W3P87-2060, Forwards Changes to QA Program (FSAR Section 17.2) Re Significant Transition at Facility from Const to Operations Phase Which Included Major Reorganization of Nuclear Operations Dept.Fee Paid
| ML20235S735 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 10/01/1987 |
| From: | Cook K LOUISIANA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| W3P87-2060, NUDOCS 8710090119 | |
| Download: ML20235S735 (162) | |
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LOUISlANA POWER & LIGHT COMPANY e Post Office Box 6008 New Orleans. Louisiana 70174 WAl%;
NEW ORLEANS PUBLIC SERVICE INC.
- Post Office Box 60340
- New Orleans. Louisiana 70160 meses October 1, 1987 W3P87-2060 A4.05 QA I
l U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
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SUBJECT:
Waterford 3 SES l
Docket No. 50-382 Updated QA Program Gentlemen:
As required by 10CFR50.54, this is notification of a change in the LP&L Quality Assurance Program. Although the change does not represent a 1
reduction of commitment when compared to the latest QA Program previously accepted by the Nuclear Regulatory Commission, it is being submitted because it is a departure from the program defined in FSAR Section 17.2.
The change, as provided in Attaciunent #1, encompasses the significant transition at Waterford 3 from the construction to the operations phase which included a major reorganization of the LP&L Nuclear Operations Department.
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To aid in your review, the latest approved QA Program description with editorial comments has been included as Attachment #2. The left margin has been coded to provide the location of the specific requirements in the QA Program Change document. Those changes that require brief explanations have been coded with a comment number which corresponds to the Remarks Document (Attachment #3). Other changes which are editorial in nature or have no impact on the QA Program description are not identified due to the extent of the change. Although the changes are extensive, the Updated QA Program continues to satisfy the criteria of 10CFR50, Appendix B.
In accordance with 10CFR50.54(a)(3)(iv) this change shall be considered accepted unless notification to the contrary is received within 60 days from the date of this letter.
Subsequently this change will be submitted in accordance with 10CFR50.71(e).
8710090119 871001 PDR ADOCK 05000382 y
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"AN EQUAL OPPORTUNITY EMPLOYER"
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Page 2 V3P87-2060 Also enclosed with this submittal is the application fee of $150 pursuant to the requirements of 10CFR170. Should you have any questions or need any additional infm uation regarding this matter, please contact P.N. Backes, Nuclear Quality Asnurance Hanager, at (504) 464-3466.
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K.W. Cook
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Nuclear Safety &
I Regulatory Affairs Manager KWC/TJG/dde l
Attachments cc:
R.D. Martin, J.A. Calvo, J.il. Wilson, NRC Resident Inspector's Office, W.M. Stevenson, E.L. Blake NS30671 i;j
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a List of Attachments Attachment #1 Updated Quality Assurance Program (FSAR Section 17.2) l Attachment #2 Quality Assurance Program Change Document Attachment #3 Remarks Document k
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17.2 QUALITY ASSURANCE DURING OPERATIONS 1
17.'2 The Louisiana Power & Light. Company has established a comprehensive program for quality assurance during the operating phase of the Waterford-3 nuclear i
plant. This Nuclear Operations Quality Assurance Program (hereafter referred to.in this document as the Quality Assurance Program) is applied to activities affecting the quality of those items which prevent or mitigate the consequences of postulated accidents which could cause undue risk to public 001 health and safety.
Those activities include:
17.2 P.1 CENERIC a) Turnover of the plant systems and equipment from the construction j
organization; l
b).
Startup testing; I
c)
Preoperational testing; and 1
1 j
d)
Operation, maintenance, repair, modification, and refueling.
1 The Quality Assurance Program as described herein complies with Regulatory Guide 1.33, Revision 2, 1978.
l Table 17.2-1 contains a listing of those Regulatory Guides (including revisio..
number and date) to which LP&L is committed with exceptions and clarifications. Table 17.2-2 identifies procedures manuals that document the 002 Quality Assurance Program. [ The Nuclear Operations Department Quality Assurance nanual (hereafter referred to in this document as the Quality i
17.2 P.3 Assurance Manual) defines the LP&L quality assurance program.l Table 17.2-3 correlates the contents of the Quality Assurance Manual with the criteria of l
In addition, Figure 17.2-4 shows graphically the
-003 hierarchy of quality relatediprograms, procedures, and instructions.
- GENERIC 17.2.1 ORGANIZATION 17.2.1.1 General 77, y
This section defines the organizational structure for executing the Quality Assurance Program. It also defines the quality assurance responsibilities of individuals and organizations performing quality related activities during preoperational testing and plant operation.
Most quality related activities are performed by personnel outside the Ouality 004 Assurance organization.] An overview of the performance of these activities 17.2.1 P.3 relative to Quality Assurance Program compliance is accomplished by Quality Assurance personnel through reviews and audits.
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1 17.2.1.2 Organizations Performing Quality Assurance Functions
'17.2.1 i'.7 Figure 17.2-1 shows the lines of authority for the major LP&L organizations involved in quality assurance for Waterford-3 during preoperational testing and plant operations. Figure 17.2-2 illustrates how gaality related activities of line and support organizations during the operational phase are under the cognizance of the Corporate Quality Assurance Manager and higher 17.2-1 4
i l
9
>th' WSES-FSAR-UNIT-3 level corporate manegement. Figure 17.2-3 amplifies the onsite organization
- 17. 2. l lP. 7 for quality assurance at Waterford-3.
005 The organizations and individuals listed below are involved in the 17.2.1 P.7 implementation of the LP&L Quality Assurance Program and have quality assurance responsibilities as described in the subsections which follow:
REF: 001
- a. LP&L Management
- b. Senior Vice President-Nuclear Operations
- c. Management Audits d Safety Review Committee
- e. Corporate Quality Assurar.ce Manager
- f. Nuclear Operations Quality Assurance Manager
.g. Engineering and Systems Development Quality Assurance Manager-Nuclear
- h. Plant Manager-Nuclear
- 1. Plant Quality Manager-Nuclear
- j. Plant Operations Review Committee
- k. Project Manager-Nuclear 1.. Nuclear Services Manager
- m. Completion Manager-Nuclear
- n. Startup Manager
- o. Joint Test Group
.p. Purchasing and Material Section
- q. Middle South Services
- r. Suppliers / Contractors 17.2.1.2.1 LP&L Management Louisiana Power & Light Company retains and exercises responsibility for the 17.2 P.1 Quality Assurance Program for Waterford-3. The Senior Vice President-Nuclear 17.2.1.1 Operations who reports to the President of LP&L directs the activities of the Nuclear Operations Department. He has overall responsibility for the Waterford-3 plant.
17.2.1.1 17.2.1.2.2 Senior Vice President Nuclear Operations The Senior Vice President-Nuclear Operations is responsible for defining LP&L 006 quality assurance and nuclear safety policies. IReporting to him are the 17.2.1.1 Nuclear Services Manager, Project Manager-Nuclear, Completion Manager-Nuclear, GENERIC Corporate Quality Assurance Manager. Plant Manager-Nuclear, and the Safety Review Committee.1 He appoints the Chairman and members of the Safety Review Committee.
The Senior Vice President-Nuclear Operations reviews status summaries of the 17.2.1.1 P.2 Quality Assurance Program submitted to him by the Corporate Quolity Assurance Manager. These summariss, in addition to his review of annual Management REF: 099 Audit Iresults enable him to adequately evaluate the effectiveness of the Quality Assurance Program. He approves and endorses the Quality Assurance Manual and revisions thereto which defines the documented program for implementation by LP&L organizations.
17.2-2 1
)
O WSES-FS AR-UNIT-3 007 17.2.1.2.3 Management Audits 17.2.2.8 In rder to obtain an independent evaluation of the LP&L Quality Assurance
'TBL 17.2-1 (4-3)
Program, the Senior Vice President-Nuclear Operations appoints a management REF., 100 audit team that is independent of the Quality Assurance Section to conduct an 17.2.1.1 P.2 annual management audit of the program. Members of the audit team are qualified to appropriate standards. Audit rer.ults are documented and reviewed by responsible managers who are required to take commensurate corrective actions. Follow up audits are performed to verify effective corrective actions.
17.2.1.2.4 Safety Review Committee 17 2.1.2 The Safety Review Committee (SRC) has been established to provide Louisiana Power & Light Company's senior management additional assurance that Waterford-3 is operated and maintained in accordance with the Operating License, Technical Specifications, and applicable Federal and State regulations which address nuclear safety and in such a manner as to present no undue risk to the public health and safety. The SRC provider for independent review and audit of Waterford-3 operations; reviews changes or modifications which involve an unreviewed safety question; reviews safety evaluations of changes made to the plant and plant procedures under the provisions of 10 CFR l
50.59; and performs special evaluations, reviews, and audits as may be requested by the Senior Vice President-Nuclear Operations.
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17.2.1.2.5 Corporate Quality Assurance Manager i
17.2.1.3.0 l
The Quality Assurance Section under the direction of the Corporate Qaality l
Assurance Manager has the authority and responsibility for developing, I
coordinating, and assuring implementation of the LP&L Quality Assurance l
Program. The Corporate Quality Assurance Manager maintains an overview of Waterford-3 quality related vetivities through reviews and audits. He and his staff have sufficient authority and organizational freedom to effectively:
17.2.1 P.5 l
a)
Identify quality assurance problems; b)
Initiate, recommend or provide solutions through designated channels; and c)
Verify implementation of solutions.
The Corporate Quality Assurance Manager and the Quality Assurance Section personnel under his direction have authority, which is delineated in writing, to stop or control further processing, delivery or installation of nonconforming material. They have the authority to direct work stoppage when work is not being performed in accordance with approved drawings, specifications, procedures or regulatory requirements and/or when conditions exist which could be significantly adverse to quality if the work were to continue.
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WSES-FSAR-UNIT-3 17i2.1.3.0.1 17.2.1.2.5.1 Responsibilities of the Corporate Quality Assurance Manager The principal responsibilities of the Corporate Quality Assurance Manager are:
a a)
Planning, organizing, and administering the Quality Assurance Program; h
b)
Developing, reviewing, approving, and maintaining administrative control of the Quality Assurance Manual and changes thereto; c)
Advising on the scope and content of quality assurance training courses 17.2.2.2 P.2 for personnel performing quality related activities; d)
Assuring effective implementation of the Quality Assurance Program through a comprehensive system of reviews and audits; e
008 e)
Verifying satisfactory performance of quality assurance functions and activities at Waterford-3. In addition to the audit program noted above, this DELETED is achieved through:
- 1) Evaluating Quality Assurance Programs and activities of LP&L's g
suppliers and contractors of quality related material, spare parts and services; j
- 2) Reviewing internally generated drawings and specifications and changes thereto to ensure inclusion of quality assurance requirements; k
- 3) Reviewing and concurring with quality related procurement documents generated offsite;
- 4) Conducting pre-award evaluations for quality assurance requirements of g
vendors, suppliers, and contractors where applicable; and i
- 5) Auditing activities of Middle South Services as they relate to Waterford-3.
1 f)
Developing and maintaining Quality Assurance Section Procedures; g)
Serving as a member of the Safety Review Committee; 009 DELETED h)
Establishing and maintaining a qualified suppliers list for use in n
procuring quality related items and services; 010 t)
Assisting in establishing and administering that portion of the Training Program that addresses quality assurance; and
- DELETED n
j)
Analyzing conditions adverse to quality for quality trends.
17.2.1.2.5.2 Corporate Quality Assurance Manager's Qualifications pij 17.2.1.3.0.2 The principal qualifications for the Cor,. orate Quality Assurance Manager are:
a)
Graduate of a college or university with a Bachelor's degree in an engineering, science or related field, or equivalent capabilities; 17.2-4
a 0-WSES-FSAR-UNIT-3
--Con ' t.
b)
A minimum of four years experience in quality assurance or a quality assurance related activity with at least two of those years in the nuclear power industry as-a manager or supervisor; c)
Experience in development and implementation of quality assurance programs, plans, and procedures; d)
Expertise in interpretation and application of Appendix B to 10 CFR 50 and related codes, standards,and regulatory guides; e)
Knowledge of inspection and nondestructive testing requirements; f)
Ability to plan, to organize, and to administer a Quality Assurance Program; and g)
Ability to maintain an effective working relationship with employees, contractors, suppliers, government agencies, and the public, 012 17.2.1.2.5.3 Engineering and Systems Development Quality Assurance Group 17.2.1.3.0 The Engineering and Systems Development Quality Assurance Group is directed by a Quality Assurance Manager-Nuclear who reports to the Corporate Qaality j
Assurance Manager.
The Engineering and Systems Development Quality Assurance Group has the responsibility for:
1 a)
Developing and maintaining LP&L Quality Assurance policies and procedures; l
b
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d b)
Assisting other LP&L groups in development of quality procedures and instructions; c)
Conducting surveys and audits of major contractors and vendors to verify g
l compliance with applicable requirements and guidance; i
d)
Auditing those offsite groups within LP&L and Middle South Services who perform quality related activities for Waterford-3; maintaining documentation i
of quality assurance activitles; h
e)
Issuing and updating the Qualified Suppliers List (QSL) for use in procurement of quality related materials, spare parts, and services for Waterford-3; and 17.2.2.2 P.2 f)
Providing assistance in establishing and administering those portions of Nuclear Operations training progfams which address quality assurance.
g)
Conducts surveillance of quality related suppliers in accordance with g
written procedures.
d h,k h)
Provide assistance in the procurement of quality related materials, spare parts, and services.
17.2-5 1
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REF: 012 17.2.1.2.5.4
' Nuclear Operations Quality Ascurance Group (Onsite) 17.2.1.3.0.1
.The Nuclear Operations Quality Assurance Group located onsite at Waterford-3
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is headed by the Nuclear Operations Quality Assurance Manager-Nuclear who reports directly to the Corporate Quality Assurance Manager. The Nuclear Operations Quality Assurance Group has the authority to communicate directly' with plant and support organizations. This group assures that the Quality
' Assurance Program at the site is being effectively implemented by:
l aI Reviewing procurement documents generated offsite to ensure inclusion of k
applicable requirements; b)
Reviewing selected quality related administrative procedures to verify c
inclusion of requirements defined by the Quality. Assurance Manual; j
c)
Reviewing internally generated design drawings and specifications, and changes thereto to assure that the documents are prepared, reviewed, and approved in accordance with applicable procedures and contain the necessary quality assurance requirements; 013 ld)
Interfacing with the Plant Quality Group; l
-DELETED e)
Providing assistance to plant and support organizations on matters related GENERIC d to quality assurance; and f)
Monitoring plant activities to verify compliance with applicable e
requirements; e
g)
Conducting audits of quality related activities.
17.2.1.4.l' 17.2.1.2.6 Plant Manager-Nuclear 014 The Waterford-3 plant operations organization is headed by the Plant GENERIC Manager-Nuclear (hereinafter referred to as Plant Manager). He reports directly to the Senior Vice President-Nuclear Operations.
The Plant Manager, is responsible for operation and maintenance of the plant and has responsibility for implementation of administrative and quality assurance measures. This responsibility includes:
h a)
Providing and maintaining a trained and qualified staff to safely operate and maintain the plant.
i b)
Assuring development and proper implementation of plant quality related procedures and instructions for activities such as plant operations, maintenance, repair, test, and inspection; 015 c)
Participating as a nember of the Safety Review Committee; DELETED 1
j d)
Addressing matters brought to his attention by the PORC.
17.2-6 i
4
WSES-FSAR-UNIT-3 An Assistant Plant Manager, designated by the Plant Manager, is responsible 17.2.1.4.1 P.2 for managing the plant in the absence of the Plant Manager. The responsibilities of an Assistant Plant Manager with regard to chairing the PORC are described in Chapter 13.
Reporting directly to the Plant Manager are the Assistant Plant Manager-Plant 17.2.1.4.1 P.3 Operations and Maintenance, the Administrative Manager-Plant Administrative Services, Plant Training Manager, Assistant Plant Manager-Plant Technical Services, and the Plant Quality Manager. The Operations Superintendent, Shift Technical Advisor (STA) Superintendent, Planning and Scheduling Supervisor, sad Maintenance Superintendent report to the Assistant Plant Manager-Operations and Maintenance. The Technical Support Superintendent and the Radiation Protection Superintendent report to the Assistant Plant Manager-Plant Technical Services. The Plant Technical Services unit incluues the Technical Support Group which provides day-to-day engineering and technical support for plant operation and maintenance activities. Plant Administrative Services Group functions include security, materials management, and plant records management.
The Plant Staff is responsible for the development of plant procedures and instructions and for assuring that quality related activities are carried out in accordance with same. The Plant Staff is also responsible for the accuracy, adequacy, and completeness of records generated during startup and plant operation.
The Plant Manager directs the activities of Plant Startup Phase III.
016 17.2.1.2.6.1 Plant Quality Manager GENERIC The Plant Quality Manager has direct responsibility to implement the requirements of the LP&L Quality Assurance Program related to Waterford-3 onsite-initiated activities. These responsibilities include:
.2.1.3.0.1 a)
Provide a Plant Quality Department adequate to meet Waterford-3 review, a
inspection, verification, and surveilitace requirements; 17.2.1.4.6.f b)
Provide training to develop, maintain, and test the skills of inspection 17.2.10.4 personnel; 17.2.1.3.0.1.c,j c)
Provide reviews of instructions, procedures, and drawings to ensure i
17.2.5.2 P.2 inclusion of quality requirements; j
i d)
Provide material receipt inspections;
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Perform or survey nondestructive examinations and other special processes;
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f)
Provide inspection and/or verification to assure maintenance of j
C bI safety-related materials, parts, and components as required by LP&L's Quality Assurance Program; g)
Identify, segregate, review, disposition, and provide notification of the s
affected organization of nonconforming materials, parts, components, or services; 17.2-7 l
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WSES-FSAR-UNIT-3 i
h)
Track the status of nonconformances until the conditions have been o
properly evaluated, corrected, and safeguards have been instituted to preclude repetition; k
i)
Provide reviews of procurement documents to ensure inclusion of quality requirements; 1
j)
Prepare inspection instructions; k)
Provide onsite quality program statur reports; m
I 017 17.2.1.2.6.2 Plant Quality Organizational Freedom j
17.2.1 P.5 Figures 17.2-1 and 17.2-3 show the lincs of communication between the Corporate Quality Assurance Manager, the Nuclear Operations Quality Assurance Manager, and the Plant Quality Manager necessary for resolving quality I
problems. The Plant Quality Manager and his staff have the authority and
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organizational freedom to perform their quality functions effectively. They:
a)
Identify quality problems; b)
Initiate, recommend or provide problem solutions through designated channels; and c)
Verify implementation of satisfactory solutions.
In accordance with approved procedures, and as delineated herein, the Plant Quality Manager and his staff have the authority to stop unsatisfactory work and to control the further processing, delivery, or installation of nonconforming material at Waterford-3. The Plant Quality Manager and his staff do not have direct responsibility for performance of work which they verify / inspect for conformance with established requirements.
018 17.2.1.2.6.3 Plant Quality Manager's Qualifications DELETED a)
High school graduation plus ten years of related experience in equivalent inspection, examination, or testing activities; or high school graduation plus eight years experience in equivalent inspection, examination, or testing activities, with at least two'as Level II, and with at least two years associated with nuclear facilities, or if not, at least sufficient training to be acquainted with the relevant quality assurance aspects of a nuclear facility, or b)
Completion of college level work leading to an Associate Degree and seven years of related experience in equivalent inspection, examination, or testing activities, with at least two years of this experience associated with nuclear facilities, or if not, at least sufficient training to be acquainted with the relevant quality assurance aspects of a nuclear facility, or c)
Four-year college graduation plus five years of experience in equivalent inspection, examination, or testing activities, with at least two years of experience associated with nuclear facilities, or if not, at least sufficient 17.2-8
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i WSES-FSAR-UNIT-3 Con't training to be acquainted with the relevant quality assurance aspects of a
'l nuclear facility.
1 2
17.2.1.4.1.1 17.2.1.2.7 Plant Operations Rcview Committee l
l The PORC is established to ensure onsite review and evaluation of plant 1
operation, maintenance, and test programs. The PORC reports to the Plant Manager and advises him on matters related to nuclear safety, including referral of topics requiring review and potential action by the Safety Review Committee. PORC membership and responsibilities are in accordance with j
Section 6.0 of the Technical Specifications (FSAR, Chapter 16).
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17.2.1.2.8 Project Manager-Nuclear l
019 DELETED The Project Manager-Nuclear who is responsible for direction and l
administration of the Project Management Group during construction completion I
and operation. This includes managing and controlling the activities of the l
Engineering and Nuclear Safety, Construction, Contracts, Records &
Administration, and Cost / Scheduling Departments.
The functions of Project Management include:
a)
Managing the design change process, including initiation, implementation 17.2.1.4.4.a and documentation of design changes, and coordinating this activity with the plant staff; b)
Reviewing and assessing the safety significance of NRC orders, bulletins, 17.2.1.4.3 circulars, and generic letters; IE inspection reports; and operating expetience information from other sources; 17.2.1.4.3 c)
Conducting independent review of plant staff activities affecting safety; d)
Recommending corrective actions to be taken in regard to safety issues; 020 DELETED e) 17 ', I
- h
- I Reviewing selected plant operating, alarm, and emergency procedures for 17. ' ' 1. 4.1.' 1 technical adequacy; 2.
17.2.1.4.1.1 f)
Providing technical input in the selection of outside contracted 17.2.1.4.4.d engineering sources for selected station modifications and managing contracted activities; 17.2.1.4.4.d 8)
Providing and managing contract support for retrofit and maintenance activities; h)
Managing cost control measures and capital expenditure, and operations and 17.2.1.4.1 maintenance budgets; i)
Purchasing necessary operational spare parts in support of station
- 17..,. l. 6. b modifications; 021 j)
Integrating schedules; DELETED 17.2-9
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WSES-FSAR-UNIT-3 022 k)
Ensuring orderly transfer of structures from construction to the plant I
DELETED staff; and 1)
Providing support for records management including execution of the 17.2.1.5.m document control and quality assurance record storage program, i
17.2.1.5 17.2.1.2.9 Nuclear Services Manager The Nuclear Services Group is responsible for providing support to the Waterford-3 Plant Staff and interfacing with Nuclear Services Group consultants and other organizations. This group includes Nuclear Support and Licensing, Emergency Planning, and Special Projects.
The functions of the Nuclear Services Group include:
a)
Coordinating and reviewing responses to Federal, State, and local a
regulatory agencies, including license related matters; b
b)
Managing the preparation of FSAR updates and responses to IE bulletins, circulars, generic letters, and information notices; d
c)
Administering environmental licensing activities; J
d)
Managing the preparation and approval of the Waterford-3 Emergency Plan e
and implementing procedures; e)
Coordinating the preparation of emergency drill scenarios and performance g
of practice drills; i
f)
Coordinating the activities of Middle South Services relative to nuclear fuel material, conversion, enrichment, fabrication processes, and in-core fuel management; 17.2.1.5.J g)
Coordinating and providing technical support, as required, to radwaste, 17.2.1.4.2.d radiation control, health physics, and ALARA programs; and 023 h)
Providing plant special projects support, including: reliability and DELETED maintainability improvements, plant monitoring computer development, training simulator procurement, and Emergency Operations Facility conceptual design.
i 024 17.2.1.2.10 Completion Manager-Nuclear DELETED The Completion Manager-Nuclear is responsible for the transition of Waterford-3 fram the construction to the operations phase. This includes ensuring that the testing and startup activities result in an effective transfer of plant systems to the plant staff. The Completion Manager-Nuclear functionally reports to the Project Manager-Nuclear for system transfers. He reports to the Senior Vice President-Nuclear Operations for all other matters.
17.2-10
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WSES-FSAR-UNIT-3 Con't.
17.2.1.2.10.1 Waterford Startup Group The Startup Manager who reports to the Completion Manager-Nuclear is responsible for managing Waterford-3 Star *up activities. The Wacerford Startup Group's responsibilities include:
a)
Preparation of startup administrative and test procedures; b)
Planning and coordinating tests; c)
Directing and supervising startup testing activities; d)
Documenting and evaluating test results; e)
Ensuring orderly transfer of plant systems, and components to the plant staff including a complete status of same; and f)
Providing assistance to the Plant Staff during Phase III testing.
17,2.1.2.10.2 Joint Test Group The Joint Test Group (JTG) is composed of personnel from LP&L's Waterford-3 Startup Group, Quality Assurance, construction, contractors / consultants, and the Plant Staff. The JTG is responsible for procedure reviews and review of j
prerequisite (Phase I) and preoperational (Phase II) test results. The JTG is also responsible for recommending the disposition of test results for Phase II testing to the Plant Manager. The JTG is responsible for conducting a comprehensive review of the Phase II test program prior to initial fuel load and the start of Phase III testing. They function as an advisory group to the PORC during Phase III testing. The JTG reports to the Startup Manager.
17.2.1.6 17.2.1.2.11 Purchasing and Materials Section The LP&L Purchasing and Materials Section of the Corporate Services Department performs various functions to support procurement of quality and non-quality related material, equipment, spare parts, and services. These functions include preparation and release of bid requests, coordination of bid evaluations by Quality Assurance and engineering groups, as required, and issuance of procurement documents.
17.2.1.7 17.2.1.2.12 Middle South Services LP&L delegates to Middle South Services, Inc. (MSS), the authority to perform those quality assurance functions necessary to ensure that the nuclear fuel is I
I designed and fabricated in accordance with regulatory requirements and accepted codes, standards, and specifications. The MSS Quality Assurance f
Section monitors the design and fabrication of the fuel through a program of audits of the fuel fabricator, including both design review audits and fuel fabrication audits. MSS also conducts audits of component suppliers as deemed l
necessary to ensure the quality of the fuel.
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Formal audit repe-$s are issued by MSS to document their audit activities and l
to identify norg-is.'mances or other items requiring action by-the~ fuel p
L fabricator. Rest'.Aion of nonconformances or other items requiring action is
-verified by MSS and focumented in follow-up reports. The LP&L Corporate Quality Assurance Manager is on distribution for all audit and follow-up reports pertaining to LP&L and Waterford-3, MSS is.also utilized to complement and supplement LP&L teams during Quality Assurance audits and surveys. The MSS Quality Assurance Section interfaces with and reports through the LP&L Corporate Quality Assurance Manager for the above activities. The MSS Quality Assurance Section conducts internal audits of those quality related activities associated with Waterford-3 that are performed by other MSS groups.
LP&L Management may use MSS to conduct supplemental interr.al management audits i
of the LP&L Quality Assurance Program. For this purpose, MSS Quality Assurance reports to the LP&L Senior Vice President-Operations.
MSS also provides support to LP&L in the areas of Nuclear Engineering, Fuel Management, and Nondestructive Examination (NDE) activities.
17.2.1.8 17.2.1.2.13 Suppliers / Contractors Suppliers / contractors of quality related material, equipment, spare parts, and/or services are, as appropriate, required by the procurement documents to have a quality' assurance program. In such cases, a line of communication exists between the supplier / contractor and the LP&L Quality Assurance organization. The overall responsibility for quality assurance at Waterford-3 remains with LP&L at all times.
The quality assurance functions performed by suppliers of quality related items and services depend upon the nature of. the activities, services.
l equipment, materials, systems, and/or components provided. Supplier Quality Assurance Program requirements are prescribed through procurement documents to provide controls and documentation in accordance with the scope of activities involved and their importance to safety.
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17.2.2 QUALITY ASSURANCE PROGRAM 17.2.2.1 General 7.2.2.1 LP&L's objective is to design, construct, test, operate, maintain, and modify the Waterford-3 nuclear plant with the highest degree of functional integrity and reliability necessary to avoid undue risk to the health and safety of employees and the general public. It is the policy of LP&L that the program j
for the design and design changes, procurement, fabrication, installation, I
inspection, testing, operation, maintenance, repair, refueling, and modification of Waterford-3 complies with the requirements of 10 CFR 50, Appendix B and related regulatory guidance.
This section describes LP&L's Quality Assurance Program for Waterford-3 which l
l assures that quality related activities are performed in a controlled manner L
17.2-12
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WSES-FSAR-UNIT-3:
and documented to provide objective evidence of compliance with NRC regulations and' guidance. This program takes.into account the need for j
special controls, processes, test equipment, tools, and skills to attain the required quality, and the need for verification of quality by inspection, j
testing, surveillance, and audit. The design control portion of this program i
will be implemented 60-days prior to fuel loading. This program as it
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applies to other areas will be implemented 90 days prior to fuel loading with applicable portions applied to preoperational testing before that time.
Procedures are developed by LP&L to assure that the Quality Assurance Program complies with the requirements of 10 CFR 50, Appendix B.
These are applicable throughout the operational phase, including startup testing (Phase I, II, and III) (see Chapter 14).
Additionally, when directed contractors / suppliers of quality related equipment and services are required to demonstrate compliance with the provisions of LP&L's Quality Assurance Program.
I The Quality' Assurance Program is implemented by those organizational groups
'l and departments wriose activities affect quality at Waterford-3 (Figure 1
17. 2-1 ) -. The personnel within these groups and departments use approved i
procedures that control quality related activities. These approved procedures incorporate the requirements of the regulatory guides and the NRC endorsed ANSI Stande.rds to which LP&L has specifically committed. Indoctrination and training programs are provided to train personnel in the requirements of the Quality Assurance Program.
