ML17346B076

Rev 8 to Topical QA Rept.

ML17346B076
Person / Time
Site:	Saint Lucie, Turkey Point, 05000000
Issue date:	06/10/1985
From:	FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML17346B075	List: ML17346B074 ML17346B076
References
(FPL-NQA-100A), FPLTQAR-1-76A, NUDOCS 8506140040
Download: ML17346B076 (153)

Text

FPLTQAR 1 -76A (FPL-NQA-100A)

REVISION 8 3VNE 10, 19SS o ica uai ssur ance e or 8506i40040 850610 05000250 PDR ADOCK FLORIDA POWER 5 LIGHT CCNPANY P I

TOPICAL QUALMYASSURANCE REPORT Rev.

TABLE OF CONTENTS June 10, 1985 FLORIDA POWER a LIGHT COMPANY Page 1

REVISION SUBJECT NUMBER DATE Title Page 3une 10, 1980 Abstract 3une 10, 1980 NRC Staff Evaluation Letter November 20, 1980 Table of Contents 3une 10, 1985 I Policy Statement 3une 10, 1984 Introduction 3une 10, l980 Topical Quality Requirements TQR 1.0 Organization Oune lo, l989 TQR 2.0 Quality Assurance Program 3une 10, 1985 TQR 3.0 Design Control May 7, 1982

'TQR 0.0 'rocurement Document Control March 31, 1981 TQR 5.0 Instruction, Procedures, and Drawings 5 3une 10, 1985 I TQR 6.0. Document Control June 10, 1983 TQR 70 Control of Purchased Items 3une 10, 1980 and Services TQR 8.0 Identification and Control of 3une 10, 1980 Materials, Parts, and Components TQR 9.0 Control of Special Processes 5 June 10, 1980 TQR 10.0 Inspection 6 3une 10, 1985 TQR 11.0 Test Control 1 3une 10, 1983 TQR 12.0 Control of Measuring and Test Equipment 3 3une 10, 1985 TQR 13.0 Handling, Storage, and Shipping 3une 10, 1980 TQR 10.0 Inspection, Test, and Operating Status 5 Oune lO, 1989 TQR 15.0 Nonconforming Materials, Parts, 5 3une 10, 1985 or Components

TOPICAL QUALITYASSURANCE REPORT Rev.

Date 3une 10, 1985 FLORIDA POWER S LIGHT COMPANY TABLE OF CONTENTS Page of 2 2 REVISION SUB3ECT NUMBER DATE TQR 16.0 Corrective Action 3une 10, 1983 TQR 17.0 Quality Assurance Records 3une 10, 1985 TQR 18.0 Audits 3une 10, 1980 Appendices Organizations and Figures Figure l-l: Organization of Departments 3une 10, 1985 Affecting Quality Qualification and Experience Requirements 3une 10, 1983 for QA Personnel C - Baseline Document Matrix 3une.10, 1980 D - Cancelled i%lay 7, 198 E - List of Corporate QA Procedures (QPs) oune lo, i935 F Topics to be Addressed in Safety Analysis i%lay 7, 1982 Reports o:

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TOPICAL QUALITYASSURANCE REPORT Rev.

ABSTRACT gate 3une l0, 1984 FLORIDA POWER d LIGHT COMPANY Page l Gf Florida Power dc Light Company (FPL) has established and implemented a Quality Assurance Program to provide assurance that the design, procurement, modification and operation of nuclear power plants conforms with applicable regulatory requirements.

The FPL Quality Assurance Program described in this Topical Report is in compliance with the requirements of Appendix B to 10 CFR Part 50.

The FPL Quality Assurance Program meets the requirements provided by the NRC Regulatory Guidance and Industry Standards as listed in Appendix C of this Topical Quality Assurance Report.

IO UNITED STATES

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" NUCLEAR REGULATORY COMMISSION REGION II g 5+)( 101 MARIETTA STREET, N.W.

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11144 November 20, 1984 Florida Power and Light Company ATTN: Mr. J. W. Williams, Jr.

Group Vice President Nuclear Energy Department P. 0. Box 14000 Juno Beach, FL 33408 Gentlemen:

SUBJECT:

FPKL TOPICAL gA PROGRAM UPDATE

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Your letter to this office dated June 8, 1984, (L-84-151) transmitted the FPSL Topical guality Assurance Report (FPL-NgA-100A), Revision 7, in accordance with 10 CFR 50.54(a). This report revised the current accepted quality assurance program description for Turkey Point and St. Lucie (Docket Nos. 50-250, 50-251, 50-335, and 50-389). Additional clarifying information was submitted in your letter dated September 13, 1984, (L-84-241) in response to questions transmitted in a letter from this office dated August 8, 1984. Based on a telephone conversation between Mr. J. B. Harper and Mr. G. A. Belisle on October 19, 1984, it is our understanding that the response to question 4 has been amended to read as follows:

Appendix A Figure:1-1 has been revised to reflect the correct new titles. Paragraph 1.2.3.2 has been revised to delete the Ass.istant Manager of gA-Turkey Point and Paragraph 1.2.3.2.c has been added to describe the duties -of the Superintendent of gA-Turkey Point. Further, Appendix A and Paragraph 1.2.3.2 have been revised to show'he correct titles and reporting relationships.

Our review of this information indicates that your topical gA program con'inues to satisfy 10 CFR 50 Appendix B requirements and is therefore acceptable.

We appreciate your timely submittal of the 'information required by 10 CFR 50.54(a). Please contact me .if you have any questions regarding our review of your submittal.

Sincerely, ohn A. Olshinski, Director Division of Reactor Projects cc: (See Page '2)

TOPICAL QUALITYASSURANCE REPORT Rev.

TABLE OF CONTENTS 3une 10, 1985 FLORIDA POWER S LIGHT COMPANY Page of 1 2 REVISION SUBJECT NUMBER DATE Title Page 3une 10, 1980 Abstract 3une 10, 1980 NRC Staff Evaluation Letter November 20, 1980 Table of Contents 3une 10, 1985 I Policy Statement 3une 10, 1980 Introduction 3une 10, 1980 Topical Quality Requirements TQR 1.0 Organization June 10, 1985 TQR 2.0: Quality Assurance Program June 10, 1985 )

TQR 3.0 Design Control May 7, 1982 T.QR 0.0 Procurement Document Control March 31, 1981-TQR 5.0 Instruction, Procedures, and Drawings 3une 10, 1985 I TQR 6.0 Document Control June 10; 1983 TQR 7.0 Control of Purchased Items 3une 10, 1980 and Services TQR 8.0 Identification and Control of 3une 10, 1980 Materials, Parts, and Components TQR 9.0 Control of Special Processes 3une 10, 1980 TQR 10.0 Inspection 3une 10, 1985 TQR 11.0 Test Control June 10; 1983 TQR 12.0 Control of Measuring and Test Equipment 3 3une 10, 1985 TQR 13.0 Handling, Storage', and Shipping 3une 10, 198ff TQR 10.0 Inspection, Test, and Operating Status 0une 10, 1989 TQR 15.0 Nonconf orming Materials, Parts, 3une 10, 1985 or Components CII Ol e

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TOPICAL QUALITYASSURANCE REPORT Rev.

Date 3une 10, 1985 FLORIOA POWER S LIGHT COMPANY TABLE OF CONTENTS Page of 2 2 REVISION

'SUBJECT NUMBER DATE TQR 16.0 Corrective Action June 10, 1983 TQR 17.0 Quality Assurance Records June 10, 1985 TQR 18.0 Audits June 10, 1980 Appendices Organizations and Figures.

Figure l-l: Organization of Departments 3une 10, 1985 Affecting Quality Qualification and Experience Requirements 3une 10, 1983 for QA Personnel Baseline Document Matrix June 10, 1980 D.- Cancelled May 7, 198 List of Corporate QA Procedures (QPs) 3une 10, 1980 Topics to be Addressed in Safety Analysis May 7, 1982 Reports

TOPICAL QUALITYASSURANCE REPORT Rev.

QUALITYASSURANCE PROGRAM POLICY>><<3une 10, l980 FLORIDA POYVER 4 LIGHT COMPANY Page I of NEED FOR POLICY To avoid undue risk to the health and safety of the public and company employees, it is necessary to design, construct, and operate nuclear power plants with a high degree of functional integrity, quality and reliability.

STATEMENT OF POLICY It is the policy of Florida Power dc Light to design, construct and operate nuclear power plants of a quality level that will meet or exceed government regulations and will merit public confidence by providing electricity in a reliable, efficient, and safe manner.

RESPONSIBILITY The President of Florida Power <k Light Company is responsible for the execution of the Quality 'Assurance Program for Florida Power 4 Light Company nuclear power plants.

The authority for developing and verifying execution of the Program is delegated to the Director of Quality Assurance, through the Group Vice President of Nuclear Energy and the Executive Vice President.

The head of each organization performing quality related activities is responsible for:

identifying those activities within his organization which are quality related as defined by the QA Program; establishing and clearly defining the duties and responsibilities of personnel within his organization who execute those quality related activities; and planning, selecting, and training personnel to meet the requirements of the QA Program.

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TOPICAL QUALITYASSURANCE REPORT Rev.

INTRODUCTION Date 3une 10, 1980 Page I of The Topical Quality Assurance Report (FPLTQAR I-76A) contains the description of the Florida Power 2 Light Company (FPL) Quality Assurance Program relative to its nuclear power plants. This report consists of three parts: The Introduction, which delineates the purpose and summarizes the scope and applicability of the Topical QA Report. The second part, Topical Quality Requirements (TQRs), which delineate QA Program requirements and summarizes the FPL approach to activities related to materials, parts, components, systems, and services included in the Quality Assurance Program. The third part, Appendices, which provide supporting statements, tabulations, and technical analyses or deviations which are not, in themselves, the subject of the report.-

The Topical QA Report shall be an integral part of the corporate Quality Assurance Manual (FPL-NQA-IOOA), and shall delineate the generic requirements and responsibilities by which FPL implements the corporate QA Program. Revisions and changes to this Report will be made in accordance with a Quality Procedure as outlined in TQR 2.0. The remainder of the QA Manual is comprised of Quality Procedur'es (QPs) which serve as the documents which describe how the interfacing of tasks between departments or organizations is achieved. The Quality Procedures also cover those technical elements which require a common corporate position for interfaces or resolution of problem areas.

In addition to the Quality Assurance Manual, Quality Instructions (QIs) are developed as required by each of the implementing plants and departments. Quality Instructions describe the measures to be used to implement the quality requirements of the QA Manual. The Quality Instructions describe actions and responsibilities to be performed within a department .or organization and address the requirements of the appropriate Topical Quality Requirements, and Quality Procedures.

The FPL Quality Assurance Program meets the requirements provided by the NRC Regulatory Guidance and Industry Standards as listed in Appendix C of this Topical Quality Assurance Report.

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TOPICAL QUALITYASSURANCE REPORT Rev.

INTRODUCTION Date 3une 10, 1980 FLORIDA POWER 4 LIGHT COMPANY Page 2 Gf 2 The requirements of this Topical QA Report apply to safety related materials, parts, components, systems and structures; and to services employed for design, procurement, construction, operation, maintenance, refueling, repair, and modification. The safety related systems for each plant are specified in the respective plant Safety Analysis Report.

The FPL Quality Assurance Program fully addresses the requirements of Appendix B to 10 CFR Part 50. The Topical QA Report shall be applicable to all existing nuclear plants, those under construction, and supporting FPL departments, and will be referenced in the Safety Analysis Report (SAR). For future plants, the description of activities, requirements, and organizational structures that are unique to a particular plant shall be addressed in the respective SAR document.

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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev.

ORGANIZATION Date 3une 1O, 1985 FLORIDA POWER 8 LIGHT COMPANY Page 1 of I.l GENERAL RE UIREMENTS The FPL organizational structure shall be defined such that the responsibilities for establishment and implementation of the Quality Assurance Program are clearly identified.'he authority and duties of individuals and organizations performing quality assurance and quality control functions shall be described, and shall illustrate the organizational'independence and authority necessary to identify problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions. In addition, the description shall illustrate that persons or groups responsible for verifying the correct performance of an activity are independent of the person or groups responsible for performing the activity.

1.2 IMPLEMENTATION The President of Florida Power -2 Light- is ultimately responsible for the execution of the Quality Assurance Program for Florida Power 2 Light Company'FPL) nuclear power plants. The authority for developing and verifying execution of the program is delegated to the Director of Quality Assurance, through the Group Vice President of Nuclear Energy and the Executive Vice President. The reporting relationship of each department involved with the Quality Assurance Program is shown in Appendix A, Figure 1-1.

To provide for a review and evaluation of QA Program policies and activities, the President has established the QA Committee, chaired by the Executive Vice President. This organization's responsibilities are defined in Section 1.2.1 below.

In addition, a Quality Assurance Program Review Committee (QAPRC) (formerly the QA/QC Coordinators) has been established to review changes to the QA Program and to provide an interface for quality matters in each department V)

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affecting quality. This organization's responsibilities are defined in Section 1.2.2 z

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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev. 8 ORGANIZATION 0"e 3une 10, 1985 FLORIDA POWER IL LIGHT COMPANY Page 2 Of 1.2 IMPLEMENTATION(Cont'd)

The head of each department or organization perf orming quality related activities is responsible for: a) identifying those activities within the organization which are quality related as defined by the QA Program; b) establishing and clearly defining the duties and responsibilities of personnel within his organization who execute those quality related activities; and c) planning, selecting, and training personnel to meet the requirements of'the QA Program. The responsibility, authority, and organizational relationship for perf orming quality related activities within each organization shall be established and delineated in organizational charts and written job or functional descriptions.

A QA Program Review Committee (QAPRC) Member shall be designated by the head of each department or organization except for the, Quality Assurance Committee, since this committee is a policy forming body (of which the Director of Quality Assurance is a member). The QAPRC Member is the prime interface for coordination of quality related matters within the member's department, with the QA Department, and with other departments.

The organization chart, Appendix A, Figure 1-1, illustrates the lines of authority and areas of responsibility for each of the organizations that are involved in quality related activities. The Project Management organization shown in this figure is applicabl~ during design, procurement, construction, repairs and preparation start-up and testing of power plant and modifications of power plants (determined by management on a case-by-case basis) as described in Section 1.2.0. Below are listed the departments and organizations that have Quality Assurance responsibilities. Specific organizational responsibilities for implementation of the Quality Assurance Program are described in the corresponding section numbers.

TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev.

ORGANIZATION Date June 1'0, 1985 FLORIOA POWER a LIGHT COMPANY Page 3 of IZ IMPLEMENTATION (Cont'd) 1.2.1 Quality Assurance Committee 1.2.9 Construction 1.2.2 ~

Quality Assurance Program 1.2.10 Power Supply Review Committee 1.2.11 Inventory Resources 1.2.3 Nuclear Energy Department 1.2.12 Company Nuclear

-Nuclear Operations Review Board

-Quality Assurance 1.2.13 Nuclear Fuel

-Nuclear Licensing 1.2.10 Corporate Records Services 1.2.0 Project Management Department 1.2.15 Executive R Documentary 1.2.5 Corporate Contracts Department Files 1.2.6 Environmental Affairs 0 1-2.7 1.2.S .

Power Plant Engineering Purchasing 1.2.1 Quality Assurance Committee The Quality Assurance Committee, chaired by the Executive Vice President, is comprised of executive level management with responsibilities for the execution of the Quality Assurance Program within their responsibilities.

This Committee's composition and reporting relationship is shown in Appendix A, Figure 1-1.

The Quality Assurance Committee is responsible for reviewing and evaluating QA Program policies and activities. Policy changes shall be initiated when Committee findings indicate the necessity. Quality Assurance Program status reports shall be periodically prepared by the QA Department and routed to the members of the QA Committee for their review.

TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev.

ORGANIZATION Da'e June l.P, l935 FLORIOA POWER a LIGHT COMPANY Page q of 27 1.2.l Quality Assurance Committee (Cont'd)

In addition, QA Committee meetings shall be held by the Executive Vice President to keep members apprised of conditions including significant problems that require management attention. The Quality Assurance Committee shall be the final authority for resolution of contested quality policies, differences of opinion, and stop-work or other corrective action requests when lower level agreement cannot be reached between QA or QC and other, departments.

"-'1.2.2 Quality Assurance Program Review Committee (QAPRC)

The QAPRC (formerly the QA/QC Coordinators) was formed as an organization with the responsibility to review and resolve recommended changes to the QA Program. This committee is administered by the QA Systems and Audits group.'A Program changes reviewed by the QAPRC are reviewed and signed by the department heads or individuals listed on each Quality Procedure.

l.2.3 Nuclear Energy Department Nuclear Energy responsibility for the plant begins with the Department's acceptance of a system or portion thereof from FPL Project Management.

Throughout the remainder of plant life, Nuclear Energy maintains control of and responsibility for any plant modifications coordinated by Nuclear Energy and for the preoperational and start up testing, operation, maintenance, refueling, and modification of the plant in accordance with written and approved procedures.

The organizational structure of Nuclear Energy is shown in Appendix A, Figure l-l. The Group Vice President of Nuclear Energy has overall responsibility for Nuclear Energy's activities.

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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev.

3 ORGANIZATION '" 3une 10, 1985 FLORIDA POWER 8 LIGHT COMPANY Page 5 of 1.2.3 Nuclear Energy (Cont'd)

Reporting to the Group Vice President of Nuclear Energy are: Director of Nuclear Licensing, Director of Quality Assurance, Manager of Planning and Control, arid the Vice President of Nuclear Operations.

1.2.3.1 Nuclear Operations The Vice President of Nuclear Operations is accountable for the safe and reliable operation, maintenance and modification of the FPL nuclear units.

He is responsible for the selection, staffing, training and development of personnel required for supervisory and operating continuity. Reporting to the Vice President of Nuclear Operations are the Vice President-Turkey 0 Point Nuclear, Vice President-St. Lucie,* iVIaintenance Manager Nuclear, Technical Manager Nuclear and the IIIlanager of Nuclear Training.

'The Vice President-St. Lucie and Vice President-Turkey Point Nuclear are accountable for the operation, maintenance, and modification of their respective nuclear plant, as well as the selection, development and direction of the assigned staff. They will act as liaison between the plants and corporate headquarters, and are accountable for assuring that company policies and procedures are properly implemented and continued at the nuclear site.

The Technical Manager iNuclear is accountable for technical staff support to the generating department and certain centralized special functions. This group consists of section supervisors and technical specialists, with functions including Health Physics, Chemistry, Radiological 0/aste, Emergency Planning, Operating Support, and Codes and Inspections.

The Maintenance Manager Nuclear is responsible for directing activities in support of major plant maintenance projects, modifications, and upgradings, as well as the development of work methods, specifications and systems to promote increased productivity.

TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev.

ORGANIZATION Date June l.0, ].935 FLORIDA POWER 8, LIGHT COMPANY Page 6 <<27 1.2.3.1 Nuclear Operations (Cont'd)

The Manager of Nuclear Training is accountable to establish company policy regarding nuclear training and secure the necessary resources to ensure that Nuclear Energy personnel are adequately trained. They must have adequate technical and job related skills to provide safe, efficient operation while complying with NRC requirements.

-The Plant Manager (Plant Manager Nuclear at PTP) through the Vice Presidents - Turkey Point Nuclear and St. Lucie Plants (as applicable) is responsible for the operation of the nuclear plant. The plant manager is additionally responsible for the establishment and implementation of plant QC policy which implements the quality control aspects of the Quality Assurance P rogram.

Reporting directly to the Plant Manager is the plant Quality Control Supervisor who has the aufhority.and freedom to administer the plant Quality Control program and, when necessary, for stopping activities adverse t

to quality. The QC Supervisor, his staff, and personnel performing QC inspection functions are required to be independent of groups or persons performing activities that they may be required to verify or inspect. QC effort includes preparation and review of plant procedures, PCMs, quality related instructions and procurement documents; the inspection, monitoring, surveillance, and review of plant activities to verify compliance with the provisions of the facility operating license and the Quality Assurance Manual. The QC Supervisor shall take corrective action for deficiencies identified, where applicable, and shall follow up on corrective action taken by oper organizations until close out. He shall receive quality program direction from the Director of Quality Assurance.

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3 ORGANIZATION Date 'June 10, 193g FLORIDA POWER 8 LIGHT COMPANY Page 7 of 1.2.3.1 Nuclear Operations (Cont'd)

The Plant Nuclear Safety Committee (PNSC) at Turkey Point Plant or the Facility Review Group (FRG) at the St. Lucie Plant is comprised of key plant management and staff personnel as described in the plant Technical Specifications. The PNSC/FRG serves the plant manager in a technical advisory capacity for the review of all saf ety related procedures and activities that impact on plant safety and the facility operating license.

1.2.3.2 Quality Assurance The Quality Assurance Department shall be responsible for administering the FPL Quality Assurance Program. This includes developing and verifying implementation of corporate policies, plans, requirements, and procedures affecting quality. This. is accomplished through the Quality Assurance Department; The Quality 'Assurance Department retains responsibility for delegated portions of the QA Program by performing initial evaluation and subsequent periodic audits of the contractors'A Programs. The QA Program responsibility further extends to the performance of audits within the Company to assure management that the established'requirements and procedures are being implemented, and that the Program complies with the baseline document requirements. Periodic audits of the Quality Assurance Department shall be perf ormed by a team independent of the QA Department, which is selected and approved by the Chairman of the Quality Assurance committee. The results of this audit are presented to the QA Committee.

The organizational freedom of the QA function is accomplished through the corporate structure, illustrated in Appendix A, which provides independence from those departments responsible for design, procurement, engineering, O

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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev.

ORGANIZATION 0'" 3une IO, 1985 FLORIDA POWER 4 LIGHT COMPANY Page 8 of 27 1.2.3.2 Quality Assurance (Cont'd) this organizationally independent department, the Manager of QA Services and the site Superintendents and their staff, both on-site and off-site, are completely free from the cost and scheduling pressures of design, procurement, construction, and operation. The Quality Assurance Department has the freedom and authority to: a) identify quality problems; b) initiate, recommend or provide corrective action; c) verify implementation of the corrective action; and d) recommend the stoppage of work or operations adverse to quality, when necessary.

The Director of Quality Assurance reports to the Group Vice President of Nuclear Energy.

The Manager of Quality Assurance Services; the Superintendent of Quality Assurance '- St. Lucie and the Superintendent of, Quality Assurance - Turkey Point report administratively and functionally to the Director of Quality Assurance. The Superintendents of QA receive technical direction from the Manager of QA Services.

The Director of Quality Assurance, the Group Vice President of Nuclear Energy, Vice President of Nuclear Operations, and the Manager of Quality Assurance Services are each members of the Quality Assurance Committee. This reporting relationship and memberships on the QA Committee assure that the QA Department has direct access to the levels of management necessary to assure effective implementation of the QA Program. Further, the Operations QC Supervisors of both Turkey Point and St. Lucie receive quality program direction from the Director of QA.

The Manager of QA Services directs and administers the Corporate Quality Assurance Program, including developing and verifying implementation of policies, plans, requirements, procedures, and audits which assure compliance with the baseline documents listed in Appendix C of this Topical Quality Assurance Report. He shall also be responsible for the technical

TOPICAL QUALITYASSURANCE REPORT TQR I.O Rev.

8 ORGANIZATION June lO, f985 FLORIDA POWER aL LIGHT COMPANY Page 9 of 27 1.2.3.2 Quality Assurance (Cont'd) direction and the administrative control (e.g., performance appraisal, salary review, hire/f ire, position assignment) of all members of the Quality Assurance Department. Reporting directly to the Manager of Quality Assurance Services are:

o Assistant Manager of QA - Systems and Audits o Manager of QA - Procurement and Reliability The duties, responsibilities, and authorities of each Manager, and his group are described in the sections which follow.

a. Quality Assurance Systems and Audits Group The Assistant Manager of Quality Assurance Systems -8 Audits is responsible for the development and maintenance of the overall QA Program, including the following:

o Develop and maintain the QA Department Quality Instructions, QA Department Organization Manual, and the corporate QA Manual; including the administration of the QA Program Review Committee (QAPRC) o Assist other departments in the development of Quality Instructions by revie'w and comment and through interpretation of corporate Quality Assurance requirements; o Develop and implement a Quality Assurance indoctrination program for FPL supervisory personnel, and a training program for the Quality Assurance Department; o Prepare reports on Quality Assurance Program activities for presentation to the Quality Assurance Committee by the IVlanager of CO C Quality Assurance Services; z0 Cb I

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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev.

ORGANIZATION >><< 3une 10, 1985 FLORIDA POWER a LIGHT COMPANY Page 10 of 1.2.3.2 Quality Assurance (Cont'd) 0 Maintain a file system for documentation of quality assurance activities performed by the QA Department; 0 Review Regulatory Guides, Codes, SAR Document Commitments and for impact on the Quality Assurance Program and recommend 'tandards appropriate program changes; Review documents submitted to the CNRB as requested by the.QAl Department CNRB member; 0 Plan, coordinate and implement a comprehensive system of periodic internal audits with support from the other Quality Assurance groups, when necessary; l*

0 Initiate, recommend or provide solutions and-verify implementation of solutions for quality problems identified.

0 Review FPL originated design specifications for inclusion of appropriate quality requirements.

b. Quality Assurance Procurement and Reliability Group The Manager of Procurement and Reliability is responsible for assuring the quality of safety related items and services, and their vendors, including the f ollowing:

o Assist in the development and implementation of policies, plans, requirements, and procedures for the requisition and purchase of materials, equipment and services related to nuclear power plants and to the acceptance and storage of equipment and material; o Perform appropriate surveillance of hardware during manufacture; o Develop and implement a program for auditing of supplier QA/QC programs including architect/engineer/NSS Suppliers; o Review and approve FPL procurement documents and changes to th'ese documents to assure that the .necessary quality requirements are Vl C imposed.

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TOPICAL QUALITYASSURANCE REPORT TQR l.p Rev..

ORGANIZATION Date June lP, $ 985 FLORIDA POWER It LIGHT COMPANY Page II of 27 1.2.3.2 Quality Assurance (Cont'd) o Assist other FPL departments in the identification of quality problems associated with procurement and storage; initiate, recommend, or provide solution; and verify implementation of solutions; o Review, approve, and periodically audit the execution of FPL contractor quality assurance programs; o Maintain a file system for documentation of quality assurance activities performed by the QA Procurement group; o Maintain the Quality Assurance Department "Approved Suppliers List".

The responsibility of this group, in terms of phases of procurement, begins with the preparation of the procurement document, extends through bid evaluation, vendor selection, fabrication, and,shipment; and ends upon receipt of shipment at the operating plant or warehouse. This group, through audits and surveillances, assures that the contractor's organizations

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. perf orming QA functions have suf ficient authority and organizational freedom to implement effective QA programs.

c. Quality Assurance Group - Turkey Point The Superintendent of QA-Turkey Point has responsibility for on-site development and implementation of the Quality Assurance Program, including the following:

o Lead in the development and implementation of policies, plans, requirements, and procedures for portions of the quality assurance program related to the operation and modification of nuclear power plants at Turkey Point Units 3 and 0 (PTP);

o Perform audits, assessments, and other observations at PTP to verify compliance with QA Program commitments, identify quality EP problems, and ensure timely corrective actions are taken in the .

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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev.

'RGANIZATION Date 3une 10, 1985 FLORIDA POWER 8 LIGHT COMPANY Page 12 of 1.2.3.2 Quality Assurance (Cont'd)

. areas of plant operation, system turnover, modif ication, and maintenance; including such areas as refueling, inservice inspection and testing, procurement of spare/replacement parts, material storage, health physics, chemistry, plant security and fire protection; o 'dentify requirements, ensure inclusion of commitments in documents and verify implementation of the Quality Assurance.

Program during the backf it activities at PTP through audits of FPL and contractor organizations; o Recommend stoppage of work or operations adverse to quality at PTP in accordance with the appropriate Quality Procedures; Review and comment on Quality Instructions or equivalent quality related administrative procedures prior to issue, with respect to the requirements of the FPL Quality Assurance Program; the PTP Final Safety Analysis Report; and the PTP Technical Specifications; 0 Assure that the status is tracked for all PTP open items identified by the FPL QA Turkey Point group, and inform appropriate management when there is an indication that a commitment will not be met on time; o Maintain a file system for documentation of quality assurance activities performed by the Turkey Point group.

Assure design related activities performed by the Architect/Engineer meet the quality aspects of the contract; 0 Review backfit procedures with respect to the FPL QA Program (for procedure review requirements see TQR 5.0);

Review site generated FPL procurement documents and changes to CO procurement documents in accordance with the appropriate Quality Procedures.

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0 Perform audits of PTP architect/engineer/NSSS suppliers both on-0 CO C

0 site and off-site, in conjunction with QAPRR.

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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev.

0 ORGANIZATION >><< June 10, 1985 FLORIDA POWER 8, LIGHT COMPANY Page 13 of 27 1.2.3.2. Quality Assurance (Cont'd)

The interface with the QA Procurement 2 Reliability group ends with the receipt of a shipment of nuclear safety related equipment at the plant site. The Quality Assurance program for the shipment is then within the purview of the QA Turkey Point group.

Off-site interfaces for the resolution of quality related problems and NRC items are with Project Management, Power Plant Engineering, Nuclear Energy Staf f, - and the architect/engineer/NSSS Quality Assurance Department. This group is called upon to audit the Turkey Point operating plant. The Turkey Point group interfaces with the Site Vice President, Plant Manager, Project Site Manager and their staff on-site by assisting in the resolution of quality related problems.

A Project Quality Assurance Engineer is assigned from this group to provide an interface with the Project Management Department and the--

QA Turkey Point group. This individual is the QA Project Team member for Turkey Point Project.

d. Project Quality Assurance Engineer The Project Engineer QA is assigned from this group to each identified major project for coordination of QA related activities. These responsibilities include:

o Represent the Director of Quality Assurance at Project Team meetings; Assist the Project General Manager and members of his staff in regard to QA activities; o Provide technical guidance on QA questions;

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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev.

ORGANIZATION Date 3une 10, 1935 FLoRIOA POWER a LIGHT COMPANY Page lq of 1.2.3.2 . Quality Assurance (Cont'd) o Submit periodic reports that will include assessments of project

. plans, progress, milestones and recommendations for improvement, to the Director of Quality Assurance.

o Identify and schedule the QA Department support needed to achieve project objectives.

o Prepare project related plans and objectives for QA support of Project Management and measuring the QA performance record against these plans and objectives.

e. Quality Assurance Group - St. Lucie The Superintendent of QA St. Lucie has responsibility for on-site development and implementation of the Quality Assurance Program, including the f ollowing:

o Coordinate in the development and implementation of policies, plans, requirements, and procedures for portions of the quality assurance program related to the operation or modification of St.

Lucie Unit 1 dc Unit 2 (PSL);

o Perform audits, assessments, and other observations at PSL to verify compliance with QA Program commitments, identif y quality problems and ensure timely corrective action are taken in the areas of plant operation, system turnover, modification, and maintenance; including such areas as refueling, inservice inspection and testing, procurement of spare/replacement parts, material storage, health physics, chemistry, plant security, and fire protection; o Identif y requirements, ensure inclusion of commitments in documents and verify implementation of the Quality Assurance IZ Program during the backfit'activities at PSL through audits of FPL D

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ORGANIZATION Date gune 10, 1935 Page 15 of 1.2.3.2 Quality Assurance (Cont'd) o Assure design related activities performed by the Architect/Engineer meet the quality aspects of the contract; o Review backfit procedures with respect to the FPL QA Program (for procedure review requirements see TQR 5.0);

o Review site generated FPL procurement documents and changes thereto, in accordance with appropriate Quality Procedures; o Perform audits of PSL architect/engineer/NSSS suppliers both on-site and off-site, in conjunction with QAPRR.

o Recommend stoppage of work or operations adverse to quality at PSL in accordance with the appropriate Quality Procedures;

. o Review and comment on Quality Instructions or equivalent quality'elated administrative procedures prior to issue, with respect to the requirements of the FPL Quality Assurance Program; the PSL Final Safety Analysis Reports; and the plant Technical Specifications; o Assure that the status is tracked for all PSL open items identified by FPL St. Lucie Projects QA group, and inform appropriate management when there is an indication that a commitment will not be met on time; The interface with the QA Procurement 2 Reliability group ends with the receipt of a shipment of nuclear safety related equipment at the plant site. The Quality Assurance program for the shipment is then within the purview of the St. Lucie Projects QA group.

Off-site interfaces for the resolution of quality related problems and NRC items are with Project Management, Power Plant Engineering, Nuclear Energy Staff, and the architect/engineer/NSSS Quality Assurance Department. This group is called upon to audit the St. Lucie El operating plant. The St. Lucie Projects QA group interfaces with the 0

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ORGANIZATION Date 3une ]0, 1935 FLORIDA POWER 8 LIGHT COMPANY Page 16 of 1.2.3.2 Quality Assurance (Cont'd)

A Project Quality Assurance Engineer is assigned from this group to provide an interface between the Project Management Department and the St. Lucie Projects-QA group. This individual is the QA Project team member for the St. Lucie Project.

1.2.3.0 Nuclear Licensing The Director of Nuclear Licensing is responsible for coordinating the NRC interface, distributing NRC documents requiring actions, evaluating L

potential impact, and responding to all NRC action items. He is also responsible for assuring that the status is tracked for all open items identified by the NRC or other federal, local and state agencies, and for informing appropriate management when there is an indication that a commitment will not be met on time. The Director of Nuclear Licensing reports to the Group Vice President of Nuclear Energy as shown in Appendix A, Figure 1-1.

1.2.0 Project Management Department The Project Management Department, through the Project General Manager Nuclear, exercises management control of assigned projects. This management control begins when a Project is assigned to the Project Management Department and continues until the facility is accepted for operation or the project is complete. This management control includes the responsibility for procurement, repair, construction and may include preoperational start-up and testing of power plant modifications. The ProjeCt Management Department organization is shown in Appendix A, Figure 1-1.

TOPICAL QUALITYASSURANCE REPORT TQR I.O Rev.

8 ORGANIZATION Date 3une lO, ],935 FLORIDA POWER a LIGHT COMPANY l7 <

27 1.2.0 Project Management (Cont'd)

The Director of Projects, reporting to the Vice President-Engineering, Project Management and Construction has overall responsibility for the activities of the Project Management Department. A Project General Manager - Nuclear, reporting to the Director of Projects, is responsible for completing the assigned project in compliance with technical and other project specifications, and for the application of the provisions of the Quality Assurance Manual during the project. The Project General Manager

- Nuclear is responsible for obtaining corrective action from any contractor's management when corrective action cannot be obtained at the project site management level and, when necessary, can exercise his authority to stop work on project activities adverse to quality.

b The overall responsibility for Plant Changes and Modifications to operating plants is def ined in each plant's Technical Specif ications. However, frequently the work of installation and administration of Plant Changes and.

Modifications is assigned to FPL Project Management. The Project Site Manager will report to the appropriate nuclear'site Vice President but will also receive guidance and advice from the Project General Manager-Nuclear. The. Project Site Manager is additionally responsible for the functional direction of construction QC for the purpose of coordinating inspection activities which implement the quality control aspects of the quality assurance program for modifications of projects assigned to project management. Activities affecting quality may be performed by FPL, or contracted. Should any of these functions be contracted, the contractor may perform the activities under his own Quality Assurance Program, which must have prior approval by FPL Quality Assurance, or the contractor may directly adopt the requirements of the FPL Quality Assurance Manual. If the contractor implements the Quality Control function directly to the FPL QA Manual requirements, the contractor's Quality Control Supervisor shall have the authority and freedom to administer the Quality Control program.

TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev.

ORGANIZATION 0"e 3une 10, 1985 FLORIDA POWER 5 LIGHT COMPANY Page 13 Gf 1.2.5 Corporate Contracts Department Project Team Members are appointed by their home department heads as the departmental representative on the respective project, when requested by the Project General Manager - Nuclear. Team Members, other than Quality Assurance and Stores Department, report functionally to the Project General Manager - Nuclear, or the Project Site Manager, but continue to receive administrative support and technical direction from their home department. The QA Department has a representative assigned to each major project, who reports functionally and administratively to the Director of Quality Assurance. Team members are responsible to the Project General Manager - Nuclear for home department support to the Project.

The Corporate Contracts Department is responsible for gen'eration, negotiation and issuance of Contracts oyer specified time periods and dollar n-limits for turbine generators, 'steam generators, nuclear steam supply systems (NSSS), new items, repairs, constructors, construction managers; and Architect Engineer (A/E) and consulting services. Corporate'ontracts is also responsible for assuring that technical and quality requirements developed by others are incorporated in such contracts, as appropriate, and that these contracts have the required approvals. Details of the activities of the department in fulfilling this responsibility shall be delineated in the appropriate Quality Procedures. The Manager of Corporate Contracts reports to the Directo'r of Corporate Contracts. The Corporate Contracts Organization is shown in Appendix A, Figure 1-1.

