ML20236W641
| ML20236W641 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 12/01/1987 |
| From: | HOUSTON LIGHTING & POWER CO. |
| To: | |
| Shared Package | |
| ML20236W640 | List: |
| References | |
| NUDOCS 8712080127 | |
| Download: ML20236W641 (49) | |
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HOUSTON LIGHTING AND POWEP, COMPANY:
,;d QUALITY ASSURANCE PROGRAM DESCRIPTION.: ,
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'l SOUTf1 TEXAS PROJECT ELECTRIC' GEfiERATING STATION .-
, , QUALITY ASSURANCE DURING DESIGN AND CONSTRUCTION f ( , . i
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HOUSTON LIGHTING & POWER COMPANY QUALITY ASSURANCE PROGRAM DESCRIPTION ; Table of Contents SECTION TITLE PAGE
-1.0 Organization 6-2.0 -Quality Assurance Program 15 3.0 Design Control 18 4.0 Procurement Document Control 20 5.0 Instruction, Procedures, and Drawings 22 6.0 Document Control 23 7.0 Control of Purchased Material, 24 Equipment and Services 8.0 Identification and Control of 26-Materials, Parts and Components 9.0 Control. of Special Processes 27 10.0 Inspection 28 11.0 Test Control 29 1
12.0 Control of Measuring and Test Equipment 30 13.0 Handling, Storage and Shipping 31 14.0 Inspection, Test and Operating Status 32 15.0 Nonconforming Materials, Parts 32 or Components 16.0 Corrective Action 33 l 17.0 Quality Assurance Records 33 18.0 Audits 34 2 w_____- - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ . - _ .a
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. .-HOUSTON LIGHTING:&TPOWER COMPANY.-
QUALITY: ASSURANCE. PROGRAM . DESCRIPTION e
. Lis't' of tTable's ', '
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~ NUMBER- -.TITL E '
1 l'. , i% ) R ANSI . Standard'and Regulatory Guide Compliance - ' i' 2 HL&P Manuals Used to Implement the-Quality' Assurance Program 'N u g c.,'. y List of, Figures m l NUMBER TITLE: o !. 1
-South Texas Project Management Organization' l
2 Construction Management' Organization. 3 Nuclear Assurance.0 organization. d a Nuclear Training Organization. J 4 + 5 Lines of Communication HL&P & BEC/ Westinghouse /ESI/ECI/ Contractors.. ' j l u
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1 j QUALITY' ASSURANCE, PROGRAM DESCRIPTION' South-Texas Project Electric Generating Station Quality Assurance During Design and'. Construction L Houston Lighting & Power. Company (HL&P), as a licensee and'as Project Manager .for itself and the other onners,:has quality . assurance responsibility?
.for deaign, engineering, procurement, fabrication, construction, and operation associated with the South-Texas' Project Electric Generating. Station (STP). Although HL&P has delegated;certain of.its quality assuran'ce authority to its' contractors, it nevertheless retains the responsibility for:
the quality. assurance' program controlling all aspects of the.STP.- HL&P reviews and approves this QAPD and all changes thereto prior.to: implementation. ' Additionally, HL&P establishes fquality assuran'ce requirements for the Project in'a Project Quality Assurance Plan.. The Project Quality Assurance Pl'an specifies requirements applicable to prime.. contractors and HL&P. The'HL&P. Quality Assurance staff' monitors-the performance of HL&P staff and contractors to.. assure compliance with the Project Quality' Assurance Plan.
'HL&P has contracted with Westinghouse Electric Corporation (Westinghouse)for the design, fabrication, and quality assurance services for the nuclear steam supply system and with Bechtel Energy Corporation (BEC)'for plant design, procurement,. engineering, construction management,. quality assurance services and.other related services, including quality assurance services for Westinghouse items upon_ receipt at the Project site'. -HL&P has contracted with Ebasco Services, Inc. (ESI) for quality assurance and quality control and with Ebasco Construction Inc. (ECI) for. construction services'for its scope of work. This quality assurance program description addresses the.
HL&P quality assurance program (Part A), the quality. assurance program of BEC- ' (Part B), and the quality assurance program of Ebasco (Part C). The Westinghouse quality assurance program ~is described in WCAP-8370,
" Westinghouse Nuclear Energy Systems Division Quality Assurance Plan" and is not included in this program description.
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q 1 PART A HOUSTON LIGHTING & POWER COMPANY QUALITY ASSURANCE PROGRAM DESCRIPTION ,l South Texas Project Electric Generating Station Quality Assurance During Design and Construction-l Houston Lighting & Power Company (HL&P), as a licensee and as Project Manager for itself and the other owners, has the Quality Assurance (QA) ] responsibility for design,-engineering, procurement, fabrication,
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construction, preoperational testing and operation of the, South Texas Project (STP) Electric Generating Station. f HL&P's Project Quality Assurance Plan requires that HL&P, .its prime contractors, subcontractors and vendors comply with the criteria established by 10CFR50, Appendix B. It is the intent of HL&P to comply with ANSI N45.2 and the applicable daughter standards and implementing Regulatory Guides as indicated in Table' 1. Furthermore, HL&P will assure through programmatic direction that the prime contractors.and all their subcontractors and suppliers performing nuclear safety-related work comply with 10CFR50, l Appendix B; ANSI N45.2, and the Regulatory Guides as. referenced herein s consistent with their scope of work. Programmatic direction is defined as the role of the owner in establishing the program requirements and ensuring the adequacy of the Prime Design,' Engineering and Construction Management Quality Assurance Program. The l programmatic direction consists of review and approval of the system' features , initially and continued monitoring of those systems if the systems need j strengthening. The assurance of compliance by first level nuclear i safety-related suppliers and contractors will. be -accomplished through the Engineer / Construction Manager's review and approval of the i supplier's/ contractor's Quality Assurance Program. l The system monitoring is achieved through audits and surveillance of work in progress. l The HL&P Quality Assurance Program is implemented in two phases: the design j and construction phase as defined by the Project Quality Assurance Plan and the operational phase, including preoperational testing and startup, as ; defined by the Operational Quality Assurance Plan. The Project Quality Assurance Plan is described herein. The Operational Quality Assurance Plan is described in Chapter 17.2 of the FSAR. l The combination of 'these Quality Assurance programs augmented by definitive- , procedures provide HL&P with the assurance that its quality commitments are - met. 5 l i
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' -1. 0 Organization:
1J The organ.ization charts shown'in.. Figures 1:thsough 5 illustrated
- (a): groups within HL&P, having Lquality responsibilities (engineering, procurement, construction): and' (b). Quality : Assurance-
. interdepartmental relationships for the South Texas Project. '
1.21 The Project Quality Assurance Manager, South Texas Project kis-
- ' responsible:for providing the ' programmatic'directionJand' administering: policies,: goals, objectives and methods'which arei .
- described.inithe' Project: QualityAssurance - Pl an.: 'The'HL&P. Group; Vice President; Nuclear,L reviews and. approves the' Project Quality '
Assurance Plan and 'has ultimate responsibility for Quality-Assurance activities. _ The Project- Quality' AssuranceLPlan describes >
, specific Quality Assurance controis to be established byLHL&P,and the prime contractors; on the South; Texas: Project.
1.3 Two levelsf of control have'been implemented by HL&P to monitor thel effectiveness of the Quality Assurance Programs 'at'the. South Texas'.- Project.
- a. Corporate level contro1 ~ - Corporate 1.evel control is achieved through the direct: involvement of the HL&P. Group'Vice President, Nuclear, and Quality Services audits or vendor; surveillance as described below. The Group Vice President',-
Nuclear, regularlyLmeets with QA management and receives . reports on-the: status of the QA Programs.to. aid him in evaluating the overall effectiveness.: .QualityfServicesTaudits and vendor surveillance are conducted-under;the direction of the General ManagerJ Nuclear ~ Assurance to evaluate-the overall ! program effectiveness.,'of. HL&P;Projecti Quality Assurance, Westinghouse and its suppliers. Quality Services audits'of the Architect Engineer / Construction: Manager's activities may be performed as requested by the Project Quality Assurance 1 Manager.
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- b. Project level control - Project level' control is achieved 1 through Project Quality Assurance Program approval'and monitoring of-the effectiveness of-implementation by HL&P, prime contractors and subcontractors.. The Project: QA' staff-under the direction of the Project Quality Assurance Manager:
prepares the Project Quality Assurance. Plan .andLreviews'and approves the Project Quality Program Manual; for. the~ Architect ~ f Engineer / Construction Manager. The monitoringuis implemented y by scheduled Project audits' performed by qualified auditors. 9 Additional monitoring is accomplished.by Project' QA personnel .j performing unscheduled selected surveillance of..in-process; -i work. HL&P Project. Quality Assurance. also maintains the ! capability to perform: inspection ~ verifications tof_ in-process ~ -l or completed work if ' determined to be necessary byLthe. < Project Quality Assurance Manager. -If necessary the . . inspections are. performed by personnel qualified in accordance , with ANSI N45.2.6. ? 6
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. I'. 4 Group Vice President, Nuclear - ' A
, The' Group.Vice President,! Nuclear,'is responsibleiforfmanagement of? ":
nuclear projects and operating' nuclear. plants and for all nuclear - activities within HL&P. relatedito design, engineering,: .
. construction, operation, and quality assurance. The Group Vice ..
President, Nuclear, provides Ltechnical guidance'and administrative: , direction to:
- a. GeneraliManager, South Texas? Project -
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- b. Manager, Nuclear Engineering , ,
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- c. Vice President, Nuclear Plant 0perations' ._
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(Description'of responsibilities is. contained.in Chapter 17.2, FSAR) o
- d. General Manager, Nuclear Assurance +,
The Group Vice President, Nuclear, reports to the Chairman of the. J Board and Chief Executive Officer.. !' u l 1.5 General Manager, South Texas Project 1 The. General Manager, South Texas Project' reports'to-the Group Vice. President, Nuclear. 4 He'has overall responsibility for the engineering, licensing,s , , construction, procurement, cost, -schedule, and .startup of- the South Texas Project. He has authority to "Stop Work" for'cause;in all a activities of the Project. >
-l, 1.5.1- Unit 2 Project Manager 1 The Unit 2 Project Manager reports. to the General ,
Manager, STP as shown in Figure 2.
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He has overall responsibility for the Unit = 2 Construction Startup, Engineering,. Licensing, Records' Management, , y Cost and Schedule'activitiesEof the' South Texas Project, 1 l acting for the General Manager, STP -in' his absence' and/or q stead. He directs the efforts of his. staff and=the prime. i contractors:to insure that Unit 2 is designedi i constructed and tested efficiently Land cost effectively 4 while upholding quality and~ safety, standards. He has' "Stop Work Authority" forlcausetin all' activities ; affecting his area of responsibility.- l 4
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. Manager,' Engineering and Licensing
.The Manager, Engineering and Licensing reports to the Unit 2 Project Manager as shown in figure 2.
