W3P88-0967, Forwards Revised Attachments 2 & 3 to Updated QA Program Description,Fsar Chapter 17.2 to Aid in Review

Forwards Revised Attachments 2 & 3 to Updated QA Program Description,Fsar Chapter 17.2 to Aid in Review

ML20148Q775
Person / Time
Site:	Waterford
Issue date:	04/07/1988
From:	Burski R LOUISIANA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
W3P88-0967, W3P88-967, NUDOCS 8804130342
Download: ML20148Q775 (81)

Text

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F l OUlS1 AN A / 317 BARONNE STREET P. O. DOX 60340 POWER & LIGHT NEW ORLEANS, LOUISI AN A 70160 (504) 595 3100

$$?N!U April 7, 1988 W3P88-0967 A4.05 QA U.S. Nuclear R(gulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

SUBJECT:

Waterford 3 SES Docket No. 50-382 Updated QA Program

REFERENCE:

Letter W3P87-2060 from K.W. Cook (LP&L) to USNRC dated October 1, 1987 Gentlemen:

In Attachment I to the referenced letter, LP&L transmitted for your review the updated QA Program description (FSAR Chapter 17.2) which since that time has been implemented in Revision 1 of the Waterford 3 Final Safety Analysis Report.

As you recall, Attachments 2 and 3 of the referenced letter were provided as supplemental information to aid in your review. contained a marked up copy of the previously accepted QA Program description (FUSAR, 12/18/86). Attachment 3 was a Remarks Document which provided brief explana-tions of the changes being made and was coded with comment numbers to corres-pond to Attachment 2.

Based on comments received f rom your Mr. J.R. Boardman during a meeting between LP&L and the NRC in Arlington, Texas on December 21, 1987, these attachments (2 & 3) have been revised to include additional clari-i fications. A portion of these clarifications, as expressed in the revisions, l

will require changes to the docketed QA program description which will be implemented in accordance with 10CFR50.71(e),

i Please note that the enclosed Attachments supersede Attachments 2 & 3 of the referenced letter, k

2 P

"AN EQUAL OPPORTUNITY EMPLOYER"

r-Page 2 W3P88-0967 April 7, 1988 Should you have any questions or need additional information regarding this i

matter, please contact S.A. Alleman, Nuclear Quality Assurance Manager, at (504) 464-3466.

Yours very truly, i

,y e

..F. Burski Acting Manager Nuclear Safety & Regulatory Affairs RFB/TJC/plm Attachments cc E.L. Blake, W.M. Stevenson, J. A. Calvo, D.L. Wigginton, R.D. Martin, j

J.R. Boardman, NRC Resident Inspector's Office (W3) l l

{--~v Attechm:nt #2 j

VSES-FSAR-UNIT-3 6

17.2 QUALITY ASSURANCE DURING OPERATIONS t'

17.2 The Louisiana Power & Light Company has established a comprehensive program for quality assurance during the operating phase of the Waterford-3 nuclear plant. Thts Nuclear Operations Quality Assurance Program (hereaf ter 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 publie 001 health and safety. "'TEose activtttes include:

17.2 P.1 GENERIC a) Turnover of the plant systems and equipment from the construction organization; b)

Startup testing; c)

Preoperational testing; and d)

Operation, maintenance, repair, modification, and refueling.

The Quality Assurance Program as described herein complies with Regulatory Guide 1.33, Revision 2, 1978.

Table 17.2-1 contains a listing of those Regulatory Guides (including revision number and date) to which LPkL is committed with exceptions and clarifications. Table 17.2-2 identifies procedures manuals that document the 002 Quality Assurance Program. l The Nuclear Operations Department Quality Assurance.7anual (hereatter referred to in this document as the Quality 1742 P.3 Assurance Manual) defines the LPEL quality assurance progras. I Table 17.2-3 correlates the contents of the Quality Assurance Manual with the criteria of j

10 CFR 50, Appendix B.

In addition, Figure 17.2-4 shows graphically the 003 hierarchy ofl quality relatedlprograms, procedures, and instructions.

GENERIC 17.2.2.4 17.2.1 ORGANIZATION I' 'I*I 0*"

17.2.1 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.1 An overview of the performance of these activittes 17.2.1 P.3 relattve to Quality Assurance Program compliance is accomplished by Quality 17.2.1.3.e Assurance personnel throuah reviews and audits.

17.2.1.2 Organizations Performina Quality Assurance Functions 7

7 Figure 17.2-1 shows the lines of authority for the major LPkL organizations involved in quality assurance for Waterford-3 during preoperational testing and plant operations. Figure 17.2-2 illustrates how quality related activities of line and support organizations during the operational phase are under the cognizance of the Corporate Quality Assurance Manager and higher i

i l

17.2-1 l

1 e

WSES-FSAR-UNIT-3 e

1evel corporate management. Figure 17.2-3 ampi.ifies the onsite organization 17.2.1 P.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 Consittee

e. Corporate Quality Assurance Manager

f. Nuclear Operations Quality Assurance Manager

g. Engineering and Systems Development Quality Assurance Manager-Nuclear

h. Plant Manager-Nuclear

i. Plant Quality Manager-Nuclear J. Plant Operations Review Coassittee

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 i

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 l Waterford-3 plant.

17.2.1.1 17.2.1.2.2 Senior Vice President Nuclear Operations The Senior Vice Paesident-Nuclear Operations is responsible for definina LP&L 006 quality assurance and nuclear safety polietes. IReporting to him are the Nuclear Servtces Manager, Project Manager-Nuclear, Completion Manager-Nuclear, 17.2.1.1 Corporate Quality Assurance Manager, Plant Manager-Nuclear. and the Safety GENERIC Review Committee.1 He appotats the Chairman and members of the Safety Review Committee.

The Senior Vice President-Nuclear Operations reviews status summaries of the TBL.17.2-1(4-3) 17.2.1.1 P.2 Quality Assurance Program submitted to his by the Corporate Qun11tv Annurance 17.2.2.8 Mananer. These summaries, in addition to his review of annual Management REF: 099 AuditIresults 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, j

17.2-2 i

s

m USES-FSAR-UNIT-3

. 007 17.2.1.2.3 Management Audits 17 ' 2'8 T9Llb2-l(4-3)

In rder to btain an independent evaluation of the LP&L Quality Assurance Program, the Senior Vice President-Nuclear Operations appoints a management BEF: 100 audtt 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 results are documented and reviewed by responsible managers who are required to take cosusensurate corrective actions. Follow up audits are performed to verify effective corrective actions.

17.2.1.2.4 Safety Review Cosusittee 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 addreas nuclear safety and in such a manner as to present no undue risk to the public health and safety. The SRC provides 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 CTR 50.59; and performs special evaluations, reviews, and audits as may be requested by the Senior Vice President-Nuclear Operations.

17.2.1.2.5 Cerporate quality Assurance Manager 17.2.1.3.0 The Quality Assurance Section under the direction of the Corporate Quality Assurance Manager has the authority and responsibility for developing, coordinating, and assuring implementation of the LP&L Quality Assurance Program. The Corporate Quality Assurance Manager saintains an overview of Vaterford-3 quality related activities through reviews and audits. He and his staff have sufficient authority and organizational freedom to effectively:

17.2.1 P.5 a)

Identify quality assurance probless; 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 l

continue, 17.2-3 J

VS ES-FS AR-llNI f-3 17.2.1.3.0.1 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, organiztng, and administering the Quality Assurance Program; d

b)

Developing, reviewing, approving, and maintaining administrative control f the Quality Assurance Manual and changes thereto; REF: 002 c)

Advising n the se pe and content of quality assurance training courses 17 * *'

• 2 * *' P ' ',

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)

Vertfying 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; g

4) Conducting pre-award evaluations for quality assurance requirements of 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; 009 g)

Serving as a sesber of the Saf ety Revtew Coasetttee; h)

Establishing and maintaining a qualified suppliges list for use in procuring quality related items and services; 010 t)

Assisting in establishing and administering that portion of the Tratates 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 011 17.2.1.3.0.2 The principal qualifications for the Corporate 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

l WSES-FSAR-UN2T-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 sanager 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 l

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 Quality Assurance Manager.

The Engineering and Systems Development Quality Assurance Group has the responsibility for:

1 a)

Developing and maintaining LPEL Quality Assurance policies and procedures; 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

compliance with applicable requirements and guidance; i

d)

Auditing those offsite groups within LP&L and Middle South Services who perfors quality reisted activities for Waterford-3; maintaining documentation of quality assurance activities; I

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 programs 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 reisted saterials, spare parts, and services.

17.2-5 l

o WSES-FSAR-UNIT-3 REF: 012 17.2.1.2.5.4 Nuclear Operations Quality Assurance Group (Onsite) 17.2.1.3.0.1 The Nuclear Operations Quality Assurance Group located onsite at Waterford-3 is headed by the Nuclear Operations Quality Assurance Manager-Nuclear who reports directly to the Corporate Quality Assurance Manager. The Nuclear Operattons 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:

k a)

Reviewing procurement documents generated offsite to ensure inclusion of 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; j DELETED e)

Providing assistance to plant and support organizations on satters related GENERIC d to quality assurance; and j

f)

Monitoring plant activities to verify compliance with applicable e

requirements; g)

Conducting audits of quality related activities.

e 17.2.1.4.1 17.2.1.2.6 Plant Manager-Nuclear j

l 014 The Waterford-3 plant operations organization is headed by the Plant Manager-Nuclear (hereinafter referred to as Plant Manager). He reports GENERIC 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 seasures. This responsibility includes:

h a)

Providing and maintaining a trained and qualified staff to safely operate and maintain the plant.