1.2.6 Environmental Affairs Environmental Affairs is responsible for obtaining the federal and state environmental permits required for FPL f'acilities and operations. During operation of the nuclear power plant, Environmental Affairs maintains responsibility for overall coordination of environmental monitoring programs. Some of the activities include: a) drafting of Environmental Technical Specifications; b) review of proposed changes to Environmental

TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev.

3 ORGANIZATION 3une 1Q, 1985 FLORIDA POWER a LIGHT COMPANY Page 19 of 27 1.2.6 Environmental Affairs (Cont'd) programs. Some of the activities include: a) drafting of Environmental Technical Specifications; b) review of proposed changes to Environmental Technical Specifications and investigation of violations; and c) review of proposed plant changes and modifications for effect on the environmental impact evaluation when requested.

The Manager of Environmental Technical Services, the IVlanager of Environmental Resources and Planning and the Manager of Environmental Permitting and Programs report to the Director of Environmental Affairs as illustrated in Appendix A, Figure l-l. The Director of Environmental Affairs has overall responsibility for implementation of the Environmental 0

Technical Specifications in nuclear power plants.

The Company Environmental Review Group (CERG) advises the Director of Environmental Affairs and the Chairman of the CNRB on all matters related to environmental quality. The CERG provides a review of proposed changes to Environmental Technical Specifications, and has prime responsibility for investigation of violations and evaluation of corrective actions.

1.2.7 Power Plant Engineering The Power Plant Engineering Department (3PE) is responsible for power plant design related aspects of the FPL QA Program throughout all phases of plant life except as specified for the Fuel Resources Department in Section 1.2.13. This responsibility extends from initial engineering evaluations of plant design related site characteristics, through preliminary and detailed design, construction, operation and decommissioning.

3PE performs design related activities and delegates design related activities to qualified contractors. For activities performed by 3PE, the work is governed by FPL's QA Program, and 3PE is responsible for approval Ol of the design output. Delegated activities are performed in accordance with CV e

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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev. 8 ORGANIZATION 3une 10, 1985 FLORIDA POWER & LIGHT COMPANY Page 20 of 1.2.7 Power Plant Engineering (Cont'd) an FPL approved QA Program and the contractor is responsible for approval of design output. 3PE is responsible for defining the scope of delegated activities and the responsibilities of the contractor. Prior to the release of design outputs by contractor organizations, 3PE ensures that the contractor is technically qualified to perform the design related activity.

3PE is responsible for development and maintenance of the design control program governing design related activities performed by 3PE and for providing technical support to the. Quality Assurance Departmen t for assessing the adequacy, implementation and effectiveness of contractor design control programs.

3PE is responsible for the preparation, revision, approval and distribution of

'lant design drawings that are identif ied to be maintained as "as-constructed" drawings during plant operation.

The Chief Engineer - Power Plants reports to the Vice President Engineering, Project Management and Construction as shown in Appendix A, Figure 1-1.

1.2.8 'urchasing The Purchasing Department is responsible for the purchase of materials and services by FPL for its nuclear power plants with the exception of those materials and services secured by Corporate Contracts and Nuclear Fuels.

Materials and services for nuclear safety related application are secured only from approved suppliers, or as commercial grade, as applicable.

The Department is responsible for assuring that technical and quality requirements developed by othres, and reviewed and approved by the Vl C

O designated quality departments as applicable, are incorporated in the R

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ORGANIZATION Date gune lP, ],93 Page 2l of 1.2.8 Purchasing (Cont'd) procurement documents which the departments authorizes. It is responsible for maintaining traceability of purchase records from acceptance of requisitions through payment of the purchase order invoices.

The Manager of Purchasing reports to the Director of Procurement and Materials Management who reports to the Vice President - Corporate Services as shown in Appendix A, Figure I-l.

1.2.9 Construction The Construction Department is responsible for providing direction and coordination regarding construction, supervision and management, equipment utilization, quality control, welding; NDE and other cons'truction support activities.

The Director of Construction reports directly to the Vice President of Engineering, Projects and Construction. He is responsible for directing and administering effective management of the Construction Department to ensure compliance to the corporate policies, practices and procedures.

Reporting to the Director of Construction are the Manager of Plant Construction, Manager of Construction QC, Welding and NDE, Manager of Transmission, Substation and Building Construction and the Manager of Labor Relations.

The Manager of Plant Construction is responsible for providing qualified construction support personnel to the Project Manager and staff support in the areas of Methods, Equipment and other staff projects. Reporting administratively to the Manager of Plant Construction are the Project Site Superintendents.

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ORGANIZATION 3une 10, 1985 FLORIDA POWER II LIGHT COMPANY 1.2.9 Construction (Cont'd)

The Project Site Superintendent is responsible for conformance of project construction activities to the requirements of specif ications, codes, regulations and site procedures. He supervises the construction personnel assigned to the project, coordinates construction activities including the scheduling of construction personnel requested by the Project Site Manager.

The Manager of Construction Quality Control, Welding and NDE is responsible for directing and administering the Construction QC and Welding Programs and for the technical direction and administrative control of all personnel within the Construction QC and Welding organizations. This includes the development and implementation of policies, -plans, and procedures to meet the requirements of the QA program, codes and standards.

Reporting to the Manager of Construction QC, Welding and NDE are the site Project QC Supervisors, NDE Level III Supervisor, FPL Welding Superintendent and a staff of QC Coordinators.

The Construction QC Department is responsible for providing quality inspection as required, to assure that backf it activities meet the requirements of engineering plans, specifications, codes and standards..This responsibility extends from receipt inspections of material on-site to acceptance of the installed items prior to turnover to the Nuclear Energy Department. It also includes verification of conformance of an item or activity accomplished during this period to quality requirements (e.g.,

records review, NDE, inspections).

Each nuclear power plant is assigned a Project Qualtiy Control supervisor, who directs the on-site QC organization. The Project QC Supervisor reports administratively and technically to the Manager of Construction Quality V>

C 0 Control, Welding and NDE, however, he also reports functionally to the Z

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8 ORGANIZATION 3une 10, 1985 FLORIDA POWER a LIGHT COMPANY Page 23 of 27 1.2.9 Construction (Cont'd)

Project Site Manager for the purpose of coordinating and scheduling inspection activities. The functional/administrative reporting roles provide the necessary independence of the site Construction Quality Control organization and also maximizes the communication between the Construction staff, the QC staff and the Nuclear Energy staff.

The Project QC Supervisor is responsible for first line verification of the conformance of backfit activities to quality r'equirements, specifications, codes, and local, State and Federal, regulations. He directs on-site implementation of the Construction QC Program which includes supervision and daily coordination and scheduling of inspection activities, and review of inspection results. The freedom and independence of the on-site QC organization to assure the effectiveness of the QC Program from pressures of cost and scheduling is derived from the. Project QC Supervisors administrative and technical reporting relationship to the Manager of Construction QC, V/elding and NDE. Both the Manager of Construction Quality Control, V/elding and NDE, and the Project Quality Control Supervisor have the authority to stop work or operations adverse to quality if the need arises.

The NDE Level III Supervisor is responsible for directing and monitoring the non-destructive examination (NDE) activities performed under the control of the Construction Department. He is responsible for preparation, revision and implementation of NDE procedures, and the training, testing 'and qualification of the NDE personnel performing these activities. He is also responsible for providing the programs and direction for performance of NDE activities meeting the ASME, AV/S and other construction welding code requirements.

The Quality Control Coordinators provide staff technical and administrative support to the Manager of Construction QC, Welding and NDE in the Ol preparation, review, issue and monitoring of the Construction QC program to OI E

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8 ORGANIZATION Date .

June 10 1985 FLORIDA POWER It LIGHT COMPANY Pe9e 0< 27 2$

1'.2.9 Construction (Cont'd)

The FPL Welding Superintendent reports to the Manager of Construction QC, Welding and NDE. His responsibilities are to develop, maintain and control the FPL Welding Control Manual with assistance from Power Plaht Engineering to originate and qualify welding procedure specifications and qualification of welders and welding operators to meet the applicable code requirements. He provides administrative and technical direction to the personnel within the FPL welding control program to meet engineering welding standards and code requirements. Reporting to the FPL Welding Superintendent are the Welding Supervisors at each Nuclear site.

The organization structure of the Construction Department is illustrated in Appendix A, Figure 1-1..

1.2.10 'ower Supply Within the Power Supply Department only equipment and services provided by the System Protection Group and Power Supply Technical Services are subject to the requirements of the Quality Assurance Program. Appendix A Figure 1-1 illustrates the reporting relationship.

System Protection is responsible for test, calibration, and maintenance of certain high voltage electrical protective relays for safety related systems of the nuclear plant. Activities of System Protection include final wiring connection checks, preoperational check-out and test of system protection devices, and providing inspection of equipment under their cognizance.

Power Supply Technical Services is responsible for providing to System Protection certain setpoint and'checkpoint values for protective devices.

TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev.

ORGANIZATION Date 3une 10, 19gg Pa9e 25 of 27 1.2.11 Inventory Resources The Inventory Resources Department is responsible for the receipt, handling, storage, shipping, and issue of items received at the plant site for control by Inventory Resources. This responsibility encompasses spare and replacement parts and components for plant equipment through all phases of plant life.

During operations, Inventory Resources also performs additional quality related activities such as handling and segregation for nonconforming items received for stores control. The Manager of Power Plant Stores reports to the Manager of Inventory Resources who reports to the Director of Procurement and Material Management as shown in Appendix A, Figure 1-1.

1.2.12 Company Nuclear Review Board The Company Nuclear Review Board (CNRB) reviews or directs the performance of reviews of activities concerning the technical aspects of the ...

operating nuclear power plant insofar as they impact on plant safety; the health and saf ety of the public; and laws, regulations, and licensing commitments. In addition, audits of these areas are performed under the cognizance of the CNRB. Where necessary, the Board may use consulting services to perform required reviews. Membership and the managemeht.

level to which the CNRB reports, is illustrated in Appendix A, Figure 1-1.

Subjects within the purview of the Board are listed in the appropriate plant Technical Specifications. The CNRB has the authority to carry out its responsibilities by way of written action letters, verbal direction, minutes of meetings or appointed subcommittees.

1.2.13 Nuclear Fuel The Nuclear Fuel Section of the Fuel Resources Department (FRN) is responsible for the procurement, management, and accountability of FPL's nuclear fuel assets, and for providing technical support to fuel users within FPL. The Nuclear Fuel Section is under the direction of the Manager of Nuclear Fuel who has the responsibilities described below:

TOPICAL QUALITYASSURANCE REPORT T R Rev.

ORGANIZATION Date FLORIDA POWER a LIGHT COMPANY 3une 10 1985 Page of 26 27 1.2.13 Nuclear Fuel (Cont'd) o Forecasting FPL's nuclear fuel requirements and the availability and price of nuclear fuel; o Preparing the procurement specifications for components of the nuclear fuel cycle; o Determining sources of supply and evaluating alternatives; o Making commercial arrangements, including contract negotiations with vendors for acquisition, processing and delivery of nuclear fuel and related services for the nuclear fuel cycle; o Assuring that technical and quality requirements including inputs from other FPL departments are incorporated in fuel contracts and letters of authorization and that these documents have the necessary approvals;

'o Administering and managing contracts for nuclear fuel and related services to assure that contractual obligations are met, and serving as FPL liaison in all matters of nuclear fuel and fuel related contracts; o Perf orming audits and coordinating accoun tability reporting on all nuclear fuel; o Providing support to the QA Department for their auditing of nuclear fuel design and fuel assembly manufacturing; o Performing fuel management and safety analyses of nuclear cores to support plant licensing; o Development and/or review of fuel and nuclear physics design; o Performing the project management function with respect to nuclear

. fuel; o Provide and maintain computer codes and procedures available for Fuel Resources line functions and other departments for daily use in maintaining records, performing safety analysis and core design, reporting of off-site nuclear fuel management activities, and providing economic data; o Maintain ef fective and controlled computer access to Nuclear applications systems; o Develop and provide, to appropriate FPL groups, information necessary to determine FPL's fuel related costs and to finance fuel related dit

TOPICAL QUALITYASSURANCE REPORT T R 1.0 Rev.

8 ORGANIZATION Date FLORIDA POWER a LIGHT COMPANY June 10 1985 Page of 27 27'.2.13 Nuclear Fuel (Cont'd) o Reviewing core related changes to Safety Analysis Reports and Technical Specif ications for compliance with design criteria and regulatory requirements; o Participating in start-up physics tests and providing other technical support for operating nuclear power plants.

o Planning, maintenance and implementation of the Corporate Special Nuclear Materials program.

The Manager of Nuclear Fuel reports to the Director of Fuels as shown in Appendix A, Figure 1-1.

~- 1.2.10 Corporate Records Services P

The Manager of Corporate Records Services is responsible for: ensuring the QA records program activities are managed in accordance with applicable laws and regulations; assisting with the development and implementation of effective and compatible records and micrographics programs; developing, approving and maintaining record retention schedules; establishing parameters for indexing in the corporate records computerized Record Management System (RMS); locating acceptable record storage areas when requested; storage, retrieval and control of records/documents as reqested by other departments; leading the evaluation of specially designated "QA approved".storage facilities and maintaining the records of this evaluation.

The Corporate Records Services organization is shown in Appendix A, Figure 1-1.

1.2.15 Executive and Documentary Files The Supervisor of Executive and Documentary Files is responsible for receiving, maintaining, retrieving and storing the QA records in connection with licenses and contracts received from other departments. The Executive and Documentary Files organization is shown in Appendix A, Figure 1-1..

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5 QUALITYASSURANCE PROGRAM Date 3une 10 1985 Page of 2.1 GENERAL RE UIREMENTS Florida Power R Light Company has established a Quality Assurance Program which complies with the criteria of 10 CFR 50 Appendix B, and meets the requirements of Regulatory Guides and Industry Standards referenced in Appendix C of this report. The Topical Quality Requirements and attached Policy Statement, together with the Quality Procedures and Quality Instructions document the Program and the FPL policy with regard to Quality Assurance. This Program shall be instituted for each plant site in a schedule consistent with accomplishing the required activity and shall be carried out throughout the life of FPL nuclear plants.

The requirements of the FPL Quality Assurance Program shall only apply to nuclear safety related structures, systems, and components as identified in the Safety Analysis Report for each nuclear unit. Additionally, the requirements of the FPL Quality Assurance Program'hall apply to all FPL, contractor, or consultant organizations performing activities affecting the quality of safety related structures, systems, and components of FPL nuclear power plants.

Documented procedures shall require and define indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.

Periodic program reviews of the status and adequacy of the FPL Quality Assurance Program shall be accomplished by the independent audit team described in Section 1.2.2 and by QA Department audits. Management of organizations outside Florida Power dc Light Company participating in the Program shall be required to regularly review the status and adequacy of that part of the FPL Quality Assurance Program which they are executing. The FPL Quality Assurance Department shall review and concur in the QA Program of contractors.

TOPICAL QUALITYASSURANCE REPORT TQR 2.0 Rev.

QUALITYASSURANCE PROGRAM FLORIOA POWER 4 LIGHT COMPANY 3une IO, 198 Page Gf 2

2.2 IMP LEiVIENTATION 2.2.l Goals and Objectives As stated in the Policy Statement of the President of Florida Power R Light Company, the goal of the FPL Quality Assurance Program is to maintain quality levels in an effective and efficient manner, and to assure the high degree of functional integrity and reliability of nuclear saf ety related structures, systems, and components..To meet this goal, the following objectives of the FPL Quality Assurance Program have been defined:

a. Def ine through documented procedures and instructions the quality activities that apply t'o the design, fabrication, procurement, modification, testing, operation, refueling, maintenance, and repair of nuclear power plants;

b. Establish, assign, and document the responsibilities for those activities affecting quality of safety related structures, systems, and components;

c. Establish conf idence that the design, fabrication, modif ication, and operation of nuclear power generation facilities are performed in a manner consistent with FPL policies by assuring quality related activities are performed by responsible personnel;

d. Apprise management of unresolved problems and trends which could have a significant effect on nuclear power plant safety; and

e. Prevent schedule delays and high cost due to poor quality.

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2.2.2 Program Documentation The Topical Quality Assurance Report, which defines the policy, goals, and objectives regarding the Quality Assurance Program, shall be contained in the FPL Quality Assurance Manual, and used as guidance for the development of corporate level Quality Procedures which are also contained in the Quality Assurance Manual. Revisions to the Topical Quality Assurance Report will be made, as needed, to reflect current FPL program requirements and descriptions of activities. These revisions shall be made in accordance with a Quality Procedure. If a program revision reflects a deviation from the baseline documents contained in Appendix C, an amendment shall be submitted to the NRC thirty (30) calendar days prior to implementation. Thirty (30) calendar days after submittal, the NRC shall be notified of FPL's intent to begin implementation of program changes identified in the amendment. In all other cases, amendments to the Topical QA Report will be submitted to the NRC to h

reflect implemented program revisions on an annual or more. frequent basis.

Quality Procedures shall be written by the department. with major responsibilities for an activity or by the Quality Assurance Department. These procedures shall be reviewed by all= the departments with responsibility for

,some portion of that procedure, and shall be approved by the major implementing departments with co-approval by the Director of Quality Assurance. A listing of corporate level Quality Procedures is contained in Appendix E. As the QA program develops and responds to new or revised requirements and guidance, 'new procedures may be adopted.

Each Quality Procedure shall be written to further address criteria contained in the Topical Quality Requirements and to further define the FPL QA policies, plans, and program where action is required by more than one department.

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2.2.2 Program Documentation (Cont'd)

Each department head shall have the responsibility for implementation of the Quality Assurance Program, which includes procedure requirements applicable to his department. In addition, he shall be responsible for the preparation, approval, and dist'ribution of Quality Instructions, operating, procedures, testing procedures, or other instructions where further guidance is necessary for implementation of the QA Program within his department. Quality Instructions shall be reviewed by the Quality Assurance Department.

2.2.3 Structures, Systems, and Components The requirements of the FPL Quality Assurance Program shall apply to nuclear safety related structures, systems, and components, as defined in the SAR.

Saf ety related structures, systems, and components are listed as those necessary to assure the integrity of the reactor coolant boundary, the capability to shutdown the reactor and maintain it in a safe shutdown condition, or the capability to prevent or mitigate the consequences of accidents which could result in off-site exposures comparable to the guideline exposures of 10 CFR 100.

Control over activities affecting the quality of safety related structures, systems, and components shall be to the extent consistent with their importance to safety. Such control shall include use of appropriate equipment, establishment of suitable environmental conditions, and assurance that all prerequisites for a given activity have been satisfied. The Program shall provide for controls over special processes and skills necessary to attain the required quality, and the need for verification of quality by inspection and test.

