records B.5.17.1. FSV Operational Records System The FSV Administrative Procedures Manual requires that record requirements be established when procurement documents, work control, test and inspection procedures 'are developed and approved. QA reviews the documents to verify the adequacy and appropriateness of record provisions.

B.S.17.2. Records Content  ;

Except in the case of record documents such as recorder charts,

' computer printouts, radiographs and similar documents, records generated and retained to provide objective evidence of conformance to specified requirements are required to contain the following information when applicable:

I a) A description of the type of observation, b) Evidence of completing and verifying an inspection, or test operation.

c) The date and results of the inspection or test.

I d) Information related to conditions adverse to quality. -

e) Inspector or data recorder identification. 1 l

f) . Evidence as 'co the acceptability of the results.

B.5.17.3. Records Accumulation, Identification and Retention Organizations generating records are responsible for verifying records completeness and accuracy, and for accumulation, organization, identification and transmittal to the Records Center in j l

_2- _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ -

"PDATED FSAR w Aston 4 _f A lea d o Ach k Ss),e lle mm us & Unkin b d*si accordance with e remen s spec fie b strative Procedures Manual. & Received records are acknowledged, logged, indexed and the documents filed. Records Center controls. assure records' security from loss or deter ~ oration and assure retrievability of retained documents for their prescribed retention periods.

B.S.18. Audits and Monitoring Activities B.5.18.1. FSV Audit and Monitoring System The FSV Administrative procedures Manual requires the implementation of a comprehensive system of audits of all activities, procedures and instructions affecting quality of the Plant and its performance, including key suppliers and contractors, at least once each two years. The system of formal audits is supplemented by monitoring actions conducted on a continuing basis to verify conformance of on going work activities to applicable requirements. The monitoring system provides greater flexibility and earlier identification of situations which may be adverse to quality.

Monitoring results are evaluated and considered when developing audit plans and checklists.

B.5.18.2. Audits Audits are performed by the Quality Assurance Division using pre- '

established procedures and checklists and are conducted by trained  :

lead auditors with no direct responsibility for the areas audited.

[ Audits are also performed by,the Nuclear Facility Safety Committee in accordance with Technical) Specification requirements (also see Section 12.5.3.3). @ Ju -u w ne a

ug Auditors and Lead Auditors are selected and qualified in accordance with ANSI N45.2.23-1978 (Refs. 12, 13 and 17).

B.5.18.3. Audit Results Audits are formally documented and distributed to affected i O management, including the Vice President, fuleekhkhmmaatsm8494m. *

  • Audit findings-are documented and reviewed with managers responsible for initiation of corrective action. Processing and follow through on any required corrective actions is accomplished through the corrective action system described by Subsection B.5.16. Follow-up l audits are performed as deemed appropriate for evaluation of  !

completed QA audits and QA monitoring results.

B.5.18.4. Manitoring Activities Quality Assurance personnel monitor compliance with the requirements of the documents which control plant operation, such as the NRC licenses, FSAR, Technical Specifications, Administrative i Procedures Manual, Operating Procedures, and other controlling documents. The monitoring functions are defined in the Quality {

Assurance Monitoring Manual which describes the pre planned instructions and checklists used in CA monitoring procedures.

UPDATED FSAR Revision 4 B.5-33 Conditions adverse to quality identified by monitoring actions are processed by the corrective action system as described by Subsection B.5.16. Formal audit type summary reports are not issued for each monitoring action performed.

B.5.19. Implementation, Wash-1283, -1284, and -1309 Except as modified in the sections which follow, the PSCo QA Program for Plant Operations utilizes the guidance provided by .NRC publications WASH-1283 (5-24-74), WASH-1284.(10-26-73) and WASH-1309 (5-10-74) (" rainbow" series) to the extent that these_ documents _Qn

@ provide practical guidelines for n'r, . . .ad activities' occurring Q A,p during the operational phase of plant life-(Refs. 9,10 and 11).

The existing Operational QA Program does not address all of the detailed requirements set forth by the " rainbow books", considering the fact that information normally developed in the design and construction phase for present-day plants was not readily available for Fort St.'Vrain Unit No. 1.

With respect to the applicability of the " rainbow books" and the associated standards, it is impracticable to apply all of the requirements sat forth by these documents to a plant for which important, and (in some respects) irreversible commitments were made several years before the current requirements were formulated. In this respect, the following sections summarize the stops and applicability of the various standards as well as specific exceptions that will be taken in the application of the guidance of these documents to the Operational QA Program at Fort St. Vrain (see Table B.5-4).

B.5.19.1. ANSI N45,2-1971 Quality Assurance Program Requirements for Nuclear power plants ,

(a) Scope and Applicability The guidance provided by this standard and the associated Regulatory Guide 1.28 shall be applied in the Operational QA Program to those activities affecting the ""+r"rd aspects of operation of Fort St: Vrain Unit No. 1 3 Gend Ly A o P~p .

Where codes or standards are referenced, or are in:orporated into the standard by reference, which are in conflict with original

' design commitments as set forth in the FSAR, the FSAR commitments shall govern. Later revisions of applicable codr:s and standards may be invoked specifically by the design requirements where deemed appropriate, consistent with the overall commitment to maintain the plant in an " equal to or better than" original condition.

mi____.________________________

UPDATED FSAR Reuision 4 B.5-34 (b) Soecific Exceptions Quality Assurance Program (Section 2)

The Quality Assurance Program describes the extent to which ANSI and other recognized standards will be recognized and applied to Fort St. Vrain Unit No. 1.

Inspection (Sectio _n 11)

First Level inspection of routine maintenance activities has h been assigned to QA personnel in Mo4etow. . . . . ;_.: ity * #o [D Genteel . Inspections for work other than routine maintenance, including activities'which involve welding or nondestructive testing, are performed by QA/QC personnel.

In any case, the program requires that inspection activities to verify quality of work shall be performed by persons other than those who performed the activity being inspected.

Handling, Storage and Shipping (Section 14)

For the most part, all items purchased for uso during the 1 operation of Fort St. Vrain Unit No. I will be stored indoors under normal (heated) warehouse conditions. For these items in general, no specific storage requirements are '

necessary. Those items which require special consideration are handled on an individual basis and requirements are n '

established as a part of the procurement document requirements.

B.5.19.2. ANSI N45.2.1-1973 Cleaning of Fluid Systems and l

Associated Components During the Construction Phase of l

Nuclear Power Plants (a) Scope and General Applicability Insofar as the requirements of N45.2,' are directed primarily at contractor activity during construction, this standard cannot be applied directly to operational requirements.

