ML20236J614
| ML20236J614 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 10/14/1987 |
| From: | David W WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| GO1-87-0134, GO1-87-134, NUDOCS 8711060193 | |
| Download: ML20236J614 (39) | |
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- WASHINGTON PUBLIC POWER SUPPLY SYSTEM REGION V i
P.O. Box 968 o ' 3000 George Washington' Way
- Richland, Washington 99ft!3 DCT l 5 A O l 4 f
October 14, 1987 Respond to: N/A G01-87-0134 Response Requested: N/A j
i Docket No. 50-460
.Mr. J. B. Martin Regional Administrator Nuclear Regulatory Commission, Region V i
1450 Maria Lane, Suite 210-Walnut Creek, California 94596
Subject:
NUCLEAR PROJECT NO. 1 QUALITY ASSURANCE PROGRAM DESCRIPTION
References:
-1.
Letter G01-83-0115 dated March ~25, 1983;' subject same 2.
Letter G01-84-0080 dated F ch 22, 1984; subject same.
1 3.
Letter G01-86-0102 dated July 1,1986 ; subject same 3), attached i s ' the Supply System's s
As required by 10CFR50.55(f)
(
Quality Assurance Program Description which is currently being implemented at WNP-1.
'This Quality Assurance Program Description refl ects.. 'recent organizational changes in Corporate QA and the Project organization.
Should you have any uestions regarding the attachment, please advice.
Y l
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,. F. David, WNP-1 Site Manager j~
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Attachment:
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E. C. Haren, UE&C.(895)
NRC Document Control Desk
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8711060193 B71014 PDR ADOCK 05000460 h
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I MD SOPi)L ' SYSTEM PSAR DEVIATION REQUEST WNP I DEVIATSON NO.
PAR AG R APH NO.
DATE 17.1-6 (WP) Rev. 4 Section 17.1 1
Deviation 17.1-6 Rev. 3 does not reflect latest Corporate QA organization or functions performed by Support Services and Engineering organizations.
l
- 2. DESIRED CHANGE (INDICATE DESIPsED STATEMENT) l Revise Deviation 17.1-6 (WP) Rev. 3 to reflect change in Supply System Corporate QA organization and minor changes in Support Services and Engineering.
1 3.
ATE ENTIFYING SIGN!PICANCE OF DEVIATION: (l.a.. WHAT IS BEING PROPOSED THAT IS DIPPERENT PROM PSAR No change is being made to PSAR commitment.
- 4. JUSTIFICATION (i.e EXPLAIN WHY THE DE56MED CHANGE 15 JUSTlPIED AND 45 EXPECTI D TO DE DEFENSIBLE BEFORE THE NRC)
Update Chapter 17.1 to reflect Supply System organization and responsibilities during the Extended Construction Delay.
- 5. DOE 5 DEVIATION APPECT QA PROGRAMP IF ANSWERED "YE5". DOES QA CH ANGE REPRESENT REDUCED COMMITMENT 57 hYES Dao OVES "APPRO NO P RT NO TO N A REQ'D 4.
SUPPLY SYSTEM APPROVALSI DATE PROJECT PROQRAM DtRECTOR ' ~
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J CHAPTER 17 00ALITY ASSURANCE The Washington Public Power Supply System will implement an overall Quality Assurance Program (QA Program) for the design, procurement, construction and-operation of the Supply System's Nuclear Project No.1 (WNP-1) in accordance-with the requirements of Appendix "B" of 10CFR50.
As the applicant, the j
Supply System is responsible for the plant and will take appropriate actions 1
to assure that icey are designed, procured, constructed and operated in accor-I dance with sound e ngineering principles and practices.
Systems, components j
and structures that are safety-related, in the context of 10CFR50 will be j
designed, specified, f abricated, installed, tested and operated in accordance 1
with applicable regulatory requirements, codes, standards, specifications and l
procedures.
The objective of the Supply Syf tem is to implement a QA Program that is responsive to the requirements of NRC Regulations, 10CFR50, Appendix 8, " Quality Assurance Criteria for Nuclear Power Plants" by assuring that quality related ef forts are performed in a controlled manner and are docu-
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mented to provide objective evidence of compliance.
l 17.1 OVALITY ASSURANCE DURING DESIGN AND CONSTRUCTION Washington Public Power Supply System 17.1.1 Organization
- This Section describes the organizational relationships within the Supply System and assigns the authorities and responsibilities for the administration and implementation of the Quality Assurance Program.
Assigned authorities and
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responsibilities demonstrate the organizational f reedom of Quality Assurance.
This organizational freedom is accomplished through Corporate and Project i
structures which provide independence from Supply System organizations respon-sibir. for Project activities.
At the Corporate Level, the Director and staff of Licensing and Assurance, and at the Project (jobsite) Level the Project QA Manager and staf f, are com-pletely free from responsibility of cost and schedule. The Director of Licensing and Assurance and the Project QA Manager have the f reedom and authority to identify quality related problems, initiate corrective actions (including stop work) and recommend or provide solutions and to verify the l
implementation of corrective actions.
The organizations of the Supply System and Supply System Quality Assurance are cl presented in Figures 17.1-1 and 17.1-2 and 11.1-3.
The functional responsi-bilities for the implementation of the Supply System Quality Assurance Program are assigned as follows:
l j;
17.1-1 O
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j WNP-1 PSAR-Corporate Oracnization j
The Managing Director of the Supply System has the ultimate responsibility for I
the Quality Assurance Program.
The Managing Director shall assure that the program is implemented and maintained by assigniTig the appropriate authority and responsibility to the Director Licensing ard Assurance.
l The Deputy Managing Director is the chief operating of ficer and has delegated authority to implement policies of the Managing Director.
The Deputy Managing Director is accountable to the Managing Director and is responsible for:
a.
coordinating and integrating the activities of supply System organizations b.
acting for.the Managing Director as required c.
supporting and advising the Managing Director on the performance of Supply System functions and evaluation of such.
The Manager of Support Services reports to the Assistant Managing Director for d
Operations who reports to the Managing Director and is responsible for the _
development and implementation of policies and programs which support design, construction and operation of Supply System Plants.
Areas in which Support Services provides support include industrial safety and fire protection, preoperational environmental monitoring, administration, instrument calibration, radiological programs, emergency preparedness and security programs.
The Chief Financial Of ficer reports to the Managing Director and is responsi-ble for the development of corporate material management and procurement i
policy, and the procurement and control of corporate, multi-project and specialized materials and related services required to support the design and construction of Supp',y System Nuclear Power Plants.
The Director, Engineering reports to the Managing Director and has responsi-bility for:
4 a.
.f. establishing controls to manage the design in accordance with l
requirements.
b.
Establishing an organization of qualified personnel resources to control activities and providing support of project objectives.
j c.
ASME Code consultation to the Project, including interfacing with ASME.
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d.
Performing and managing selected technical programs, having applicability to several Projects, including geology.
e.
Providing independent technical evaluations when requested.
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f.
Implementation of Supply System records management policy.
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17.1-2 l
i j
WNP-1 PSAR The Manager, Construction Projects reports and is accountable to the Director Engineering, for development and implementation of policies and programs supporting Project activities. The Manager, Construction Projects carries out-his responsibilities through the Site Manager and Engineering Manager.
The Site Manager and Engineering Manager are responsible for the safe, successful completion of the Project.
They discharge their responsibilities by managing and directing the Architect-Engineering ( AE) organization which is performing design; and Supply System Project personnel.
j The Director, Licensing Ond Assurance reports and is accountable to the l
Managing Director and is responsible for the overall development, implementa-l tion and verification of the Supply System Quality Assurance and Regulatory Programs to ensure com,oliance with regulations, codes and standards.
These responsibilities inc'lude:
a.
Interpretation of ASME Code quality assurance requirements and Quality Assurance Manual requirements.
i b.
Definition, app; oval, revision and distribution, of the Supply System i
Quality As>crance Manuals to ensure that the manuals adequately describe i
requirements.
c.
Approval of all Corporate quality affecting implementing pr,ocedures and instructions and Project Quality Assurance Instructions.
.d.
Determining the adequacy and effectiveness of program implementation.
4.s e.
Apprising the Managing Director of the effectiveness of the QA and Regulatory Programs by periodic reporting of activities, trends, and pro-blems, through established corrective action systems.
f.
Exercising the authority vested in the Quality Assurance organization to cause the acceptance or rejection of materials and components based on conformance verification to engineering requirements and the requirements of the ASME Code.
9 Ensuring that Quality Assurance and Regulatory policies and programs pro-vide Project Quality Assurance and Licensing Managers the freedom to inform the Director, Licensing and Assurance of significant conditions affecting quality, h.
Maintaining cognizance of changing regulatory requirements and providing controlled interface between the Supply System and regulatory agencies so as to assure that commitment documents receive the nEcessary degree and depth of reviews prior to transmittal, i.
Exercising authority to stop nonconforming work of any Supply System Contractor or Supplier. organization; and notification of the Authorized Nuclear inspector ( ANI) of the work stoppage for ASME activities.