Advance planning is required, for the control of management and technical interfaces between FPL and contractors, during the phase-out of design and construction and during preoperational testing and plant turnover. This is achieved through periodic meetings of concerned organizations and the

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2.2.3 Structures, Systems, and Components (Cont'd) development of procedures which define responsibilities and interfaces, and control the testing and turnover of plant systems to FPL.

2.2A Participating Organizations The FPL organizations with responsibilities for activities affecting quality of nuclear safety related structures, systems, and components are identified in TQR 1.0, which also briefly describes their assigned responsibilities. The Quality Assurance Department shall be responsible for: a) the development, coordination, and control of the QA Program, including coordination of Quality Procedure review and approval; b) control and issuance of the FPL Topical 0 Quality Assurance Report and the QA Manual as a controlled document, and c) review of Quality Instructions written by other departments.

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Florida Power dc Light Company may delegate activities to contractor organizations and equipment vendors. Delegated activities are subject to the external organization's FPL approved QA Program or the FPL QA Program, or some FPL approved combination thereof. However, FPL shall retain overall responsibilities for the QA Program. Procurement documents shall define the scope of delegated activities, as well as QA Program requirements that shall govern these activities.

The Quality Assurance Department shall review and approve the QA Program h

governing contracted activities prior to award of contract except for activities for which the output is of a conceptual and/or prototype nature. In all cases, final approval shall occur at a point in the process to ensure that the output complies with the requirements of the FPL approved QA Program. The object of this review shall be to verify that the program is in compliance with. the applicable requirements of Appendix B, 10CFR50, and ANSI N05.2. Audits shall N

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QUALITYASSURANCE PROGRAM FLORIDA POWER II LIGHT COMPANY 3une l0, 1985 Pege 2.2.0 Participating Organizations (Cont'd) be conducted periodically to verify the acceptable implementation of the contractor's FPL approved QA Program governing delegated activities. The Quality Assurance Department is responsible for conducting these audits. The initial review and periodic audits shall be performed by qualified Quality Assurance Department personnel, and as appropriate, by technical specialists from other FPL departments and contractor organizations.

2.2.5 Indoctrination and Training A program shall be established and maintained for quality assurance indoctrination, and for training'hich assures that the required level of personnel competence and skill is achieved and maintained in the performance of quality related activities. Quality Procedures . shall delineate 'he requirements for an indoctrination program to assure that personnel responsible for performing quality activities are instructed in the purpose, scope, and implementation of the quality related manuals, instructions, and procedures and that compliance to these documents is a mandatory requirement. The Quality Assurance Department shall be responsible for the indoctrination of supervisory personnel. Each department head is responsible for the indoctrination of non-supervisory personnel within his department who perform quality related activities. V/hen personnel are assigned to perform their functions under the direction of personnel from other than their home department, the department head of the organization providing direction is responsible for the indoctrinaton and training of personnel who perform quality related activities under his direction.

Quality Procedures shall also require the head of each department (including the QA Department) to be responsible for a training plan which assures that personnel performing quality related activities are trained in the principles and techniques of the activity being performed.. This training shall maintain the proficiency of personnel in the skills necessary for the quality related activities through retraining, requalif ication or reexamination, as appropriate.

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of 2.2.5 Indoctrination and Training (Cont'd)

Quality Procedures shall specif y the. requirements for documenting indoctrination and training sessions, including a course description, attendance, location, and date.

2.2.6 Management Participation In addition to the involvement of department heads in implementing the QA Program within their departments and the involvement of the Director of Quality Assurance and the Manager, r of QA Services in the development, coordination, and review of the Program, the Quality Assurance Committee shall be apprised of the status and adequacy of the Quality Assurance Program on a periodic'basis. The following actions shall be instituted to assure that the Quality Assurance Committee remains informed and meets its Program responsibilities:

a. The Committee shall review a summary of the results of. management level QA audits of FPL Departments.

b. The Quality Assurance Department shall circulate, monthly reports of quality related activities to members of the QA Committee and affected department heads. The monthly reports may include such items as the status of audits, a summary of audit findings, the status of development projects, and descriptions of policy matters or problems requiring management attention.

c. The Quality Assurance Committee shall review the status of the QA Program on a semiannual basis. The review will include assessment of the Program goals, objectives, and accomplishments.

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, g 2.2.6 IIrlanagement Participation (Cont'd)

d. Periodic audits of the QA Department and Program shall be conducted by an independent audit group under the direction of the Chairman of the Quality Assurance Committee. This audit group shall employ FPL audit procedures and shall distribute the audit report to the QA Department, and to the Quality Assurance Committee for review of findings and corrective action. Auditor certifications of independent audit teams will be retained by the Quality Assurance Department.

The programs of contractor organizations that perform quality related activities shall be reviewed to assure that their management regularly reviews the status and adequacy of that part of the FPL Quality Assurance Program which they are exe'cuting.

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TOPICAL QUALITYASSURANCE REPORT TQR 3.0 R ev.

DESIGN CONTROL Date FLORIOA POWFR 4 LIGHT COMPANY May 7 19 Page 1

of 3.1 GENERAL RE UIREMENTS A Quality Assurance Program shall be established for design related activities.

This design control program shall ensure that the design is defined, controlled and verified; that applicable design inputs are specified and correctly translated into design output documents; that design interfaces are identified and controlled; that design adequacy is verified by persons other than those who designed the item; and that design changes, including field changes, are governed by control measures commensurate with those applied to the original design.

Design records shall be developed to provide evidence that the. design process and design verification were performed in accordance with the requirements of FPL's Quality Assurance Program. The design organization, the Power Plant Engineering Department, the Fuel Resources Department ot'esignated contractor organization shall be responsible for the content of these records..

Design records shall include design output documents and the important stops in the design effort. The intent of this documentation is to allow a technically qualified person to understand how the design was developed, and to'allow him to verify the design based on the design documentation and engineering data sources referenced therein.

3.2 IMPLEMENTATION The design organization's Quality Assurance Program for design control shall be approved by the FPL Quality Assurance Department prior to the release of approved design output by the design organization. The design organization is the organization responsible for approval of design output.

Quality Procedures and Quality Instructions shall be developed to delineate design control requirements governing design related activities performed by the Power Plant Engineering Department and the Fuel Resources Department and for delegating activities to contractor organizations.

TOPICAL QUALITYASSURANCE REPORT TQR 3.0 Rev.

DESIGN CONTROL May 7, 1982 FLORIDA POWER a LIGHT COMPANY Page 2 of 3.2.1 Design Process The design organization shall specify and document its design activities to the level of detail necessary to permit the design to be developed in a correct manner and to permit verification that design output documents satisfy design input requirements. Design methods, materials, parts, equipment and processes, including those associated with commercial grade items that are essential to the function of the structure, system or component shall be selected, reviewed and approved for suitability of application by the design organization.

Design inputs shall be identified, documented, reviewed and approved by the design organization. They shall be specified to the level of detail necessary to permit the design activity to be carried out in a correct manner, and to provide a consistent basis for making design related decisions, 'performing design verification and evaluating design changes. Changes to approved design inputs, including the reason for the changes, shall be approved, documented and controlled by the design organization.

The design organization shall identify aspects of manufacture, construction, inspection and testing critical to achieving the function of the structure, system or component. Quality standards and quality requirements shall be specified on design output or procurement documents. Changes from approved quality related requirements specified in design output, including the reason for the changes, shall be approved, documented and controlled by the design organization.

Design analyses shall be controlled and documented. Approved design output documents and approved changes thereto shall be relatable to the design input by documentation in sufficient detail to permit verification. The design organization shall establish procedures to review industry design experience.

As appropriate, this experience shall be made available to cognizant design personnel.

TOPICAL QUALITYASSURANCE REPORT TQR 3.0 Rev.

DESIGN CONTROL Date FLORIDA POWER 4 LIGHT COMPANY May 7 l982 Pe9e 3 af 3.2.2 Design Change Control Changes to approved design output documents, including field changes, shall be justified, subjected to control measures commensurate with those applied to the original design, and shall be reviewed and approved by the same design organization that approved the original design unless other organizations are specifically designated.

Where a significant design change is necessary because of an incorrect design, as appropriate, Power Plant Engineering or Fuel Resources shall determine the cause of the incorrect design. As necessary, design and verification procedures shall be reviewed and modified to correct the cause of the incorrect design.

During the operations phase, design changes shall also be reviewed by operating plant management including plant Quality Control. The intent of this review is to ensure that implementation of the design change is coordinated with any - necessary changes to operating procedures and practices, and required QC Surveillance activities. In accordance with plant technical specification requirements, nuclear safety related design changes are reviewed by the Plant Nuclear Safety Committee (PNSC) or Facility Review Group (FRG) and the Company Nuclear Review Board (CNRB).

3.2.3 Design Interface Control The design organization shall be responsible for identification, control, resolution and documentation of design interface requirements. Procedures shall establish interface controls between participating organizations and between the various technical disciplines within the design organization.

These procedures shall include the assignment of responsibility, and be in sufficient detail to cover the preparation, review, approval, release, distribution and revision of design output documents.

TOPICAL QUALITYASSURANCE REPORT TQR 3.0 Rev.

DESIGN CONTROL May 7, l982 FLORIOA POWER II LIGHT COMPANY Pe9e 0~

q 3.2.3. Design Inter face Control (Cont'd)

For interdisciplinary 'esign, approval documentation of each involved discipline of the design organization shall appear on the design output document or on a separate document directly traceable to the design output.

The design organization shall designate a discipline(s) responsible for resolution of the comments of participating organizations. The designated discipline(s) approval of a design output shall also document resolution of the comments of participating organizations.

3.2A Design Verification Design control measures shall be established to independently verify the design inputs, design process, and that design inputs are correctly incorporated into design output. The design organization shall develop procedures that govern design verification. These procedures shall require that the design organization identify and document the verification method utilized and that the documentation clearly identify those iI dividuals performing the design verification.

Design verification shall be performed by technically qualified individual(s) or group(s) other than those who performed the design. The original designers and verifiers may both be from the design organization. Design verification by the designer's immediate supervisor shall be limited to those instances where the supervisor is the only .qualified individual available within the design organization. These instances are further restricted to designs where the supervisor did not specify a singular design approach, or did not restrict design methods or alternatives, or did not specify design inputs (unless the specif ied design inputs have already been independently verified).

3ustification for verification by the designer's immediate supervisor should be documented along with the extent of the supervisor's involvement in the design.

TOPICAL QUALITYASSURANCE REPORT TQR 3.0 Rev.

DESIGN CONTROL FLORIOA POWER 4 LIGHT COMPANY May 7 1982 Page 5 of 3.2.0 Design Verification (Cont'd)

The design organization shall be responsible for determining the extent of design verification and methods to be employed. The methods may include one or more of the following: the performance of design reviews, the use of alternate calculations, or the performance of qualification tests. This shall apply to original design and to changes to approved design output. Where reverif ication is not required for a design change the bases shall be documented by the design organization. Cursory supervisory reviews and mathematical checks for calculation accuracy do not satisfy the independent design verification requirement.

Design verification shall normally be completed prior to release of design output for procurement, manufacture or release by the design organization for use in design activities by a participating organization. Verification shall be conducted based on the status of design at the time of release of design documents. Where this timing cannot be met, verification may be deferred provided that the unverified portion of the design output, and all design output documents, structures, systems and components based on the unverified portion of design are identified and controlled. In all cases verification shall be completed prior to relying on any affected items to perform their design functions.

3.2.5 Computer Codes Organizations utilizing computer codes as a method for design shall maintain instructions or procedures to effect the following:

l. That such codes are verified for their particular use using benchmark problems, alternate calculations, comparison with other code or experimental results, design review or similar methods,

TOPICAL QUALITYASSURANCE REPORT TQR 3.0 Rev.

DESIGN CONTROL FLORIDA POWER t LIGHT COMPANY May 7, 1982 Page Gf 6

3.2.5 Computer Codes (Cont'd)

2. That such codes have been qualified for their specific application sufficient to ensure valid results,

3. That such codes are provided with user instructions sufficient for a technically competent individual to follow, That configuration controls are provided to assure that such code changes or modifications are documented and controlled.

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TOPICAL QUALITYASSURANCE .REPORT 0.0 TQR Rev.

1 PROCUREMENT DOCUMENT CONTROL

'" March 31, 1981 FLORIDA POWER aL LIGHT COMPANY Page 1

of 3 O.l GENERAL RE UIREMENTS Procurement of items and services shall be performed in accordance with procedures which assure that applicable regulatory requirements, design bases, code requirements, and other requirements necessary to assure quality shall be included or invoked by reference in the procurement document. These procedures shall delineate the sequence of actions to be accomplished in the preparation, review, approval, and control of procurement documents. Changes to procurement documents shall be subjected to the same degree of control as utilized in the preparation of the original documents.

0.2- -IMPLEMENTATION 0.2.1 Procurement Document Provisions Quality Procedures and Quality Instructions shall identify the'responsibilities and actions required of the organizations originating, reviewing, approving, and controlling procurement documents. These procedures shall require the procurement documents to specify:

ao The scope of work to be performed.

b. Technical requirements (by specifying or referencing) which shall include the applicable components and materials identification requirements, drawings, specifications, procedures, instructions, codes, and regulations and provide for identification of applicable test, inspection and acceptance requirements, or special pr ocess instructions.

c QA Program requirements ta be imposed on contractors which shall include the applicable portions of 10 CFR 50, Appendix B.

d. Right of access which provides, as appropriate, for access to contractor facilities and records for inspection or audit by FPL or its designated representative, and to access for events such as witness and hold points.

TOPICAL QUALITYASSURANCE REPORT 00 TQR Rev.

l PROCUREMENT DOCUMENT CONTROL

'" March 31 198l FLORIOA POWER d LIGHT COMPANY Pe9e 2 <f 3 0.2.1 Procurement Document Provisions (Cont'd)

e. The documentation required to be prepared, maintained, and/or submitted to FPL or its representative for review, approval, or historical record. The time of submittal of this documentation and the retention and disposition of quality assurance records which will not be delivered to FPL shall be prescribed.

0.2.2 Procurement Document Review Procurement documents shall be reviewed for correctness, and inspectability and controllability of quality requirements in accordance with Quality Procedures and Quality Instructions to assure that the appropriate provisions of Section 0.2.l are included. This review shall be documented and performed by designated technical.and quality eyaluators, and shall assure that the procurement document was prepared, reviewed and approved as required.

Procurement documents for the purchase of spare or replacement parts for

-safety related structures, systems, and components are subject to controls equivalent to those used for the original equipment.

Changes to procurement documents, whether initiated by FPL or their representative, are subjected to the same degree of control as that utilized in the preparation of the original document.

0.2.3 Selection of Procurement Sources The Purchasing, Fuel Resources or Corporate Contracts Department, as applicable, shall verify that the procurement document has been reviewed and approved, and that the supplier has been approved prior to issuing the purchase order for safety related materials or services. Supplier approval is not necessary if the important characteristics of the item can be verified by inspection or test.

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TOPICAL QUALITYASSURANCE REPORT TQR 4.0 Rev.

PROCUREMENT DOCUMENT CONTROL

'" March 31, 1981 FLORIDA POWER 4 LIGHT COMPANY Page Qf 3 3 0.2.0 The overall procurement requirements including those related to planning, bid evaluation, and review and concurrence'f suppliers QA programs are described in Quality Procedures and Quality Instructions.

TOPICAL QUALITYASSURANCE REPORT Rev.

INSTRUCTIONS, PROCEDURES, Date FLORIDA POWER 8 LIGHT COMPANY 3une 10 1985 AND DRAWINGS Page of 1 3 5.1 GENERAL RE UIREMENTS Activities affecting quality of nuclear safety related structures, systems, and components shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. These documents shall include appropriate quantitative criteria such as dimensions, tolerances, and operating limits, and qualitative criteria such as comparative workmanship samples, to assure that the quality assurance activity has been satisfactorily accomplished.

5.2 IMPLEMENTATION 5.2.1 Quality Assurance Program Documents The FPL Quality Assurance Manual described in TQR 2.0 contains corporate Quality Procedures which comply with the criteria of 10 CFR 50, Appendix B. Quality Procedures and department level Quality Instructions provide direction for activities affecting quality. The Quality Assurance Department reviews and comments on Quality Instructions written by other departments. Comments concerning compliance with corporate QA commitments and requlatory requirements are resolved prior to issuance. The Quality Assurance Department receives controlled copies of Quality Instructions issued by other departments.

During the design, modification, and procurement phases, the Architect/Engineer or other contractors may be delegated responsibility for maintaining, issuing and verifying the implementation of appropriate, program documents. In this case, Quality Assurance Department audit and/or Construction Quality Control surveillance activities shall assure that such measures are established and implemented. Contractor programs shall clearly delineate the actions to be accomplished in the preparation, review and

TOPICAL QUALITYASSURANCE REPORT Rev.

INSTRUCTIONS, PROCEDURES, Date FLORIDA POWER a LIGHT COMPANY AND DRAWINGS Page of 2

5.2.1 Quality Assurance Program Documents (Cont'd) control of instructions, procedures and drawings, and the methods for complying with the appropriate criteria of 10 CFR 50, Appendix B.

5.2.2 Procedures and Instructions Instructions and procedures for activities affecting quality shall be prepared, reviewed, and approved in accordance with written Quality Procedures or Quality Instructions.

For plant operations, on-site plant procedures shall be prepared; reviewed, and P

approved in accordance with written instructions which includes a review for concurrence by Quality Assurance or Quality Control personnel. These plant procedures include operating procedures, off-normal and emergency procedures, test procedures, and calibration procedures. Also included are maintenance and 'repair procedures for subcontracted maintenance and repair activities which are outside the normal scope of plant craft capability. A

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plant change or modification of a magnitude requiring the assignment of a Project General Manager - Nuclear shall be subject to the QA Program as discussed in 5.2.1.

For backfit activities, contractors shall be required to have Quality Assurance Programs which contain written instructions for preparation, review, and approval of procedures, instructions, and drawings affecting quality. In addition, Contractor's site procedures and Quality Control inspection procedures shall be approved by FPL Project Site Manager, or his designee, following reviews by Quality Assurance or Quality Control personnel to assure compliance with Corporate commitment and regulatory requirements.

TOPICAL QUALITYASSURANCE REPORT T R Rev.

INSTRUCTIONS, PROCEDURES, Date FLORIDA POWER a LIGHT COMPANY 3une 10 1985 AND DRAWINGS Page of 3 3 5.2.3 Drawings The design organization is responsible for review and approval of drawings.

For delegated design activities, as appropriate, the Power Plant Engineering Department or the Nuclear Fuel Department may approve changes to drawings. The, technical control of drawings, i.e., review and approval of the drawing and all changes thereto shall be governed by procedures. A means shall be developed and updated as required to identify approved drawings and revisions thereto. A Master Drawing List is the normal means used for this.