The guidance provided by this standard and the associated ( g-g,y g Regulatory Guide 1.37 f. hall be applie_d to sahed maintenance,W p bd' repair, and modification activitiesfoccurring during the opera'tional A J phase of Fort St. Vrain Unit No. 1 to the extent that such activities are camparable in nature and degree to similar activities occurring during the design and i: construction phase.

Where the scope of a*(C -itM plant modification,

@ maintenance or repair work is such as to make the guidelin:s contained in this standard practicable, the work shall be performed with consideration to the guidance provided.

Where coder, standards and specific design requirements are referenced, or are 11corporated into the '.tandard by reference, wqich are in conflict with original design commf eents as set forth in the L -___ _ _ - ___-__ --__ - _--____ ____- _ -________ a ______ __________-____-______-

Up0ATED FSAR Revision 4 B.5-35 FSAR, the FSAR commitments shall govern. Later revisions of applicable codes and standards may be invoked specifically by the design requirements where deemed appropriate, consistent with the overall commitment to maintain the plant in an " equal to or better than" original condition.

(b) Specific Exceptions General Requirements (Section 2)

Cleaning requirements for almost all maintenance, repair and modification work will be included as a part of the overall job requirements. In this respect, detailed cleaning procedures will not be prepared as separate documents, unless specified. Necessary requirements, consistent with the scope of the work, will be included as a part of the overall work instructions.

Criteria for Cleaning (3ection 3)

For cleanliness classifications where the scope of plant modification work is such as to make application of the guidance provided by Section 3 of this standard practicable, the cleanliness classifications and requirements thereof shall be evaluated and applied, as appropriate, as a part of the overall work requirements. For most modification or maintenance work, however, involving only small portions or individual components of larger systems, it is not considered practicable to conduct ASTM E11-70 cleanliness tests. Appropriate cleanliness will be maintained during the work and appropriate preoperational flushing will be conducted, consistent with the scope of the work performed and the original design requirements.

It should be noted that the cleanliness requirements and tests for cleanliness as specified by Classes A, B, C and D are not applicable directly to gas cooled reactors and primary coolant systems especially with reference to helium systems. In this respect, cleanliness requirements necessarily must b4e dictated by specific design requirements rather than the general criteria set forth by N45.2.1, Section 3. General cleanliness requirements will be defined by system and included in appropriate procedures by reference.

Maintenance of Installation Cleanliness (Section 6) i l

Access control requirements are established in accordance l with N45.2.3. Access control inte radiation areas is l contiolled by radiation work permits. Cleanroom requirements and associated access control are established i as dictated by specific job requirements.

l  !

l l l l

UPDATED FSAR R; vision 4 B.5-36 Pre-Operational Cleaning (Section 7)

For work which requires specific cleanliness levels, acceptance criteria for flushing shall be established as a part .of the overall work requirements. Most modifications and maintenance work will involve only small portions of various systems and will- be done under controlled conditions. As such, requirements for extensive cleaning and flushing will not be required.

Records (Section 9)

For normal repair, maintenance and modification work, cleaning requirements will be performed as a normal part of the overall work. Applicable rec 9rds will be retained with the overall work records. Typically, such records as personnel qualification, calibration records, etc., are kept in files and will not be included as a part of specific job work records.

B.5.19.3. ANSI N45.2.2-1972 Packaging, Shipping, Receivina t Storage and Handling of Items for Nuclear power Plants (Ouring the Construction phase)

(a) Scope and Applicability ,

The guidance provided by this standard shall be applied to those packaging, shipping, receiving, and handling c=&.tkli g>Lc

{j} storage activities associated with ::'::; :':::f itemst to the extent that\;{[Avr=w such activities are comparable in nature and degree to similar activities occurring during the construction phase.

Where codes, standards and specific design requirements are referenced, or are incorporated into the standard by reference, which are in conflict with original design commitments as set forth in the FSAR, the FSAR commitments shall govern. Later revisions of applicable codes and standards may be invoked specifically by the design requirements where deemed appropriate, consistent with the overall commitment to maintain the plant in an " equal to or better than" originrl condition.

(b) Specific Exceptions The Operational QA Program is not structured to meet the

(=) general requirements set forth by this standard. The program is y,9, ng yl A, structured to identify ::' -, . J i _ _ f equipment'and to associate that 44 rdf **-

equipment with the various levels set forth by this standard. This classification, however, cannot be applied directly to individual spare parts or subassemblies of the parent equipment. Due to difference in volume, complexity, .inspectability, etc., the packaging, shipping, handling and storage requirements of spare parts and subassemblies will necessarily be different from the requirements which may be imposed on the entire component or piece of parent equipment.

hmmmm___ _ _ _ _ _ _ _ _ _ _ . _ ___

UPDATED FSAR Revision 4 B.5-37 The majority of items purchased for an operating plant consist of components, subassemblies and individual spare parts which could be used..in~a multitude of different applications. Such items are; purchased to the highest requirement of intended use, but it is not considered practicable to pre-classify or categorize individual

_ parts by levels.as req'uired by Section 2.7' of this- standard. The volume, and characteristics of purchases during the operational phase'

' differ significantly from those purchases made during the design and

. construction phase, and storage facilities are considerably different. Almost all parts and components purchased in the operational phase will be : stored indoors under normal warehouse conditions. Items that require special. storage protection weasures will be; identified as a part of. the purchasing document review requirements. Items that must be stored outdoors (equivalent- of Level 0) or items that. must be stored in covered but unheated.

conditions (equivalent of Level C) will be evaluated on an' individual case basis. Shipping and packaging ' requirements. for such items likewise will .be handled .in the purchase order. documents,- as appropriate.

B.S.19.4. ANSI N45.2.3-1973 Housekeeping Ouring the Construction phase of Nuclear power Plants (a) Scope'and General Applicability The guidance provided by this standard and.the associated Regulatory Guide 1.39 for control of housekeeping requirements shall be applied to work conditions and other applicable activities which could affect qualit.y of important operational aspects of Fort St.

Vrain Unit No. 1, to the extent that such activities are comparable in nature and degree to similar activities occurring during the design and construction phase.

Where codes, standards and specific design requirements are referenced, or are incorporated into the standard by reference, which are in conflict w th original design commitments as set forth in the FSAR, the FSAR commitments shall govern. Later revisions of applicable codes and standards may be invoked specifically by the design requirements where deemed appropriate, consistent with. the overall commitment to maintain the plant in an " equal to or better than" original condition.