He has overall resporisibility for Engineering and. Licensing activities of the South Texas Project acting. for the Unit 2; Project Manager in his absence and/or stead. He provides-the primary' interface with the NRC. He directs the engineering personnel in the performance of the. owner's review of the design and engineering work performed by the prime contractors. He insures that adequate engineering, planning, coordination of solutions to problems, and work priorities are established _ by the prime. contractors. He has "Stop Work Authority" for cause in the engineering and design activities on the project. 1.5.3 Principal Engineer, Project Site The Principal Engineer, Project Site reports to-the Manager, Engineering and Licensing. He is responsible for coordinating the' site engineering interface in the, technical resolution of all site related engineering problems, reviewing field change requests, site initiated design change notices and for monitoring the activities of the prime contractors construction engineering groups, He assists in the release and interpretation of design documents. He can recommend "Stop' Work" for cause in the area of engineering and design within his responsibility. 1.5.4 Principal Engineer, Project Houston The Principal Engineer, Project Houston reports to the Manager, Engineering and Licensing. He is responsible for coordinating the Houston Engineering interface in the technical resolution of all Houston related engineering problems, reviewing Houston change requests, Houston initiated design change notices, and for monitoring the activities of the prime contractors engineering groups. He assists in the release and interpretation of design documents. He can recommend "Stop Work" for cause in the I area of engineering and design within his responsibility. 1.5.5 Principal Engineer, Houston Licensing The Principal Engineer, Houston Licensing reports to the L Manager, Engineering and Licensing. He provides the administrative and technical' support necessary to' ensure that licensing documents are prepared and published so as to be both timely and accurate. l 8 _a
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.si. 4 i .,- ; J t 1' 1.5.6 Manager Project: Controls
;The' Manager, Project Controls.' reports to the Unit'2' Project Manager. .He-is: responsible for directing and monitoring'the cost and. scheduling contro1 and reporting _
activities'for the.projecti 1;5.7- Manager, Records Management / Document' Control'and-
'Information Processing The Manager, Records Management / Document Control 'and-
.InformationJProcessing' reports to'the Unit'2 Project Manager. The' Manager,tRM/DC/IP is responsible for L managing.the Records' Management;personne1'and interfacing; I with the prime. contractors and al1~ Project-organizations' with respect- to the establishment of systems that ,
control, collect, store'.and transfer records.~related to the South Texas Project.
- L 1.5.8 Manager, Project Records' Review Program The Manager, Project Records Review Program.reportsLto the Manager, Records Management / Document Control and Information Processing. -He is. responsible' for reviewing-safety related installation records for technical.
3 adequacy, identification of records: discrepancies,, i returning of discrepant < records to the originating-group for correction, and HL&P final acceptance of the records.' This review is a joint effort between Ebas'co, Bechtel'and l HL&P. l , 1.5.9 Startup Organization ]
)J NOTE: The detailed discussion of the startup j organization is contained in the Operations Quality Assurance Plan (0QAP). :
1.5.10 Manager, Construction ' The Manager, Construction reports to the Unit 2 Project Manager. He is responsible for 'providing technical 1 l ' direction'and administrative guidance to HL&P and its + 4 prime contractors in the area of construction,. j construction control and reviewing documents, drawings ; and specifications 'related to construction.. He provides ! direction to Site Security,'with respect to the- ' Construction-organization. He is responsible for ! ensuring that the prime contractors comply with all ; contractual and ' construction requirements. He monitors the prime contractors construction in the areas of l construction plans, schedules,' work methods, craft L ' performance, staffing, equipment utilization and progress. He has-the authority' to "Stop Work" for cause in all activities related to construction. 1 9
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g J! 3 1.5.11 Supervisor, Project' Services and-Administration' The Supervisor 6bject; Services and Administration - reports to the General: Manager South Texas Project. j He .is' responsible' for. assuring' proper review and.n coordination of all Project procedures, maintenance' ofi . j the'STP forms control program, maintaining a controlled . req'uired reading program'for the STP Project.Teamiand the 1
~R review of,non-project procedures >to ensure consistency, 1 with Project requirements.and objectives.
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1.6 General Manager,' Nuclear Assurance The General Manager, Nuclear Assurance,.has thefauthority and-responsibility .to . identify, initiate,' recommend, . or provide - : solutions to quality related. problems and verify lthe implementation 3 and effectiveness of the solutions.. He has.the authority to "Stop' Work" for cause in the design,: construction, and operation phase of.
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the nuclear plant. The minimum requirements established for this . position are: a) JA ' college degree in a' field of engineering or. science,- or. equivalent experience', b) Familiarity with nuclear. power generation. facilities and,the; related operations. c ). - Knowledge-of the industry's quality assurance standards and regulatory. requirements, d) Management experience and familiarity with HL&P corporate: - organizations. The General Manager, Nuclear Assurance, provides techn'i cal guidance , and administrative. direction to: e) ' Project Quality Assurance-Manager f) Quality Services Manager' g) Operations Quality Assurance Manager
'(The responsibilities iof the Operations' Quality: Assurance A .
Manager are described in Chapter 17-.2,:FSAR). h) Engineering Assurance Manager l The General Manager, Nuclear Assurance,Lreports to the: Group Vice: President, Nuclear.
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- 1. 6.1; Project Qua11ty Assurance Manager,iSouth'Tdxas'Projest' ilq 4
., ' The Project Q'uality Assurance Manager, S6uth Texas 1 Project.(PQAM)-has the responsibility to identify, . q initiate, recommend, or provide solutions and authority; ' '
to solve quality related problems. and to verify the< . implementation =and effectiveness:of. the solutions.mHe9 has'the. authority to "Stop Work" for.cause of any quality-related; activity during tthe. design and. construction phase.of the South Texas: Project. 'The Project. Quality ' Assurance Manager, South Texas -Project,L- .t
;y must', asca minimum, have:.
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q (q a) A college degree in a field of engineering or-science, or equivalent ' experience. b)- Familiarity;with nuclear' power generation- facilities. and related' operations. c) ' Knowledge of the QA standards and regulatory , requirements'. d)' ; Management experience.and familiarity with'HL&P corporate organizations. The major responsibilities of the Project Quality Assurance Manager.are: e) Develop and administer QA policies,' goals, objectives, and methods which ensure the proper planning, development, implementation, coordination and administration of the: Project Quality Assurancel Pl an. ; f) Provide programmatic direction Lon QA related matters of HL&P, and contractor management.- g) Direct the onsite audit and surveillance ' activities; direct audits / surveillance of,the Engineer / Construction. Manager's QA program implementation in the design office. h) Coordinate activities relating to. auditing and. vendor surveillance in conjunction with.the HL&P Quality Services Manager.. The Project Quality Assurance Manager reports on:all- o Quality Assurance matters directly to the General 1 Manager, Nuclear Assurance. 11 j u
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3 i i i i 1.6.2- Project QA Supervisor - Analysis ] The' Project QA Supervisor:- Analysis reports directly to the Project QA' Manager. He is responsible for assisting in development of QA programs and procedures, provides ,j input for responses to NRC Inspection .and Enforcement - l Reports, performs special studies,, investigations and. analysis of quality programs as requested, provides, fi quality engineering input.into trend analysis, technical .j analysis and corrective action and participates in audits s as requested. He has " Conditional Stop Work Authority" j for cause on any quality related activity during the j design and construction phase of the project at the. site, i 1 1.6.3 Lead QA Specialist - Audits I i The Lead QA Specialist - Audits reports directly to the l Project QA Manager. He _ is responsible for coordinating, -{ scheduling and participating in audits of HL&P, the ' Architect Engineer / Construction Manager, the Constructor and other contractors, and supports special task force efforts and project team studies when requested. He has I
" Conditional Stop Work Authority" for cause on any 1 quality related activity during the design and l construction phase of the project at the site. j 1.6.4 Project QA Supervisor - Surveillance / Effectiveness , !
Inspections The Project QA Supervisor - Surveillance / Effectiveness Inspections reports directly to the Project QA Manager.- .] 3 He is responsible for coordinating and directing l surveillance of HL&P and contractors, directing the HL&P inspection of selected construction and fabrication activities and coordinating with prime contractor personnel. He is responsible for nonconformance identification and assures that personnel within the Quality Control Group are properly certified. He has
" Conditional Stop Work Authority" for cause on any quality related activity,during the design and construction phase of the project at the site.
1.6.5 Quality Services Manager l The Quality Services Manager is responsible for directing l Quality Services activities which are primarily. involved l with plant outages and modifications under the Operations-QA Program, but also includes Vendor Control, Quality Engineering and Quality Systems / Administration i activities performed in support of the Project. The l Quality Services Manager exercises "Stop Work Authority" l for Project related matters through' the Project QA Manager by notifying the Project QA Manager of a deficient condition which could warrant possible stop work. The Quality Services Manager, South Texas Project, must, as a minimum have: 12
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l 1 j a) A college degree in a field of engineering or j science. . b) Familiarity with. nuclear power generation facilities and related operations. c) Knowledge of thelQA standards and regulatory . requirements. d) Management' experience'and familiarity with HL&P corporate organizations. The major responsibilities of the Quality Services Manager are: e) Develop and adm'inister Quality Assurance policies and ensure the proper planning, development, implementation, coordination and- administration of 'j the Operation Quality Assurance Plan. f) -Provide programmatic direction on QA related matters y to HL&P and contractor management. The Quality. Services Manager reports on all Quality I Assurance matters directly;to the General Manager, Nuclear Assurance. 1.6.6 Quality Services Supervisor, Vendor Control i i The Quality Services Supervisor, Vendor Control reports -l directly to the Quality Services Manager, South Texas . ; Project. He is responsible for providing administrative l guidance and direction to the HL&P Vendor Surveillance .l and Evaluation Group. He exercises "Stop Work Authority" through the Quality Services Manager by notifying the Quality Services Manager of a deficient condition which could warrant possible stop work. 1.6.7 Quality Services Supervisor, Quality Engineering The Quality Services Supervisor, Quality-Engineering reports to the Quality Services Manager, for project related activities he reports to the Project QA Manager. He is responsible for providing technical direction and administrative guidance to HL&P Design / Procurement . Quality Assurance personnel, coordinating the resolutions of vendor. problems-identified by HL&P QA and providing programmatic direction to the Engineer / Construction Manager regarding design control, vendor surveillance and auditing functions. He exercises "Stop Work Authority" by notifying the. Quality Services Manager of a deficient condition which could warrant possible stop_ work. 13
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'l.6.8 Supervisor, Quality Systems / Administration- '
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' The' Supervisor, Quality! Systems / Administration' reports'- h
~ directly to the- Quality 5 ervices' S Manager. He is;
- responsible for providi.ngctechnical direction and;:
administrative guidanceito_ the Qualityi.. Systems / Administration' personnel, Redeveloping and'
' maintaining the HL&P Project QA Plan, evaluating"the: l i
Engineer / Construction Manager-and Constru'ctor QA ' programs,i administering the:HL&P: STP QA~ personnel, training - and 'certi fication . program, ? admini strative .. control of HL&PJSTP Project. Quality: Assurance-Procedures.- and providing mechanisms to correct-.the>QA' programs as-c necessary. .He exercises "StoptWork Authority" by. notifying' the~ Project QA Manager .of a' deficient; condition-which could: warrant possible stop Work. . l 1.6.9 Engineering ~ Assurance Manager The Engineering-Assurance Manager reports directly to the General Manager, Nuclear Assurance. .He is responsible for the' planning, ccheduling, and execution oft , independent technical. reviews of-selected design and. ' engineering
- activity performed-by,both HL&P Engineering and, as appropriate, the prime. contractors.-lHe exercises "Stop Work Muthority"'by notifying the' Project QA Manager,. Quality Services.Ma'ager n or Operations QA-Manager as appropriate,. of a deficient condition which ,
could~ warrant possible stop work. 1.7 Manager, Nuclear Training i The Manager, Nuclear Training re' ports to the Vice President, , Nuclear-P1 ant Operations. 'He directs,; coordinates, and administers the STP nuclear training efforts and provides direction to the , prime contractors relative to training. . The STPEGS Nuclear d Training program includes-the' Quality Assurance Indoctrination for :1 HL&P personnel associated with the safety related activities for { j the South Texas Project. ' l !+ 3 1.8 Manager, Nuclear Engineering' The Manager, Nuclear Engineering reports to the Group' Vice President, Nuclear. He is responsible for directing personnel in the performance of an-owner's review of selected analyses. He is. L also responsible for overseeing and coordinating nuclear. fuel plant design interface support to the STP Project Team. l l L L 14 i
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1.9 The organizations or: entities: listed below:may be delegated Quality Assurance tauthority within their scope of work.. HL&P has the L ;
*;(responsibility'to auditiand monitor:all of the' below listed H organizationsor. entities' performance-to assureLthat their;
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' quality _ programs' provide' sufficient authority-and organizational- a freedom for personnel performing QA functions and that they are- )
- effectively _ implemented.- j 1
a) -Houston Lighting &LPower Company as-a. licensee'and: Project U
' Manageriforiitselfiand the other, owners.has the overa11x M ;
responsibility for" design,' engineering,.. procurement,
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construction,u operation and quality assurance activities. Bechtel. Energy Corporation and. Westinghouse Electric: ., Corporation:have' contractual responsibility to provide. . . 1 acceptable QA programs to HL&P. The contract provides HL&P'
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,the- authorityL to audit and monitorf BEC and. Westinghouse- '
. performance to assure'thatLthe-QA. programs provide'for..