,i 17.1-3
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D-j i-r WNP-1 PSAR s
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_ Ensuring the adequacy, clarity and appropriateness of Supply System 1
Quality Assurance and Regulatory oriented communications and commitments
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directed to Supply System direct contracts and the Authorized Inspection t
Agency.
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Ensuring that significant conditions af fecting quality or Regulatory Programs, which are identified by Project Quality Assurance and which are j
addressed to the Licensing and Assurance Directorate for resolution, are adequately investigated and/or corrected.
I 1.
Providing licensing support functions in such areas as acquisition and j
maintenance of nuclear power plant construction permits and operating
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li: ens es -.
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Administering Corporate and Project Quality Assurance and Regulatory Program activities, n.
Establishment and maintenance of adequate and qualified Licensing and l
Assurance staffing (on-site as well as off-site) levels based on work load analysis.
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Manager. Programs' & Audits The Manager, Programs & Audit's reports to the Director, Licensing and Assur-ance and is responsible for the development and implementation of the Quality Assurance program during the Nuclear Power Plant Design and Construction phases.
He is also responsible for procurement QA. qualification and certifi-cation of Supply System nondestructive examination and inspection personnel, and other personnel requiring certification; surveillance of non-destructive examination and inspection activities, has the lead role for acquiring and snaintaining ASME Certificates of Authorization and is responsible for main-taining an organization of qualified auditors responsible for verifying implementation of the Quality Assurance Program as follows:
a.
Performing Quality Assurance audits of internal Supply System organiza -
tions and external organizations (c 9., AE/CM); except for Management Audits.
b.
Developing audit schedules and selecting qualified personnel to perform the activities of this function.
c.
Certification of Audit Team Leaders.
d.
Training of audit personnel, e.
Participating in audits and providing overview of AE activities.
f.
Periodic review of Corporate and Project audit reports to identify any quality trends which may constitute a need for corrective action.
17.1-4
WNP-l' d
PSAR I
2 g.
Maintenance of' Audit Records.
The Manager of Programs & Audits is supported by the following:
Manaaer. Procurement Quality Assurance The Manager of Procurement Quality Assurance reports to the Manager, Programs 1
& Audits and is primarily responsible for the definition and implementation of 1
~
source surveillance / audit program for verification of activities performed by the Supply System vendors (including the Nuclear Steam Supply System vendors).
Pro.iect Quality Assurance Manager The Project Quality Assurance Manager reports directly to the Manager, Pro-grams & Audits and is matrixed to the Site Manager and Engineering Manager.
g Project Quality Assurance Manager is responsible for:
l a.
Verification of the implementation of the Quality Assurance Requirements
- Manual, Verifying adequate imple[nentation of an approved stop work authority pro-b.
gram and directing a stop work order should conditions so dictate.
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Performing receiving inspecton, quality records review and acceptance, quality records retention and control, and identification and reporting of nonconformances.
d.
Verification, by audits and surveillance, that the AE, selected Contractors and other Project organizations are implementing applicable quality requirements.
e.
Ensuring that adequate staffing is obtained to implement the Quility Assurance programs at the Project.
j f.
The assignment of adequately trained and qualified / certified personnel to l.
perform quality verification activities.
V g,
Overview of AE approval of Contractor procedures and instructions.
h.
Reporting significant conditions adverse to quality to the Manager, l'
Construction Projects and the Director, Licensing and Assurance.
3 l
i.
Reporting Quality Assurance problems and trends to the Manager, Programs
& Audits for use in developing standards for Quality Assurance management systems to preclude repetition of Quality Assurance problems.
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Approval of all Supply System quality affecting Project implementing
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procedures and instructions.
17.1-5 C_
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LManager. Requlatory Programs-The Manager, Regulatory Programs. reports to the Director, Licensing and L
- Assurance and is' responsible for. formal contacts between~the Supply System and.
, the Nuclear Regulatory Commission:(NRC) on nuclear safety issues pertaining to j
licensing. The Manager, Project Licensing-reports to.the Manager, Regulatory.
1 LProgram and is responsible for the following ~
i 1
fa..
coordinating and maintaining a working interface between~the Supply; j
. System and the'NRC b..
. managing, coordinating and' participating in the preparation of-all required license applications and supporting documentation d
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- c..
maintaining a working knowledge of all pertinent regulations
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d.
assuring review of.and providing technical input!, to Safety Analysis Reports l
- e.-
assuring' review of. regulatory guides for applicability to the projects'.
,l Pro.iect Organization
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The. Site Manager and Engineering Manager are responsible and accountable to the. Manager. of Construction Projects for the safe,- successful completion of the Project.
The Site Manager / Engineering Manager directs overall-engineer-ing, program management, construction, and testing.
Specific. quality related 6.,
activities are:
a.
Engineering 1)
Review and ' approve repurchased equipment and construction specifi-cations-(hereinafter'also called equipment and construction speci-fications or procurement' documents)* and significant. changes.
thereto,.to assure that Supply System regulatory, c. ode, and stan-dard requirements are included and met, and that they are'techni-cally adequate. This review-and approval shall be at the system or Repurchased equipment specifications and construction specifications are
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differentiated as follows-
' Repurchased equioment:
Specification'wherein the Supply System purchases equipment or material directly from a manufacturer or supplier and includes all activities through delivery to the site.
Construction: Specification wherein the Supply System purchases site construction activities through a contractor.
The specifica-tion.may include a requirement for the contractor to purchase plant equipment or materials for its installation, or may only require I
installation of repurchased equipment, or both.
17.1-6 6
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-PSAR m
istructure-level which' deals'with basic concepts of overall plant-design 'and at the component level Lfor critical components.
Field initiated changes will be reviewed-and approvedLif the changes represent a change in design.
Field' changes which implement con-j structability but do not affect the basic design will generally not:
'be reviewed and. approved by the. Supply System, Included in'the~
' responsibility is the completion of:a Comment / Resolution Form for initial release'of a specification and a documented approval / sheet
- for subsequent changes.
Significant" changes are-defined as those changes which affect the basic design.- Hon-significant changes are those which implement or enhance constructability but do not change the basic design..
~
-2)
Reviews applicable drawings for information to assure that they are technically adequate and that' appropriate quality control-provi-sions have been included.
3)
Approves 'and/or determines the' disposition of nonconforming items s
or matcrial found.durin'g site activities a's members of the Noncon-
-formance Review Board (see Subs'ection 17.2);
q 4)
Providpr personnel to Supply System Quality Assurance to assist in vendor surveillance activities and to perform surveillance'and l
audits,of. site contractors' and AE's home office activities, as requested.
1 b.=
Business Mananement i
1).
Review and approve equipment and construction specifications, and i
r.hanges thereto,: to assure that the contractual requirements delineated ~in the bidding documents and the'generaliand special conditions sections provide Supply System with.the requirements necessary to administer the contract effectively;
[q 2)
Administers the contracts to assure'that activities affecting
. quality are performed in accordance with the requirements specified in the procurement documents, and that'when nonconformances are identified, approved corrective action is implemented in a timely l
and effective manner.
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Review and approve equipment and construction specifications, and y
significant changes thereto, to assure that PSAR/FSAR commitments and regulatory requirements are included and met.
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17.1-7 4
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. Plant Operations 21):
Responsible' forithe; review and approval of specifications,;and J
significant. changes thereto',;for the operability and maintainabi-H lity of. the equipment, systems :and. structures ; '
q 2)
'Provides personnele to Supply S stem Quality Assurance to assist in-
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, vendor surveillance activities and to perform other surveillance '
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- and, audit functions, as requested.
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Construction fianagement 1):
Responsible for quality of the construction work,-implementation of j
, schedules and cost control technique as well as implementation of the policies 'and overall objectives.of 'the Supply System.
.2)
- Responsible for construction. contract' performance, including '.
.r verifying ac'ceptability -of contract change orders, to. assure _.that
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activities aro performed in accordance with the requirements
- specified in the contract-documents, and.that when nonconformances; are tidentified,; steps are taken to stop'the. nonconforming activity -
j
'and to' assure that resolution is implemented in a timely. and effec-
-tive manner.
3)
Responsible'for Preventive and Corrective Maintenance Activities.'
4 )'
Resonsible for receiving, handling and storage'of Project j
4
' mate rial /equipmen t.
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Major organizations :to' whom. Quality Assurance functions have been delegated
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a)
United Engineers and Constructors, Inc. -(UE&C)-
1 Architect 1-Engineer. and 0A Services
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-b)
' Babcock &'Wilcox (B&W)
~ Huclear Steam Supplier b:
UE&C has been contracted to provide overall Architect-Engineering for the
.i LProject. As AE, UE&C is resporisible' for generation of specifications for procurement. of-repurchased equipment and construction services.
These l-contract specifications are sent to the Supply System for review and approval priori to award 'of contracts.
The ~ administration of specifications is per-g',
4 formed ~ jointly by the Supply System and UE&C for repurchased contracts.