(a) Specific Exceptions General Requirements (Section 2)

The specified zone requirements contained in Section 2.1 generally will be adhered to, with the exception that' the reactor building generally will be controlled per Zone III-requirements except for material accountability. There will be no specific material accountability for reactor building access unlest specifically required by Health Physics.

l b n? b

m.

r UPDATED'FSAR Revision 4-B.5-38 ,

y Requirements (Section 3) s Fire protection and prevention equipment will be provided.as set forth in the FSAR and as supplemented by. requirements-settforth~by-response to NRC Branch Technical Position 9.5-1

.(Refs. 14 and 15). General housekeeping requirements are-set' forth by various' zone designations. Specific requirements will.be included as a part of the overall work instructions, as appropriate.

B.5.19.5. ANSI N45.2.4-1972 Installation, Inspection and Testing Requirements for Instrumentation and Electric Equipment During the Construction Phase of Nuclear Power Generating Stations (a) . Scope and Applicability This ' standard was written for construction efforts of nuclear plants and, as such, the requirements set forth and the feasibility, both from an economical viewpoint and a practical viewpoint, _ are based on initial construction. As such, implementation of all the requirements of this standard for operating plants, considering the scale of plant modification v.ersus initial construction, is not practicable.

(s% Cu:h so)

@- The guidance provided by this standard and the associated RegulatoryGuide1.30)shallbeappliedto installation, inspection 0 and. testing of electrical equipment and systems associated with (3) onsite ufa*y=h modification work occurring during the operational- phase of Fort St. Vrain Unit No. 1, to the extent that such work is comparable in nature and degree to. similar work occurring during the design and construction phase.

Where codes or standards are referenced, or are incorporated into the standard by reference, which are.in conflict with original design commitments as set forth in the FSAR, the codes and standards may be invoked specifically by the design requirements where deemed appropriate, consistent with the overall commitment to maintain the plant in an " equal to or better than" original condition.

Where specific design requirements included in this standard or referenced codes and standards are in conflict with original design requirements set forth in the FSAR and other appropriate

. design documents, the original design requirements shall govern.

(b) Specific Exceptions Definitions (Section 1.4) i The definition of Class I and Class IE electrical equipment set forth by this standard does not conform to the equipment categories of Fort St. Vrain Unit No. 1.

Essential electrical items and Class I equipment lists upon which the Operational QA Program is based are described in

. _ _ . ____ _ _ _ . _ _ _ - ______----____-____-__n _ _ _ _ _ _ -

UPDATED FSAR Revision 4 B.5-39 the FSAR, and the scope and applicability of this standard necessarily shall be limited to these defined areas.

Procedures and Instructions (Section 2.3) i Appropriate requirements for installation, inspection and tests will be set forth by job specifications and work instructions developed as a part of the modification work package. It is not intended that separate procedures be established which specifically address the various t.reas of this standard. However, in the development of the work package, consideration will be given to the areas outlined in Section 2.3, as appropriate.

physical and Chemical Tests (Section 5.2.3)

Application of the 9/ dance provided by the additional codes and standards listed in Appendix B will be considered to the extent that such codes and standards provide useful and practicable guidance for the work being performed.

Commitment to the guidarce of N45.2.4 shall not include commitment to the guidance'of referenced standards.

Installation, Verification and Test (Sections 4.0, 5.0 and 6.0)

The requirements for installation and the associated inspections, verifications and tests are included in the work instructions as appropriate, consistent with the scope of the work and the importance to quality. In the development of the work instructions, consideration will be given to the guidance provided by Sections 4.0, 5.0 and 6.0 of this standard, .and appropriate requirements will be incorporated into the instructions. It is not intended that separate procedures be established which specifically address all of the areas referenced.

Applicable Codes, Standards and Guides (Section 9.0)

See Regulatory Guide 1.30 (Safety Guide 30).

B.5.19.6. ANSI N45.2.5-1974 Supplementary Quality Assurance Requirements for Installation, Inspection and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear power plants (a) Scope and Applicability This standard was written for construction efforts of nuclear plants and, as such, the requir.ements set forth and the feasibility, both from an economical viewpoint and a practical viewpoint, are based on the construction situation. As such, implementation of all the requirements of this standard for operating plants, considering the scale of plant modification versus initial construction, is not practicable.

(

_ _ - _ - _ _ _ _ _ _ - _ _ _ - _ r~ '

UPDATED FSAR Revision 4 B.5-40 The guidance provided by this standard and the associated S/,,pd h Regulatory Guide 1.94 shall be applied to activitiest involving A p . p

':t ,_ L .J concrete and structural steel work occurring during' the operational phase of Fort St. Vrain Unit No. 1, to the extent that such activities are comparable in nature and degree to similar activities occurring during the design and construction phase.

Where codes and standards are referenced, or are incorporated into the standard by reference, which are in conflict with original design commitments as set forth in the FSAR, the commitments shall govern. Later revisions of applicable codes and standards may be invoked specifically by the design requirements where deemed appropriate, consistent with the overall commitment to maintain the plant in an " equal to or better than" original condition.

Where specific design requirements included in this standard or referenced codes and standards are in conflict with original design requirements set forth in the FSAR and other appropriate design documents, the original design requirements shall govern.

(b) Specific Exceptions Procedures and Instructions (Section 2.2)

Appropriate requirements for installation, inspection and I tests will be set forth by job specifications and work instructions developed as a part of the modification work package. It is not intended that separate procedures be established which address specifically the various areas of this standard. However, in the development of the work package, consideration will be given to the areas outlined in Section 2.2, as appropriate.

Calibration and Control (Section 2.5.2)

The requirements of control and calibration of measuring and test equipment set forth by this standard shall be applied i to 411- measuring and test equipment used by PSCo or their agents, test laboratories and contractors. Such requirements, however, will not be imposed on commercial l batch plant facilities. Instrumentation at commercial batch i plant facilities will be evaluated to determine that sufficient accuracy can be obtained.

Qualification Tests (Section 3.2.1)

For small quantities of concrete involved in modification work, all concrete must be purchased from commercial concrete batch plants. For small quantities of concrete, it is unreasonable to expect commercial facilities to shut down normal operations to provide certified aggregate, cement, .

admixtures, fly ash, water, etc. In this respect, the i qualification tests required by Table A for aggregate, cement, acmixtures, fly ash and pozzolans, water and ice

.e Up0ATED FSAR Revision 4 B.5-41 will .'ot'be.

n required. Appropriate evaluations will be made-to. determine that good quality and generally: acceptable materials are used. This:-evaluation, coupled with slump tests,.~ airs entrainment- tests and concrete cylinder strengths, will provide adequate control and qualification of the concrete.