sufficient authority and organizational: freedom to bei a effectively implemented.- " a b). Bechtel Energy Corporation as the Archit'ect/ Engineer' and. L Construction Manager provides HL&P,'with design, engineering,. j i procurement, construction management:and. Quality Assurance j services. y l c) Westinghouse Electric Corporation as'the Nuclear Steam Supply 1 System (NSSS) supplier provides HL&P with the:NSSS design,O j engineering, procurement, fabrication, an'd quality; assurance, 4 services. i 1 d)' Ebasco Services Inc. as the Constructor shall . provide.HL&Pz . with construction quality; assurance (ASME'Section III;only) i and quality control services under the' direction and as ' l approved by the Construction Manager. ' e) Consultants - HL&P utilizes the services of_ qualified' ! consultants to assist in the performance of quality tasks. 1 Figure 5 illustrates how these . companies interrelate'with HL&P t for the South Texas Project. i i 2.0 Quality Assurance-Program 1 2.1 The HL&P Project Quality Assurance Program for the South Texas Project has been developed in accordance with the criteria of' . : 10CFR50 Appendix B, ANSI N45.2'and' Regulatory Guides asl reference' herein,-to provide programmatic direction.on quality requirements: ) for the prime contractors and subcontractors during design and- i construction. l I l j , l 15 : i __m__.____ ___ . . . _ _ _ _ _ _ .
y' -t l 2.2 The nuclear safety-related structures, systems and components covered by this program'a e listed in Section 3.2 of the FSAR. Westinghouse' Electric Corporation provides' quality assurance services for the items listed in Table 3.2.B-1 of- the FSAR until delivery .to'the site. BEC and ESI provide' quality assurance services for the items listed in Table 3.2.A-1 of the FSAR within the scope of their work. BEC provides quality assurance and quality control services for Westinghouse items-(Table 3.2.B-1) upon receipt at the site until release for-construction, after- l which ESI provides such services. , i 2.3 The HL&P Quality Assurance Program for the South Texas Project is described by.the HLLP Project Quality' Assurance Plan. The plan requires that written procedures, Training and Certification, issuance of specifications and drawings, and work and inspection planning be accomplished in advance of performing nuclear safety-related activities. HL&P Project Quality Assurance ensures l through procedure reviews that this advance preparation is I accomplished. j l The Project Quality Assurance Plan for the South Texas Project j } has in the past been structured in accordance with the -l Regulatory Guides (RGs) and Industrial Standards that are 1 addressed in the NRC publications " Guidance on QA Requirements . 1 During Design and Procurement' Phase of Nuclear Power Plants," (The l ) Gray Book) Revision 1 dated May 24, 1974 (WASH.1283) and " Guidance on QA Requirements During the Construction Phase of Nuclear Power j Plants," (The Green Book) dated May 10, 1974 (WASH 1309). l Presently the regulatory guides and standards listed on Table 1 are 1 in effect for the South Texas Project. I 2.4 The HL&P Plans and Procedures Manuals, which are used to l implement the quality related activities for each major HL&P organization, are listed in Table 2. Verification that plans and procedures are properly implemented is accomplished by HL&P Quality Assurance through audits, surveillance, and regular management assessment of the Quality Assurance Program. 2.5 It is the policy of HL&P, acting as a licensee and Project Manager for the other owners for the South Texas Project, to assure that the design, fabrication, construction, testing and operation of STP are in conformance with Project specifications, procedures, codes and NRC regulations. It is the responsibility of each organization assigned to the STP to ensure that Project procedural review l methods include provisions to ensure that the requirements' stated in this program description are incorporated into Project procedures. The Project Quality Assurance Plan identifies activities' and establishes requirements for procedures which identify, initiate and verify the resolution of nuclear safety-related quality problems. The implementing procedures call 16
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l for the' resolution of quality. problems ~ at theilowest possible-
. authorized level. However, if a dispute is encounteredJin the.
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cresolution of. arqualityfproblem which cannot be.L resolved at lower :
' levels, the General Manager, Nuclear Assurance, presents:the:
problem ultimately to'the HL&P. Group Vice President, Nuclear; for < resolution. 2.6 The HL&P Nuclear Training Department is responsible for' conducting: a quality. oriented. indoctrination program for new HL&P' personnel ' .; who have quality-related functions; , The 'HL&P Project -Quality. l1 Assurance Plan -requires;that prior' to performing' activities-affecting'qu'ality the. personnel are; trained, as necessary,LinLthe' applicable procedures. -_The training providos a: thorough-understanding.of the purpose,: scope, policies,i principles,j and~ techniques of the specific procedures or instructions. ,When personnel perform specialJ activities, a. training and certification ' program is established'and maintained. Refresher trainingList conducted as necessary to: ensure that proficiencyLis> maintained. Bechtel is required to establish a: training. program for-Bechtel and-administer the constructor's-training program including refresher. , training as necessary, toLensure proficiency.is achieved and main- 1 tained. Quality Assurance audits and surveillance are performed- g to ensure compliance with these criteria. 2.7 The Project Quality Assurance Manager is.directly responsible ~ for' assuring effective implementation.of the Quality Assurance . + program'. The qualifications'for this position are defined in, Section 1.7.1. 2.8 The HL&P Project Quality Assurance Plan requires BEC to review and approve procedures which control nuclear safety-related construction activities. j It is.the responsibility of BEC's Project Quality Assurance to determine that the contractors s procedures q require proper equipment, environment and other prerequisites'to ; perform the associated activity. . The implementation of; these ' > < requirements is verified'through audits and surveillance performed by either HL&P, BEC or ESI Quality Assurance. 2.9 All quality related activities implemente'd for the South Texas . Project are audited annually at a minimum, or at leastionce within . the life of the activity, whichever;is shorter. These: audits are ; performed by either HL&P,' BEC, or ESI Quality Assurance personnel. 1 Selected areas are targeted and scheduled for more frequent ; auditing based on 'such factors as' complexity, relative- j significance, past performance, etc. Supplemental audits-will also R be performed as described in Section 18, 2.10 The results of the South Texas Project Quality Assurance' audit and: surveillance activities are presented in a periodic ~ report to-the HL&P Group Vice President, Nuclear. Regular executive management review of these activities and the direct' involvement of the HL&P Group Vice President, Nuclear, assures.that;an objective-l program assessment of the South Texas Project Quality Assurance programs is being performed. 17 __ - - __- _ _ _ _ . - . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ a
'l HL&P Project Quality Assurance reviews 'and documents approval' of .
the BEC Project Quality Program Manual (PQPM); and audits and! k; ' surveillance.are performed by either HL&P Quality Assurance or
'Bechtel. Quality Assurance to ensure compliance with.the BEC PQPM.
2.11 HL&P and BEC Project Quality Assurance willEestablish and document a program for transferring responsibilities and controls for quality-related activities from BEC to HL&P during phaseout of - 4 design / construction and: plant. turnover. This. program.will be implemented prior-to preoperational testing. This program will be' in accordance with and consistent with the requirements of this, section and/or 17.2 of the FSAR. . 2.12 HL&P is committed to maintaining the Quality Assurance ' Program Description as an effective and meaningful document to provide programmatic direction to HL&P and the prime contractors on the South Texas Project. .When changes are proposed to the QAPD-for HL&P'or its. prime contractors and those proposed changes reduce the commitments previously established in.the QAPD, approval'by the NRC will be obtained prior to implementation of the change (s). 2.13 When changes are made to the QAPD which alter the program for . . HL&P or its prime contractors and those changes do not reduce the. commitments previously established in the QAPD, appropriate notification will be made to the NRC within .90 days of , implementation. 3.0 Design Control HL&P has the overall responsibility for design and engine'ering of the-South Texas Project and imposes the requirements of 10CFR50, Appendix B, Criterion III, Regulatory Guide 1.64 and ANSI N45.2.11 on the prime con-tractors and applicable subcontractors. HL&P has assigned the authority to BEC and Westinghouse to perform the design, engineering and design verification. HL&P, as appropriate, selects contractors / subcontractors to perform design related tasks. These tasks include but are not limited to the following: New design Special design studies Design work outside the scope of prime contractors Changes to existing design performed by contractors no longer associated with the South Texas Project. 18 L - . - - - _ - . - .