1 b)

Assuring developeent and proper implementation of plant quality related procedures and instructions for activities such as plant operations,

]

maintenance, repair, test, and inspection; i

009 c)

Participating as a neeber of the Safety Review coseitter,

DELETED j

d)

Addressing satters brought to his attention by the PORC.

i i

17.2-6 i

WSES-FSAR-UNIT-3 An Assistant Plant Manager, designated by the Plant Manager, is responsible 1?.2.1.4.1P.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 l

Services, and the Plant Quality Manager. The Operations Superintendent, Shift Technical Advisor (STA) Superintendent. Planning and Scheduling Supervisor.

and Maintenance Superintendent report to the Assistant Plant Manager-Operations and Maintenance. The Technical Support Superintendent and i

the Radiation Protection Superintendent report to the Assistant Plant Manager-Plant Technical Services. The Plant Technical Services unit includes j

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 i

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 i

plant operation.

l 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 LPEL Quality Assurance Program related to Waterford-3 onsite-initiated activities. These responsibilities include:

17.2.1.3.0.1 a)

Provide a Plant Quality Department adequate to meet Waterford-3 review, 8

inspection, verification, and surveillance requirements; 17.2.1.4.6.f b)

Provide training to develop, maintain, and test the skills of inspection I

17.2.10.4 personnel; 17.2.1.3.0.1.c,j e)

Provide reviews of instructions, procedures, and drawings to ensure 17.2.5.2 P.2 inclusion of quality requirements;

}

d)

Provide saterial receipt inspections; r

e/17,2.9.2 e)

Perform or survey nondestructive examinations and other special processes; f)

Provide inspection and/or verification to assure maintenance of a&r safety-related materials, parts, and components as required by LPEL's Quality i

1 Assurance Program; g)

Identify, segregate, review, disposition, and provide notification of the s

affected organization of nonconforming materials, parts, components, or se rvices; 4

17.2-7 l

a i

e

~

1 VSES-TSAR-UNIT-3 h)

Track the status of nonconformances until the conditions have been o

properly evaluated, corrected, and safeguards have been instituted to preclude repetitton; k

i)

Provtde reviews of procurement documents to ensure inclusion of quality requirements; 1

j)

Prepare inspection instructions; k)

Provide onsite quality program status reports; m

017 17.2.1.2.6.2 Plant Quality Organizational Treedon 17.2.1 P.5 Tigures 17.2-1 and 17.2-3 show the lines of communication between the Corporate Quality Assurance Manager, the Nuclear Operations Quality Assurance Manager, and the Plant Quality Manager necessary for resolving quality problems. The Plant Quality Manager and his staff have the authority and organizational freedom to perform their quality functions effectively. They:

a)

Identify quality problems; b)

Initiate, recommend or provide probles solutions through designated channels; and c)

Verify implementation of satisfactory solutions.

In accordance with approved procedures, and as delineated herein, the Plant Quality Managet and his staf f 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 !!, 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)

Tour-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

WSES-FSAR-UNIP 3 Con't training to be acquainted with the relevant quality assurance aspects of a nuclear facility.

17.2.1.4.1.1 17,2.1.2.7 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 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 Section 6.0 of the Technical Specifications (TSAR, Chapter 16).

019 17.2.1.2.8 Project Manager-Nuclear The Project Manager-Nuclear who is responsible for direction and administration of the Project Management Group during construction completion and operation. This includes managing and controlling the activities of the Engineering and Nuclear Safety, Construction, Contracts Records &

Administration, and Cost / Scheduling Departments.

The functions of Project Management include:

17.2.1.4.4.a a)

Managing the design change process, including initiation, implementatica 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 experience 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 e)

Reviewing selected plant operating, alarm, and emergency procedures for 17.2.1.5.e,f technical adequacy; 17.2.1.4,1.i 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 sanaging contracted l

activities; 17.2.1.4.4.d g)

Providing and managing contract support for retrofit and maintenance activities; h)

M:naging cost control measures and capital expenditure, and operations and 17.2.1.4.1 matatenance budgets; i)

Purchasing necessary operational spare parts in support of station 17.2.1.6.b

,ogggie,gton,;

021 j)

Inter

• sting schedules; DELETED 17.2-9 I

BSES-FSAR-UN8T-3 l

022 k)

Ensuring orderly transfer of structures free construction to the plant staff; and DELETED 1)

Provtjtng support for records management including execution of the 17.2.1.5.m document control and quality assurance record storage program.

17.2.1.5 17.2.1.2.9 Nuclear Services Manager a

The Nuclear Services Group is responsible for t roviding support to the Waterford-3 Plant Staff and interf acing with Nuclear Services Group j

consultants and other organtastions. This group includes Nuclear Support and Licensing, Energency 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; I

b b)

Managing the preparation of TSAR updates and responses to IE bulletins, circulars, generic letters, and information-notices; t

d c)

Administering environmental licensing activities; d)

Managing the preparation and approval of the Waterford-3 Emergency Plan o

and implementing procedures; e)

Coordinating the preparation of energency drill scenarios and performance g

i of practice drills; i

f)

Coordinating the activities of Middle South Services relative to nuclear j

i fuel material, conversion, enrichment, fabrication processes, and in-core fuel t

l management;

)

17.2.1.5.j g)

Coordinating and providing technical support, as required, to radwaste, radiation control, health physics, and ALARA programs; and 17.2.1.4.2.d 023 n)

Providing plant special projects support, including: reliability and i

DELETED maintainability improvements, plant monitoring computer development, training

]

simulator procurement, and Energency Operations facility conceptual design.

024 17.2.1.2.10 Completion Manager-Nuclear i

DELETED The Completion Manager-Nuclear is responsible for the tran6ition of Vaterford-3 from the construction to the operations phase. This includes a

ensuring that the testing and startup activities result in an effective transfer of plant systees 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 othat matters.

17.2-10 1

m WSESoFSAR UNITo3

. Con't.

17.2.1.2.10.1 Waterford Startup Group The Startup Manager who reports to the Completion Manager-Nuclear is responstble for managing Waterford-3 Startup activities. The Waterford Startup Group's responsibilities include a)

Preparation of startup administrative and test procedures; b) 01anning and coordinating tests; c)

Directing and supervising startup testing activities; d)

Documenting and evaluating test results; e)

Ensuring orderly transfer'of plant systees, and components to the plant staff including a complete status of same; and f)

Providing assistance to the Plant Staff during Phase III testing, j

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 i

the Plant Staff. The JTG is responsible for procedure reviews and review of prerequisite (Phase I) and preoperational (Phase !!) 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 progras prior ta 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 saterial, equipeent, spare parts, and services. These functions include preparation and release of bid requests, coordination of bid evaluations by Quality Assurance and ensinaerint aroups, as required, and issuance of procuresant documents.

l 17.2.1.2.12 Middle South Services 17.2.1.7 LP&L delegates to Middle South Services, Inc. (MSS), the authority to perform those quality assurance functions necessary to ensure that the nuclest fuel is designed and f abricated in accordance with regulatory requirements sad accepted codes, standards, and specifications. The MSS Quality Ass nad::

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 necessary to ensure the quality of the fuel.

17.2-11 1

u USES-FSAR-UNIT-3 Formal audit reports are issued by MSS to document their audit activities and to identtfy nonconformances or other items requiring actico by the fuel fabricator. Resolution of nonconformances or other items requiring action is vertfied by MSS and documented in follow-up reports. The LP&L Corporate Qualtty Assurance Manager is on distribution for all audit and follow up reports pertaining to LP&L and Waterford-3.

MSS is also utiltaed 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 internal management audits 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 (FDE) 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 dwcuments to have a quality assurance program. In such cases, a line of ommunication esists between the supplier / contractor and the LP&L Quality Assurance organization. The overall responsibility for gus*ity assurance at Vaterford-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, equipment, materials, systems, and/or components provided. Supplier Quality Assurance Progran requirements are prescribed thtough procurement documents to provide controls and documentation in accordance with the scope of activities involved and their importance to safety.

17.2.2 QUALITY ASSURANCE PROGRAM 17.2.2.1 Ceneral 17.2.2.1 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 for the design and design changes, procurement, fabrication, installation, 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.aich assures that quality related activities are performed in a controlled manner I

17.2-12 l

USES-FSAR-UNIT-3 and documented to provide objective evidence of compliance with NRC regulations and guidance. This program takes into account the need for special controls, processes, test equipment, tools, and skills to attain the required quality, and the need for verification of quality by inspection, testing, surveillance, and audit. The design control portion of this program will be implemented e0 days prior to fuel loading. This program as it applies to other areas will be implemented 90 days prior to fuel loading with applicable portionai 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.

The Quality Assurance Program is implemented by those organizational groups and departments whose activities af fect quait.y at Waterford-3 (Figure 17.2-1).

The personnel within these groups and departments use approved procedures that control quality related acti"ities. These approved procenures incorporate the requirements of the regulatory guides and the NRC endorsed ANSI Standards to which LP&L has specifically committed. Indoctrination and training programs are provided to train personnel in the requirements of the Quality Assurance Program.

17.2.2.2 Development of Program 17.2.2.3 Figure 17.2-4 depicts, in graphic form, th'e hier.irchy 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 j

related activities for Waterford-3. The Quality Assurance Program defines the duties of individuals and organizations participating in quality related activities.

The quality assurance policies, goals, and objectives are documented in the REF: 002 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 17.2 P.3 mandatory for responsible organizations and individuals and is enforced.

Quality Assurance Program policy is approved by the Senior Vice President-Nuclear Operations.

l The hierarchy of documents in the Quality Assurance Program is as follows:

17.2.2.3 a)

The first tier of docum:nts consists of those government regulations; a

industry codes and standards; and LP&L policies and directives, commitments, 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)

At the second tier of documentation, the Quality Assurance lisuual defines 3

the responsibilities, interfaces, and authorities of LP&L personnel, 17.2 13

o 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 10 CFR 50, Appendix B and its regulatory guides, and ANSI Standards implement whtch are Ltsted in Table 17.2-1.

The individual Nuclear Operations Department groups assigned responsibilities 17.2.3.1 P.3 under the scope of the Quality Assurance Maoual are responsible for the development, maintenance, and implementation of procedures and instructions to detail respective elements cf program performance.

The Quality Assurance Manual assigns to the Corporate Quality Assurance 025 Manager the responsibility and authority for developing, coordinating, and 17.2.2.3 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 Responsibilities for approval and control of the Manuals assurance measures.

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 manual are required to remove j

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.

The Plant Operating Manual (POM) consists of a series of procedures that 026 address required aspects of plant management and operations. lThese TBL 17.2-2 procedu.es:

1) Implement the policy and direction of the Quality Assurance Manual to provide control over quality related operations and activities to a degree consistent with their importance to safety;

2) Provide a clear understanding of the operating philosophy at Waterford-3; and

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 the Startup Test Program their respective responsibilities and the procedures which govern the administration of the Startup Test Program.