17.2.2.3 17.2.2.2 Development of Program Figure 17.2-4 depicts, in graphic form, the hierarchy of documents comprising LP&L's Quality Assurance program. This figure illustrates the relationship of the various programs, procedures, and instructions which control the quality related activities for Waterford-3. The Quality Assurance Program defines the duties of individuals and organizations participating in quality related activities.
J REF: 002 The quality assurance policies, goals, and objectives are documented in the i
Quality Assurance Manual. This document provides the means for communicating 17.2.2.3.b the understanding that implementation of the Quality Assurance Program is f
17.2 P.3 mandatory for responsible organizations and individuals and is enforced, j
Quality Assurance Program policy is approved by the Senior Vice President-Nuclear Operations.
The hierarchy of documents in the Quality Assurance Program is as follows:
17.2.2.3 a)
The first tier of documents consists of those government regulations; 3
industry codes and standards; and LP&L policies and directives, commitments, l
specifications, and criteria necessary to design, construct, operate, and maintain Waterford-3. An intergral part of this tier is Chapter 17.2 of the Waterford-3 FSAR.
.b b)
At the second tier of documentation, the Quality Assurance Manual defines j
the responsibilities, interfaces, and authorities of LP&L personnel, 1
17.2-13
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.WSES-FSAR-UNIT-3 contractors, vendors, and suppliers during the operation and' testing phases of Waterford-3. The Quality Assurance Manual defines LP&L's requirements to implement 10 CFR 50, Appendix B and its regulatory guides, and ANSI Standards which'are listed in Table 17.2-1.
The individual Nuclear Operations Department groups assigned responsibilities 17.2.2.1 P.3 under the scope of the Quality Assurance Manual are responsible.for the development, maintenance,.and implementation of procedures and instructions to L
detail respective elements of program performance.
The Quality Assurance Manual assigns to the Corporate Quality Assurance 025 Manager the responsibility and authority for developing, coordinating, and DELETED' evaluating the implementation of the Quality Assurance Program, and to responsible Nuclear Operations Department managers the authority and responsibility for the execution of the administrative controls and quality assurance s.aasures. Responsibilities for approval and control of the Manuals and procedures are defined in Table 17.2-2.
A listing of manual assignees is maintained and revisions are issued as necessary to ensure effective implementation of regulatory requirements.
Personnel holding controlled copies of the mant,a1 are required to remove superseded and outdated pages when filing revisions.
The Corporate Quality Assurance Manager is responsible for review of selected 17.2.5.2 P.2-procedures that implement the QA program (Figure 17.2-4).
FIG. 17.2-3.
17.2.2.3.c c) The third tier of documentation is departmental /section level procedures and instructions which implement the Quality Assurance Manual.
026 The Plant Operating Manual (POM) consists of a series of procedures that address required aspects of plant management and operations. [These.
TBL 17.2-2 procedures:
- 1) Implement the policy and direction of the Quality Assurance Manual to provide control over qualit related operations and activities to a degree f
consistent with their importance to safety; j
- 2) Provide a clear understanding of the operating philosophy at f
Waterford-3; and I
- 3) Delineate the responsibilities and authorities of Waterford-3 plant personnel.
The Quality Assurance Section Procedures Manual provides procedures to specify and control the activities of the Quality Assurance Section.
{
The Startup Administrative Procedures identify to individuals associated with i
the Startup Test Program their respective responsibilities and the procedures which govern the administration of the Startup Test Program.
I l
Project Management Procedures and Nuclear Services Procedures prescribe j
activities and responsibilities which apply to the Nuclear Services and Project Management Groups based on LP&L's commitments to codes, standards, and quality assurance requirements.
17.2-14
o WSES-FSAR-UNIT-3 i
'17.2.2.4 17.2.2.3 Identification of Safety Related Structures, Systems and Components The Quality Assurance Program provides control of activities affecting the quality of structures, systems, and components to an extent commensurate with their importance to safety. Table 3.2-1 of this FSAR provides the safety related classification of plant structures, systems, and components and identifies those items subject to the 10 CFR 50, Appendix B, Quality Assurance Program as herein described.
Procedures for preparation and control of procurement documents provide guidance for determination of classification of spare and replacement parts.
These procedures require that applicable codes, standards, and regulations, as well as the FSAR be reviewed and considered when determining the classification of spare or replacement parts or materials.
17.2.2.4 Resolution of Disputes 027 Disputes involving quality, arising from a difference of opinion between the Plant Quality Group and other plant groups (Maintenance, Operation, etc.) or 17.2.2.5 contractor / suppliers of quality related equipment and services are normally I
resolved through the Plant Manager. If a satisfactory resolution cannet be reached, the Plant Quality Manager has the organizational freedom to bring the dispute to the attention of the Nuclear Operations Quality Assurance Manager or to the Corporate Quality Assurance Manager, if necessary, using the line of communication shown in Figure 17.2-1.
Disputes involving quality, arising from a difference of opinion between the Quality Assurance Section and the Nuclear Operations Department are resolved through the LP&L Senior Vice President-Nuclear Operatiens.
]
Disputes involving quality, arising from a difference of opinion between the j
Quality Assurance Section and other departments within LP&L, but external to the Nuclear Operations Department, are normally resolved via direct
)
interaction between managers involved.
If a satisfactory resolution cannot be reached, the disputes are resolved through higher levels of management.
17.2.2.6 17.2.2.5 Quality Assurance Indoctrination and Training Indoctrination and training programs are established for Nuclear Operations l
Department personnel performing quality related activities. The program is
)
designed to ensure that personnel involved are knowledgeable in the quality assurance procedures / requirements and have the necessary proficiency to implement the requirements. The scope, objective, and method of implementing-the indoctrination and training program are documented in approved procedures.
028 The Plant Manager is responsible for the conduct of quality assurance and administrative controls training to assure that Nuclear Operations Department j
17.2.2.2 personnel are properly trained to perform activities in a safe and ef fective manner.I Ihe Quality Assurance Section assists with the development and 17.2.2.2 conduct of quality assurance indoctrination and training. The Corporate 17.2-15 4
e
WSES-FSAR-UNIT-3 y
~17.2.2.2 Quality Assarance Manager reviews and concurs with the content of quality assurance indoctrination and training programs.
17.2.2.6 The Quality Assurance Training and Indoctrination Program requires that a)
Personnel responsible for performing activities that affect quality are a
instructed on the purpose, scope, and implementation of quality related manuals, instructions, and procedures; b
b)
Personnel performing activities that affect quality are trained and qualified in the principles, techniques, and requirements of the activity being performed; c)
Proficiency and requalification of personnel performing activities c
requiring certification are maintained by retraining, re-examining, and/or decertifying on a periodic basis; 029 d)
Proficiency tests be given to those personnel performing and verifying d
activities affecting quality, and acceptance criteria developed to determine if individuals are properly trained and qualified; e)
Certificates of qualification clearly delineate (1) the specific functions e
personnel are qualified to perform and (2) the criteria used to qualify personnel in each function; and e
f)
Documentation concerning training and qualification programs which describes the content, who attended, and results of tests as required by the training program are maintained.
The training program for Waterford-3 is further described in Chapter 13.
030 The Quality Assurance Section conducts audits of other organizational units, 17.2.18.3 P.4.bsuch as vendors, suppliers, and contractors engaged in quality related activities to verify that personnel are adequately trained, indoctrinated, and qualified.
17.2.2.7 17.2.2.6 Controlled Conditions for Quality Affecting Activities Quality affecting activities are accomplished under controlled conditions by personnel with the necest.ary skills to attain the required quality.
Activities affecting quality are performed with appropriate equipment, under suitable environmental conditions and with the assurance that prerequisites for inspections and tests have been satisfied.
17.2.2.B 17.2.2.7 Management Review of the Quality Assurance Program 17.2.18.10 3 7 ' ',, ' 3
- 7 p, 4 The Senior Vice President-Nuclear Operations ensures that a management audit of LP&L's Quality Assurance Program is conducted annually by a qualified independent auditing organization.
The information from these management audits in conjunction with summaries of the Quality Assurance Program status presented to him by the Corporate Quality 17.2-16
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l WSES-FSAR-UNIT-3 l
Assurance Manager enables the Senior Vice President-Nuclear Operations to assess the scope, status, implementation, and effectiveness of the program and takes action to assure that the program complies with applicable regulatory requirements.
031 17.2.2.8 Startup Testing (Phase I, II, and III) and Systeas Turnover DELETED The startup test program is part of the overall Quality Assurance Program.
This program meets the intent and guidance of applicable regulatory guides and standards listed in Table 17.2-1.
The testing and turnover activities are accomplished by qualified personnel using approved and controlled procedures and drawings. Required records documenting the activities are controlled and maintained in accordance with program requirements. Responsibilities and control of quality related activities will be transferred from the principal contractors to LP&L during the phase out of design and construction, and during preoperational testing and plant turnover in accordance with contractual requirements.
032 17.2.2.9 Maintenance of Quality Assurance Program DELETED Amendments to the FSARland revisions to the Quality Assurance Manual lare issued as necessary to' support effective implementation of the Quality Assurance Program. The NRC is notified annually of any changes to the Quality Assurance Program description that do not reduce the commitments previously accepted by the NRC.
If a change is contemplated which would reduce the commitments in the approved Quality Assurance Program description, the proposed change is submitted to the NRC for approval prior to implementing the change.
LP&L requires their principal contractors to notify LP&L of changes to their Quality Assurance Program description. Significant changes are reported, as applicable, to the NRC in writing. In addition, LP&L requires principal contractors to provide notification of changes which reduce the commitments to a subcontractor's Quality Assurance Program description which have the effect of changing the Quality Assurance Program of the principal contractor or LP&L.
033 17.2.2.10 Fire Protection Program 17.2.2.10 The Quality Assurance Program for Fire Protection is under the control of the Corporate Quality Assurance Manager. This program as defined in the :uality Assurance Manual consists of the necessary 10 CFR 50 Appendix B criteria. The Corporate Quality Assurance Manager's control of the Fire Protection Quality Assurance Program includes formulating and/or verifying that the program incorporates suitable requirements and verifying the ef festiveness of the program through review and audit.
17.2-17
o WSES-FSAR-UNIT-3 17.2.3 DESIGN CONTROL 17.2.3.1 17.2.3.1 General i
I The Quality Assurance Program defines the quality requirements for the design control of plant quality related systems, components, structures, and equipment and modifications thereto. Procedures are established which address company activities regarding design control. These procedures assure that design activities associated with the preparation and review of design documents for Waterford-3 are executed in a planned, controlled, and orderly manner.
034 17.2.3.2 Design Control Measures 17.2.3.2 l The Project Manager-Nuclear lis responsible for design activities during the operational phase, {beginning with 60 days prior to core loading. The Project l l Management Group { is responsible f or preparing, reviewing, approving, and verifytag design documents such as system descriptions, design input and criteria, design drawings, design analyses, computer programs, specifications, and procedures.
The design control program includes design activities associated with the 17.2.3.3 preparation and review of design documents, including the translation of applicable regulatory requirements and design bases into design, procurement, I
and procedural documents.
Included in the scope of the design control program are such activities as field design engineering; physics, seismic, stress, thermal, hydraulic, radiation, and the SAR accident analyses; associated computer programs; compatibility of materials; accessibility for inservice inspection, maintenance, and repair; quality standards; and safety significance. When a new design or design change is prepared during 17.2.3.3 P.2 operations, quality standards are specified in the design documents.
Deviations and changes from these quality standards are controlled in accordance with approved procedures.
1 Procedural control is established for design documents that reflect 035 c mmitments of the FSAR. Such design documents subject to procedural control DELETED include specifications, calculations, computer programs, system descriptions, the FSAR when used as a design document, and drawings including flow diagrams, piping and instrument drawings, control logic diagrams, electrical single line diagrams, structural drawings for major facilities, site arrangements, and
)
equipment locations. Specialized reviews are used when uniqueness or special design considerations warrant.
i Procedures are established to assure that verified computer codes are 179 '3*5 P,
certified for use and that their use is specified.
New designs and modifications proposed for existing designs which involve
)
17.2.3.3 quality related structures, systems or components are reviewed in accordance l
with approved procedures to assure that:
a) Design characteristics can be controlled, inspected, and tested to ensure l
no adverse effect on safety; and W
I 17.2-18 l
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c, WSES-FSAR-UNIT-3
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b) Inspection and test criteria are identified.
Internal and external ~ design interface controls, procedures, and lines of
{
-17.2.3.4 communication are established and described for the review, approval, release, 17.2.3.3 P.4 distribution, and revision of documents involving design interfaces to assure structures, systems, and components are compatible geometrically, i
functionally, and with processes and environment. A documented check is conducted.to verify the dimensional accuracy and completeness of design drawings and specifications.
17.2.3.6 17.2.3.2.1 Design Verification 1
Design verification processes such as design review, alternate calculations, 17.2.3.6 P.1 and qualification testing are accomplished in accordance with approved procedures.
Qualification testing of a prototype unit under adverse design conditions is 17.2.3.6 P.6.b required when a test program is used to confirm design adequacy. l1f design verification is by other than qualification testing, it is normally completed 036 prior to drawing release. In cases where this cannot be done and design DELETED verification is deferred, the justification for such action is documented and the unverified portion of the design appropriately identified and controlled.
Design verification will be complete prior to relying upon the structure.
17.2.3.6 P.7 system, or component to perform its quality related function.
Procedures require that qualified individuals or groups responsible for design
'17.2.3.1 verification be other than the original designer or the designer's immediate supervisor. However, the designer's immediate supervisor may perform the 17.2.3.6 P.9 verification if the following conditions apply:
a) The supervisor is the only technically qualified individual; a
h b) The need is individually documented and approved in advance by the responsible management; and j
17.2.3.6 P.10 c) Quality assurance audits take into account the frequency and effectiveness of using supervisors as verifiers to guard against abuse, The responsibilities of the qualified design verifier are identified in 17.2.3.6 P.164 appropriate procedures. The procedures specify -the areas and features to be verified and the documentation requirements.
i 17.2.3.6 P.6 If the design verification method is by test alone, the following provisions are included:
a) Procedures provide criteria that specify when verification should be by a
test; b
b) Prototype, component, or feature testing is performed as early as possible prior to installation of plant equipment, or prior to the point when the installation would become irreversible; and I
17.2-19 l
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WSES-FSAR-UNIT-3 17.2.3.6 P.6 c) Verification by test is performed under conditions that simulate the most adverse conditions as determined by analysis.
c 17.2.3.7'P.1 17.2.3.2.2 Design Changes Quality related design and specification changes, including field changes, are subject to the same type of design controls and approvals as the original-design. LP&L reserves the option of employing qualified organizations other than.the original designer _in order to modify or develop designs. Anyone preparing design changes reviews the original design and/or secures design information from the original designer, as appropriate. Errors and
- 17'.2.3.1 P.2 deficiencies identified during the design process are documented and 17.2.3.7 P.2 corrective action taken to preclude repetition.
Materials, parts, and equipment which are commodity, catalogue (off the
- 17.2.7.9 shelf), or which have been previously approved for a different application are reviewed for suitability. Such reviews are documented. The organizations responsible for design reviews and other design activities are identified by written procedures which delineate the authority and responsibilities involved. Valid industry standards and specifications are utilized in the process of selecting suitable parts and materials.
Design changes are included within the scope of the Waterford-3 document 17.2.6.6 control program. Design change notices are controlled documents. Any design 17.2.3.9_
change which might affect the performance of plant personnel duties is documented in a change notice and distributed to the affected parties.
Working documents, such as drawings, specifications, and procedures, which are affected by design changes are also revised and controlled so that responsible parties remain informed.
17.2.3.8 17.2.3.3 Maintenance and Modification A program is provided to ensure that quality related structures, systems, and components are maintained at the quality level required for performance of their intended functions. A preventive maintenance program is established which includes procedures dictating maintenance frequency and type.
17.2.3.8 P.6 Maintenance is performed in a manner which does not compromise plant safety.
Maintenance or modification activities which affect the functioning of quality 17.2.3.8 P.1 related structures, systems, or components are performed in a manner which will maintain a quality level at least equivalent to what was originally specified.
Inspection and performance testing verify that quality related structures, system 8, and c mponents are functioning adequately after 17 ' ' 3
- 8 P * *9 maintenance or modifications are complete. The results are documented and maintained in accordance with applicable records management procedures.
17.2.3.2 The Plant Manager has final approval authority for station modifications.
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17.2-20 i
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WSES-FSAR-UNIT-3 ll' 17.2.3.4 Replacement or Repair l
Malfunctions are promptly documented and evaluated to determine probable' i
17.2.3.8 P.5' cause.
If evidence indicates that common components in quality related
' systems have performed in an unsatisfactory manner, corrective measures are planned prior to replacement or repair of such components. Approved procedures for repair are made available prior to actual performance.
Replacement parts must receive adequate evaluation and/or testing if they.are not of a design which has been previously proven satisfactory. A phased l
replacement is considered, when possible, to permit inservice performance evaluation and minimize the possibility of a hidden deficiency developing into a systematic failure. An augmented testing and incpection program is implemented following a large scale component replacement or repair as necessary to demonstrate component reliability.
1 1
17.2.4 PROCUREMENT DOCUMENT CONTROL 17.2.4. 2 17.2.4.1 General Procurement document control applies to drcuments used to obtain materials, spare and replacement parts, components, and services required to modify, 17.2.4.2 maintain, repair, test, inspect, or operate Waterford-3. Quality Assurance Program procedures define requirements for controlling procurement of quality related items and services. Quality related suppliers / contractors and subtier 17.2.4.3.c suppliers.are required, through procurement documents, to implement quality assurance programs consistent with the LP&L Quality Assurance Program. It is LP&L policy that the quality and design of purchased replacement materials, 17.2.7.10 components, and spare parts e-* equal to or better than the original item.
17.2.4.2 Preparation of Procurement Documents Nuclear Operations Department p rsonnel are responsible for preparation of 1
procurement documents for quality related parts, components, systems, and services. Their responsibilities include procurement planning, preparation, review, approval, and control of purchase requisitions; bid evaluation; and assisting in supplier selection (subject to Quality Assurance Section concurrence).
17.2.4.3 Control of Procurement Documents 17.2.4.4 Procedures are provided for the review of procurement documents to determine that quality requirements are correctly stated, inspectable, and controllable; there are adequate acceptance and rejection criteria; and procurement documents have been prepared, reviewed, and approved in accordance with Quality Assurance Program requirements. Organizations preparing purchase requisitions are responsible for determining the applicable quality classification in accordance with 17.2.2.3 and referencing codes, standards, design bases, or other provisions necessary to assure adequate quality.
Procurement documents as applicable:
17.2.4.3 a
a) State the scope of the work to be performed by the supplier; 17.2-21 l
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WSES-FSAR-UNIT-3 6
b b) Contain or invoke by reference the technical requirements, including drawings; test and specification requirements; special instructions; and applicable' regulations, codes, and industrial standards; c) Identify the documentation (e.g., drawings, specifications, inspection and e
fabrication plans, inspection and test records, personnel and procedure qualifications, and chemical and physical test results of material) to be prepared, maintained, and submitted to LP&L for review and approval; d) Identify to the extent necessary the LP&L Quality Assurance Program
.c requirements which must be described and met in the supplier / contractor and subtier supplier Quality Assurance Programs; e) Identify those records to be retained, controlled, and maintained by the supplier and those delivered to LP&L prior to use or installation of the item; e
d f) Establish the right of access for LP&L and its agents to the supplier's facilities and records for source inspection and audits; g) Specify when necessary the requirement for suppliers to comply with 10 CFR f
Part 21 for reporting defects and noncompliance which could create a substantial safety hazard; and b&
Establish measures for the identification, control, and disposition of h) 17.2.16.5 items and services that do not meet procurement document requirements.
17.2.7.8 LP&L utilizes recognized standards for the procurement of standardized items 037 such as bearings, V-belts, capacitors, resistors, transistors, and lubricating DELETED Other items are purchased by part number or recommendations supplied by oils.
the original manufacturer or supplier. Items which are covered by industry codes or standards (e.g., welding rod and pressure boundary materials) are purchased in accordance with the applicable codes and standards. Where commodity _or catalogue items are to be used in quality related applications, the procurement documents may specify special inspections, tests, verifications or documentation required to assure suitability for the intended application.
17.2.4.4 Review and Approval REF: 013 The Quality Assurance Sectionland the Plant Quality Group l review quality related procurement documents for Waterford-3. This review is conducted to DELETED 17.2.4.2 verify:
17.2.4.4 17.2.4.3 b
a)
Use of the proper source for the technical and quality requirements; b)
That appropriate technical and quality requirements are included; e
b c)
That the technical and quality requirements can be verified by inspection or other methods; and d)
That technical and quality requirements are controlled through a program c
of planned and systematic actions.
4 17.2-22
o WSES-FSAR-UNIT-3 17.2.4.5 Qualified Suppliers List 17.2.4.2 P.5 The Engineering and Systems Development Quality Assurance Groep is responsible for establishing and maintaining the Qualified Suppliers List. Prospective vendor / supplier / contractor organizations qualify for inclusion on this list through an evaluation of their quality assurance capabilities for providing quality related items and services.
(see Subsection 17.2.7.2 for the basis used in the evaluation). Re-evaluation and requalification of suppliers on the Qualified Suppliers List is made on a periodic basis, as specified in applicable procedures.
17.2.4.6 Changes and Revisions 17.2.4.5 Changes and revisions affecting the technical and/or quality requirements of procurement documents are subject to at least the same review and approval as the original documents.
17.2.5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS 17.2.5.1 17.2.5.1 General Instructions, procedures, and drawings for the operational phase of Waterford-3 are developed to prescribe those activities that affect the quality related functions. Activities affecting quality, such as designing, procuring, installing, testing, inspecting, operating, maintaining, and modifying are accomplished in accordance with these documents.l The Quality 038 Assurance Manual defines requirements for developing and controlling 17.2.5.1 instructions and procedures for quality related activities.
i 17.2.5.3 17.2.5.2 Preparation of Instructions, Procedures, and Drawings i
Procedures are written to provide a controlled method for preparing, reviewing, changing, and approving instructions and procedures. Instructions, procedures, and drawings prescribing quality related activities are prepared by the LP&L organizational unit engaged in that activity, by external consultants or by other LP&L groups as assigned. Appropriate department heads are responsible to provide instructions, procedures, and drawings as required for the administration, operation, maintenance, and modification of I
Waterford-3.
17.2.5.4 17.2.5.3 Contents of Instructions, Procedures, and Drawings i
Instructions and procedures prescribing operational activities that affect quality related functions identify any special equipment and conditions I
required to perform the activity, provide applicable quantitative and qualitative acceptance criteria, and include provisions for documenting that activities were accomplished in accordance with these instructions. When appropriate, instructions and procedures include checklists of the elements of an activity to be observed or measured.
17.2-23 l
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s WSES-FSAR-UNIT-3 17.2.5.4 Review and Approval 039 Instructions, procedures, and drawings prescribing quality related activities 17.2.5.5 are reviewedland approveolby the individual in charge of the organization engaged in that activity. Whenever a quality related instruction, procedure, or drawing of one organization affects or involves the activities of another 17.2.5.5 P.2 rganizati n, the originating organization is responsible for ensuring that the affected organization reviews and concurs with the document content. [The9 040
[ originating organization is responsible for resolving comments.
DELETED Instructions, procedures, and drawings for quality related activities are e ncurred with by the Quality Assurance Section or by the Plant Quality Group.
041 Table 17.2-2 identifies procedures requiring Quality Assurance concurrence.
17.2.5.2 For onsite quality related activities the Plant Quality Group reviews and concurs with test, calibration, special process, maintenance, modification and repair instructions, and work plans.
PORC reviews and recommends approval to the Plant Manager of instructions and 17.2.5.2 procedures for quality related activities for plant operation in accordance with the Waterford-3 Technical Specifications (FSAR, Chapter 16). Such documents are not approved for implementation until comments from the above 17.2.5.5 P.5 reviews have been resolved. Control of these documents is in accordance with Subsection 17.2.6.
17.2.6 DOCUMENT CONTROL 17.2.6.1 General Documents and their revisions which control quality related systems, 17.2.6.1 P.1 structures, components, and activities are prepared, reviewed by qualified individuals, and approved by authorized personnel before release or issuance in accordance with written procedures. These procedures identify the organizations responsible for the actions and assure that changes to these 042 documents are reviewed and[ approved by the same groups.l 17.2.6.1 P.2 l
17.2.6.2 Review and' Issuance of Controlled Documents l
Document control procedures require that documents, including changes, be i
17.2.6.2 reviewed for adequacy and approved by authorized persons prior to issuance.
17.2.6.1 This includes a quality assurance review of documents prescribing quality related activities as described in Subsection 17.2.5.4.
l Controlled documents and revisions generated within LP&L which affect the l
17.2.5.3 quality related structures, systems, components, and activities are prepared by the responsible group, consultants, other qualified groups within LP&L, or combinations of these organizations. These documents are reviewed for accuracy and completeness, and for compliance with quality assurance policies and procedures. After review comments have been resolved, the documents are 17.2.5.3 approved by the supervisor of the responsible greup, effective dates assigned, and the documents distributed in accordance with applicable procedures and 17.2-24 l
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VSES-FSAR-UNIT-3 17.2.6.1 P.2 instructions. Controlled documents are distributed prior to starting an 17.2.6.2.a activity and. if necessary, are on hand at the locations where the prescribed
?
activities are performed before work begins.
17.2.6.3.a Controlled lists of documents are updated and issued in accordance with applicable procedures to preclude the use of superseded documents. These lists identify the current revision number of the instructions, procedures, specifications, drawings, and procurement specifications. Record copies of 37*9**77,3 the documents are retained in accordance with appropriate records management procedures. Obsolete or superseded documents are controlled by approved 17.2.6.1 P.2 written procedures to prevent inadvertent use.
Changes to quality related documents are reviewed and approved by the same 17.2.6.1 P.2 organization that performed the original review and approval or by other qualified responsible organizations delegated by LP&L. Approved changes are included in the instructions, procedures, drawings, and other appropriate documents associated with the change.
17.2.5.2 17.2.6.2.1 Quality Related Plant Procedures REF: 043 Administrative procedures prescribe steps involved in the preparation and review of plant procedures. The procedures require that quality related maintenance, modification and test instructions, and procedures prepared by the plant staff be routed to the Plant Quality Group for review and concurrence prior to implementation. The Plant Quality Manager assigns this review to qualified personnel within his group. The review is conducted in 17.2.5.5 accordance with approved procedures to determine:
a) That the need for inspection, identification of inspection personnel, and documentation of inspection results have been properly specified; b) That the necessary inspection requirements, methods, and acceptance criteria have been identified; and c) That hold and witness points are clearly identified and acceptance criteria provided.
Prepared checklists or guidelines are used in conducting and documenting the reviews.
17.2.6.2.2 As-built Drawings 043 Those drawings required for the safe operation of the plant reflecting the DELETED as-built status of Waterford-3 are transferred from the Architect-Engineer to LP&L prior to receipt of the operhting license. These drawings are stored in a controlled facility, with reproducible copies of those drawings required for plant operation and maintenance furnished to the Plant Manager. l The Project 044 Management Group is responsible for the revision and update oi master drawings t reflect station modifications.
17.2.6.6 l
The Project Management Group issues Station Modifications (SMs) which l
delineate the drawings affected by proposed modifications.l The Plant Manager 17.2-25
WSES-TSAR-lfNIT-3 implements and maintains administrative controls which assure that as-built 17.2.6.6 P.6 drawirgs utilized for plant operation and maintenance are obtained and disseminated upon completion of the related modification. The Nuclear 1,,..,.6.2 P.4 Operations Quality Assurance Group monitors the status of as-built drawings.
Field drawings and sketches may be prepared by plant personnel to clarify or 17.2.6.6 P.3 provide additional details for operation, maintenance, or testing, and these are controlled in accordance with written instructions which specify requirements for identifying, reviewing, approving, and filing. They are reviewed for accuracy by at least one qualified person other than the originator. They are reviewed and approved by the originating group supervisor before issuance. Revisions are bandled in the same manner as the original issue.
l l
17.2.6.5 17.2.6.3 Types of Controlled Documents The documents controlled under the Quality Assurance Program include as a minimum:
f a) Safety Analysis Report; b) Design documents including calculations, drawings, specifications, change a
requests, analyses, and documents related to computer codes; c) Procurement documents; e
i d) Quality Assurance Manual; e) Quality Assurance Section Procedures; e
1 1
d f) Inspection and test procedures for fabrication, construction, installation, test, maintenance, modification, and operation; g) Nonconformance Reports; g
b h) As-built documents; i
i) Emergency Plans; i
j) Physical Security Plana; k) Plant Operating Manual; e
- 1) Nuclear Services Procedures; and e
045 m) Project Management Procedures. l DELE 1LD 17.2-26
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17.2.7 CONTROL OF PURCHASED MATERIAL. EQUIPMENT, AND SERVICES J y V
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17.2.7.I'
' General a
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,2 17.2.7.1 Material, equipment, and services-whether purchased directly or through
.others, conform to procurement document specifications as described in Subsection 17.2.4.
Provisions are made, as appropriate, for source evaluation and selection, review for objective evidence of quality, inspection at source C '
and. inspection upon delivery. Quality assurance measures of suppliers are assessed at periodic intervals commensurate with.the importance, quantity, and Isi complexity of.the product or services being purchased. This assessment 4
employs audit, independent. inspection or test to verify that documentation 17.2.7.4 such as inspection records and certificates of conformance are valid. Where onsite, failures occur, the cause is evaluated to determine if the original 17.2.3.8 P.3 equipment or the original design is appropriate for replacement or repair.