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s... To be eligible to participate inL de' sign activities' the contractor must be approved to assure he has the capability to perform the design lor requested task-infaccordance with-specified' requirements.- When a contractor has been selected, the' HL&P General Manager,'STP,: or designee! '
.shall; ensure that all appropriate design background information with '
which to perform the task ~is provided.' HL&P_ Engineering performs' r'eviews of selected elements of: the' completed design, design documents"and specifications;to ensure that contractual-requirements are met. ,
;The.HL&P Manager, Engineering and Licensing'is responsible for ensuring that engineering activities'are-conducted in.accordance with approved engineering procedures.; The' Engineering organization provides
- programmatic, direction: and overview of the engineering . activities.. The; HL&P Engineering activities are' conducted'in accordance'with Project Engineering Procedures (PEP's).
When HL&P has direct. responsibility or assumes direct responsibility fori G . conducting' design activities, these activities will be conducted in ; accordance with the requirements of this section and/orJthe'FSAR-Section J 17.2.3. j HL&P contractors are; required 'to provide the ~following design ' control. measures in their quality ~ assurance programs: 1 A design control system is established'to document the methods ofe ' accomplishing and controlling essential design activities.:
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q Design documents _such as calculations, diagrams, s)ecifications and drawings are prepared and records. developed such t1at the final , design'is traceable to its sources.
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g Design activities, documents and interfacesLare cont' rolled to-assure that applicable input'such as' design' bases,' regulatory . - requirements,' codes and standards are incorporated'into: the final { design. Design input requirements, including design criteria,.are I documented and their selection reviewed and approved. Design documents include an indication as to their importancectom
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i safety and shall specify the_ quality characteristics, including ;
- materials, parts, equipment'and processes; that are essential to safety-related aspects of structures,_ systems, and components. :
Design documents also include, as appropriate, acceptance criteria - for inspections and tests. Design control measures are. applied to safety-related items such 'as-L seismic, stress, thermal, hydraulic, radiation and'accidentL analyses, as they apply to the _ development;of design input or =as they .are used to analyze the design.7 ' o , 19 4 e
Safety-related ' designs, including Seismic Category. I designs, are verified for adequacy and accuracy through independent: objective 3
' review of' design documents by. individuals competent in the subject ; 1 activity. This verification may ~ include the~ use. of alternate or- ,
simplified solution methods or qualification testing, as appropriate. . 7 Design changes, including engineering, vendor and construction 1 originated changes; are controlled in;a manner commensurate with, ! the control imposed on the original design. Document distribution' is controlled such that all' individuals using a design document or its results and/or conclusions for.further ; design work can be notified if the document is revised or 1 cancelled. , 1 Design documentation includes evidence that design control require . . ments have been satisfied. Errors and deficiencies in approved design documents, including design methods (such as computer codes), that could adversely 1 af fect safety-related structures,. systems and components are documented; and action taken to assure that all errors and deficiencies are corrected. ) 6 Deviations from specified quality standards are' identified and-1 procedures ~are established to ensure their: control. - An accurate definition of the quality classes, including systems ! designated as safety-related is'provided. { Quality Assurance audits are performed by either HL&P or'BEC Quality f Assurance personnel of HL&P, BEC and Westinghouse to ensure.that design -; controls, requirements, specifications and documents are in accordance ! with the design control criteria. 1 l In addition, HL&P Project Quality Assurance reviews selected '4 quality / construction procedures to ensure that the quality requirements .; of the design specifications are incorporated. Quality Assurance audits and surveillance are performed by either HL&P or BEC Quality Assurance personnel to ensure that the work is accomplished in accordance with the j design requirements and to ensure that field changes to the design are ! processed in accordance with the design control criteria. 1 4.0 Procurement Document Control To assure that nuclear safety-related items are purchased in a planned a g and controlled manner, the HL&P Project Quality Assurance Plan l establishes basic requirements which are to be-used by HL&P and ' prime i contractors in preparing procurement procedures for the South Texas Project. BEC performs procurement activities for nuclear safety-related equipment, materials and services, exclusive of the NSSS contract, which j .. 20 1
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i is performed by Westinghouse. BEC will approve any Ebasco nuclear ' safety-related procurement. BEC, and as appropriate, Ebasco verify . l through contract, vendor surveillance and audit that their' suppliers: H comply with the established requirements.- When HL&P has direct responsibility or assumes direct' responsibility for procurement activities, these activities will be conducted-in accordance with the requirements of-this'section. The basic requirements are: Written procedures are established clearly delineating-the sequence' - of actions to be accomplished in the preparation,. review, approval, and control'of procurement documents. A review of the adequacy of quality requirements stated in
. procurement-documents is performed by qualified personnel knowledgeable in the QA requirements. 'This-review is to determine- 4 all quality requirements are correctly stated; they can be inspected and controlled; there are. adequate' acceptance and rejection criteria; and the procurement' document has been prepared-in accordance with QA Program requirements. .
Documented evidence of the review and: approval of procurement documents is provided and available for verification. - Procurement documents identify those quality assurance requirements which must be complied with and described in the supplier's'QA Program to meet 10CFR50, Appendix B; ANSI N45.2 and applicable ANSI standards and Regulatory Guides. This 'QA Program shall be reviewed , 1 for adequacy by qualified personnel knowledgeable in quality. assurance. Procurement documents contain or reference applicable design bases; j technical requirements, including regulatory requirements;. .j component and materiel identification; drawings;. specifications;- codes and industrial standards, including their revision status; . tests and inspection requirements; and instructions of such ' activities as fabrication, cleaning, erecting, packaging, handling, shipping, storing and inspecting. Procurement documents contain, as applicable, requirements which. ) identify the documentation to be prepared, maintained, submitted ' and made available to the procuring agent for review and/or approval, such as drawings, specifications, procedures, inspection and test records, personnel and procedure qualifications and material and test reports. I Procurement documents contain, as required, provisions for .. extending' applicable requirements to lower tier subcontractors and suppliers, including purchaser's access to facilities and records. l I 1 f 21 l a
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' Procurement documents contain provisions forl control of nonconfor~-
mances including 10CFR21 notification and.for.. method of; acceptance of 'the item or service. Procurement documents contain the requirements for, the retention, i control, submittal and maintenance of records. .) Procurement documents contain the procuring agency's right of-access to Vendor's' facilities.and records for sourcezinspection and. audit.
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Changes and/or revisions to procurement documents are subject to.at I least the same review and approval requirements as the original. i document. Purchase documents for spare or replacement parts:of safety-related 1 structures, systems and components.are reviewed for' adequacy of' quality requirements by qualified personnel' knowledgeable in. l quality assurance. The review is to determine the adequacy of the l quality assurance requirements and acceptance. criteria relative to l the original design. i The evaluation and selection of suppliers are determined.by-qualified personnel in accordance with written procedures acceptable to HL&P. Procurement documents, records and changes thereto-are collected,' i stored, maintained and retrievable in a systematic and controlled . manner. i HL&P Engineering is responsible for review of selected BEC Procurement Specifications. I Audits and surveillance are performed by either HL&P or BEC Quality. Assurance personnel to verify that the requirements have been implemented and that they are effective. l 5.0 Instructions,' Procedures and Drawings ; The HL&P Project Quality Assurance Plan requires HL&P, the prime contractors and their suppliers to establish and implement a Quality Assurance Program which is in compliance with 10CFR50 Appendix B, ANSI N45.2 and applicable ANSI standards and Regulatory Guides. Each program is required to be effective in verifying that the defined activities are-accomplished and documented in accordance with written procedures, , instructions, and drawings and that they provide quantitative and qualitative acceptance criteria. j i
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a. m 1.
'HL&P Project Quality.Assurancereviewsandapproves'the,BECSoUthTexa.s Project. Quality Assurance Program. To measure.the effectiveness'of the-
' prime contractors' quality? assurance programs,' aimonitoring program) consisting. of' audits and surveillance has been established for the-South Texas Project. HL&P Project Quality Assurance- also a'udits HL&P
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' Corporate' organizations ~that perform functions:for the. South Texasf Project.' Additionally, HL&P' Qual.ity' Services audits HL&P Project - '
.' Quality Assurance and . Westinghouse for' compliance with their.' respective; Quality Assurance Programs. ,
o a 6.0 Document' Control , The HL&P: Project Quality Assurance Plan.and. implementing -procedurest
' require that HL&P, the prime contractors and subcontractors, implement:a' '
-document control ' system for. nuclear safety-related: items for the South -
Texas. Project. The established system ensures that design, engineering, ,l procurement, fabrication, construction.and QA/QC. procedures, plans and-changes' thereto are -reviewed and approved by procedurallyLa'uthorized . ,
. groups and that'the documents are issued,-maintained current and
" controlled by the use~ of controlled lists of documentL holders- to ensure-that superseded documents are . replaced inJa; timely manner.
Measures are established and documented to control theJissuance of- - documents, such as instructions, procedures and drawings,. including c changes:thereto, which prescribe activities;affectingiqual.ity. These-measures assure that documents, including changes, are reviewed,for-technical adequacy and the' inclusion- of appropriate quality requirements," are. approved :for release by authorizedLpersonnel .and are . ! distributed to and used at the location:where the prescribed. activity:is performed. . Changes to documents'are. reviewed.and' approved by the same organizations that performed the; original review and-approval' unless- l l- other organizations are specifically, designated. The reviewing . l organizations have access to pertinent' background information:upon which I to base their_ approval and shall have adequate understanding of: the-
< requirements and intent of the origina1' document.
,9 Those participating in an activity are made. aware of and use' proper and current instructions, procedures, drawings and-engineering requirements-i for performing the activity. Participating: organizations have-procedures for control of the documents and changes thereto to preclude the possible use of outdated or inappropriate' documents.
Document Control measures provide for: 1 i j Identification of indi.viduals~ or organizations . responsible for- 1 preparing, reviewing, approving and issuing documents and revisions J thereto; i f Identifying the proper documents to be used iniperforming.the j activity; i a Coordination and control of interface documents; j
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1 y > c h Ascertaining that proper documents are being used;'- ! J-M " Establishing current and updated distribution lists;: A' listing identifying the current revision of instructions, . 1
; procedures, specifications, drawings;and procurement: documents.
'The list is updated;and distributed to predetermined responsible '{
. personnel.. 1
' Audits :and surveillance are. performed:by either HL&P, BEC or ESI QAL '
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personnel .to verify that document control: systems.are in. place andi # jl effectively. implemented. 7.0 : Control of Purchased Material, Equipment and-Services I
- The HL&P Quality Assurance Plantand implementing 'procedur~es require'thatl HL&P, prime contractors 'and' subcontractors define and' document the; '
system and ' requirements for the: control of: nuclear safety-related; s
> purchased material,+ equipment and services. - .