Project Management Procedures and Nuclear Services Procedures prescribe 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

WSES-FSAR-UNIT-3 17.2.2.4

• '.2.2.3 Identification of Safety Related Stcuctures, Systems and_ components

ne Quality Assurance Program provides control of activities af fecting the 1

qualtty 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 identifier 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 is the FSAR be reviewed ac4 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.) ce 17.2.2.5 contractor / suppliers of quality related equipment and services are normally resolved through the Plant Manager. If a satisfactory resolution cannot 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, uains 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 Operations.

Disputes involving quality, arising from a difference of opinion between the 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 secpe, 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 17.2.2.2 personnel are properly trained to perform activities in a safe and effective manner. l The Quality Assurance Section assists with the development and 17.2.2.2 conduct of quality assurance indoctrination and training. The Corporate i

17.2-15

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o WSES-FSAR UNIT-3

• 17.2.2.2 Quality Assurance 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 af fect quality are trained and qualified in the principles, techniques, and requirements of the activity being performed; c)

Proficiency and requalification of personnel performing activities e

requiring certifi:ation are maintained by retraining, re-examining, and/or recertifying on a periodic basis; 029 d)

Proficiency tests be given to those personnel performing and verifying j

activitie affecting quality, and acceptance criteria developed to determine g'

if individuals are properly trained and qualified; j

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 Assurcnce Section conducts audits of other organizational units, such as vendors, suppliers, and contractors engaged in quality related 17.2.18.3 P.2 activities to verify that personnel are adequately trained, indoctrinated, and qualified.

17.2.2.7 17.2.2.6 Controlled Conditions for Quality Affectina Activities Quality af fecting activities are accomplished under controlled conditions by personnel with the necessary stills to attain the required quality.

Activities af fecting quality are performed with appropriate equipment, under suitable environmental conditions and with the assurance that prerequisites for inspections and tests have been satisfied.

17.2.2.8 17.2.2.7 Manasement Review of the Quality Assurance Program 17.2.18.10 The Senior Vice President-Nuclear Operations ensures that a management audit 17.2.1.7 P.4 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

=

USES-FCAR-UN8T-3 Assurance danager 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 Testina (Phase I, II, and III) and Systems 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 accomplisbed 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 preoparational testing and plant turnover in accordance with contractural requirements.

032 17.2.2.9 Maintenance of Quality Ascurance Program DELETED Amendments to the FSARland revisions to the Quality Assurance Manual \\ 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 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.

j LP&L requires their principal contractors to notify LP&L of changes to their Quality Assurance Program description. Significaist 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 tha 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 Quality 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 effectiveness of the program through review and audit.

17.2-17

u WSES-FSAR-UNIT-3 17.2.3 DESIGN CONTROL 17.2.3.1 17.2.3.1 ceneral The Quality Assurance Program defines the quality requirements for the design control of plart quality related systems, components, structures, and I

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 l The Project Manager-Nuclear lis responsible for design activities during the operational phase,lbeginning with 60 days prior to core loading. The Project l l Management Groupl is responsible for preparing, reviewing, approving, and vertfytag 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, 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 controllea in accordance with approved procedures.

Procedural control is established for design documents that reflect 035 commitments 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.

Procedures are established to assure that verified computer codes are 17'3*5 P*9' 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 i

with approved procedures to assure that:

a) Design characteristics can be controlled, inspected, and tested to ensure no adverse effect on safety; and i

17.2-18 l

USES-FSAR-UNZT-3 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, distribution, and revision of documents involving design interfaces to assure 17.2.3.3 P.4 structures, systems, and components are compatible geometrically, 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 Design verification processes such as design review, alternate calculations, and qualification testing are accomplished in accordance with approved 17.2.3.6 P.1 procedures.

Qualification testing of a prototype unit under adverse design ecnditions is

17. 2. 3. 6 P. 6.b required when a test program is used to confira design adequacy.

If design verification is by other than qualification testing, it is normal:,y 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 verification be other than tLe original designer or the designer's immediate

'17.2.3.1 supe rviso r.

However, the designer's immediate supervisor say perform the 17.2.3.6 P.9 verification if the following conditions apply:

a) The supervisor is the only technically qualified individual; a

b b) The need is individually documented and approved in advance by the responsible management; and 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.

3 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.

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; l

b b) Prototype, component, or feature testing is performed as ea-ly as possible f

prior to installation of plant equipment, or prior to the point when the installation would become irreversible; and 17.2-19

VSES-FSAR-UNIT-3 c) Verification by test is performed under conditions that simulate the most 17.2.3.6 P.6 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 dasign 17.2.3.9 change which might affect the performance of plant persoanel 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, systems, and components are functioning adequately af ter 17.2.3.8 P.2 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.

17.2-20 m

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l WSES-FSAR-UNIT-3 l

17.2.3.4 Replacement or Repair 17.2.3.8 P.6 Malfunctions are promptly documented and evaluated to determine probable cause.

If evidence indicates that common components in quality related systems have performed in an unsatisfactory manner, corrective measures are 17.2.3.8 P.2 planned prior to replacement or repair of such components. Approved procedures for repair are made available prior to actual performance.

17.2.3.6 Replacement parts must receive adequate evaluation and/or testing if they are not of a design which has been previously proven satisf actory. A phased 17.2.7.9 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 inspection program is implemented following a large scale component replacement or repair as necessary to demonstrate component reliability.

17.2.4 PROCUREMENT DOCUMENT CONTROL 17.2.4. 2 17.2.4.1 General Procurement document control applies to documents 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 cequired, through procurement documents, to impleneat 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 are equal to or better than the original item.

17.2.4.2 Preparation of Procurement Documents Nuclear Operations Department personnel are responsible for preparation of procurement documents for quality related parts, components, systems, and s e rvice s. Their responsibilities include procurement planning, preparation, review, approval, and control of purthase requisitions; bid evaluation; and i

assisting in suppl.er selection (subject to Quality Assurance Section concurrence).

)

17.2.4.3 control of Procurement Documents 17.2.4.4 2.4.3 b&c 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 respcasible 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:

I

• 2*

a) State the scope of the work to be performed by the supplier;

)

17.2-21

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USES-FSAR-UNIT-3 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 e

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 e

supplier and those delivered to LP&L prior to use or installation of the itee; i

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; f

g) Specify when necessary the requirement for suppliers to comply with 10 CFR Part 21 for reporting defects and noncompliances which could create a substantial safety hazard; and b&

h) Establish seasures for the identification, control, and disposition of 17.2.16.5 items and services that do not meet procurement document requirenants.

17.2.7.8 t

LP&L utilizes recognized standards for the procurement of standardized items 037 such as bearings, V-belts, capacitors, resistors, transistors, and lubricating DELETED oils. Otber itees are purchased by part number or recommendations supplied by 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 applic'?CE '1 des and standards. Whe:re commodity or catriogue itess are to be a quality rclated applications, 4

the procurement documents may specif;,

< W inspections, tests, verifications or documentation requir6<.f assure suitability for the intended application.

17. 2. '+. 4 Review and Approval REF: 013 The Quality Assurance Section[and the Plant Quality Grouplreview quality DELETED related procurement documents for Waterford-3. This review is conducted to 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 j

or other methods; and d)

That technical and quality requirements are controlled through a program c

of planned and systematic actions.

17.2-22

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WSES-FSAR-UNIT-3

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17.2.4.5 Qualified Suppliers List

'17.2.4.2 P.5 The Engineering and Systems Development Quality Assurance Group is responsible for establishing and maintaining the Qualified Supplie,rs 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 Ch.nges and revisions affecting the technical and/or quality requirements of procurement documeats 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 phsse 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, maintainina, 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.

17.2.5.3 17.2.5.2 Preparation of Instructions, Procedures, and Drawings Precedures are written to provide a controlled method for preparing, reviewing, changing, and approving instructions and procedures, lustructions, 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 Waterford-3.

17.2.5.4 17.2.5.3 Contents of Instructions, Procedures, and Drawings Instructions and procedures prescribics operational activities that affect quality related functions identify any special equipment and conditions 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 elemants of an activity to be observed or measured.

17.2-23

o WSES-FSAR-UNIT-3 17.2.5.4 Review and Approval Instructions, procedures, and drawings prescribing quality related actiitties 039 are reviewedland approved lby the individual in charge of the organization 17.2.5.5 engaged tn that activity.

Whenever a quality related instruction, procedure,,

or drawing of one organization af fects or involves the activities of another 17.2.5.5 P.2 rganization, the originating organization is responsible for ensuring that the affected organization reviews and concurs with the document content. [ tee" 040 I risinating 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 impirmentation 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 CO.VI'FOL 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 andl approved oy the same groups 71

)

17.2.6.1 P.2 17.2.6.2 Review and Issuance of Controlled Documents I

Document control procedures require that documents, inc.luding changes, be 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 3rescribing quality related activities as described in Subsection 17.2.5.4.

i Controlled documents and revisions generated within L?&L which affect the i

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 17.2.5.5 approved by the uupervisor of the responsible group, effective dates assigned, and the documents distributed in accordance with applicable procedures and 17.2-24

y U3ES-FSAR-UNIT-3 17.2.6.1 P.2 instructions. Controlled documtnts are distributed prior td stseting an 17.2.6.2.a activity and, if necessary, are on hand at ene }ocations where the prescetbed acttvtt tes are performed beft ce Cork tigina.

17.2.6.3.a controtted Itsts,f documents are updated arJ isswed in accordance with appitcable procedures to prec,*ade the use of Supersedod documents. These Itsts identifv the current revistou number of the iustru:t)ons, procedures, specfficatiens, dtawings, aad procurement specifications. Record copies of 77*3**17'3 c:le documents are retained in accordance with ap;eopriate records management proced,res. Obsolete er superseded documents Lee controlled by approved 17.2.6.1 P.2 written procedures P.o prevent inadvertent use.