5.2A Acceptance Criteria

~ 'uality Procedures and Quality Instructions require that quality related instructions, procedures, and drawings include adequate quantitative and qualitative acceptance criteria, as appropriate, for determining satisfactory work performance and . quality . compliance. These acceptance criteria requirements apply to important activities such as design, operations, test control, inspection, and plant modifications.

0 TOPICAL QUALITYASSURANCE REPORT TQR 6.0 Rev.

3 DOCUMENT CONTROL June 10, 1983 FLORIDA POWER 8 LIGHT COMPANY 6.1 GENERAL RE UIREMENTS I

The distribution of documents such as instructions, procedures, and drawings which provide guidance, specifications, or requirements affecting the quality of nuclear safety related structures, systems, and components shall be controlled.

These documents shall be prepared, reviewed for adequacy, and approved for release by authorized personnel in the effected organization. These documents shall be distributed to locations where the activity is performed.

Changes to controlled documents shall be so identified and shall be reviewed and approved by the same organization that performed the original review and unless otherwise specified in the implementing procedures. In addition, 'pproval procedures shall provide for controlling obsolete documents to preclude the possibility of use of outdated documents.

6.2 IMPLEMENTATION 6.2.1 Responsibility Quality Procedures shall delineate the control measures for controlled documents including direction for the review for adequacy, approval by authorized personnel, distribution of controlled documents and verification that changes are promptly incorporated. These control measures shall apply to documents affecting the quality of nuclear safety related structures, systems, and components such as:

a. design specifications;

b. design, manufacturing, construction, and installation drawings;

c. quality program manuals, procedures, and instructions;

TOPICAL QUALITYASSURANCE REPORT

.TQR 6.0 Rev.

DOCUMENT CONTROL 3une 10, 1983 FLORIDA POWER aL LIGHT COMPANY Page 2 of 6.2.1 Responsibility (Cont'd)

d. inspection, manufacturing, and test procedures and instructions;

e. plant operating and maintenance procedures;

f. plant Safety Analysis Reports and related design criteria documents.

The requirements for control of procurement documents are contained in TQR 0.0.

During all phases of the plant life, it shall be the responsibility of each organization issuing controlled documents to use. document control procedures. Procedures shall document the responsibility for review, approval, maintenance and distribution of documents, including coordination and control of documents which describe interface relationships.

During the design and construction phase and for operating plant changes under their cognizance, the Architect/Engineer, Nuclear Steam Supply System vendor, and other contractors shall be responsible for assuring that all revisions required as a result of FPL comments, nonconformances, or engineering work are incorporated into revised documents.

6.2.2 Distribution of Controlled Documents Quality Procedures shall specify that controlled documents and revisions be distributed to locations where the activity is performed.

TOPICAL QUALITYASSURANCE REPORT TQR 6.0 Rev.

3 DOCUMENT CONTROL June IO, 1983.

FLORIDA POWER & LIGHT COMPANY Page Gf 3 3 6.2.3 Drawing Control FPL assumes control of the drawings and Master Drawing List after initial operation of the facility or delegates this activity to a qualified contractor.

The Power Plant Engineering Department shall require that participating design organizations update the drawings and Master Drawing List to reflect the as-built conditions of the facility prior to FPL's acceptance of these documents.

.Maintenance, distribution and control of the drawings and the Master Drawing List by FPL during the operation phase shall be assigned to a drawing custodian. Revision to drawings shall be approved prior to release by the drawing custodian, approval shall be by, as appropriate, -Power Plant 0 Engineering, Nuclear Fuel, or a design organization designated by one of these departments.

During the operation phase a system shall be established to provide ready access and availability of drawings to engineering and operations personnel; to identify drawings'affected by approved plant design changes; and to update drawings and the Master Drawing List to reflect implemented design changes.

6.2A Instruction dc Procedure Control Participating organizations shall be responsible for development, maintenance and control of those documents identified in paragraph 6.2.l issued by them as controlled documents. Each organization shall be responsible for the adequacy of their procedures.

6.2.5 Obsolete Documents Controls established by Quality Procedures or Quality Instructions shall assure that outdated copies of controlled documents are not inadvertently used.

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TOPICAL QUALlTYASSURANCE REPORT TQR 7.0 Rev.

3 CONTROL OF PURCHASED Oate June l.0, l93lf FLORIOA POWER 5 LIGHT COMPANY ITEMS AND SERVICES Page Gf 2 3 7.2.2 Verification Activities Quality Procedures shall define the requirements for verification activities such as surveillance, inspection, or audit to assure conformance of procured items and services to identified requirements. These verification activities shall be performed in accordance with written procedures which specify the documentation required and the characteristic or process to be witnessed, inspected, verified, or accepted. FPL verification activities shall be accomplished by qualified personnel to verify that the supplier complies with quality requirements, and when possible, shall be performed on those items where verification of procurement requirements cannot be determined upon receipt.

7.2.3 Receiving Inspection Quality Procedures and Quality Instructions shall delineate requirements and I

responsibilities for the performance of receiving inspection. This inspection-shall verify that suppliers have fulfilled their contractual obligation and that the procured items meet the appropriate quality requirements. Receiving inspection shall include, as appropriate:

ao Measures for verifying that the shipment is complete, properly identified, undamaged, and corresponds with 'he r eceiving documentation;

b. Measures for inspection of the item and review of supporting documentation (e.g., mill test reports, NDE reports) as required by the purchase documents; Ci Measures for inspection and acceptance of items to inspection instructions;

d. Measures for identifying and controlling acceptable items including identification of inspection status prior to release from the receiving inspection area;

TOPICAL QUALITYASSURANCE REPORT 7.0 TQR Rev.

CONTROL OF PURCHASED Oate June l0 l98ff, FLORIDA POWER 6 LIGHT COMPANY ITEMS AND SERVICES Page of 3 3 7.2.3 Receiving Inspection (Cont'd)

e. Measures for identifying, segregating, and handling nonconforming items;

f. Measures to. ascertain that inspection records or Certificates of Conformance are available prior to release.

7.2A Supplier Furnished Records Records required to be furnished by the supplier are specified in the procurement document. Certifications or documentation verifying conformance, provided by the supplier shall identify the specific procurement requirements met (either by reference to the purchase order or by delineation). Such certification shall identify any procurement requirements which have not been met. and provide a description of those nonconformances dispositioned "accept as is" or "repair". Control of procurement documents is described in TQR 0.0.

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TOPICAL QUALITYASSURANCE REPORT 8.0 TQR Rev.

IDENTIFICATIONAND CONTROL OF Date June IP, I98q MATERIALS, PARTS, AND COMPONENTS Page l Of S.l GENERAL RE UIREMENTS Materials, parts, and components, including partially fabricated assemblies, shall be identified and controlled as required throughout fabrication, storage, installation, construction, and use of the item. The identification of the item shall be maintained by heat number, part number, serial number, FPL MRS number, or other suitable means, and shall be physically marked on the item or on records traceable to the item. The object of these controls shall be to prevent the use of incorrect or defective materials, parts, and components. (The FPL Material and Supplies MdcS number is a number given to each unique type of item in inventory to distinguish it from each other type of item in inventory).

8.2 IMPLEMENTATION Quality Procedures and Quality Instructions shall establish the responsibilities arid requirements for the identification and control of materials, parts and components. The procedures and instructions shall assure that identification and control is maintained 'throughout fabrication, receipt, handling, storage and installation of items. Provisions include:

a0 Requirements for traceability to appropriate documentation, =such as:

procurement documents, manufacturing documents, drawings, specifications, inspection and test records, and nonconformance reports.

b. Controls to assure that the correct identification of an item is verified and documented prior to release for fabrication, assembly, shipping or installation.

C. Requirements which assure that the method or location of markings do not

.affect the function or quality of an item.

d. Establishment of identification requirements by specifications, drawings, procurement documents, instructions or procedures during initial planning.

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TOPICAL QUALITYASSURANCE REPORT 80 TQR Rev.

IDENTIFICATIONAND CONTROL OF MATERIALS, PARTS, AND COMPONENTS aune lo, l93e FLORIDA POWER 4 LIGHT COMPANY Pe9e 2 of FPL may delegate any portion of the implementation of the identification and control program to the Architect/Engineer, Constructor, Nuclear Steam Supply System vendor or other contractors. If delegated, contracts shall require that the contractor establish an identification and control program which meets the requirements of this TQR.

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TOPICAL QUALMYASSURANCE REPORT TQR 9.0 Rev. 5 CONTROL OF SPECIAL PROCESSES Oate one 10, 198$

Pege 1 Qf 3 9.1 GENERAL RE UIREMENTS Measures shall be established to assure that special processes such as welding, heat treating, and nondestructive examination, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements.

9.2 IMPLEMENTATION The Power Plant Engineering Department, or the Fuel Resources Department or the delegated contractor organization, as appropriate, shall include special process requirements in their design outputs and changes thereto. Special processes used during plant operations shall be the responsibility of the plant manager, who shall ensure that procedures are developed, reviewed, approved and controlled, and that personnel are qualified.

9.2.1 Identificatio~ of Special Processes Special processes are those processes which must be qualified and controlled where quality is highly dependent on close control of process variables or operator skills, and objective verification of end quality (inspection, examination or testing) is difficult.

As a further clarification, special processes identified as such by applicable codes and standards shall be controlled, qualified, and implemented in accordance with those codes and standards. Examples of special processes include (but are not limited to) welding, heat treating, and nondestructive examination. Others, i.e., flushing, protective coating, plating applications'nd nuclear cleaning should be reviewed to determine if they are special processes.

TOPICAL QUAL1TY ASSURANCE REPORT TQR 9.0 Rev. 5 CONTROL OF SPECIAL PROCESSES Date June lP, l98lf FLORIDA POWER EL LIGHT COMPANY Page 2 of 9.2.2 Procedure Qualification and Control Quality Procedures specify that written process control procedures shall be used and qualified as required by applicable specif ications, codes, or standards.

Where FPL assigns work to outside contractors, the contractors shall make their procedures and personnel qualifications available to FPL prior to the start of work. The Architect/Engineer, Nuclear Steam Supply System vendor, or other organimtion designated by FPL shall be responsible for the evaluation and acceptance of on-site contractor special process procedures, and shall interface with the appropriate FPL department, as necessary, to resolve review comments with the contractor. The contractor shall also be responsible for the control and approval of sub-contractor procedures.

9.2.3 Personnel Qualification and Certification Pro-edures or instructions shall specify personnel qualification/certification requirements. Personnel responsible for the performance and verification of special processes shall be trained, tested, and .certified as required by applicable specifications, codes and.standards. Requirements for the period of certification, retesting, and recertification of personnel shall also be specified. Contractors shall qualify personnel and maintain records. of qualified personnel in accordance with applicable codes, standards, specifications, and contract or procurement document requirements. The control, maintenance and calibration of equipment used for special processes shall be controlled in accordance with the QA Program.

9.2.0 Special Process Records g

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a The Plant Manager is responsible for the review and retention of records.

7 Records shall provide objective evidence that special processes were 8 performed in compliance with approved pr ocedures by qualified personnel, and Z

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TOPICAL QUALITYASSURANCE REPORT TQR 90 Rev. 5 CONTROL OF SPECIAL PROCESSES June i0, 1984 FLORIDA POWER IL LIGHT COMPANY Page 3 Of 9.2.0 Special Process Records (Cont'd) that when required by procedures, specifications, and codes, such performance was verified. Results of nondestructive examinations shall be recorded in accordance with applicable specifications, codes and standards. These records shall be retained by the vendor or supplied to FPL as required by contract or purchase orders. If records are to be retained by the vendor, the contract or purchase order shall specify the retention period and instructions for final disposition of such records.

For backfit activities, the Construction Quality Control organization is responsible for the review of nondestructive examination documents for

-acceptance. The Project Site Manager is responsible for assuring that documents for special processes utilized for modifications are properly collected, reviewed, accepted and transmitted for retention of records.

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TOPICAL QUALITYASSURANCE REPORT Rev.

INSPECTION Date FLORIOA POWER 8 LIGHT COMPANY 3u e Page of 1

10-1 GENERAL RE UIREMENTS A program for inspection shall be established and executed by or for FPL to verify conformance with the documented instructions, procedures, and drawings for accomplishing an activity. Such inspections shall be performed by individuals or groups other than those who per formed the activity being inspected.

Examinations, measurements, and tests of materials or products processed shall be performed for each work operation, where necessary, to assure conformance to established requirements. If direct inspection of processed materials or products is impossible or disadvantageous, indirect control by monitoring shall be provided. Mandatory inspection, witness, or hold points beyond which work shall-not proceed without the consent of FPL or a designated representative shall be indicated in the appropriate documents.

10.2 .

IMPLEMENTATION 10.2.1 Inspection Responsibilities For plant operations activities, a program for on-site inspection of activities affecting quality shall be established by the Nuclear Energy Department.

Nuclear Energy shall perform inspections, surveillance, and monitoring of plant activities and plant operations as required by established plans, schedules, and/or procedurally required inspection, witness, or hold points.

In all cases, the personnel performing the inspection shall be independent of the group performing the work.

For plant modifications assigned to Project Management Department or when requested by the Plant Manager, a program for on-site inspection of these activities affecting quality shall be established and executed by the Construction Department to ensure conformance with documented g

V) instructions, procedures and drawings.

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TOPICAL QUALITYASSURANCE REPORT TQR 10.0 Rev.

INSPECTION 3une 10, 198

. FLORIDA POWER a LIGHT COMPANY Page 2

of 10.2.1 Inspection Responsibilities (Cont'd)

For these plant modifications, the Construction Department may delegate the establishment and execution of this program to a contractor or other designated FPL representative, but shall retain ultimate responsibility for the program. For preoperational start-up and testing of plant modifications, Nuclear Energy personnel may report functionally to the Project Site

'anager and establish plans, schedules, and procedurally required inspection, witness or hold points. In all cases, the personnel performing the inspection shall be independent of the group performing the work. The Construction Department shali also be responsible for performing receiving and process verification inspections for work under, the jurisdiction of the Project General iManager, or as requested by the Plant Manager.

The System Protection Department may perform inspections of equipment within their purview during operations. Inspections shall be performed in accordance with approved, written procedures by qualified personnel.

Quality Procedures and Quality Instructions shall be written which delineate the requirements and responsibilities for the performance of inspections.

10.2.2 Inspection Plans and Schedules Documented inspection plans may be either a separate document or an integral part of work instruction documents. The plans shall be based on design specifications, procurement documents, drawings, other specifications, or previous experience, as appropriate. Inspections shall be scheduled to assure that sufficient time and resources are available, and to assure inspections are not inadvertently omitted or bypassed.

TOPICAL QUALITYASSURANCE REPORT Rev.

Date INSPECTION FLORIDA POWER E LIGHT COMPANY Page of 3

10.2.3 Inspection Personnel a~ Inspections shall be performed by individuals other than those who performed, or directly supervised the activity being inspected.

Inspection personnel shall be qualified and certified in accordance with appropriate codes, standards, and/or company training programs.

Qualifications and certifications shall be kept current.

b. Prior to performing inspections, inspection personnel shall have access to the 'drawings, procedures, specifications, or other documented criteria necessary for performance of the inspection.

10.2A Inspection Procedures

a. Required inspection, surveillance, or monitoring activities shall be performed and documented according to written, approved instructions

.or procedures. Inspection procedu'res, instructions, or checklists shall contain the following:

o Identification of characteristics to be inspected.

o Identification of the individual or groups responsible for performing the inspection.

o Acceptance criteria or reference to the acceptance criteria.

o A description of the method of inspection.

o Verification of completion and certification of inspection.

o ' record of the results of the inspection.

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TOPICAL QUALITYASSURANCE REPORT T R 00 Rev.

6 INSPECTION Date 3une 10 19 FLORIDA POWER a LIGHT COMPANY Page of 0

10.2.0 Inspections Procedures, (Cont'd)

b. Inspection procedures shall be reviewed by QC personnel to determine the need for an independent inspection and the degree and method if such an inspection is required, and to assure the identification of inspection personnel and the documentation of inspection results.

c. Written approved instructions shall specify surveillance or monitoring of processing methods, or testing and operation of equipment when inspection is impossible, inaccessible or not applicable.

d. Modification, repair, replacement or rework items shall be inspected in accordance with original inspection requirements .or acceptable alternatives.

10.2.5 Inspection, Witness, and Hold Point Identification Appropriate. inspection, witness, or hold points shall appear in process documents (e.g., construction, testing, operating and maintenance procedures). These process procedures are subject to the review of the appropriate Quality Control organization for adequacy of inspection, witness, and hold points.

Mandatory hold points shall be used when witnessing and inspecting must be performed and signed-off by the responsible personnel before work can proceed.

FPL shall indicate FPL witness or hold points applicable during the manufacture of an item in procurement documents. A distinction shall be made between witness points and mandatory hold points.

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TOPICAL QUALITYASSURANCE REPORT 11.0 TQR Rev.

1 TEST CONTROL oate FLORIDA POWER 4 LIGHT COMPANY one 10, 1933 Page 1

of 3 11.1 GENERAL RE UIREMENTS A test program shall be established to assure that testing required to demonstrate that structures, systems and components will perform satisfactorily in service is identified, accomplished, and documented in accordance with written procedures. The test program shall include, as appropriate, proof tests, prior to installation, preoperational tests, start-up tests, and operational tests, and retest following repairs, replacements or modifications.

11.2 IMPLEMENTATION 11.2.1 Test Program

'W "Testing requirements shall be identif ied in the, engineering/design documents, SAR documents,'rocedures, or procurement documents, as-

'ppropriate. Retest following repairs, replacements, or modifications shall be performed in accordance with the original design and test requirements or accep)able alternatives. Retest shall be performed when the original test results are invalidated.

'uality Procedures and Quality Instructions shall be written which delineate the methods and responsibilities for controlling, accomplishing, and documenting testing.

FPL may delegate the implementation of all or any part of the test program to other organizations but shall retain ultimate responsibility for the program. The contractor shall be required to control, perform and evaluate tests in accordance with written procedures and shall be required to prepare a written test program detailing the testing required.

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TOPICAL QUALITYASSURANCE REPORT TQR 11.0 Rev.

TEST CONTROL 3une l0 J983 FLORIDA POWER 4 LIGHT COMPANY Page Gf 2 3 l 1.2.2 Test Procedure Preparation and Test Performance Testing shall be accomplished in accordance with written approved test procedures which incorporate or reference the requirements and acceptance limits in the applicable design and procurement documents. The test procedure or test program documents shall include the following as a minimum:

a. Instructions for the testing method used;

b. Required test equipment and instrumentation;

c. Test requirements and acceptance criteria;

d. Hold, witness, inspection and data collection points;

e. Test prerequisites such as: calibrated instrumentation; trained, qualified, and licensed or certified personnel; preparation, condition and completeness of item to be tested; suitable and controlled environmental conditions.

f. Methods for documenting or recording test dat'a and results;

g. Provisions for data collection.

