ML20246D359
| ML20246D359 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 06/30/1989 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-89-078, CON-NRC-89-78 VPNPD-89-368, NUDOCS 8907110307 | |
| Download: ML20246D359 (35) | |
Text
.
i 4
?
' Electnc POWER COMPANY 231 W MicNgart RO. Box 2046. Milwaukee. WI 53201 (414)221 2345 VPNPD 36 8 NRC-89 07 8 June-30,-1989 10 CFR 50.54 Document Control Desk U.S NUCLEAR REGULATORY COMMISSION Mail Station Pl-137 Washington, D.C.
20555 Gentlemen:
DOCKETS 50-266 AND 50-301 SUBMITTAL OF QUALITY ASSURANCE PROGRAM DESCRIPTION CHANGES POINT. BEACH NUCLEAR PLANT - UNITS 1 AND 2 In accordance with the requirements of 10 CFR.50.54(a)(3),
Wisconsin Electric Power Company is submitting the latest revisions to Section 1.8 of the Final Safety Analysis Report (FSAR) for Point = Beach Nuclear Plant (PBNP).
Section 1.8 of the FSAR describes the present Quality Assurance Program implemented for PBNP.
This section was last submitted to the NRC on June 13, 1988, with a follow-up transmittal on June 23, 1988.
Changes to
~the program description since that time are highlighted in the attachment and following discussion.
None of the changes are considered to be reductions in quality assurance program commitments as previously approved by the NRC.
In fact, we consider the substantive changes to be notable enhancements to the program.
TP'se changes are summarized as follows:
1.
Effective 4/1/89, the Quality Assurance Section (QAS) was j
reorganized.
This reorganization was the culmination of our efforts to improve the efficiency and effectiveness of QAS.
In this regard, an on-site QAS group was established and a number.of quality related activities being performed at Point Beach were consolidated under this group.
The responsibili-ties of QAS were clearly expanded as a result of this change and some of the functions which were previously performed by plant personnel as concurrent assignments were reassigned.
The QA Coordinator and QA Representative positions remain; however, their responsibilities are somewhat modified con-sistent with the above mentioned consolidation of functions.
The Quality, Standards, and Records Organization (QSRO) previously provided a focal point for quality related issues at the plant.
With the reorganization, this focus will now be 89071{0 66 l
DR PDC
.4subsnyanuvawska&w nymtkw
\\
Document Control Desk 4
June 30, 1989 Page 2 provided by the on-site QAS group.
Aside from the tangible benefits-of this reorganization and consolidation of func-i tions, it should be noted that the independence of personnel i
performing various quality related functions is also enhanced.
2.
The responsibilities of the Off-Site Review Committee (OSRC) have been expanded to include responsibility for assessing the l
adequacy and effectiveness of the quality assurance program.
This function was previously provided, in part, by the i
Wisconsin Electric QA Committee.
Due to the knowledge and experience level of.OSRC members and the functions they perform, it was determined that they could better provide an assessment of the QA Program.
With this reassignment of responsibility, it was concluded that the QA Committee was no longer needed and has since been disbanded.
3.
Effective June 1, 1989, some changes in executive level management took place.
Among these changes, the President of Wisconsin Electric (to whom the Vice President-Nuclear Power reported) became Chairman of Wisconsin Electric.
With regard to QA Program commit /ments, this essentially translates to a L-title change since the Nuclear Power Department continues to report to the same individual.
It should, however, be recognized that we expect this situation, i.e.,
Nuclear Power reporting to the Chairman, to be an interim situation.
It should not be construed as a commitment to elevate or maintain this level of reporting of the Nuclear Power Department.
It should be noted that the first two items above were discussed with representatives from Region III during a meeting on January 31, 1989, in our Milwaukee offices.
Changes as of June 1989 are summarized as follows:
A.
Page 1.8-1, Paragraph 1 - For clarity, replaced the phrase "The program described" with "This description."
B.
Page 1.8-4, Paragraph 2 - Replaced the word "specifying" to
" activities affecting" for clarity.
C.
Page 1.8-4, Paragraph 3 - Deleted the reference to Figure 1.8-4 (Refer to revised Figures 1.8-1, 1.8-2, and 1.8-3) and changed to reflect title changes.
D.
Page 1.8-4, Paragraph 4 - First Sentence - Added "(PBNP)"
following " Manager - Point Beach Nuclear Plant" for completeness.
= _
T i
Document Control Desk
' June 30, 1989 Page.3 E.
Page 1.8-4, Paragraph 4, Page 1.8-5, Page 1.8-6, and Page 1.8-7, Items 2.3.4, and First Paragraph - These paragraphs have been rewritten to reflect present responsibilities of persons and organizations within the Nuclear Power Department performing quality assurance functions.
F.
Page 1.8-7, Paragraph 3 - Revised to reflect changes in OSRC responsibilities, as described above.
G._
Page 1.8-8, Paragraph 1 and Item 3 "PBNP QA Volume I" changed.to "PBNP Administrative Control Policies and Procedures Manual" to more accurately describe the document.
H.
Page 1.8-8, Items 1 and 2 - Replaced the title " General Superintendent of Quality Assurance" with " General Superintendent - Quality Assurance Section" for clarity.
I.
Page 1.8-8,. Paragraph 2 - Revised to reflect changes in titles and changes in OSRC responsibilities as described above.
J.
Page 1.8-8, Paragraph 3 - Replaced the phrase "important to safety" with "QA-Scope" to standardize terminology.
K.
Page l.8-9, Paragraoh 2 - For clarity, replaced the phrase
" specific items witain a system" with " specific portions of systems" and the phrase "important to safety" with "QA-Scope."
L.
Page 1.8-12, Paragraph 3 - Replaced the industry organization named " Coordinating Agency for Supplier Evaluation (CASE)'
with " Nuclear Procurement Issues Council (NUPIC)."
This reflects reorganization and consolidation of CASE with the Nuclear Supplier QA Committee (a joint utility audit program).
M.
Page 1.8-14, Paragraph 2 - Revised to reflect a minor change in processing of purchase documents initiated at PBNP.
With the establishment of a QAS on-site group, all purchase requisitions are scoped by the QA Section versus the QA Coordinator, as previously done.
N.
Page 1.8-14, Paragraph 3 - Replaced " CASE" with "NUPIC" for reasons described in Item L.
O.
Page 1.8-22, Paragraph 5 - The reference to the auditing of the in plant QA program by the QA Coordinator or his designee on a normally quarterly basis is replaced by the sentence "The QA program is audited periodically by the QA Section."
This reflects changes in responsibility as a result of the QA Section reorganization.
The QAS on-site organization is now responsible for monitoring the day-to-day activities at the a- _ __ _ _ _ _ _ _ _ _ _ _ _ _ __ --
4 r'.
. Document Control Desk June 30, 1989 Page 4 plant in lieu of the QA Coordinator.