Changes to quality rel3.ed documents are reviewed.and approved by the same 9

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 peccedures. 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 determiae:

a) That the need for inspection, identification of inspection personnel, and documentation of inspection results have been properly sp2cified-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 conductics 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 as-built status of Waterford-3 are transferred from the ArchiJect-Engineer to DELETED LP&L prior to receipt of the operating license. These drawings are stored in a controlled facility, with reproducible copies of those drawints required for plant operation and maintenance furnished to the Plant Manager.j The Project 044 Management Group is responsible for the revision and update or master drawings e reflect station modifications.

17.2.6.6 The Project Management Group issues Station Modifications (SMs) which delineate the drawings affected by proposed modifications.l The Plant Manager 17.2-25 l

1 1

23

VSES-FSAR-UNIT-3 implements and maintains administrative controls which assure that as-built

'17.2.6.6 P.6 drawings utilized for plant operation and maintenance are obtained and disseminated upon completion of the related modification. The Nuclear 17.2.6.2 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. :. 6. 6 P. 3 provide additional details for operation, maintenance, or testing, and these are centrolled 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 handled in the same manner as the original issue.

17.2.6.5 17.2.6.3 Types of Controlled Documents The documents controlled under the Quality Assurance Progras include as a minimum:

f a) Safety Analysis Report; b) Design documents including salculations, drawings, specifications, change a

requests, analyses, and documents related to computer codes; j

c) Procurement documents; c

i d) Quality Assurance Manual; e) Quality Assurance Section Procedures; e

d f) Inspection and test procedures for fabrication, construction, installation, test, maintenance, modification, and operation; j

g) N neonformance Reports; 3

b h) As-built documents; i

1) Emergency Plans; i

j) Faysical Security Plans:

1 k) Plant Operating Mancai; e

e

1) Nuclear Services Procedures; and 045 m) Project Management Procedures.

DELETED 4

17.2-26 e

WSES-FSAR-UNIT-3 17.2.7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES 17.2.7.1 General 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, and inspection upon delivery. Quality assurance measures of suppliers are assessed at periodic intervals commensurate with the importance, quantity, and complexity of the product or servi,:es being purchased. This assessment employs audit, independent inspection or test to verify that documentation i

17.2.7.4 s"ch 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.5 equipment or the original design is appropriate for replacement or repair.

Proposals (bids or quotations) by suppliers are reviewed to ensure that no j

17.2.4.4 exceptions are taken which would violate safety, technical, or quality j

requirements. The program requirements for control of purchased material, 17.2.8.2 equipment, and services are contained in approved written procedures.

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17.2.7.2 Evaluation of Suppliers j

17.2.4.2 P.5 Quality related 89uipment, materials, and services are obtained from suppliers, contractors, and consultants on the LP&L Qualified Suppliers List 17.2.7.2 P.6 when required to assure compliance with codes, standards, sni regulatory commitments. Suppliers, contractors, and consultants are qualified for inclusion on the Qualified $uppliers List through an evaluation of their quality as_surance 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 17.2.18.3 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 wha 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 which meets design, manufacturing, and quality requirements.

LP&L's Corporate Quality Assurance Manager is responsible for establishina 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 of potential suppliers for providing quality related items and services as needed.I Suppliers of quality related structures, systems, components, and services for Waterford-3 are informed through procurement documents of their 17.2.4.3.f requirement to comply with 10 CFR Part'21 for reporting defects and noncompliances that could create a substantial safety hazard.

17.2-27

o WSES-FSAR-UNIT-3 17.2.7.3 Surveillance of Suppliers Audit and surveillance of quality related suppliers during f abrication, 17.2.7.7.1 P.3 inspection, testing, and shipment of materials, equipment, and components is 17.2.18.1 planned and performed in accordance with written procedures to ensure conformance to the procurement document requirements. These procedures provide for:

a) Instructions that specify the characteristics or processes to be witnessed, inspected or verified, and accepted; b) The method of surveillance and the extent of documentation required; and c) The personnel responsible for implementing these instructions; Surveillance is performed on those items where verification of procurement 17.2.7.7.1 P.1 requirements cannot be determined upon receipt. Suppliers' quality related 17.2.7.4 P.2 activities including the validity of certificates of conformance are periodically evaluated by audits, independent inspections or tests. The ef fectiveness of supplier quality control is assessed by LP&L at intervals 17.2.7.4 P.1 consistent with the importance, complexity, and quantity of the item or service being delivered.

17.2.7.4 Receiving Inspection Receiving inspection of material, components, and equipment is performed in y,#*2*7*7*1 P*4 accordance with written procedures which provide that:

a) The material, component or equipment is properly identified and 17.2.7.7.1 corresponds to the requirements of the procurement documentation; b) Material, components, equipment, and records are inspected and judged 17.2.7.7.1 acceptable in accordance with procurement document requirements prior to installation or use; 048 c) Inspection records or certificates of conformance attesting to the quality 17.2.7.7 of material, components, and equipment are available at Waterferd-3 prior to 17.2.7.11 P.4 installation or use; and d) Accepted and released items have their inspection status identified prior 17.2.14.3 P.1 to being forwarded to a controlled storage area or released for installation 17.2.7.7 or further work.

17.2.7.5 Procurement of Commercial Items 17.2.7.9 Standard commercial material, parts, and equipment that are essential to the quality related functions of structures, systems, and components are eviewed 049 and documented for suitability of applicationIbefore selection of the ites andt DELETED lits supplier.l The preparer of the purchase requisition is responsible to clearly identify the commercial ites to be procured and list the receiving inspection requirement. The ites selected must be equal to or better than the original part. If the part is different from or an addition to the original 17.2-28

o WSES-FSAR-UNIT-3 050 design and constitutes a plant modification, thel Project Management GroupI reviews the material application and verifies the part's suttabiltty for the 17.2.7.9 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 leest 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 furnish the following records, as a minimum, to LP&L 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) Decumentation that identifies any procurement requirements which have not been set, together with a description of those nonconformances dispositioned "accept-as-is" ct "repair".

The review, evalustion, and acceptance of the required supplier records 051 furnished to LP&L are described in procedures. Review and acceptance of the 17.2.7.11 P.2 records is performed by thel Plant Quality Group] 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 17.2.8.1 17.2.8.1 General The identification and control of quality related materials, parts, and components is accomplished in accordance with written requirements and applies to materials, parts or components in any stage of fabrication, storage, installation, use or removal from use. Procedures define requireuents for the l

17.2.8.2 identification and control of materials, parts, and components.

Materials, parts, and components identified as nonconforming is handled in 17.2.15 accordance with Subsection 17.2.15.

i 17.2-29 4

USES-FSAR-UNZT-3 17.2.8.2 Requirements for Identification and Control 17.2.8.2.a Identtfication 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 identificatnen ma rkines are employed, they are clear, unambiguous, and indelible.

The inclusion of identification requirements in design documents is checked during design verification by the design 052 organization.

DELETED Procedures include provisions to prevent the use of incorrect or defective g7','8*2 items by requiring that identification be maintained either on the item or on records traceable to the ites. 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 part; 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 i

chemical test reports. When traceability is required, identification will be 17.2.8.3.4 maintained for each part of subdivided items either on the part or in the documentation traceable to the part. Replacement parts and materials 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 seasures to control purchased items and maintain traceability to plant locations.

17.2.8.4 Responsibility for Identification and Control l The Administeative Manager-Nuclear, Plant Administrative Services Department.J 053 provides instructions for the identification and control of~ items for quality g 7 ' ', ' 8

• 2 related applications which are received, stored, and issued se. the plant site.

The Plant Manager provides instructious 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 oroper documentation accompanies quality related items by surveillance of

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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 condestructive 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

VSES-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.

17.2.9.2 Special Processes Subject to Controls 17.2.9.3 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) Heat treating, 056 c) Radiography, e

17.2.9.3.c c

d) Ultrasonic examination, e

e) Eddy current examination, c

f) Magnetic particle examination, c

g) Liquid penetrant examination, d

h) Chemical cleaning, e

1) Concrete placement (seismic applications),

f j) Cadwelding, and h

k) Protective coatings.

17.2.9.3 Special Process Procedures Procedures for performing special processes &re writteo, qualified, and 17*2*9.4 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 testing 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 surveillances or audits.

DELETED Personnel, procedures, and/or equipment connected with special processes are qualified / certified in accordance with applicable codes, standards, and 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 I

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WSES FSAR-UNIT 3 l

Con't.

the special processes to be performed. Certification includes necessary I

training followed by an examination of each individual. The period of validity for certification of personnel is in accordance with criteria described in applicable codes standards, and specifications. Personnel failins retest are not allowed to perform the special process pending recertification.

058 A f.evel III inspector for the type of nondestructive examination (NDE) process t

Table 17.2-1(8) addressed reviews and approves the NDE procedures.l For special processes not i

C **"4

'Y **'* ttag coces or stanoaros, or wnen ene quality requinsents 17.2.9.5~

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, and equipment are maintained by the responsible plant supervisor and reviewed 17.2.17.3.b by the Plant Quality Group.l Special process control records of vendors say be L7.2.9.6 recatned by the vendor or supplied to I.P&L as specified by contract or 060 procurement document.

DELETED 17.2.10 INSPECTION 17.2.10.1 General 17.2.10.1 P.3 Inspection is perforsted during esintenance, modification, repair, material receiving, and storage activities affecting quality related itses at Waterford-3Iin accordance wita reoutrements cettneo in the Quality Assurance l l Manual._] Maintenance and sodification instructions, and work plans axe 17.2.10.3 P.3 revteved by Plant Quality] personnel to assure the inclusion of inspection RIF: 059 requirementa and to verify that methods and criteria are defined.

061 The inspection program at Waterford 3 is developed under the direction of the 17.2.10.2 P.[

Plant Manager and is implemented by the Plant Quality Manager. Normal inspections are performed by qualified personnel reportina to the Plant o,,2

, Quality Manager.l 5peciaL inspections, such ao nuclear fuel receiving, are performed by qualified personnel reportina to the Plant Mdnamer or his 17.2.10.3 P.4 designee._l For quality related activities (e.g., surveillance testing) where 063 dtract inspection is not utilised, the Plant Quality Group eenitors the activities in accordance with established procedures.

g Doc. 1&4 Inspection requiring expertise in a particular area, such as preservice and 17.2.10.3 P.5,. inservice inspection, certain nondestructire testing, nad containment vessel leak rate testa and inspections, may be conducted by offsite LPkt., Middle South Services or contractor personnel. In such Lastances, the inspection activities are conducted under the LP&L Quality Assursace Program or under a

!.P&L approved contractor prograa.