The
-QA responsibility includes Home Office-QA, vendor surveillance and site QA.
(See: Section ~17.2)'
B&W has' been contracted.to provide the Nuclear Steam Supply System which l
= includes 'the responsibility for' the QA and Quality Control activities j
Lassociated with their scope;of supply.
(See Section 17.3) l l
4 17.1-8 l
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4 WNP-1 PSAR 17.1.2 Quality Assurance Program The Supply System QA Program described in Section '17.1 is currently in effect for ongoing quality functions.
Section 17.1. delineates in detail' the intent and substance of the Supply. System QA Progran. The Supply System. Program is based upon the Quality Classification as assigned to the structures, com-i ponents, and systems in Tables 3.2-1 and 3.2-2.
. Structures, components, and systens are classified as Quality Class I, II Augmented, G Augmented, II and G in accordance with their design basis or functional requirements.
The applic-able requirements of Appendix 'B..to 10CFR50 are applied to those items classi-fied as Supply System Quality Class I due to their relationship to a nuclear safety function.
Those items classified as Supply System Quality Class II Augnented, G Augmented, II or G are not safety related and are not subject to the requirements _ of Appendix B to 10CFR50.
Supply System Quality Class II Augmented or G Augmented meet the applicable requirements of the NRC Branch Technical Positions for Radioacti.ve Waste and Fire Protection Systems respec-ti vely.
Supply System. Quality Class II or G are required to meet applicable comnercial standards.
The Supply Systa quality assurance classifications are as follows:
Quality Clcss I - Any nuclear structure, system, subassembly, component or design characteristic that prevents or mitigates the consequences of a postulated accident that could cause undue risk to the health and safety of the public. All safety-related items fall within this category.
- The Supply System QA Program defines non-safety related items as follows.
Quality Class II Augmented - The liquid radioactive waste system and those portions of the solid radioactive waste systems which contain liquid waste.
Quality Class G Augmented - Those portions of the fire protection system protecting safety related equipnent or protecting areas which contain potential fire hazards to safety related equipment.
Quality Class II - Any structure, system, subassembly, component or design characteristic which, as a result of.being defective, could cause a safety hazard to plant personnel, an extended reduction in unit output, an unscheduled unit trip, or equipment damage.
Quality Class G - Any non-nuclear portion of the plant to which QA requirements are assigned in accordance with the consequence of failure and operating costs.
If necessary, Quality Class G can be upgraded to l
Quality Class II.
The Supply System Quality Assurance Program fianual contains the written policies and procedures structured from the requirements of ANSI N45.2-1971 l
and 10CFR50, Appendix B by which the Supply System performs its related quality assurance activities.
A matrix of the Supply System QA Program proce-dures and the corresponding criteria of 10CFR50, Appendix B appears in the l'
tabic below followed by description of the scope covered by these procedures.
17.1-9 1.
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'I HCFR50, Appendix B Criteria Supply System 'QAR
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-I Organization
- QAR-1 II Quality Assurance Program QAR-2 III Design Control QAR-3 IV Procurement Document Control QAR-4 Y
Instructions, Procedures and Drawings QAR-5 VI Document Control QAR-6
.VII Control of Purchased Material, Equipment
-QAR-7 and Services-VIII Identification and Control of Material, 0AR-8 Parts and Components IX Control of Special Processes QAR-9 I
X Inspection
' QAR-10 XI Test Control QAR-ll XII Control of Measuring and Test Equipment QAR-12 XIII Handling, Storage and Shipping QAR-13 XIV' Inspeci. ion, Test and Operating Status QAR-14 XV Nonconforming itaterials, Parts or Components QAR-15 XVI Corrective Action QAR-16 XVII Quality Assurance Records QAR-17 XV III - Audits QAR-18 17.1-10
WNP-1 PSAR a.
Organization, QAR-1 Establishes an organizational structure that will direct the resources of the Supply System and its contractors to engineer, design, procure,
' fabricate, manufacture, install, construct and test the Supply System Huclear Projects to maximize safety, reliability and efficiency.
b.
Program, OAR-2 I
Defines the Quality Assurance Program established by the Supply System for design. and construction.
Included in this program is a system for classifying structures, systems, components, design characteristics and procurement documents to determine the Quality Assurance activities associated with each item.
c.
Design Control, QAR-3 Establishes a system of independent reviews to assure applicable quality, regulatory, code and design basis requirements are properly translated into design and procurement documents for each structure, system and com-ponent. The documented review provides a check for design adequacy, inspectability and compatibility with intended usage, d.
Procurement Document Control QAR-4 Establishes c system to assure that procurement documents and changes thereto incorporate the technical and quality assurance requirements necessary to assure the quality and integrity of procured material, equipment and services, e.
Instructions, Procedures and Drawings, QAR-5 Establishes system defining the requirements and responsibilities con-trolling the preparation, review, approval and release of instructions, procedures and drawings which implement quality requirements.
f.
Document Control, 0AR-6 Establishes a system to control the issuance of documents, including changes thereto, which prescribe activities affecting quality, g.
Control of Purchased ttaterial, Equipment and Services, QAR-7 Establishes a system to assure material, equipment and services are procured in accordance with the requirements specified in the procurement documents.
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Identification and Control of Materials, Parts and Components, 0AR-8 4
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. Establishes fa' system for the identification-and control of material,.
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, parts,Jcomponents, equipment"and partially completed assemblies to assdre 1
- thatjitems < incorporated into the plant are of proper configuration and,'
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.when.'necessary,' traceable tolall supporting quality assurance documen tation.
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Control of. Special Processes, 0AR-9 i
s Establishes:a system for the control of special processes.
J.-
Inspecti on, ' 0AR,
y Establishes = a-system which assures the program requirements for inspec-tion are delineated in the specifications and contracts'and assures that.-
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. inspection and' surveillance activities are performed in accordance with-
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' pre-determined requirements. delineated -in written instructions in 'a.
. planned and systematic manner.
k'.
-Test: Control, 0AR-11 Establishes 'a system.to assure that plant testi.ng ; activities ~are-per-(formed in accordance with pre-determined requirements, approved and
- delineated in written instructions.
- 1.-
Control" of fleasuring and Test Equipment, 0AR-12 Establishes a system 'for' the1 control, calibration and adjustment of.
tools,-gauges,' instruments and other inspection, measuring,: testing and maintenance devices at -specified periods.to; assure the useage;of proper
. type, range'and accuracy necessary to verify conformance to established requirements.
m.
Handling, Storage and Shipping, 0AR-13 4
Establishes system to control the handling, storage, shipping, cleaning.
J and preservation of' material,-parts, components and equipment in accor-dance with written and approved procedures, instructions' and recommenda-tions, to assure that the designed integrity and functionality of the i
item are naintained.
n.
Inspection, Test and Operating Status, 0AR-14 Establishes a system to indicate the inspection, test and operating status' for all structures, systems or components to preclude the inadver-tent bypassing of their inspection and test requirements and to prevent ll their inadvertent operation.
17.1-12 1
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Nonconforming'a Material.'I Parts or ' Components ;' 0AR-15'
. o.1 Establishessa; system to askure thst nonco'nfdrm'a'nces! are identified. docc--
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mented, s'egregated or otherwise. controlled, previnted f rom inad'vektent i
b Tuse or installationjand that notification;of-actions ~taken-is transmitted yd Lto theJaffected partie's.
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' Corrective Action'. ' 0AR-16' '
o,r-Establishes.a system;to assure that significant. conditions adverse to -
quality are identified, the cause determined,-documented, brought to the H
attention of, upper management, corrected as soon as possible and!that-
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. measures' are; taken to..proclude repetition.
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Quality ' Assurance Records.' OAR-17 Establishes 'a' system for the control and maintenance ;of 'all records
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sufficient and'necessary,to provide objective evidence of the activities 4..
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. "affecting quality,
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L Audits. 0AR-18 '
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Establishes a. system of audits to be performed in a planned and systema-1 tic manner to verify' compliance and effectiveness of the Supply. System 4
QualityLAssurance Program.
c The Supply System Quality Assurance Program was in ef fect during' the.prepara-
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LSupply System Quality Assurance.is responsible for. establishing Quality 'Assur-J-
lance' policy, goals, and objectives through the development and administration.
of the Supply System QA Program.. This program is defined in the Supply System-
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-QA Program Manual developed by the Manager, Programs & Audits,'and reviewed
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~and' approved by the Director,' Licensing and.~: Assurance and endorsed by the j
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W Managing Director.
JSupply-System QA personnel have'the authority.and responsibility.to perform l
anygactions necessary, including Stop Work Authority, to ' accomplish their^ man-datelas delineated in the Quality Assurance Manual.
This responsibility andf authority 11s stated in a Management Statement signed by the Supply System
' Managing ~ Director. The Management Statement' appears in each Quality Assurance
~
Manual,. and is included as Figure 17.1-4.