Also, reference to
" quarterly" audits by the QA Section has been changed since the. internal audit program has evolved whereby more than four (4) audits per year are performed.
P.
Page 1.8-23, Paragraph 1 - The phrase
... scheduled commensurate with the work's importance to plant safety and reliability..." is added to more adequately describe the basis for performance of on-site and off-site contractor audits.
Q.
Page 1.8-23, Paragraph 3 - This paragraph has been reworded to be consistent with the consolidation of quality assurance functions and to clarify the difference between " technical audits" and those audits which are performed to meet the requirements of Section 4.5 of ANSI N18.7-1976.
The paragraph has also been rearranged ad a clearer description of personnel, both QA personnel and other qualified WE and/or contractor personnel, assigned to perform audits is provided.
R.
Figures 1.8-1, 1.8-2, and 1.8 The figures are revised to depict the new organizations resulting from the changes noted i
above.
To avoid misunderstanding, please note that some of the pages have a 1989 date even though no changes are highlighted in the text or summarized above.
This is due to the extensive changes in Section 1.8.1 which resulted in a shifting of some of the succeeding sections to different pages, i.e.,
the wording has not changed, just moved.
Please be advised that we intend to include the revised pages of Section 1.8 in an FSAR update which we expect to submit in the fall of this year.
Accordingly, your timely review of this information would be appreciated.
If you have any questions in regard to the above discussion or the attached information, please contact Mr. G.
M.
Krieser at (414)221-2810.
Very truly yours,
[ '/L
$[
C. W.
Fay Vice President l
Nuclear Power I
Attachments Copies to NRC Resident Inspector NRC Regional Inspector, Region III l
________m.m___
~
4 1.8 00ALITY ASSURANCE PROGRAM In accordance with Paragraph 50.34 of 10 CFR 50 and 71.24 of.10 CFR 71, a Nuclear Quality Assurance Program Description is provided by Wisconsin Electric Power Company (WE).
This Program assures that the required manpower, procedures, and management of Point Beach Nuclear Plant are directed toward satisfying the Company objectives of providing safe and reliable structures, systems, and components; and complying with the provisions of 10 CFR 50, Appendix B " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants"; 10 CFR 11, Subpart H
" Quality Assurance for Packaging and Transportation of Radioactive Material"; and the applicable Sections of the ASME Boiler and Pressure Vessel Code.
This description is structured in accordance with the 18 l
criteria of Appendix B.
The following describes the quality assurance program established and imposed by the Company for application to the functional aspects of' structures, systems, components, including the design, purchasing, con-struction, and fabrication, handling, storage, shipping, cleaning, instal-lation, erection, inspection, testing, operation, maintenance, refueling, repair, and modification of equipment considered significant to safety by the Company.
These structures, systems, and components may be classified as safety-related in that they prevent or mitigate the consequences of postulated accidents, or as in the case of radioactive material packaging and fire protection, they may contribute to causing undue risk to the health and safety of the public or loss of services should they fail or malfunction.
Structures,
- systems, and components not classified as safety-related items are controlled as necessary to provide assurance of quality commensurate with the importance of the function (s) to be performed.
Revision 5 1.8-1 1989
e The. principal objectives of the quality assurance program and the key i
functions and elements which it contains are not expected to change.
t However, circumstances may make advisable changes in the organization or in the implementing detail necessary, and such changes will be made in accordance with established procedures.
Changes in the quality assurance program description.will also be submitted to the NRC as required by 10 CFR 50.54.
The Point Beach Nuclear Plant Quality Assurance Program commits to the guidance provided in ANSI N18.7-1976, except as specifically noted. Where exceptions are noted in the text of this section, the PBNP alternative system is discussed.
Commitment to ANSI N18.7-1976 includes either complete or partial commitment to the following additional standards:
ANSI N18.1-1971 Selection and Training of Nuclear Power Plant Personnel ANSI N18.17-1973 Industrial Security for Nuclear Power Plants ANSI N45.2.1-1973 Cleaning of Fluid Systems and Associated Com-l ponents for Nuclear Power Plants.
ANSI N45.2.2-1972 Packaging,
- Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants (During the Construction Phase)
ANSI N45.2.3-1973 Housekeeping During the Construction Phase of Nuclear Power Plants ANSI N45.2.4-1972 Installation, Inspection, and Testing Require-l ments for Instrumentation and Electric Equipment During the Construction of Nuclear Power Gen-erating Stations ANSI N45.2.5-1974 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants ANSI N45.2.6-1973 Qualification of Inspection, Examination, and Testing Personnel for the Construction Phase of Nuclear Power Plants Revision 3 1.8-2 September 1987
' ^
1 1
Supplementary Quality Assurance Requirements for Installation, Inspection,. and Testing of Mechanical Equipment and Systems for the Con-struction Phase of Nuclear Power Plants ANSI N45.2.9-1974.
Requirements for Collection, Storage, and Main-l tenance of. Quality Assurance Records for Nuclear Power Plants ANSI N45.2.10-1973 Quality Assurance Terms and Definitions i
ANSI N45.2.11-1974 Quality Assurance Requirements for the Design of Nuclear Power Plants ANSI N45.2.12, Requirements for Auditing of Quality Assurance Draft 4, Rev.2 Programs for Nuclear Power Plants ANSI N45.2.13-1976 Quality Assurance Requirements for Control of l
Procurement Items and Services for Nuclear Power Plants ANSI N45.2.23-1978 Qualification of Quality Assurance Program Audit Personnel For Nuclear Power Plants ANSI N101.4-1972 Quality Assurance for Protective Coatings Applied to Nuclear Facilities To the extent required by ANSI N18.7-1976 as hereinafter specifically noted, PBNP hereby commits to the above standards.
Table 1.8-1 provides further information regarding commitments to regulatory guides and related standards.
1.8.1 ORGANIZATION The authorities and responsibilities of persons and organizations perform-ing quality related activities are established, assigned, and documented in a formal system.
All quality assurance and quality control functions are performed by Company organizations (including both on-site and off-site personnel) except when the scope of specific projects dictate the need to engage contractors to perform specific services or as other-wise noted.
Revision 4 1.8-3 June 1988
Those persons and organizations assigned such functions are given appro-priate and sufficient authority and organizational freedom to identify quality problems; verify implementation of the solutions; and prevent further processing, delivery, installation, or use of nonconforming items until proper dispositioning has occurred.
The organizational structure and functional responsibility assignments are such that: (1) attainment of quality objectives is accomplished by individuals assigned responsibility for activities affecting quality or l
performing work to specifications, (2) audits verifying conformance to established quality requirements are accomplished by those who do not have diact responsibility for performing the work being verified, and (3) parsonnel in key quality assurance functions have direct access to responsible management.
The education and experience required of individuals assigned to QA positions is documented and approved by management.