Proposals (bids or quotations) by suppliers are reviewed to ensure that no
'17.2.4.4-exceptions are taken which would violate safety, technical, cr quality requirements. The program requirements for control of-purchased material,
/n3; i17.2.8.2 equipment, and services are contained in approved written procedures.
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- 3 17.2.7.2 Evaluation of Suppliers 17.2.4.2 P.5 Quality related equipment, materials, and services are obtained from suppliers, contractors, and con-sultants on the LP&L Qualified Suppliers List 17.2.7.2 P.6 when required to assure compliance with codes, standards, and regulatory commitments. Suppliers, contractors, and consultants are qualified for a'
J inclusion on the Qualified Suppliers List through an evaluation of their quality assurance capabilities for providing quality related items and services. IThe evaluations are conducted by qualified personnel and the 046 results documented and maintained in accordance with quality records 17.2.16.3 P.2 management procedures.
The evaluation of suppliers is based on one or more of the following criteria:
17.2.7.3 a) The supplier's ability to comply with those requirements of the LP&L Quality Assurance Program which are applicable to.the type of material, equipment or service being procured; b) A review of the records and performance of suppliers who have provided articles similar to the type being procured; and c) A survey of the supplier's facilities and quality assurance program to determine his capability to provide a specified service or to supply a product 4
which meets design, manufacturing, and quality requirements.
i LP&L's Corporate Quality Assurance Manager is responsible for establishing and 17.2.7.2 P.6 maintaining the Waterford-3 Qualified Suppliers List.I Plant Quality and 047 engineering groups (plant or support personnel) participate in the evaluation DELETED f poten.tial suppliers for providing quality related items and services as needed.I Suppliers a quality related structures, systems, components, and services for Waterford-3 are informed through procurement documents of their
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17.2.4.3.f requirement to comply with 10 CFR Part 21 for reporting defects and
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noncompliance that could create a substantial safety hazard.
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' AudiC an,d surveillsucciof q.tality related suppliers during f abrication, l< 17.2.7/] 1 P.3
,dtspeption, testiag,. ed sh pment of materials, equipment, and components is P anrM' pad perforined id arcordancy witLt gritten procedures to ensure
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iconformance to the pr.gcuredent docurr. ant testirements. These procedures b
provide for.
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{1_ s ) Inttuctists tbpt specify1 the characteristicQor processes to be i
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T' g) The peracetch espo,nsible for fpplementing these instructions; c
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%rveillance a( perprmed on these items where verification of procurement rh uirements cannot be determined upon ccriipt. Suppliers' quality relatd h
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17 2,7.4'.2 / Entivities including the validity of cert.ficates of conformance are I
pe'riodically evaluated by audits, indeicudent inspections or tests. The.
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0-N.h, df tectiveness of supplier quality centrob '.s assessed by LP&L at intervals i
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7 service being delivered.
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-,Receivi..g inspection of material, :omponents, and equipment is performed in j
accordance with written procedure which provide that:
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() The material, ccimponent or equipment is properly identified and
- 17. 2.,/. i. !
corresponds to the requiremr.its of the procurement documentation;
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b) Material, r.omponents, equipment, and records are inspecteo and judged
!t IJ.2.7.7.1 ac eptable iA accordance with procurement document requirements prior to
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iristallation or use;
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048 c) Inspectiop.recceds or certificates df conformance attesting to the quality 17.2.7.7,
- material, % porents, and equipment are available at Waterford-3 prior to
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' installation, g se{ and
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d) Accepted dad rei9ased items have their inspection status identified prior
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'y being forwaided m a controlled storage area or released for installat.on 17.2.7.7 or fur n y, work.
17.2.7[5.
Procurement of Commercial _ltemes '
.2.7.9 St2ndesi commercial material, parts, and equipment that are esential to the i taliti+ related functions of structures, systems, and components are reviewed i
_ 049 and dohunented for suitability of application hfgejlection of the item andi
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DELETED' lits supplier.l The preparer of the purchase ceqnsitior; is responsible to 1
f clearly Tdentify the commercial iten to be procit % and list the receiving i
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..4 inspection requirement. The itea selette.( :nust be equt( r to or better than the
{t originsi part.
If the part is differest from or an additio2 to the original i
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e WSES-FSAR-UNIT-3 050 design and constitutes a plant modification, thel Project Management Group l 17.2.7.9 reviews the material application and verifies the part's suitability for the intended use.
Any additional inspection or test requirements are specified in the purchase requisition or attachments.
17.2.7.6 Spare and Replacement Parts 17.2.7.10 Spare and replacement parts for quality related systems, structures, and components are subject to present Quality Assurance Program controls and to codes, standards, and technical requirements at least equivalent to or better than those used for the original equipment.
17.2.7.7 Records 17.2.7.11 Quality assurance records, when required by procurement documents, are collected and retained by suppliers of quality related items. Suppliers i
furnish the following records, as a minimum, to LPS2,or its agent:
a) Documentation that identifies the purchased material or equipment and the specific procurement requirements (e.g., codes, standards, specifications) met by the items; and b) Documentation that identifies any procurement requirements which have not been met, together with a description of those nonconformances dispositioned
" accept-as-is" or " repair".
051 The review, evaluation, and acceptance of the required supplier records furnished to LP&L are described in procedures. Review and acceptance of the 17.2.7.11 P.,,'
records is performed by thel Plant Quality Group l personnel.
Documentation is available at Waterford-3 prior to use of purchased material, components or equipment. The documentation is retained in accordance with quality assurance records management procedures.
17.2.8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS
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17.2.8.1 17.2.8.1 General j
The identification and control of quality related materials, parts, and j
components is accomplished in accordance with written requirements and applies 1
I to materials, parts or components in any stage of fabrication, storage, installation, use or removal from use.
Procedures define requirements for the 17.2.8.2 identification and control of materials, parts, and components.
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Materials, parts, and components identified as nonconforming is handled in 1
17.2.15 accordance with subsection 17.2.15.
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17.2.8.2 Requirements for Identification and Control 17.2.8.2.a Identification by means of heat numbers, serial numbers, date coding, lot numbers, part numbers or other appropriate means is required by procurement 17.2.8.3.4 documents. When identification markines are employed, thev are clear, unambiguous, and indelible.
The inclusion of identification requirements in 052 design documents is checked during design verification by the design organization.
DELETED Procedures include provisions to prevent the use of incorrect or defective 17.2.8.2 items by requiring that identification be maintained either on the item or on records traceable to the item. The identification of materials, parts, and components is verified to ensure that only correct and accepted items are used 17.2.8.2 b-d and installed.
17.2.8.3 Traceability 17.2.8.3.1 Purchased materials and parts important to the function of quality related structures, systems, and components are identified to enable the items to be traced to documents such as drawings, specifications, procurement document, manufacturing and inspection documents, deviation reports, and physical and chemical test reports. When traceability is required, idattification will be 17.2.8.3.4 maintained for each part of subdivided items either on th part or in the documentation traceable to the part. Replacement parts and saterials are similarly identified by coded part numbers to records and documents.
Inventory and issue controls are documented in applicable plant procedures as 17.2.8.2 P.2 part of the measures to control purchased items and maintain traceability to plant locations, 17.2.8.4 Responsibility for Identification and Control l The Administrative Manager-Nuclear. Plant Administrative Services Department. l 053 provides instructions for the identification and control oi items 1or quality 1 7 * *'
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related applications which are received, stored, and issued at the plant site.
The Plant Manager provides instructions for the identification and control of 17.2.8.2 P.1 items drawn from stores, installed, or used. lThe Plant Quality Group ensures 054 that proper documentation accompanies quality related items by surveillance of 17.2.7.7 activities.
17.2.9 CONTROL OF SPECIAL PROCESSES 17.2.9.1 17.2.9.1 General Special processes, including welding, heat treating, and nondestructive testing are identified and controlled to ensure that they are accomplished according to approved written qualified procedures. Procedures are qualified 17.2.9.4 in accordance with applicable codes and standards, or, where no appropriate 17.2.9.5 standards exist, to LP&L requirements. As required by applicable codes and standards, personnel performing special processes are qualified and their 17.2-30
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WSES-FSAR-UNIT-3 qualifications are documented. Applicable codes, standards, specifications, criteria, and other special. requirements are identified and used in qualifying
' procedures and personnel used to accomplish special processes.
17.2.9.3 17.2.9.2 Special Processes Subject to Controls Special processes controlled by the Quality Assurance Program include, but are 055 not limited to, the followinglas they are applied to quality related items:
l DELETED-a) Welding, a
b b) Heat treating.
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Radiography, c
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d) Ultrasonic examination, c
e) Eddy current examination, e
f) Magnetic particle examination, c
g) Liquid penetrant examination, i
d h) Chemical cleaning, e
- 1) Concrete placement (seismic applications),
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j) Cadwelding, and h-k) Protective coatings.
17.2.9.3 Special Process Procedures Procedures for performing special processes are written, qualified, and 179'9*4 l
approved before use. Personnel responsible for performing special processes are qualified to the, procedure before implementation. Special process control procedures specify the preparatory steps, processing details, conditions to be maintained during the process, and inspection and te, sting requirements.
17.2.9.4 17.2.9.4 Qualification of Personnel, Procedures, and/or Equipment The Quality Assurance Program requires that personnel (both internal and external to LP&L) performing special processes for Waterford-3 are qualified and are using procedures qualified to meet applicable codes, specifications, 17.2.9.2 and standards. Qualifications of personnel and procedures are verified by REF: 013 Quality Assurance and Plant Quality Groups during surveillance or audits.
L Personnel, procedures, and/or equipment connected with special processes are qualified / certified in accordance with applicable codes, standards, and i -
057 specifications. Qualification / certification may be provided by authorized DELETED agencies or by individuals within the LP&L organization who are qualified for 17.2-31 l
Q WSES-FSAR-UNIT-3 Con't.
the special processes to be performed. Certification includes necessary training followed by an examination of eacn individual. The period of validity for certification of personnel is in accordance with criteria described in applicable codes, standards, and specifications. Personnel failing retest are not allowed to perform the special process pending decertification.
058 A Level III inspector for the type of nondestructive examination (NDE) process DELETED addressed reviews and approves the NDE procedures.l For special processes not 17.2.9.5 e vered by exzsting cooes or stanaaros, or wnen one quality requirements exceed the requirements of established codes or standards, the necessary qualifications of personnel, procedures, and/or equipment are defined.
17.2.9.6 17.2.9.5 Records 059 Current qualification records of plant special process personnel, procedures, 17.2.17.3.b and equipment are maintained by the responsible plant supervisor and reviewed by the Plant Quality Group.l Special process control records of vendors may be 17.2.9.6 060 retained by the vendor or supplied to LP&L as specified by contract or procurement document.
DELETED 17.2.10 INSPECTION 17.2.10.1 General 17.2.10.1 P.3 Inspection is performed during maintenance, modification, repair, material receiving, and storage activities affecting quality related items at Vaterford-31in accordance with requirements detined in the Quality Assurance l l Manual.l Maintenance and modification instructions, and work plans are 17.2.10.3 P.3 reviewed by Plant Quality l personnel to assure the inclusion of inspection REF: 059 requirements and to verify that methods and criteria are defined.
061 The inspection program at Waterford-3 is developed under the direction of the Plant Manager and is implemented by the Plant Quality Manager. Normal 17.2.10.2 P.1 inspections are performed by qualified personnel reporting to the Plant 062
- Quality Manager. l Special inspections, such as nuclear fuel receiving, are performed _by qualified personnel reporting to the Plant Manager or his 17.2.10.3 P.4 designee.l For quality Telated activities (e.g., surveillance testing) where 063 direct inspection is not utilized, the Plant Quality Group monitors the DELETED activities in accordance with established procedures.
J Inspection requiring expertise in a particular area, such as preservice and 17.2.10.3 P.5 inservice inspection, certain nondestructive testing, and containment vessel leak rate tests and inspections, may be conducted by offsite LP&L, Middle J
South Services or contractor personnel. In such instances, the inspection
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activities are conducted under the LP&L Quality Assurance Program or under a LP&L approved contractor program.
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i 17.2.10.2 Inspection Procedures, Instructions, and Checklists 17.2.10.8 Inspection requirements are implemented using applicable procedures, instructions, checklists, drawings, and specifications.
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Procedures, instructions, and checklists governing inspections provide for the following:
a) Criteria for determining wnen inspections are required and how they are performed; b) Acceptance and rejection criteria; c) Identification of individuals or groups responsible for performing inspections; d) The points during fabrication, erection, installation, test, operation, or maintenance at which the inspections are to be performed; e) Identification of characteristics and activities to be performed; f) A description of the inspection method; g) Identification of required inspection, measuring, and test equipment; h) Accuracy requirements for inspection, measuring and test equipment; i) A method for recording the identity of the recording inspector or data recorder and recording the inspection results and/or observations; j) A method for recording evidence of completing and verifying a manufacturing, inspection or test operation; k) Identification of procedures, drawings, and specifications, including revision level used to conduct the inspection.
The procedure originator is responsible for ensuring that the accuracy requirements of inspection equipment are sufficient to obtain reliable data.
The accuracy requirements are based on procurement or plant technical REF: 063 Specifications. Thel Plant Quality Group l reviews quality related procedures to verify the inclusion of accuracy requirements of inspection equipment. The individuals performing the inspections are responsible for assuring that the equipment used meets the criteria noted in the procedure. { Plant Quality l inspectors are responsible for verifying that the inspection equipment meets the criteria of the procedure and that the inspection results are within the acceptance criteria of the procedure.
17.2.10.3 Indirect Inspection When it is not possible or practical to verify conformance of processed REF: 063 material or products by direct inspection, indirect control is employed by DELETED monitoring processing methods, equipment, and personnel. To ensure adequate I
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control, both direct inspection and process monitoring are used when control by only one method is considered inadequate.
17.2.10.4 Inspection by Sampling Methods 17.2.10.7 Sampling inspection methods may be used when tests are destructive or when quality assurance records and inherent characteristics of the item indicate a reduction in items inspected or tested can be achieved without i
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jeopardizing the assurance of quality. When a sampling method is used to verify acceptability, the sampling procedures provide justification for the sample size and selection process.
17.2.15.7 P.4 17.2.10.5 Inspection of Replaced, Reworked or Repaired Items Modifications, repairs, and replacements are inspected in accordance with the original design and inspection requirements or acceptable alternatives.
Further information on the disposition, inspection, and documentation for repaired or reworked items is contained in Section 17.2.15.
17.2.10.6 Inspector Qualifications Inspectors are qualified through experience, education, and training programs to perform the assigned inspection tasks. Where required, inspectors are 064 formally examined and certified. lA file is maintained containing the 17.2.17.b credentials for each inspector.
Inspector qualifications and certifications 17.2.2.6 are kept current.
The Plant Training Department develops procedures for training programs for Plant Quality Group inspectors. These procedures contain qualification criteria for inspection personnel for the various types of inspections. The j
Plant Quality Manager is responsible for certification of Plant Quality 17.2.10.2 inspectors.
The inspector qualification program is reviewed and concurred with by the Corporate Quality Assurance Manager or his designee.
j 17.2.10.6 17.2.10.7 Identification of Hold Points Quality related suppliers and vendors are required through procurement documents where applicable, to submit their manufacturing plans to LP&L, as 17.2.10.6 P.162 indicated in the procurement document. This is done prior to manufacture in their shops or shops of their suppliers so that LP&L has the opportunity to identify mandatory inspection hold points for witness by an LP&L representative. Work may not proceed beyond these hold points without LP&L consent.
Work plans, procedures, and instructions for maintenance, modification or test 17.2.10.6 P 3 of quality related structures, systems or components are reviewed to verify inclusion of inspection requirements, criteria, and hold points. Work in 17.2-34 i
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WSES-FSAR-UNIT-3 process does not proceed past the identified hold points without satisfaction of inspection requirements.
i 17.2.11 TEST CONTROL 17.2.11.1 17.2.11.1 General i
waterf ord-3 preoperational and startup tests are performed in accordance with j 065 the criteria of Regulatory Guide 1.68, as described in Chapter 14 of this 17.2.11.1 FSAR. Following issuance of the operating license, testing is performed to demonstrate that quality related systems and equipment will perform satisfactorily in service and malfunctions are identified in a timely manner.
This includes surveillance, functional, and special tests.
Proceiures define requirements for control of quality related tests and 17.2.11.4 methods for implementing Quality Assurance Program requirements.
Test program procedures include criteria for determining _when a test is 17.2.11.4 required and how testing activities are performed. l Test program procedures also require system engineers to review spectiications provided by the 066 Architect-Engineer, test guidelines supplied by the NSSS vendor and equipment I7.2.11.4 technical manuals in order to determine the test equipment accuracy that is necessary to satisfactorily perform a test.
17.2.11.2 Content of Test Procedures Written test procedures for structures, systems, and components are prepared in accordance with Regulatory Guides 1.33 and 1.68, as applicable, and provide, as required, for the following:
17.2.11.3 a) The requirements and acceptance limits contained in applicable design and procurement documents; 17.2.11.4 b)
Instructions for performing the test; c)
Test prerequisites such as:
1)
Calibrated instruments; 2)
Adequate and appropriate equipment; 067 3)
Trained, \\ qualified, and licensed or certifiedlpersonnel; TBL 17.2-1 Doc-2b 4)
Completeness of item to be tested; 5)
Suitable and controlled environmental conditions; 6) provisions for data collection and storage; and 7)
Status of system.
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. 1 WSES-FSAR-UNIT-3 17.2.11.3 d)
Criteria for determining accuracy requirements of test equipment; 068 e)
Mandatory inspection hold points; 17.2.10.6 17.2.11.4 f)
Acceptance and rejection criteria; g)
Methods of documenting or recording test data and results; h)
Provisions for assuring test prerequisites have been met; and 069 i)
Provisions for assuring system arrangement is acceptable after test.
17.2.11.3 lPreoperational and startup test procedures are developed by the Waterford-3 070 Startup Group and Plant Staff with appropriate inputs from the NSSS vendor and
- 17. 2. l'I. 2 the Architect-Engineer.
1 17.2.11.4 Testing activities are performed using test procedures that have been 1
17.2.5
, reviewed, approved, and released for execution. IRetesting activities are 071
[ based on reviews and direction by the Joint Test Group or the PORC.
17.2.11.2 P.2 17.2.11.3 Evaluation of Completed Tests 072 Completed tests including test results are documented and evaluated by a qualified responsible individual or group. This evaluation determines:
17.2.11.5 17.2.11.6 a)
That the test results are adequate; b)
That the recorded data reveals the adequacy of the equipment or system to meet the specified requirements in the acceptance criteria; and
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I c)
That nonconforming conditions or conditions which deviate from l
requirements are reported, evaluated, and corrected.
Test data found to be in conformance with the requirements is accepted and 17.2.11.5 approved by a qualified responsible person and appropriately documented.
073 The Joint Test Group reviews the results of preoperational tests (Phase II) and makes recommendations regarding acceptability to the Plant Manager. The DELETED PORC reviews the results of initial Startup tests (Phase III) and makes recommendations regarding acceptability to the Plant Manager. l The Safety 17.2.11.2 P.4 Keview Committee reviews the results of special tests in accordance with Waterford-3 Technical Specifications.
If test results do not meet acceptance criteria, the responsible organization initiates appropriate corrective action 17.2.11.6.f in accordance with written procedures.
17.2.11.4 Test of Modified, Repaired or Replaced Items M dified, repaired or replaced items of quality related equipment are tested 17 * ~7'3'8 in accordance with the original design and testing requirements or acceptable alternatives.
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WSES-FSAR-UNIT-3 17.2.11.5 17.2.11.5 Test Records Test records include report forms completed during tests and identify the person responsible for conducting the test and indicate the date or period when the test was performed. Original test data report forms are reviewed for 17.2.17 completeness, identified, indexed, and stored in accordance with Section 17 2.17.
17.2.12 CONTROL OF MEASI' RING AND TEST EQUIPMENT 17.2.12.1 General 17.2.12.2 Measuring and test equipment (M&TE) utilized in or related to operation of quality related st.tctures, systems, and equipment is controlled in accordance with written prc edures or instructions. These procedures define requirements 17.2.12.1 for control of Mt CE, including measuring instruments, test instruments, tools, gauges, reference standards, transfer standards, and nondestructive test equipment used in the measurement, inspection, and monitoring of quality related structures, systems, and components.
Requirements for the control of M&TE apply to M&TE used by the individuals or 17.2.12.1 organizations participating in the installation, inspection, testing or maintenance of quality related structures, systems or components for Waterford-3. IIhe extent to which these requirements apply depends upon the 074 nature and scope of the work to be performed and the importance of the item or DELETED service involved. LP&L has established and implemented a calibration program for M&TE to be used during preoperational testing and operations.
17.2.12.2 Responsibility The Plant Manager is responsible for ensuring that the affected groups 17.2.12.2 establish and maintain a calibration control program. The PORC is responsible for reviewing calibration control procedures and for submitting recommendations to the Plant Manager or his designee.
075 The plant department head or supervisor of the group performing or contracting DELETED calibration activities is responsible for the calibration and control of M&TE under his cognizance. He ensures that the calibration program requirements are fully and effectively implemented within his department or group.
076 The Plant Quality Manager is responsible for the revi'ew of calibration 17.2.12.2 P.2 procedures. He is responsible for conducting an inspection / surveillance program of calibration activities as required to assure procedural compliance.
l The Corporate Quality Assurance Manager is responsible for performance of audits to verify that the calibration control program meets the requirements of the Quality Assurance Manual and that site procedures are properly implemented.
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WSES-FSAR-UNIT-3 17.2.12.3 Requirements The calibration program is designed to ensure the accuracy of M&TE. The l
17.2.12.1 calibration program provides for the prompt detection of inaccuracies and 37**,*12*4
timely, effective corrective action. The calibration program includes the 3
following requirements as a minimum:
l 077 a) Lists of M&TE which specifically identify items under the calibration program.
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b) Reference standards and documented procedures for calibrating M&TE.
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17.2.12.4.1 P.1 Procedures such as published stsndard practices, written instructions that accompany purchased equipment, or other acceptable instructions may be used.
l c) Calibration of M&TE is against standards that nave an accuracy greater 17.2,12.4.1 P.2 than four times the required accuracy of the equipment being calibrated. When this is not possible, standards have an accuracy that assures the equipment being calibrated will be within required tolerance. lThe basis for the 078 calibration is documented and approved by the Assistant Plant Manager, Plant 17.2.12.4.1 P.3 Maintenance and Operations.
l 079 d) M&TE is stored, calibrated, and used in envirorsents which will not i
17.2.12.5 adversely affect its accuracy.
17.2.12.4.2 e) M&TE is calibrated at prescribed intervals to verify the required accuracy. The interval between calibrations is based upon experience, manufactures' recoranendations, inherent stability, purpose or use, and the accuracy required of the equipment. Recalibration is performed on or before 080
_ the designated calibration date. l Reference standards are calibrated by
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17.2.7 17.2.18 f) M&TE is calibrated using reference standards whose calibration has known 17.2.12.4.1 P.1 valid relationship to nationally recognized standards or accepted values of natural physical constants.
If no national standard exists, the basis for i
calibration is documented.
17.2.12.4.2 g) M&TE is labeled to indicate its control status. l The label indicates the t
date of last calibration, by whom it was calibratea, and when the next 081 calibration is due.
When labeling is not practical, an identifying code is 17.2.c2.4.2 used.
If neither labeling or coding is practical, the calibration procedures 17.2.12.2 provide for monitoring of records to ensure control. M&TE is identified to provide traceability to calibration test data. The methods to be used for identifying the equipment is specified in applicable station procedures.
17.2.12.4.2 h) M&TE found to be out of calibration is identified as nonconforming and l
removed from service. Equipment tested or calibrated by the nonconforming j
equipment since the last calibration is identified and sufficient 082 investigations performed to either re-establish the acceptability of the 17.2.12.4.2 equipment or to confirm the nonconformance. The results of such 17.2.12.4.2 investigations are documented. l M&TE which has been subjected to possible damage is identified as nonconforming and removed from service until corrective measures are taken.F M&TE consistently found to be out of 17.2-38
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WSES-FSAR-UNIT-3 calibration is identified as nonconforming, removed from service, and repaired 083 or replaced. l Lost / misplaced M&TE is treated the same as M&TE found to be out
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17.2.12.4.2 of calibration.
i) The following measures are taken for M&TE to maintain accuracy and obtain e nsistent results:
084 17.2.12.4.2
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Environmental and handling controls; b) Training and qualification of personnel; c) Checking calibration status before use; d) Documenting and recalibrating damaged M&TE; and e) Limiting use to authorized personnel.
17.2.12.4 Procedures Procedures are established for calibration (technique and frequency),
17.2.12.2 maintenance and control of M&TE (instruments, tools, gauges, fixtures, reference and transfer standards, and nondestructive test equipment) that is used in the measurement, inspection, and monitoring of structures, systems, and components.
a r3 n procedures include at least:
085 DELETED a) The identity of the item to be calibrated; b) Calibration equipment and reference standards to be used; l
c) Checks, tests, measurements, and acceptance tolerances; i
d) Sequence of operations; l
e) Special instructions, when necessary; and f) Means for traceability between test equipment and calibration test data.
17.2.12.6 17.2.12.5 Records The status of M&TE under the calibration program is recorded. Records are maintained to show that established schedules and procedures for the 086 calibration of M&TE have been followed. The records contain a history of 17.2.12.6 calibration or other means of control for each item showing the calibration interval, date of last calibration, and the conformance or nonconformance to required tolerance prior to and following adjustments. Records identify the equipment or reference standard to which the records apply, the procedure or instruction followed in performing the calibration, and the calibration date.
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WSES-FSAR-UNIT-3 Equipment and identification lists, procedures, calibration records, personnel qualifications, and nonconformance reports are retained as required by codes,
?17.2.17 standards, and specifications and in accordance with Section 17.2.17, 17.2.13 HANDLING, STORAGE, AND SHIPPING 17.2.13.1 17.2.13.1 General Quality related items are handled, stored, cleaned, and shipped in a manner to prevent deterioration, contamination, damage,.or loss of identification.
Procedures are provided for control of these activities. As appropriate, detailed. instructions are provided for handling, cleaning,- storing, maintaining while stored, and shipping specific items of equipment or material. Under normal circumstances, the manufacturer's instructions or recommendations are followed and are implemented to maintain material integrity and protection. Personnel performing these activities are knowledgeable of the work to be performed and the procedures employed.
17.2.13.6 17.2.13c2
.Consumables Procedural controls are established for chemicals, reagents, fuels, oil, lubricants, and other consumables to assure proper storage, handling, utilization, and disposition.
17.2.13.7 17.2.13.3 Material Handling Equipment Material' handling equipment such as cranes, forklifts, and cables are tested in accordance with established procedures.
17.2.14 INSPECTION, TEST, AND OPERATING STATUS 17.2.14.1 General The inspection, test, and operating status of structures, systems, and 17.2.14.2 equipment under the scope of the Quality Assurance Program is controlled in accordance with procedures.
17.2.14.2 Requirements 17.2.14.2 The Plant Manager develops procedures relating to the operational status of l
the plant. These procedures require:
a) That the status (inoperative, test or operational) of quality related 17.2.14.4 P.1 systems and equipment be indicated; and i
17.2.14.3 P.1 b) That the status of inspections and tests performed on quality related systems and equipment be indicated.
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WSES-FSAR-UNIT-3 17.2.14.3 Identification System 17.2.14.3 P.1 The status of quality related systems and equipment is indicated by stamps, tags, labels, status boards, routing cards, logs, schedules, computerized readouts or a combination thereof. The Technical Specifications establish the 17.2.14.4 P.3 status of quality related structures, systems, and components required for the safe operation of the plant, including provisions for periodic and nonperiodic tests and inspections of various instruments, structures, components, systems or parts of systems.
Systems and equipment at the plant are controlled to prevent their inadvertent 17.2.14.4 operation, in accordance with Waterford-3 clearance procedures which specifies the control of status indicators and the authority for application and removal.
Plant instructions that require equipment to be removed from service for
- 17. 2.14. 4 P. 263 maintenance, testing or modification specify the equipment associated with i
these activities so that the appropriate type of clearance may be issued.
Required inspections, tests, and operations are performed in accordance with 17.2.14 3 approved procedures. cognizant plant supervisors, assure that necessary inspections and tests are conducted in their area of responsibility and the status of these inspections and tests is maintained current.
Changes to the requirements of these procedures and instructions, including 17.2.5 altering the sequence, are controlled by procedures.
17.2.15 NONCONFORMING MATERIALS, PARTS, OR COMPONENTS i,
17.2.15.1 General 17.2.15.1 The Quality Assurance Program requires control of quality related nonconforming materials, parts or components. These requirements which control the identification, documentation, segregation, review, disposition, notification to affected organizations, repair, rework, retest, and reinspection of nonconforming materials, parts, components, and, as applicable, activities and services (including computer codes) are defined by procedures.
17.2.15.2 Control of Nonconformances The Quality Assurance Program provides for the following actions when quality related materials, parts, com'ponents, systems, activities, or services do not conform to drawings, specifications, workmanship standards or other applicable documents:
)
i 17.2.15.4 a) Identify the nonconfortning items and clearly describe the nonconformance; l
17.2.15.5 b) Document the nonconformance:
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.c)
Segregate from acceptable items (where practical) and identify the nonconforming items until properly dispositioned to prevent their inadvertent use or installation; 17.2.15.7 P.1
.d)
Review the nonconformance; 17.2.15.7 e) Provide approved written dispositions for the nonconformance;
.17.2.15.3 P.1 f) -Provide copies of reports which identify the nonconformance for distribution as required by appropriate procedures; and 17.2.15.3'P.1 g) Notify affected organizations.