In matters of conflict regarding
]
- Quality Assurance policies or the Quality Assurance organizational authority j
.to enforce them at the working level, the Director, Licensing and Assurance
~has direct access to all levels of upper management including the Managing' Director for satisfactory resolution.
ij l
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- f WHP-1 PSAR To ' assure that Supply' System personnel performirig quality related activities are ' knowledgeable of procedures and requirements, and will be proficient'in implementing them, the Supply System Quality Assurance Training Program under coordination'and direction of Corporate Licensing and Assurance is established l
and documented as required by the applicable Supply System Quality Assurance l
Training. Procedure and implementing instructions.
This Training Program consists of:
j a.
The' initial formal training and orientation one receives as to the pur-pose, scope and implementation of applicable codes and standards, includ-ing 10CFR50 Appendix B. :This initial training phase also includes specific detailed instruction on the Supply System QA procedures an'd instructions, project specific procedures and other. activities which L
directly relate to the employee's job functions.
Supply System super-i visory personnel also indoctrinate and train personnel performing quality 1
related activities in the principles and techniques of the activity being performed.
b.
on-going instruction by lecture, discussion, and pre-planned presenta-tions, supplemented by outside courses as deemed useful.
In addition to the training delineated above, Quality Assurance personnel will receive trainingc to provide them with an understanding and appreciation of the i
management of an effective Quality Assurance program.
QA personnel will 1
receive orientation and indoctrination to position responsibilities, and to applicable codes and standards.
This training may be augmented by both inhouse training and attendance at appropriate industry sponsored training i
sessions, the' extent of which will be determined by an evaluation of the prior QA experience and knowledge of the employee, and the comparative requirements of the current QA position.
After this training has been completed, such
. individuals will be assigned initial work under the direction and guidance of j
qualified, experienced personnel (e.g... Lead Auditors) and will receive on-the-job training to establish and maintain proficiency.
The Supply System position on NRC Regulatory Guide requirements is stated in Section 3.12.
These requirements are verified as being included in the design specification during the design review process described in Subsection 17.1.3.
The Supply System QA Program will comply with the requirements contained in 10CFR50, Appendix B, and will comply with the guidance contained in the Supply Systen positions (Section 3.12) for NRC Regulatory Guides, the NRC's Gray j
Book, " Guidance on Quality Assurance Requirements During Design and Procure-nent Phase of Nuclear Power Plants-Revision 1", and the.NRC's Green Book,
" Guidance on Quality Assurance Requirements During the Construction Phase of Nuclear Power Plants".
The Supply Systen QA Program's scope, implementation, and effectiveness is audited by the Corporate Audit organization.
Copies of all audit reports and correspondence are routinely routed to Supply System Project Management, and Project Quality Assurance so that management can regularly assess the effec-tiveness of the Quality Assurance Program.
17.1-14 i
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_ Additiona.lly; -om an1 annual. basis, management will arrange for an independent audit and evaluation of. the ' adequacy of' the scope, implementation,- and effec-j J
y < iti.veness of the, Supply System QA Program. - This will beiaccomplished by know-p~g,
1 q<
fledgeable: personnel outside the Quality Assurance. Organization to assure d
[W achievinq 'anf objective program assessment.. Results from this independent i
- review will trreported to. the Managing ~ Director.
l 1Thel Supply System requires its Quality Class I contract _ ors, ' including UE&C'and'
' U B&W, to, establish.and inplement. Quality Assurance Programs consistent with the J
V, applicable" Criteria of 10CFR50, Appendix B.
The Quality Assurance programs of
$ 'f'
,, l:UE&C;and, R&W are reviewed for compliance. with Appendix 8 by the Supply
?
1 System.' Quality: Class I contractor's Quality Assurance programs are reviewed l
W for compliancelwith Appendix B by UE&C.
A The' details of tihe UEAC and B&W QA. Program are described in Sections 17.2 and:
a" (17.3 respectively.
ye 17.1.3-
' Design Control
}
The' Su'pplyl System has: organized, and is following, a system of design review
'.fa
- and,ipproval by.QA, Engineering, Licensing, Operations, and Project Management
!of Supply: System and _UE&C ' generated procurement documents for Supply System
- %Qua.lity Class I systems, structures, subassemblies, components and design y'
characteristics.
UE&C~ Engineering has been assigned the responsibility to g
review the remaining design contractor's procurement documents.
- [qi JIn allicases, prior'to' submittal to :either the Supply System or UE&C for-G l
- reviewland/or. approval, the < design contractors, including.UE&C, are respon-ssible for veHfying that; the design meets the requirements of the.specifica-i tion,11stcommensurate with ' good. design: practices and that the components can l
4 be readily. inspected.
This verification is achieved 'by the performance of J design reviews, the use of alternate or simplified calculation methods, 'or by
/
- the' performance of a suitable testing program.- The verification or checking pr_ocess-is perforned by individuals or groups other than those who performed a
the'originaT design.: Where a test program is used to verify the adequacy of a
]
. specific 1 design. feature in lieu of other verification or checking processes, i
it(includes. suitable, qualification. testing of a prototype unit under the most j
(adverse design conditions.
Design control neasures are applied to items such
]
as thel following:
reactor physics, stress, thermal, hydraulic, radiation, and J
accident analyses; compatibility of material; accessibility for inservice reinspection, maintenance, and repair; and the delineation of acceptance j
- criteriaLfor inspections and' tests.
1
(
. Supply System Prnject Engineering has the primary responsibility for the l
ttechnical review aid approval of Supply Systen and UE8C generated repurchased
)
f
> equipment' and construction specifications.
Each discipline, mechanical, l
'.f
' clectrical, ' nuclear, and civil reviews the specifications to assure they are Technically adequate.
The depth of this review is outlined in an engineering
]
- design. review che:k list utilized by the reviewing engineer for each Supply 1
' System Quality' C? ass I specification. ' The design review check list cutlines a y,
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I jrevidw 'of:
1)Ldesignirequirements, including the appropriate section of the PSARtan'd referenced Regulatory requirements; 2) codes andistandards require-6 ments; 3) classification.of characteristics; 4) materials-selection adequacy; T ',
- S) testing requirements;.6) welding ' requirements; 7) identification and-serialization; and ' 8) preservation, packagi.ng, and handling.
S. u
~ Supply Systen: Licensing reviews-and approves the. specifications to assure s ? conformance to ' PSAR/FSAR and other-regulatory Leequirements.
t
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JSupply System Operations reviews and approves, the specifications to assure
' s that the: item being specified can be. inspected, L operated and. maintained.
) Supply System.P'roject; Management reviews and: approves the specifications-to
. assure:that the: general and special conditions sections contain adequate
' requirements: for contract administration.-
p' 1
M 1 Supply.. System,QA reviews and approves th'e specifications. to assure that ade-quate requirements 'are included in the specifications.
The QA review assures-
- that: 1) the. specifications /contain the.necessary QA requirements; 2) the test and speciale processes are*properl
' acceptance / rejection criteria; 3)y identified and contain appropriate codes and standards are correct;;4) Quality
" Classifications are identified;.and, S) the. applicable generic sections of
-: welding, cleaning,;and packaging are included.
.Stipply _ System QA signs the' Design' Review Route Sheet to indicate review of Comment? Issues, and signs the' Comment Issue Approval Sheets after assuring the glQA; requirements are included land.that the specifications have been through the
- g. required Supply: System design review. - (See Subsection.17.1.3.1 )
y.
W EDesign chan. gest including field changes, are subject 'to design control r
leasures commensurate with those applied to the original design and are i
.spproved by thetorganization that performed the original design unless the Supply: System has designated another-responsible organization.
l
+
Documentation-pertaining to design control of Supply System Qttality Class I
~
' procurement documents will become part of the objective evidence of the iguality of.the applicable items, 'and will be filed and maintained in a trace-l able, retrievable, systematic manner.
The details of the design control measures implemented by UE&C and B&W are described in Section 17.2 and 17.3 respectively.
-The Supply Systen QA Program requiret that Supply System and UEAC generated procurement-documents be. reviewed and approved to verify that requirements have:been included which provide for the development and implementation of a
' Quality Assurance Program for Supply Systen Quality Class I items and activi-ties which specifically comply with 10CFR50, Appendix B criteria.
In addi-ti^on,' the contractors and ver. dors of: Supply System Quality Class I items and activities are required-to have Quality Assurance Programs which comply with ANSI 41.45.2-1971' and additional requirements as delineated in the procurement
~
documents.
I 17.1-16 m.m.
WNP-1 PSAR l
The procurement documents specify that the contractors and vendors of -Supply System Ouality' Class I items and activities develop and implement design and interface control ~ procedures which assure:
. The translation of regulatory requirements and design bases correctly.
a.
into the design documents; b.
The incorporation of appropriate ' quality standards with deviations and changes being controlled; c.
The application of design control measures to such items as:
reactor physics, stress, thermal, hydraulic, radiation, and accident analyses; compatibility of materials; accessibility for inservice inspection, main-tenance, repair; and specifying criteria for inspection and test; d.