The operating organization is reflected in Figure 15.6.2-2 of the Techni-cal Specifications.
The organization for quality assurance is reflected in Figures 1. 8-1, 1. 8-2, and 1.8-3.
The Vice President-Nuclear Power Department, who reports directly to the Chairman of the Board - Wisconsin Electric Power Company, has been delegated the authority by the Chairman to establish quality assurance policies, goals, and objectives as applic-able to the Point Beach Nuclear Plant and the Nuclear Power Department although the Chairman retains ultimate responsibility.
l Manager - Point Beach Nuclear Plant The Manager-Point Beach Nuclear Plant (PBNP) is the senior company I
representative at the plant facility and, as such, is in direct day-to-day control of all normal plant administration and technical operations.
In matters related to quality assurance, the Manager remains cognizant through direct involvement and through input from various sources includ-ing the in plant Quality Assurance Coordinator and QA Representatives.
The Quality Assurance Coordinator and QA Representatives are appointed by l
the Manager and are considered concurrent assignments.
Their primary l
Revision 5 1.8-4 1989
functions are summarized as follows:
Quality Assurance Coordinator l
1.
Provide primary interface between plant groups and other department groups in matters related to quality assurance.
2.
Report to the Manager on matters involving quality assurance.
3.
Assist plant groups in interpreting quality related codes, standards and procedures.
4.
Provide guidance and direction as necessary to in plant groups in regard to performance of quality related functions, e.g.
records administration, quality control.
5.
Coordinate the updating of in plant quality related procedures primarily the Point Beach Nuclear Plant Administrative Control Policies and Procedures Manual.
(QA Volume I)
Quality Assurance Representatives 1.
Assist their respective plant groups in conforming with QA policies and procedures including QA Volume I and the Nuclear Power Department QA policies and procedures manuals.
2.
Interface with the Quality Assurance Liaison on matters related to quality assurance.
3.
Perform work reviews and QA acceptance as described and required by procedures.
General Superintendent of Quality Assurance I
The General Superintendent of Quality Assurance as the head of the l
Quality Assurance Section reports to the Vice President - Nuclear Power l
Department and has responsibility for both " headquarters" quality assurance functions and various quality assurance activities at the site.
The QA Section has staff located both in the corporate office and at the l
plant.
The Nuclear QA Division is divided into three units (see Figure 1.8-3) with primary responsibilities summarized as follows:
I l
i Site QA Unit 1.
Perform quality assurance reviews of maintenance and modification documents.
In regard to modifications this includes scoping for QA applicability of work to be performed.
2.
Perform reviews of plant generated procurement documents.
These reviews include scoping for QA applicability and establishment of appropriate quality assurance requirements.
3.
Verify conformance of received items to purchase document require-ments through various activities including review of documentary evidence of quality prior to release of the items (Section 1.8.7).
4.
Provide department control of the nonconformance reporting system.
This includes review of nonconforming conditions, review of proposed corrective actions, and verification of corrective actions.
5.
Monitor performance of in plant contractors through surveillance, and perform periodic surveillance of day-to-day plant activities.
6.
Perform trending of nonconformances and internal audit deficiencies.
Audit & Surveys Unit 1.
Implement the internal audit program to verify compliance to established quality assurance program requirements and satisfactory performance of quality activities.
This includes audits of in plant groups as well as off-site company organizations performing quality-related activities for Point Beach.
It also includes audits of the technical specification which are performed under the cognizance of the Off-Site Review Committee.
2.
Perform quality assurance evaluations and audits of vendors and contractors commensurate with the importance, complexity, and quantity of the product or services provided, i
Quality Systems Unit 1.
Maintain the Qualified Suppliers List including periodic review of supplier performance.
Revision 6 1.8-6 1989
~
2.
Maintain and control issuance of quality assurance instructions and procedures manuals including the Nuclear Power Department QA Policy Manual, Nuclear Power Department QA Procedures Manual, and the QA Section Instructions Manual.
3.
Perform QA indoctrination and training, as applicable.
4.
Perform reviews of headquarters generated procurement documents.
The Quality Inspection and Nondestructive Examination Services units also provide limited support to Point Beach including source verification of procured items and inservice inspection activities.
Off-Site Review Committee The Off-Site Review Committee (0SRC) is established in accordance with Technical Specifications, Section 15.6.5.2.
The OSRC selectively reviews l
designated activities involving the operation of Point Beach Nuclear Plant including Technical Specification compliance.
Specified duties and responsibilities are described in the plant Technical Specifications, Section 15.6.5.2.
l In addition to the above, the OSRC is also tasked with the responsibility of assessing the adequacy and effectiveness of the Nuclear Power Depart-ment (NPD) Quality Assurance Program.
This is done in concert with their review functions as described above in addition to review of NPD QA policies, procedures and practices.
Assessment of the program is also achieved through other means such as initiation of periodic audits.
I
- 1. 8. 2 QUALITY ASSURANCE PROGRAM I
4 A quality assurance program is established and implemented in accordance with written policies, procedures, and instructions which comply with the requirements of 10 CFR 50 Appendix B and 10 CFR 71, Subpart H.
The program is also applied to activities such as fire protection to a degree commensurate with Wisconsin Electric commitments.
Specific QA Program applicability to fire protection and radioactive material packaging is defined in Tables 1.8-2 and 1.8-3, respectively.
The Nuclear Power Department Quality Assurance Program is set forth in the NPD QA Policy i
Revision 7 1.8-7 1989
)
+
Manual, the NPD QA Procedures Manual, the NE Administration Manual, and the PBNP Administrative Control Policies and Procedures Manual.
Control I
of the above manuais is as follows:
1.-
Distribution and maintenance of the " Nuclear Power Department Quality Assurance Policy Manual" and revisions thereto are controll-I ed by the General Superintendent - Quality Assurance Section.
The l
policies in this manual are approved by the Vice President - Nuclear Power Department.
t 2.
Distribution and maintenance of the " Nuclear Power Department Quality Assurance Procedures Manual" and revisions thereto are con-trolled by the General Superintendent - Quality Assurance Section.
l The manual procedures are approved by each of the section heads within the Nuclear Power Department.
l 3.
Distribution and maintenance of the "PBNP Administrative Control Policies & Procedures Manual" and revisions thereto is controlled by l
Point Beach Nuclear Plant.
The manual is reviewed and approved on-site by the plant organization.
- Final responsibility for modifications, repairs, maintenance, and opera-tions, including the quality assurance program, lies with the Chairman.
l Management review of the status and adequacy of the quality assurance program is accomplished by at least semiannual review by the Off-Site Review Committee (Section 1.8.1) and by regular briefings (at least once every two months) with the Chairman.
The quality assurance program applies to structures, systems, components (including expendable and consumable items which are used therein) and services which are classified as QA-scope from the standpoint of safety-related functions to be performed.