I A technical evaluation is made to determine whether a nonconforming item may
)
'17.2.15.7 be accepted "as-is", reworked or repaired to an acceptable condition or rejected. Nuclear Operations Department managers are responsible for
'17.2.15.2 P.1 documenting, segregating, dispositioning, and reviewing nonconformances and for ensuring that corrective action is taken by cognizant persons or organiza-tions.
087 The Onsite Safety Review Subgroup of the Project Management Department provides an independent review of nonconformances, disposition, and closeout
- 17. 2.15. 2 P. 2,6 during the operations phase. The Nuclear Operations Quality Assurance Group performs a screening and evaluation, if required, of potential 10 CFR 21 items. Following the deportability determination, the Nuclear Operations Quality Assurance Group reports the item to the NRC.
088 The Plant Quality Manager is responsible for conducting inspections to verify 17.2.16.2 P.2 adequate implementation of corrective action concerning nonconformances. l The Quality Assurance Section is responsible to conduct reviews and audits to 17.2.15.2 P.5 verify the adequacy of control measures for identification, notification, segregation, technical review, disposition, and documentation of j
nonconformances.
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17.2.15.3 Quality Trends
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.17.2.15.2 P.5-Nonconfolmance reports are periodically analyzed by the Quality Assurance Section for quality trends and any significant results reported to the Senior Vice President-Nuclear Operations for review and assessment. Quality trending of plant nonconformances will be provided by the Plant Quality Group reporting the results to the Plant Manager.
17.2.15.7 P.4 17.2.15.4 Repair and Rework of Nonconforming Items l
Reworked, repaired, and replaced items are inspected and tested in accordance with the original inspection and test requirements or acceptable alternatives.
Nonconforming items are also reinspected in accordance with any additional requirements established by the technical evaluation. The rework, repair or inspection procedure is documented and made part of the inspection records.
17.2.15.4 Rejected items are identified by tagging, and where. practical, removed from 17.2-42 l
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'the area.to preclude further use or installation. Final alternative action in the case _of rejected items may be the return of such material / equipment,to the supplier or.to scrap.
17 2.15.8 17.2.15.5 Records Documentation of nonconforming materials, parts or components is maintained in accordance with LP&L's quality assurance records management procedures.'
Information contained in the documentation includes but may not be limited to:
a)
Identification of the nonconforming item; b)
Description of the nonconformance; 1
_c)
Inspection requirements; d)
Disposition of the nonconformance; and e)
Signature approval for disposition.
17.'2.16.1 17.2.16 CORRECTIVE ACTION
.17.2.16.1 General Conditions adverse to quality, such as nonconforming items, equipment failures, malfunctions, deficiencies, and deviations are promptly identified and corrected.
Significant conditions adverse to quality are: (1) conditions reportable to 17.2.16.4 the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or within 30 days in accordance with the Technical Specifications, (2) conditions reportable under 10 CFR Part 21, (3) any gross or widespread noncompliance with procedural requirements that negates the effectiveness of quality assurance controls, or (4) any condition which has recurred with such a frequency that it indicates past corrective actions (if any) have been ineffective.
17.2.16.2 P.1 Conditions adverse to quality are evaluated, reported to supervision and/or to the Quality Assurance Section, and corrected in a manner consistent with safety. Those conditions adverse to quality determined to be significant are 17.2.16.4 P.1 documented, the cause of the condition identified, and corrective action taken to prevent recurrence.
Methods for implementing corrective action requirements are documented in 17.2.16.3 procedures.
17.2.16.2 Procedural Requirements 17.2.16.3 Procedures and instructions for corrective action of adverse conditions include provisions for:
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WSES-FSAR-UNIT-3 a) Each person employed by LP&L to identify and report to his immediate supervisor or a Quality Assurance representative conditions suspected to be
)
adverse to quality within his area of responsibility;
)
)
b) Supervisory review and classification of reported conditiors adverse to quality; c) Correction of adverse conditions; and d) Documenting conditious adverse to quality and initiating corrective action to preclude recurrence.
Corrective action reports become part of the plant quality assurance records.
17.2.16.6 The Plaut Quality Manager verifies implementation of corrective action for REF: 088 e nditions adverse to quality within the plant (the Corporate Quality 17*2'16*2 Assurance Manager for those external to the plant) and reviews documentation generated by the action before the corrective action report is closed.
17.2.16.3 Significant Conditions Adverse to Quality 090 For those conditions adverse to quality determined to be significant, the 17.2.16.1 corrective action is reviewed by PORC and approved by the Plant Manager. He 17.2.16.4 has the authority to cause immediate temporary corrective action to be taken.
The Quality Assurance Section makes a det'ermination of deportability under REF: 087 10 CFR Part 21, l
f l
17.2.16.4 Contractor Responsibility 17.2.16.5 Contractors performing services or activities pertaining to the quality related portions of the plant or any quality related systems or components are required to comply with LP&L approved procedures which require conditions adverse to quality to be identified, reported, and corrected.
17.2.17 QUALITY ASSURANCE RECORDS 17.2.17.1 General 17.2.17.1 Quality assurance records are those completed records that furnish documentary evidence of the quality of items or of activities affecting quality and those 17.2.17.3.f records required by the Technical Specifications. LP&L has established a l
quality assurance records management program for Waterford-3. Requirements 17.2.17.3 P.1 for control of quality assurance records are defined in procedures.
091 The Records and Administrative Manager-Nuclear, Project Management Group is 17.2.17.2 responsible for the management of quality assurance records.
Organizations that initiate requests for services or materials are responsible 17.2.17.2.b for assuring that the applicable quality assurance records requirements are imposed upon the contractor or supplier / vendor. Each organization responsible 17.2.17.2.c for the receipt of quality assurance records designates a responsible person 17.2-44 l
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' or group.for the rev'iew, acceptance, and forwarding for 'further processing of
)
those. quality assurance. records they review.
)
17.2.17.2 Types of Records.
17.2.17.3 P.7 Quality; assurance records include but are not limited to the following:
)
i ua ) Records completed during the design and construction of the plant,.
including design drawings and specifications; construction logs and results of reviews, inspections, tests, audits and monitoring of work performance; I
procurement documents; material analyses and certifications; NDE records; and other similar documents, b) Documents and records compiled during operation, including operating logs; maintenance'and modification records, reportable occurrences; results of reviews, inspections, tests and material analyses; monitoring of work performance; qualification of personnel, procedures and equipment;. procurement documents and specifications; calibration records and nonconfonmance reports l
and corrective actions.
17.2.17.3 P.8
'17.2.17.3 Inspection and Test Records Inspection and test records include the following:
a) A description of the type of observation; b) Evidence of completing and verifying a manufacturing, inspection or test operation; c) The date and results of the inspection or test; l
d). Information related to conditions adverse to quality; i
e) Inspector and/or data recorder identification; f) Evidence regarding the acceptability of the results; and g) Action taken to resolve any discrepancies noted.
17.2.17.3 P.6 17.2.17.4 Corrections and Supplements Quality assurance records required by codes and regulations are corrected or supplemented only in accordance with written procedures which provide for appropriate review and approval by the originating organization. The correction or supplement includes the date and the identification of the person authorized to issue each correction or supplement.
17.2-45
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17.2.17.5 Retention and Storage of Records Records are maintained current and complete and made available by applicable
17.2.17.6 contra'ctors and suppliers for audit by LP&L or its representative at any
.17.2.4.3.e.
reasonable time. Those records are maintained in facilities that provide a suitable environment to minimize deterioration and to prevent damage or loss.
17.2.17.4 Written procedures are provided for records storage and maintenance by contractors and suppliers.
The storage location, preservation, retrieval, transmittal, and disposition of 17.2.17.3 quality assurance records for Waterford-3 is established by procedure.
Quality assurance records are identifiable and retrievable. Procedures for L17.2.17.5
, retention and storage include requirements for maintenance, preservation, and 17.2.17.4 protection of quality assurance records. These requirements identify methods for maintaining control of, access to, and accountability of records; provide for storing records in a manner to preclude deterioration; provide for security; and provide for record storage facilities which protect the contents from possible destruction by causes such as fire or flooding.
A satisfactory alternative to the establishment of a single. record storage 17.2.17.4 P.3 facility is the maintenance of a duplicate copy of records in a remote location. Where duplicate storage is employed, the storage area environment will be the prevailing building temperature and humidity.
17.2.17.3 P.4 A listing of the required records is developed and available prior to or with the receipt of the records. The retention times of the records and the location of the record copies of the records is injicated in a records index.
Records which may not be sent to and stored at tre pant but retained by the 092 quality related suppliers and contractors include Gy are not limited to the DELE'1ED following:
a)
Permanent records -
- 1) Design calculations;
- 2) Verifications of design calculations; and
- 3) Technical evaluations, analyses, and reports.
b)
Non-permanent records -
- 1) Quality Assurance audits;
- 2) Vendor audit reports; and
- 3) Pre-award Quality Assurance surveys.
Procurement documents specify that e manufacturer, supplier, consultant or contractor either retain radiographs produced by them for the life of the project and throughout commercial operation of Waterford-3 or that they send such radiographs to LP&L af ter being retained in accordance with contractual or code requirements. Radiographs received by LP&L from quality related consultants, contractors, manufacturers, and suppliers are handled and stored in accordance with approved procedures.
17.2-46
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e WSES-FSAR-UNIT-3 17.2.18 AUDITS 17.2.18.1 General The Corporate Quality Assurance Manager has the authority and organizational 17.2.18.*,
freedom (see Section 17.2.1) to schedule and perform internal and external 17.2.1 P.5 audits of quality related programs and activities during the startup and operation of Vaterford-3. Requirements for the audit program are defined in
.REF: 002 the Quality Assurance Manual and procedures for its implementation are contained in the Quality Assurance Section Procedures Manual.
17.2.18.1 The audit system is designed to satisfy the requirements of 10 CFR 50, Appendix B, and the Technical Specifications. The Senior Vice 17.2.1.3.0.1.e President-Nuclear Operations has delegated to the Corporate Quality Assurance Manager the responsibility and authority to plan, schedule, conduct, and report audits of activities associated with quality related functions of Waterford-3.
17.2.18.3 Objectives of the audit program are:
a) To ensure that the LP&L Quality Assurance Program is defined and documented; b) To verify on a regular basis by examination and evaluation of object.1ve evidence that established requirements, methods, procedures, and instructions are being implemented; c) To assess the effectiveness of the Quality Ass 1rance Program; d) To identify program weaknesses and nonconforman:es; and e) To verify correction of identified adverse conditions.
17.2.18.2 Audit Scope 17.2.18.3 P.2 Audits are conducted to verify that procedures and activities of LP&L organizations and its contractors / suppliers comply with the Quality Assurance Program requirements. Audits are performed by the Quality Assurance Section to provide a comprehensive independent verification and evaluation of quality related procedures and activities. Additional audits are performed as required to verify and evaluate supplier Quality Assurance Programs, procedures, activities, and interface controls.
Audits include objective evaluation of work areas, activities, and processes; 17.2.18.3 P.3 and the review of documents and records. Audits also include an objective evaluation of quality related practices, procedures, and instructions; the effectiveness of their implementation, and the compliance with policy directives.
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WSES-FSAR-UNIT-3 17.2.18.3 P.4 Audits are performed in areas where 10 CFR 50, Appendix B, requirements are being implemented. These. areas include, as a minimum, the quality related activities associated with:
!REF: 001 a) Startup, operation, maintenance, and modification; b) The preparation, review, approval, and control of designs, specifications, procurement documents, instructions, procedures, and drawings; c) Receipt inspection; d) Indoctrination and training programs; e) Implementation of operating and test proced tres; f) Calibration of measuring and test equipment; and g) Interface control among LP&L organizations and contractors / consultants.
In addition to the above, audits are conducted of the Radiological Environmental Monitoring Program, the Emergency Plan, the Fire Protection Plan, the Security Plan, and any other areas required by LP&L Management, the Corporate Quality Assurance Manager or regulatory agencies. These audits are TBL 17.2-1 (16) conducted in accordance with requirements of the guidance documents listed in Table 17.2-1.
17.2.18.3 Audit Planning and Scheduling 17.2.18.2 P.1 The Corporate Quality Assurance Manager is responsible for determining the need for audits of quality related programs and activities. The audit program 17.2.18.4 includes a documented schedule of audits showing the organizations to be audited, the dates of the audits, and the areas to be audited in accordance TBL 17.2-1 (2) with regulatory position C.4 of Regulatory Guide 1.33 and Section 6 of the Waterford-3 Technical Specifications. Audits are scheduled based on the status and safety importance of the activities to be audited. Audit frequency 17.2.18.4 is determined by the requirement to ensure et/t: teve quality assurance during the startup testing and operational phases. Ti t:
adit schedule is approved by 17.2.18.2 the Corporate Quality Assurance Manager.
Quality Assurance audits are planned and conducted in accordance with approved 71.2.18.5 P.1 procedures. Audit planning includes preparation of checklists or procedures that will ensure consistency and completeness in the evaluation. l Unresolved 093 ttems noted during previous audits are reviewed prior to checklist preparation 17.2.18.5 and-included for reaudit as appropriate.
17.2.18.6 17.2.18.4 Audit Performance Audits are performed using prepared checklists or audit procedures.
The audit 094 checklist is a guide and,does not restrict the audit scope when additional TBL 17.2-1 (16) investigation is needed.} Audit notification, pre-audit conference, audit process, and post-audit conference is in accordance with established 17.2.18.6 procedures.
17.2-48
WSES-FSAR-UNIT-3 17.2.18.5 Audit Personnel 095 Audits are conducted by qualified LP&L auditors who are experienced, trained, TBL 17.2-1 (16) and familiar with requirements and standards applicable to the area or (17),a'ctivity being auditec.l Audit team members are independent of any direct 17.2.18.1 respons10111ttes for the activities which they~ audit.l Auditors participate in 096 the LP&L Auditor Training Program and maintain proficiency through review and study of codes and standards related to quality assurance and through active 17.2.2.6
, participation in the audit program. l LP&L lead auditors are certified in TBL 17.2-1 (16) accordance with Reguiatory Guide 1.146.
Audit teams may include consultants and technical specialists not certified as auditors so long as they are under direct supervision of a certified lead auditor.
17.2.18.6 Audit Reporting and Follow-up 17.2.18.7 Audit procedures require that upon completion of an audit, findings are reported to responsible management of the organization audited. Any audit 17.2.18.6 finding which requires immediate resolution is reported without delay tc appropriate supervision. Audit findings are discussed in the exit interview.
TBL 17.2-1 (16) Formal audit reports are issued within 30 working days of the exit interview.
097-Distribution includes the Senior Vice President-Nuclear Operations, the 17.2.18.7 Corporate Quality Assurance Manager and the manager responsible for corrective i
action in the area audited. l It is the responsibility of the cognizant manager 17.2.18.2 to review the audit report and to take action as necessary to ensure that 17.2.18.8 P.1 e erective action is accomplished in a timely manner. The responsible Quality 17.2.18.8 P.2 Assurance group manager or the audit team leader is responsible for follow-up action (including reaudits) as required to ensure that corrective action has been taken and is effective. Audit findings are documented in the audit 17.2.18.9 report and corrective actions and reaudits are documented with reference to the original audit.
17.2.18.7 Management Audits 098 17.2.1.1 P.2 An independent review and evaluation of the Quality Assurance Program is 17.2.2.8 performed annually at the direction of the Senior Vice President-Nuclear TBL 17.2-1 (4-3) Operacions. In combination with regular reports and assessments provided by the Corporate Quality Assurance Manager, these program audits enable the Senior Vice President-Operations to adequately evaluate the effectiveness of the Quality Assurance Program.
1 Ogg 17.2.18.8 Analysis of Audit Data 17.2.1.3.0.Im g 7 ' '9*y'g p*~
Audit data is analyzed by the Corporate Quality Assurance Manager who reports 9
i any significant quality problems and the effectiveness of the Quality j
Assurance Program, including the need for reaudit of deficient areas, to the Senior Vice President-Nuclear Operations.
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WSES-FSAR-UNIT-3 TABLE 17.2-3 (Sheet 1 of 3)
QUALITY ASSURANCE MANUAL COMPLIANCE WITH 10 CFR 50, APPENDIX B 10 CFR 50, Appendix B Criterion Quality Assurance Manual I.
Organization Chapter-1.0 Defines the organizational structure and delineates the authority and responsibilities of individuals and organizations performing quality assurance activities.
II.
Quality Assurance Chapter-2.0 Defines the scope of the Program Quality Assurance Program and establishes that activities affecting quality related structures, systems, and components l
will be conducted in accordance with approved i
procedures.
III.
Design Control Chapter-3.0 Defines requirements for the control of the design of quality related structures, systems, and components including the j
design of plant
)
modifications.
IV.
Procurement Chapter-4.0 Defines requirements for Document the control of procurement Control of quality related structures, systems, components, materials, and services.
V.
Instructions, Chapter-5.0 Defines requirements for l
Procedures, and the development and control I
Drawings of instructions, procedures, and drawings.
l i
I
1 WSES-FSAR-UNIT-3
)
.1 TABLE 17.2-3 (Sheet 2 of 3)
QUALITY ASSURANCE MANUAL 3
1 COMPLIANCE WITH 10 CFR 50, APPENDIX B 10 CFR 50, Appendix B Criterion Quality Assurance Manual VI.
Document Control Chapter-6.0 Defines requirements for the control of documents for quality related structures, systems, and components and identifies the types of documents to be controlled.
VII.
Control of Pur-Chapter-7.0 Defines requirements for chased Material, ccntrol of purchased Equipment, and material, equipment, and Services services, including control of suppliers and receiving inspection.
VIII.
Identification Chapter-8.0 Defines requirements for l
and Control of control of materials, parts Materials, Parts, and components.
and Components IX.
Control of Special Chapter-9.0 Defines requirements for Processes control of special processes including welding, heat treating, NDE, and chemical cleaning.
X.
Inspection Chapter-10.0 Defines requirements for inspection of materials and activities important to safety including criteria for determining when and how inspections are performed.
XI.
Test Control Chapter-11.0 Describes the scope of the test control program and establishes requirements for test procedures and instructions.
l k
o WSES-FSAR-UNIT-3 TABLE 17.2-3 (Sheet 3 of 3)
QUALITY ASSURANCE MANUAL COMPLIANCE WITH 10 CFR 50, APPENDIX B l
10 CFR 50, Appendix B Criterion Quality Assurance Manual i
XII.
Control of Chapter-12.0 Defines requirements for Measuring and control of measuring and Test Equipment test equipment used for inspections, tests, and monitoring of quality related equipment and activities.
XIII.
Handling, Storage, Chapter-13.0 Defines requirements for i
and Shipping handling, storage, and shipping of quality related structures, systems and components.
XIV.
Inspection, Test, Chapter-14.0 Defines requirements for and Operating
' control of inspection, l
Status test, and operating status of quality related items and equipment.
XV.
Nonconforming Chapter-15.0 Defines requirements for l
Material, Parts, identification, j
or Components documentation, segregation, j
4 review, and disposition of nonconforming materials, parts, and components.
XVI.
Corrective Action Chapter-16.0 Defines requirements for establishment of an effective corrective action program with followup to verify proper implementation.
XVII.
Quality Assurance Chapter-17.0 Defines requirements for a Records quality related records i
program including l
identification of types and l
content of records.
XVIII.
Audits Chapter-18.0 Defines requirements for audits of quality related activities including audit program scope and methods.
1 I
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Attachment #3
].
REMARKS DOCUMENT
~
DESCRIPTION COMHENT 9
001 This revision incorporates the deletion of references to construction and start-up testing and reflects the reorganization of the Nuclear Operations Department.
002 The Corporate level quality policies which are presently contained in Section V and VI of the Fuelear Operations Management Manual provide improved accessibility to all Nuclear Operations Personnel. Additionally, all Senior Management concur with and are therefore cognizant of its content.
003 The term " safety related" has replaced " quality related" throughout this revision, however the scope of the activities remains unchanged. The current usage of the term " safety related" in 17.2.2.4 is more consistent with LP&L QA Program documentation and provides LP&L management the option of applying 10CFR50, Appendix B criteria to "non-safety related" activities by categorizing the activity as " quality related".
1 004 Verification activities are performed by individuals other than personnel in the Quality Assurance Group. Verifications I
in the form of inspections are performed by plant staff personnel as described in the Technical Specifications. Other verifications such as surveillance may be performed by groups such as ISEG or engineering. The Quality Assurance Group currently performs audits, reviews, inspections and surveillance as required.
1 005 Those individuals or organizations no longer applicable since f
the commencement of the operations phase have been deleted.
The remaining individuals and organizations have been listed f
in the following paragraphs.
l 006 This change documents the reorganization of the Nuclear Operations Department at the Senior Manager level.
I 007 This sub-section was relocated to Section 17.2.2 where it is more applicable.
Reference comment 098 for basis of change.
008 Editorial change only. This paragraph does not contain additional responsibilities or requirements.
009 This responsibility was deleted because it created a potential conflict with para. 17.2.1.1 which states that: "The Senior Vice President - Nuclear Operations appoints the Chairman and members of the Safety Review Committee."
Page 1
REMARKS DOCUMENT COMMENT DESCRIPTION 010 This responsibility was deleted because it was a duplication
[
of item c.
011 The Nuclear QA Manager's qualification requirements in the previous version contained potential conflicts with the requirements of ANS 3.1 - 1978 as referenced in Table 17.2-1.
Therefore, the paragraph has been changed to reference the standard.
012 The references to sections under the control of the Nuclear Quality Assurance Manager were deleted.
The responsibilities previously contained in the QA Section Manager's descriptions were moved to the Nuclear QA Manager's description throughout the QA Program description.
013 The Plant Quality Group was reorganized into the Quality Assurance Group during the reorganization of the Nuclear Operations Department.
014 Reference Figure 17.2-2.
The Plant Manager currently reports to the Vice President - Nuclear. The managers reporting to the Vice President - Nuclear have been added, and the responsibilities have been redistributed as shown.
015 This responsibility was deleted because it created a potential conflict with para.
17.2.1.1 wh1ch states that:
"The Senior Vice President - Nuclear Operations appoints the Chairman and members of the Safety Review Committee."
016 The Plant Quality Manager position was deleted during the reorganization.
The responsibilities have been redistributed as shown.
017 This section was deleted. The responsibilities have been redistributed as shown.
018 The position of Plant Quality Manager was deleted. The responsibilities have been redistributed as shown.
019 The Project Manager - Nuclear position as previously defined was deleted. The responsibilities have been redistributed as shown.
020 This responsibility is common to all of the Nuclear Operation's organizations.
Page 2 8
q.
REMARKS DOCUMENT u
COMMENT DESCRIPTION 021
- This responsibility was deleted.. Scheduling is performed by the Planning and Scheduling section under the Plant Manager -
Nuclear and under the.Vice President -_ Nuclear.
022.
This construction responsibility was deleted.
023 These responsibilities were deleted because they were either completed and are not on-going, or do not require Nuclear Services support.
I l
024' The Completion Manager - Nuclear. position was deleted. There are no operational responsibilities associated with this position.
q 025
.Also reference comment 002. The Quality Assurance Policies are presently contained in Section V & VI of the Nuclear Operations Management Manual which is a controlled manual.
026 The specific departmental /section level procedures have been reorganized as shown in Table 17.2-2.
.027 This section was revised to incorporate the reorganization.
I 028 The responsibility for assuring that training is conducted is common to all Senior Management.
029 This requirement was changed to more accurately reflect the j
requirement of ANSI N45.2.6-1978 as endorsed by Regulatory Guide 1.58 Rev. 1, 1980 and particularly Regulatory Position C-10 for the use of " Determination of Initial Capability" in lieu of required education and experience.
030 This paragraph was deleted.
The requirement is redundant with that contained in 17.2.18.3.
J 031 This paragraph was deleted. The Startup Testing and Systems Turnover requirements are no longer applicable.
032 Reference to the Quality Assurance Manual was deleted. This paragraph is intended to show maintenance of the QA Program description. The implementing policies and procedures are maintained and controlled in accordance with 17.2.5 and 17.2.6.
Page 3
)
^
REMARKS DOCUMENT f
COMMENT DESCRIPTION 033 The Fire Protection QA Program is currently defined in a Quality Policy contained in the Nuclear Operations Management Manual. The program is based on guidance contained in Regulatory Guide 1.120, " Fire Protection Guidelines for Nuclear Power Plants" and Branch Technical Position CMEB 9.5-1, " Guidelines for Fire Protection for Nuclear Power Plants."
034 The Project Manager - Nuclear position as previously defined has been deleted. This responsibility now resides with the Nuclear Operations Engineering Manager. The 60 day reference is no longer applicable and has been deleted.
035 This paragraph was deleted because it was redundant with controls placed on all design documents. The examples cited in this paragraph are not all inclusive and were not considered pertinent to the requirement. Procedural control is specified in 17.2.3.1.
Design reviews are procedurally controlled as stated throughout 17.2.3.
036 Design verification other than qualification testing is completed prior to drawing release.
037 This requirement was deleted because it was a duplication of requirements defined in 17.2.4.3.b which delineates the technical requirements for procurement of items and services.
038 The Quality Assurance Manual has been replaced by Sections V &
VI of the Nuclear Operations Management Manual which provides 1
direction for procedural control of safety related procedures 1
and instructions.
039 Approval of procedures is not only by the individual in charge of the organization engaged in the activity, but by other responsible management as applicable.
l 040 The originating organization will in most cases actively resolve the comments generated by procedure reviews.
If, however they do not, approval of the procedure or procedure change is required by the originating organization after comments have been resolved.
Page 4
REMARKS DOCUMENT COMMENT DESCRIPTION 041 The responsibilities for procedure review were redefined. As documented in Amendment #18 of the Waterford 3 Technical Specifications, the Plant Operations Review Committee (PORC) was reorganized and obtained a member who is knowledgeable in Quality Assurance / Control. PORC reviews all safety related plant procedures. The Quality Assurance Group reviews other selected Nuclear Operations Procedures.
042 Changes to documents are reviewed and approved by the same organizations that performed the original review and approval or as designated by management. The management perrogative was added due to the changing structure of the Nuclear Operations Departments. Certain organizations may be deleted or redefined.
043 The requirement was deleted because it was not relevant to the operations phase.
044 This responsibility was shifted to the Nuclear Operations Engineering Group during the reorganization.
Station Modifications are now referred to as design changes.
045 The Project Management Procedures (PMP) are being deleted and replaced by other organizational procedures as a result of the reorganization.
PMPs have been replaced by NOEPs, N0 SAPS, NOCPs and NPCPs as defined in table 17.2-2.
l 046 The evaluations of suppliers are conducted through audits and surveillance by Quality Assurance Group personnel
)
appropriately qualified and certified in accordance with ANSI N45.2.23-1978.
)
f 047 The audit program, as defined by ANSI N45.2.23-1978 encourages the use of technical specialists when conducting audit j
activities. The source of the technical specialist may vary
{
and therefore the statement was not of benefit to the QA Program requirement.
)
048 Documentary evidence of material or equipment acceptability
)
must be available prior to use but not necessarily installation. This allows installation to proceed under specified conditions but precludes dependence on the item for safety purposes. Therefore, the intent of 10CFR50 Appendix B continues to be met.
i Page 5 i
.________________-___a
REMAPKS DOCUMENT COMMENT DESCRIPTION 049 Deletion of the requirement to review commercial item suitability prior to supplier or item selection does not affect the quality of the item.
Items must be reviewed for suitability prior to use of the item.
050 The Project Management Group was deleted during the reorganization. Th1s responsibility has been shifted to the Nuclear Operations Engineering Group or Plant Engineering.
051 This review is being conducted by the Quality Assurance Group.
The Plant Quality Group was deleted during the reorganization.
052 Reference 17.2.8.3.1.
The inclusion of identification requirements in design documents and the subsequent verifications are only as required by specified codes, standards or specifications. LP&L utilizes procedures to define the applicability of this requirement.
053 The title of Administrative Manager - Nuclear, of the Administrative Services Department has been changed to the Nuclear Operations Administration Manager.
054 This function is performed by the Quality Assurance Group through receipt inspections and surveillance.
055 The phrase "as they are applied to quality related items" was deleted. The scope of this section of the QA Program is defined in 17.2.2 which defines the scope of the entire QA Program.
056 The Non-Destructive Examination categories have been consolidated to "NDE".
057 The requirements regarding the qualifications and certification of personnel performing special processes vary with the process and the applicable standards. Therefore, this requirement was changed to state that qualifications of personnel, procedures and equipment comply with specified requirements.
Further, it states that the requirements of applicable codes and standards...are specified or referenced in the procedures or instructions.
i REMARKS DOCUMENT
. COMMENT-DESCRIPTION' 1
l 058-Ref: ~057.
The' requirement for a Level III to review and.
J
-approve procedures for a special process is common among other
- j inspection disciplines. Therefore, the requirement is not
)
stated for NDE only. The codes and Standards applicable to l
the NDE and other examination or inspection methods are defined or-referenced in procedures.
/
1 059 The retention of qualification records is defined by I
17.2.17.3.