That proper selection and accomplishment of design verification or check-l ing methods such as design reviews, alternate calculations, or qualifica-tion testing is performed. Where a test program is used to verify the adequacy of a design, a qualification test of a prototype unit under the most adverse design conditions will be used; e.
That ind_ividuals or groups responsible for design verification or check-ing are other than those who performed the original design; j
f.
Design and specification changes, including field changes, are subject to the same design controls that were applicable to the original design; g.
Design documents and revisions thereto are distributed to responsible j
' individuals in a timely manner and controlled to prevent inadvertent use i
of superseded material; h.
Errors and deficiencies which adversely affect safety related structures, systems-and components in the design process are documented and that appropriate corrective action has been taken; i.
Design documents, design reviews, records, and changes thereto are collected, stored, and maintained in a systematic and controlled manner; j.
Standard "off the shel f" comnercial or previously approved materials, parts, and equipment (that are essential to the safety related functions of the structures, systems, and conponenets) are selected and reviewed for suitability of application.
17.1.3.1 Supply System or UEAC Generated Specifications and Drawings Supply System or UEaC Engineering prepares Client Comment, Revised Client Comment and Bid Issues of specifications for WNP-1 in accordance with all applicable Codes and Standards and QA Procedures utilizing engineering data generated from Technical Memorandums, Project Criteria Documents, PSAR commit-ments and/or Supply System requirements.
Calculations and specification data are independently reviewed and checked by engineers experienced in the appro-priate engineering discipline.
17.1-17 I
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.WNP-1 PSAR E
.. Supply System.or. UE&C Engineering prepares specifications and associated
' drawings which are reviewed and approved internally..The Client Comment Issue i
of the specifications are:then sent to the Supply System for. review ~and a pp roval.'
Client Comment Issuesiare received by the. Supply System and are assigned to a Reviewing Engineer.~- Copies of the Client Comment Issues are also assigned to Supply System QA, Licensing, Operations, and Project Management.
Each disci--
~
pline reviews the specification-in accordance with the Supply System design i
review procedures and checklists.
The Reviewing Engineer is responsible =for li the overall, review, obtaining signoffs from the reviewers, preparation'of the Y
Comment / Resolution form for resolution of comments. For UE&C prepared speci-fications the forn is transmitted to UE&C for resolution; for Supply System i
prepared s' specifications the form ~ remains with the Reviewing. Engineer for resolution.
Pages and drawings which;are affected by the Sup' ply System review are cor-(
rected and issued as a Revised Client Comment Issue.. This document is reviewed.to assure that comments have been resolved and incorporated based on
.the1 Comment / Resolution form.
The original Supply System reviewers' acceptance is. secured on comments which have been rejected.
Rejections which are
- unacceptable to the Supply System will be resolved and so noted on the
-Coment/ Resolution form.
i A: Bid Issue is' then prepared.and sent to the Supply ' System for final approval.
The Reviewing Engineer reviews the Bid Issue.
The final Supply System approval. is indicated'by the signature of the Supply System Program Director: on the Bid Issue Approval Sheet.
m 17.1.3.2 Contractor and Vendor Generated Drawings and Specifications 1
JWhen a' contractor or a vendor initiates a design he is required to perform
. design review activities in'accordance with internal design review proco-dures.- Upon conpletion of' this review his design' drawings and specifications areLforwarded to UE&C Engineering for interface review.
i UE&C conducts.a review of the drawings and specifications in accordance with j
UE&C procedures which includes measures to control the receipt, approval, and transmittal of vendor drawings, and an approval of the procedures and specifi-cations required to be submitted to UE8C in accordance with the procurement documents.
~
The receipt.of vendor drawings, specifications and other documents is acknow-1 edged by the Supply System staff via a transmittal which lists and describes the material received.
Supply Systen personnel review the attachments to I
' these transmittals on a selective basis and transmit any comments to UE&C for j
inclusion in the document.
1
'.it 17.1-18 j
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1 WNP-1 PSAR 1
17.1.4' Procurement Document Control Procurement of original plant ma'terials, parts, components, and construction activities is generally accomplished through repurchased equipment, construc-tion, and other contracts prepared by the Supply System, or UE&C for the p
Supply System.
Purchasing is accomplished by award of contracts based on
. proposals submitted in conformance with the speci fications.
1 Each proposal is evaluated by the Supply System and UE&C (if UE&C generated).
I
- The evaluations include any exceptions taken to the specification requirements.
l 1
Purchase requisitions / purchase orders may be used, with applicable QA and I
technical requirements included or referenced, to procure equipment, supplies, j
material, parts and services.
.j 1
The Supply System QA Program-requires that Supply System and UE&C develop and I
implement measures which assure that procurement documents are prepared, reviewed, approved and issued under controlled conditions. These control i
measures have been established and are currently in effect. These measures are described in Subsection 17.1.3.
In addition, addenda / revisions require a j
review and approval commensurate to that performed on the original procurement i
documen t.
The Supply System QA Program requires that Supply System and UE&C generated procurement documents be reviewed and approved by Supply System QA personnel.
These reviews verify the inclusion of applicable organizational, program, design control, procurement control, document control, identification, special process, inspection, testing, calibration, handling, storage, shipping, non-
.l conformance control, corrective action, record retention, record control, record maintenance, audits acceptance / rejection criteria and other quality requirements.
The procurement documents require that contractors and vendors 1
of Supply System Quality Class I items have a QA Program which meets the applicable requirements of 10CFR50, Appendix B and ANSI N45.2-1971.
In addition, the Supply System QA Program requires that Supply System and UE8C generated procurement documents be reviewed and approved by Supply System, and UE&C (if UE&C generated) Engineering personnel. These reviews verify the I
inclusion of applicable design, regulatory, code, material, testing, metal joining, part identification, spare parts, cleaning, preservation, packaging, l
handling, storage, shipping, installation and other design and procurement related requirements.
l l
The Supply System is responsible for the orientation and training of personnel l
performing quality affecting activities.
The Supply System QA Program j
requires that Supply System personnel performing quality functions be ade-quately qualified, thus providing a mechanism to assure that personnel review-j ing procurement documents are sufficiently knowledgeable to verify that proper i
quality related requirements have been incorporated.
1 i
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The review and app'roval rof Supply System and UE&C generated procurement 'docu.
ments ;is documented by the' Supply System.. This documentation may consist of -
approval. sheets, comment /resolut:f on sheets and applicable-correspondence.
' This. objective evidence: is filed 'and maintairdd in ~ a controlled, traceable, l
retrievable systematic manner.
Documentation lrequirementslare specifically delineated in the procurement y
Ldocuments indicating to the bidders,. contractors and. vendors which documents must be submitted for information or approval.
Procurement documents ~ include requirements which assure the right of. access by Supply System and/or 'UE&C personnel to the contractor's operations or the L'
vendor's ' facilities,'and their records..QA requirements are incorporated in y
procurement documents in accordance with their Quality. Class and complexity.
'Bi.dders on SupplyLSystem Quality Class l' documents are required' to submit with their bids a comprehensive QA Plan describing.their QA system, policies, responsibilities and procedures which will be,.or are being, implemented to
- control quality throughoutlall phases from design to final shipment, erection, fabrication, installation, testing or startup, as. applicable.
'~
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l
. Prior to procurement award, bids / proposals are reviewed by Supply System QA' and Engineering Department personnel with assistance from UE&C QA and l
Engineering Department personnel (i f 'UE&C generated) to determine. the accept--
ability of the proposed QA programs. This evaluation consists'of an examina-i
-tion of their QA Plan, evaluation of past quality performance based on pre-q A-
, vious experience with Supply System, UE&C, and industry experience, and if a.
a
- reasonable judgment cannot.be made or the importance of the activity requires j
Ja QAlevaluation 'of the vendor's> facilities or contractor's operations, then a f
s
- QA' evaluation will ~ be performed.. Af ter completion of the-documented 1
. bid / proposal' evaluation, the Program Director is notified as.to the acceptabi-i llity of.the proposed _QA, program based on his demonstrated ability of commit-ment. to' meet: the procurement ~documen t requirements.
The details of the. procurement document control measures implemented by JE&C and 'B&W are. described in Sections 17.2 and 17.3 respectively.
- 17.1. 5-Instructions, Procedures and Drawings 1
The. Supply. System QA Program Manual delineates the methods by which the Supply 1
System complies.with the criteria of 10CFR50, Appendix B.
Implementation of
.the Supply System QA Program assures control of the activities affecting l
quality.
The Supply System QA Program requires UE&C to have based the development of l
' their QA Program, and the procedures for its implementation, on the require-ments delineated in 10CFR50, Appendix B.
UE&C generated procurement documents require that instructions, procedures and drawings relative to the work being performed will~ be maintained in the general work area and available for reference by the personnel performing the work.
17.1-20
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WNP-1 l
PSAR The Supply System, contractors 'and vendors,. including UE&C ~and B&W, are.
required to have written instructions, procedures, policies and/or drawings which govern their quality related activitics and which include appropriate I
quantitative and qualitative acceptance / rejection criteria.