QA-scope structures, systems and components are identified in the Nuclear Power Department Quality Assurance Policy Manual.
This list is consistant with requirements of the regulations as described in this FSAR, and also includes non safety-related systems and components requiring quality assurance coverage such Revision 4 1.8-8 1989
,as' fire protection.and radioactive material packaging._
Positive controls are implemented to assure updating of the list as necessary.
The classification of a system or component as QA-scope does not imply l
that the complete system, or all the components or component parts within that system, are QA-scope.
Those specific portions of systems considered l
to be QA-scope are also identified in the Nuclear Power Department Quality Assurance Policy Manual.
The program provides for indoctrir.ation and training of personnel per-forming activities affecting queiity as necessary to assure that suitable proficiency is achieved and mnintained.
The indoctrination and training i
program is structured to assure that:
1.
Personnel performing quality activities are instructed as to the purpose, scope and implementation of the quality-related manuals, procedures and instructions; and it is emphasized that these are mandatory requirements which must be implemented and enforced.
2.
Personnel performing quality-related activities are trained and qualified in the principles and techniques of the activity being performed.
3.
Appropriate training procedures are established and that records of training are maintained.
Section 5.2.10 of ANSI W18.7-1976 states that the provisions of ANSI N45.2.3-1973 snall be applied to those activities which are comparable in nature and extent to related activities occurring during construction.
Point Beach Nuclear Plant practices good housekeeping and cleanliness involving activities performed by plant and contractor personnel to maintain the necessary standard of cleanliness.
Scheduled and documented daily-to-weekly surveys of potentially contam-inated or radioactive areas are conducted by health physics personnel, 1
Revision 6 1.8-9 1989
followed by decontamination or radioactive cleanup as necessary.
Surveys
' ensure cleanliness checks of even the least traveled areas.
An addi-tional program provides that Operations shifts are assigned specific plant areas to patrol and c!can up as a housekeeping duty.
Plant policy is that each person is responsible for cleanliness and good housekeeping in their own immediate work area.
Final inspections of work areas following completion of work, including final internal inspections of pressure vessels, tanks, etc., are routinely completed by supervisory personnel.
Such inspections are formally documented only in special cases when considered necessary; these normally being final inspections by plant supervisory personnel following work by outside contractors.
Storage of items are controlled to established quality assurance and fire protection requirements.
Access to safety-related equipment or radiation controlled areas is controlled by security regulations or defined health physics rules.
PBNP complies with OSHA regulations in the physical safety and environ-mental condition of work places.
Significant attention to housekeeping is provided by plant management including frequent housekeeping inspections of portions of the plant by the Manager-Point Beach Nuclear Plant.
This constitutes a complete and in-depth inspection of essentially the total plant on a weekly basis.
1.8.3 DESIGN CONTROL Procedures and practices are established and documented to assure that applicable regulatory requirements and design bases are correctly trans-lated into design documents, such as specification and drawings, for work involving changes or additions to the original design of safety-related structures, systems, and components.
These measures include provisions to assure that appropriate quality standards are specified and included in the design documents and that deviations from such standards are controlled.
The measures also include provisions to control selection and review for the suitability of application of materials, parts, equip-ment, and processes that are essential to the safety-related function.
Revision 4 1.8-10 1989
o
~
Procedures and practices are established and documented for. the identi-fication and control of design interfaces and for coordination among design. Organizations.
These' include procedures among. participating design ' organizations for the review, approval, release, distribution, and revision of design documents.
The design control measures provide for verifying or checking the adequacy of design by design reviews, by alter-nate or simplified calculational methods, or by suitable testing programs performed by individuals or groups other than the originator.
Where.a test program is used to verify the adequacy of a specific design feature, provisions include suitable qualification testing of a prototype unit 'under the most adverse design conditions.
Design control measures consider, as appropriate, reactor physics; stress, thermal, hydraulic, and ' accident analyses; compatibility of materials; accessibility for inservice inspection, maintenance and repair; and delineation of accept-ance criteria for inspections and tests.
Changes to designs are subjected to commensurate design control measures.
-When a contemplated change is considered by appropriate management to be of sufficient scope as to be beyond the expertise of in-house personnel, these changes are reviewed by the organization that performed the origi-nel design, or other design organizations determined to be equally qualified.
Pesign activities associated with modifications of safety-related structures, systems and components are accomplished in accordance with the provisions of Section 8 of ANSI N45.2.11-1974.
1.8.4 PROCUREMENT DOCUMENT CONTROL l
Procedures and practices are established and documented to provide assur-l ance that applicable regulatory requirements, design bases, and other l
requirements which are necessary to assure adequate quality are included or referenced in the documents for procurement of materials, products, or services.
These measures are applied to spare and replacement parts and equipment, new material, and equipment and contracting of services.
Procedures require that procurement documents be prepared, reviewed, and approved in accordance with QA program requirements.
The Quality Assur-ance Section reviews procurement documents to ensure the inclusion of adequate quality criteria.
Records of the review are maintained.
Revision 5 1.8-11 1989 I
~
Procurement documents require suppliess, contractors, or subcontractors
' to~ implement quality assurance programs to the extent necessary.
The programs.are reviewed by the QA Section, qualified third party organiza-I tions. such as the American Society of Mechanical Engineers (ASME),
industry ' organizations such as the Nuclear Procurement Issues Council I
(NUPIC) or joint utility groups.
The evaluation and qualification of cupplier programs is docomented.
l Further details of the system for control of procurement documents is contained in Section 1.8.7.
- 1. 8. 5.
INSTRUCTIONS, PROCEDURES, AND DRAWINGS l
Activities ' affecting quality are prescribed by documented instructions, procedures or drawings appropriate to the work at hand with the work l
accomplished in accordance with these documents.
Measures are esta-blished.. for the preparation, revision, and control' of procedures, in-structions, or drawings.
Instructions, procedures, and drawings are required to include appro-priate quantitative or qualitative acceptance criteria to ensure work has been satisfactorily accomplished.
Supervisors may direct that data be taken without the data taker being cognizant of the acceptance criteria when it is considered that forehand knowledge of the acceptance criteria may prejudice results.
The Sjpervisor is then reponsible to verify conformance.
To the extent applicable, as-built drawings and original equipment and system specifications, subject to improvements resulting from operational experience and subject to the necessary design control, establish acceptance criteria. When required, these instructions, proce-dures, and drawings provide methods for complying with appropriate
-regulations.
Section 5.2.2 of ANSI N18.7-1976 requires that temporary major procedure changes which do not change the intent of an approved procedure be approved by two members of the plant staff knowledgeable in the areas affected by the procedure.
One of these individuals is to be the Duty Shift Superintendent who holds a senior operators license.
As described i
Revision 4 1.8-12 1989
I-I in Section 15.6 of the Technical Specifications, Point Beach follows the
' above guidance for operating procedures.