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TOPICAL QUALITYASSURANCE REPORT 11.0 TQR Rev.

1 TEST CONTROL ate June 10, 1983 FLORIDA POWER i LIGMT COMPANY Page 3 of 11.2.3 Evaluation of Test Results The documented test results shall be evaluated against the predetermined acceptance criteria by a group or individual having appropriate qualifications. The acceptance status of the test shall be documented.

Deficiencies noted during the evaluation shall be documented and dispositioned in accordance with approved Quality Procedures or Quality Instructions.

The evaluation of the test results may be delegated to other organizations; however, FPL shall retain the responsibility for the evaluation. The evaluating organization shall be required to use qualified personnel, evaluate the data against predetermined criteria, and document the results of the evaluation and acceptance status of the test.

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TOPICAL QUALITYASSURANCE REPORT Rev.

Date CONTROL OF MEASURING FLORIDA POWER W LIGHT COMPANY AND TEST EQUIPMENT Page 1

12.1 GENERAL RE UIREMENTS Tools, gauges, and other measuring and testing equipment used as the basis for acceptance in activities affecting quality shall be properly controlled, periodically calibrated, and adjusted to assure that accuracy is maintained within limits necessary to verify that design requirements have been met. It is the responsibility of each department maintaining calibrated instruments to provide for the calibration and control of such instruments.

12.2 IMPLEMENTATION 12.2.1 Control of Measuring and Test Equipment Procedures shall be written to delineate the methods and responsibilities for the control, maintenance, and calibration of measuring and test equipment (MME). MdcTE control procedures or calibration program documents shall contain the following:

a. A listing of MitcTE to be controlled;

b. Frequency of calibration of listed MdcTE. The frequency may be based on calendar time or relate to usage, and be based on such factors as experience, inherent stability, instrument purpose, or accuracy required;

c. A method for controlling issue and recall of portable MdcTE;

d. A method to. identify controlled MRTE (e.g., labeling) required calibration frequency and calibration test data applicable to the MRTE; f

e. Method to document and maintain the status of MRTE.

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TOPICAL QUALITYASSURANCE REPORT R ev.

3 CONTROL OF MEASURING Date FLORIDA POWER a LIGHT COMPANY 3une 10 1985 AND TEST EQUIPMENT Page of 2 3 12.2.1 Control of Measuring and Test Equipment (Cont'd)

FPL may delegate the control and/or calibration of MRTE to other organizations. FPL, however, retains ultimate responsibility for control and calibration, and the contractor shall meet the requirements of this TQR or an acceptable alternative program as required by the procurement document for the contracted services.

12.2.2 Calibration Procedure MdcTE shall be calibrated in accordance with written approved procedures.

The calibration. procedures shall contain, as a minimum:

a. Identity of MATE to which the. procedure applies;

b. Calibration equipment and reference standards to be used;

c. Acceptance criteria;

d. Sequence of operations and special instructions;

e. Documentation and data collection requirements;

f. A requirement that MATE be checked and results recorded before adjustments or repairs are made;

g. Calibration frequency required.

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TOPICAL QUALITYASSURANCE REPORT Rev.

CONTROL OF MEASURING Date FLORIDA POWER a LIGHT COMPANY 3une 10 1985 AND TEST EQUIPMENT Page of 3 3 12.2.3 Calibration Standards MATE shall be calibrated using reference standards whose calibration has a known, documented, valid relationship to nationally recognized standards or accepted values of natural physical constants. If no national standard exists, the basis for calibration shall be documented. Standards and reference standards shall have an accuracy level, range and stability which are adequate to verify that the equipment being calibrated is within tolerance and adequate for the programmatic requirements of the equipment being calibrated.

NBS/LAB "greater than" tolerance PRIMARY STANDARD (if applicable)

'greater than" tolerance SECONDAR, Y STANDARD (if applicable)

"greater than" tolerance iVlRTE (installed instruments, measuring equipment used for inspection and maintenance, etc.)

The accuracies of MATE and reference standards shall be chosen such that the equipment being calibrated can be calibrated and maintained within the required tolerances.

12.2.0 "Out of Tolerance" Control MdcTE and reference standards, when found out of tolerance, shall be so identified and removed from service. An investigation shall be conducted to determine the validity of previous inspection or test results gained through use of the instrument, and of the acceptability of items previously inspected or tested.

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TOPICAL QUALITYASSURANCE REPORT TQR 13.0 Rev.

HANDLING,STORAGE AND SHIPPING 3une 10, 1980 FLORIDA POWER 4 LIGHT COMPANY Page 1 of-13.1 GENERAL RE UIREMENTS Written instructions or procedures shall be established and implemented for the cleaning, shipping, storage, preservation, packaging, and handling of specified items. These instructions and procedures shall delineate measures which prevent degrading an item through damage or deterioration. When necessary for particular products, special protective environments such as inert gas atmosphere, specific moisture content levels, and temperature levels shall be specified and provided.

13.2 IMPLEMENTATION 13.2.1 General Instructions or procedures shall be written to define the requirements and responsibilities for the cleaning, packaging, preservation, handling, storage,.

and shipping of equipment and material, and shall require!mplemqntation of the established design. and: specification requirements by personnel having appropriate qualifications. FPL may delegate any portion of the responsibility for handling, storage and shipping of material and equipment, but shall retain ultimate responsibility. Where any of the functions in the section which follow is delegated to a contractor, the contractor shall be required to adhere to the FPL requirements stated herein.

Consideration shall be given to the need for special requirements in the preparation and review of procurement documents (see TQR 0.0).

Procedures and instructions shall be prepared and implemented for special op-site handling or storage requirements. The receiving department shall be responsible for on-site implementation of the special handling, shipping, and storage requirements for items received and controlled by their organization.

TOPICAL QUALITYASSURANCE REPORT TQR 13.0 Rev.

HANDLING,STORAGE AND SHIPPING Date June 10 FLORIOA POWER 5 LIGHT COMPANY 198'age 2 of 13.2.2 Establishment of Handling, Storage, and Shipping Requirements Special handling, preservation, storage, cleaning, packaging, and shipping requirements shall be specified, as appropriate, in the design documents or purchase orders. The requirements established in the design documents or purchase orders shall be consistent with industry accepted standards, the importance of equipment or material to nuclear safety, and the material or equipment's sensitivity to damage. The preparation of these design documents or purchase orders may be delegated by FPL to other organizations. The preparation and control of design documents and purchase orders is described in TQR 3.0 and 0.0.

13.2.3 Handling, Storage, and Shipping Procedures Materials and equipment which are to be incorporated into a safety related system of a nuclear power plant shall be handled,, stored, and shipped in accordance with written procedures, where necessary, to implemem the

'design document and purchase order requiremen s. These procedures shall assure that cleaning, handling, storing, packaging, shipping, and preserving materials, components and systems will preclude damage, loss, or deterioration by environmental conditions, such 'as temperature or humidity.

The preparation and/or implementation of these pt'ocedures may be delegated to other organizations, but. FPL shall retain the ultimate responsibility for proper material handling, storage, and shipping.

13.2A Verification of Proper Handling, Storage, and Shipping.

The Quality Assurance Department shall be responsible for verification of proper handling, storage and shipping at vendor facilities. The Plant Manager and the QA Department shall be responsible for verification of proper handling, storage, and shipping at the plant.

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TOPICAL QUALITYASSURANCE REPORT Rev.

INSPECTION, TEST, Date 3une 10 1985 0

FLORIDA POWER a LIGHT COMPANY AND OPERATING STATUS Page of 1 2 10-1 GENERAL RE UIREMENTS Measures shall be established to indicate by the use of markings such as stamps, tags, labels, routing cards or other suitable means, the status of inspections and tests performed on material, equipment, or systems. These measures shall provide for the identification of items which have satisfactorily passed required inspections and tests. Measures shall also be established for indicating the operating status of structures, systems and components to prevent inadvertent operations.

10.2 IMPLEMENTATION "

10.2.1 General

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For operations activities, the Nuclear Energy Department is responsible for

.establishment and maintenance of a suitable system for identifying the inspection, test, and operating status of materials, equipment, systems, and components. "

For plant modifications assigned to Project Management Department or when requested by the Plant Manager, the Project Site Manager is 'responsible for establishing a suitable system for identifying, inspecting and testing for material, equipment systems and components which is approved by Nuclear Energy Department. Each system shall be established, implemented and maintained in accordance with written Quality Procedures and Quality Instructions. The Architect/Engineer or Contractors shall develop and implement procedures to comply with contractual responsibilities, and applicable codes, standards, specifications, and criteria governing the status identification of procurement items being tested, installed, or fabricated. The Architect/Engineer (where applicable),

suppliers and contractors shall be required to maintain a system for identifying the inspection, test and processing status of materials, parts, and CO C

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TOPICAL QUALITYASSURANCE REPORT Rev.

INSPECTION, TEST, Date FLORIDA POWER 5 LIGHT COMPANY 3une 10 198 AND OPERATING STATUS Page of 2 2 10.2.1 General (cont'd) components. Elements of this system require that suppliers and contractors have a controlled manufacturing and test operation in order to preclude the inadvertent bypassing of processing, inspections or test, and to provide a positive identification of component status throughout all phases of I

manufacturing, testing, and inspecting, by means of tagging, routing cards, stamping, manufacturing or test reports, labeling or other appropriate methods. The Vice Presidents - Turkey Point and St. Lucie and Quality Assurance Departments shall verify adequacy. of the controls established and implemented, as appropriate for their site.

10.2.2 Status Identification and Control W

'Quality Procedures and .Quality Instructions shall describe control of the application and removal of markings such as stamps, tags, labels, routing cards, and other suitable means to indicate the status of non-operational, nonconforming, or malfunctioning nuclear safety related structures, systems and components to prevent inadvertent operation, and to prevent omission of inspections, tests, or other critical operations. These procedures and instructions shall delineate the requirements, methods and responsibilities for indicating the status of the affected items. These procedures will clearly delineate the individuals or groups responsible for application and removal of status indicators.

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TOPICAL QUALITYASSURANCE REPORT Rev.

Date NONCONFORMING MATERIALS, FLORIDA POWER a LIGHT COMPANY PARTS OR COMPONENTS Page 1

15.l GENERAL RE UIREMENTS Measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation. These measures shall include, as appropriate, procedures for identif ication, documentation, segregation, disposition, and notification to affected organizations. Nonconforming items sh'all be reviewed and accepted, rejected, repaired or reworked in accordance with documented procedures.

15.2 IMPLEMENTATION 15.2.1 Program Quality Procedures and Quality Instructions shall define the responsibilities and methods for identifying, documenting, segregating and dispositioning nonconforming items. For procedure review requirements, see TQR 5.0.

Each department shall., be. responsible for the identification, control, and disposition of nonconformances within the scope of their departmental responsibilities.

Throughout plant life, FPL may delegate any portion of the identification and control of nonconforming items and services to an Architect!Engineer (A/E), constructor, NSSS vendor or other contractors. In any case, FPL retains the responsibility for assuring that requirements are met, and shall assure that the contractor's actions conform to requirements set by FPL.

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TOPICAL QUALITYASSURANCE REPORT Rev.

NONCONFORMING MATERIALS, Date FLORIDA POWER tL LIGHT COMPANY 3une 10 198 PARTS OR COMPONENTS Page of 2

15.2.2 Documenting and Controlling Nonconformances All'onconformances in safety related items shall be documented and reported for corrective action. Measures shall be delineated in Quality Procedures and Quality Instructions which control further processing, installation, or operation of nonconforming items. 'hese measures shall include:

a. Physical identification of the item as nonconforming.

b. Segregation of nonconforming items until properly dispositioned.

Where physical segregation is not practical, suitable tags, marking or documentation shall be used to assure control.

15.2.3 Documentation Documentation of the nonconforming item shall: identify the item; describe the nonconformance; show disposition of the nonconformance and inspection requirements and include the signature of the person approving the disposition.

15.24 Evaluation and Disposition Power Plant Engineering, Nuclear Fuel, Nuclear Energy, System Protection or the delegated contractor organization, as specified by procedure, shall evaluate nonconformances and disposition them based on the results of the evaluations. These evaluations and dispositions shall be reviewed, approved and documented in accordance with procedures.

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TOPICAL QUALITYASSURANCE REPORT Rev.

NONCONFORMING MATERIALS, Date FLORIOA POWER a LIGHT COMPANY 3une 10 198 PARTS OR COMPONENTS Page of 15.2.0 Evaluation and Disposition (Cont'd) d., Accessibility of material or items after release;

e. Cost of removal and repair of replacement should material or items eventually have to be removed, repaired, or replaced;

f. Impact on plant safety.

Items shall be reworked or repaired in accordance with documented procedures and shall be verified by reinspecting the item as originally inspected or by a documented method which is at least equal to the original inspection method.-

Quality Assurance or Quality Control personnel shall periodically review nonconformance reports to identify quality trends. The results'of these analyses shall be reviewed with appropriate members of upper level management.

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TOPICAL QUALITYASSURANCE REPORT R ev.

CORRECTIVE ACTION Date FLORIOA POWER & LIGHT COMPANY 3une l0 1983 Page of 2 3%

16.2. l Corrective Action and Follow-Up (Cont'd)

b. "Routine Corrective Action" applies to conditions which do not require immediate corrective action.. Routine corrective action is assured through the distribution and disposition associated with inspection reports, surveillance reports, nonconformance reports, and audit reports; and the investigation analysis and action associated with reportable conditions.

Follow-up to verify implementation of corrective action and close-out of corrective action documentation is accomplished by the QA or QC organization responsible for verifying the corrective action. The Quality Assurance DepPrtment shall track, follow-up, and close-out open. items identified by QA Depart'ment audits and vendor surveillances, and shall assure the tracking of unresolved items and violations identified by NRC inspections. Each department shall be responsible for follow-up and close-out of corrective action resulting from their departmental inspections, tests, or operations.

If corrective action is inadequate or not timely, the follow-up organization shall request corrective action from management, as delineated in procedures. The Quality Assurance Committee is the final authority in the event that agreement is not reached at lower levels regarding stop work requests or other corrective action.

Where corrective action is required of contractor personnel, FPL shall define in procedures and contracts the corrective action interface between FPL and the contractor. FPL shall require the A/E, NSSS vendor, constructor and 11 other suppliers of safety related materials and services to have a documented l7 U

corrective action system.

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TOPICAL QUALITYASSURANCE REPORT Rev.

CORRECTIVE ACTION Date FLOAIOA POWER k LIGMT COMPANY 3une 10 1983 Page of 3 3 16.2.2 Recurrence Control It is the responsibility of the organization which identifies the significant condition adverse to quality to verify that corrective action description not only corrects the immediate condition, but also precludes the condition from recurring. The organization(s) that provide(s) the corrective action disposition and implementation is responsible to assure that the corrective action taken not only corrects the immediate condition, but also precludes recurrence.

16.2.3 Incidents and Reportable Occurrences Reporting Operating Reportable Occurrences and reports of incidents shall be investigated, documented as to cause and corrective action, and reported to the NRC in accordance with the applicable plant Technical Specifications.

Reportable Occurrences and reports of incidents that result in damage or are otherwise safety related, shall be forwarded to the Company Nuclear Review Board (CNRB) for review. Conditions adverse to quality are reported to operating plant management through: distribution of QA audit reports, QC inspection reports, corrective action requests, and the investigation and reporting of Reportable Occurrences in accordance with plant Technical Specifications.

TOPICAL QUALITYASSURANCE REPORT TQR 17.0 R ev.

QUALITYASSURANCE RECORDS Date June 10, 1985 FLORIDA POWER L LIGHT COMPANY Page 1 of 3 17.1 GENERAL RE UIREMENTS Sufficient records shall be maintained to furnish documented evidence of the quality of safety related structures, systems, and components, and of activities affecting their quality. The records shall include, as appropriate, data such as qualifications of personnel, procedures, and equipment; and other documentation such as inspection or test acceptance criteria, and the action taken in connection with deficiencies noted during inspection.

The records required to furnish documentary evidence of quality, herein called quality assurance records, shall be identifiable and retrievable. These records shall be maintained in facilities that provide a suitable environment to minimize deterioration or damage and to prevent loss.

The requirements and responsibilities for quality assurance record control, transmittal, retention,'and 'maintenance shall be established and documented.

These record requirements shall be consistent 'with applicable design, manufacturing, and installation codes,and standards, and with procurement document requirements.

17.2 IMPLEMENTATION 17.2.1 Records Identif ication Quality Procedures shall define the quality assurance records necessary to I

furnish documentary evidence of the quality of safety related structures, systems, and components; and activities affecting quality. These records shall include plant operating logs; results of design reviews, inspections, tests, audits, and material analyses; qualification of personnel, procedures, and equipment; design records such as drawings and specifications; procurement documents; calibration records; and nonconformance or

TOPICAL QUALITYASSURANCE REPORT 17.0 TQR Rev.

I QUALITYASSURANCE RECORDS 3une 10, FLORIDA POWER 4 LIGHT COMPANY 198.'age 2 of 3 17.2.1 Records Identification (Cont'd) corrective action reports. As a minimum, inspection and test records shall identify:

a. Inspector or data recorder;

b. Method or type of observations;

c. Test or inspection results;

d. Statement of acceptability;

e. Date of observation; and

f. Deficiencies and nonconformances, and the action taken in connection with these deficient conditions, either by inclusion or by reference to other documents.

17.2.2 Responsibilities Responsibilities shall be established and documented for the control, transfer, maintenance, and retention of quality assurance records. Quality Procedures shall provide guidance for determining the retention requirements of quality assurance records. Each organization responsible for the conduct of a quality activity shall be responsible for the maintenance of the subsequent quality assurance records unless retention responsibilities have been transferred by a prearranged agreement. In any case, the organization initiating the quality assurance records shall be responsible for their validity and approval.

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t TOPICAL QUALITYASSURANCE REPORT TQR 18.0 Rev.

AUDITS FLORIOA POWER S LIGHT'COMPANY 3une l0, 198ff Page 1

of 18.1 GENERAL RE UIREMENTS A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program. The audits shall be performed in accordance with the written procedures or checklists by'ppropriately trained personnel not having direct responsibilities in the areas being audited. =Audit results shall be documented and reviewed by management having responsibility in the area audited. Follow-up action, including reaudit of deficient areas, shall be taken, where necessary.