In addition, contractors and vendors, including UESC and B&W, are required to impose similar documentation requirements on their subcontractors.
The details of the measures which UE&C and B&W implement to assure the development and issuance of instructions, procedures and drawings are described in Sections 17.2 and 17.3 respectively.
17.1.6 Document Control j
Document control is implemented by the Supply System, UE&C and B&W in accor-dance with the requirements delineated in their respective QA Manuals.
These requirements provide $asures to assure that appropriate written
)
instructions, procedures, policies, drawings, and procurement documents, sincluding changes thereto, are properly reviewed and approved prior to release
' by personnel ' assigned review and/or approval authority as delineated by the QA
. P rogram. Changes to these applicable documents require a review and/or approval commensurate to that performed on the original document. These reviews and/or approvals verify the inclusion of adequate quality requirements and evaluate the impact of the changes on other project activities.
Addi tion-ally, issuance of controlled documents is performed by personnel assigned distribution authority as delineated by the-QA Program.
This controlled l
1ssuance is-designed to distribute controlled documents in a timely manner to
'the locations where the applicable activity is being performed and to prevent the use of obsolete or superseded documents.
The Supply System QA Program provides for the controlled updating of the
]
Supply System QA Program Manual through a process that specifically requires holders of a controlled copy of the Supply System QA Program Manual to destroy or return superseded documents, i
Procurement documents generated by the Supply System, UE&C and B&W require that contractors and vendors, including their subcc9 tractors, of Supply System Quality Class I items have document control procedurks in accordance with 10CFR50, Appendix B.
The Supply System QA Program document control measures, as delineated in the procurement documents, require that quality related documentation be avail-I able prior to the perfornunce of the activity to which they relate.
The Supply System QA Program document control measures pertain as a minimum to contract speci fications, contract drawings, QA Program Manual procedures, operating procedures, quality related instructions and various process, test and inspection procedures as delineated in the contract specifications.
17.1-21 I
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WNP-1 i
PSAR i
The details of the document control measures implemented by UE8C and B&W are described in Sections 17.2 and 1,7.3 respectively.
17.1.7 Control of Purchased Material, Equipment and Services As described in Section 17.1.4, procurement for the Project is accomplished through procurement documents (i.e repurchased equipment, construction, and other contracts and purchase requisitions / purchase orders).
Prepurchas?d equipment, construction and other contracts generally contain sections sich describe the general conditions, special conditions and technical specifica-tions which the contractor is required to meet. The requirements of the general conditions, special conditions and technical sections are to assure that purchased material, equipment and services, whether purchased directly or through contractors, conform to design requirements.
Purchase requisitions include or reference the QA and technical requirements to assure the equip-ment, supplies, materials, parts and services conform to design requirements.
Measures to control these activities include a review and approval of procure-ment documents by Supply System; source evaluation and selection, vendor sur-i veillance, inspections, and audits by Supply System and/or UE&C; and receiving inspection of these items upon receipt at the site.
Specifically, QA requirements are incorporated in procurement documents in accordance with their quality class and complexity.
Bidders on Supply System Quality Class I repurchased equipment, construction and other contracts are required to submit with their bids a comprehensive QA Plan describing their QA systems, policies, responsibilities and procedures which will be, or are being implemented to control quality throughout all phases, from design to final shipment, erection, f abrication, installation,. testing, or startup, as applicable.
The Supply System QA Program requires that surveillance of contractors and vendors be performed in accordance with written procedures, and that surveil-lance activities be planned and designed to verify and document that the contractors and vendors are conforming to the requirements of the procurement documen t.
In addition, the Supply System QA Program requires that receiving inspection of items at the site be performed in accordance with written procedures, and that receiving inspection activites be planned and designed to verify and document that the material, equipment, or component being received conforms to the requirements of the procurement documents and that the required documenta-tion is available at the site prior to installation or use.
The Supply System QA Program requires that received items will be stored and handled on a controlled basis with nonconforming items being processed in accordance with the requirements described in Subsection 17.1.15.
17.1-22 I
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WNP-1 PSAR l
Documentation pertaining to the control of purchased material, equipment, and :
. services will become part of the objective evidence of the quality of the applicable ' items, and will be filed and maintained in a traceable, retriev-able, systematic manner.
The details of the measures which UE&C and B&W implement to assure the control of purchased material, equipment and services are described in Section 17.2 and 17.3 respectively.
17.1.8 Identification and Control of Materials, Parts and Components The Supply System QA Program requires that Supply System and UE&C generated procurement documents be reviewed and approved to verify that requirements have been included which provide for the development and implementation of measures for the identification and control of materials, parts, and compo-n en ts.
In addition, these reviews and approvals assure that identification and marking requirements have been adequately delineated and that the location and method of identification and marking do not adversely affect the function or quality of the subject item.
The requirements which are incorporated into the procurement documents provide for a positive system of identification and control of materials, parts, com-ponents and partially completed subassemblies while in storage, warehousing and holding areas and during their fabrication, manufacturing, installation 4
and construction.
These identification and control measures establish a means by which items can be traced to, and conformance verified with, their applicable documentation.
~
' Verification that the items have been properly identified is to be performed during vendor surveillance activities prior to shipment of the items.
Identi-fication is further verified during receiving inspection at the site to assure that identification status was not adversely affected during shipping and to provide a verification check if the vendor surveillance verification check was waived.
Documentation pertaining to the identification and control of materials, parts and components will become part of the objective evidence of the quality of the applicable items, and will be filed and maintained in a traceable, retrievable systenutic manner, j
1 T he details of the measures which UE8C and E&W implement to assure the identi-l fication and control of materials, parts, and components are described in l
Sections 17.2 and 17.3 respectively.
l l
17.1.9 Control of Special Processes
)
The Supply System QA Program requires that Supply System & UE&C generated pro-curement documents be reviewed and approved to verify that requirements have l
been included which provide for the development and implementation of measures i
I 17.1-23 j
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I WNP-1 PSAR for the control of special processes.. These requirements specify applicable
. codes,-standards, specifications and any special requirements necessary for i
the control of the delineated slecial processes.
'In addition, the procurement documents spect fy that special processes will be performed and controlled in accordance with written procedures and will further delineate which special processes procedures will be submitted to UE&C for inform tion or approval.
The procurement documents will require that procedures be developed to control such special processes as:
a.
Wel di ng -
b.
Cleaning c.
Hea t Trea ting d.
Repairing Essential ingredients of these procedures shall assure that:
a.
Equipment utilized in the performance, inspection, and control of special processes that require qualification shall be qualified to'its intended usage. prior to being installed or used.
b.
Personnel performing any special processes shall be qualified in accor-dance with ' applicable standards prior to the performance of work.
.c.
Data collected in conjunction with the control of special processes shall include the type of operation, results, acceptability, action taken when deficiencies were noted, and the identification of inspector and/or data j
recorder.
.j Special processes, procedures, qualification documentation, inspection and test results will become part of the objective evidence of the quality of the applicable item, and will be filed and maintained in a traceable, retrievable, systemtic manner.
The details of.the measures which UE&C and B&W implement to assure the control of special processes are described in Sections 17.2 and 17.3 respectively.
l 17.1.10 I nspection The. Supply System QA Program requires that Supply System & UE&C generated procurement documents be reviewed and approved to verify that requirements have been included which provide for the development and implerrentation of inspection measures. These requirements specify that inspections will be per-fortred by personnel who are independent from the individual or group respon-sible for performing the activity being inspected.
17.1-24
WNP-1 PSAR In addition, the procurement documents specify that inspection activities will be performed and controlled in accordance with written procedures, instruc-tions and/or checklists. These' procedures, instructions and/or checklists are required to provide for:
a.
The identification of quality characteristics to be inspected.
b.
The identification of those individuals or tne organization responsible for performing the inspection operation.
c.
Acceptance / rejection criteria.
d.
A description of the method of inspection.
e.
Evidence of completion and certification of inspection operation, f.
Record of the resul ts of the inspection operation.
i The procurement documents further require that procedures, instructions, and drawings relative to the work being performed will be maintained in the work
. area and available for reference by the personnel performing the work.
Contractors 'and vendors are required by the procurement documents to speci fy the qualification requirements for inspection personnel, and to assure that l
each inspector's qualifications are maintained current.
The contractors and vendors are further required to perform inspection of modifications, repairs and replacement items, which are made after the initial inspections, in a manner commensurate with the original inspection requirements or to Supply Sys tem and/or UE&C approved al ternatives.
l Inspection equipment is required to be calibrated as described in Subsection 17.1.12.
UE&C has been delegated the responsibility to perform source inspection activities associated with repurchased items.
Supply System Project Quality Assurance performs site receiving inspection of purchased items and sur-veillance of the activities performed by Supply System site organizations and the AE with sufficient sampling to provide assurance that the applicable quality requirements are being implemented.
Pre-surveillance planning devel-opea by responsible organizations will define surveillance requirements, acceptance criteria, and provide documented results to provide objective evi-dence that the particular quality characteristic inspected actually conforms to the speci fica tion requirement.