Desigr, mixes consistent with, .or. equivalent to, original requirements will be specified. and the' results of the.

cylinder tests will be: evaluated based on the acceptance criteria associated with- the original design mix requirements.

ASTM A-36 steel will not require certifications except for-that which.is used in the building's main structural steel.

Main structural steel .is that steel which is required in

' order for the building to maintain its integrity during design conditions, protection' of Materials (Section 4.2)

! The inspection requirements of Section 4.2 will-not be performed unless specified, as the small quantities of concrete ~ involved in modification work .no doubt will be mixed using materials already- in .the . batch plant bins.

Control of storage of materials would not be practicable.

Measuring, Mix W and Transporting (Section 4.3)

If available, appropriate certifications shall be obtained from the concrete supplier which verify the adequacy of truck mixers per the requirements of ACI-304 and ASTM C-94.

Where certifications are not available, two concrete test cylinders representing the first and last one-third of truck mixer contents shall be taken for evaluation of the mixer l truck, over and above the normal concrete cylinders taken to evaluate the in place concrete. The concrete' batch plant facility shall be inspected to assure that appropriate controls are being exercised with reference to the inspection guidelines set forth by Section 4.3(1) and (2).

replacement Preparation (Section 4.4) i Inspection of soils and earthwork will meet the general l requirements set forth, with the qualification that the extent to which individual inspection requirements are met will depend upon the nature and scope of the work to be performed.

'In-Process Tests on Concrete and Reinforcing Steel (Section 4.8)

Except for normal batch qualification tests (slump, air content, temperature and compressive strength) and initial reinforcing steel certifications, the in process tests I

l

- _ _ _ _ _ _ _ _ _ _ . _ - _ . .J

s.

-4 Up0ATED.FSAR-Revision 4

~B.5 required by Table B are generally applicable ~ to the periodic control _ which must be exercised with reference to.long-term construction type programs. The in process test

., requirements: of Table B are not considered applicable to short-term modification work as would be required under our

. Operational QA Program.-

B.5.19.7. ANSI N45.2.6-1973 Qualification of' Inspection, Examination and Testing personnel for the Construction Phase of Nuclear Power Plants (a) Scope and Applicability-The guidance _provided by this standard and the associated

.. Regulatory Guide 1.58 shall be applied to inspection, . examination 7- ~7 and testing activities associated with "h--"d modification O D wor accomplished.during the operational phase of Fort St. Vrain Unit

[ N'y} No. .1, to? the extent that'such activities are comparable in nature and degree to similar activities that occurred during the design and construction phase. For maintenance 'and repair activities, it is intended that the onsite operating organization be qualified in accordance with the provisions of ANSI N18.1-1971. Personnel performing inspection, examinations and testing activities during the operational : phase would be qualified to ANSI N18.1-1971 or ANSI N45.2.6-1973 and QA experience for levels I, II and III should be interpreted to mean equivalent experience in construction, p manufacturing, operation or installation activities. h Where codes, standards and specific design requirements are referenced, or are-incorporated into the standard by reference, which are in conflict.with original design commitments as set forth in the FSAR,. the FSAR commitments shall govern. Later revisions of applicable codes and standards may be invoked specifically by the design requirements where deemed appropriate, consistent with the overall commitment to maintain the plant in an " equal to or better than" original condition.

(b) Specific Exceptions This, -standard was written primarily for construction activitives, and in this respect cannot be applied directly to operatiorial activities in its entirety.

Qualifications (Section 3)

The following levels of capability for persons performing inspection or testing work are consistent with the requirements of the standard but have been revised slightly to reflect operational conditions.

\

\

t m

UPDATED FSAR Revision 4 B.5-43 n

Level I To be considered for certification,_ a candidate aust satisfy -

the following requirements:

High school. graduate or equivalent,'plus:

(1) One (1). year of experience. in quality assurance or engineering, design, operations, maintenance, inspection or testing of manufacturing, construction, operations and installation activities; OR (2) Demonstration of proficiency in the inspection discipline based on past performance, testing 'or job-related' technical capabilities; AND (3) In. addition to (a) or (b), successful completion of the f bt. sic Quality Assurance Indoctrination Program or-equivalent specific training.

Level II To be considered for certification, a candidate must satisfy-one of the following requirements:

(1) Graduate of a four year. accredited engineering or science college or university, plus:

(a) Two (2) years experience in quality assurance or engineering, design, operations, maintenance, inspection or testing of power plants, or equivalent manufacturing, construction, operations or installation activities; OR ,

. (b) One (1) . year experience and demonstration of proficiency by past performance, testing or job-related technical capabilities.

(2) High school graduate, or equivalent, plus:

(a) Four (4) years of experience in quality assurance or engineering, design, operations, maintenance, inspection or testing of power plant or equivalent manufacturing, construction, installation or operational activities; AND (b) Successful completion of the basic Quality Assurance Indoctrination Program or equivalent specific training.

_ _ _ _ _ _ _ _ r>

  • l

, UPDATED FSAR Revision 4 8.5-44 Level III-e

'To be considered:for certification, a candidate must satisfy

' one of the following requirements:

(1)~ Graduate of ..a four year' accredited engineering ..or science college or university,' plus five (5) years

. experience;in quality assurance or. engineering, design, operations,- maintenance, inspection, testing 'or supervision thereof 'cf power plants, or equivalent manufacturing, design, construction, operation or installation activities. . 'At least two (2) years of

'this experience should be associated with nuclear.

facilities; or, if not, the_. individual shall have training sufficient to acquaint him thoroughly with the safety aspects and . general quality assurance requirements of a nuclear facility; OR-(2) High school graduate, or equivalent, plus ten (10)

. years experience in_ general quality essurance or engineering, design, operations, -maintenance, inspection, testing or supervision thereof of power planc, or equivalent manufacturing, design, construction, operation or installation activities. At least two (2) years of this experience should be associated with nuclear facilities; or, individual shall if not, the have training sufficient to acquaint

[

him thoroughly with the safety aspects and general quality assurance requirements of a nuclear facility.

Specific Required Capabilities for Inspection Examination OM and Testing personnel (Section 3.2) k fg 4 s% ut*W 4] Each pef,o ertified to perform under the Levels designated

,. a, w g,,4 ~ herein c.i meet the following physical requirements:

@8' M * (1) Natural or corrected near-distance visual acuity such that the applicant is capable of reading J-1 letters on

. standard Jaeger's test type chart for near-vision or equivalent test type;

'(2) Color vision; and (3) Other medical requirements for the physical demands af performing the required activities (such as heart and circulatory. conditions).