Under the reorganization,' the Nuclear Services Manager is responsible for the administration of the Records Management System. The Nuclear Quality Assurance Manager is responsible for verifying the adequacy of the Special Process'
]
Program.
1 060 Special process control records to be supplied to LP&L would be specified in the applicable procurement documents as stated l
in 17.2.4.3.e.
f 061 Under the Nuclear Operations reorganization, the inspection program is now under the direction of the Nuclear QA Manager.
Normal routine inspections are performed by qualified maintenance personnel reporting to the Nuclear Plant Operations Manager as well as personnel reporting to the Nuclear QA Manager.
062 Under the reorganization, LP&L utilizes inspection personnel from various sources as shown in 17.2.10.3, Paragraph 1.
Special inspections such as' nuclear fuel receiving may require qualified individuals from outside of the Quality Assurance organization who possess the necessary expertise to adequately perform the inspection.
063 Inspections or tests of materials or products are performed l
for each work operation where necessary to assure quality.
Additionally, surveillance are performed periodically to l
supplement the audit program. The functions performed by the Plant Quality Group have been incorporated or replaced by Quality Assurance Group activities.
Indirect inspections and monitoring no longer apply, j
064 Training of inspection personnel is defined in 17.2.2.6.
The Nuclear Operations Training Manager is responsible for providing training to Nuclear Operations inspection personnel.
Qualification criteria is defined in applicable procedures.
065 References to preoperations and startup have been deleted.
Page 7 I
~
^
REMARKS DOCUMENT COMMENT DESCRIPTION 066 Test procedures include provisions to ensure that adequate instrumentation is available and used. The references to the Architect - Engineer and NSSS Vendor have been deleted as they may not be all inclusive or no longer applicable.
067 The personnel performing test activities are qualified in accordance with ANS 3.1 - 1978 and as shown in FSAR Chapter 13.
During construction and startup, the startup engineers were certified to perform testing activities. This has been discontinued since operation.
068 The inclusion of mandatory inspection hold points was deleted.
It is appropriately located in 17.2.10.6 " Inspection", which states that hold points are indicated in the appropriate documents which would include test documentation as necessary.
1 069 Test requirements and acceptance criteria are provided or l
approved by the organization responsible for the design and are based upon specified requirements contained in applicable design or technical documents.
Such design or technical documents define system arrangements and are used in conjunction with operating procedures for verification.
070 Since achieving commercial operation, the Nuclear Plant Operations Manager is responsible for the development of test procedures.
The Startup Group no longer exists.
071 PORC is responsible for the review of all testing procedures that affect systems / equipment classified as safety related prior to implementation.
072 The test results are evaluated to assure that test requirements have been satisfied. The test requirements as listed in 17.2.11.3 include the acceptance criteria and the specific requirements of the applicable design or other pertinent technical documents.
The scope of the evaluation or method may vary from design to design.
073 These preoperational and startup requirements are no longer applicable and were therefore deleted.
074 This statement was deleted because these requirements apply as stated in 17.2.12.1 and are implemented in accordance with written procedures.
Page 8
RDIARKS DOCUMENT COMMENT DESCRIPTION l
075 The plant department heads or supervisors are assigned these responsibilities through the implementing procedures for which the Nuclear Plant Operations Manager is responsible.
076 Under the reorganization PORC is responsible for the review of Plant Operations procedures including the calibration procedures. The Nuclear QA Manager is responsible for the performance of audits and surveillance to verify adequate implementation of the program.
077 The program's implementing procedures list the specific identities of items under the calibration program. Paragraph 17.2.12.4.2 states that "The method and interval of calibration for each instrument and control device is defined...".
J i
078 Due to the reorganization, this title has changed. To preclude confusion and permit authorization by levels equal to or higher than the one stated, the phrase was changed to "by responsible management."
079 The specific instructions for the proper handling of M&TE are contained in the implementing procedures. The broader statement that "M&TE is properly handled and stored to maintain accuracy" assures that not only environmental controls are in place, but many other controls as well.
4 080 Organizations performing calibrations for reference standards would be detenmined qualified through the audit program if the
)
organization was internal or through the Supplier Audit i
Program if external. Therefore, this requirement is satisfied by 17.2.7 or 17.2.18.
l 081 The Nuclear Plant Operations Manager is responsible for the development of procedures to implement these requirements.
Paragraph 17.2.12.4.2 now requires the control of M&TE to j
assure that equipment is calibrated prior to use and that each piece of equipment is suitably labeled or otherwise identified.
082 A calibration is performed when the accuracy of the equipment is suspect. This would include equipment which has been i
subject to possible damage. The calibration would determine if the equipment is adequate or whether further corrective actions would be necessary.
Page 9
)
6 REMARKS DOCUMENT
~
COMMENT DESCRIPTION 083 Lost or misplaced M&TE is' treated the same as M&TE found out of calibration. This is done in accordance with the implementing procedures which define the necessary controls.
084 The measures listed in'this paragraph are included in the implementing procedures. Paragraph-17.2.12.4.2 outlines the:
general control measures'which includes some of these requirements.
085 The requirements contained in this paragraph are included in the implementing procedures.
Procedure content is defined in 17.2.5.
086 The records requirements contained in this paragraph are defined in the implementing procedures and 17.2.17.
087 Under the reorganization, the Nuclear Safety and Regulatory Affairs Manager is now responsible for the 10CFR21 deportability functions. The Onsite Safety Review Subgroup has been replaced by the Independent Safety Engineering Group (ISEG) who performs the independent review of nonconformances on a random basis during the operations phase..
088 The Nuclear QA Manager is responsible for verifying the adequate implementation of corrective actions per 17.2.16.2.
089 The Nuclear QA Manager is now responsible for the Trend analysis of all nonconformances. The results are forwarded to the Sr. Vice President - Nuclear Operations.
1 090 The identification, cause, and corrective action for significant conditions adverse to quality is documented and reported to appropriate levels of management. This function is'further defined in implementing procedures.
091 Under the reorganization, the Nuclear Services Manager is now-responsible for the establishment and administration of the Nuclear Operations Records Management System.
092 The record retention requirements for suppliers is defined within the procurement documents.
The requirements may vary from those listed in 17.2.17.5 and were therefore deleted.
Page 10
J..-
REMARKS DOCUMENT C'OMMENT
' DESCRIPTION 093 Paragraph 17.2.18.5 states that: " Planning is conducted prior to each. scheduled audit." and "Such preparation is documented according to Quality Assurance Group Procedures."
Additionally, 17.2.18.6 states that:
" audit results are analyzed to determine the need for reaudit of deficient areas." Quality Assurance Procedures provide for the reaudit of unresolved items.
094 As stated in Table 17.2-1, Document 16, ANSI N45.12 - 1977, paragraph 4.3.2.1, the checklist is used as a guide and should not restrict the audit investigation. Quality Assurance
. Procedures specifically provide this instruction.
095 As shown in Table 17.2-1, LP&L is committed to ANSI N45.12 -
1977Property "ANSI code" (as page type) with input value "ANSI N45.12 -</br></br>1977" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. and ANSI N45.23 - 1978 which requires auditors to be experienced, trained and familiar with requirements and standards applicable to the area or activity being audited.
l f
I 096 The training of LP&L auditors is conducted in accordance with Quality Assurance Procedures as stated in 17.2.2.6.
These procedures define training, decertification and audit participation requirements.
097 The Sr. Vice President - Nuclear Operations cas deleted from the audit report distribution. As stated in 17.2.1.1, the Sr.
Vice President - Nuclear Operations is appraised of the the status _of the QA Program through status summaries submitted by l
the Nuclear QA Manager.
098 The annual Management Review of the LP&L QA Program is conducted at the direction of the Sr. Vice President - Nuclear Operations. As part of the review, an annual assessment is made by an independent qualified organization. The Sr. Vice President - Nuclear Operations provides the general scope for the assessment and in conjunction with the other regular reports and assignments such as the Quarterly Trend Analysis Report, he can better evaluate the effectiveness cf the QA Program.
099 As stated in 17.2.1.1, status summaries of the QA Program are prepared and submitted by the Nuclear QA Manager to the Sr.
Vice President - Nuclear Operations. The results of the
(
regular audit reports are an integral part of the status summaries.
1 Page 11
i REMARKS DOCUMENT COMHENT DESCRIPTION 100 As stated in Comment #1 of Document #1 (Table 17.2-1), 10CFR50 Appendix B, documentary evidence of material or equipment acceptability must be available prior to use but not necessarily installation. This allows installation ^o proceed under specified conditions..., but precludes depende~ce on the item for safety purposes. Therefore, the intent o 10CFR50 k
continues to be met.
101 This comment relates to the change from audits by offsite personnel to the annual assessments.
See comment 098 for further information.
102 LP&L has optioned to commit to ASNT Recommended Practice No.
SNT-TC-1A-1980 versus the 1975 version endorsed by Regulatory Guide 1.58, Revision 1 (Table 17.2-1, Document #8). The 1980 version of SNT-TC-1A provides further clarification of the requirements and is not considered a reduction in commitment.
The comment relating to the qualifications of Startup testing personnel is not applicable since operations, and therefore has been deleted.
103 The comment regarding in-process tests on concrete and reinforcing steel was formally withdrawn prior to this revision.
Reference LP&L letter #W3P87-1028 from K. W. Cook, Nuclear Safety and Regulatory Affairs Manager to the U.S.
Nuclear Regulatory Commission, Document Control Desk on May 1, 1987.
104 The comment regarding pre-audit and post-audit conferences had been added to this revision, however, prior notice has been issued per LP&L letter # W3P86-1078 from K. W. Cook, Nuclear Support and Licensing Manager to G. W. Knighton, Office of Nuclear Reactor Regulation on April 9. 1986.
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Page 12
r Attachment #1 j
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WSES-FSAR-UNIT-3
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CHAPTER 17 1
1 QUALITY ASSURANCE TABLE OF CONTENTS l
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l SECTION TITLE PAGE 1
17.0 QUALITY ASSURANCE 17.1-1 j
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17.1 QUALITY ASSURANCE DURING DESIGN AND 17.1-1 CONSTRUCTION 17.2 QUALITY ASSURANCE DURING OPERATIONS 17.2-1 17.2.1 ORGANIZATION 17.2-1 17.2.2 QUALITY ASSURANCE PROGRAM 17.2-11 17.2.3 DESIGN CONTROL 17.2-16 l
f 17.2.4 PROCUREMENT DOCUMENT CONTROL 17.2-21 17.2.5 INSTRUCTIONS, PROCEDURES AND DRAWINGS 17.2-24 i
17.2.6 DOCUMENT CONTROL 17.2-26 17.2.7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT 17.2-29 AND SERVICES 17.2.8 IDENTIFICATION AND' CONTROL OF MATERIALS, 17.2-34 PARTS AND COMPONENTS 17.2.9 CONTROL OF SPECIAL PROCESSES 17.2-36 17.2.10 INSPECTION 17.2-38 17.2.11 TEST CONTROL 17.2-42 i
17.2.12 CONTROL OF M&TE 17.2-44 i
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.4-WSES-FSAR-UNIT-3 CHAPTER 17 QUALITY AS3URANCE i
TABLE OF CONTENTS (Cont'd)
SECTION TITLE PAGE 17.2.13 HANDLING, STORAGE AND SFIPPING 17.2-46 17.2.14 INSPECTION, TEST AND OPERATING STATUS 17.2-48 17.2.15 NONCONFORMING MATERIALS, PARTS OR 17.2-50 COMPONENTS 17.2.16 CORRECTIVE ACTION 17.2-53 17.2.17 QUALITY ASSURANCE RECORDS 17.2-55 17.2.18 AUDITS 17.2-58 l
11 i
I
09/09/87 WSES-FSAR-UNIT-3 CHAPTER 17 QUALITY ASSURANCE LIST OF TABLES TABLE TITLE 17.2-1 Regulatory Guidance Documents 17.2-2 LP&L Nuclear Operations Quality Assurance Program Documentation 1
l 17.2-3 Nuclear Safety Quality Policies l
Compliance with 10CFR50, Appendix B l
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09/09/87 WSES-FSAR-UNIT-3
-TCHAPTER 17 f
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QUAMTY ASSURANCE
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-LIST OF FIGURES i
FIGURE TITLE 19 f.
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17.2-1 Organization for Nuclear Operations Quality Assurance l
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l 17.2-2 Organizations Affecting Quality During Operations Phase
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17.2-3 Nuclear Operations Document Hierarchy t,
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09/09/87 L,
3-WSES-FSAR-UNIT-3 17.2 OUALITY ASSURANCE DURING OPERATIONS
,k Louisiana Power & Ligut Company has a comprehensive operitions phase quality assurance program (hereafter referred to in this document as the Quality Assurance Program) which is applied to activit1es affecting those items which prevent or mitigate the consequences of postulated accidents which could cause undue risk to public health and safety. Activities controlled under the Quality Assurance Program include operations, maintenance, repair, modification, and refueling. LP&L retains and exercises responsibility for the Waterford-3
)
Quality Assurance Program.
The Quality Assurance Program for the operations phase as described herein complies with Regulatory Guide 1.33, Revision 2, 1978. Table 17.2-1 provides a listing of those Regulatory Guides and industry standards (including revis..%n number and date) to which LP&L is committed.
L/
A Corporate level quality policies which are approved by the Senior Vice Presiden't - Nuclear Operations define LP&L's QA Program for implementing 10CFR50, Appendix B.
Table 17.2-2 identifies procedures manuals that doct$eht the Quality Assurance Program. Table 17.2-3 correlates the contents of the Nuclear Safety Quality Policies with the criteria of 10CFR50, Appendix B. i 17.2.1 ORGANIZATION This Section defines the organizational structure and responsibilities of organizations performing safety-related activities during the operations phase of Waterford-3.
TheLP&LQualityAssuranceProgramprovidesclearanddefinitivelinesli.'[, authority, re Operational Quality Assurance Program. These lines extend from the highest management level through intermediate levels to and including the on-site operating organization and off-site organizational elements.
The organizational structure and functional responsibility assignments are such that attainment of program objectives is accomplished by those who have been assigned responsibility for performing the work. Verification of conformance to established requirements is accomplished by qualified personnel who do not have responsibility for performing or directly supervising the work, y
Figure 17.2-1 illustrates the lines of authority and communication for LP&L organizations involved in quality assurance for Waterford-3 during operations.
7 Figure 17.2-2 illustrates line and support organizational quality assurance responsibilities for safety-related activities.
The quality organizations have the authority and organizational freedom to perform their quality functions ef f ectively. They:
17.2-1
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Identf.fyqualityproblems;
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- b. P In.itiate,-recommend or provide solutions to problems through designated channels; and l
'c.
. Verify ' implementation of satisfactory solutions.
s p,
In accordance with approved procedures and as delineated herein, the Nuclear q
Quality A6uvegnee Mr. nager and his, staff have the authority to stop unsatisfac-
} i, nonconforming material at Waterford-3.toryworkjandr,ocontrol-the:furtherprocessing, deli The. quality organizations do not have direct responsibility for the performance of work which they verify / inspect for
'U gonformance with established requirements.
9 Organf nations and individual's involved in the implementation of the LP&L Quality Assurance Program are de & ibed in the paragraphs which follow.
3 n
x 17.L 1.1 Senior Vice 'P2 esident - Nuclear Operations
~
i o
The' Senior Vice President
' Nuclear Ope'ations who reports to the President and Chief Executive officer is responsible for<defihing LP&L quality assurance and nuclear safety policies. Reporting to tue Senior Vice President - Nuclear 1
Operations are the Vice President - Nuclear, Nuclear Services Manager Nuclear a
Quality Assurance Manager, and the Safety Review Committee. The Senior Vice Itysident.- Nuclear Operations appoints the Chairmat. and members of the Safety Yeview Committee.
r The Senior Vice President - Nuclear Operations reviews annual management d status summaries of the Quality
'!lausessment results, Quarterly Trend Reports, an Aseurance Program submitted by the Nuclear Quality Assurance Manager. These reportejeiable the evaluation of the effectiveness of the Quality Assurance Program. 'The Senior Vice President - Nuclear Operations approves and endorses the qudlity pglicies and revisions thereto. 1The Nuclear Safety Quality Policies defins the Quslity Assurance Program for implementation by LP&L organizations.
l 17.2.1.2 Safety Review Commitree The Fa ety Review Committee (SRd) provides Louisiana Power & Light Company's
)
senior management additional assurance that Waterford-3 is operated and maintained in.accordance with the Operating License, Technical Specifications, and applicable Federal and Fcate regulations which address nuclear safety. The SRC provides for: an independent re' view and audit of Waterford-3 operations; J
reviews of changes or modifications which involve an unreviewed safety question;
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reviews of safety evaluations of changes made to the plant and plant procedures s
?
uvder the provisions of 10CFR50.59; and special evaluations, reviews, and audits as' v y4be requested by the Senior Vice President - Nuclear Operations. The 1
(
h.chnical Specifications further describe the activities of the SRC.
17.2-2
09/09/87 3
WSES-FSAR-UNIT-3 17.2.1.3 Nuclear Quality Assurance Manager The Nuclear Quality Assurance Manager has the assigned responsibility for developing Quality Policies for senior manager concurrence and Senior Vice President approval. He assures implementation of the Nuclear Safety Quality Policies through reviews, audits, and inspections.
17.2.1.3.1 Nuclear Quality Assurance Manager's Responsibilities The principal responsibilities of the Nuclear Quality Assurance Manager include:
Planning, organizing, and administering the Quality Assurance Program; a.
b.
Preparation, maintenance, review and concurrence of quality policies; Reviewing and concurring with selected implementing procedures (see c.
Figure 17.2-3) and changes thereto; d.
Providing expertise and assistance to Nuclear Operations organizations for quality assurance activities; Assuring effective implementation.f the Quality Assurance Program through e.
a comprehensive system of reviews, audits, surveillance, and inspections; f.
Maintaining communications with regulatory agencies, suppliers, contractors, and LP&L organizational units, regarding safety-related activities; g.
Planning and performing evaluations, surveillance, audits or other verifications of supplier quality assurance programs and activities; h.
Maintaining a Qualified Suppliers List as an aid for use in procuring safety-related items and services; i.
Auditing the activities of Middle South Utilities System Services, Incorporated (MSUSSI) as they relate to Waterford-3; j.
Reviewing internally generated safety-related design drawings and specifications, and changes thereto to assure that the documents are prepared, reviewed, and approved in accordance with applicable procedures and contain the necessary quality requirements; k.
Reviewing and concurring with safety-related procurement documents; 1.
Developing and maintaining Quality Assurance Group Procedures; Submitting reports on the status and adequacy of the Quality Assurance m.
Program to the Senior Vice President - Nuclear Operations; n.
Providing periodic review and analysis of nonconformance documents to detect quality trends and publishing quarterly trend reports; 17.2-3
l fi 09/09/87 o
I WSES-FSAR-UNIT-3 Tracking of conditions adverse to quality which are identified by or o.
referred to the Quality Assurance Group; p.
Certifying Lead Auditors and Quality Assurance Inspectors; q.
Providing assistance to MSUSSI for nuclear fuel related activities; r.
Administration of a receipt and an instorage inspection program to assure acceptability and maintenance of safety-related materials, parts, and l
f components according to design; and l
Assuring that nonconforming materials, parts, and components are s.
identified, segregated (where applicable), reviewed, dispositioned and that the affected organization is notified.
l 17,2.1.3.2 Nuclear Quality Assurance Manager's Qualifications The qualifications of the Nuclear Quality Assurance Manager are at least equivalent to those described in paragraph 4.4.5 of ANSI /ANS-3.1-1978.
17.2.1.4 Vice President - Nuclear The Vice President - Nuclear reports directly to the Senior Vice President -
Nuclear Operations.
The Vice President - Nuclear is responsible for:
Managing the activities and maintaining administrative control of the a.
Nuclear Operations Support & Assessments, Nuclear Operations Engineering, Nuclear Operations Construction, Nuclear Plant Operations, and Nuclear Operations Training departments-1 b.
Developing goals and objectives for his organization in accordance with LP&L policies and the Quality Assurance Program; Developing and maintaining organizational strategies, guidelines, c.
responsibilities, and procedures commensurate with the defined objectives of his organization; d.
Participating in major project decisions and recommendations regarding operations, maintenance, engineering design, scope, schedule, budget and cost between LP&L and other organizations providing engineering / design or construction / modification services;
)
Monitoring the overall project effort to ensure compliance with the scope c.
of contracts, schedules and budgets; f.
Developing and maintaining technical expertise within his. organization as required to perform designated functional responsibilities; g.
Managing the establishment of safety evaluation methods for review of plant operations; 17.2-4
t-1 09/09/87 WSES-FSAR-UNIT-3 h.
Developing contro3s to ensure that quality and regulatory requirements are maintained for modification and engineering design work performed by organizations providing these services; i.
Developing cost / scheduling controls to ensure that budgets and schedules are developed to support plant operation and outages; and j.
Developing controls to ensure the proper administration of LP&L contracts.
l 17.2.1.4.1 Nuclear Plant Operations Manager i
The Waterford-3 plant operations organization (hereinafter referred to as the Nuclear Plant Operations staff) is headed by the Nuclear Plant Operations Manager and reports directly to the Vice President - Nuclear.
The Nuclear Plant Operations Manager is responsible for:
a.
Operation of the plant in accordance with the Operating License; l
b.
Reliable plant operation; l
Corrective and preventive maintenance of the plant; c.
d.
Implementing and maintaining various programs and procedures such as radiation protection, fire protection and security to ensure plant and personnel safety; Maintaining the physical configuration of the plant in conformance with the e.
approved design; f.
Implementing the Quality Assurance Program as it applies to the Nuclear Plant Operations staff; g.
Requisitioning, receiving, and storing materials, equipment, and supplies required for plant operation and maintenance; h.
Providing and maintaining a trained and qualified staff to safe!.y operate and maintain the plant; i.
Developing and implementing plant safety-related procedures and instructions for actf.vities such as plant operations, maintenance, repair, and testing; and j.
Addressing matters brought to his attention by the Plant Operations Review Ccmmittee (PORC).
The Nuclear Plant Operation: Manager delegates management authorities to his staff in his absence.
Reporting directly to the Nuclear Plant Operations Manager are a.
The Assistant Plant Manat,er - Operations and Maintenance; b.
The Nuclear Operations Administration Manager; 17.2-5
09/09/87 WSES-FSAR-UNIT-3 The Assistant Plant Manager - Technical Services; and c.
d.
The Planning & Scheduling Supervisor.
The Operations Superintendent and Maintenance Superintendent report to the Assistant Plant Operations Manager, Operations and Maintenance. The Radiation Protection Superintendent and the Plant Engineering Supe.rintendent report to the Assistant Plant Manager - Technical Services. The Plant Technical Services unit includes the Plant Engineering Group which provides day-to-day engineering and technical support for plant operation and maintenance activities. The Nuclear Operations Administration Group's functions include security, materials management, and plant records management.
The qualification requirements of the Nuclear Plant Operations staff are defined in Table 11.2-1 and FSAR Chapter 13.
17.2.1.4.1.1 Plant Operations Review Committee The PORC is established to ensure onsite review and evaluation of plant operation, maintenance, and test programs. The PORC reports to the Nuclear Plant Operations Manager and advises him on matters related to nuclear safety, including referral of topics requiring review and potential action by the Safety Review Committee. PORC membership and responsibilities are in accordance with the Technical Specifications.
17.2.1.4.2 Nuclear Operations Support & Assessments Manager The Nuclear Operations Support & Assessments Manager, who reports to the Vice President - Nuclear, is responsible for independent safety reviews of plant activities.
The responsibilities of the Nuclear Operations Support & Assessments Manager include:
Managing the process of performing independent safety reviews of plant a.
activities; b.
Reviewing plant system problems and performance; c.
Reviewing operating abnormalities and Licensing Event Reports; d.
Providing technical advice in support of Radiological Environmental Monitoring, ALARA, and Chemistry / Radiochemistry Programs; Reviewing and assessing the safety significance of operating experience; e.
f.
Performing management assessments; and g.
Coordinating input and support to the W3 Availability Program.
17.2.1.4.3 Independent Safety Engineering Group 17.2-6
09/09/87 WSES-FSAR-UNIT-3 The Independent Safety Engineering Group (ISEG) is an organizational unit within the Nuclear Operations Support & Assessment Group.
Its function includes examining plant operating characteristics, NRC issuances, industry advisories, Licensee Event Reports, and other sources of plant design and operating experience which may indicate areaa for improving plant safety. The ISEG makes recommendations for improving plant safety including procedure revisions, equipment modifications, maintenance activities, and operations activities to the Nuclear Operations Support & Assessments Manager and appropriate senior management. The ISEG is responsible for maintaining an overview of plant activities to provide independent verification that these activities are performed correctly and that human errors are reduced as much as practical.
17.2.1.4.4 Nuclear Operations Engineering Manager The Nuclear Operations Engineering Manager, who reports to the Vice President - Nuclear, is responsible for the direction and administration of the Nuclear Operations Engineering Group activities.
The responsibilities of the Nuclear Operations Engineering Manager include:
a.
Managing the design process, including initiation, implementation documentation, verification and acceptance of design changes, and coordinating this activity with plant staff; b.
Coordinating plant design changes; c.
Coordinating procurement of equipment, parts, materials, and supplies in support of plant operations and design changes; d.
Providing outside contracted engineering sources for selected design changes and managing contracted support for retrofit and maintenance activities; l
Coordinating activities for ISI, ASME Section XI, and Equipment e.
Qualification; and f.
providing configuration control of drawings and documents describing plant designs.
17.2.1.4.5 Nuclear Operations Construction Manager The Nuclear Operations Construction Manager, who reports to the Vice President -
Nuclear, is responsible f.or managing construction activities at Waterford-3.
~
The responsibilities of the Nuclear Operations Construction Manager include:
Reviewing and processing requests and managing contracted services for a.
plant repair, modification, and construction; b.
Reviewing completed modification and construction work prior to acceptance to ensure completion; 17.2-7
09/09/87 WSES-FSAR-UNIT-3 c.
Coordinating construction tasks involved with outages and retrofitting; and d.
Administering field engineering,. field supervision, and facilities coordination.
17.2.1.4.6 Nuclear Operations Training Manager The Nuclear Operations Training Manager, who reports to the Vice President-Nuclear.is responsible for the direction and administration of the Nuclear Operations Training Group activities.
The responsibilities of the Nuclear Operations Training Manager include:
Training for Operators and Shift Technical Advisors; a.
b.
Providing technical training; c.
Maintaining training records and library; d.
Providing instructor certifications; e.
Providing General Employee Training; and f.
Providing training for Nuclear Operations Engineering and Quality personnel.
l 17.2.1.5 Nuclear Services Manager The Nuclear Services Group is responsible for providing support to the Senior Vice President - Nuclear Operations and interfacing with Nuclear Services Group consultants and other organizations. The Nuclear Services Group includes the following organizational units: Nuclear Safety & Regulatory Affairs, Nuclear Emergency Planning & Records, Nuclear Technical Support and Nuclear Cost Control.
l The responsibilities of the Nuclear Services Group include:
a.
Coordinating and reviewing responses to Federal, State, and local regulatory agencies, including license related matters, as assigned to Nuclear Services; b.
Managing the preparation of SARUS updates and responses to IE bulletins, NRC orders, circulars. IE Inspection reports, generic letters, and information notices; c.
Managing the Nuclear Operations Department's Commitment Management System; d.
Administering environmental licensing activitics; Managing the preparation and approval of the Waterford-3 Emergency Plan and e.
implementing procedures; f.
Reviewing licensing aspects of plant systems, programs, and procedures; 17.2-8 i
09/09/87 WSES-FSAR-UNIT-3 L
Coordinating the preparation of emergency drill scenarios and performance g.
of-practice drills;
.h.
Providing SRC support; i.
Coordinating the activities of Middle South Services that relate to nuclear fuel conversion, enrichment, fabrication processes, and in-core fuel management; j.
Supporting low level radwaste and coordinating fuel management activities; k.
Maintaining the Nuclear Operations Management Manual; 1.
Managing cost control measures, capital expenditures, and operations and maintenance budgets; Providing support for records management including execution of the
- m. '
document control and records storage program; and r
Providing NUMARC/ Nuclear Management Committee support.
n.
17.2.1.6 Nuclear Purchasing and Contract Administration Manager The Nuclear Purchasing and Contract Administration Manager, who functionally reports to the Vice President - Nuclear, supports all of Nuclear Operations and is responsible fort Coordinating the selection of vendors and contractors; a.
b.
Purchasing and expediting receipt of equipment, parts, materials, and supplies in support of plant operations and design changes; Developing and administering engineering, construction, maintenance and c.
technical service contracts; d.
Providing outside contracted engineering sources for selected design changes; e.
Administering contracted support for retrofit and maintenance activities; and f.
Resolving claims, providing litigation support and other legal interface.
17.2.1.7 Middle South Utilities System Services. Incorporated (MSUSSI)
LP&L delegates to MSUSSI the authority to perform those quality assurance functions necessary to ensure that the nuclear fuel is designed and fabricated in accordance with regulatory requirements and accepted codes, standards, and specifications. The MSUSSI Quality Assurance organization monitors the design and fabrication of the fuel through a program of audits of the fuel fabricator, including both design review audits and fuel fabrication audits. MSUSSI also conducts audits of component suppliers as deemed necessary to ensure the quality of the fuel.