Source inspection will be accomplished by the UE&C vendor surveillance group from inspection plans developed by UE&C from the procurement documents. This inspection will assure adequa to control of processes to assure that required quality is obtained when inspection is not possible or disadvantageous.
17.1-25
WNP-1 PSAR Surveillance data sheets will betone part of the objective evidence of the quality of the. applicable items inspected, and will be filed and maintained in a traceable, retrievable, systeniatic manner.
The details of the inspection measures and/or surveillance activities imple-mented by UE&C Hone Office, the applicable Project QA organization and B&W are described in Sections 17.2 and 17 ' respectively.
17.1.11 Test Control The Supply System QA Program requires that Supply System and UE&C generated procurement documents be reviewed and approved to verify that the test requirements which are required to be perforned by vendors and contractors are s peci fied. The test requirements include adequate test prerequisites, instructions for testing, proper instrumentation, documentation, and evalua-tion by quali fied, responsible individuals or gr.oups.
The procurement documents require that testing be performed in accordance with written procedures, instructions and/or plans which define the overall inspection and test requirements, the acceptance / rejection criteria and data to be recorded.
.The Supply System QA Program further requires that site testing be monitored in accordance with testing inspection plans which provide for:
a.
An itemized list of the status identification system to be employed (i.e.,
tags numbering sys tem).
b.
An itemized list of the documents to be reviewed or referenced to verify the testing and inspection status of the system or component to be tested.
c.
An itemized list of the tests to be performed.
d.
An itemized list of the testing devices to be utilized.
e.
A detailed list of acceptance criteria together with adequate space to reflect actual resul ts.
~
Construction testing will be performed by the contractors to ensure that the installation of equipment is done in accordance with applicable codes and s tan da rds. These tests include inspection of the equipment during and follow-ing installation, integrity tests to veri fy proper installations, and tests, and inspections to verify cleanliness.
The contractors will be required to implement inspection and Test Plans which define overall inspection and test requirements, criteria for acceptance, and data to be-recorded. These plans shall be approved by UE&C.
Integrity tests,
i.e. hydros ta tic, con tinuity, resis tance, etc. and cl eanliness tests, will be perforned in accordance with UESC approved procedures.
The contractor will be required to provide control of installed equipment in accordance with Supply System equipment tagging procedures.
Upon completion of contractor installa-tion and testing of a given system, all associated inspection and test records 17.1-26
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a.
b' 1
WNP-1 1
- j 1
l will. be' turned over to the Supply -System for review and concurrence with resul ts. System inspections will be performed by the. Supply System to ensure that equipment is installed in accordance with design requirements and that l
the system installation is complete. Following resolution of any discrep-l ancies, contractor tags will be removed, Supply System tags installed, and control. of the system will then be transferred to the Supply System for func-l tional testing -purposes.
Contractor test documentation will become a part of the overall permanent plant testing records.
i l
Test control documentation will bacom part of the objective. evidence of the
. quality of the applicable items tested, and will be filed and maintained in a i
l traceable, retrievable, systematic manner.
The details of the test control measures implemented by UE&C and B&W are described in Section 17.2 and 17.3 respectively.
l 17.1.12 Control of Measur[ng and Test Equipment The Supply System QA Program requires that Supply System & UE&C generated procurement documents and Supply System calibration procedures be reviewed and i
approved to verify that requirements have been included which provide for the
~ development and implementation of measures to control measuring and test equi pmen t.
These requirements specify that:
a.
Procedures will describe the calibration technique, calibration fre-i quency, maintenance and control of all measuring and test instruments, j
tools, gauges, fixtures, reference standards, transfer standards, and non-destructive examination equipment which are to be used in the measurement, inspection, and monitoring of components, systems, and structures.
b.
Allowable deviations from calibration standards (tolerances) will be specified in procedures and submitted to the Supply System and/or UE&C for approval.
c.
Inspection, measuring, testing and maintenance devices are calibrated and adjusted at scheduled intervals against certified standards having known valid relationships to national standards, when such standards exists, d.
Calibration intervals for each device are based on the type of equipment, required accuracy, intended usage, and other conditions affecting inspec-tion, measurement, testing, and maintenance control.
j
(
e.
Calibration standards are mintained, calibrated and used in an environ-l ment having temperature and humidity controls that are compatible with required accuracy and operating characteristics of the standards.
'f.
Records are maintained that indicate the calibration history and the next scheduled calibration date for each controlled device.
17.1-27
y I
\\
WNP-1 l
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l g.
Each. inspection, measuring, testing and maintenance device is properly identified with serial numbers,.or other suitable identification, and has its last and next scheduled calibration dates. clearly indicated.
h.
Devices that have not been properly maintained or calibrated in accor-dance with specified schedules have been identified and removed from service.
i.
An investigation will be conducted and documented to determine the i
validity of previous inspections performed when measuring and test equip-l mnt are found to be out of calibration.-
1 Documentation pertaining to the control of measuring and test equipment will become part of the objective evidence of the quality of the applicable items, and will be filed and maintained in a traceable, retrievable, systematic mnner.
I The details of the measures which UE&C and.B&W implement to assure the control of measuring and test equipment are described in Sections 17.2 and 17.3 i
res pecti vely.
17.1.13 Handling, Storage and Shipping -
The Supply System QA Program requires that Supply System and UESC generated procurement documents be reviewed and approved to verify that requirements have been included which provide for the development and implementation of appropriate cleaning, preservation, handling, storage and shipping measures.
s These requirements specify that procedures will be developed based on the j
requirements of the procurement documents, with consideration. to the need for special tools, equipment and quali Med personnel.
Cleaning, preservation, handling, storage and shipping requirements are incor-porated into t. 2 procurement documents to assure that the item's designed integrity and ability to function are maintained, items delivered to the site are stored, handled and preserved in accordance with procurement documents.
Also, the equipment manu facturer's recommenda-tions are considered. These functions are performed in accordance with approved procedures and instructions.
Site storage, handling and preservation j
are mnitored by Supply System Project QA on a scheduled basis and corrective j
action is taken when required.
Supply System Project QA also has respon-sibility for follow-up of corrective action.
4 During the extended construction delay, handling, storage, shipping and 1
preventive mintenance activities are performed by the supply System in accor-dance with approved procedures and ins tructions which implement the require-I ments of the Supply System QA Program.
1 17.1-28 1
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I Wi1P-1 l
PSAR L
1 Documentation pertaining to the cleaning, preservation, handling, storage and l
shipping of the items will become part of the objective evidence of the quality of the applicable items,' and will be filed and maintained in a trace-able, retrievable, systematic manner.
The details of the measures which UE&C and B&W implement to assure control of the cleaning, preservation, handling, storage. and shipping of items are described in Section 17.2 and 17.3 respectively.
17.1.14 Inspection, Test and Operating Status l
The Supply System QA Program requires that Supply System and UE&C generated J
l procurement documents be reviewed and approved to verify that requirements l
have been included which provide for the development and implementation of inspection, test and operating status measures.
These requirements specify that procedures will be developed to assure that specified inspections and tests are performed, and that the acceptability of the items with regard to their inspection, test and operating status is known throughout the manufac-tur ng, installation and startup testing phases.
i In addition, the procedures are required to specifically delineate the methods by which the inspection, test and operating status of an item will be identi-fied and the controls which will be implemented to control the use of the identification methods.
The implementation of the status identification system will be designed to preclude the inadvertent bypassing of required inspections or tests, unless formally waived, and to prevent the inadvertent j
~
operation of the equipment.
i Documentation pertaining to the inspection, test and operating status of items will become part of the objective evidence of the quality of the applicable items, and will be filed and maintained in a traceable, retrievable, systema-tic manner.
The details of the measures which UE&C and B&W implement to assure implementa-tion of an inspection, test and operating status system are described in Section 17.2 and 17.3 respectively.
17.1.15 flonconforming Materials, Parts or Components The Supply System QA Program requires that Supply System and UE&C generated procurement documents be reviewed and approved to verify that requirements have been included which provide for the development and implementation of measures to assure control of nonconforming materials, parts or components.
The Quality Assurance programs of UESC, B&W, other contractors, subcontrac-
)
-tors, and vendors will provide for the identification, documentation, segrega-tion, review, disposition, and noti fication to affected organizations of 1
nonconforming materials, parts, components, services or other program activi-l ties at any stage of manufacturing, fabrication, erection, or construction to j
prevent their inadvertent use or installation. Written procedures will pro-vide for the handling, processing, dispositioning and reinspection of noncon-forming materials, parts, components, services or other program activities.
WNP-1 PSAR l
Nonconforming items shall be identified and marked with a " HOLD" tag (when i
possible); removed to a " HOLD" area, roped off, or otherwise segregated (when l
practical) to prevent their inadvertent use or installation.
The details of the measures which UE&C an.d B&W implement to assure control of nonconforming material, parts or components are described in Section 17.2 and 17.3 respectively.