17.2-32

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WSES-FSAR-UNIT-3 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.

Procedures, instructions, and checklists governing inspections provide for the following:

a) Criteria for determining when inspections are required and how they s.e performed; b) Acceptance and rejection criteria; c) Identification of individuals or groups responsible for performing inspections; d) The points during f abrication, erectica, 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 sethod for recording the identity of the recording inspector or data recorder and recording the inspection results aed/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 { reviews quality related procedures to verify the inclusion of accuracy requirements of inspection equipment. The individuals performing the inspections are responsible for assurina that the equipment used meets the criteria noted in the procedure. 1 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 i

acceptance criteria of the procedure.

17.2.10.3 Indirect Inspection l

When it is not possible or practical to verify conformance of processed l

REF: 063 material or products by direct inspection, indirect control is employed by DELETED monitoring processing methods, equipment, and personnel. To ensure adequate i

17.2-33 i

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o WSES-FSAR-UNIT-3 Con't.

control, both direct inspection and process monitoring are used when control j

by only one method is considered inadequate.

17.2.10.4 Inspection by Samplina 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 that a reduction in items inspected or tested can be achieved without jeopardizing the assurance of quality. When a sampling method is used to i

i verify acceptability, the sampling procedures provide justification for the I

sample size and selection process.

17.2.15.7 P.4 17.2.10.5 Inspection of Replaced, Reworked or Repaired Items j

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. l A 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 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 er his designee.

l 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 of quality related structures, systems or components are reviewed to verify 17.2.10.6 P.3 inclusion of inspection requirements, criteria, and hold points. Work in 17.2-34

o USES-7SAR-UN1T-3 process does not proceed past the identified hold points without satisfaction of inspection requirements.

17.2.11 TEST CONTROL 17.2.11.1 17.2.11.1 General 065 Waterford-3 preoperational and startup tests are performed in accordance with 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 satisf actorily in service and salfunctions are identified in a timely manner.

This includes surveillance, functiona'., and special tests.

Procedures define requirements for control of q'uality related tests and 17.2.11.4 methods for implementing Quality Assurance Program requirements.

Test program procedures include criteria for determinina when a test is 17.2.11.4 reqaired and how testing activities are performed. l Test program procedures also require system engineers to review specitications provided by the 066 Architect-Engineer, test guidelines supplied by the NSSS vendor and equipoent technical manuals in order to determine the test equipment accuracy that is 17.2.11.4 necessary to satisfactorily perform a test.

17.2.11.2 Content of Test Procedures Written test procedures for structures, systems, and compocents are prepared in accordance with Regulatory Guides 1.33 acd 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; j

c)

Test prerequisites such as:

1)

Calibrated instruments; 2)

Adequate and appropriate equipment; 067 3)

Trained,loualified. and licensed or certifiedlpersonnel; TBL 17.2-1 Doc-2b 4)

Completeness of ites to be tested; 5)

Suitable and controlled environmental conditions; 6)

Provisions for data collection and storage; and 7)

Status of system.

17.2-35

USES-FSAR-UNfT-3 17.2.11.3 d)

Criteria for determining accuracy requirements of test equipment; 068 e)

Mandatory inspection hold points; J

i 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 Preoperational and startup test procedures are developed by the Waterford-3 070 Startup Group and Plant Staff with appropriate inputs from the NSSS vendor and 17.2.11.2 the Architect-Engineer.

17.2.11.4 Testing activities are performed using test procedures that have been 17.2.5

. reviewed, approved, and released for execution. l Retesting activities are 071 lbased on reviews and direction by the Joint Test Group or the PORC.

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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 individus1 or group. This evaluation determines:

17.2.11.5 17.2.11.6 a)

That the test results are adequate; I

b)

That the recorded data reveals the adequacy of the equipment or system to l

meet the specified requirements in the acceptance criteria; and i

c)

That nonconforming conditions or conditions which deviate from 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 teste (Phase III) and makes recommendations regarding acceptability to the Plant Manager.l The Safety 17.2.11.2 P.4 Meview 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.ll.6.f in accordance with written procedures.

J 17.2.11.4 Test of Modified, Repaired or Replaced Items M dified, repaired or replaced items of quality related equipment ace tested 17*2*3*8 in accordance with the original design and testing requirements or acceptable alternatives.

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17.2-36 j

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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 MEASURING 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 structures, systems, and equipment is controlled in accordance with written procedures or instructions. These procedures define requirements 17.2.12.1 for control of M&TE, 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 o_f quality related structures, systems or components for Waterford-3.1 The 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&TZ 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 review 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.

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, l

l 17.2-37

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l WSES-FSAR-UNIT-3 17.2.12.3 Requirements The cattbration program is designed to ensure the accuracy of M&TE. The 17.2.12.1 calibrati n Pr gram Provides for the prompt detection of inaccuracies and 17 ' ' 12 * *i o ttmely effective corrective action. The calibration program includes the following requirements as a minimum:

077 a) Lists of M&TE which specifically identify items under the calibration 17.2.12.4.2 b) Reference standards and documented procedures for calibrating M&TE.

17.2.12.4.1 P.1 Procedures such as published standard practices, wettten instructions that accompany purchased equipment, or other acceptable instructions may be used.

c) Calibration of M&TE is against standards that have an accuracy greater than four times the required accuracy of the equipment being calibrated. When 17.2.12.4.1 P.2 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.

079 d) M&TE is stored, calibrated, and used in environments which will not 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, manuf actures' recommendations, inherent. stability, purpose or use, and the accuracy required of the equipment. Recalibration is performed on or befqre 080 the designated calibration date. l Reference standards are calibrated by jqualtftedorgantzations.

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 f

calibration is documented.

17.2.12.4.2 g) M&TE is labeled to indicate its control status. I The label indicates the date of last calibration, by whoe it was calibrateo, and when the next 081 calibration is due. When labeling is not practical, an identifying code in 17.2.12.4.2 used.

If neither labellug 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 removed from service. Equipment tested or calibrated by the nonconformins 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 investinations are documented.l M&TE which has been subjected to possible damage is identified as nonconforator and removed free service until_

corrective measures are taken.F M&TE consistently found to be out of 17.2-38 m

7 USES-ISAR-UNIT-3 calibration is identified as nonconforming, removed from service, and repaired or replaced. l Lost / misplaced M&TE is treated the same as M&TE found to be out 083 17.2.12.4.T of caltbration.

1) The following measures are taken for M&TE to maintain accuracy and obtain consistent usults:

084 17.2.12.4.2 a) Environmental and hacdling controls; b) Training and qualification of personnel; c) Checking calibration status b 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 condestructive test equipment) that is used in the sensurement, inspection, and monitoring of structures, systems, and components.

Calibration procedures include at least:

085 DELETED a) The identity of the itt.e to be calibrated; b) Calibration equipment and reference standards to be used; c) Checks, tests, measurements, and acceptance tolerances; d) Sequence of operations; e) Special instructions, when necessary; and f) !.eans for traceability between test equipment and calibration test data.

17.2.12.6 17. 2.1.'. 5 Records The status of M&TE under the calibration program is recorded. Records are

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meintained 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 ites 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.

17.2-39 i

1

o WSES-FSAR-UNIT-3 Equipment and identi;:. cation 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 HANDI.ING, STORAGE, AND SHIPPING 17.2.13.1 17.2.13.1 Ceneral Quality related items are handled, stored, cleaned, and shipped in a manner to prevent deterioration, contaminatien, damage, or loss of identifict. tion.

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 17.2.13.2 Consumables Procedural controls are established for chemicals, reagents, fuels, oil, lubricants, and other consumable s 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 i

l l

The inspection, test, and operating status of structures, systems, and equipment under the scope of the Quality Assurance Program is controlled in 17.2.14.2 accordance with procedures.

17.2.14.2 Requirements 17.2.14.2 The Plant Manager develops procedures relating to the operational status of the plant. These procedures require:

l a) That the status (inoperative, test or operational) of quality relatd

)

17.2.14.4 P.1 systems and equipment be indicated; and 17.2.14.3 P.1 b) That the status of inspections and tests performed on quality related systems and equipment be indicated.

17.2-40

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VSES-FSAR-UNIT-L 17.2.14.3 Identification Systes 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.

• he Technical Specifications establish the 17.2.14.4 P.3 stataa of quality related structures, systems, and ceiponents required for the safe operation of the plant, including provisions foi periodic and nonperiodic tests and inspections of various instruments, structures, components, systems or parts of systems.

Systems and equipment at P.ne plant are controlled to prevent their inadvertent 17,.2.14.4 opetation, 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 1

2.14.4 P. 263 maintenance, testing or modification specify the equipment associated with

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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. Cogaizant plant supervisors, assure that necessary inspections and tests are conducted in their area of responsibility and the status of these inspections and tests is saintained current.

Changes to the requirements of these procedures and instructions, including 17.2.5 alteries the sequence, are controlled by procedures.

'7.2.15 NONCONTORMING MATERIAI.S PARTS, OR COMPONENTS i

17.2.15.1 General 17.2.13.1

/

The Qaality 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 Progras provides for the following actions when quality related materials, parts, components, systems, activities, or services do not conform to drawings, specifications, workmanship standards or other applicable documents:

17.2.15.4 a) Identify the nonconforming items and clearly describe the nonconformance; Doc' nent the nonconformance:

17.2.15.5 b) u 17.2-41

WSES-FSAR-UNIT-3 17.2.15.6 c) Segregate from acceptable items (where practical) and identify the nonconforming items until properly dispositioned to prevent their inadvertent use or tnstallation; 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 17.4.15.3 P.1 g) Notify affected organizations.

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 documenting, segregating, dispositioning, and reviewing nonconformances and I

17.2.15.2 P.1 for ensuring that corrective action is taken by cognizant persons or organiza-j tions.

l 087 The Onsite Safety Review Subgroup of the Proj1ct Management Department pr vides an independent review of nonconformances, disposition, and closeout 17*2*15*** P*2 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 reportability determination, the Nuclear Operations Quality Assurance Group reports the ites to the NRC.