Items (1), (2) and (3) will be met at the time of initial certification. Items (1) and (2) will be verified at least annually consistent with the decertification requirements.

The initial physical examination (Item (3)) will not be j reverified unless there is an apparent need.

Quality Assurance Division personnel involved in non-destructive examination functions will be qualified to the ky,,,J w A fhg.uk asakJ/m., Ad.c sc. lu,,:Se4tofujn m 4 9 a.u w t, aa. m u p.,.iuu, up .

UPDATED FSAR Revision 4 B.5-45 requirements of SNT-TC-1A as appropriate. For work where the QA Division does not have properly qualified NDE personnel, personnel with proper qualifications will be obtained from outside sources.

B.5.19.8. ANSI N45.2.8 - Draft 3 Rev. 3, Apr. 1974 Supplementary Quality Assurance Requirements for Installation, Inspection and Testing of Mechanical Ecu1pment and Systems for the Construction phase of Nuclear Power Plants (a) Scope and Applicability This standard was written for construction efforts of nuclear plants and, as such, the requirements set forth and the feasibility, both from an economical viewpoint and a practical viewpoint, are based on the construction situation. As such, implementation of all the requirements of this standard for operating plants, considering the scale of plant modifications versus initial construction, is not practicable.

The guidance provided by this standard shall be applied to "g 4 d u 1 installa61on, inspection and testing of mechanical equipment and systems

  • associated with onsite __ _ _ _ . modification work
  1. b f'" occurring during the operational phase o'f Fort St. Vrain Unit No. 1, to the extent that such work is comparable in nature and degree to similar work occurring during the design and construction phase.

Where codes or standards are referenced, or are incorporated into the standard by reference, which are in conflict with original design commitments set forth in the FSAR, the FSAR commitments shall govern. Later revisions of applicable codes and standards may be invoked specifically by the design requirements where deemed appropriate, consistent with the overall commitment to maintain the plant in an " equal to or better than" original condition.

Where specific design requirements included in this standard or referenced codes and standards are in conflict with original design requirements set forth in the FSAR and other appropriate design documents, the original design requirements shall govern.

(b) Specific Exceptions procedures and Instructions (Section 2.2)

Appropriate requirements for installation, inspection and tests will be set forth by job specification and work l instructions develooed as a part of the modification work package. It is not intended that separate procedures be established which specifically address the various areas of <

this standard. However, in the development of the work i package, consideration will be given to the areas outlined in Section 2.2, as appropriate.

)

e e

p _ _ _ - - __-

UPDATED FSAR Revision 4 B.5-46 Cleaning (Section 2.4)

Implementation of ANSI N45.2.1 is specified by separate

' documentation. (See 8.5.19.2)

Receiving, Storage and Handling (Section 2.5)

Implementation of ANSI N45.2.2 is specified by separate documentation. (See 8.5.19.3)

Housekeeping (Section 2.6)

Implementation of ANSI N45.2.3 is specified by separate documentation. (See B.5.19.4)

Personnel Qualification (Section 2.7)

Implementation of ANSI N45.2.>6 is specified by separate documentation. (See 8.5.1L 7) 8.5.19.9. ANSI N45.2.9-1974 Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants (a) Scope and Applicability h The guidance provided by this standard and the associated bI Regulatory Guide 1.88 shall be applied to quality assurance records associated with operation of Fort St. Vrain Unit No. 1.

Those design, manufacturing, construction and operating records generated prior to implementation of this standard are, not backfitted to the detailed requirements of this standard. All such records, however, are designated initially for lifetime storage.

Until specific review dictates otherwise, they will be stored in the permanent record storage facility. Appropriate record indexes and filing systems permit reasonable identification and retrieval. The records are stored and preserved per the Requirements of Section 5.0 of this standard.

(b) Specific Comments Safekeeping (Section 5.5)

The Records Storage Building is located at the plant site within the site access control fence. During off-duty hours the facility is kept locked and is monitored,by regular guard patrols under the auspices of the plant security program.

Facility (Section 5.6)

A records storage building has been constructed onsite to provide for storage .o f records. This facility was

a. -

UPDATED FSAR Revision 4-B.5-47 L constructed to provide adequate record protection to prevent destruction by fire, theit, flooding and vandalism.

B.5.19.10. ANSI N45.2.10-1973 Quality Assurance Terms and Definitions The quality assurance terms and definitions contained in this.

standard shall be used as guidance and applied as appropriate to the Operational QA' Program for Fort St. Vrain Unit No. 1.

There may be instances where existing procedures contain

definitions that may not be in strict accordance with those provided 4

by this standard. As existing procedures are revised, however, such definitions shall be evaluated to determine if the intent of definitions meets the intent of those provided by this standard.

B.5.19.11. -ANSI N45.2.11-1974 Oc411ty Assurance Requirements for Design of Nuclear Power Plants teJA

@ The guidance prov ed by this standard and the associated Regulatory Guide 1.64 shall be applied to design, activities W ,b )

involving "#t-'M modification workF and the revision or A 44 A.p development of plant design documents occurring during operation of- -

Fort St. Vrain Unit No. 1.

Where codes, standards or design requirements.are referenced, or are incorporated into the standard by references, which are in conflict with original design commitments as set forth in the FSAR, the FSAR commitments shall' govern. Later revisions of applicable codes and standards may. be invoked specifically by the design requirements where deemed appropriate, consistent with the overall commitment to maintain the plant in an " equal to or better than" original condition.

Appropriate design controls have been implemented to control modification work and associated design activities to assure that all modification work meets, or exceeds, original design requirements. ,

8.5.19.12. .

ANSI N45.2.12-1974 Requirements for Auditing of Quality Assurance Programs for Nuclear Plants

]

(a) Scope and Applicability 1

Except as expressly modified below, the guidance provided by this standard shall be app'.ed to the audit program identified by the Operational QA Program for Fort St. Vrain Unit No. 1.

(b) Specific Exceptions Audit Schedule (Section 3.4.2)

Due to the large scope of our QA Program and the audit areas defined, it is not practicable to audit the entire program on an annual basis. Our scFaduling provides lor applicable elements of the QA Program to be audited at least once every

_ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ __ J. I

UPDATED FSAR Revision 4 B.5-48 I two (2) years. QA monitoring activities serve to identify

. problem areas, and results of QA monitoring may be used to

, increase audit frequency or change audit schedules.