17.1.15.1 Detection and Documentation of Nonconformances The detection and documentation of nonconformances detected by the Supply System follows:
a.
Site Nonconformances The Supply System Quality Assurance Program. provides for the identifica-tion, documentation, segregation, review, disposition, and notification to affected organizations of nonconforming materials, parts, components, services or other program activities at any stage of manufacturing, fab-rication, erection, or construction, to prevent their inadvertent use or installation.
Written procedures provide for the handling, processing, dispositioning and reinspection of nonconforming materials, parts, com-ponents, services or other program activities.
Nonconforming items shall be identified and marked with a " Hold" tag (when possible) to stop work or control further processing; removed to a
" Hold" area, roped off, or otherwise segregated (when practical) to pre-vent their inadvertent use or installation, b.
Vendor Nonconformances Nonconforming material, parts, components, services, or other program activities detected by Supply System and/or UE&C during vendor surveil-lance activities will be brought to the attention of the Vendor's Quality Assurance personnel for their initiation of nonconforman~ e control, using c
their procedure.
Failure of the vendor to take appropriate actions will result in appropriate corrective actions initiated by the Supply System or UE&C.
c.
System Nonconformances A system has been established to assure quality discrepancies concerning documentation, procedures, instructions or program activities are identi-fled, documented and corrected and that notification of action taken is transmitted to affected parties.
Quality Assurance personnel review AE and Supply System generated pro-curement documents to assure that requirements establishing a system of corrective action have been included.
This review shall be accomplished in accordance with established procedures.
17.1-30
WHP-1 PSAR 17.1.15.2 Review of Nonconformances UE&C QA is responsible for assuring that a copy of nonconformance documents generated by UE&C Vendor Surveillance and UE&C which identify potentially
-significant deviations (10CFR 50.55(e)/10CFR Part 21) are transmitted to the.
Supply System QA organization.
The Supply System Quality Assurance organization shall assure review of Supply System generated and UE&C transmitted nonconformance documents to assure that proper corrective actions have been taken to preclude the repetition of similar nonconformances, that all applicable nonconformances have been evalu-ated by the Nonconformance Review Board (See Section 17.2), and that those g
nonconformances pertaining to conditions outlined in the requirements of 10CFR50.55(e)/10CFR Part 21 have been properly processed.
(
The details of the measures.which UE&C and B&W implement to assure the control of nonconforming materials, parts or components are described in Sections 17.2 and 17.3 respectively.
17.1.16 Corrective Action The Supply System QA Program requires that Supply System and UE&C generated procurement documents be reviewed and approved to verify that requirenants have been included which provide for the development and implementation of measures to assure that conditions adverse to quality are identified, evalu-ated, corrective action implemented, certified, documented and reported to the appropriate levels of management.
In addition, the cause of significant con-ditions adverse to quality are required to be identified, evaluated, correc-tive action implemented to preclude repetition verified, documented and reported to the appropriate levels of management.
The Supply System QA Program requires that Supply System QA assure a review of nonconformance reports and other significant conditions adverse to quality to assure that dispositions have been effected, proper corrective actions have been taken to preclude the repetition of similar nonconformances, and that items pertaining to the conditions cutlined in the requirements of 10CFR50.55(e) and 10CFR Part 21 have been properly processed.
The procurement documents require the contractor or vendor to take timely corrective action when requested by Supply System and/or UE&C.
This require-ment is in addition to their own procedure for implementing corrective action which the procurement documents specify.
Documentation pertaining to corrective actions will become part of the objec-tive evidence of the quality of the applicable items, and will be filed and maintained in a traceable, retrievable, systematic manner.
The details of the corrective action measures implemented by UE&C and B&W are described in Sections 17.2 and 17.3 respectively.
17.1-31
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1 i
1 j
WNP-1 i-PSAR i
i 17.1.17' Quality Assurance Records The Supply System QA Program requires that Supply System and UE&C generated procurement documents be reviewed and approved to verify that requirements have been includeu which provide for the development and implementation of measures _to assure that documentation necessary to provide objective evidence of-the activities affectin5 quality are generated, reviewed, approved, filed q
~
and maintained.
4 The procurement documents-delineate which documentation is required for objec-tive evidence. The objective evidence requirements include such documentation i
as inspection, test, nonconformance, corrective action and audit reports, as well as procedures, personnel' qualifications, drawings and other procurement documents and related quality documentation.
In addition, the procurement iocuments require tnat contractors or vendors:
I
.a.
Have written measures to control the filing and retrieval of quality records.
l b.
Have quality records which provide. sufficient information to permit-1 identification between the records and the item or activity to which they
- apply, c.
Have quality records which are legible, complete, and authenticated and j
dated by authorized personnel.
i
.d.
Maintain control over the quality records to assure that revisions are performed under controlled conditions in accordance with written pro -
j cedures by authorized personnel.
Revisions will include the'date and l
identification of the person authorized to make the revision.
l 1
e.
Maintain their quality records in a retrievable, identifiable manner.
f.
Have their quality records accessible for review by Supply System and/cr UE&C.
g.
Have quality record storage facilities which are constructed and located to prevent destruction by fire, flooding, or theft, and to prevent deterioration from temperature or humidity conditions.
l The Supply System has the responsibility to receive, store and maintain the a
construction and repurchased equipment quality records at the site during the extended construction delay.
UE&C has been given the responsibility to receive, store and maintain quality records associated with design and ASME Ill Div. 2 activities.
Quality records will be at the site in storage facilities constructed and l
located to prevent the contents from being destroyed by fire, flooding or theft, or deterioration by temperature or humidity conditions.
17.1-32
(s 9
a if L
WNP-1 PSAR L
Supply System QA has the' responsibility to review quality records to-assure their correctness and' completeness.
Quality records are required to be submitted-in accordance with the requirements of.the procurement documents.
Quality' records are utilized to verify that activities affecting quality have in fact occurred, and that they have been performed in compliance.with the
. specified requirements.
Analyses of conditions adverse to quality are performed as indicated in Sub-sections 17.1.15 and 17.1.16.
These analyses utilize quality records as one means of disclosing discrepancies and nonconforming conditions.
- Further, quality records provide the basis upon which dispositioning, and verification of resolutions are accomplished.
Safety related equipment will not be installed until it is assured that either-the documentation proving that the equipment does in fact meet-the specifica-tion and code requirements is at the site, or a certification is received stating that this documentation is available and will be furnished, signed by an authorized representative of the manufacturer, and approved by Supply System QA.
The details of the Quality Assurance record measures that are implemented by UE&C and B&W are described in Sections 17.2 ard 17.3 respectively.
17.1.18 Audits The Supply System QA Program requires the contractors and veadors, and their subcontractors, to develop and implement a comprehensive system of planned and documented audi ts. These audit activities are required to be performed in
~accordance with written procedures or checklists.
Audit measures are required
. to assure that:
a.
Audits are performed by appropriately trained personnel not having responsibility in the areas being audited.
b.
Audits are conducted periodically based on a preplanned schedule.
c.
Audits include an objective evaluation of quality related practices, pro-cedures, instructions, work areas, activities, items and documentation.
In addition, audits include an evaluation of the effectiveness of imple-menting compliance to specified requirements.
d.
Management action is taken to correct deficient areas.
e.
Follow-up audits are performed to verify corrective action and to evalu-ate the effectiveness of implementation.
Supply System audit activities are performed in accordance with written proce-dures by appropriately trained personnel not having direct responsibility for the areas being audited.
17.1-33
m Q
}
1 a
.i WNP-1 PSAR Supply ~. System audits determine the adequacy of,1and adherence to, the Supply
. System QA Program, and the effectiveness of its implementation. This'is 1
determined.by:
T "a..
The Licensing and. Assurance. Director, Manager, Programs & Audits, and the Project QA Manager review reports of audits performed by the Supply System on UE&C Home Office, NSSS Vendor and the Supply System.
b.
The Project QA Manager reviews reports of audits performed by UE&C an'd.
I Supply System Quality Assurance on UE&C site and vendor activities.
. Supply System audits are performed based on preplanned schedules and audit plans.
-The implementation of each applicable Criterion of 10CFR50, Appendix B, is scheduled to be audited by the Supply System annually.
Additional follow-up audits may be scheduled to verify implementation of corrective action to find-ings identified by audits.
The frequency of audits may be increased or decreased. based on findings.
The scope of Supply System audits include:
a.
UE&C's home office, site and vendor surveillance activities, b.
' 8&W's.home office, site (if any) and applicable manufacturing activities.
4 c.
Supply System home office and site activities.
q Supply System audit results are documented and reported to the appropriate levels 'of management for corrective action implementation. The responses to Supply System audit findings are verified for implementation and effectiveness during follow-up audits.
Documentation pertaining to audits will become part of the objective evidence l
of quality of the applicable items, and will be filed and maintained in a traceable, retrievable, systematic manner.
The details of the audit activities implemented by UE&C and B&W are described in Sections 17.2 and 17.3 respectively.
r 17.1-34
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