088 The Plant Quality Manager is responsible for conducting inspections to verifv adequate implementation of corrective action concerning nonconformances d The 17.2.16.2 P.2 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 nonconformances.

17.2.15.3 Quality Trends 089 17.2.15.2 P.5 Nonconformance 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 Reworked, repaired, and replaced items are inspected and tested in s uordance with the original inspection and test requirements or acceptable alte enatives.

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 prsctical, removed from 17.2-42 m

u L'SES-FSAR-UNIT-3 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 ites; b)

Description of the nonconformance; 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 ind 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 1er 10 CFR Part 21, (3) any gross or widespread noncompliance with procedG.u tequirements that negates the effectiveness of quality assurance controls, or (4) any condition which has recurred with such a frequency that it indicates past corrective actiors (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 i

safety. Those conditions adverse to quality deters had 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:

17,2-43

u 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 o be adverse to quality within his area of responsibility; b) Supervisory review and classification of reported conditions adverse to quality; c) Correction of adverse conditions; and d) Documenting conditions 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 Plant Quality Manager verifies impletentacion of corrective action for REF: 088 C nditi ns adverse to quality within the P ant (the Corporate Quality l

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 Si2nificant 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 causa immediate temporary corrective action to be taken.

The Quau ty Assurance Section makes a determination of reportability under REF: 087 10 CFR Part 21, 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 itees or of activities affecting quality and those 17.2.17.3.f records required by the Technical Specifications. LP&L has established a 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 managemant of quality assurance records.

l 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 irposed upon the contractor or supplier / vendor. Each organization responsible i

17.2.17.2.c for the receipt of qualit.y assurance records designates a responsible person 17.2-44 O

e-WSES-FSAR-UNIT-3 or group for the review, acceptance, and forward'us for further processing of those quality assurance records they review.

17,2.17.2 Types of Records 17.2.17.3 P.7 9"*l'cy assurance records include but are not limited to the following:

a) Records completed during the design and construction of the plant, including design drawings and specifications; construction loss and results of reviews, inspections, tests, audits and monitoring of work performance; 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 equipeent; procurement documents and specifications; galibration records and nonconformance reports 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; d) Information related to conditions adverse to quality; 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 a

)

M

WSES-FSAR-UNIT-3 17.2.17.5 Retention and Storage of Records Records are maintained current and complete and made available by applicable i

17.2*17*6 contractors a-4 suppliers for audit by LP&L or its representative at any Those records are maintained in facilities that provide a 17.2.4.3.e reasonable ti e.

suitable environment to minimize deterioration and to prevent damage or loss.

l 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.

17.2.17.5 Quality assurance records are identifiable and retrievable. Procedures for 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 esployed, 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 indicated in a records index.

Records which may not be sent to and stored at the plant but retained by the 092 quality related 8upPliers and contractors include but are not limited to the DELETED 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 a 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 after being retained in accordance with contractural 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.

1 17.2-46 e

o WSES-FSAR-UNIT-3 17.2.18 AUDITS 17.2.18.1 General The Corporate Quality Assurance Manager has the authority and organizational 17.2.18.2 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.

17.2.13.1 The audit system is designed to satisfy the requirements of 10 CFR 50, Appendix B, and the Technical Specifications. The Senior Vice President-Nuclear Operations has delegated to the Corporate Quality Assurance 17.2.1.3.0.1.e 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 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 weaknesses and nonconformances; 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 organtrations and its contract 3rs/ suppliers comply with the Quality Assurance Program requirements. Audite 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 evaluar. ion 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, procadures, and instructions; the effectiveness of their implem5ntation, and the compliance with policy directives.

17.2-47 i

O WSES-fSAR-UNIT-3 1

17.2.18.3 P.4 Audits are performed in areas where 10 CFR $0, 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 procedures; f) Calibration of measuring and test equipment; and g) InterfacecontrolamongLP&Lorganizationsandcontractors/cbasultants.

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.n Table 17.2-1.

17.2.18.3 Audit Plannina and Schedulina 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 1718*4 is determined by the requirement to ensure effective qv411ty assurance during the startup testing and operational phases. The audit schedule is approved by 17.2.18.2 the Corporate Quality Assurance Manager.

71.2.18.5 P.1 Quality Assurance audits are planned and conducted in accordance with approved procedures. Audit planning includes preparation of checklists or procedures that will ensure consistency and completeness in the evaluation, iUnresolved 093 teems notea '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 Perfgemance Audits are performed using prepared checklists or audit procedures.

The audit 394 checkiist is a guide and,does not restrict the audit scope when additional TdL 17.2-1 (16) investigation is needed.} Audit nottfication, pre-audit conference, audit process, and post-audit conference is in accordance with established 17.2.18.6 precedures.

i 17.2-48 j

l 1

USES-FSAR-UNIT-3 17.2.18.5 Audit Personnel 095 Audits are conducted by qualified LPEL auditors who are experienced, trained, YBL 17.2-1 (16) and familiar with requirements and standards applicable to the area or (17),activitybeingaudited.[~Auditteammembersareindependentofanydirect 17.2.18.1 responstotitttes tor tne activities which they audit.l Auditors participate in 096 the LP&L Auditor Training Program and maintain proficiency through review and study of codet and standards related to quality assurance and through active 17.2.2.6 participation in the audit progras.l LPEL lead auditors are certified in TBL 17.2-1 (16) accordance with Regulatory Guide 1.146.

Audit teams may include consultants and technical specialists not certified as auditors so long as they are under direct supervision af a certified lead auditor.

l 17.2.18.6 Audit Reportina and Follow-up 1

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 to 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.

l 097 Distribution includes the senior Vice Fresident-Nuclear Operations, the 17.2.18.7 Corporate Quality Assurance Manager and the manager responsibls for corrective action in the area audited. l It is the responsibility of the cogsiaant 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 crective 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 ia the audit 17.2.18.9 report and corrective actions and reaudits are documented with reference to the original audit.

17.2.18.7 Manaaesamt 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) Operations. In combination with regular reports and assessments provided by thm Corporate Quality Assursace henager, these pregram audits enable the 4

Ser.ior Vice President-operations to adequately evaluate the effectiveness of the Quality Assursace Program.

P 099 17.2.18.8 Analysis of Audit Data 17.2.1.3.0.lm 17.2.1.1 P.2 Audit data is analyzed by the Corporate Quality Assurance Manager who reports any significant quality probless and the effectiveness of the Quality Assurance Program, including the need for reaudit of deficient areas, to the Senior Vice President-Nuclear Operations.

1 17.2-49 I

e

]

l r.

~ _ _ _ _ _ _ -

4 WSES-FSAR-IRIIT-3 TASIE 17.2-1 (Sheet I of F)

REGURATORY GUIDAllCE DOCLNENTS Docessent Comusent I.

Appendia 3 to 10 CFR 50 "Quality Assurance Criteria No esceptions.

100 go,g,,g,,,p.,,,pg,g,,,,y,,,,,,,,,,,,,,,pg,,,.

TBL 17.2-1 (1) 2.

A.

Regulatory Guide 3.5, Revision 3-5, I.

The atualifications of personnel in the September 1975, "Personnel Seleition and Nealth Physics Radweste, and Chemistry Training" (Endorses AIISI NIS,'s-19FI)

Departments are in accordance with AllSI N18.3-19FI as endorsed by this Regulatory Guide and/or as shown in FSAR Chapter 13.

B.

ANSI /ANS 3.1-1978, "Seandard for Selection and Training of Personnel for Nuclear Power Plants" 2.

The qualifications of personnel other than those in the Ilealth Physics, Radmaste and Chemistry Departments are in accorden(c with AIISI/AIIS 3.1-1978.

Specific commitments are shown in FSAR Chapter 13.

3.

IIcebers of the Independent Safety Ensincering Group acet the qualitication requirements of huREG-OF31-1940 instead of section 4.7.2 of AllSI/ Alls 3.1-1978.

i

WSES-FSAR-UNIT-3 TABLE 17.2-3 (Sheet 2 of 7)

RECtllATORY CUIDANCE DOCTRENTS Docuecat Comment 3.

Regulatory Guide 1.33, August 1972, "Quality I.

LP&L applies the provisions of this Assuranac Requirements for the lastallation, Begulatory Guide and its endorsed stanJard Inspection and Testing of Instrumentation and to Class IE eqwipment only.

Electrical Equipment" (Endorses ANSI N45.2.4-1972) 2.

Each quality related item of process instrumentation is identified with a unique number. This number is used in instrument maintenance records so that current calibration status, including data such as the date of the calibration and identity of the persea that performed the calibration, can be readily determined. Such information may also be contained on tags or labels that may be attached to installed iAALrumeRtatioE.

4.

RegulLtory Guide 1.33 Rev. 2, February 1978, "Quality 1.

ANSI N18.7 references certain other Assurance Program Requirements (Operatieas)" (Eadorses standards to which LP&L takes exception.

ANSI NI8.7-1976)

LP&L's esceptions and appropriate alternatives are listed in this table.

2.

LP&L complies with Regulatory Position C.3 of Regulatory Guide 1.33 escept under emergency conditions in whieb case LP&L shall submit proposed changes to Technical Specifications or license amenderais in accordance eith 10 CFR 50.54 and/or 10 CFR 50.71.

WSES-FSAR-t2EIT-3 TABli 87.2-3 (Sheet 3 of F)

RECULATORY CUIDA38CE DocurENTS Document Comment 4.

3.

ANSI N18.7, Ses-tion 5.2. 7, Haantenarwe and "lBL 17.2-1 (4-3).

Modification: LP&L preplan; and performs mainte.a c of equipac.t 4. accords.c, with written procedures escept in emergency or abnormal conditions where innsediate action 4

is required to:

a.

Protect the health and safety of the public.

b.

Protect equipment or personnel, c.

Prevent the deterioration of plant conditions to a potentially unsafe or wastable level.

4.

AltSI NIS.7, Section 5.2.7.1. Maintenance Prosram: Repair of qualit= related equipw at will be accomplished in accordance 5

mammals.

5.

LP&L will provide procedures for the 6

activitin im Wadis A of Resulatwy hik I.33 as discussed in Sectio. C-3 of this Regulatory Guide. Nowever, LP&L does not consider all activitics listed to be "safety related" (e.g., activities in F.c).