17.2-9
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09/09/87 l
WSES-FSAR-UNIT-3 Formal audit reports are issued by MSUSSI to document their audit activities and to identify nonccnformances or other items requiring action by the fuel fabricator. Resolution of nonconformances or other items requiring action is verified by MSUSSI and documented in follow-up reports. The LP&L Nuclear Quality Assurance Manager is on distribution for all audit and follow-up audit j
reports pertaining to LP&L and Waterford-3.
l
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MSOSSI is utilized to complement and supplement LP&L teams during Quality Assurance audits and surveys. The MSUSSI Quality Assurance organization interfaces with and reports through the LP&L Nuclear Quality Assurance Manager for the above activities. The MSUSSI Quality Assurance Section conducts internal audits of those safety-related activities associated with Waterford-3 that are performed by other MSUSSI groups.
MSUSSI also provides support to LP&L in the areas of engineering, nuclear engineering, fuel management, nondestructive examination (NDE) activities, and training.
17.2.1.8 Suppliers / Contractors Suppliers / contractors of safety-related material, equipment, spare parts, and/or services are, as appropriate, required by the procurement documents to have a quality program.
In such cases, a line of communication exists between the supplier / contractor and the LP&L Quality Assurance organization. The overall responsibility for quality at Waterford-3 remains with LP&L at all times.
The quality functions performed by suppliers of safety-related items and services depend upon the nature of the activities, services, equipment, materials, systems and/or components provided.
Supplier Quality Program requirements are prescribed through procurement documents to provide controls and documentation in accordance with the scope of activities involved and their i
importance to safety.
The quality affecting procedural controls of principal contractors are provided for review for LP&L's acceptance prior to initiation of activities affected by the program.
17.2-10
09/09/87 WSES-FSAR-UNIT-3 17.2.2' QUALITY ASSURANCE PROGRAM 17.2.2.1'
' General-LP&L's objective is to operate, maintain and modify the Waterford-3 nuclear plant attaining the degree of functional integrity and reliability necessary to avoid ~ undue' risk'to the health and safety of employees and the general public.
.It is LP6L's policy that the quality assurance program for the operations phase complies with the requirements of 10CFR50, Appendix B and related regulatory guidance..
This section describes LP&L's Quality Assurance Program for Waterford-3, which assures that. safety-related activities are performed 11n a. controlled manner and documented to. provide objective evidence of compliance with NRC regulations and guidance. This program takes into account the need for trained personnel, approved procedures, special controls, processes, test equipment, tools, and skills to attain the required quality, and.the need for verification of quality by inspection, surveillance, testing, and audit.
Quality assurance policies and implementing procedures are developed by LP&L to assure that the Quality Assurance Program complies with the requirements of 10CFR50, Appendix B.
These documents are applicable throughout the operational phase.
Implementation of the Quality Assurance Program is mandatory.
Additionally, when directed, contractors / suppliers of safety-celated equipment and services are required to demonstrate compliance with the provisions of LP&L's Quality Assurance Program.
The Quality Assurance Program is implemented by those organizations whose activities af fect quality at Waterford-3 (Figure 17.2-1). Personnel within these groups and departments use approved procedures that control safety-related activities. These approved procedures incorporate the requirements of Regulatory Guides and NRC endorsed industry codes and standards to which LP&L has specifically committed.
Table 17.2-1 identifies the NRC regulatory guides and industry standards on which the LP&L quality program is based and contains appropriate clarification.
Indoctrination and training programs are provided to train personnel in the requirements of the Quality Assurance Program.
17.2.2.2 Responsibilities LP&L senior managers are responsible for the implementation of quality assurance policies as applicable to their areas of responsibility. They review and concur with such policies which are prepared by the Nuclear Quality Assurance Manager and are approved by the Senior Vice President - Nuclear Operations.
Additionally, senior managers are responsible for the conduct of training to assure that Nuclear Operations Department personnel are properly trained to perform activities in a safe and effective manner.
17.2-11
09/09/87 WSES-FSAR-UNIT-3 The Nuclear Quality Assurance Manager is responsible for reviewing and auditing the implementation of the Quality Assurance Program. The Quality Assurance Group, as requested by management, assists with the development and conduct of quality assurance indoctrination and training.
The Nuclear Quality Assurance Manager reviews and concurs with the content of quality assurance indoctrination and training programs.
Responsibilities for review, approval, and control of quality program documentation are defined in Table 17.2-2.
17.2.2.3 Hierarchy of Quality Assurance Program Documents Responsibilities of individuals and organizations participating in safety-related activities are defined in Quality Assurance Program documentation. The hierarchy of documents comprising LP&L's Quality Assurance Program as shown in Figure 17.2-3, Nuclear Operations Document Hierarchy, is discussed below:
a.
The first tier of documents consists of those government regulations, industry codes and standards, LP&L policies and directives, commitments, specifications, and criteria necessary to operate and maintain Waterford-3.
An integral part of this tier is Chapter 17.2 of the Waterford-3 FSAR; b.
The second tier of Quality Assurance Program documentation consists of policies which define responsibilities, interfaces, and authorities of LP&L personnel, contractors, vendors, and suppliers. The quality policies define LP&L's program for implementing 10CFR50, Appendix B, regulatory guides and endorsed industry standards which are listed in Table 17.2-1.
Documentation at this level in the hierarchy of documents is concurred with by senior management and approved by the Senior Vice President - Nuclear Operations; and The third tier of documentation is departmental /section level procedures c.
and instructions which implement quality program policies.
Selected elements of this third tier documentation are described in the following paragraphs. These documents:
1)
Implement quality program policies to provide control of safety-related activities to a degree consistent with their importance to safety;
- 2) Provide for a clear understanding of Nuclear Operations methodology; and
- 3) Delineate responsibilities and authorities of Nuclear Operations Department personnel.
17.2.2.4 Identification of Safety-Related Structures, Systems and Components The Quality Assurance Program provides control of activities affecting the 17.2-12
09/09/87 WSES-FSAR-UNIT-3
(
l quality of structures, systems, and components including spare and replacement l
parts to an extent commensurate with their safety significance.
i FSAR Table 3.2-1 provides the identification of safety-related structures, systems, and components subject to 10CFR50, Appendix B, quality assurance program requirements. Procedures provide guidance for determining the classification of safety-related items in accordance with applicable codes, standards, and regulations.
LP&L may use the term quality-related interchangeably with safety-related in implementing procedures, instructions and other documents. Quality-related is defined to include as a minimum safety-related activities and may also include additional activities prescribed at the option of LP&L Management.
17.2.2.5 Resolution of Disputes Disputes involving quality, arising from a difference of opinion between the Quality Assurance Group and other Nuclear Operations groups are normally resolved through the respective managers.
If a satisfactory resolution is not achieved, the Nuclear Quality Assurance Manager resolves dif ferences with the Vice President - Nuclear, if appropriate, or the Senior Vice President - Nuclear Operations.
Disputes involving quality arising from a difference between the Quality Assurance Group and other LP&L organizations external to the Nuclear Operations Department or contractors are normally resolved via direct interaction between managers involved.
If a satisfactory resolution cannot be reached, disputes are resolved through higher levels of management.
17.2.2.6 Indoctrination, Training, and Qualification Programs Indoctrination, training, and qualification programs are provided for Nuclear Operations Department personnel performing safety-related activities. These programs are designed to ensure that personnel are knowledgeable of the quality assurance procedures / requirements and have the necessary proficiency to implement the requirements. The scope, objective, and method of implementing the indoctrination and training programs are documented in approved procedures.
Indoctrination, training, and qualification programs require that:
a.
Personnel performing activities that af fect quality are instructed on the purpose, scope, and implementation of safety-related manuals, instructions, and procedures; b.
Personnel performing activities that affect quality are trained and qualified in the principles, techniques, and requirements of the activity being performed; c.
Proficiency of personnel performing or verifying activities affecting quality requiring certification is maintained by retraining, re-examining, and/or decertifying on a periodic basis; 17.2-13
09/09/87 WSES-FSAR-UNIT-3 l
d.
Proficiency testing is utilized to determine qualifications when education, experience, and training cannot be verified by other means; and Documentation concerning training and qualification programs is maintained, e.
which describes the objective, content, attendance, test results, functions personnel are qualified to perform, and the criteria used to qualify i
personnel.
The training program for Waterford-3 personnel is further described in FSAR Chapter 13.
17.2.2.7 Controlled Conditions for Quality Affecting Activities i
l Quality affecting activities are accomplished under controlled conditions by personnel with the necessary skills to attain the required quality. Activities I
affecting quality are performed with appropriate equipment, under suitable environmental conditions and with the assurance that prerequisites for the activity have been satisfied. As appropriate, inspections and tests are performed to assure conformance with design or operational requirements.
17.2.2.8 Management Review of the Quality Assurance Program LP&L management regularly reviews the scope, status, adequacy, and ccmpliance of the Quality Assurance Program to 10CFR50, Appendix B.
Assessment methods include:
a, Frequent management review of the Quality Assurance Program status through meetings and/or assessments.
b.
Performance of an annual preplanned and documented assessment by an organization external to the Nuclear Operations department.
Corrective action associated with assessments is identified and tracked.
17.2.2.9 Maintenance of Quality Assurance Program Amendments to the FSAR are issued as necessary to support effective implementation of the Quality Assurance Program. The NRC is notified annually of any changes to the Quality Assurance Program description that do not reduce the commitments previously accepted by the NRC.
If a change is contemplated l
which would reduce LP&L's commitments to 10CFR50, Appendix B or those contained in the approved Quality Assurance Program description, the proposed change is submitted to the NRC for approval prior to implementation.
l LP&L requires principal contractors to notify LP&L of changes to their quality assurance program description which reduce previously accepted commitments.
Significant changes to such program descriptions are reported, as applicable, to i
the NRC in writing.
In addition, LP&L requires principal contractors to provide notification of changes which reduce the commitments to a subcontractor's quality assurance program description which have the effect of changing the quality program of principal contractors or LP&L, 17.2-14
09/09/87 WSES-FSAR-UNIT-3 17.2.2.10 Fire Protection Program The Fire Protection Quality Assurance Program is defined in a corporate level l
quality policy. It provides for the controls defined in Branch Technical Position CMEB 9.5.1, " Guidelines for Fire Protection for Nuclear Power Plants."
The Nuclear Quality Assurance Manager is responsible for preparation and maintenance of the Fire Protection Quality Assurance Program and for verifying the effectiveness of the program through audits.
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09/09/87 WSES-FSAR-UNIT-3 17.2.3 DESIGN CONTROL 17.2.3.1 General The Quality Assurance Program defines the requirements for design control of plant safety-related structures, systems and compcnents and modifications thereto. Applicable design inputs are appropriately specified on a timely basis and correctly translated into design documents. Design interfaces are identified and controlled. Design adequacy is verified by persons other than those who performed the original design. Design changes, including field changes, are governed by control measures commensurate with those applied to the original design.
Procedures assure that design activities associated with the preparation and review of design and design change documents for Waterford-3 are executed in a planned, controlled, and orderly manner.
Errors and deficiencies in approved design documents, including design methods that could adversely affect structures, systems, and components are documented and action is taken to assure that all errors and deficiencies are corrected.
l 17.2.3.2 Responsibilities The Nuclear Operations Engineering Manager is responsible for design activities during the operational phase. His responsibilities include, but are not limited to, preparing, reviewing, approving, and verifying design documents such as design input and criteria, design drawings, design analyses, computer codes, specifications and design procedures and completed design change packages. He may delegate these functions to other organizations; however, he is responsible for the approval of the final design.
The Nuclear Plant Operations Manager has final approval authority for design changes prior to implementation. He assures that plant personnel are made aware of design changes or modifications which may affect the performance of their duties.
The Nuclear Quality Assurance Manager has responsibility for review of design change packages to ensure inclusion of quality assurance requirements and to assure that the documents are prepared, reviewed, and approved in accordance with LP&L procedures.
17.2.3.3 Design Process The scope of the design control program includes design activities associated with the preparation and review of design documents including the correct translation of applicable regulatory requirements and design bases into design, procurement and procedural documents.
Included in the scope are such activities as field design engineering; physics, seismic, stress, thermal, hydraulic, f
radiation, and the FSAR accident analyses; associated computer programs; compatibility of materials; accessibility for inservice inspection, identification of inspection and test criteria, maintenance and repair; and quality standards.
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WSES-FSAR-UNIT-3 Design activities are prescribed and documented on a timely basis and to the level of detail necessary to permit the design process to be carried out in a correct manner, and to perm 1t verification that the design meets requirements.
I Design documents adequate to support facility operation are prepared.
f Appropriate quality standards are identified and documented, and their selection J
reviewed and approved.
Changes from specified quality standards, including the reasons for the changes are identified, documented, approved, and controlled. Design methods, materials, parts, equipment, and processes that are essential to the function of the structure, system, or component are selected and reviewed for suitability of application.
Procedures are provided for performing a documented check to verify the dimensional accuracy and completeness of design drawings and specifications.
17.2.3.4 Interface Control Design interfaces are identified, controlled and coordinated among the participating organizations.
Interface controls include the assignment of responsibility and the establishment of procedures among participating design organizations for the review, approval, release, distribution, and revision of l
documents involving design interfaces.
Design information transmitted across interfaces is documented and controlled.
Transmittals identify the status of the design information or document provided and, where necessary, identify incomplete items which require further evaluation, review, or approval.
17.2.3.5 Design Analysis Design analyses are planned, controlled, and documented. Design analysis documents are legible and in a form suitable for reproduction, filing, and retrieval. They are sufficiently detailed as to purpose, method, assumptions, design input, references, and units such that a person technically qualified in the subject can review and understand the analyses and verify the adequacy of the results without recourse to the originator.
Calculations are identifiable by subject (including structure, system, or component to which the calculation applies), originator, reviewer, and date, or by other data such that the calculations are retrievable.
Computer codes may be utilized for design analysis without individual
{
verification of the program for each application provided:
a.
The computer program has been verified to show that it produces correct solutions for the encoded mathematical model within defined limits for each parameter employed; and b.
The encoded mathematical model has been shewn to produce a valid solution to the physical problem associated with the particular application.
17.2-17
09/09/87 WSES-FSAR-UNIT-3 Computer programs are controlled to assure that changes are documented and approved by authorized personnel. Where changes to previously verified computer programs are made, verification is required for the change, including evaluation j'
of the effects of these changes on a. or b. above.
17.2.3.6 Design Verification Design verification methods include, but are not limited to design review, l
alternate calculations, and qualification testing. These methods are 1
accomplished in accordance with approved procedures.
)
The extent of the design verification required is a function of the importance i
to safety of the item under consideration, the complexity of the design, the degree of standardization, the state of the art, and the similarity with previously proven designs.
Where changos to previously verified designs have been made, design verification is required for the changes. This verification also evaluates the effects of thore changes on the overall design and on any design analyses upon which the f
design is based.
Design reviews provide assurance that the final design is correct and satisfac-tory. Where applicable, the following items are addressed to assure that:
The design inputs were correctly selected; a.
b.
The assumptions necessary to perform the design activity are adequately described and reasonable; c.
An appropriate design method was used; d.
The design inputs were correctly incorporated into the design; e.
The design output reasonably compares to design inputs; and f.
The necessary design input and verification requirements for interfacing organizations were specified in the design documents or in supporting procedures or instructions.
Alternate calculations, or analyses are made with alternate methods to verify correctness of the original calculations or analyses.
The appropriateness of assumptions, input data used, and the computer program or other calculative methods used is also reviewed.
If the design verification method is by test alone, the following provisions are included:
Procedures provide criteria that specify when verification should be by a.
l test; b.
Prototype, component, or feature testing is performed as early as possible prior to installation of plant equipment, or prior to the point when the I
installation would become irreversible; and 17.2-18
09/09/87 WSES-FSAR-UNIT-3 Verification by test is performed under conditions that simulate the most c.
adverse conditions as determined by analysis.
Design verification will be complete prior to relying upon the structure, system, or component to perform its quality related function. Where design adequacy is'to be verified by qualification tests, the tests are identified.
The test configuration is clearly defined and documented. Operating modes and environmental conditions in which the item must perform satisfactorily are considered in determining the most adverse conditions. Where the test is intended to verify only specific design features, the other features of the design are verified by other means. Test results are documented and evaluated by the responsible design organization to assure that test requirements have been met.
Regardless of their title, individuals performing design verification shall not:
Have immediate supervisory responsibility for the individual performing the a.
design except as provided for below; b.
Have specified a singular design approach; c.
Have ruled out certain design considerations; or d.
Have established the design inputs for particular design aspects being verified.
In exceptional circumstances, the designer's immediate supervisor may perform the verification if the following conditions apply:
The supervisor is the only technically qualified individual; and a.
b.
The need is individually documented and approved in advance by the supervisor's management.
Quality Assurance audits take into account the frequency and effectiveness of using supervisors as verifiers to guard against abuse.
I 17.2.3.7 Change Control Changes to final designs, field changes, modifications to operating facilities, and nonconforming items requiring design supported resolution are justified and subjected to design control measures commensurate with those applied to the original design. These measures include assurance that the design analyses for the structure, system, or component are still valid.
Changes are approved by the same affected groups or organizations which reviewed and approved the i
original design documents except where an organization which originally was l
responsible for approving a particular design document is no longer responsible.
In this case, the Nuclear Operations Engineering Manager or his designee designates a new responsible organization which may be an LP&L engineering organization. The designated organization shall have demonstrated cotapetence in the specific design area of interest and have an adequate understanding of the requirements and intent of the original design.
Where a significant design change is necessary because of an incorrect design, the design process and verification procedure are reviewed and modified as necessary.
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09/09/87 WSES-FSAR-UNIT-3 17.2.3.8 Maintenance and Modification Maintenance or modifications of safety-related structures, systems, or components are performed in a manner to ensure quality at least equivalent to that specified in original design bases and requirements, materials specifications and inspection requirements, or any reviewed and approved revisions thereto or an alternate design with justifiable bases and l
requirements. A suitable level of confidence in structures, systems, or components on which maintenance or modifications have been performed is attained by appropriate inspection and performance testing.
Maintenance or modifications of safety-related equipment are preplanned and performed in accordance with written procedures, documented instructions or drawings appropriate to the circumstances which conform to applicable codes, standards, specifications, and criteria.
Means for assuring quality of maintenance and modification activities (for example, inspections, measurements, tests, welding, heat treatment, cleaning, nondestructive examination and worker qualifications in accordance with l
applicable codes and standards) and measures to document the performance thereof I
are established.
Such documentation is retained as quality records.
Written safety evaluations of design changes are prepared as required by l
The preventive maintenance program including procedures as appropriate for safety-related structures, systems and components is maintained and prescribes the frequency and type of maintenance to be performed. The program is revised and updated as required.
l l
The causes of malfunctions are promptly determined, evaluated, recorded, and l
disseminated to appropriate plant staff personnel. Experience with malfunctioning equipment and similar components is reviewed and evaluated to determine whether a replacement component of the same type can be expected to perform its function reliably, if evidence indicates that common components in safety-related systems have performed unsatisfactorily, corrective measures are planned prior to replacement or repair of all such components. Replacement components are tested or are of a design for which experience indicates a high probability of satisfactory performance. Consideration is given to phased replacement to permit inservice performance evaluation of the new component thereby minimizing the possibility of a hidden deficiency producing a systematic failure. An augmented testing and inspection program is implemented following a large scale component replacement (or repair) until such time as a suitable level of performance has been demonstrated.
Maintenance is scheduled and planned so as not to compromise the safety of the plant. Planning considers the possible safety consequences of concurrent or sequential maintenance, testing or operating activities. Equipment required to be operable for the prevailing mode is available, and maintenance is performed in a manner such that license limits are not violated. Planning for maintenance includes evaluation of the use of special processes, equipment and materials in performance of the task, including assessment of potential hazards to personnel and equipment.
17.2-20 1
09/09/87 WSES-FSAR-UNIT-3 17.2.3.9 Design Documentation and Records Design documentation and records, which provide evidence that the design and design verification processes were performed in accordance with Quality Program requirements are collected, stored, and maintained in accordance with documented procedures.
The documentation includes final design documents, such as drawings and specifications, and revisions thereto and documentation which identifies the important steps, including sources of design inputs that support the final design.
17.2.4 PROCUREMENT DOCUMENT CONTROL 17.2.4.1 General Applicable design bases and other requirements necessary to assure adequate quality are included or referenced in documents for procurement of items and services required to modify, maintain, repair, test, inspect, or operate Waterford-3. To the extent necessary, procurement documents require suppliers to have a quality assurance program consistent with applicable codes, standards, and other requirements.
17.2.4.2 Responsibilities The Vice President-Nuclear is responsible for ensuring that appropriate procedures are developed and implemented for activities related to the preparation, review, approval, and control of requisitions and for performing various functions to support procurement of safety-related material, equipment, spare parts, and services.
Certain procurement functions including supplier selection (subject to Quality Assurance concurrence), release of bid requests, coordination and control of bid evaluations, and preparation and issuance of contracts and purchase / contract orders are delegated to the Nuclear Purchasing and Contract Administration Manager.
The Nuclear Operations Engineering Manager has overall responsibility for ensuring that appropriate procedures are developed and implemented for the activities related to the preparation, review, approval, and control of requiettions; procurement planning; and assistance in supplier selection.
The Technical Support Manager, who reports to the Nuclear Operations Engineering Manager, is responsible for coordinating all activities related to the preparation review, approval, and tracking of purchase / contract requisitions transmitted to the Nuclear Purchasing and Contract Administration Manager and assisting in supplier selection.
The Nuclear Quality Assurance Manager is responsible for the review of procurement documents and changes thereto to verify inclusion of appropriate quality program requirements.
17.2-21
09/09/87 WSES-FSAR-UNIT-3 The Nuclear Quality Assurance Manager is responsible for the performance of pre-award surveys, audits, and/or reviews of supplier quality assurance programs in order to qualify and to maintain their qualification as a supplier of safety-related items or services. The Nuclear Quality Assurance Manager establishes and maintains the Qualified Suppliers List (QSL) and is also responsible for scheduling and performing source surveillance of items when necessary to ensure product acceptability.
The originator of procurement documents is responsible for applying appropriate technical and quality requirements.
17.2.4.3 Content of Procurement Documents Procurement documents include and require inclusion by the supplier in lower tier documents, provisions for the following, as deemed necessary by LP&L:
Scope of Work - A definition of the scope of work to be performed by the a.
supplier; b.
Technical Requirements - Where necessary, technical requirements are specified by reference to specific drawings, specifications, codes, standards, regulations, procedures, or instructions, including revisions thereto that describe the items or services to be furnished. The procurement documents provide for identification of test, inspection, and acceptance requirements for monitoring and evaluating the supplier's performance; Quality Assurance Program Requirements - Procurement documents require that c.
the supplier have a documented and acceptable quality assurance program that implements applicable requirements of LP&L's Quality Assurance Program. Changes to the quality assurance programs of contractors which reduce previously accepted commitments are required to be submitted for review by LP&L Quality Assurance. The extent of the program required depends upon the type and use of the item or service being procured; d.
Right of Access - Procurement documents provide for access to the supplier's facilities and records for inspection, surveillance, or audit by the purchaser, his designated representative, and/or other parties authorized by the purchaser; Documentation Requirements - Procurement documents at all tiers identify e.
the documentation required to be submitted for information, review, or approval by LP&L. The time of submittal is also established.
When LP&L requires the supplier to maintain specific quality assurance records, the retention times and disposition requirements are prescribed; f.
Defects and noncompliance - Safety-related procurement documents impose 10CFR21 and include requirements for reporting and approving the disposition of nonconformances; and g.
Spare and Replacement Parts - Procurement documents require the identifi-cation of appropriate spare and replacement parts or assemblies and the appropriate delineation of the technical and quality assurance related data required for ordering these parts or assemblies.
17.2-22
09/09/87 WSES-FSAR-UNIT-3 17.2.4.4 Procurement Document Review A review of the procurement documents and changes thereto is made to assure that documents transmitted to the prospective supplier (s) include appropriate provisions to assure that items or services will meet the specified requirements. Reviews are performed and documented prior to issuance of the purchase / contract order.
Changes made as a result of the bid evaluations or pre-award negotiations are incorporated into the procurement documents.
The review of such changes and their effect is completed prior to contract award. This review includes the following considerations:
Appropriate requirements specified in 17.2.4.3; a.
b.
Determination of any additional or modified design criteria; and Analysis of exceptions or changes requested or specified by the supplier c.
and determination of the effects such changes may have on the intent of the procurement documents or quality of the item or service to be furnished.
17.2.4.5 Procurement Document Changes Procurement document changes are subject to the same degree :c control as i
utilized in the preparation of the original documents.
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09/09/87 WSES-FSAR-UNIT-3 17.2.5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS 17.2.5.1 General Activities affecting quality are prescribed by and performed in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances. These documents include or reference appropriate quantitative or qualitative acceptance criteria for determing that prescribed activities have been satisfactorily accomplished.
Activities affecting quality, such as designing, procuring, installing, testing, inspecting, operating, maintaining, and modifying are accomplished in accordance with these documents. Quality Assurance Program implementing procedures define requirements for developing and controlling instructions and procedures for safety-related activities.
17.2.5.2 Responsibilities Nuclear Operations management is responsible for developing, maintaining and implementing instructions, procedures, and drawings, as appropriate, to control the quality affecting activities.
The Quality Assurance Group reviews and concurs with selected instructions, procedures, and drawings with regard to quality assurance related aspects.
PORC reviews and recommends approval to the Nuclear Plant Operations Manager of instructions and procedures for safety-related activities for plant operation in accordance with the Waterford-3 Technical Specifications.
17.2.5.3 Preparation of Instructions, Procedures, and Drawings l
Procedures provide for a controlled method for preparing, reviewing, changing, j
and approving instructions and procedures.
Instructions, procedures, and l
drawings, prescribing safety-related activities are prepared by the LP&L organizational unit engaged in that activity, by external consultants or by other LP&L groups as assigned. Appropriate department heads are responsible for providing instructions, procedures, and drawings as required for the administration, operation, maintenance, and modification of Waterford-3.
l 17.2.5.4 Contents of Instructions, Procedures, and Drawings j
i Instructions, procedures, and drawings controlling operational activities that affect safety-related functions identify and control special equipment and conditions required to perform the activity, provide applicable quantitative and qualitative acceptance criteria, and include provisions for documenting that cctivities were accomplished in accordance with these instructions.
When appropriate, instructions and procedures include checklists of the elements of an activity to be observed or measured.
1 17.2-24
09/09/87 WSES-FSAR-UNIT-3 17.2.5.5 Review and Approval Instructions, procedures, and drawings controlling safety-related activities are reviewed by the individual in charge of the organization engaged in that activity or designee and approved by management.
Whenever instructions, procedures, or drawings of one organization affects or involves the activities of another organization, the originating organization is responsible for ensuring that the affected organization reviews and concurs with i
the document content.
instructions, procedures and drawings that are prepared by the Nuclear Plant Operations Staff are reviewed in accordance with approved procedures to determine:
a.
That the need for inspection, identification of inspection personnel, and documentation of inspection results have been properly specified;-
b.
That the necessary inspection requirements, methods, and acceptance criteria have been identified;
(
That hold points are clearly identified and acceptance criteria provided; c.
and d.
That the instruction, procedure, or drawing is in compliance with upper tier Quality Assurance Program requirements.
Prepared procedures, checklists or guidelines are used in conducting and documenting reviews of instructions, procedures, and drawings.
Instructions, procedures and drawings are not approved for implementation until comments from the above reviews have been resolved.
Control of these documents is in accordance with the controls described in 17.2.6.
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WSES-FSAR-UNIT-3' 17.2.6
. DOCUMENT CONTROL 17.2.6.1
- General, l.
'The preparation, issue, and change of documents that specify quality requirements are controlled to assure that correct documents are being employed.
Such' documents, including changes thereto, are reviewed for adequacy and approved for release by authorized personnel.
Changes to documents-are reviewed and approved by the same organizations that performed the original review and approval or as designated by management.
Documents prescribing activities'affecting quality are distributed to and used at the location where the prescribed activity.is performed.
Obsolete or superseded documents are removed from work areas and replaced by applicable tevisions in a timely manner.
17.2.6.2 Responsibilities Nuclear Operations department managers are responsible for implementation of l
quality assurance requirements and related implementing procedures that outline the requirements for the receipt, collection, review, distribution and control of documents within their respective organizations.
The Nuclear Services Manager is responsible for the operation of the centralized document control center which provides for the collection, receipt, review, processing, and distribution of documents required under the Quality Assurance Program.
Departments or individuals generating documents or using controlled documents are responsible for the following:
Ensuring that documents have been properly received and approved prior to a.
use in performing safety-related work; b.
Transmitting' documents and revisions / changes thereto to Document Control to ensure controlled distribution; c.
Establishing the Standard Distribution List for documents originated within that department; d.
Notifying Document Control of needed changes to the Standard Distribution List for a given document (s);
Acknowledging receipt of controlled documents from Document Control; and e.
f.
Notifying Document Control of lost or destroyed documents.
The Nuclear Quality Assurance Manager audits document control measures including the status of as-built drawings.
I 17.2-26
09/09/87 WSES-FSAR-UNIT-3 17.2.6.3 Document Preparation, Review, Approval, and Issuance The document control system provides for:
The identification of documents to be controlled by master lists or a.
equivalent means and their specified distribution; b.
The identification and assignment of responsibility for preparing, reviewing, approving, and issuing documents; and The review of documents for adequacy, completeness, and correctness prior c.
to approval and issuance.
17.2.6.4 Document Changes Changes to documents are reviewed and approved by the same organizations that performed the original review and approval unless other organizations are specifically designated. The reviewing organization has access to pertinent background data or information upon which to base their approval.