1 Control.and verificatic of supplier!s activities during'f'abrication, inspection, testing ana. shipment of materials, equipment and components- ?) is planned .and performed as earlycas possible, as required Lto assure 9.. I conformance to the purchase < order or contractual requirements. These; , procedures provide ~for: q f - Requiring the supplier to identify processos to be. utilized in' ] fulfilling procurement -requirements. ; Reviewing documents required to be' submitted by the procurement- ! requirements. ~ l 1 Specifying the characteristics'or processes to be witnessed-1 inspected or verified and accepted based upon the fabrication 1l'
- schedules; the ~ method of surveillance and.the extent' of l'
documentation required; and those responsible for implementing q these procedures.. i Audits, surveillance and/or inspections which verify that the-supplier complies with the quality requirements ofL his.QA: program. i Control and verification of: organizations performing services is ~accom-plished by technical verification of data -provided, surveillance and/or.- ; audit of the activity and review of objective evidence"such as certifications,. reports, etc. The selection of suppliers is based on evaluation 'of their . capability.to -
. provide items or services in accordance with the requirements of theR
procurement documents prior to award of contract. - Procurement source evaluation and selection measures are implemente'dlby HL&P and BEC'which provide for the ' identification of the organizational responsibilities for determining supplier capability.. 24-a
a i i Measures for evaluation and' selection of. procurement sources, and the -_ results thereof, are documented and. include one or more of (a)Lthrough' q (c)' and also must include. (d) below: ;
- a. . Evaluation of the supplier's history of. providing an identical or- 1 similar product or service which performs satisfactorily in actual- !
use. The supplier's history shall reflect current capability, i b .- Supplier's current quality records supported by documented qualitative and. quantitative information which can be objectively.
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evaluated. The records reviewed may include the_ASME Section_III ! Certificates of Authorization for N, NA, NPT and NV stamps. l
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- c. Supplier's technical and quality capability as determined by-a I direct _ evaluation of his facilities and personnel and the. .
implementation of his approved quality assurance program. Reviews of ASME Nuclear Certificates of. Authorization may be used to qualify the supplier in lieu of direct evaluation. ,1
- d. Evaluation of bid documents' including review for technical l j
adequacy, quality assurance and commercial considerations. {i Procurement of spare or replacement parts for safety-related structures, ! , systems and components is subject to QA. program controls, to codes and standards and to technical requirements at least equal;to the invoked i original technical requirements or any properly reviewed and approved j. revisions. 8 A receipt inspection is planned and implemented to assure: j Timely inspection of items upon receipt. The material, component or equipment is properly identified and l corresponds to the identification on the purchase document and receiving documentation. Material, components, equipment and acceptance records satisfy the j I receiving inspection instructions prior to installation or use. Specified inspection, test and other records are accepted and available at the South Texas Project prior to installation or use where required unless otherwise authorized by conditional release- . Items accepted and released are identified as to their inspection status prior to forwarding them to a controlled storage area or releasing them for further work or installation. t Coordination of receipt inspection with vendor surveillance activities to verify-the required vendor inspection has been performed or a waiver documented. 1 Deficiencies if applicable have been resolved prior to shipment. ! 25 U
g Supplier control and use of Certificates of Conformance, when required '. by procurement documents, are evaluated by audits, vendor inspections or , tests to ensure they-are valid. >The supplier's records shall include a ' description of those'nonconformances from the procurement requirements dispositioned " accept as is" or " repair," including evidence of acceptance by the purchaser's engineering organization. ! Site receiving inspection ensures that, for nuclear safety-related items- I received at the South Texas Project, there is accompanying' documentation i that indicates review and concurrence by the appropriate prime s-
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contractor or designee, that the item complies with establishe'd requirements or has an authorized waiver prior to shipment. . Audits-and. .; surveillance are performed by either HL&P or BEC- Quality Assurance' ! personnel to ensure compliance with these criteria. HL&P Quality Services ensures by audits / surveillance of the AE/ Construction Manager's vendor surveillance function that source j surveillance and inspection are performed in accordance'with the quality j } assurance program. In addition, audits and surveillance are performed j by either HL&P or BEC Quality Assurance personnel of activities commencing with receiving inspection at the site to ensure proper
- controls of purchased material and equipment are exercised and to ensure overall compliance.
+ )
8.0 Identification and Control of Materials, Parts and Cdaponents The HL&P Project Quality Assurance Plan requires that prime contractors and suppliers establish written procedures for the identification and ! control of materials, parts and components , including partially assembled l components. Prime contractor's and supplier's procedures shall include { the documented verification of correct identification of materials, , components and subassemblies, and that the method of-identification does { not affect the function or quality of the item prior to release of the q items for assembly or installation. These procedures must: 4 Establish controls to identify and control materials (including I consumables), parts and components (including partially fabricated subassemblies) . i Provide specific identification and traceability controls when required by codes, standards or specifications. Provide a method for identification and control of incorrect or defective items. This system includes verification and documentation prior to release for fabrication, assembling, shipping and installation. All safety related items and material sht.ll be controlled by one or more of the following: Uniquely identified an1 traceable. 1 26 '
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g y l Physically marked - items are not traceable but' are readily ni retrievable. , 9' v s .
-. Physically identified as to type and user tested. #
Identifiable' as to type,' by some phisical characteristic or other, administrative control. f BEC and ESI Quality Assurance verify that the above criteria are incor- , porated into the quality / construction grocedures during the i review /appr' oval cycle. Audits and surveillance are performed by either HL&P, BEC or ESI Quality Assurance personnel to verify compliance. lj t 9.0 Control of Special Processes ' ( \ The HL&P Project Quality Assurance Plan reduires that writtep procedures '
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be established by prime contractors and subcontractors for tha a. activities associated with all special ' processes. For special processes ' l the qualification of personnel, procedures and equipment relating to { l specific codes, standards, specifications and contractual requirements l shall be documented and maintained current. i Special Processes - special manufacturing processes, metallurgical, chemical, material cleaning, welding, pigt'ng and other processes where assurance of the process quality is depenfent largely on the inherent. skill of the operator and cannot be assured by the inspection of.. articles alone. A t ( > i l Special processes'for the South Texas Project include but are not P, y' l limited to: # i Welding i 1 Heat treating Cadwelding Nondestructive examination [ Chemical cleaning and flushing Coatings , j Organizational responsibilities are defined in procedutw for , I qualification of special processes, equipment and parsonnel. These 1 ! responsibilities will include the provision to<eM ure that.special i processes are performed by qualified personnel using procedures qualified and approved in accordance with applicable codes, standards 04 . other requirements. 3 27
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, ,: Special processes are performed unden nntroibd conditions by qualified c .,
personnel using procedures qualified andhwrfpved fn accordance with l
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applicable codes, standards-or other regfemehts. , for spec',:1 a 1 processes not covered by existing code _s of standards the. specific- : equipment, . personnel qualification and proc #inie ' qualification requirements are defined prior to applicationhf the special process. l { Recordsye maintained for the qualification of , procedures, ecJipment ! and peisonnel associated with special processes. Records de in ; sufficient detail to clearly define the proceC;res, equipment or i p<#hnnel being qu611fied; criteria or require'nknts used for { edification; and the individual. approving e.he-qualifications ! j' HL&P Quality Assurance verifies that the special process control criteria are' met by BEC and ESI review and approval of special process procedures, n ,/ : 1 HL&P will rett.% tAe capability with a qualitj, control group to perform, as directed by the PQAM, certain special pr6 cess examinations (NDE) during the. irapection verf fication process. Special process i examinations performed during the inspection. verification process will be accomplished using the same procedure'that was used for the initial examination. These examinations will be performed by personnel I qualified in accordance with SNT-TC-1A-80. Instances of recommendations within SNT-TC-1A-80 ('shoulds') will be considered mandatory Vequire-1 m 2 ments ('shalls'). This exception will be reflected in approvM imple- - menting procedures. d' .. i J ? Audits and surveillance of special process ~act!vities\ a' re performed by' either HL&P, BEC or ESI Quality Assurance perscnnel 19 ensud compliance ! with W aspects of theOuality tdsurance Program. a !
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10.f1pgeetkn s l\ $f*, (\ t a The bl.19 Project Quali10 Aisurance Plan requires the prime contractor i for con ~scruction and s; Contractors to establish and implement an inspction operation w ose activities are independent from the g or up i perforring the activities being inspected. The training, qualifications ' and certifications of inspectors include criteria from appro)riate codes, standards, and procedures. Inspector training shall 3e ' documented and kept current. Inspection activities relating to construction, thbrication, installation and testing are documented, kept ' e carrent and identify all mandatory inspection hold and test points and, the criteria to be witnessed by authorized inspectors. Operations and inspections (including rework, replacad~ items) are performed in predetermined, documented sequences. Deviations or deletions must be accomplished in accordance with approved and documented systems. Inspe:Aion procedures include all required inspection operations:O;?f tned by the specifications, drawings, codes and standards. These;Mscedures provida for the following: y i a. Identification of characteristics and activities to be inhheted. ! b. A description of the method of inspection. U p 28 v , I b to b
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- c. Identification of the individuals or groups responsible for j performing the inspectior.' operation.
- d. Acceptance and rejection criteria.
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- e. Identii'ication of required procedures, drawings and specifications and revisions. ,
f. Recording the identification of irspector and/or data recorder. if-applicable and the results of the inspection operation,
- g. Specifying necessary ineasuring and test ecuipment including accmf;y requirements end verification of calibration.
- h. Ivaluation of inspection results.
Where direct inspections are impossible or-disadvantageous, in-process monitoring is specified in the inspection procedures and both direct and in-process monitoring are used when control. is inadequate without both.
'All required procedures, specifications and drawings are made available to the inspectors prior to performing inspection. If mandatory ..
inspection hold points are required beyond hhich work cannot proceed without the specific consent of the designated representative, the ..~ specific hold points will be indicated in appropriate documents.
. Inspection retults are documented, evaluated and their acceptability determined by a responsihJe individual or group.
SEC or ESI Quality Assurance verify that inspection control criteria are complied with by review and approval of the inspection procedures. ht&P Quality Controi may occasionally perform inspection verifications as deemed necesaary.by the Project Quality Assurance Manager. Audits and surveillasces of inspection activities are performed by either HL&PL SEC or GSI Quality Assurance perdonnel to ensure compliance
.with all aspects of the quality assurance prograg.
The HL&P inspectors are trained had certified by a program conforming to AiC1 N451.6 and as applicable, SNT TC-1A-80. Instances of recommendations within SNT-TC-1A 80 ('sbjulds') will be considered mandatory r:egairements ('shalls'). , Thit exception will be reflected in - approved implementing procedures. 11.0 lest Control The)HL&P Project Quality Assurance Plan requires that a test control progrtm be developed and documented by the prime contractors and contractors for tests that they are responsible for, which demonstrates that the facility performs-in accordance with the South Texas Project requirements and specifications. Preoperational testing and start-up testing requirements are establis':ed by the Operational Quality. Assurance Plan, as described in Chapter 17.2 of the FSAR. The training, 29
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certification of- personnel, calibration and certification of test equipment, system _or component status,. environmental conditionst
' inspection hold points:and configuration of the items to be tested are:
included in the procedures'. Test results are documented, evaluated :and : the acceptance' status' determined-by the authorized departments.
~ Test procedures or instructions. provide for_ the: following as required: >
y - . . E a.- The inclusion;of7 requirements and acceptance limitsicontained in, ' applicable' design'and procurement' documents.