W5ES-FSAR-tBitT-3 TAtlE 17.2-1 (Sheet 4 of F)

RfCU!ATORY CU'Dr.NCE DOCIDEENTS Docunent Comment 5.

Regulatory Guide 3.37, fearch 1973, "Quality No esceptions.

Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water Cooled Nuclear Plants" (Endorses ANSI N45.2.5-1973)

For the storage of new fuel assemblies and 6.

Regulatory Cuide 1.38 Rev. 2, May 1977, "Quality neutron startup sources, LP&L teamits to the Assurance Requirceents for Packaging, Shipping and storage requieements oC Level 5 of ANk!

Receiving, Se m age and Ilandling of Itces for Water N45.2.2-1972 less the fleeding preventien Cooled Nuclear Power Plants" (Endorses ANSI requirements and will minimi e dust and other N45.2.2-1972) particles contacting these items ty placing a fire retardant polyethylene cover ove; t%ese Items or the cell loretions i.e whnth abe items are stored.

The zone designations of Section 2.I of F.

Regulatory Guide 1.39. Rev. 2. Sept-aber 1977 N45.2.3+1973 and the requirescots associated with "Nousekeeping Requirceents for Water Cooled Nuclear each mone are not cervictent with the Power Plants" (Endorses ANSI N45.2.3-1973) requirceents for an operating plant.

Instead, procedures or instructious for housekeeping activities which include the applicable requirements outsined in Section 2.1 of N45.7.3 and which talte into secount rad.ation control considerations, security considerations, and personnel and equipment safety considerations are developed on a came basis.

~

WSEti-FSAA-tailT-3 TABLE 17.2-1 (Sheet 5.cf 7)

RECUIATORY CUIDANCE DOCtfENTS Dornment Comment 102 8.

Regulatory Guide 1.ss,Rev.

I, September 19s0, Startup testing personnel are qualified to "Qualification of Nuclear Power Plant inspection.

Regulatory Guide 1.58, Rev. O, August 1973 as TBL 17.2-1 (8)

Examination and Testing Personnel" (Endorses ANSI described in section 14.2 of the Waterf ord-3 ISAR M45.2.6-1978) with the exception that the required physical reezamination will be performed every two years and not annually as specified.

9.

Regulatory Guide 3.64. Rev. 2, June 1976, "Quality No exceptions.

Assurance Requirceents for the Design of Nuclear Power Plants" (Endorses ANSI N45.2.ll-1974) 10.

Regulatory Guide 1.70, Rev. 2, September 1975, No exceptions.

"Standard Forest and Contents of Safety Analysis Reports for Nuclear Power Plants" II.

Regulatory Guide 1.74, February 1974, "Quality No caceptions.

Assurance Terms and Definitions" (Esdorses ANSI N45.2.IO-1973) 12.

Regulatory Guide I.88, Rev. 2, October 1976, No caceptions.

"Collection, Stora3e and Maintenance of NucIcar Power Plant Quality Assurance Records (Endorses ANSI M45.2.9-1974)

WSES-FSAR-tBIIT-3 TASLE 17.2-1 (Sheet 6 of 7)

REctllATORY CUIDAleCE IKKIMENTS Document Co-ent g g)3 13.

• caulatory Guide 1.94, Rev.

I, April 79F6, "Qinality a) No esceptions during constauction phase.

g g Atsierance Requirement s for Installation, 3mspection, and Testing of Structural Concrete and structural b) LP&L takes esception to tine following Steel During Construction Phasr of Nuclear Pouer paragraphs of N45.2.5:

Plants" (Endorses ANSI M45.2.5-1974) 3.

4.8 la-process tests on concrete and reinforcing steel - table R regesired in process tests. The course and fine aggregate in-process tests will not be performed during the maintenance and modification program dise to the seat!

questity of concrete to be produced.

The aggregates wi!I be tested for con-formance to ASTM-C-33 where purchased.

14.

Regulatory Guide 1.!!6, Rev. 0-R, May 1977, "Qinality llo enceptions.

Assurance Requirements for Intellation, Inspection ass.1 Testing of Mechmeical Equiparat med Systems" (Endosses AlfSI N45.2.5-1975) 15.

Regulatory Guide 1.123 Rev. 1. July 1977, "Qisality No exceptions.

Assurance Requirements for Control of Procurement of items and Services for Bluclear P,wer Plants" (Endorses ANSI N45.2.13-1976) 16.

Regulatory Guide 1.144, Rev.

1, September 1980, LP&L takes esception to the following paragraphs "Auditing of Qisality Assurance Programs for Nuclear of M45.2.12:

Pouer Plants" (Endorses ANSI N45.2.12-1977) 1.

2.3 - Training - Te<haical specialists wito assist in performing audsts in their area of special empertise well not neces=arily be trained in ausdit te<heiques; however, they will atuays be accompamaed by i

a trained and quals fied andator.

.c

c-. - -

-._ _. -...= _~.

. ~ ~

=

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4 l

t#5ES-FSAR-tellT-3 TAsti 17.2-1 (Sincet 7 of F) i REGutATORY CtflDAIICE DOCISENTS i

Consent Do(nament i

i 2.

4.4 - Report s - Anseit reports will t>e I6.

issued witInis 30 wortting days of tine yest I

med6t meeting.

l 104 TBL 17.2-1 (16-3) i 17.

Regulatory Guide 1.lM, Aegnet 1984, "Qualificatises lie exceptions.

ef Quelity Assurance Program Aedit Perseemet for Iloclear Feuer Fleets" (Endorses AIISI 3865.2.23-1978) i i

1 I

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f l

4

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WSES-FSAR-UNIT-3 TAtti 17.2-2 (Sheet I of 3)

LP&L mlCIIAR OPERATIONS QtlALITY ASSURANCE PROGRAM DoctDENTATION Identification Descripties Ayproval and Centrol

~

I.

FSAR Chapter IF.2, "Quality Assurance A description of the Nuclear Prepared by the Quality Assurance g

During the operating Phase" Operations Quality Assurance Secties and coordinated enth Program.

p; sat operations and support organizations. Approved by the Semier Vice President-Nuclear Operations ame centrolled by Liccasing.

REF: 002 2.

Quality Assuraece Ma mal The Quality Assurance Manual Prepared by the quality defines the Nuclear Operations Assurance Secties. Coordsmated Quality Assuraece Program, with affccted organizations and assiges rescensibilities to submitted to the Semier Vice various LP&L erganizations for President-Nuclear Operations for program implementaties, and approval by the Corporate defines regstreerats for esality Quality Assurance Manager.

related activities.

Issued and controlled by tbc Quality Assurance Secties.

4 3.

Waterford-3 Plant Operating Meenal A meenal coesisting of a set of Prepared by (egeizant plaat precedures which prescribe groups /departerets. Reviewed reysired aspects of pleet by the Plant Quality Departeret management and operation. Tb6s and FORC. Approved by the Plant moeuel provides the mechanise Manager.

Issued and centrolled threagh which the administrative by pleet document teatrol, centrols med goality assurance Selected precedures that reysirements are implemented impleerst the QA Progree during the operation of regsire review med concurrence Waterford-3.

by the Corporate QA Manager er bis desigare before issue.

WSES-TSAR-tMIT-3 TABLE 17.2-2 (Sheet 2 of 3) 1.P&L NUCIIAR OPERATIONS QUALITT ASStmAIICE P90 GRAM DOCtBENTATIUM Identification Description Aggreval and Centrol 5

4.

Quality Assurance Secties Procedures A set of proc-dures (Q4SPs)

Prepared, issued, and sentrolled Manual prepared med issued to specify by the Quality Assursore med control the internal Section. Coordsmated with other activities of the Quality organizations as applicable.

Assurance Secties. Included are Approved by the Corporate precedures for nuclear Quality Assuraece Manager.

• • "**""*****'"I*'**'

10 by the Corporate Purchasing and Materials secties.

REF: 001 5.

Startup Administrative Precedures A set of precedures (SAPS) which Prepared by ceseirant indsviduals identify to LP&L contracter i the Startup Group. Reviewed groups and others, their by the Startup Joint Test Creep respective respeesibilities and and approved by the Startup the procedures whirb gewere the Nemager. Issued and coetrolled administraties of the Startup by Startup Documret Centrol.

Test Program. These Procedures which govere psality administrative precedures gewere related activitica are reviewed startup activities, prescribe and coecurred with by the areas of reopensibility, Quality Assurance Namager er his identify the tashs to be designee befere issut, performed, and outline the interface precedures.

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Project h eagement Procedures A set of precedures which Psepared by cogeiraat personnel prescribe activities med within the reeject Namageerst D RETED reopensibilities within the Group. Approved, issued, and Project Hamagement Group.

centrolled by the Freject Namager and concurred with by the Correrate (>sality Assurance Manager.

6 7.

is cIcar services rrecedures a set of procedures which Frepared by cessiemet persommel prescribe activities and within the 18eclear Services respeesthilites within the Creep. Approved, issued, med leuclear Services Creep.

centrolled by the IIe< Icar Services Manager and coecurred with by the Corporate Quality Assurance Nanager.

NOTE: See added procedures m

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QUALITY ASSURANCE MANUAL COMPLIANCE WITH 10 CTR 50. APPENDIX B r

10 CFR 50, Appendix B L

Criterion Quality Assurance Manual I '.

Organization Chapter-1.0 Defines the organizational structure and delineates the authority and responsibilities of 4

individuals and organizations performing quality assurance activities.

II.

Quality Assurance Chapter-2.0 Defines the scope of the Progree Quality Assurance Program and establishes that activities affecting quality related structures, systems, and components will be conducted in r

accordance with approved j

procedures.

l III.

Design Control Chapter-3.0 Defines requirements for the control of the desisa of quality related structures, systems, and i

components including the design of plant modifications.

I IV.

Procurement Chapter-4.0 Defines requirements for Document the control of procurement Control of quality related structures, systems, components, saterials, and se rvices.

V.

Instructions, Chapter-5.0 Defines requirements for I

Procedures, and the development and control Drawings of instructions, procedures, and drawings.

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TABLE 17.2-3 (Sheet 2 of 3) f I

i QUALITY ASSURANCE PUORLAL COMPLIANCE WITH 10 CTR 50. APPENDIX B 10 CTR $0, Appendix B Criterion Quality Assurance Manual VI.