Minor changes to documents, such as inconsequential editorial corrections, do not require that the revised documents receive the same review and approval as the original documents. To avoid a possible omission of a required review, the type of minor changes that do not require such a review and approval and the persons who can authorize such a decision is delineated in procedures. This provision does not apply to those procedures required by the Technical Specifications.
17.2.6.5 Types of Controlled Documents Procedures are established for review, approval, issue, change and use of documents in the following categories:
Design documents (e.g., calculations, drawings, specifications, analyses) a.
including documents related to computer codes; b.
As-built drawings, procedures, and related documents; c.
Instructions and procedures for activities such as fabrication, installation, inspection, test, and station maintenance, modification, and l
operation; e.
Procedures that implement the quality assurance program, f.
Final Safety Analysis Reports; g.
Reports of nonconformance; I
17.2-27
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Technical Specifications; and i.
Documentation which implements the quality assurance policies.
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17.0.6.6 As-built Drawingn,.
As-built drawings are stored in a. controlled facility. Copies of those drawingr7 are furnished to the Nuclear Fladt Operations staf f for plant operaticas end # }r,
maintenance activities. The Nuclear Operations Engineering Group is responsible f
for the revision of master drawings to reflect design changes.
i; The Nuclear Operations Engineering Group issues d.esign change ddedments whichdelineatethedrawingsaffretedbyproposedmodificationsandissuns{
as-built documentation. The Nuclear Plant Operations Manager implements 'and
/
maintains administrative controls which assure that as-built drawings a'c2 utilized for plant operation and maintenance. The Quality Assurance Group audits the status of as-built drawings.
Field drawings and sketches may be prepared by plant personnel to clarify or provide additional details for operation, maintenance, or testing. These l
documents are controlled in accordance with written instructions which specify requireraents for identifying, reviewing, c7pyoving, and filing. They are reviewed for accuracy by at least one qu111ried person other than the originator..They are revdewed and approved by the originating group supervisor before issuance, Revisions are handled in the came manner as the original issue.
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09/09/87 WSES-FSAR-UNIT-3 17.2.7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES 4
17.2.7.1 General 4 j The procurement of items and services are controlled to assure conformance with specified requirements.
Such control provides for the following as appropriate:
source evaluation and selection, evaluation of objective evidence of quality e
furnished by the supplier, source inspection / surveillance, audit, and j
examination of items or services upon delivery or completion.
i Procurement control wasures are applied to procurement of those materials and components includin,, uafety-related consumables and spare and replacement parts necessary for plant operation, refueling, maintenance and modification.
i 17.2.7.2 Responsibilities The Nuc1 car Purchasing & Contract Administration Manager is responsible f9r
/
performing centralized. purchasing and contracting activities for the Nuclear l
Operations Department including the purchase of equipment and materials and l
contracting for services required to cupport plant operations and modifications'.
The Nuclear Operations Engineering Manager establishes technical and quality requirements and is responsible for procurement to support plant operations and modifications including spare and replacement parts.
The Procurement Engineering Unit of the Technical Support Group is responsible for the technical review of procurement documents. Technical Reviewers are responsible for verifying that an adequate scope of work and applicable quality class, technical design, and documentation requirements are specified in the procurement documents, including the establishment of equipment qualification l
and availability requirements.
The Nuclear Plant Operations Manager is responsible for receipt and storage of equipment and materials procured for use at Waterford-3.
The Nuclear Services Manager is responsible for the procurement of equipment, materials, and services in support of Nuclear Services Group activities.
The
. Nuclear Services Manager establishes technical and quality requirements for procurement initiated by Nuclear Services.
The Nuclear Quality Assurance Manager is responsible for assuring that appropriate quality standards are maintained throughout the Nuclear Operations procurement process and for providing assistance in the procurement of safety-related equipment, materials, and services including conducting pre-award evaluations of suppliers and in-process surveillance, establishing and maintaining the Qualified Suppliers List (QSL), performing the quality review of procurement documents, and conducting receipt and storage inspections of safety-related parts, materials, and components.
17.2-29
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09/09/87 i
WSES-FSAR-UNIT-3 Q
h#
$7.2.7.3 Supplier Selection-h
- i i
i The rulection of suppliers is based on evaluation of their capability to provide L
'itcuis.dr services in accordance with the requirements of the procurement d6ctmen'e s..
i ag4,,
.firpsures for evaluation and selection of procurement sources, and the results-cc.re Cocumented and include one or more of the following:
l a.(,Egal'uStfonoftheSupplier'shistoryofprovidinganidenticalorsimilar vproduct which performs satisf actorily in actual use. The supplier's Jistoryreflects.currentcapability;-
b.
Evaluation of supplier's current quality records supported by documented qualitative and quantitative information which can be objectively (3
evaluated $ or 1
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c.
. Evaluation of supplier's technical and quality capability as determined by a direct evaluation of his facilities and personnel and the irnplementation
-4 of his quality assurance program.
M 17.2.7.4 Supplier Performance Evaluaridn-The extent of verification activities, including planning, is a function of the relative importance,- cor:plexity, and quantity of the item or services procured and the supplier's quality performance. Verification activities are performed i
and documented by qualified personnel assigned to check, inspect, audit, or witness the activities of suppliers in accordance with applicable procedures.
Suppliers' certificates of conformance are periodically evaluated by audits, independent inspections, or tests to assure they are valid and.the results are documented.
Activities performed to verify conformance to requirements of procurement f
documents are recorded.
j 1
Source surveillance and inspections, audits, receiving inspections, I
nonconformances, dispositions, waivers, and corrective actions are documented.
I This documentation is evaluated to determine the supplier's quality assurance l
l-program effectiveness and conformance to his quality assurance program.
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.17.0.7.5' Control of Supplier Generated Documents Supplier generated documents are controlled, handled, and approved in accordance with established methods. Means are implemented to assure that the submittal of these documents is accomplished in accordance with the procurement document j
requireme~nas. These measures provide for the acquisition, processing, and recorded evaluation of, technical, inspection, and test data against acceptance criteria.
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09/09/87 WSES-FSAR-UNIT-3 17.2.7.6 Control of Changes In Items or Services Measures'to control changes in procurement documents generated by LP&L are established, implemented, and documented. The requirement for the supplier t-o control changes and to notify LP&L of such changes are established in the procurement documents.
17.2.7.7 Acceptance Of Item Or Service Prior to offering the item or service for acceptance, LP6L verifies that the item or service being furnished complies with the procurement requirements.
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Where required by code, regulation, or contract requirement, documentary evidence.that items conform to procurement documents is available at Waterford-3. This documentary evidence is available prior to use but not necessarily prior to installation. This allows installation to proceed under specified conditions while.any missing documents are being obtained, but precludes dependence on the item for safety purposes.
Items accepted and released are identified as to their inspection status prior to forwarding them to a controlled storage area or releasing them for installation or further work.
17.2.7.7.1 Methods of Acceptance Methods used to accept an item or related service from a supplier includes:
Supplier Certificate of Conformance, source verification, receiving inspection, or testing at Waterford-3, or a combination thereof.
When a Certificate of Conformance is used, the minimum criteria acceptable to LP&L are specified in the procurement documents.
When source verification is used, it is performed at intervals consistent with the importance and complexity of the item or service, and it is implemented to monitor, witness, or observe activities.
Source verification is implemented in accordance with plans to perform inspections, examinations, or tests at I
predetermined points. Upon acceptance by source verification, documented evidence of acceptance is furnished to the LP&L receiving destination.
When receiving inspection is used, purchased items are inspected as necessary to verify conformance to specified requirements, taking into account source verification and audit activities and the demonstrated quality performance of the supplier. Receiving inspection is performed in accordance with established procedures and inspection instructions, to verify by objective evidence such features as proper configuration; identification; dimensional, physical, and other characteristics; freedom from shipping damage; and cleanness. Receiving inspection is coordinated with review of supplier documentation when procurement documents require such documentation to be furnished prior to receiving
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inspection, j
4 When post-installation testing is used, post-installation test requirements and acceptance documentation are approved by LP&L.
17.2-31
09/09/87 WSES-FSAR-UNIT-3 In certain cases involving procurement of services only, such as third party inspection; engineering and consulting services; and installation, repair, overhaul, or maintenance work, LP&L accepts the service by any or all of the following methods:
a.
Technical verification of data produced; b.
Surveillance and/or audit of the activity; and c.
Review of objective evidence for conformance to the procurement document requirements such as certifications, stress reports, etc.
17.2.7.8 Control of Supplier Nonconformances LP&L and its suppliers establish and document methods for disposition of items and services that do not meet procurement document requirements. Procurement documents contain provisions for:
a.
Evaluation of nonconforming items; b.
Submittal of nonconformance notice to LP&L by supplier as directed by LP&L; Disposition of supplier recommendations; and c.
d.
Verification of implementation of the dispositions and maintenance of records of supplier submitted nonconformances.
17.2.7.9 Procurement of Commercial Items Standard commercial items that are essential to safety-related functions, structures, systems, and components are reviewed and documented for suitability f
of application.
The preparer of the purchase requisition is responsible to clearly identify the commercial item to be procured and list the receiving inspection requirements. Special receipt inspection or source verification requirements are included as necessary to dedicate a coumercial grade item for use in safety-related systems. The item selected must be equal to or better than the original part.
If the part is different from or an addition to the original design and constitutes a plant modification, the Nuclear Operations Engineering Group or Plant Engineering as applicable reviews the material application and verifies its suitability for the intended use.
Any additional source verification, inspection or test requirements are specified in the purchase requisition or attachments as necessary to dedicate the commercial grade item for use in safety-related systems.
17.2-32
V 09/09/87 WSES-FSAR-UNIT-3 17.2.7.10 Procurement of Spare and Replacement Parts Spare and replacement parts for safety-related systems, structures, tnd components are subject to present Quality Assurance Program controls tnd to codes, standards, and technical requirements equivalent to or better than those used for the original equipment.
Methods of product acceptance may be source evaluation of the supplier's Quality Assurance program, source inspection / surveillance, receipt inspection, in place testing or qualification testing by LP&L or a qualified test laboratory. LP&L procedures detail the methodology to control these processes.
17.2.7.11 Records Quality assurance records required by the procurement documents are collected and retained by suppliers of safety-related items or if specified, supplied to LP&L. As a minimum, suppliers are required to furnish the following records to LP&L:
a.
Documentation that identifies the purchased material or equipment and the specified procurement requirements (e.g., codes, standards, specifications) met by the items; and b.
Documentation that identifies procurement requirements which have not been met, together with a description of those nonconformances dispositioned
" accept-as-is" or " repair."
The review, evaluation, and acceptance of the required supplier records furnished to LP&L are described in procedures. Review and acceptance of the records is performed by the Quality Assurance organization.
Records associated with qualification testing (inplace or test laboratory) are considered quality assurance records and are retained by LP&L.
Documentation is available at Waterford-3 prior to use of purchased material, components, or equipment. The documentation is retained in accordance with records management procedures.
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09/09/87 WSES-FSAR-UNIT-3 17.2.8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS AND COMPONENTS 17.2.8.1 General Correct identification of materials, parts, and components is verified and documented prior to release for fabrication, assembling, shipping, and installation.
Identification is maintained either on the items or in documents traceable to the items.
17.2.8.2 Responsibilities The Nuclear Plant Operations Manager has overall responsibility for ensuring the adequacy and implementation of plant procedures which prevent the use of incorrect or defective items through proper identification and control.
The Nuclear Operations Administration Manager ensures the development and implementation of procedural controls necessary to ensure prop.er identification of items in storage, items issued for installation, and the control of items in l
storage which have a limited shelf life.
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The Nuclear Quality Assurance Manager is responsible for:
a.
Ensuring that appropriate identification and control requirements, as applicable, are included in procurement documents; b.
Verifying proper identification of materials, parts and components during receiving inspections; c.
Verifying transfer of required identification or traceability information prior to items being subdivided; and i
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d.
Verifying adherence to applicable procedures for the identification and i
control of materials, parts, and components through performance of periodic inspections.
l 17.2.8.3 Requirements 17.2.8.3.1 Identification and Traceability of Items l
When specified by codes, standards, or specifications that include specific identification or traceability requirements (such as identification or traceability of the item to applicable specification and grade of material; heat, batch, lot, part, or serial number; or specified inspection, test, or other records) procedures provide for such identification and traceability control.
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09/09/87 WSES-FSAR-UNIT-3 17.2.8.3.2 Item Identification Items of production (batch, lot, component, part) are identified from the initial receipt and fabrication of the items up to and including installation and use. This identification relates an item to an applicable design or other pertinent specifying documents.
l 17.2.8.3.3 Physical Identification Physical identification is used to the maximum extent possible. Where physical identification on the item is either impractical or insufficient, physical separation, procedural control, or other appropriate means are employed.
17.2.8.3.4 Markings Identification markings, when used, are applied using materials and methods which provide a clear and legible identification and do not detrimentally affect the function or service life of the item. Markings are transferred to each part of an identified item when subdivided and are not obliterated or hidden by surface treatment or coatings unless other means of identification are substituted.
17.2.8.3.5 Limited Life Items Where specified, items having limited calendar or operating life or cycles are identified and controlled to preclude use of items whose shelf life or operating life has expired. Use of such items beyond the time or cycle limits shall be evaluated and documented justification provided.
17.2.8.3.6 Maintaining Identification of Stored Items Provisions are made for the control of item identification consistent with the planned duration and conditions of storage, such as: (1) provisions for maintenance or replacement of markings and identification records due to damage during handling or aging; (2) protection of identifications on items subject to excessive deterioration due to environmental exposure; and (3) provisions for updating existing plant records.
17.2-35
09/09/87 WSES-FSAR-UNIT-3 17.2.9 CONTROL OF SPECIAL PROCESSES 17.2.9.1 General Special Processes'are those processes that require interim in-process controls in addition to final inspection and include welding, heat treating, and nondestructive testing. They are controlled and accomplished by qualified personnel using qualified procedures in accordance with specified requirements.
17.2.9.2 Responsibilities The Nuclear Plant Operations Manager has overall responsibility for the establishment, approval, and implementation of the special processes program under the control of the plant staff.
The Nuclear Operations Engineering Manager has overall responsibility for establishment, approval and implementation of the special process program in the areas of concrete and grout placement (seismic applications) and reinforcing steel cadwelding (seismic applications).
The Nuclear Quality Assurance Manager is responsible for verifying the adequacy of the Nuclear Plant Operations staff's program for the control'of special processes and for verifying the effectiveness of its implementation.
Additionally, the Nuclear Quality Assurance Manager is responsible for assuring the establishment and implementation of the procedures and programs for nondestructive examination in compliance with applicable industry codes and standards through reviews, audits, surveillance, and inspections.
17.2.9.3 Process Control Special processes controlled under the Nuclear Quality Assurance Program include, but are not limited to the following:
a.
Welding; b.
Heat treating; c.
NDE; d.
Chemical cleaning; c.
Concrete and grout placement (seismic application);
f.
Reinforcing steel cadwelding (seismic application);
g.
Brazing; and h.
Protective coatings.
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WSES-FSAR-UNIT-3 Processes are controlled by instructions, procedures, drawings, checklists,
. travelers,'or other. appropriate means.
These means assure that process parameters are controlled and that specified environmental conditions are maintained.
17.2.9.4 Special Processes Each special process is performed in accordance with appropriate instructions which include or reference procedure, personnel, and equipment qualification requirements.
It is the responsibility of the organization performing the special process to adhere to the approved procedures and processes.
Qualification of personnel, procedures, and equipment comply with specified requirements. Conditions necessary for accomplishment of the process are included An. procedures or instructions. These conditions include proper equipment. controlled parameters of the process, and calibration requirements.
The requirements of applicable codes and standards, including acceptance
- criteria for the process, are specified or referenced in the procedures or instructions.
17.2.9.5' Special Requirements For special processes not covered by existing. codes and standards or where quality requirements specified for an item exceed those of existing codes or standards,.the necessary requirements for qualifications of personnel, procedures, or equipment are specified or referenced in the procedures or instructions.
.17.2.9.6 Records Records are maintained as appropriate for the currently qualified personnel, procedures, processes, and equipment of each special process in active use.
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09/09/87 WSES-FSAR-UNIT-3 17.2.10 INSPECTION 17.2.10.1 General Inspections are planned and executed as required to verify conformance of an item or activity to specified requirements. Characteristics to be inspected and inspection methods to be employed are specified.
Inspection results are documented. Inspection for acceptance is performed by persons other than those who performed or directly supervised the work being inspected.
Inspections (examinations or measurements) or tests of materials or products are performed for each work operation where necessary to assure quality.
If mandatory inspection hold points are required, the specific hold points are indicated in appropriate documents.
At Waterford-3, inspections of maintenance, modification, repair, material receipt and storage activities for safety-related items are conducted in accordance with the requirements contained in applicable codes, standards, and specifications.
17.2.10.2 Responsibilities The inspection program at Waterford-3 is under the direction of the Nuclear Quality Assurance Manager. The Nuclear Quality Assurance Manager is also responsible for the activities of inspection personnel.
In addition, the Nuclear Quality Assurance Manager is responsible for certification of inspection personnel.
The Quality Assurance organization reviews plans and procedures for inspections conducted by Nuclear Plant Operations Maintenance personnel or organizations external to LP&L, such as contractors, prior to the initiation of the activity.
The Quality Assurance organization is responsible for the conduct of receipt inspections and for inspection of materials and components in storage.
17.2.10.3 Inspection Program The LP&L Nuclear Operations Department has three sources of inspection personnel for safety-related operations and maintenance activities at Waterford-3:
a.
Quality Assurance Inspection personnel; b.
Line organization personnel; or c.
Contract personnel.
Inspections are controlled as follows:
a.
Inspections are performed at mandatory hold points in accordance with procedures approved by LP&L; l
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09/09/87 WSES-FSAR-UNIT-3 b.
Inspection results are documented, evaluated and their acceptability determined by responsible personnel in accordance with approved procedures; c.
Inspection procedures, personnel qualifications, and certifications, are concurred with by the Quality Assurance organization; d.
Inspections are performed by qualified individuals other than those who performed or directly supervised the activity being inspected; and e.
Inspection of operating activities may be conducted by second-line supervisory personnel or by other qualified personnel not assigned first-line or supervisory responsibility for the conduct of the work.
Maintenance and modification instructions and work plans are reviewed by Quality Assurance personnel to assure the inclusion of inspection requirements and to verify that inspection methods and criteria are defined.
Receipt and storage inspections are performed by qualified personnel reporting to the Nuclear Quality Assurance Manager. For special inspections such as nuclear fuel receiving, qualified personnel reporting to the Nuclear Plant Operations Manager may be utilized.
Inspections requiring expertise in a particular area, such as inservice inspection, certain nondestructive testing, and containment vessel leak rate tests and inspections may be conducted by offsite LP&L, Middle South Services, or contractor personnel.
In such instances, the inspection activities are conducted under the LP&L Quality Assurance Program or under an LP&L approved contractor program.
17.2.10.4 Inspector Qualifications Each person who verifies conformance of work activities for purposes of acceptance is qualified to perform the assigned inspection task.
Inspectors are qualified through experience, education, and training programs to perform the assigned inspection tasks. Where required, inspectors are formally examined and certified.
Inspections by persons during on-the-job training for qualification are performed under the direct observation and supervision of a certified person.
Verification of conformance is by the certified person until certification is achieved.
17.2.10.5 Inspection Planning Planning for inspection activities is accomplished and documented. The docu-mentation identifies characteristics, methods, and acceptance criteria, and provides for recording objective evidence of inspection results.
17.2-39
09/09/87 WSES-FSAR-UNIT-3 17.2.10.6 Inspection Hold Points If mandatory inspection hold points are required beyond which work shall not proceed without the specific consent of the designated representative, the specific hold points are indicated in appropriate documents. Consent to waive specified hold points are recorded prior to continuation of work beyond the designated hold point.
Suppliers and vendors are required, where applicable, to submit their manufac-turing plans, as indicated in the procurement document, so that LP&L has the opportunity to identify mandatory hold points for witness by an LP&L representative.
Work plans, procedures, and instructions for maintenance, modification, or test of safety-related structures, systems, or components are reviewed to verify inclusion of appropriate inspection requirements, acceptance criteria, and hold points.
17.2.10.7 Inspection by Sampling Sampling inspection methods are used when tests are destructive or when quality assurance records and inherent characteristics of the item indicate that a reduction in items inspected or tested can be achieved without jeopardizing the assurance of quality.
When a sampling method is used to verify acceptability, the sampling procedures provide justification for the sample size and selection process.
Where a sample is used to verify acceptability of a group of items, the sampling procedure is based on recognized standard practices.
17.2.10.8 Inspection Procedures, Instructions, and Checklists Inspection requirements are implemented using applicable procedures, instructions, checklists, drawings, or specifications.
Procedures, instructions, er checklists governing inspections provide for the following, as applicable:
a.
Criteria for determining when inspections are required and how they are performed; b.
Acceptance and rejection criteria; c.
Identification of individuals or groups responsible for performing inspections; d.
The points during fabrication, erection, installation, test, operation, or maintenance at which the inspections are to be performed; e.
Identification of characteristics and activities to be inspected; 17.2-40
09/09/87 WSES-FSAR-UNIT-3 f.
A description of the inspection method; g.
Identification of required Measuring and Test Equipment (MSTE);
b.
Accuracy and precision requirements for inspection, and M&TE; 1.
A method of documenting the identity of the recording inspector or data racorder and documenting the inspection results and/or observations; j.
A method for recording evidence of completing and verifying a manufacturing, inspection or test operation; and k.
Identification of procedures, drawings, and specifications, including revision level used to conduct the inspection.
The procedure originator is responsible for ensuring the accuracy and precision l
requirements of inspection equipment are sufficient to obtain reliable data.
The accuracy and precision requirements are based on procurement or plant technical specifications. The Nuclear Quality Assurance organization reviews safety-related procedures to verify the inclusion c2 accuracy requirements of inspection equipment. The individuals performing the inspections are responsible for assuring that the inspection equipment used meets the criteria noted in the procedure and that the inspection results are within the acceptance criteria of the procedure.
17.2.10.9 Records Records of inspections, as a minimum, identify the following:
a.
Item inspected; l
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Date of inspection; c.
. Inspector; d.
Type of observation; 1
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Results or acceptability; and j
e.
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Reference to information on action taken in connection with nonconfe rmances.
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09/09/87 WSES-FSAR-UNIT-3 17.2.11 TEST CONTROL 17.2.11.1 General Tests required to verify conformance of an item to specifled requirements and to demonstrate that items will perform satisfactorily in service are planned and executed. Characteristics to be tested and test methods to be employed are specified. Test results are documented and their conformance with acceptance criteria are evaluated.
17.2.11.2 R, responsibilities The Nuclear Plant Operations Manager is responsible for ensuring the development and implementation of procedures for the Nuclear Plant Operations staff's testing activities and the approval of PORC recommended test procedures and approval of test results.
PORC is responsible for the review and recommendation of approval to the Nuclear Plant Operations Manager of all testing procedures that affect systems / equipment classified as safety-related prior to implementation.
Instructions for the performance of functional checks do not require PORC approval.
PORC is responsible for the review and recommendation of approval to the Nuclear Plant Operations Manager of all testing results which result in a change to the Technical Specifications or involving an unreviewed safety question.
The Safety Review Committee reviews the results of special tests in accordance with Waterford-3 Technical Specifications.
17.2.11.3 Test Requirements Test requirements and acceptance criteria are provided or approved by the organization responsible for the design of the item to be tested unless otherwise designated. Required tests, including, as appropriate, prototype qualification tests, production tests, proof tests prior to installation, construction tests, pre-operational tests, and operational tests are controlled.
Test requirements and acceptance criteria are based upon specified requirements contained in applicable design or other pertinent technical documents.
17.2.11.4 Test Procedures Test procedures include or reference test objectives and provisions to: assure that prerequisite ior the given test have been met; prove that adequate instrumentation is available and used; provide for acceptance and rejection criteria; provide instructions for performing the test; provide that necessary monitoring is performed; and provide that suitable environmental conditions are maintained. Prerequisites include the following, as applicable:
calibrated instrumentation, appropriate equipment, trained personnel, condition of test equipment and the item to be tested, suitable environmental conditions, and provisions for data acquisition.
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WSES-FSAR-UNIT-3 In lieu of specially prepared written test procedures, appropriate sections of related documents, such as ASTM methods, supplier manuals, equipment maintenance instructions, or approved drawings or checklists with acceptance criteria, can be used.
Such documents include adequate instructions to assure the required quality of work.
17.2.11.5 Test Results Test results are documented and evaluated by a responsible authority to assure that test requirements have been satisfied.
17.2.11.6 Test Records Test records, as a minimum, identify:
a.
Item tested; b.
Date of test; c.
Tester or data recorder; d.
Type of test / observation; l
e.
Results and acceptability; f.
Action taken in connection with any deviations noted; and g.
Person evaluating test results.
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09/09/87 WSES-FSAR-UNIT-3 17.2.12 CONTROL OF M&TE 17.2.12.1 General Tools, gages, instruments, and other M&TE used for activities affecting quality are controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits.
17.2.12.2 Responsibilities The Nuclear Plant operations Manager is responsible for ensuring the establich-ment and implementation of procedures by the Nuclear Plant Operations staff for the calibration, control, and utilization of safety-related M&TE and installed I&C devices. The Nuclear Plant Operations Manager is also responsible for approving calibration and control procedures, as applicable, which have been recommended for approval by the PORC.
The Nuclear Quality Assurance Manager is responsible for the review and audit of the program for control of measuring and test equipment.
17.2.12.3 Selection of M&TE Selection of M&TE is controlled to assure that such items are of proper type,
. range, accuracy, and tolerance to accomplish the function of determining l
conformance to specified requirements.
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l 17.2.12.4 Calibration and Control 17.2.12.4.1 Calibration
{
M&TE is calibrated, adjusted, and maintained at prescribed intervals or, prior to use, against certified equipment having known valid relationships to I
nationally recognized standards. If no nationally recognized standards exist, the bases for calibration is documented.
l Calibration of this equipment should be against standards that have an accuracy j
of at least four times the required accuracy of the equipment being calibrated i
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 s
documented and authorized by responsible management, j
i Calibrating standards have greater accuracy than standards being calibrated.
Calibrating standards with the same accuracy may be used if it can be shown to be adequate for the application and the basis of acceptance is documented and authorized by responsible management.
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09/09/87 WSES-FSAR-UNIT-3 17.2 12.4.2 Control The method and interval of calibration for each instrument and control device is defined, based on the type of equipment, stability and reliability characteristics, required accuracy, intended use, and other conditions affecting measurement control. M&TE is labeled or tagged or otherwise controlled to indicate the calibration due date. When M&TE is found to be out of calibration, an evaluation is made and documented of the validity of previous inspection or test results and of the acceptability of itees previously inspected or tested.
Out-of-calibration devices are tagged or segregated and not used until they have been recalibrates.
If any measuring of test equipment is consistently found to be out of calibration, it is repaired or replaced. A calibration is performed when the accuracy of the equipment is suspect.
17.2.12.4.3 Commercial Devices Calibration and contr,ol measures may not be required for rulers, tape measures, levels, and other such devices, if normal commercial manufacturing practices provide adequate accuracy.
17,2.12.5 Handling and Storage M&TE is properly handled and stored to maintain accuracy.
17.2.12.6 Records Records are maintained and equipment is suitably marked to indicate calibration status.
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09/09/87 WSES-FSAR-UNIT-3 17.2.13 HANDLING, STORAGE AND SHIPPING 17.2.13.1 General Safety related items are handled, stored, cleaned, packaged, and shipped by suitably trained individuals in a manner to prevent deterioration, contamination, damage, or loss of identification. As appropriate, detailed instructions are provided for handling, cleaning, storing, maintaining while stored, and shipping specific items of equipment or material. Under normal circumstances, the manufacturer's instructions or recommendations are followed and are implemented to maintain material integrity and protection. Personnel performing these activities are knowledgeable of the work to be performed and the procedures employed.
When required for particular items, special equipment (such as containers, shock absorbers, and accelerometers) and special protective environments (such as i
inert gas atmosphere, specific moisture content levels, and temperature levels) are specified, provided, and their existence verified.
When required f or critical, sensitive, perishable, or high-value articles, specific procedures for handling, storage, packaging, shipping, and preservation are used.
i 17.2.13.2 Re sponsibilit,1,es j
The Nuclear Plant Operations 12r.ager is responsible for ensuring the adequacy of controls established by the Nuclear Plant Operations staff and for evaluating the effectiveness of their implementation for safety-related activities associated with system, material, or equipment handling, shipping, cleaning, preservation, storage, housekeeping, and preventive maintenance (both in storage and after installation).
The Nuclear Quality Assurance Manager is responsible for receiving inspection of safety-related items and for performing inspections of the Nuclear Plant Operations staff's safety-related activities associated with handling, shipping, storage and prevent.ive maintenance of items in storage.
Such inspections are conducted by qualified inspection personnel under the supervision of the Nuclear Quality Assurance Manager.
The Materials Management Superintendent is responsible for handling, cleanliness, storage and preservation of items within storage and warehouse areas. In addition, the Materials Management Superintendent is responsible for packing and shipping outgoing items (except radioactive waste and spent fuel) and for housekeeping within the receiving and warehouse areas.