~b. Instructions for. performing the test.
- c. Test prerequisites'such as calibrated. instrumentation, adequate ;
test equipment and~ instrumentation' including their accuracy
- requirements, completeness lof item to be: tested, suitable andf controlled environmental; conditions and provisions for data -
collection and storage.
- d. Mandatory inspection hold points. for witness:by.0wner and the contractor's inspector (as required).
- e. Acceptance and rejection' criteria.
l f. Methods for documenting or recording test data-and results.-
- g. Provisions for assuring that test prerequisites have been met.
- h. Evalua: ion of results. ,
BEC and/or ESI Quality Assurance verify = inclusion of, adequate test' control criteria by review 'and approval of test procedures.- Audits and : surveillance are performed by either HL&P, BEC. or ESI Quality. Assurance ! personnel to verify that the c'ontrols.are implemented and ' effective. The test control activities are an example of a case in which HL&P- i Project Quality Assurance monitoring activities and the Operational ; Quality Assurance monitoring activities will interface-and in some ' instances overlap. HL&P Project Quality Assurance procedures will specifically define the responsibilities for this period. ' 12.0 Control 'of Measuring and Test Equipment , q The HL&P Project Quality Assurance Plan requires the establishment,. ! documentation and implementation of a Measuring and Test Equipmentz ! Control System. The system' is. to include calibration techniques, accuracy, frequency and-maintenance of all measuring instruments / test' ; equipment used in the measuring, inspection' and monitoring of nuclear ' safety-rel'ated items. Calibration and maintenance' data shall be filed l and kept current. Calibration standards are to be traceable to ' 30 L _ _ _ __- - - _ _ _ - - - _
nationally recognized standards'where standards exist. If standards ~do not. exist, the basis for calibration of the equipment shall be documented. If measuring or test equipment is found to be out-of calibration, missing or lost, an investigation is-required to be performed to determine the validity of the use of the instrument and whether measurements or tests are required to be reperformed. Reinspection when required will be documented. Equipment is identified and traceable to the calibration test-data and, suitably marked to indicate calibration due date.
. Measuring and test equipment is calibrated'at specified intervals and based on the required accuracy, purpose, frequency of use, stability characteristics, and other conditions affecting the measurement.
Calibration of this equipment is against ' standards.that have an accuracy of at least four times the renuired accuracy of the equipment being calibrated, or when this is not possible,. have an accuracy that assures the equipment being calibrated will be within required tolerance and that the basis of acceptance is documented and authorized by responsible management. Calibrating standards will, when possible, have greater accuracy than, standards being calibrated. Calibrating standards with the same accuracy may be used if they can be shown to be adequate for the requirements and the basis of acceptance is documented and. authorized by responsible management. BEC and/or ESI Quality Assurance review and approve procedures for control of calibration of measuring and test equipment to er,sure these criteria are incorporated. Audits-and surveillance'are performed by either HL&P, BEC or ESI Quality Assurance personnel to verify compliance. In the conduct of its inspection verifications, as directed by the PQAM, HL&P Quality Control is required to use measuring and test equipment of the appropriate accuracy level which is controlled by procedures meeting the requirements of this section. 13.0 Handling, Storage and Shipping The HL&P Project Quality Assurance Plan requires that for nuclear safety-related items, written procedures be developed in accordance with design requirements, specifications and standards to control the-cleaning, handling, storage, packaging, shippirg and preservation to preclude damage and deterioration by environmental conditions. The activities are to be accomplished by appropriately trained and experienced personnel. BEC and, as~ appropriate, ESI Quality Assurance review and approve quality construction procedures for receiving, handling, storage and-cleaning to verify that the appropriate criteria of Regulatory Guide 1.38 and ANSI N45.2.2 are included. Periodic audits and surveillance are conducted by either HL&P,- BEC or ESI Quality Assurance personnel to verify compliance with the procedures. 31 w--- _ _ _. -
;-- ., 3
..7
'14.0 Inspection, Test and Operating Status LThe HL&P: Project' Quality: Assurance Plan requires that the prime. .
contractor.and construction contractors-indicate the current inspection,- ' ' ' test and operating status of nuclear safety-related items' through the'. use of stamps, markings, tags or:other . suitable means. . Procedures-include the requirements for:.
- a. Controlling the application ~.and removal!of inspection st'atus - a indicators such as tags, markings, labels'and' stamps.: , .. ,
- b. Documenting the status of nonconforming,-inoperative, or.
H malfunctioning structures, systems and components;to prevent ' inadvertent use.
- c. ~ Defining, controlling and documenting the use, application and '] <
removal of inspection tags, labels or, markings which identify the e status of inspections or tests" performed.and attest to the ' ~ ;, acceptability of the structure . system or component.
- d. . Controlling the altering of the sequence-of required tests, .
l inspections and other operations. BEC and/or ESI Quality Assurance review'and approve these procedures.=- Audits and surveillance are performed by either HL&P,;BEC.'or.ESI: e l j Quality Assurance personnel to assure compliance. ' 15.0 Nonconforming Materials, Parts or Components The HL&P Project Quality Assurance Plan requires that HL&P. maintains'and the prime contractors Quality Assurance Programs include.a syster which' is documented by written procedures =for.the identification, segregation and disposition of nonconforming materials, parts'and. components'. The u procedures shall specify the preparation and. handling of nonconformance documents,= segregation requirements'and which groups are responsible for review and disposition of the items. Documentation identifies the' nonconforming item; describes the nonconformance,? the disposition .of the nonconformance and the inspection requirements; and includes. signature approval of the disposition and final closecut. Nonconformances are corrected or resolution determined prior to;initiationfof V
- preoperational . test program on the item. ~ Rework,urepairs. . subsequent reinspection and tests are conducted:in accordance with the original inspection-and test requirements or accepted alterna.tives. These tests shall be performed in accordance with controlled procedures and contain.
mechanisms for providing'information to the identifying group as to the disposition of the nonconformance. For NSSS items, the organization responsible for dispositioning of the nonconformance shall obtain-concurrence of the Westinghouse Site Representative. HL&P. Quality. Assurance performs trend analysis of- HL&P,-BEC and ESI: nonconformances. Procedures are established by HL&P:to report'significant. deficiencies during the design, construction and startup phase to HL&P. executive management and to the Nuclear Regulatory Commission in accordance with 10CFR50.55(e) and 10CFR21 where applicable. . Either HL&P,. BEC.or ESI Quality Assurance personnel perform periodic audits and surveillance to .i assure compliance. L 32 L
l 1 I i 16.0 Corrective Action The HL&P Project Quality Assurance' Plan for the. South Texas Project: requires that a system be established and documented by HL&P and the prime contractors which defines the responsibilities, authorities and methods used by specific groups involved in the evaluation of nonconformances and trending to determine the need for corrective action. The system includes measures to identify the cause of significant conditions adverse to quality, measures to ensure that the. root'causes are correctedi and measures to ensure that timely action is taken. Follow-up is performed to ensure the effectiveness of corrective - action and that appropriate levels of. management are informed of the results. HL&P performs trend analysis of HL&P, BEC and ESI identified deficiencies to determine the need for corrective action. General categories of documents to be. trended are: Nonconformance Reports; ' Standard Deficiency Reports; Deficiency. Notices; Inspection Reports; and Audit Deficiency Reports. Specific documents to be trended, and the frequency of' trending, are identified in approved' procedures. Either-HL&P, BEC or ESI Quality Assurance personnel perform audits and surveillance to assure compliance. 17.0 Quality Assurance Records The HL&P Project Quality Assurance Plan requires that a Quality. Assurance record system be developed by HL&P and the prime contractors-. for the South Texas Project. The record system provides evidence that activities relating to quality are defined, implemented and that inspection and test documents contain a description of the type of observation, reference to nonconformance reports, evidence relating to status of' observation, date and inspector identification. Quality records shall . include reviews, audits, reports, specifications, nonconformance reports, analyses, personnel and equipment qualification procedures. The HL&P Project Quality Assurance Plan requires that HL&P and prime contractors establish requirements to ensure that records generated during the design, procurement and construction are identifiable,- i retrievable and meet the requirements of 10CFR50, Appendix B, and ANSI ' N45.2.9 as endorsed by Regulatory Guide 1.88. As an alternative to the ANSI N45.2.9 storage requirements, records may be maintained for the South Texas Project in a two-hour. rated fire j resistant file room meeting NFPA No. 232-1975 including the following ! provisions: An automatic fire suppression system and an early warning fire detection system is utilized. Records are stored in fully enclosed metal. cabinets. Smoking and eating / drinking are prohibited within the records storage facility. > 33 w_ . __ _ i
i l i Work not directly associated with record storage or retrieval is 4 prohibited within the records storage facility. .l Ventilation, temperature and humidity control equipment is l; controlled where they penetrate fire barriers bounding the storage facility. { Either HL&P, BEC or ESI Quality Assurance personnel perform audits and .) surveillance to assure' compliance. I 18.0 Audits j i' The HL&P Project-Quality Assurance Plan establishes the requirement that HL&P, prime contractors and subcontractors develop, document and' implement audit activities which are structured in accordance with the' ) requirements of ANSI N45.2.12.for the South Texas. Project. As required by the ANSI standard, .results of audits are presented.for review to management of the audited organization and, in the case of HL&P. 3 performed audits the HL&P Group Vice President, Nuclear. Where -l indicated HL&P performs follow-up action. - 1 HL&P has the. ultimate responsibility for the auditing of quality related ; activities on the Project. HL&P Quality Services audits are performed i primarily on the HL&P Project Quality Assurance group, and Westinghouse, j HL&P Project Quality Assurance is primarily responsible for audits of. j
- the Engineer / Construction Manager, constructor, subcontractors. HL&P ,. 1 Project team organizations, and the HL&P corporate organizations. i providing services to the Project. To the extent possible; audits are i scheduled such that recurring audit areas are audited by different organizations on successive audits when deemed appropriate. Certain selected audit areas will be retained by HL&P in order to provide. !'
continued assurance that HL&P, Bechtel and Ebasco programs are maintained as required. The prime contractors and subcontractors perform quality related audits of internal activities and suppliers of material, components and systems. , HL&P, BEC or ESI personnel perform supplemental audits when required,. based on such factors as significant. changes'in the Quality Assurance Program, results of trending programs or investigations into the root causes of problems. 1 34 E-
i TABLE 1 ANSI ~ STANDARD AND REGULATORY GUIDE COMPLIANCE The STP Quality Assurance Program complies with the following ANSI Standards Land .j associated Regulatory Guides except 'as' noted- 4 STANDARD TITLE ANSI N45.2-1971 Quality Assurance Program R.G. 1.28 (Rev. O, 6/72) ' Requirements for Nuclear Power Plants l ANSI N45.2.1-1973 Cleaning of Fluid Systems and { R. G. 1.37 (Rev. O, 3/73) Associated Components During (see notes 8 through 10) Construction Phase of. Nuclear Power :
- Plants.