18.2 IMPLEMENTATION A comprehensive. program of audits is carried out by the Quality Assurance Department during the design, procurement, construction, and operations phase of nuclear power-plants. These audits are performed to verify that all safety related activities associated with nuclear power plants are carried out in accordanc'e with the requirements of the FPL QA Program, and that the implementation is effective.

18.2.1 Personnel Quality Procedures provide instructions for the training of QA Department personnel who perform audit activities, to assure that they are adequately indoctrinated and trained, and that they are qualified to carry out these activities. Quality Procedures provide for personnel qualified as Principal Auditors to be formally certified by Quality Assurance Department management. Certification shall be based on education, experience, training and other specified criteria.

TOPICAL QUALITYASSURANCE REPORT TQR IS.O Rev.

AUDITS Date June la, I9S!k FLORIDA POWER 4 LIGHT COMPANY Pa9e 2 Df 1S.2.2 Planning and Scheduling Quality Procedures and Quality Instructions provide requirements for written audit plans and schedules. The audits are planned and scheduled on the basis of the following requirements, as appropriate:

a. Activities shall be audited as early in their life as practicable. Auditing shall be initiated early enough to assure effective quality assurance during the design,'procurement and contracting activities.

b. Applicable elements of the internal and on-site QA Programs shall be audited at least once every two years during the operation phase of plant life following initial fuel loading. For other. plants'hases, the applicable elements shall be audited at least once every year or once within the life of a quality related activity, whichever is shorter.

~,, Cg An annual evaluation of suppliers'uality performance history shall be performed to determine reaudit requirements. Reaudit requirements for suppliers shall be based on the supplier's quality performance and the complexity and criticality of the equipment or service being procured.

A facility evaluation (audit) will be performed at least every three years and shall be conducted in accordance with Quality Procedures and Quality Instructions for supplier evaluations.

d. Audits shall be regularly scheduled for on-going activities.

e. Regularly scheduled audits shall be supplemented, as required to cover unforeseen events or changes in requirements.

The scope of audit activities shall include, as a minimum:

TOPICAL QUALITYASSURANCE REPORT TQR 18.0 Rev.

AUDITS June 10, 198ff Page 3

of 18.2.2 Planning and Scheduling (Cont'd)

a. The determination of site features which affect plant safety (e.g., core sampling, site preparation, and meteorology). ~

b. The preparation, review, approval, and control of the SAR, designs, specifications, procurement documents, instructions, procedures, and drawings.

c. Request for proposals and evaluation of bids.'.

Indoctrination and training programs.

e. Receiving and plant inspections.

f. Operation, maintenance, modification, and repair controls.

g. The implementation of operating and test procedures.

h. All criteria in Appendix 8 to 10 CFR Part 50.

i. Preplanned sample verification of the validity of Certificates of Conf ormance.

External audits shall be performed by the Quality Assurance Department on Architect/Engineers, NSSS vendors, constructors, and other suppliers of safety related materials and services to evaluate their QA programs, procedures and activities. Procurement documents require that FPL suppliers and contractors in turn perform audits on their sub-tier suppliers and contractors.

TOPICAL QUALITYASSURANCE REPORT TQR 18.0 Rev.

AUDITS oate gune l0, l98q FLORIDA POWER a LIGHT COMPANY Page f of 18.2.3 Conduct of Audits Quality Procedures and Quality Instructions shall delineate requirements for the conduct of audits. These procedures and instructions shall require that:

a. Audits be conducted by trained and qualified personnel.

b. Personnel conducting audits shall not have direct responsibility in the ar ea audited.

c. Checklists or procedures shall be used to ensure depth and continuity of audits.

d. Objective evidence shall be examined for compliance with quality assurance program requirements. This shall include examination of-procedures and activities to assure that documented objective evidence is meaningful and in compliance with the overall Quality Assurance Program.

e. Audits shall include evaluation of work areas, activities, processes and items; and the review of documents and records.

18.2.0 Reporting of Audit Findings Audit findings shall be documented in written reports. Audit reports shall be distributed to the responsible management of the audited FPL organization within thirty calendar days after completion of the audit.

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TOPICAL QUALITYASSURANCE REPORT TQR 18.0 Rev.

AUDITS FLORIDA POWER S LIGHT COMPANY gune l0, I98$

Page Gf g

18.2.5 Follow-up Responsible management of the audited organization shall take action to correct the deficiencies identified in the audit report and provide a written response within thirty calendar days after receipt of the report. This response shall include action taken and/or planned to. correct deficiencies and to prevent recurrence of the deficiencies, and commitment dates for actions not yet complete. The mechanism for evaluation and follow-up of corrective action is described in TQR l6.0. The status of correction of deficiencies shall be followed until the corrective actions have been accomplished. When implementation of corrective action cannot be verified by other means,' reaudit of deficient areas shall be performed to accomplish verification.

l8.2.6 Reports to Management Quality Assurance Program status reports are periodically prepared by the QA Department and routed to the members of the QA Committee for their review. This status report summarizes the results of QA Department audit activities for the period, keeps all Committee members apprised of current conditions and program effectiveness, and when necessary, directs management attention to significant trends and problems.

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0 TOPICAL QUALITYASSURANCE REPORT APPENDIX B Rev.

3 QUALIFICATIONAND EXPERIENCE Date June lo l983 FLORIDA POWER 4 LIGHT COMPANY REQUIREMENTS FOR FPL QUALITY ASSURANCE PERSONNEL >>ge l af EDUCATION AND BACKGROUND EXPERIENCE>>

Manager of Quality Shall satisfy the following set of requirements:

Assurance and Supet intendent- Graduate of a four year accredited engineering or science St. Lucie Projects - QA college or university, plus seven years of industrial experience, including five (5) years of managerial experience in industry. At least two (2) years of this five (5) years experience shall be nuclear power plant experience in the implementation of the Quality Assurance Program. Six (6) months of the two (2) years experience shall be obtained within a Quality Assurance organization. A masters degree in engineering or business management is considered equivalent to two (2) years of general industry experience.

Assistant Manager of Shall satisfy one of the following sets of requirements:

Quality Assurance Graduate of a four year accredited engineering or science college or university, plus seven years of industrial experience including three years in positions of leadership, such as lead engineer, project engineer, audit team leader, etc. At least two years of this experience should be

. associated with nuclear facilities. A masters degree in engineering or business management is consider ed equivalent to two years of experience.

Completion of college level work leading to an associates degree in a related discipline plus fifteen years of industrial experience including three years in positions of leadership, such as project engineer, audit team leader, supervisor,

. etc. At least five years of this experience should be associated with nuclear facilities.

High school graduate, plus twenty years of industrial experience, including three years of positions of leadership, such as project engineer, audit team leader, supervisor, etc. At least five years of this experience should be associated with nuclear facilities.

The education and experience requirements should not be treated as absolute when similar training or an outstanding record will provide reasonable assurance that a person can perform the required tasks.

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TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev.

7 BASELINE DOCUMENT MATRIX 3une 10, l980 Pe9e Gf I 23 This topical report contains the program requirements for Florida Power dc Light Company's Quality Assurance Program. The Quality Assurance Program is described in detail in the Florida Power R Light Company Quality Assurance Manual.

The Regulatory Guides, codes, and standards specifically listed in the matrix of this appendix (on page 2) represent the baseline documents used in the preparation of FPL's QA Manual and this topical report. These documents, therefore, provide the basis for the FPL QA Program, but they are not considered to be part of the QA Program unless specifically addressed in the applicable SAR, technical specifications, etc.

The FPL Quality Assurance Program meets the requirements of the documents referenced in this appendix. Any alternatives or clarifications made to the requirements contained in these documents are stated on pages subsequent to the second page of this appendix.

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev.

.7 BASELINE DOCUMENT MATRIX oace one 10 FLORIDA POWER 4 LIGHT COMPANY

>>ge REFERENCE INDUSTRY DRAFT REV.

GOVERNMENT DOCUMENT DATED STANDARD ISSUED DATE 10 CFR PART 50, APPENDIX B 2/19/75 ANSI-N45.2 1971 10 CFR PART 50.55a ASME BdcPV Code Specified in the

,Section III dc SAR document of XI the respective plant Regulatory Guide 1.8 Rev. 1 9/7.5 ANSI-N18.1 1971 ANSI/ANS 3.1 1978 Regulatory Guide 1.28 6/7/72 ANSI-N05.2 1971 Regulatory Guide 1.30 8/11/72 ANSI-N45.2.0 1972 Regulatory Guide 1.33 Rev. 2 2/78 ANSI-N18.7 1976 Regulatory Guide 1.37 3/16/73 ANSI-N05.2.1 1973 Regulatory Guide 1.38 Rev. 2 5/,77 ANSI-N05.2.2 -- 1972 Regulatory Guide 1.39 Rev. 2 '/77 ANSI-N05.2.3 3

1973 Regulatory ( uide 1.58 Rev. 1 9/80 'NSI-N05.2.6 1978 Regulatory Guide 1.60 Rev. 2 6/76 ANSI-NO 5.2.11 1970 Regulatory Guide 1.70 2/7O ANSI-N05.2.10 1973 Regulatory Guide 1.88 Rev. 2 10/76 ANSI-N05.2.9 1970 Regulatory Guide 1.90 Rev. 1 0/76 ANSI-N05.2.5 1970 Regulatory Guide 1.116 6/76 ANSI-N05.2.8 1975 Regulatory Guide 1.123 Rev. 1 7/77 ANSI-N05.2.13 1976 Regulatory Guide 1.100 Rev. 1 9/80 ANSI-N05.2.12 1977 Regulatory Guide 1.106 8/80 ANSI-N45.2.23 1978

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev.

BASELINE DOCUMENT MATRIX June 10, 1980 FLORIDA POWER 4 LIGHT COMPANY Page 3 of 23 Florida Power dc Light Company position regarding conflicting guidance and exceptions:

T AR A endix C Clarification ANSI/ANS 3.1 - 1978 (PSL-2)

The Regulatory Guides and industry standards listed in Appendix C to the Topical Quality Assurance Report take precedence over any Regulatory Guide or industry standard which may be referenced in any one of these documents.

Re ulator Guide 1.8 Rev. 1 ANSI N18.1-1971 ANSI/ANS 3.1 (PSL-2)

ANSI N18.1 describes the training and education requirements for plant staff positions and is endorsed by Reg. Guide 1.8 with an exception. That e'xception is the requirements for the Supervisor - Radiation Protection. ANSI N18.1 is invoked by Technical Specifications (Appendix A of the Facility Operating License) at the Turkey Point plants and PSL-l. ANSI/AiVS 3.1-1978 is invoked by Technical Specification at PSL-2. Reg. Guide 1.8 is also invoked by Technical Specifications at.our St. Lucie plant and a licen'se amendment has been approved for our Turkey Point plant to specify thr Health Physics Supervisor qualifications addressed'in Reg. Guide 1.8.

To avoid duplication of requirements, FPL will address Plant Staff Qualifications in only the Technical Specif ications.

Re ulator Guide 1.30 ANSI N45.2.0-1972 ANSI N05.2.0-1972, Paragraph 2.3 addresses installation specifications and requires the inclusion of inspection and test objectives. FPL maintains that test values and inspection scope are inherently contained in the applicable procedures.

ANSI N05.2.0-1972, Paragraph 6.1.2 requires that the inspection of installed equipment verify that "good and proper workmanship" has prevailed. FPL maintains that acceptable parameter compliance with codes and standards along with company preference is the verification of "good and proper workmanship".

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev.

7 BASELINE DOCUMENT MATRIX June 10, 1980 FLORIOA POWER a LIGHT COMPANY Page f of Re ulator Guide 1.33 Rev. 2 ANSI N18.7- 1976 FPL's method of addressing Paragraphs 0.0, 5.2.2, 5.2.15 and 5.3 of ANSI 18.7 - 1976 as modified by Regulatory Guide 1.33, Rev. 2 is covered in Section 6 of each individual plant's Technical Specif ications.

ANSI N18.7-1976, Section 0.3, requires that personnel performing the independent review and audit be specified in number and technical discipline. This standard is invoked by the Technical Specifications (Appendix A of the Facility Operating Licenses) which have been approved for the FPL nuclear plants at St. Lucie and Turkey Point. Specifically this function is performed by the Company Nuclear Review Board (CNRB) identified in Section 6.5.2 of the Technical Specif ications.

To avoid duplication of requirements, FPL will address the personnel and functions of this independent review and audit only in the Technical Specifications.

~ h FPL's method of addressing Section 5.2 of ANSI N18.7-1976, as modified by Regulatory Guide 1.33, Rev. 2, is b) administratively controlling licensed operator hours on shift and by our Duty Call Supervisor system. Further, FPL has developed a response to NUREG 0650 which provides staf fing availability.

FPL's method of addressing Paragraph 5.2.8 of ANSI N18.7-1976, as modified by Regulatory Guide 1.33, Rev. 2, is covered in Section 0 of each plant's Technical Specifications.

FPL's method of addressing Paragraph 5.2.9 of ANSI N18.7-1976, as modified by Regulatory Guide 1.33, Rev. 2, is covered in 10 CFR 73 and each plant's Security Plan, and as such is not included in the Quality. Assurance Program.

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev.

7 BASELINE DOCUMENT MATRIX Dune 10, 1980 Peoe 5 af Chemical cleaning is not presently controlled as a special process per se; however, the requirements of ANSI N05.2.1-1973 and Regulatory Guide 1.37 dated 3/16/73 are part of the FPL QA Program and are met in our program. FPL proposes these requirements to be an alternative to the requirements of ANSI N18.7-1976, Paragraph 5.2.18. Further, TQR 9.0, Paragtaph 9.2 explains the review of potential special processes and determination of their status as special processes.

FPL meets the intent of Section 5.2.19.3 of ANSI N18.7-1976 as modified by Regulatory Guide 1.33, Rev. 2, as applied to significant changes to operating procedures, by the technical review of the procedure change by knowledgeable plant professionals, by the safety review of the procedure change by the on-site facility review group, by the regulatory and QA review of the procedure by plant Quality Control, by training the licensed operators in the change through the training report system, and by trained, licensed operators using the revised operating procedure and observing the proper result. In addition, procedure changes will be reviewed to assure 10 CFR 50.59 requirements are met.

Paragraph 5.3.5(0) - Clarification - V/hen FPL uses vendor manuals and drawings which provide adequate instructions for maintenance, these documents are attached or referenced with Plant

%'ork Orders which are reviewed and approved by Supervisory and Quality Control personnel and are considered to be adequate procedures in themselves. These vendor manuals and drawings, when received at site, are controlled documents and changes to the applicable sections and instructions of these documents require the same level of review and approval as the operating procedures.

Appendix A of Regulatory Guide 1.33 lists "typical safety related activities which should be covered by written procedures". Regulatory Guide 1.33 is invoked by the Technical Specifications at FPL Nuclear Plants.

In order to avoid duplication of requirements invoked in our licensing documents, the FPL Quality Assurance Program does not list those required operating procedures specified in Appendix A.

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev.

7 BASELINE DOCUMENT MATRIX oate gune 1P, 198$

FLORIDA POWER a LIGHT COMPANY Pa9a Of 6 23 Re ulator Guide 1.37/ANSI N05.2.1-1973 ANSI N05.2.1-1973, Paragraph 5 states in part that, "Fitted and tackwelded joints (which will not be immediately sealed by welding) shall be wrapped with polyethylene or other non-halogenated plastic film until the welds can be completed". The FPL QA Manual shall require that the weld be covered to prevent entry of moisture and contaminants but will not specify the material to be employed. Materials employed to cover openings shall meet the requirements of Regulatory Guide 1.37, Position 4.

ANSI N05.2.1-1973, Paragraph 7.1 states in part, "provisions shall be made to collect leakage and protect insulation from being wetted". FPL Quality Assurance Program includes the above requirements. However, FPL's program allows the wetting of metallic type insulations which are not adversely affected by wetting.

ANSI N05.2.1-1973, Paragraphs 7.2.2, 7.2.3, and 7.3 address specific cleaning methods (Alkaline, Ch'elate; Acid) and make recommendations associated with several types of cleaning methods.

FPL's QA manual does not specifically delineate these paragraphs. However, the procedure developed per Paragraph 2.2 of ANSI N05.2.1 will ensure that any specific cleaning method chosen will be properly considered and controlled.

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TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev.

7 BASELINE DOCUMENT MATRIX June 10, 1980 FLORIOA POWER 4 LIGHT COMPANY P~9e G~

7 23 Re ulator Guide 1.38 Rev. 2/ANSI N05.2.2 - 1972 FPL will meet the requirements of Reg. Guide 1.38, Rev. 2, Position 2C, D and E for safety

- related applications during preoperational and operational activities. Restrictions imposed for tapes to be color constrasting will only be applied to the extent that these colors are dissimilar or otherwise distinguishable. This does not preclude using other tapes when precuations are taken to ensure these tapes do not come in contact with austentic stainless steel or nickel alloy materials.

Vapor barrier material (other than metal) shall be colored to contrast with or be otherwise

.~ distinguishable from safety related systems to prevent undisclosed entry into the system.

These requirements do not apply to components in storage which would require removal of such tapes and barriers to effect installation.

, ANSI N05.2.2-1972 Section 2.7 requires that items governed by this standard'be classified into one of .four levels by the buyer or the contractor. FPL intends to consider what care is appropriate for each item individually rather than generically classifying the material into protection levels and providing care required of that level. The following shall be considered determining the handling, storage, and shipping requii ements: 'hen

l. The vendor's recommended handling, shipping, and storage standards.

2. Environmental requirements which may include such requirements as inert gas atmosphere, humidity limits, temperature limits, chemical requirements, acceleration (g force) requirements.

3. Special tools or equipment which are provided and controlled as necessary to ensure safe and adequate handling. These tools or equipment shall be inspected and tested at specified times to verify that they are adequately maintained.

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev.

7 BASELINE DOCUMENT MATRIX 3une 10, l980 FLORIOA POWER 4 LIGHT COMPANY Page 0E 8

Packaging, covering or coatings required to meet environmental requirements such as barrier and wrap material, desiccants, pipe caps, plugs, contact preservatives, etc.

5. Container, crating, skids of sufficient strength to support the item (including stacking).

6. Cushioning, blocking, bracing, and anchoring to prevent movement during shipment or handling.

7. Special handling or storage procedures for unique situations.,

8. Marking and identification of the item and its packaging.

9. 'nticipated "shelf life" of the item.

FPL considers this to be a more effective approach since the quantity of spare and replacement material, parts and components governed by this standard will be . af forded protection commensurate with the recommendations of Section 2.7 of'this standard.