The Radiation Protection Superintendent has overall responsibility for housekeeping inside of the radiation controlled area and for the on-site handling, storage, packaging, cleaning and release for shipping to a transit carrier of radioactive wastes and radioactive sources.
The Maintenance Superintendent is responsible for the establishment and implementation of the programs / procedures required to perform preventive maintenance of items in storage and those that are installed. The Maintenance Superintendent is also responsible for the in-plant handling, inplace otorage, 17.2-46
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WSES-FSAR-UNIT-3 preservation, and cleanliness of parts and components until released for l
operation.
In addition, the Maintenance Superintendent is responsible for l
establishment of required cleanliness classifications (or zones) when opening components or systems for maintenances purposes which require specific internal cleanliness levels to be maintained. Additionally, the Maintenance Superintendent is responsible for housekeeping outside of the radiation controlled area except for receiving and warehouse areas.
The Operations Superintendent is responsible for the operation of plant systems for any required flushes or chemical cleaning as well as for assuring that systems and components are appropriately placed and maintained in lay-up condition, when required.
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17.2.13.3 Procedures Handling, preservation, storage, cleaning, packaging, and shipping of items are conducted in accordance with established work and inspection instructions, drawings, specifications, shipment instructions, or other pertinent documents or procedures specified for use in conducting the activity.
l 17.2.13.4 Tools and Equipment Special handling tools and equipment are utilized and controlled as necessary to ensure safe and adequate handling.
Special handling tools and equipment are inspected and tested in accordance with procedures at specified time intervals to verify that the tools and equipment are adequately maintained.
17.2.13.5 Marking Instructions for marking and labeling for packaging, shipment, handling, and storage of items are established as necessary to adequately identify, maintain, and preserve the item, including indication of the presence of special environments or the need for special controls.
17.2.13.6 Consumables Procedural controls are established for chemicals, reagents, fuels, oil, lubricants, and other consumables to assure proper storage, handling, utilization, and disposition.
17.2.13.7 Material Handling Equipment Material handling equipment such as cranes, forklifts, and cables are tested in accordance with established procedures. Operators of special handling and lifting equipment are experienced or trained in the use of this equipment.
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17.2.14 INSPECTION, TEST AND OPERATING STATUS 17.2.14.1 General The status of inspection and test activities is identified either on the items or in documents traceable to the items where it is necessary to assure that required inspections and tests are performed and to assure that items which have not passed the required inspections and tests are not inadvertently installed, used, or operated.
Status indicators such as tags, markings, shop travelers, stamps, inspection records, or other suitable means are maintained. The authority for application and removal of tags, markings, labels and stamps is specified by procedures. Status indicators provide for indicating the operating status of systems and components at Waterford-3, such as by tagging valves and switches, to prevent inadvertent operation.
17.2.14.2 Responsibilities The Nuclear Plant Operations Manager is responsible for developing and maintaining procedures for defining responsibilities and controls for identifying the inspection, test, and operating status of safety-related plant equipment, components, and systems.
The Nuclear Quality Assurance Manager is responsible for the development and l
administration of procedural controls defining status as related to inspections conducted by Nuclear Quality Assurance.
The Assistant Plant Manager - Operations and Maintenance is responsible for the development and administration of procedural controls related to the status of inspections, test, and operations.
17.2.14.3 Inspection and Test Status Procedures require that the status of inspections and tests performed on systems, structures, and components at Waterford-3 be indicated by the use of l
markings such as stamps, tags, labels, routing cards, or other suitable means.
)
Suitable means include identification numbers which are traceable to records of
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the status of inspections and tests.
j Procedures also provide for the identification of items which have not satisfactorily passed required inspect 1ons and tests, where necessary, to preclude inadvertent bypassing of such inspections and tests.
In cases where j
required documentary evidence is not available, the associated equipment or
)
materials are considered nonconforming. Affected systems are evaluated for j
operability in accordance with the Waterford-3 Technical Specifications.
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09/09/87 WSES-FSAR-UNIT-3 17.2.14.4 Operating Status Procedures are established and maintained to assure that the operating status of equipment and systems is indicated and to control altering the sequence of required tests, inspections, and other operations.
Procedures are provided for control of equipment, as necessary, to maintain personnel and reactor safety and to avoid unauthorized operation of equipment. These procedures require control measures such as locking or tagging to secure and identify equipment in a controlled status. Control room tagging is performed in such a manner as to prevent obstruction of other instruments, controls, or indicating lights.
Procedures provide for the authority for release of plant systems or equipment for maintenance or surveillance testing. Technical Specifications and other requirements are considered when preparing for such activities. Documentation is provided for such releases.
1 Equipment and systems in a controlled status are clearly identified, at a minimum, at any location where the equipment can be operated.
Systems are removed or returned to service in accordance with approved procedures and the Waterford-3 Technical Specifications including independent verification where applicable. Control room authorities are informed of changes in equipment status and the effect of such changes.
Temporary modifications, such as temporary bypass lines, electrical jumpers, lifted electrical leads, and temporary trip point settings, are controlled by approved procedures which include a requirement for independent verification by either a second person or by a functional test which conclusively proves the proper installation or removal of the temporary modification. Documented evidence of the current status of such temporary modifications is provided.
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WSES-FSAR-UNIT-3 17.2.15 NONCONFORMING MATERIALS, PARTS OR COMPONENTS 17.2.15.1 General
' Items that do,not conform to specified requirements are controlled to prevent inadvertent installation or use.
Controls provide for identification, documentation,: evaluation, segregation, when practical, and disposition of nonconforming items, and for notification to affected organizations.
17.2.15.2 Responsibilities Nuclear Operations Managers are responsible for the nonconformance control system at Waterford-3 for material, parts, and components and for the development and maintenance of procedures to control nonconformances.
The Nuclear Safety and Regulatory Affairs Manager is responsible for the review of documentation of nonconformances provided by various Nuclear Operations organizations for screening, evaluation, tracking and reporting to the NRC under 10CFR21.
The Nuclear Operations Engineering Manager and the Assistant Plant Manager -
Technical Services are responsible for evaluating and dispositioning of nonconformances with' recommended dispositions of "use as is" or " repair" if the nonconformance relates back to plant design.
Nuclear Operations Department personnel are responsible for the identification of nonconforming items at Waterford-3. Department personnel use the appropriate nonconformance form to identify the nonconforming material.
The Nuclear Quality Assurance Manager is responsible for the review and audit of the nonconformance control system and analyzing nonconformances for quality trends.
The results of such analyses are reported to appropriate management levels on a quarterly basis.
In order to fulfill this responsibility, the Quality Assurance Group is included on distribution for all nonconformance reporting documents.
The onsite Independent Safety Engineering Group is responible for providing a random independent review of nonconformances, disposition, and closeout during the operations phase.
17.2.15.3 Procedures Procedures are provided for identification, documentation, segregation, review, disposition, and notification to affected organizations of nonconforming materials, parts, components and as applicable to services (including computer i
codes) if disposition is other than to scrap. Procedures provide identification of authorized individuals for independent review of nonconformances, including disposition and closecut.
7 I
17.2-50
09/09/87 WSES-FSAR-UNIT-3 17.2.15.4 Identification Identification of nonconforming items is by marking, tagging, or other methods I
which do not adversely affect the end use of the item. The identification is j
legible and easily recognizable.
If identification of each nonconforming item is not practical, the container, package, or segregated storage area, as appropriate, is identified.
17.2.15.5 Documentation Procedures provide that documentation identifies the nonconforming item, the disposition of the nonconformance, the inspection requirements, and includes signature approval of the disposition.
17.2.15.6 segregation Nonconforming items are segregated, when practical, by placing them in a clearly identified and designated hold area until properly dispositioned.
When segregation is impractical or impossible due to physical conditions such as size, weight, or access limitations, other precautions are employed to preclude inadvertent use of a nonconforming item.
17.2.15.7 Disposition I
Nonconforming characteristics are reviewed and recommended dispositions of nonconforming items are proposed and approved in accordance with documented procedures. Further processing, delivery, installation, or use of a nonconforming item is controlled pending an evaluation and an approved disposition by authorized personnel.
Technical justification for the acceptability of a nonconforming item dispositioned repair, or use-as-is, is documented.
Nonconformances to design requirements dispositioned use-as-is or repair are subject to design control measures commensurate with those applied to the original design. The as-built records, if such records are required, reflect the accepted deviation.
Personnel performing evaluations to determine a disposition have demonstrated competence in the specific area they are evaluating, have an adequate understanding of the requirements, and have access to pertinent background inf o rmation.
Repaired or reworked items are reexamined in accordance with applicable procedures and with the original acceptance criteria unless the nonconforming item disposition has established alternate acceptance criteria. The rework, repair or inspection / test procedure is documented and made part of the inspection records.
17.2-51
09/09/87 WSES-FSAR-UNIT-3 17.2.15.8 Records Documentation of nonconforming materials, parts or components is maintained in accordance with LP&L's records management procedures.
Information contained in the documentation includes, but may not be limited to:
a.
Identification of the nonconforming item; b.
Description of the nonconformance; c.
Inspection requirements; d.
Disposition of the nonconformance; and Signature approval for disposition.
e.
17.2-52
09/09/87 WSES-FSAR-UNIT-3 17.2.16 CORRECTIVE ACTION 17.2.16.1 General Conditions adverse to quality are identified promptly and corrected as soon as practical.
In the case of a significant condition adverse to quality, the cause of the condition is determined and corrective action taken to preclude recurrence. The identification, cause, and corrective action for significant conditions adverse to quality is documented and reported to appropriate levels of management. Follow-up action is taken to verify implementation of this corrective action.
17.2.16.2 Responsibilities Nuclear Operations Department personnel are responsible for promptly identifying and reporting potential conditions adverse to quality an the appropriate nonconformance document and submitting the report to the appropriate organization. luclear Operations senior management prepare and maintain procedures to ado;a_;
.ective action requirements.
Nuclear Quality Assurance is responsible for tracking, reviewing for validity and significance, accepting or rejecting corrective action, and verifying corrective action is complete for conditions adverse to quality. Nuclear Quality Assurance is also responsible for reviewing significant conditions adverse to quality to determine if the activity should be stopped. If it is determined that the activity should be stopped, Nuclear Quality Assurance is responsible for notifying the responsible organization of the significant condition and recommend they stop the activity at the next safe stopping point.
If the responsible organization does not stop the activity, the Quality Assurance organization is responsible for issuing a Stop Work Order (SWO).
In addition, Nuclear Quality Assurance is responsible for analyzing conditions adverse to quality to identify quality trends. The results of such analyses is reported to executive and senior management on a quarterly basis.
The Nuclear Safety & Regulatory Affairs organization is responsible for making determinations of deportability under 10CFR Part 21.
The Nuclear Plant Operations Manager is responsible for deportability for items other than those identified in 10CFR Part 21.
17.2.16.3 Procedural Requirements l
Procedures and instructions for corrective action of conditions adverse to i
l quality include provisions for:
l l
l Each person employed by LP&L to identify and report to his immediate l
a.
l supervisor or to the appropriate quality organization representative conditions suspected to be adverse to quality within his area of responsibility; l
\\
l l
17.2-53 j
l
09/09/87 WSES-FSAR-UNIT-3 b.
Supervisory review and classification of reported conditions adverse to quality; c.
Correction of conditions; and d.
Initiating corrective action to preclude recurrence.
17.2.16.4 Significant Conditions Adverse to Quality For significant conditions adverse to quality, the cause of the condition, and the corrective action taken to preclude recurrences is documented and reported to cognizant levels of management and the off-site Safety Review Committee.
Significant conditions adverse to quality are:
(1) conditions reportable to the l
NRC in accordance with Title 10 of the Code of Federal Regulations, (2) any I
gross or widespread nonecmpliance with procedural requirements that negates the effectiveness of quality assurance controls, or (3) any condition which has recurred with such a frequency that it indicates past corrective actions (if any) have been ineffective.
17.2.16.5 Contractor Responsibility Contractors performing services or activities pertaining to safety-related systems, structures, or components are required to comply with LP&L approved procedures which require conditions adverse to quality to be identified, reported, and corrected.
17.2.16.6 Records Corrective action reports and supporting documentation become quality assurance records.
l l
17.2-54
09/09/87 WSES-FSAR-UNIT-3 17.2.17 QUALITY ASSURANCE RECORDS 17.2.17.1 General Records that furnish documentary evidence of quality are specified, prepared, and maintained. They are legible, identifiable, and retrievable. Records are protected against damage, deterioration, or loss. Requirements and responsibilities for record transmittal, distribution, retention, maintenance, and disposition are established and documented.
17.2.17.2 Responsibilities The Nuclear Services Manager is responsible for the establishment and administration of the Nuclear Operations Records Management System.
Nuclear Operations Department managers are responsible for:
Generation, receipt, and processing of records in accordance with quality a.
assurance program requirements and approved implementing procedures and instructions; b.
Identifying specific record requirements during the generation of procurement documents; and Processing records received from external sources, determining individual c.
responsibilities for review and acceptance of such records, and processing them in accordance with approved procedures.
17.2.17.3 Records Administration The records system is defined, implemented, and enforced in accordance with written procedures.
Applicable design specifications, procurement documents, test procedures, operations and maintenance procedures, or other documents specify the records to be generated, supplied, or maintained by or for LP&L. Documents that are designated to become records are prepared such that they are legible, accurate, and completed appropriate to the work accomplished.
Documents are considered valid records when stamped, initialed, or signed and dated by authorized personnel or otherwise authenticated.
An indexing system is provided to enable records to be efficiently retrieved.
The indexing system includes, as a minimum, record retention times and the location of the record within the record system. The records and/or indexing system (s) provides sufficient information to permit identification between the record and the item (s) or activity (ies) to which it applies.
17.2-55
s 09/09/87 MSES-FSAR-UNIT-3 Records are classified as either Lifetime or Nonpermanent. Lifetime records are required to be maintained by or for the life of the particular item while it is installed in the plant or stored for future use.
Nonpermanent records are those required to show evidence that an activity was performed in accordance with the applicable requirements. The retention period for nonpermanent records is' l
established in writing.
.\\
Recorde may be corrected in accordance with procedures which provide for appropriate review or approval by the originating organization. The correction
. /
includes the date and the identification of the person authorized to issue such
/
correction.
Quality.cassurance records include:
Results of reviews, inspections, surveillance, tests, audits,Jnd material a.
analyses; b.
Qualifications of personnel, procedures, and equipment; c.
Operating Logs; d.
Maintenance and modification procedures and reinted inspection results; e.
Reportable occurrences; f.
Records required by the stations' Technical Specifications; i
g.
Nonconformance reports; h.
corrective action reports; i.
The results of monitoring work performance and materials analyses; and j.
Other documentation socn as design drawings, specifications, procurement documents, calibration procedures, and reports.
Inspection and test records, as a minints, identify the inspeccor er data recorder, the type of observation sad the date, the results, tDe ot' reputability, and the action taken in connection with any deficiencies note.L The rccords are distributed, handled, end controlled in accordance with written procedures.
17.2.17.4 Storage, Preservation. and Safekeeping Records are stored at predetermined location (s) that meet the requirements of l
applicable standards, codes, and regulatory agencies.
Records are stored in f acilities constructed and maintu* ned in a manner which minimize the risk of damage or destruction from natural disasters sucL as winde, floeda, or fires; environmental conditions such as high and low temperatures and humidity; and infestation of insects or rodents.
17.2-56
l
. i, 09/09/87
~'
WSES-FSAR-UNIT-3 Records are stored in either single or dual facilities. Where duplicate storage is employed, the storage area environment will be the prevailing building temperature and humidity.
The entry of unauthorized personnel into the storage area is precluded by procedural control to guard against larceny and vandalism.
17.2.17.5 Retrieval Records storage systems provide for retrieval of information in accordance with procedures.
A list is maintained designating those personnel who have access to the files.
Records maintained by a supplier at his facility or other locations are accessible to LP&L.
17.2.17.6 Disposition of Supplier Records Records accumulated by suppliers are made accessible to LP&L. When received, LP&L inventories the submittals, acknowledges receipt, and processes these records.
Supplier's nonpermanent records are not disposed of until the following conditions are satisfied:
a.
Items are released for shipment, a Code Data Report is signed, or a Code Symbol Stamp is affixed; b.
Regulatory requirements are satisfied; c.
Operational status permits; d.
Warranty consideration is satisfied; and Other requirements as specified in procurement documents are satisfied.
c.
17.2-57
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17.2.!i A DlTS
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y 17.2.18.1 General V
y Planned'and, scheduled audits in accordance withwFSAR and Technical
. Specification's commitments are per ormed to iarify. compliance with the Quality f
Assurance Pr' gram requirements and to determine' the Prograrf s ef festiveness.
o These audits are performed in accordance with %ritten procedures or checklists
,i' s by I r/sonnel who do not have direct responsibility for performing the activities d
being' audited. Audit results are documented.and reported to responsible management. Follow-up corrective action is taken where indicated.
17.2.18.2 Resp nsibilities The Nuclear Qualit7:Ar,surance Manager is responsible for the planning, sche.duling, and conduct of audits of the Quality Assurance Program and
' implementing procedures, audits of suppliers, and for determining the adequacy ofauditresponses.1{'
m Managementoftheauditedorganizationisresponsibleforinvestigatingaudit findings, scheduling corrective action including measures to prevent recurrence, and notification of the Quality Assurance organization in writing of action-planned and/or taken.
i f'.
17.2.18.3 Audit P;ogram Objectives of the audit program are:
To ensure that the LP&L Quality Assurance Program is defined and documented; a.
b.
To verify on a regular basis by examination and evaluation of objective evidence that established requirements, methods, procedures, and instructions are being implemented; c.
To assess the effectiveness of the Quality Assurance Program; d.
To identify program ur.akness and nonconformances; and l
To verify correction of identified conditions adverse to quality.
e.
Audits are performed by the Quality Assurance Group to provide a comprehensive independent verification and evaluation of LP&L safety-related activities.
Additional audits are performed as required to verify and evaluate supplier Quality Assurance programs, procedures, activities, and interface controls.
Audits include objective evaluation of work areas, activities, and processes including the review of selected associated documents and records. Audits also include an objective evaluation of safety-related practices, procedures, and instructions; the effectiveness of their implementation; and compliance with quality policy directives.
i 17.2-58 r
09/09/87 WSES-FSAR-UNIT-3 Audits are performed in areas where 10CFR50, Appendix B, requirements are being implemented. These areas include, as a minimum, the safety-related activities associated with:
a.
Operation, maintenance, and modification; b.
The preparation, review, approval, and control of designs, specifications, procurement documents, instruction, procedures, and drawings; c.
Receipt inspection; d.
Indoctrination and training programs; Implementation of operating and test procedures; e.
f.
Calibration of measuring and test equipment; g.
Interface control among LP&L organizations and suppliers; and h.
Nonconformance control and corrective ac fon programs.
l In addition to the above, audits are conducted of the Radiological Effluent and Environmental Monitoring Program, the Emergency Plan, the Fire Protection Plan, the Security Plan, areas required by the Technical Specifications, and/or as may be required by LP&L Management.
17.2.18.4 Scheduling Internal and external quality assurance audits are scheduled in a manner to provide coverage and coordination with ongoing Quality Assurance Program activities. Audits are scheduled at a frequency commensurate with the status and importance of the activity. The audit schedule is reviewed periodically and revised as necessary to assure that coverage is maintained current. Regularly scheduled audits are supplemented by additional audits of specific subjects when necessary to provide adequate coverage.
17.2.18.5 Preparation Planning is conducted prior to each scheduled audit.
Such planning identifies the audit scope, requirements, audit personnel, activities to be audited, organizations to be notified, applicable documents, schedule, and written audit procedures or checklists.
Such preparation is documented according to Quality Assurance Group procedures.
Auditors are selected to be independent of any direct responsibility for performance of the activities which they audit.
In the case of internal audits, personnel having direct responsibility for performing the activities being audited are not involved in the selection of the audit team.
17.2-59 L _-__-
l 09/09/87 WSES-FSAR-UNIT-3 17.2.18.6 Performance Audits are performed in accordance with written procedures or checklists.
Elements that have been selected for audit are evaluated against specified requirements. Objective evidence is examined to the depth necessary to determine if these elements are being implemented effectively. Audit results l
are documented by auditing personnel and are reviewed by management having responsibility for the area audited. Audit results are analyzed to determine the need for reaudit of deficient areas.
Conditions requiring prompt corrective action are reported immediately to the management of the audited organization.
17.2.18.7 Reporting Formal reports are issued within 30 working days following discussion with management. Distribution includes the Nuclear Quality Assurance Manager, the manager responsible for corrective action in the area audited and for operations audit reports, the Safety Review Committee.
17.2.18.8 Response and Follow-up Action Management of the audited organization or activity is responsible to investigate adverse audit findings, to schedule corrective action, including measures to prevent recurrence, and to notify the Quality Assurance organization in writing of action taken or planned.,
The adequacy of audit responses are evaluated by the Quality Assurance organization. Follow-up action is taken to verify that corrective action is accomplished as scheduled.
17.2.18.9 Records Audit records include audit plans, reports, written replies, and documentation of completion of corrective action. Other documentation are retained as quality records as necessdry to support audit results.
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- ~
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WSES-FSAR-UNIT-3 TABLE 17.2-3 (Sheet 1 of 3)
NUCLEAR _ SAFETY QUALITY POLICIES COMPLIANCE WITH 10CFR50, APPENDIX B 10 CFR 50, Appendix B CRITERION Policy Chapter I.
Organization 1.
Defines the organizational structure and delineates the
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authority and responsibilities of individuals and organiza-tions performing quality assurance activities.
II.
Quality Assurance 2.
Defines the scope of the Program Quality Assurance Program and establishes that activities affecting safety-related structures, systems, and components will be conducted in accordance with approved procedures.
III. Design Control 3.
Defines requirements for l
the control of the design of safety-related structures, systems, and components, in-cluding the design of plant modifications.
IV.
Procurement 4.
Defines requirements for Document the control of procurement Control of safety-related structures, j
systems, components, materials, and services.
V.
Instructions, 5.
Defines requirements for Procedures, and the development and control Drawings of instructions, procedures, and drawings.
VI.
Document Control 6.
Defines requirements for the control of documents for i
safety-related structures, systems, and components, and identifies the types of documents to be controlled.
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09/09/87 WSES-FSAR-UNIT-3 TABLE 17.2-3 (Sheet 2 of 3)
NUCLEAR SAFETY QUALITY POLICIES COMPLIANCE WITH 10CFR50, APPENDIX B 10 CFR 50, Appendix B CRITERION Policy Chapter VII. Control of Purchased 7.
Defines requirements for Materials, Equipment control of purchased and Services material, equipment, and services, including control of suppliers and receiving inspection.
VIII. Identification and 8.
Defines requirements for Control of Materials, control of materials, parts Parts, and Components and components.
IX.
Control of Special 9.
Defines requirements for Processes control of special processes including welding, heat' treating, NDE, and chemical cleaning.
l X.
Inspection 10.
Defines requirements for inspection of materials and activities important to safety including criteria for determining when and how inspections are performed.
XI.
Test Con':rol 11.
Describes the scope of the test control program and establishes requirements for test procedures and instructions.
XII. Control of 12.
Defines requirements for Measuring and control of measuring and Test Equipment test equipment used for inspections, tests, and monitoring of safety related equipment and activities.
XIII. Handling, Storage, 13.
Defines requirements for and Shipping handling, storage, and shipping of safety-related j
structures, systems and components.
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09/09/87 WSES-FSAR-UNIT-3 TABLE 17.2-3 (Sheet 3 of 3)
NUCLEAR SAFETY OUALITY POLICIES COMPLIANCE WITH 10CFR50, APPENDIX B 10 CFR 50, Appendix B CRITERION Policy Chapter XIV. Inspection, Test, 14.
Defines requirements for and Operating control of inspection, test Status and operating status of safety-related items and equipment.
XV.
Nonconforming 15.
Defines requirements for Material, Parts identifications, l
or Components documentation, segregation, review, and disposition of nonconforming materials, parts, and components.
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l XVI. Corrective Action 16.
Defines requirements for establishment of an effective corrective action program with followup to verify proper implementation.
XVII. Quality Assurance 17.
Defines requirements for a Records a safety-related records program including identification of types and content of records.
XVIII. Audits 18.
Defines requirements for audits of safety-related activities including audit program scope and methods.
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09/09/87 WSES-FSAR-UNIT-3 ORGANIZATION FOR NUCLEAR OPERATIONS QUALITY ASSURANCE 1
PRESIDENT & CHIEF EXECUTIVE OFFICER SENIOR VICE PRESIDENT NUCLEAR OPERATIONS 1
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OPERATIONS OPERATIONS PLANT OPERATIONS DEVELOPMENT /
OPERA TIONS SUpP ER I
ENGINEERING CONSTRUCTION OPERATIONS TRAINING ADMINISTRATION QA MANAGER MANAGER MANAGER MANAGER MANAGER QA MANAGER MANAGER I
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. ORGANIZATIONS AFFECTING QUALITY DURING OPERATIONS PHASE PRESIDENT AND CHIEF EXECUTIVE OFFICER OFF SENIOR VICE PRESIDENT NUCLEAR OPERATIONS
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OFF VICE PRESIDENT-NUCLEAR l
ON Wl00LE NUCLEAR e
NUCLEAR OUALITY
. SOUTH SERVICES MANAGER ASSURANCE l
SERVICES MANAGER i
NUCLEAR 00ERATIONS o glear Engineering
_. SUPPORT A S SSMENTS o Nuciew Sofety a o Quotity Systems Re fator Affoire o Auerte o Fuel Procurement ON
, y,[toin [WS and o Station Modification and Monogement SARUS progrome Pockage Review o Other services ce ropted o Independent Sofety o Perform Quality o Supplier Surveillance /Audite Evcluotlon Group Toom octivities o Procurement Packoge Review o Plant Performance Review o Emergency Plening o QuoHty Trend Ancfysis o Operating Abnormelltles o Fuel Weegement o Quellfred Svopilere List NUCLEAR PURCHASING ed LER Review activities e QA Trainino Assistance
& CONTRACT o Avoilobility improvement o cost ed Budgets o Procedure koviews ADMINISTRATION Program o Records Wonogement o inspections MANAGER o Communicotlone o Wiecellaneous Reviews and CN o Strotegic Ploming Evolvations o Rodwoote. Rodlological Environmental Monitoring NUCLEAR OPERATIONS NUCLEAR OPERATIONS NUCLEAR PLANT NUCLEAR OPERATIONS ENGINEERING SERVICES CONSTRUCTION OPERATIONS TRAINING ENGINEERING ON ON ON OFF l MM,h,,,,,o,,Cowdindh o ge.ceion re trol controcted o operatione ed con o Tr"Uti Tecnnmdvisors for operatore o,,,, oo, y,
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-S o Wonitor Contreeted De$ Wort construction octMtles o Plant Ploming & Scheduling o Technical Training o Coordinate construction o Securit e Wotntain Trotning.
o Coordinote ISI. ASnE tion XI.
ed EQ netivities toeke involved with outogee o Meterlofe Weo ent Records and Library a Pr0--t ed retrofitting o Plant Recorde onogement e Instructor C.ertificotton o rioid Enginee,%
o Csemieir, o ceee,al Emp oyee T,oinin, o Fleid Seerviolon o Hoofth Phyelce e Focilitlee coordination o Plont Engineering ADMINISTRAflVC
COMMUNICMIVE ON - Organirotlen located at fotorford 3 OFF - Organization located at General Office or elsewhere
- Except for the Operational Licensing. Emergency Preparedness and Recorde Monogement functions, the Nuclew Services FIGURE t7.2-2 organization le physicolfy located off-site.
09/09/87 4 :. -
WSES-FSAR-UNIT-3 NUCLEAR OPERATIONS DOCUMENT HIERARCHY EXTERNAL INTERNAL-REQUIREMENTS REQUIREMENTS Industry Codee
- Ind. Standards
- Design Criterio Fed. Regulations
- Corp. Policles State Rege.
and Directives Etc.
Licensing Commitments
- Executive Directives Etc.
Non-QuoHty NUCLEAR OPERATIONS MANAGEMENT MANUAL Wiesion & Coole Wonogement Documentation Quality Requirements Matrix Nuclear Sofety Quality PoGelee Special Scope Quality Policies NUCLEAR NUCLEAR OPERATIONS OPERATIONS ADMINISTRATIVE PROCEDURES PROCEDURES I
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NUCLEAR MXLEAR NUCLEAR WEE #N NUCLEAR 00ALITY NUCLEAR T&
M RAT M OPERAT M EAW PURCHASING &
SERVICES ASSURANCE OPERAtl0NS Atw W S ENGINEERING CONSTRUCTION OPERATIONS CONTRACTING PROCEDURES PROCEDURES TRA NG PROGDW4ES PROCEDURES PROCEDURES PROCEDURES PROCEDURES (NSP's)
(QAP's)
(pgg4p.s)
(NOEP's)
(NOCPs)
(Pows)
(NPCP's)
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MEAR NUCLEAR QUALITY SUPPORT &
OPERAtl0NS OPERATIONS
[EPARTW NTAL PURCHASING &
SERYlCES ASSURANCE ASSESSENTS ENGIEERING CONSTRUCTION PROCEDLK S CONTRACTING INSTRUCTIONS INSTRUCTIONS INSTRUCTIONS INSTRUCTIONS INSTRUCTIONS INSTRUCTIONS NOTE:
Selected procedures which implement the QA progran require review and concurrence by the %:loor Quellty Asetronce Emoger/ designee.
l FIGURE 17.2 - 3
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