ANSI.N45.2.2-1972 Packaging, Shipping, Receiving,- R.G. 1 38 (Rev..0, 3/73) Storage and Handling of Items for , (see Notes 11 through 16) Nuclear Power Plants 1 ANSI N45.2.3-1973 Housekeeping During the Con-R.G. 1.39 (Rev. O, 3/73) struction Phase of Nuclear Power (see Notes 17 and 18) Plants A!!SI N45.2.4-1972 Installation, Inspection and R.G. 1.30 (Rev. O, 8/72) Testing Requirements for (see Notes 19 and 20) Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating l -Stations l ANSI N45.2.5-1974 Supplementary Quality Assurance (see Notes 1 and 2) Requirements for Installation, Inspection and Testing of Structural Concrete and Structural , 1 t Steel During the Construction Phase of Nuclear Power Plants. ANSI N45.2.6-1973 Qualifications of-Inspection, R.G. 1.58 (Rev. O, 8/73) Examination and Testing Personnel As modified by positions C.5, for the Construction Phase of l C.6, C.7, C.8 and C.10 of Nuclear Power Plants Rev. 1 (see Note 34) ANSI N45.2.8-1975 Supplementary Quality Assurance Reg. 1.116 (6/76) Requirements for Installation, (see Notes 21 through 23) Inspection and Testing of Mechanical Equipment and Systems I for the Construction Phase of l Nuclear Power Plants l
L 5 i i 1 TABLE 1-ANSI STANDARD AND REGULATORY GUIDE COMPLIANCE
-(Continued)-
ANSI N45.2.9-1974 Requirements for Collection, , R.G. 1.88 (Rev. 2, 10/76) Storage-and Maintenance of Quality (see Notes 24 through 26) Assurance Records'for Nuclear; Power. Plants' '
- ANSI N45.2.10-1973 Quality Assurance: Terms an'd R.G. 1.74 (Rev. O, 2/74) Definitions-ANSI N45.2.11-1974* ' Quality Assurance Requirements.for R.G. 1,64 (Rev. 2, 6/76) the Design of Nuclear Power Plants:
(see Notes 3.through 7) ANSI N45.2.12-1977 Requirements for.' Auditing of. ! R.G. 1.144 (Rev. 1, 9/80) -Quality Assurance ProgramsFfor. (see. Notes 32 and 33) Nuclear Power Plants ANSI N45.2.13-1976 Quality Assurance Requirements for-R.G. 1.123 (10/76) Control of. Procurement of Items and . (see Notes 27 through 31) Services for Nuclear Power Plantss ANSI N45.2.23-1978 . Qualification of Quality Assurance-R.G. 1.146 (Rev. O, 8/80) Program Audit Personnel- for Nuclear Power P1 ants-Exception Notes
- 1. ANSI N45.2.5-1974, Section 4.8 states " Pumped concrete.must be sampled from .
the pump line discharge." In lieu of this. statement, in-process strength samples of pumped concrete are.taken at the. delivery point. . Correlation tests of air content, slump, and temperature are performed to verify these
' plastic properties of the concrete at the placement-point in accordance with the following frequency requirements:
- a. A minimum of 2 correlation tests are performed for .each pumped placement exceeding 200 cu. yds.
- b. Otherwise, a minimum of 2 correlation tests per week are performed when any individual pumped placement during-a week requires delivery -
of more than one truckload of concrete.
- c. During a week when a pumped placement exceeding'200 cu. yds. is made, the correlation tests performed on that ~ placement will. satisfy the weekly requirement for performing two correlation tests 'as specified in Item b above.
L___ _ _ - _ _ _ _ _ - _ _ - - - - - - -
j TABLE I 1 ANSI STANDARD AND'REGULATCRY GUIDE COMPLIANCE
.(Continued)-
.If the correlation test. result shows a concrete property not, meeting the specification-limits and/or tolerances at the point of placement, the .
j s frequency of correlation testing shall-be increased to 100 cubic yards. If.- ' two consecutive: correlation tests exceed the specified-limit for slump,; air content, . or temperature, the Constructor shall document the condition,. notify Bechtel Site Engineering within 24 hours:of. completion of the- - placement and- shall . return' to' control ~of the concrete by in-process testing-at the point of placement per ANSI N45.2.5-1974.
" Correlation Tests," " Delivery Point," and-" Placement Point" ana as defined in ANSI N45.2.5-1978, Section 1.4.
- l. 2. Samples and frequency for cadweld testing is in accordance with ACI-359/-
l ASME Section III Division 2, issued for trial use and comment in 1973, l including addenda 1 through 6, (see Sections.3.8.1.6.3 and 3.8.3.6.3 of the STP Final Safety Analysis Report).
*:The following interpretations '(Notes 3 through 7) of. ANSI N45.2.11-1974 and Regulatory Guide l.'64, Rev. 2-6/76, apply to HL&P, their contractors and consultants working under HL&P's Quality . Program.
/l
- 3. Section 3.1, Design Input Requirements, General. This section' implies that all necessary design input (as listed in Section 3.2) should be available prior to the start of a design activity._ In practice, certain design activities are initiated before the firm input requirements are available.
(For example, foundation designs prepared based on preliminary information or equipment sizes and mounting, embedded conduit run based on preliminary estimates'of circuit requirements, etc.). The design phase Quality Assur-ance program will be structured to ensure that all necessary design input is available before completion of final design of the work affected by the input, and that final design input is available for use in verification of the final design. .'
- 4. Section 4.1, Design Process, General. Paragraph 3 implies traceability back from final design to the source of design input. In practice, a literal interpretation of this is not always possible. For example, final 1
' design drawings do not identify the related calculations. .This paragraph I will be interpreted to mean that it shall be possible'to relate the cri , !
teria used and analyses performed to the final design documents and that J record files will permit location of analyses supporting specific design output documents.
- 5. Section 4.2, Design Analyses. This section implies a. requirement for retention of all calculations. In principle, it is considered good prac-l tice for the responsible engineer or engineering-organization to retain all '
i _ - _ _ - _ - _ - _ _ _ - _ - _ _ _ _ _ . -_ - J
TABLE 1 ANSI STANDARD AND REGULATORY GUIDE COMPLIANCE (continued) final calculations, and this will be done for all manual calculations covered by the program. However, for computer programs only documentation-of the design input, assumptions-made in the analyses, results obtained, and evidence of verification will be retained- since permanent. retention.of all versions of all computer programs is not considered practical or necessary if sufficient information is available for a competent individual-to verify the results using the input and assumptions.
- 6. Section 10, Records. In-process documentation, relating to checking and coordination of drawings (for example, check and coordination prints) or copies of marked-up specifications used to solicit comments, shall be retained until the drawing or specification is approved and issued for use outside of Engineering. Such in-process documents will be available for review / audit until the document is approved, but may be discarded once the
, document has been approved. In the first sentence of the second paragraph ! the' phrase " final design documents" shall mean those documents' which are the latest revision that has been issued for'use. , 1
- 7. Regulatory Position, Section C-2: If, in an exceptional circumstance, the l originator's immediate supervisor is the only technically qualified 1 individual available, the design verification or checking will be enweted by the supervisor with the following provisions:
- a. The other requirements of Regulatory Guide 1.64 will be met.
- b. The justification will be individually documented and approved by the next level of. supervision. 1
- c. Quality Assurance audits will include review of the frequency and J j- effe.tiveness of the use of the immediate supervisor to assure that this provision is used only in exceptional circumstances.
I
- 8. Section 2.1, Planning. The required planning is frequent 1y' performed on a generic basis for application to many installations on one or more pro-jects. This results in standard procedures or plans for installation and.
l inspection and testing which meet the requirements of the standard. Individual plans for each item or system are not normally prepared unless the work operations are unique. However, standard procedures or plans:will be reviewed for applicability in each case. Installation plans or proce-dures are also limited in scope to those actions or activities which are essential to maintain or achieve required quality. This is consistent with Section II, Paragraphs 2 and 3 of ANSI N45.2-1971 which provides for examination, measurement, or testing to assure quality or indirect control L by monitoring of processing methods. However, final cleaning or flushing activities will be performed in accordance with-procedures specific to the system. 4
m 7 TABLE 1 ANSI STANDARD AND REGULATORY GUIDE COMPLIANCE (continued)
- 9. Section 4, Preinsta11ation Cleanliness; This .section ::tates, " Items should' not be delivered to the point of installation 3;te ' sooner:than necessarys :
unless' the installed location is considered' a better. storage area." As an. l alternate to this requirement, items may be delivered.to thesinsta11ation .i site sooner than absolutely necessary when determined to.be. advantageous for other considerations, for example,, reduced handling or. easier access,. l thereby reducing' susceptibility to handling damage. . In.all'such cases, . equipment stored inplace will be protected in accordance with Section- 5 of. ANSI N45.2.1. 1
- 10. Section 3.1.2, HL&P interprets the lighting level of 100 footcandles to be guidance. It is HL&P's normal practice that the. lighting -level for deter- l mining " metal clean" of accessible surfaces of piping and components. is 1 determined by the inspector. Typically he uses.a. standard'two-cell- 1 flashlight supplemented by other lighting as.he' deems necessary.. i
- 11. Section 2.7, Classification of Items. The four-level classification . system may not be used explicitly. However, the specific requirements for each 1 classification as-specified in the standard willebe applied toothe itemsw i suggested in each classification and for similar items. l Classification differing from Section 2.7 will be considered acceptable :
provided no degradation is assured; for example,: electric. motors designed ' for outside service may be stored in Level C area rather'than a Level B.
- 12. Section 6.2,-Storage Areas. Paragraph 6.2.1. requires control and limited. I access to storage areas. In lieu of and to amplify this paragraph, the ..
following will be applied: Access to storage areas for Level A, B'and C will be controlled by.the individual (s) responsible for storage. While the above areas will be posted to limit access, other positive controls (other than that for the overall site area) or guards may not be provided. Level D areas will be l posted with the storage level designation only. i 13. Section 5.5, Correction of Nonconformances. This section provides for
" rework" and "use as is" dispositions'for nonconforming items. As an .
L alternate, the " repair" disposition (as defined in ANSI,N45.2.10-1973).will l also be used.
- 14. Section 6.2.4, Storage of Food and' Associated Items. -Controlled areas,-
i within storage areas, will be established for the storage of food, drink, and salt tablets. These areas will be controlled through normal super-vision and inspection. _= -
1 TABLE 1 ANSI STANDARD AND REGULATORY GUIDE COMPLIANCE' (continued) ;
- 15. In Section 8, the control of documentation and records shall be in accord-ance with Section 17 of this Program Description.
- 16. Appendix A 3.4.2,-Inert Gas Blankets. There may,be-cases.involvingilarge or complex shapes for which an inert or dry air purge flow-is provided rather than a static gas blanket in order to. provide adequate projections due to difficulty of providing a leakproof barrier. In these cases a positive pressure purge flow may be utilized-as an alternative to the j leakproof barrier.