. Audit Process (Section 4.3.2)

For Third Leve s conducted by direction, and un e d9 M auspices of the Quali -

conference is held with +

ance Divisi re-audit ssurance Operations Manager. It is th . ility of t lity Assurance l Operations M to review the audit scope a t plan. j He als vides for the necessary liaison betwee e a or and the organization being audited.

Post-Audit Conference and Follow-up (Sections 4.3.3 and I 4.5.1)

At the conclusion of the audit, a meeting is held with appropriate personnel of the audited organization to discuss audit findings. This meeting provides for presentation of audit findings and for discussion of these findings by the audited organization.

Within thirty (30) days after this post audit conference, an audit report i s issued,' " "1._r, , 0. . : ' O ". . . . . . Tu r

[, [_ TN!U_I5 NI 'b:" "' ""'" * '"" """ b 8.5.19.13. ANSI N45.2.13 - Draft 3, Rev. 3, June 1975 Quality Assurance Requirements for Control of procurement of Items and Services for Nuclear power Plants (a) Scoce and Applicability To the extent that the information set forth by this standard provides useful and practical guidelines for purchasing associated with nuclear "'^ t " M equipment,

@ activities components, parts, materials and services, the guidance provided will be applied to such activities associated with the Fort St. Vrain Unit No. 1 Operational QA Program.

It must be recognized, however, that equipment and components purchased during the design and construction phase were not purchased on the basis of present-day standards, especially with reference to Seller qualification and Seller quality assurance programs. In this respect, replacement parts and spare parts for existing equipment often are limited to sole-source suppliers, some of whom may not meet present-day qualification standards. Such replacement parts or spare parts are purchased to appropriate quality standards to maintain an equal to, or better than, condition but it is not considered practicable to backfit the requirements of the standards to all such sellers.

_ - _ _ _ - _ _ _ - _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ ________________-________ ~_________ ____ . _ _ -

UPDATED FSAR-Revision'4 B.5-49

.(b) . Specific Exceptions Selection Measures (Section 4.2)

In addition'to the methods outlined by subparagraphs 4.2.a.,

4.2.b. and 4.2.c. , consideration must be given to . products in, which quality can be verified.by. receiving inspection, test or other means. Evaluation of procurement sources for such items may be'made on the basis of subparagraph 4.2.a.,

but on a much less restrictive basis.

Sole-source replacement part or spare part suppliers may have to be evaluated based on product performance and maintenance of an equal to, or better than, condition.

Conformance to procurement Documents (Section 5.2)

Measures shall be established to assure the successful bid conforms to procurement document requirements. There will be no requirement, however, to document the bid evaluations, preaward Evaluation (Section 5.3)

The requirement and extent to which preaward evaluations are

. performed will be subject to the conditions of Section 6.2.

Certificate of Conformance (Section 10.2)

The' minimum criteria set forth are much too restrictive for general application of certification of conformance involving off-the-shelf items and many applications involving the purchase of simple spare parts. . The requirements set forth by this section will be considered in purchasing activities to the extent that the guidance provided is useful and can be applied practicably to our purchasing activities.

I B.S.19.14. ANSI N18.1-1971 Selection and Training of Nuclear j

power Plant personnel and Regulatory Guide 1.8, i September, 1975 )

The Fort St. Vrain Technical Specifications require that American-National Standards Institute N18.1-1971, " Selection an of  ;

Personnel for Nuclear Power Plants", shall be ~ " gTyaining - M: for O3l selecting and training naa&amament plant personnel (except for the Radiation Protection Manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975) and for retraining requirements for those persons on the staff.

B.5.19.15. ANSI N18.7-1972 Administrative Controls for Nuclear power plants

-)

The Operational QA Program for Fort St. Vrain Unit No. 1 is intended to be responsive to,the guidance provided by this standard.

_ _ _ _ _ _ _ _ _ _ _ . a. '

UPDATED FSAR

{ Revision 4 8.5-50 h Where codes or standards are referenced, or are-incorpor^ted into the standard by reference, which are in conflict with original design commitments as set forth- in the FSAR, the FSAR comitments shall govern.- Later revisions of applicable codes and standards may be invoked specifically by the design requirements where deemed appropriate, consistent with the overall commitment to maintain the plant in an " equal to or better than" original condition. Specific requirements of the Fort St. Vrain Technical Specifications differ in some respects from .the requirements of this standard. Where differences do occur, the Technical Specifications shall govern.

i I

_ - _ . _ _ - _ _ - _ _ _ _ _ - _ _ _ - _ _ _ S?<"

~.

Table B.5-1 POLICIES AND GUIDELINES FOR h "L" T*d: ~~~""J TITNUCLEAR ACTIVITIES

1. General Policy Statement
2. Organization Policy
3. Quality Assurance Policy
4. Nuclear Engineering Policy
5. Procurement Policy
6. Construction Policy
7. Nuclear Operations Policy
8. Maintenance Policy
9. Safety Policy
10. Physical Protection Policy
11. Documentation Policy
12. Training Policy
13. Nuclear Emergency Planning Policy ,,
14. Fire Prevention / Protection Policy
15. Nuclear Plant Startup and Testing Policy
16. Environmental Protection Policy
17. Nuclear Plant Procedures i 18. Fitness for Duty Policy
14. & man.u l. s m Akm 30 . (emm imm h Lnh-sI /et;
h. &~ b s Greq keht.; plan ystsy JL M a ge -e-, 4 %. 4/ 9 gh J). r'la n i ;. Sa, dot Pt. w rys.d. umpdua s J$. kv. H e ;. on wo is Q a vst w . Or$a ,ta. 4 % foI: w

}4 NLL Aeld; man:p fr1 Wylios, La. ms. A of ma,treIn ,* d k *'Y"=~*'* bAlf

,11 WA C del d.u,>~.y o" Amen dul h)els.0: ors , or 4 ;ha.ds t'al:L y fut befreel Sn.s jf. 6 viedame W Sva/;[u.f m g Efec6;c, ,:fm / [4'd) dhc

~ -

7 Table B.5-2

~

MINIMUM QUALIFICATIONS FOR MANAGER, OUALITY ASSURANCE

1. EDUCATION:

College Degree, preferably in the technical sciences area, or equivalent in experience and' technical training.