Document Control Chapter 6.0 Defines requirements for i

the control of documents for quality related 1

structures, systees, and components and identifies 4

the types of documents to be controlled.

l VII.

Control of Pur-Chapter-7.0 Defines requirements for chased Material, control of purchased Equipeent, and material, equipment, and Se rvices services, including control of suppliers and receiving inspection.

t i

VIII.

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and Control of control of materials, parts Materials, Parts, and components.

and Components I

IX.

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processes including i

j welding, heat treating, j

NDE, and chemical cleaning, i

l j

X.

Inspection Chapter-10.0 Defines requirements for 4

inspection of materials and 1

activities important to i

safety including criteria for determining when and j

how inspections are performed.

XI.

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QUALITY ASSURANCE MANUAL COMPLIANCE WITH 10 CFR 50, APPENDIX B 10 CTR 50, Appendix 8 Criterion Quality Assurance Manual 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 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, Status test, and operating status of quality related items 1

and equipment.

XV.

Nonconforming Chapter-15.0 Defines requirements for l

Material, Parts, identification, or Components documentation, segregation, review, and disposition of l

nonconforming materials, parts, and components.

i XVI.

Corrective Action Chapter-16.0 Defines requirements for I

establishment of an j

effective corrective action program with follovup to verify proper implementation.

XVII.

Quality Assurance Chapter-17.0 Defines requirements for a i

Records quality related records i

program including identification of types and content of records.

1 XVIII.

Audits Chapter-18.0 Defines requirements for audits of quality related i

activities including audit program scope and methods.

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A3

Attcchment #3 REMARKS DOCUMENT COMMENT DESCRIPTION 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 presently contained in Section V and VI of the Nuclear Operations Management Manual (NOMM) have replaced the Nuclear Operations Department Quality Assurance Manual. Sections V and VI of the NOMM define the Nuclear Operations Department Quality Assurance Program. The accessibility to the QA program description has been enhanced by the inclusion into the NOMM. Additionally, all Nuclear Operations Sr. Management are responsible to concur / approve the NOMM thereby assuring their ongoing cognizance of the QA Program.

003 The term "safety related" has replaccd "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".

The Nuclear Operations Management Manual provides the definitions and scope of quality and safety related as they relate to the LP&L Nuclear Quality Program.

004 Verification activities are performed by individuals other than personnel in the Quality Assurance Group. Verifications in the form of inspections are performed by plant staff personnel as described in the Technical Specifications. Other verifications such as surveillances may be performed by groups such as ISEG or engineering.

The Quality Assurance Group J

currently performs audits, reviews, in?pections and surveillances as required.

005 Those individuals or organizations no langer applicable since the commencement of the operations phase have been deleted.

The remaining individuals and organizations havc bsen listed in the following paragraphs.

006 This thange documents the reorganization of the Nuclear Operations Department at the Senior Manager level.

007 Ihis sub-section was relocated to Section 17.2.2 where it is more applicable.

Reference comment 098 for basis of change.

1 Page 1

REMARKS DOCUMENT COMMENT DESCRIPTION 008 Euitorial change only. This paragraph does not contain additional responsibilities or requirements.

009 Ref. Attachment #2, 17.2.1.2.5.1 and 17.2.1.2.6.

The responsibilities for the Nuclear QA Manager and the Nuclear Operations Plant Manager to serve as members of the Safety Review Committee have been deleted. As shown in Attachment fl. 17.2.1.1, the Sr. Vice President - Nuclear Operacions appoints the Chairaan and members of the Safety Review Committee. The Waterford 3 Technical Specifications define the membership qualification requirements as ANSI /ANS 3.1 -

1978, Section 4.7.

The Sr. Vice President utilizes t.tese guidelines in his selection of SRC members.

010 This responsibility was deleted because it was a duplication of item c.

011 Based on inquiries regarding the change of the qualification requirements for the Nuclear Quality Assurance Manager during the NRC review of the December, 1987 QA Program submittal, LP&L will submit a change to revert to those listed in the previously accepted QA Program description (FUSAR, 12/18/86).

The qualification requirements will read as follows:

The principal qualifications for the Nuclear Quclity Assurance Manager will include as a minimum a)

Graduate of a college or university with a Bachelor's degree in an engineering, science or related field, or equivalent capabilities; 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 procedureo; 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.

Page 2

REMARKS DOCUMENT COMMENT DESCRIPTION 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 i

responsibilities have been redistributed as shown.

015 Deleted. Ref. 009 016 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.ss shown.

020 This responsibility is common to all of the Nuclear Operation's organizations.

021 This responsibility was deleted.

Scheduling is performed by the Planning and Scheduling section under the Plant Manager -

Euclear 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 Nui: lear Services support.

Page 3

REMARKS DOCUMENT 1

C0KMENT DESCRIPTION 024 The Completion Manager - Nuclear position was deleted. There are no operational responsibilities associated with this position.

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 showa in Tabla. 17.2-2, 027 This section was revised to incorporate the reorganization.

1 028 The responsibility for assuring that training is conducted is common to all Senior Management, 029 This requirement was changed to more accurately reflect the requirement of ANSI N45.2.6-1978 as endorsed by Regulatory j

Guide 1.58, Rev. 1, 1980 and particularly Regulatory Position C-10 for the use of "Determination of Initial Capability" in lieu of require 4 education and experience.

030 This paragraph was deleted. The requirement is redundant with that contained in 17.2.18.3.

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.

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 Piants" and Branch Technical P0sition CMEB 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants."

Page 4

REMARKS DOCUMENT COMMENT DESCRIPTION 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 incluaive 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 direction for 1.rocedural control of safety related procedures 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.

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.

041 The responsibilities for procedure review were redefined. As documented in Amendnent #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 i

plant procedures.

The Quality Assurance Group reviews other selected Nuclear Operations Procedures.

Page 5

REMARKS DOCUMENT COMMEN T DESCRIPTION 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 uca 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 N0EPs, N0 SAPS, NOCPs and NPCPs as defined in table 17.2-2.

046 The evaluations of suppliers are conducted through audits and surveillances by Quality Assurance Group personnel appropriately qualified and certified in accordance with ANSI N45.2.23-1978.

047 The audit program, as defined by ANSI N45.2.23-1978 encourages the use of technical specialists when conducting audit 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 m:sst 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.

049 Deletion of the requirement to review commercial item suitability prior to st pplier or item selection does not af fect 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. This responsibility has been shifted to the Nuclear Operations Engineering Group or Plant Engineering.

Page 6

REMARKS DOCUMENT COMMENT DESCRIPTION 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. LP6L 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 surveillances.

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 whi i 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 parsonnel 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 i

requirements. Further, it states that the requirements of applicable codes and standards...are snecified or referenced in the procedures or instructions.

058 The requirement for a Level III to review and approve inspection procedures is not isolated to NDE only. The requirement for the review of inspection procedures is contained in Regulatory Position C.5 of Regulatory Guide 1.58, Revision 1 which LP&L has committed to per Table 17.2-1, Document 8.

Page 7

REMARKS DOCUMENT COMMENT DESCRIPTION 059 The retention of qualificatioa records is defined by 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.

060 Special process control records to be supplied to LP&L would be specified in the applicable procurement documents as stated in 17.2.4.3.e.

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 The functions performed by the Plant Quality Group have been incorporated into the Quality Assurance Group activities. The requirements for indirect inspection and process monitoring are included in the Nuclear Operations Management Manual. LP&L does not take exception to those commitments.

Reference Table 17.2-1 Documents 1 and 4.

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.

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 c'l inclusive or no longer applicabic.

Page 8

REMARKS DOCUMENT COMMENT DESCRIPTION 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.

069 Tast requirements and acceptance criteria are provided or approved by the crganization 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 or 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 requirew:nts 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 evcluation 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 recordance with written procedures.

075 The plant department heads or supervisors are assigned these responsibilities through the implementing procedures for which the Nuclear Plant Operations Manager is responsible.

Page 9

_ ~ _. _ _ _. _. - _ _ _

REMARKS DOCUMENT COMMENT DESCRIPTION

-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 surveillances 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...".

i 078 Due to the reorganization, this title has changed. To preclude confusion and permit authorizetion 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.

P 080 Organizations performing calibrations for reference standards would be determined qualified through the audit program if the organization was internal or through the Supplier Audit Program if external. Therefore, this requirement is satisfied by 17.2.7 or 17.2.18.

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 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 subject to possible damage. The calibration would determine if the equipment is adequate or whether further corrective actions would be necessary.

Page 10

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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 liste'd 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 responsibile for the 10CFR21 reportability 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.

i 088 The Nuclear QA Manager is responsible for verifying the adequate implementation of corrective actions per 17.2.16.2.

i 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.

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 eutablishment and administration of the Nuclear Operations Records Management System.

092 The record retention riquirements for suppliers is defined within the procurement documents. The requirements may vary from those listed in 1".2.17.5 and were therefore deleted.

Page 11 L-

.~

REMARKS DOCUMENT COMMENT 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.

i 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 i

experienced, trained and familiar with requirements and standards applicable to the area or activity being audited.

096 The training of LP&L suditors is conducted in accordance with Quality Assetance Procedures as stated in 17.2.2.6.

These procedures define training, recertification and audit participation requirements.

097 The Sr. Vice President - Nuclear Operations was deleted from the audit report distribution. As stated in 17.2.1.1, the Sr.

Vice President - Nucletr Operations is appraised of the the status of the QA Program through status summaries submitted by the Nuclear QA Manager.

098 The annual Management Review of the LPGL 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 of 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.

I l

Page 12

- _ _ _. _-~

REHARKS DOCUMENT COMMENT 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 to proceed under specified conditions..., but precludes dependence on the item for safety purposes.

Therefore, the intent of 10CFR50 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.

105

Reference:

(Revision 1, 12/87) Para. 17.2.1.1 and Figure 17.2-1.

The Safety Review Committee is shown as administrative 1y reporting to the Nuclear Services Manager with a communicative line to the Sr. Vice President - Nuclear Operations. The administrative function in no way detracts from the reporting responsibility to the Sr. Vice President -

Nuclear Operations.

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