- I
- 17. Section 2.1, Planning. The required planning-is frequently performed on a j generic basis for application to many installations on one or more pro- '
jects. This results in standard procedures or plans for installation and inspection and testing which meet the requirements of the standard.
- Individual plans for each item or system are not normally prepared unless l the work operations are unique. .However, standard procedures or plans will I be reviewed for applicability in each case. Installation plans or proce-dures are also limited in scope to those actions or activities which are essential to maintain or achieve required quality. l
- 18. Alternative equivalent zone designations and requirements may be utilized to cover those situations not included in the subject standard; for exam-L ple, situations in which shoe covers and/or coveralls are required but-material accountability is not. In addition, zones might be combined into the next more restrictive category in order to reduce total number of zones.
- 19. Section 1.2, Applicability. The Standard is applied to the items and systems identified in Paragraph 1.1.1 and to additional systems depending on the nature and scope of the work to be performed and the importance of the item or service involved.
- 20. Section 2.1, Planning. The required planning is frequently performed on a generic basis for application to many installations on one or more pro-jects. This results in standard procedures or plans for installation and-inspection and testing which meet the requirements of the st&ndard.
Individual plans for each item or system are not normally prepared unless the work operations are unique. However, standard procedures or, plans will be reviewed for applicability in each case. Installation plans or proce-l dures are also limited in scope to those actions or activities which are I essential to maintain or achieve required quality. i _ . _ _ _ _m.
l a l i 1 TABLE 1 ANSI STANDARD AND REGULATORY GUIDE COMPLIANCE-(continued)
- 21. Section 1.1, Scope. The term "important. items" will be interpreted to-apply to those activities or quality attributes of an item or service that could. affect a nuclear safety-related characteristic. For example, if a barrier is required for leakage control, but serves no structural function, the leaktight characteristic would be considered "important", but appear-ance, dimensional requirements, and structural features.would not neces-sarily be considered important; or if a pump casing is required for coolant boundary integrity, but.the pump does not have to operate.to provide for nuclear safety, those attributes which affect its operation would not be considered important from the standpoint of nuclear safety.
i Section 2.1, Planning. . The required planning is frequently performed on a generic basis.for application to many installations on one or more pro- ' jects. This results in standard procedures or plans for installation and ' inspection and testing which meet the requirements of the standard. Individual plans for each item or system are not normally prepared unless l the work operations are unique. However, standard procedures or plans will be reviewed for applicability in each case. Installation plans or proce- ! dures are also limited in scope to those actions or activities which are essential to maintain or achieve required quality.
- 22. Section 3.3, Process and Procedures. .The terms " installation site",
" installation area", and " site" used in this standard shall be interpreted as follows:
i a. " Installation site" or " site" will be interpreted the same as l " construction site". When applied to documents, these may be at the central office or work area document control station. b.- Installation area - immediate proximity of location where work is to be performed.
- 23. Section 3.5(e), Site Conditions. This requirement will be applied only if subsequent correction of adjacent nonconformances could damage the item being installed.
Section 4.6, Care of Items. HL&P retains the authority and is the "Respon-sible Organization" for temporary usage of equipment or facilities unless specific (i.e. on a case by case basis) or general authority is granted in , l writing to the Construction Manager's organization, j
- 24. Section 1.4, Definitions. Quality Assurance Records - A document is
,' considered completed when it has finished full processing and has been j issued for use in design, procurement, construction, or manufacturing. ! l j l _ _ __ - _ _ _ _ - - I
TABLE 1 ANSI STANDARD'AND REGULATORY GUIDE COMPLIANCE (continued)-
=25. Section 1.4, Definitions. Authenticated Records - Those records which"are-clearly identified as a statement by.the individual or organization holding.
responsibility. Handwritten. signatures are not required if the document or: printout is clearly identified ast a statement <by the = reporting; individual or organization.
- 26. : For Appendix A,' an installation shall w considered to be in an "as con-v structed" condition if it is installed within the-tolerances established by; Project Engineering indicated in the design output documents.
27 Adton C.3. of the Regulatory Guide ~- A corrective action system may, depending upon. complexity-and/or importance to safety .of the ' item or service provided, be. imposed upon the supplier.. When a corrective action-system is imposed on a supplier, the' applicable elements:of Section 9.0:of; the standard will be included and its implementation will be verified.
- 28. Section C.4 of the Regulatory Guide .- Applicable information concerning th'e method (s) of acceptance of.an item or service will be.made available tot receiving inspection personnel.
- 29. Section 4.2.a of the Standard - When evaluation of a ' upplier s .is' based solely on historical supplier data, these data will primarily< include HL&P's or a prime contractor's records that have been accumulated int connection with previous procurement. actions. Data that includes lexper-ience of users of identical or similar products of the prospective supplier and product operating experience will be used. if they~ become available; however, such data are normally available only to those involved in plant operations.
g' 30. Section 10.2.d. of the Standard The requirements of this section are interpreted as follows: The person attesting to a certificate'shall be an authorized and responsible employee of the supplier and shall: be identified ' by the supplier.
- 31. HL&P's position relative to ANSI N45.2.13-1976, .Section 10.2.f., Verifi-cation of the Validity of Supplier Certificates and the Effectiveness of
" 'the Certification System,.is as follows: The verification of the validity of supplier: certificates and the effectiveness of the certification system-
, are accomplished-as an integral part of the. total . supplier control and l product acceptance program,.and no separate HL&P system exists.that ad - l ) dresses itself solely to such verification. The' degree of verification required will depend upon the type'of item or service and their safety importance. The means of verification may include source witness / hold n points, source audits, and document reviews; independent inspections at the-time of material receipt; user tests on' selected-commodities, such as concrete components; and tests after installation on selected components L I and systems. All of these means verify whether or not a supplier has fulfilled procurement document requirements. and whether or not a certifi-cation system is effective. a
TABLE 1 A_NSI STANDARD AND REGULATORY GUIDE COMPLIANCE (continued)
- 32. ANSI,N45.2.12-1977, Section 4.5.1 states, "The audited organization- shall provide a follow-up report stating the corrective action taken and the date corrective action was completed." This implies that the audited organiza- .;
tion must provide the auditing organization with written notification, - detailing what corrective action was taken and when.the-corrective action was-completed. In actual practice, the audited organization will provide the auditing organization with documented corrective action including,the date when the corrective action will be completed. The auditing organization will evaluate the corrective action response to determine if corrective action verification is necessary. If verification is necessary, the corrective action verification will be performed after the scheduled completion date and the results of the verification will be documented.
- 33. ANSI N45;2.12-1977, Section 1.3 states, "In no way shall the performance of .
audits by an organization diminish the responsibility of the audited organization or contractor for audit of his designated portion of the ! quality assurance program or the quality of his product or services". For the South Texas Project all quality related activities implemented for the i South Texas Project are audited annually at a minimum, or at least once - within the life of the activity, whichever is shorter. These audits are I performed by either HL&P or BEC Quality Assurance personnel. Ebasco Services Inc. (ESI) activities are limited to those audits performed in accordance with Section QA-III-9 of Part C.-
- 34. As an alternate, compliance with ANSI N45.2.6-1978 and R. G.1.58 (Rev.1, 9/80) in its entirety is acceptable.
)
I j
TABLE 2 HL&P MANUALS USED TO IMPLEMENT THE QUALITY ASSURANCE PROGRAM Project Quality Assurance Plan Project Specific Quality Assurance Procedures Manual Standard Quality Assurance Procedures Manual Quality Services Procedures Manual Project Engineering Procedures Manual Interdepartmental Procedures Manual Project Licensing Procedures Manual L' Project' Procurement Procedures Manual-Project Management Procedures Manual Records Management Systems Procedures Manual Standard Site Procedures Manual l
1 i
)
- 1. 4 GROUP VICE PRESIDENT.
NUCLEAR
- 1. 5 1. 6 GENERAL MANAGER GENERAL MANAGER:
SOUTH TEXAS NUCLEAR 1 PROJECT ASSURANCE i
- 1. 8 VICE PRESIDENT MANAGER NUCLEAR PLANT NUCLEAR' DPERATIONS ENGINEERING l l 1. 7 WANAGER
- CHAIRMAN .I l
NUCLEAR NUCLEAR SAFETY TRAINING REVIEW BOARD-4 i
- 0PERATIONS RESPONSIBILITIES ONLY REFER TO FSAR AND OPERATIONS DA PLAN PROJECT & TECHNICAL DIRECTION -
Figure 1
I 1
- 1. 5 GENERAL MANAGER SOUTH TEXA5
. PROJECT
- 1. 5. I LNIT 2 PRQJECT MANAGER
- 1. 5. 6 l 1.5.9 l 1 M. In l 1.5.7 1.5.11
- 1. 5. 2 1. 5. 8 MANAGER MANAGER ENGINEERING Alg PROJECT RECDRDS LICENSING RW I D PROGRAM I 1. 5. 3 1. 5. 4 l 1.5.5 PRINCIPAL ENGINEER PRINCIPAL ENGINEER PRINCIPAL ENGINEER PROJECT SITE PROJECT NOUSTON HOUSTON LICENSING a
I PROJECT & TECHNICAL DIRECTION l l 1 Figure'2-i
I
- 1. 6 l CENERAL MANAGER NUCLEAR ASSURANCE
- 1. 6. ) 1.6.9 ' 1, 6. 5 PROJECT OPERAT]DNS ENGINEERING DUALITY i
HANAGER MANAGER MANAGER-
- 3. 6. 2 l 1. 6. 3 1. 6. 4 l 1. 6. 6 'l 1. 6. 7 l 1. 6. 8 PROJECT & TECHNICAL DIRECTION PROJECT DIRECTION ------------
l Figure 3 i
- 1. 7 HANAGER NUCLEAR TRAINING TRAINING MANAGER TRAINING HANAGER. HANAGER OPERATIONS TRAINING STAFF' TRAINING ADM N RT DIVISION DIVISION DIVISION PROJECT & TECHNICAL DIRECTION 1
Figure 4 i -- - _ _ - - - _ - _ - - - - - - - - _ - - - _ - - - _J
V ; i HL&P BEC / WESTINGHOUSE /
.ESI / ECI (CONTRACTORS) i i
I CROUP 9EC/ WESTINGHOUSE VICE-PRESIDENT (CONTRACTORS) NUCLEAR MANAGEMENT. k I I VICE-PRESIDENT CENOtAL MANAGER 1 ML"1 EAR ENGINEDtJNG ue CoNstauCTroN NUCLEAR ASSURANCE 4 I l i cENERAL E NAGER souTN TEu s rRaJECT g PROJECT QA MMcEn 4 mgry ASSURNaCE PROJECT MMCEMENT l MEGDDT Al AN Ak AN
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- LINES OF COMMUNICATION HL&P AND BEC/ WESTINGHOUSE /ESI/ECI i (CONTRACTORS) I l
Figure 5 _ _ _ _ _ _ _ _ - _ _ _ - _ _ - _ - _ _}}