For Maintenance, Instruments-tion and Control, Reactor Engineering, Chemistry, and Health Physics pro-l cedures, approval is not required from the Duty Shift Superintendent for l
temporary changes.
For a further description of the system for temporary I
changes, refer to Section 15.6.8 of the Technical Specifications.
1 Section 5.3.2 of ANSI N18.7-1976, which discusses the content of proced-1 ures, states in part, "... procedures shall include, as appropriate...(8)
Acceptance Criteria."
PBNP has determined through considerable experi-ence that the incorporation of acceptance criteria is not always advanta-geous, as discussed herein.
- 1. 8. 6 DOCUMENT CONTROL Procedures and practices are established and documented to control the issuance and revision of documents, such as:
maintenance and modifica-tion procedures; design specifications; design, manufacturing, construc-tion, and installation drawings; procurement documents; manufacturing, inspection, and testing instructions; test and operating procedures; QA manuals; safety analysis reports; and related design criteria documents.
The procedures identify responsibility for review, approval, and issuance of the documents and associated changes.
For quality related documents, the review includes an assessment of applicable quality requirements.
The procedures provide assurance that documents, including changes, are reviewed for adequacy, approved for use by authorized personnel and distributed to and used at the location where the prescribed activity is performed prior to commencement of the activity.
These include prompt issuance of changes and control of the obsolete or superseded documents to prevent inadvertent use.
Controls, such as maintenance and distribu-tion of indices, are also implemented to identify current revision of documents to be used.
These provisions are also used as a basis for auditing the document control system.
Document control procedures include provisions for determining responsibility for review of changes to documents.
Revision 6 1.8-13 1989
(.
.o"'
Documents classified as QA records are subjected to the additional require-ments described in Section 1.8.17.
1.8.7' CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES Procedures and practices are established and documented to assure that purchased material, equipment and services conform to the procurement documents.
These measures include review of all purchase requisitions by the Quality Assurance Section.
QA scope requisitions are processed by the Quality Assurance Section to ensure incorporation of appropriate quality requirements.
The bases for selection of suppliers include previous experience, satisfying the required qualifications of the contractor who erected the plant, or'a pre-award evaluation of the proposed supplier's capabilities and qualifications.
Industry' programs, such as those applied by ASME, NUPIC, or other established utility groups, are used as input or the l
basis for supplier qualification whenever appropriate.
Control of purchased items includes provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the contractor or subcontractor, inspection at the source, and examina-tion of products at receipt.
These controls also include provisions for monitoring contractors providing services through performance of audits and surveillance, as necessary, to verify conformance with procurement requirements.
These are performed by appropriately trained personnel in accordance with written procedures and instructions.
Documentary evidence is required to be available prior to use of equipment.
Procedures require assignment of a Quality Assurance Release (QAR) identification number prior to placing the purchased items into service.
These procedures require all documentation required by the purchase order to be available and satisfactory prior to issuance of the QAR.
Measures are provided for monitoring the effectiveness of contractor control of quality consistent with the importance, complexity, and quantity of the product or services.
Revision 6 1.8-14 1989
~
The requirements of ANSI N45.2.13-1976 are met for the procurement of
' components within the scope of Section 5.2.13 of ANSI.N18.7-1976.
1.8.8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS Procedures and practices are established and documented requiring identi-i fication of materials, parts, and components, including partially fabri-cated assemblies, to prevent'use of incorrect or defective items.
Identi-fication requirements are based on as-built drawings and specifications.
1 Identification requirements for. other than identical replacement items are determined during planning for the modification or addition.
Identi-4 fication methods and locations are selected so as not to affect the function or quality of the item.
These measures assure that identification is maintained by stock number, system identification, part number, or other appropriate means, either on the item or on records traceable to the item, as required during instal-lation and use.
These measures apply to plant items as well as those provided by on-site contractors.
Procurement documents invoke appropriate requirements for identification l
and control of material during manufacture, including provisions for WE in process audits of the manufacturer's program.
1.8.9 CONTROL OF SPECIAL PROCESSES Procedures and practices are established and documented to assure that special-processes, such as welding, heat treating, and nondestructive examinations are controlled and accomplished by qualified personnel using qualified procedures or process sheets in accordance with applicable codes and standards.
Verification of conformance is documented.
These measures require copies of qualifications to be on site during process performance whether by WE personnel or contractors.
Procurement docu-ments specify appropriate control requirements for processes performed off-site.
Revision 2 1.8-15 1989
1.8.10 INSPECTION Procedures and practices are established and documented providing for appropriate inspection of activities affecting quality and to verify conformance with the documented instructions, procedures, drawings, or specifications for accomplishing the activity.
Inspection procedures, instructions, and checklists include the following, as applicable:
1.
Identification of characteristics to be inspected.
2.
Identification of the individuals or groups responsible for performing the inspection. operation.
3.
Acceptance and rejection criteria.
4.
The method of the inspection.
5.
Verification of completion and documentation of the inspection.
Maintenance, replacement, or rework items are inspected in accordance with original inspection requirements and criteria or improved require-ments based on operating experience.
Modified items are inspected by methods at least equivalent to the original inspection methods.
These measures provide for verification of conformance to be performed by appropriately qualified individuals other than those who performed the activity.
Quality control inspections may be performed by a workman's first line supervisor; however, quality assurance acceptance is not per-
' formed by the first line supervisor or anyone reporting to him.
Qualifi-cation of these individuals in accordance with appropriate requirements is documented.
Provisions for Code Authorized Inspection are included when required.
Examinations, measurements, or tests are performed for work operations where necessary.
Procurement documents for materials or products specify examinations, measurements, or tests to be performed for each work opera-tions where necessary to assure quality.
Storeroom personnel perform receiving inspection on procured materials as appropriate per the pro-curement documents, specifications, procedures, and instructions.
Storeroom personnel are knowledgeable of the requirements of the quality assurance program. Questions regarding quality assurance are referred to Revision 3 1.8-16 1989
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ = _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ - _.
,. the QA Section.
Procurement documents for materials or products, for l
which direct inspection is impossible or disadvantageous, specify pro-visions for indirect control by monitoring processing methods, equipment, and personnel.
When control is inadequate without both inspection and process monitoring, provisions for both are included.
Mandatory hold points are specified and used where required.
Section 3.4.2.
of ANSI N18.7-1976 states that personnel performing inspection, examination, and testing activities shall be qualified to ANSI N18.1-1971, or shall meet the requirements of ANSI N45.2.6-1973.
With few exceptions, Point Beach personnel meet or exceed the qualifi-cation requirements of ANSI N18.1-1971, and are therefore qualified to perform piant inspection, examination, and testing activities. Those few exceptions are in job functions not discussed in ANSI N18.1-1971 and cer-tain inspection and test personnel who work for contractors as dis-cussed below.