2. GENERAL EXPERIENCE: (Professional Level)

Five to eight years experience in a responsible position that includes coordination, direction and supervision of personnel, equipment and materials. Experience in handling diverse projects preferred. Should have a working knowledge and understanding of plant design and operation and an understanding of construction practices.

3. QUALITY ASSURANCE EXPERIENCE AND TRAINING:

Experience of two to five years in quality assurance or related activities. Experience should preferably include work with .

codes and/or standards and the application of codes, standards and/or regulatory requirements to construction, industrial or operational requirements.

4. DIRECT EXPERIENCE:

Two years experience in direct supervision of quality assurance activities.

5. FORMAL TRAINING: ,

Basic and advanced supervisory training preferred. Basic QA indoctrination and fundamental training in OA techniques or the equivalent in experience.

1

~

i l

Table B.5-3 '

(Page 1 of 2)

THREE LEVEL QUALITY ASSURANCE PROGRAM FOR PLANT OPERAT EXPLANATION OF FIRST, SECONO AND THIRO LEVEL QA RESPONSIBILITIES Engineering & Const.ruction Operation Nuclear Fuel procurement ,

First level - Quality a. First Level - Inspection a.

Control & Insoection I Personnel at this level are j The First Level, which '

constitutes the Quality charged with the Control and Inspection responsibility for direct function, is performed by inspection, witnessing and nuclear fuel fabricators, sign-off, attesting that work has been performed at equipment manufacturers, each stage in accordance and construction contractors. with the quality Such manufacturers are requirements of the generally expected to have controlling documents.

separate Quality Control organizations, which are Inspection and quality l control denadaaenenee is I l charged with direct '

inspection and sign-off performed by Maintenance fg l

attesting that quality Quality Control personnelgal/o.-

l #"- 4-"'--  : f L:y l requirements have been met '-

l at each stage of manufacture " - '

, _ "O l QA/QC personnel, l or construction.

Second Level - Quality b. Second Level - Quality

b. Assurance Monitoring Assurance Surveillance The Second Level, which This function is performed ,

constitutes the Quality by Quality Assurance personnel assappropriate Assurance Surveillance function, is performed by for the work involved. The the prime contractor, a documents which control the major design contractor, testing, operation, the construction manager, maintenance, and or the owner's QA personnel, modification are prepared as appropriate for the work for review and approval by involved. The drawings and this level, for use by First Level personnel.

documents that control the design, fabrication, construction and installation Second Level QA is are prepared at this level, responsible for assuring that all controlling for use by the First Level documents for operation contractors. During the design pnase of the project, include appropriate quality Second Level QA is requirements. During

~~m

Table B.5-3 (Page 2 of 2) y 1THREE LEVEL QUALITY ASSURANCE PROGRAM FOR PLANT OPERATION E_XPLANATION OF FIRST, SECONO AND THIRD LEVEL QA RESPONSIBILITIES Engineering & Construction Operation Nuclear Fuel Procurement responsible for assuring operation, Second Level QA that specifications, is responsible for drawings, and purchase monitoring the work to ~

documents include assure that QC and appropriate quglity inspection programs are requirements. During the being carried out and that fabrication'and construction the quality requirements

. phase of the project, are being met.

Second Level QA is responsible for maintaining surveillance of the manufacturing and construction work to assure that contractor Quality Control and Inspection programs are, in fact, being carried out and that the quality requirements are, in fact, being met,

c. Third Level - Ouality
c. Third Level - Ouality Assurance Audit Assurance Audit .

The Third Level, which This function is performed constitutes the Quality by, or under the direction Assurance Audit function, of, high-level management.

is performed by the owner, Persons performing these the owner's representative, audits are generally not or the prime contractor.

involved in the day-to-day In either case, these audits Inspection or Quality are. carried out by or under Assurance monitoring the direction of high-level functions. Audits will management.- Persons normally be performed by, performing these audits or under the direction of, are generally not involved the Manager, Quality I

in the day-to-day Assurance.

Insoection, Quality Control or Surveillance functions.

i

_._._._...___._____.____.A_ _ _ . _ _ - _ _ _ _ _ _ _ _ _ _ _ . _ _ -

UPCATED FSAR Revision 2 Table 3.5-4 (Page 1 of 2)

ANSI STANDARDS AND REGULATCRY COCUMENTS APPLICABLE 70 FSV CPERATICNS CA PC.CGRAM Final Safety Analysis Report - Appendix B (Amendment 32) a)

b) FSV Tecnnical Specifications USNRC Cuality Assurance Criteria for Nuclear Power Plants, c) 10CFR50, Appendix B WASH-1283, Guidance on Quality Assurance Requirements Ouring d)

Design and Procurement Phase of Nuclear Power Plants -

Revision 1, cated 5/14/74 WASH-1284, Guidance on Quality Assurance Requirements During :ne e) 10/26/73 Operations Phase of Nuclear Power Plants, dated f) WASH-1309, Guidance,on Quality Assurance Requirements Ouring the Construction Phase of Nuclear Power Plants, dated 5/10/74 g) N45.2-1971, Quality Assurance Program Requirements for Nuclear Power Plants (Standard) and Regulatory Guide 1.28, June 7,1972.

l h) N45.2.1-1973, Cleaning of Fluid Systems and Associatad Comconents During the Construction Phase of Nuclear Power Plants (Standard) i and Regulatory Guide 1.37, Maren 16, 1973, 1)

N45.2.2-1972, Packaging, Shioping, Receiving, Storage, and . "

Handling of items for Nuclear Power Plants (Curing :ne C:nstrx:f on Phase) (Stancard) and Regulatory Guice 1.38, l

Maren 16, 1973.

j) N45.2.3-1973. Housekeeping during the Construction Phase of Nuclear ::wer Plants (Stancarc) and Regulatory Guide 1.39.

I Maren 16, 1973.

k) N45.2.4-1972, Sucolementary Quality Assurance Requirements for Installati:n, ;rsoection and 7esting of :nstrumenta:1on and h Electric E:ui: ment Curing the Construe:f on Of Nue!aarG Power Generating 5:a-i:ns (Stancare IEEE) anc S n ,..- / uide \ 30, 1

Augus: ;1, '.972. **7

1) N45.2.5-1974, su==lementary Cuality Assurance Requirements f:r Installa:fon. :nscec-fon, 5: eel and 7esting :f S-rue: ural C:ncrete Ouring :ne Construe: ten Phase of Nuclear anc 5true:.ral Power P' an 5 (5:ancarc) anc Regula: cry Guice 1.94, Au. i, A/r.L 'O %-

m) N45.2.5-1973. Sai'ficati:ns of Inscection, Examinati:n arc Tes:teg :e s:enei f:r :ne Construe:icn :*ase =f Nuclear  : wer 1973.