I All positions at Point Beach have been evaluated to determine the minimum qualification requirements.
The areas considered during the evaluation l
Included regulation, code and standard requirements, education and train-l ing, work experience, and physical condition.
Applicants for positions at Point Beach not meeting the minimum requirements, or not satisfying reemployment aptitude testing requirements are not considered for the position.
Additionally, prior to employment, all plant personnel are interviewed by senior plant management and in most cases are interviewed i
by the Manager-Point Beach Nuclear Plant who makes the final determina-l tion of acceptability.
There is only one level of qualification at Point Beach, not three levels as' indicated in ANSI N45.2.6-1973.
I When the extent of the maintenance or modification is such that it must be performed by contract, the potential contractor's QA program is evalu-ated by the QA Section to determine its acceptability.
Included in the evaluation is consideration of the qualifications of inspection and test personnel.
In cases where it is determined that a contractor's organiza-tion is suitably qualified in all other respects, including qualified personnel, a qualification and certification program which meets all the requirements of ANSI N45.2.6-1973 is not insisted upon.
Implementation of the audit program assures qualification of such personnel.
Revision 7 1.8-17 1989 l
All' nondestructive' examination personnel are required to be qualified in
' accordance with the appropriate sectioris and editions of ASNT Recommended Practice No. SNT-TC-1A.
Section 3.2 of ANSI N18.7-1976 requires that verification of conformance be performed by individuals other than those performing or directly supervising the work.
Verification of conformance is conducted in this manner at Point Beach.
Section 5.2.17 of ANSI N18.7-1976 requires inspections for modifications and non-routine maintenance to be performed in a manner similar to that associated with construction phase activities.
Modifications and non-routine maintenance for which outside contractors are used are performed in this mar.r,er.
Modifications and non-routine maintenance items within the capabilities of the onsite operating organization are performed as a routine maintenance activity.
1.8.11 TEST CONTROL Procedures and practices are established and documented to provide a pro-gram of periodic testing and continuing surveillance to demonstrate that I
structures, systems, and components continue to perform satisfactorily in service.
The measures require tests to be performed by appropriately trained and qualified personnel in accordance with written test pro-cedures which incorporate the requirements and acceptance limits (except as noted in Section 1.8.5) from applicable design documents.
Test pro-cedures include provisions for assuring that all prerequisites for the test have been met, that adequate test instrumentation is available and used, and that the test is performed under suitable environmental con-ditions.
Test results are documented and evaluated to assure test requirements have been satisfied.
These measures require replacement or modified structures, systems and components to be subjected to sufficient proof, preoperational, and operational testing to demonstrate that they will perform satisfactorily in service.
Revision 7 1.8-18 1989
,v 1.5.12 CONTROL OF MEASURING AND TEST EQUIPMENT Controlled procedures and practices are established and documented to assure that tools, gauges, instruments, and other measuring and testing devices 'used in activities affecting quality are properly identified, controlled, calibrated, and adjusted at specific intervals to maintain accuracy within necessary limits.
Calibration procedures specify stan-l dards to be used for performing the calibration.
Procedures require that standards used have greater accuracy than the item being calibrated.
I These measures provide for identification of the equipment and associated records and appropriate corrective action when out-of-calibration condi-tions are noted.
1.8.13 HANDLING, STORAGE, AND SHIPPING Procedures and practices are established and documented to control the handling, storage, shipping, cleaning, and preservation of material and equipment by qualified individuals in accordance with work and inspection instructions to prevent damage or deterioration and preclude loss of identification..
The measures include specification and use, when nec-essary, of special protective environments, such as inert gas atmosphere, specific moisture content, and temperature levels.
1.8.14 INSPECTION, TEST, AND OPERATING STATUS Procedures and practices are established and documented to indicate by suitable means, the status of inspections and tests to be performed upon individual items.
These measures include provisions for the identifica-tion of items which have satisfactorily passed required inspections and tests when necessary to preclude inadvertent bypassing of such inspec-tions and tests.
Procedural controls to perform operations out of sequence are established.
These measures also include provisions for indicating nonconforming, inoperative, or malfunctioning components within a system to prevent inadvertent operation.
i Revision 7 1.8-19 1959 l
l
1.8.15 NONCONFORMING MATERIALS, PARTS, OR COMP 0NENTS Procedures and practices are established and documented to control mater-ials, parts and components, or quality activities which do not conform to 1
established requirements. To prevent the inadvertent use or installation of ' purchased material, parts, or components, these measures may include timely return of nonconforming materials, parts, or components to the vendor for' replacement with satisfactory items.
Formal nonconformance control systems are in place to assure control and disposition of noncon-forming items or activities including adherence to 10CFR21 as necessary.
Maintenance Work Requests identify and control nonconforming items requiring repair or rework to be returned to satisfactory condition.
Where a safety-related component is required to be temporarily or permanently changed, such that it no longer complies with the original and approved design, such changes, with required approvals, are made via the approved modification request procedure.
The Nuclear Power Department has established provisions for documenting and dispositioning nonconforming items or conditions, which are identi-fied during inspection, surveillance or auditing activities.
1.8.16 CORRECTIVE ACTION Procedures and practices are established and documented to assure that conditions adverse to quality; such as failures, malfunctions, deficien-cies, deviations, defective material, and equipment and nonconformances; are promptly identified and corrected.
In the case of significant condi-tions adverse to quality, these measures include assurance that the cause of the condition is determined and corrective action taken to preclude recurrence.
These include provisions for identification of the signifi-cant condition adverse to quality, the cause of the condition and the corrective action taken which is documented and reported to appropriate levels of management.
Provisions are included for followup reviews to verify proper implementation of corrective actions and to close out the corrective action documentation.
Revision 5 1.8-20 1989
l
.e 1.8.17-QUALITYASSURANCERECORDS Procedures and practices are established and documented to assure that sufficient records are generated and maintained to furnish evidence of activities affecting quality.
Where practicable, the guidelines of ANSI N45.2.9-1974 apply.
The records consist of at least operating logs and the results of reviews, inspections, tests, ' monitoring,-_ work per-formance, and materials analyses.
Also included are closely related data such as qualifications of personnel, procedures and equipment.
Inspec-tion and test records include, as a minimum, identity of the inspector or data recorder, the type of observation, the results and the accepta-bility, or action taken in connection with any deficiencies noted.
Records are identifiable and retrievable.
Requirements concerning records retention, such as duration, location, and assigned responsibility, are established to be consistent with applicable regulatory requirements.
Radiographs, with the exception of those associated with ASME Section XI components or systems (to be retained for the service life of the component or systems), are retained as non permanent records for a minimum of ten years after the date of the radiograph.
In either case, associated radiographic review records are permanently retained and provide necessary weld quality / acceptance information.
In 1971, Point Beach recognized the need to improve its records manage-ment program in the area of preservation of records.
In the absence of any guidance in the form of regulatory guides or national standards, it was decided to generally follow the requirements of NFPA 232-1970.
The requirements of NFPA 232-1970 were reviewed in light of importance of the records being stored and the risk of destruction of the records.
It was determined that the records being stored required positive protection as many were irreplaceable.
Possible locations for records storage facility were studied, and it was determined that the lower level of the Energy Information Center located on the plant grounds, offered an ideal location for a records storage facility.
l Revision 6 1.8-21 1989 L
- e
^
This location was chosen since it was an area of minimum weight of combustibles and the building itself was fire resistant.
It was deter-mined, based on the above factors, that a separate room would be con-structed in the lower level of the Energy Information Center to provide s
further protection.
The room was built to meet Wisconsin Administrative Code requirements for four-hour construction, and was treated to minimize the risk of water infiltration.
In addition, the room was equipped with an inert gas fire i
suppression system which is automatically triggered by smoke or heat.
Triggering of the fire suppression system also activates an alarm signal and a visible alarm which can be observed from a continuously manned guard station.
Based on the analysis of the fire hazard present in the Energy Informa-tion Center, the alarm system, and the sophisticated fire suppression system, it was decided that the requirement for a four-hour vault door was unnecessary. The entrance to the room is closed with a Class A 250 F labeled fire door.
In addition, the fire suppression system required an electrical supply, which led to the waiving of the requirement that walls.
could not be penetrated by electrical conduit.
The electrical supply for room is brought into the room via a conduit through one of the walls which has been installed to minimize the risk of fire passing through the wall via this penetration.
1.8.18 AUDITS Procedures and practices have been established and documented to provide a comprehensive system of planned and periodic audits to verify compli-ance with all aspects of the quality assurance program and to determine the effectiveness of the program.
Audits are performed in accordance with written procedures or checklists by appropriately trained personnel not having direct responsibilities in the areas being audited.
The QA program is audited periodically, by the QA Section.
The QA Section also performs audits under the cognizance of the Off-Site Review Committee as required by Technical Specification Revision 5 1.8-22 1989 w_____--.-_--__mmm.-_m_
.e 15.6.
On site and off-site contractor audits are scheduled commensurate with the work's' importance to plant safety and reliability and are timed as appropriate for the work scheduled.
Audit results are documented and reviewed by management personnel having responsibility in the area audited.
Audit reports are routed to manage-ment responsible for correcting any unsatisfactory items noted.
Follow-up action, including reaudit of deficient areas, is taken when indicated.
When. follow-up audits reveal repetitive occurrences which reflect pos-sible trends adverse to the effectiveness of the QA program, these results are reported to the appropriate management level to effect corrective action.
In a footnote to Section 4.5 of ANSI N18.7-1976, it is stated that the provisions of proposed ANSI N45.2.12, Draft 4, Revision 2, dated January 1,1976, shall be used for audits performed to meet the requirements of Section 4.5.
Sufficient audits are performed, by the QA Section, in accordance with the provisions of ANSI N45.2.12 to meet the requirements of Section 4.5 of ANSI N18.7-1976.
Also, internal audits performed by the QA Section are lead by individuals certifietl as Lead Auditors in accordance with the requirements of ANSI N45.2.23.
It should be noted that Section 3.2 of ANSI N18.7-1976 recognizes that quality assurance is an interdisciplinary function and that advantages may accrue from having reviews of certain plant functions performed by individuals other than quality assurance personnel.
WE strongly endorses this position.
Typically, the QA Section assigns technically competent quality assurance personnel to perform audits, however when necessary, QA personnel are supplemented with other technically qualified WE and/or contractor personnel.
In addition, certain review and audit functions may be assigned to technically qualified individuals in lieu of quality assurance personnel.
These " technical audits" are performed in addition to those required to meet Section 4.5 of ANSI N18.7-1976, and as such are not performed under ANSI N45.2.12 requirements.
Revision 2 1.8-23 1989 l
yc v-TABLE 1.8-1 ComITMENT TO REGULATORY GUIDES AND' ANSI STANDARDS 1.
Regulatory Guide 1.8 (Safety Guide'8) dated March 10, 1971 Full commitment except that Point Beach commits to ANSI N18.1-1971 in lieu of the proposed ANSI N18.1 dated June 22, 1970.
2.
Regulatory Guide 1.28 (Safety Guide 28) dated June 7,1972 ANSI N18.7-1976 states in part, "This standard fully and com-(
1 pletely describes the general requirements and guidelines of f
ANSI N45.2-1971 as those requirements, and guidelines f
apply. during the operational phase ' of plant life." As such,
)
commitment to ANSI N18.7-1976 for Point Beach obviates the need to commit to Regulatory Guide 1.28 which endorses ANSI N45.2-1971.
Point Beach does, however, commit to the position of Regulatory Guide 1.28 to the extent of requiring its vendors to have qual-ity assurance programs which meet the appropriate requirements of ANSI N45.2-1971 as mentioned in Section 5.2.13.1 of ANSI N18.7-1976.
3Property "ANSI code" (as page type) with input value "ANSI N18.7-1976.</br></br>3" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
Regulatory Guide 1.30 (Safety Guide 30) dated August 11, 1972 Commitment to follow the position of Regulatory Guide 1.30, l
which endorses and supplements ANSI N45.2.4-1972, for activities i
occuring during the operational phase that are comparable in i
nature and extent to related activities during construction.
4.
Regulatory Guide 1.37 dated March 16, 1973 Commitment to follow the position of Regulatory Guide 1.37, which endorses and supplements ANSI N45.2.1-1973, for activities occurring during the operational phase that are comparable in nature and extent to related activities occurring during con-struction.
~ Revision ~1 June 1986
[
1, c.
TABLE 1.8-1 (Continued) 5.
Regulatory Guide 1.38. Revision 1, dated October 1976 Commitment to follow the position of Regulatory Guide 1.38, which endorses and supplements ANSI N45.2.2-1972, for activit-ies occurring during the operational phase that are comparable in nature and extent to related activities occurring during construction.
6.
Regulatory Guide 1.39, Revision 1, dated October 1976 Commitment to follow the position of Regulatory Guide 1.39, which endorses and supplements ANSI N45.2.3-1973, for activit-ies occurring during the opt tional phase that are comparable in nature and extent to re h... A activities occurring during construction except that Point Beach does not commit to the 1
documentation requirements of ANSI N45.2.3-1973 and provides an alternative to the housekeeping zone requirements therein.
Descriptions of these differences are provided in Section 1.8.2.
7.
Regulatory Guide 1.54 dated June 1973 Commitment to follow the position of Regulatory Guide 1.54, which endorses and supplements ANSI N101.4-1972, for activities occurring during the operational phase that are comparable in nature and extent to related activities o: curring during con-
]
struction.
l 8.