1 Plants (5:arcarc) anc Regulat:ry Guice 1.53, Augus:

L -A-~~ ._. _-___________ _ _ _

i

  1. g' UPDATED FSAR Revision 2 '

Table 8.5-4

L (Page 2 of 2)

ANSI STANDARDS AND REGULATORY

-DOCUMENTS APPLICABLE TO FSV CPERATICNS CA PROGRAM N45.2.8, Supplementary Quality Assurance Requirements for n)

Installation, Inspection, and Testing of Meenanical Equipment and Systems for the Construction Phase of Nuclear Power Plants (Draft 3, Rev. 3, April 1974) o)

N45.2.9-1974, Requirements for Collection, Storage and

. Maintenance ef Quality Assurance Records for Nuclear Power i

Plants (Standard) p)lN45.2.10-1973, Quality Assurance Terms and Definitions (Standard) and Regulatory Guide 1.74, Ormy,eUV.

q) N45.2.11-1974, Quality Assurance Requirements for Design of Nuclear Power Plants and Regulatory Guide 1.64,' Revision 2, l

l June 1976.

r) N45.2.12-1974, Requirements.for Auditing of Quality Assurance Programs for Nuclear Power Plants (Standard) s)

N45.2.13, Quality Assurance Requirements for Control of Procurement of Equipment, Materials and Services for Nuclear Power Plants (Oraft 3, Rev. 3, June 1975) t) American National Standards Institute Standard ANSI N18.7-1972, Administrative Controis-for Nuclear Power Plant Personne>l and

@ l l 7 r4 -rj Guide %33 (See Ref. 7).

'+_ay u)

American National Standards Institute Standard ANSI N18.1-1971, Selection and Training of Nuclear Power Plant Personnel, anc

) Regulatory Guide 1.8, Septemoer 1975.

e v) N45.2.23-1978, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants (Stancarc) and Regulatory

.h Guide 1.146,n(see s+,1410Ref. 12 and 13).

l w) Regulatory Guide 1.21, Revision 1 June 1974 (Reference 19).

1 x) Regulatory Guide 4.1, Revision 1, April 1975 (Reference 19).

I NOTE: Cocuments referenced acove from d) througn x) inclusive do not acoly in their entirety. Specific exceptions to tnese cocuments are set fortn in Section 3.5.19.

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UPDATED FSAR Revision 3 8.6-1 B.6. REFERENCES FOR APPENDIX B y 1. Final Safety Analysis Report for the Fort St. Vrain Nuclear Generating Station, as revised through Amendment 32.
2. NRC letter dated May 9, 1975, Division of Reactor Licensing to Additional information on PSC QA Program Walker (PSC);

Subject:

for Operation.

3. PSC letter dated June 23, 1975, Walker to Giambusso (NRC);

Subject:

FSAR Amendment 31.

4. PSC letter dated Octcber 31, 1975, Walker to Clark (NRC);

Subject:

FSAR Amendment 32.

5. Code of Federal Regulations, Title 10, Part 19 (10CFR19); Part 20- 73 (10CFR20); Part 50 (10CFR50); Part 55 (10CFR55); Part (10CFR73).

letter dated March 4, 1982 (P-81085), Brey to Seyfrit (NRC);

I G. PSC Changes to OA Program as described in the FSAR I

Subject:

(10CFR50.59).

Assurance Program Requirements (Operation), USNRC

7. Quality November 1972, (endorsing ANSI N18.7-h _rgg S;f m ; Guide %33, 1972).
8. American Society for Nondestructive Testing Recommended Practice No. SNT-TC-1A.
9. Guidance on Quality Assurance Requirements Ouring Design and Procurement Phase of Nuclear Power Plants, WASH-1283, Revisi,on 1, May 24, 1974
10. Guidance on Quality Assurance Requirements During the Operations phase of Nuclear Power Plants, WASH-1284, October 26, 1973.

Requirements During the

11. Guidance on Quality Assurance Construction Phase of Nuclear Power Plants, WASH-1309, May 10, 1974.

I 12. NRC letter dated May 1, 1981 (redated for transmittal to PSC of January 5, 1982) (G-82008), Eisenhut (NRC) to Holders l

Construction Permits;.

Subject:

Qualification of Inspection, j Examination and Testing and Audit Personnel (Generic Lettar 81-

! 01).

13. PSC Letter dated February 3, 1982 (P-82042), Lee to Eisenhut (NRC);

Subject:

Qualification of Inspection, Examination and Testing and Audit Personnel.

14. PSC letter dated October 13, 1978 (P-78167), Fuller to Gammill (NRC);

Subject:

Evaluation of Fire Protection Provisions (Branch Technical Position 9.5-1).

. n _ _ _ _ _ - - _ _ _ -

Up0ATED FSTA Revision 3 8.6 '

dated November 13, 1978 (P-76182), Fuller to Gammill

15. PSC letter

-(NRC);

Subject:

Evaluation of Fire Pratection Provisions (Branch Technical Position 9.5-1).

) 16. NRC letter dated June 12, 1981 (G-81107), Seidle (NRC)-to Millen; l

Subject:

NRC 1&E Inspection 81-10, QA Program.

17. Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants, ANSI N45.2.23-1978.
18. PSC letter. dated June 16, 1982 (P-82188), Warembourg to Collins (NRC);

Subject:

NUREG-0737.

l 19. NRC letter dated November 23,1983 (G-83429), Wagner (NRC) to Lee;

Subject:

Technical Specifications Amendment 37.

letter dated . January 24, 1983'(G-83060), Taylor to l 20. NRCDistribution;

Subject:

Final Rulemaking: Reporting of Changes to QA Programs l 21. NRC letter dated August 10,1983 (G-83301), Wagner (NRC) to Lee;

Subject:

Technical Specifications Amendment 35.

l 22. PSC letter dated June 27, 1984 (P-84185), Gahm to Johnson (NRC);

Subject:

FSAR Appendix 8.

10, 1984 (G-84282), Johnson (NRC)'to Lee:

l 23. NRC

Subject:

letted dated AugustApproval of Revision 1 of the Quality Assurance Pr for Plant Operation, Appendix B, FSV FSAR.

l 24. PSC letter dated September 28,1984 (P-84369), Lee to Director of Nuclear Reactor Regulation;

Subject:

Fort St. Vrain Updated FSAR l

l Revision 2, Appendix B.

I 1

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