Regulatory Guide 1.58 dated August 1973 Commitment to follow the position of Regulatory Guide 1.58, which endorses and supplements ANSI N45.2.0-1973, for activities occurring in the operational phase that are comparable in nature and extent to related activities during construction, except that Point Beach does not commit to the levels of qualification nor separate certification requirements of ANSI N45.2.6-1973.
Descriptions of these differences are provided in Section 1.8.10.
Revision 1 June 1986 L_ _ _ _ _ _____. _ _ _ _ _ _ _
l
,.e
~'
TABLE 1.8-1 (Continued) 9.
Regulatory Guide 1.64 dated October 1973 Commitment to follow the position of Regulatory Guide 1.64, except that Point Beach commits to ANSI N45.2.11-1974 in lieu of Draft 3 Rev.1 dated July 1973, for design activities associated with modif-ication of safety-related structures, systems and components.
- 10. Regulatory Guide 1.74 dated February 1974 Full commitment.
11.
Regulatory Guide 1.88, Revision 1, dated December 1975 Commitment to follow the position of Regulatory Guide 1.88, which endorses and supplements ANSI N45.2.9-1974 and NFPA 232-1970.
Point Beach has determined that the existing records storage facility pro-vides a level of protection to the vital records at the plant which is equivalent to the requirements of Regulatory Guide 1.88.
Des-cription of the differences are provided in Section 1.8.17.
The Point Beach policy for the retention of radiographs and associated review records is outlined in Section 1.8.17.
4 12.
Regulatory Guide 1.94 dated April 1976 Commitment to follow the position of Regulatory Guide 1.94, which endorses and supplements ANSI N45.2.5-1974, for activities occurring during the operational phase that are comparable in nature and extent to related activities occurring during construction.
i
- 13. Regulatory Guide 1.146 dated August 1980.
I Commitment to follow the position of Regulatory Guide 1.146, which l
endorses ANSI N45.2.23, for internal audits performed by the Quality l
)
Assurance Section (QAS).
t
- 14. ANSI 18.7-1976 Refer to Section 1.8,0 for details of the Point Beach commitment.
Revision 4 1988 3
a e,*;
4 TABLE 1.8-2 SUBSECTIONS OF SECTION 1.8 APPLICABLE TO THE FIRE PROTECTION PROGRAM Subject-Subsection Administrative and Organizational 1.8.1, 1.8.2 Design and Procurement Document Controls 1.8.3, 1.8.4
. Instructions, Procedures and Drawings 1.8.5 i
. Document Control 1.8.6 l
Control of Purchased Materials, 1.8.7, 1.8.10 Equipment and Services Inspection 1.8.10 Test end Test Control 1.8.11 Inspection, Test and Operating Status 1.8.14 Nonconforming Items 1.8.15 Corrective Action 1.8.16 l
Records 1.8.17 i
Audits 1.8.1, 1.8.18 Revision 1 1988 i
lF
.i 3
- TABLE 1.8-3 M
SUBSECTIONS OF'SECTION 1.8 APPLICABLE TO SHIPPING
' PACKAGES FOR RADIOACTIVE MATERIALS (10 CFR 71, SUBPART H)
{
t Subject Subsection
)
Organization 1.8.1 Quality Assurance Program 1.8.2 Design Control-
- not applichble Procurement Document Contro1~
1.8.4 Instructions, Procedures and Drawings 1.8.5 Document Control-1.8.6 Control of Purchased Material, 1.8.7 Equipment and Services Identification and Control of 1.8.8 Materials, Parts and Components Control of Special Processes I.8.9 Inspection 1.8.10 Test Control
- not applicable-Control of Measuring and Test Equipment 1.8.12 Handling, Storage and Shipping 1~.8.13 Inspection Test and Operating Status 1.8.14 Nonconforming Materials, Parts or Components 1.8.15 Corrective Action 1.8.16
. Quality Assurance Records 1.8.17 Audits 1.8.18 Design and testing control are activities which are not normally performed by Point Beach Nuclear Plant personnel.
However, these-activities are imposed on suppliers providing radioactive material packaging or associated services, as appropriate.
Revision 2 June 1984
EP F
L E
CE C
D e
U e
M N
S
(
(}
E T
A RO P
RO C
T N
()
E S
I E
DS NC E AR R MU P UO HS E
E R
C R
E M
IC E
F E E TWT gF I
gO SET MM N
TEM gO FRO O
T C
C ET O
(>
r)
RP 1-8 1
S e
E ru C
M T
T g
T F
N N
i E
E R R GP O S 9 S T
ID E
D 0 E O N RI T
S N
N I
E E
NR R G E HE T
CR MHR D
EP P N R
R A
9 S
I RO O
T D
IAF E
E E
HO B R
C C A UT C
P VI M R PS EP O
(
T.
P T
&E C>
EN D
G 0
N N 9
I O
E RIT R EE C P
N U I
R E G T C NS M ENO C
T N
E D
ROS I
E T
NR l
L N
EP AT E
S T N D
E R NE N
C O EM E
T MT T
9 M
C NR N
OA R
t E
I R
D I
RP E
D ME P
C)
ND U
E S
(>
C ne 5
t N
inrep u
S U
la G
r E
e
^ R ne G
N IO T
n t
C e
N
)
E d
YO 3
S n
TIS t
UI n
8 e
E t
V C
n AI e
1 d
N i
UD r
n e
A e
Q R
p E e r
C t
u U
u RA N in ig S
S r
F E A e S
la LR p
A e
r CU u e
Y e
T n
US S S
e NS
(
T U
A G
N A
E U
2 I
Q D
S 8
E 1
RP e
r E
u C
T r
I N
o ig V
t A
a F
L n
s P
id e
r iv R
o t
A o
a E
r C
t L
e n
C g
e e
c U
a n&s e N
n a
r S
a r
T H
M u
p s
e RC C
s R
OE A
A TJ E
AO B
y A
RR il Q
t T
T P a
S N
u I
I NL O
Q IA P
MI l
C D E A PS I
tne dn C
e tn S
ir "1S ep u
Y S S A lar ne e
C G
UN
(
l
s e
ic vre S
E D
N t
inU n
io N
O tc I
ep T
sn A
i Z
y t
I li N
au A
Q G
R O
i N
t t
n E
n U
O C
e 3
I d
N s
- T n
A e
m 8 C R
t SO in e
UN r
t 1
E SI e
s T
p y
e S AC u
S r
E S
YS u
T y
U l
t ig a
E A
e li F
r a
C U
n Q
e u
G Q
NA R
U S
S itn U
A t
s Y
A n
y Q
e e
N d
v T
R0 n
r I
e u
A1S t
E n
S L
LM ir A
CD e
U p
U N
u S
s i
Q t
du A
i t
in U
AQ e
t iS i
I