ANSI N05.2.2-1972 Sections 3.0, 0.0, and the Appendix address all the requirements applicable to the packaging and shipping of material. FPL in general does not package. or ship material governed by this standard. Suppliers of material are required by purchase order "to provide adequate packaging and shipping protection. Isolated cases of material packaging or shipping are treated on a case-by-case basis and receive protection comparable to that required by the manufacturer of that material. Loading, rigging and handling precautions identified in Section 0.3 are applied to material unloaded by FPL from a transport vehicle.

ANSI N05.2.2-1972 Section 5.2 requires that specific attributes of material and components received by FPL be inspected. For plants with operating licenses FPL verifies conformance to procurement documents during receipt inspections. Any of these attributes identified in these procurement documents are verified during this inspection.

TOPICAL QUALITYASSURANCE REPORT APPENDIX C R ev.

7 BASELINE DOCUMENT MATRIX Date gune 10, 198q Pa9e 9 af ANSI N05.2.2-1972 Section 5.2, paragraph 5.2.1, requires certain preliminary inspections to be done "prior to unloading" of material which is received. We believe that the sequence specified in the standard is to facilitate commercial claims, and should these preliminary inspections occur "after unloading" that control of materials quality would not be degraded. Accordingly, required shipping damage inspections may be performed after unloading.

The requirements of ANSI N05.2.2, Paragraph 7.2 for items that require special handling instructions is clarified by FPL to be limited to those items covered in the scope of NUREG 0612, entitled "Control of Heavy Loads at Nuclear Power Plants".

.. ANSI N05.2.2-1972, Paragraph 7.0 requires that an inspection program be established for handling equipment and,rigging, including methods for identifying acceptable and nonconforming items. In lieu of having a program of periodic, documented inspections of rigging and handling equipment, FPL's practice is to have the individual user determine the equipment's acceptability .

.,,, prior to each use. This prior-to-use inspection is exactly the same as that required during

, periodic inspections, and uses criteria identified in ANSI N05.2.2-1972, paragraph 7.0. This practice also precludes the need for-a. system to indicate the acceptability of rigging.and handling equipment. Implementation of this prior-to-use inspection will be assured through periodic surveillances and audits performed by Quality Assurance a'pd Quality Control. Cranes are inspected on a periodic basis and will not be subjected.to this prior-to-use inspection.

Certain mechanical components of the PSL-2 nuclear unit have been designed for a service environment of the site area because portions of the plant are exposed to the temperature, humidity, and ocean salt spray during operations. Extreme air temperature variations, snow or slush are not encountered during operations or in the out-of-doors storage environment. As an alternative to the rigid requirements of storage levels B and C in paragraph 6.1 of ANSI N05.2.2-1972, FPL proposes to store these particular mechanical components outdoors, but

,within controlled areas, with sufficient periodic surveillances and inspections to minimize the possibility of damage or lowering of quality due to corrosion, contamination, deterioration, or physical damage. In cases where special environmental conditions are present (Le. hurricanes, paint sprays, concrete pours, etc.) precautions or additional steps will be taken to further protect the items.

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TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev.

7 BASELINE DOCUMENT.MATRIX 3une 10, 1980 PLORIOA POWER & LIGHT COMPANY Page 1O of 23 Re ulator Guide 1.39 Rev. 2 ANSI N05.2.3-1973 For FPL's operating nuclear plants, alternative methods are followed to achieve equivalent objectives for the below listed sections of ANSI N05.2.3-1973:

The zone designations of Section 2.1 of N05.2.3 and the requirements associated with each zone are not consistent with the FPL Housekeeping requirements at our operating nuclear units. In lieu of the zone designation, cleanliness is maintained at a level consistent with the work being performed, so as to prevent the entry of foreign material into safety related systems.

Documented cleanliness inspections are performed immediately prior to system closure.

Control of personnel, tools, equipment, and supplies is established with approved procedures when the safety function of a system, component, or item may be jeopardized and also while the reactor system is opened for inspection, maintenance, or repair.

Re ulator Guide 1.58 Revision 1 ANSI N05.2.6-1978 ANSI IV05.2.6-1978, Paragraphs 1.J,, 3.1, 3.2.2(a) and 0 (Table-1) identify requirements which apply to personnel who perform inspections, tests or nondestructive examinations or who participate in the approval of procedures, the handling of data or test results, or the control of reports and records.

FPL proposes an alternative to capability requirements for those who participate in: '(1)'the approval of procedures, (2) the handling of data or test results and (3) the control of reports and records. FPL accomplishes this by having personnel determined to be qualified and competent by management through consideration of education, training, and experience.

The Florida Power dc Light Company position on the scope of AiVSI N05.2.6-1978 is that personnel participating in testing who take data or make observations, where special training is not required to perform this function, need not be qualified in accordance with ANSI N05.2.6 but need only be trained to the extent necessary to perform the assigned function.

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev.

7 BASELINE DOCUMENT MATRIX oate June 10, 198$

Page 11 af 23 For leak testing conducted as part of the preoperational and operational testing programs, FPL considers that the qualification requirements of Regulatory Guide 1.8 (ANSI N18.1-1971) and ANSI N05.2.6-1978, Paragraph 3.0 to be an acceptable alternative to SNT-TC-lA-1975 requirements for leak testing, except for leak testing defined in and performed under Section III of the ASME Code, where in such cases, the Code shall govern.

For preoperational and operational inspection, examination and testing by Quality Control Inspectors, FPL considers that Position C.l of Regulatory Guide 1.58, Revision 1 and ANSI N05.2.6-1978, Paragraph 3.0 are acceptable requirements for training and qualification, except for inspections, tests and examinations defined in and performed under Section III of the ASME Code, where in such cases, the Code shall govern.

For all other preoperational and operational inspection, examination and testing performed by operating plant and support personnel, FPL considers that training and qualification to the requirement of ANSI N18.1-1971 and Regulatory Guide 1.8 are sufficient for the type and scope of activities performed and that qualifications to ANSI N05.2.6-1978 is unnecessary and redundant. These preoperational and-operational inspection, examination tests shall be supervised or directed by personnel, qualified to 'Position C.l of Regulatory Guide 1.58, Revision l.

FPL shall comply with Position C.10 of Regulatory Guide 1.58, Revision 1, effective with Revision 0 of the Topical Quality Assurance Report, in that all new certifications issued for personnel shall meet the education and experience requirements or shall document objective evidence demonstrating that the individual indeed does have comparable or equivalent competence to that which would be gained from having the required education and experience.

FPL's position on ANSI N05.2.6-1978, Paragraph 2.3 is-that an initial and periodic review (not to exceed two years) of personnel shall determine the capabilities in his qualified area. If during this review or at any other time, it is determined that the individuaVs capabilities are not in accordance with the specified requirements, that individual shall be removed from that activity until the required capability has been demonstrated. In addition, during this review a determination shall be made that an individual has been actively involved in the inspection process in his qualified area.

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev.

7.

BASELINE DOCUMENT MATRIX oate June 1P, 198$

FLORIDA POWER a LIGHT COMPANY Page 12 of 23 Re ulator Guide 1.60 Rev. 2 ANSI N05.2.11-1970 FPL's exception to Regulatory Guide position C.2 is as follows:

Design verification shall be performed by technically qualified individual(s) or group(s) other than those who performed the design. The original designers and verifiers may both be from the design organization. Design verification by the designer s immediate supervisor shall be limited to those instances where the supervisor is the only qualified individual available within the design organization. These instances are further restricted to designs where the designs where the supervisor did not specify a singular design approach, or did not restrict design methods or alternatives, or did not specify design inputs (unless the specified design inputs have alt'eady been independently verified)., Justification for verification by the designer's immediate supervisor should be documented along with the extent of the supervisor's involvement-in the P

design.'

ANSI N05.2.11-1970, Paiagraph 11.0 requires that "audits shall include an evaluation of design quality assurance policies, practices, procedures and instructions...." FPL's design quality assurance (and all other QA elements) policie., procedures and instructions are included in FPL's Quality Assurance Program documentation. The Quality Assurance Department evaluates all of this documentation in reviews performed during its development and revision. Accordingly, FPL does not require subsequent (and redundant) evaluations of these Quality Assurance Program policies, procedures and instructions during audits. FPL audits will include evaluations of.the adequacy of the practices which are the implementation of these policies, procedures and instructions.

Re ulato Guide 1.68 (11/73)

Regulatory Guide 1.68 (ll/73) entitled "Preoperational and Initial Start-up Test Programs for Water Cooled Power Reactors" is addressed in Section 10.2.1 of the St. Lucie Unit 2 FSAR which states in part, "The start-up test program is developed using the recommendations of Regulatory Guide 1.68". To avoid duplication of requirements, FPJ will address Regulatory Guide 1.68 in the FSAR.

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TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev.

7 BASELINE DOCUMENT MATRIX Dace gune lO, I98tk FLORIOA POWER 4 LIGHT COMPANY 10 23 Inspector (Owner's or Installer's) A qualified inspector employed by the Owner or Installer, whose duties include the verification of quality related activities on installations.

Inspection Examination, observation, or measur ement to determine the conformance of materials, supplies, components, parts, appurtenances, systems, processes, or structures to predetermined requirements.

'I Procurement Documents Contractually binding documents, including such documents as contracts, letters of intent, work orders, purchase orders or proposals and their acceptances which authorize the seller to perform services or supply equipment, material, or facilities on behalf of the purchaser.

Qualif ication (Personnel) The characteristics or abilities gained through training or experience or both as measured against established requirements such as standards or tests that qualify an individual to perform a required function.

Quality Assurance All those planned and systematic actions necessary to provide adequate confidence that a structure, system or component will perform satisfactorily in service.'uality Assurance includes quality I

control.

Quality Control Those quality assurance actions related to the physical characteristics or material, structure, component or system, which provide a means to control the quality of the material, structure, component or system to predetermined requirements.

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev.

BASELINE DOCUMENT MATRIX Dune 10, 1980

'LORIDA POWER 4 LIGHT COMPANY Pe9e Storage That period following the release of an item for shipment until turnover for start-up preoperational testing. This would include in-place storage.

System An integral part of a nuclear power plant comprised of electrical, electronic, or mechanical components (or combinations thereof) that may be operated as a separate entity to perform a specific function.

Testing Performance of those steps necessary to determine that systems or components function in accordance with predetermined specif ications.

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.. "Re uirements" Clarification. for Glossar A mandatory action, denoted by the word shall. (See "Guidelines" )

Requirements are generally based on statutes or regulations, but may be internally generated within the company. "Shall" is therefore used for both external, legally enforceable actions and internal requirements not enforceable under current IVRC practices.

Re ulator Guide 1.88 Rev. 2/ANSI N05.2.9-1970 AIVSI N05.2.9-1970, Section 3.2.5 requires Quality Assurance records be classified as lifetime or non-permanent and further defines lifetime and non-permanent in Section 2.2 of the Standard.

FPL provides the following definitions as an alternative to the above.

Lifetime Records: Records which are required by the IVRC facility operating license, the NRC construction permit, applicable parts of IOCFR, the FSAR, or other IVRC commitments to be retained for the life of the plant.

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev.

7 BASELINE DOCUMENT MATRIX 3une 10, 1980 FLORIDA POWER 1 LIGHT COMPANY Page Of 16 23 Non-permanent Records: Records which are required by the NRC facility operating license, the NRC construction permit, applicable parts of 10CFR, the FSAR, or other NRC commitments to be retained for periods of time less than the life of the plant.

ANSI N05.2.9-I970, requirements for Section 5.6, "Facility", are clarified by FPL as follows:

QA records shall be stored in a manner as to protect contents from possible destruction by causes such as fire, flooding, tornados, insects, rodents, and from possible deterioration by a combination of extreme variations in temperature and humidity conditions.

A QA Record Storage Evaluation Team (QARSET) shall be responsible for determining methods utilized to assure that QA Records are adequately stored and protected.

The QARSET shall consist of the'-following: the Manager'f Quality Assurance, the Loss Prevention Engineer, and the Manager of Corporate Record Services, who shall be responsible for maintaining records of evaluations and establishing schedules to assure that reevaluations are performed every two (2) years. If necessary, the abc.ve QARSET. Committee may delegate appropriate designees to serve as team members.

As part of their responsibility, the QARSET shall evaluate the status of existing facilities and the adequacy of additional records facilities prior to the construction of a new facility or the conversion of existing structures. Preferably, such evaluations should be performed during the design phase.

ANSI N05.2.9-1970 will be utilized in the evaluation of potential record storage facilities.

Section 5.6 "Facilities" is modified as follows and shall be the basis for QARSET approved QA Record Storage Facilities.

l. A 2-hour vault meeting NFPA No. 232 without additional provisions.

2. 2-hour rated fire resistant file room as defined in iVFPA No. 232-1980 if the following additional provision are provided:

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev.

7 BASELINE DOCUMENT MATRIX 3une 10, l980 FLORIOA POWER 5 LIGHT COMPANY Page l7 of 23

a. Early warning fire detection and automatic fire suppression shall be provided, with electronic supervison at a constantly monitored central station.

b. Records shall be stored in fully enclosed metal cabinets. Records shall not be permitted on open steel shelving. No storage or records shall be permitted on the floor of the facility. Adequate access and aisle space shall be maintained at all times throughout the facility.

c. Work not directly associated with records storage or retrieval shall be prohibited within the storage facility..

d. Smoking and eating/drinking shall be prohibited throughout the records storage facility.

e. Ventilation, temperature, and humidity control equipment shall be provided with approved fire dampers where they. penetrate fire barriers.

3. Other conditions from the above may be approved by the QARSET if in their judgement the condition meets the established level of protection defined above.

There are two acceptable alternatives to the establishment of an approved QA record storage facility:

l. The maintenance of duplicate QA Records stored in separate locations which are not subject to the same destructive force at the same time.

2. The use of QARSET approved factory built record protection equipment, such as insulated record containers, fire-resistive safes, and insulated filing devices.

Where a specially constructed storage room is maintained to store the only copy of QA records, at least the following features should be considered in its construction:

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev.

7 BASELINE DOCUMENT MATRIX 3une 1Q, 1980 FLORIDA POWER 4 LIGHT COMPANY Pe9e 18 of 23 (1) Reinforced concrete, concrete block, masonry, or equal construction.

(2) Concrete floor and roof with sufficient slope for drainage; if a floor drain is provided, a check valve (or equal) shall be included.

(3) Structure, doors, frames and hardware should be fire-rated with a recommended two hour minimum rating.

(4) Sealant applied over walls as a moisture or condensation barrier.

(5) Surface sealant on floor providing a hard-wear surface to minimize concrete dusting.

(6) Foundation sealant and provision for drainage.

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('7) Forced-air circulation with filter system.

(8) Adequate fire detection and/or suppression system.

(9) No pipes other than those. providing fire protection to the storage facility are to be located within the facility.

Re ulator Guide 1.116/ANSI N05;2.8-1975 ANSI N05.2.8-1975, Paragraph 2.3 requires that Measuring and Test Equipment (MdcTE) used for inspection be identified on the Inspection Report. FPL may, as an option, employ a MdcTE issue log which provides traceability between MdcTE and the applicable inspections.

AiVSI N45.2.8-1975, Paragraph 0.6 addresses care of items to the extent that temporary use of equipment or facilities to which the standard applies that are to become part of the completed project may be desirable..

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev.

7 BASELINE DOCUMENT MATRIX Date gune 10, 193g FLORIDA POWER d LIGMT COMPANY Pa9e 19 ~f 23 The following clarification applies to the above statement. For FPL plants in the construction phase (to the point of plant operation license) temporary use of equipment and facilities may be used according to need and/or situation. In this case, authorization for usage shall be provided along with all the documents, conditions, safeguards and evaluations to verify permanent plant equipment'adequacy.

In the operations phase all equipment, including temporary equipment, is subject to identical controls to preclude adverse effects on safety and suitability for use.

Re ulator Guide 1.123 Rev. 1/ANSI N05.2.13-1976 ANSI N05.2.13-1976 Section 1.1 states that the extent to which the individual requirements of this standard will apply will depend upon the nature and scope of the work to be performed and the required quality of the items or services purchased. For commercial grade items, FPL has.

determined that certain aspects'f the individual requirements of ANSI N05.2.13 need not apply. Commercial gr'ade items are those (1) not subject to design or specification requirements that are unique to facilities or activities licensed by the NRC, and (2) used in applications other than facilities or activities licensed by the NRC, and (3) to be ordered from the manufacturer/supplier on the basis of specifications set forth in the manufacturer's published product description. These commercial items are subject to varying degrees of control as indicated in the FPL Quality Assurance Manual.

As a minimum, an evaluation is performed by qualified personnel to assure that the commercial item satisfies the necessary technical and quality requirements and the item is checked upon receipt to assure that the item received was the one ordered, damage was not sustained during shipment, and documentation, if required, was received.

ANSI N05.2.13-1976 Section 1.3 provides a definition of "procurement document" which is different from the definition contained in ANSI N05.2.10-1973 and Regulatory Guide 1.70. The Florida Power R Light (FPL) Quality Assurance Program uses the definition of "procurement document" contained in ANSI N45.2.10-1973 as modified by Regulatory Guide 1.70.

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev.

7 BASELINE DOCUMENT MATRIX 3une 10, 1980 FLORIOA POWER 4 LIGHT COMPANY Page 20 af 23 ANSI N05.2.13-1976 Section 3.3.a requires that procurement documents be reviewed prior to release for bid and contract award. The FPL Quality Assurance Program requires procurement document reviews prior to bid and contract award for all safety related purchases with the exception of these accomplished by "Confirming Purchase Order". A "Confirming Purchase Order" is an order which is initially placed verbally with the supplier and then later confirmed with a written Purchase Order. A "Confirming Purchase Order" is only used when time restraints would prohibit the normal review and approval cycle. The following controls are provided in the FPL Quality Assurance Manual to assure that the intent of ANSI N05.2.13 is satisfied for "Confirming Purchase Orders".

Quality Assurance must be contacted prior to contacting the supplier to place the order unless it is an emergency purchase after normal working hours in which case Quality Assurance is contacted the next working day.

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-'(2) Prior to verbally placing the order, it must be verified that the intended supplier is on the FPL Quality Assurance Approved Supplier List.

(3) . The verbally placed order must be promptly followed-up (confirmed) with a written procurement document which is subject to all reviews and approvals required for safety related purchases.

Section 8.2 of ANSI N05.2.13 identifies'those nonconformances which. shall be submitted to the Purchaser. Florida Power 2 Light's (FPL) position regarding the nonconformances to be reported is as follows. Suppliers (including A/E's and Contractors) shall submit all nonconformances which consist of one or more of the following:

I) Technical or material requirements are violated.

2) Requirement in supplier documents which have been approved by the Purchaser is violated.

3) Nonconformances which would affect the quality of the item in regard to function of safety related features. In cases where the supplier cannot make this determination, they shall be submitted to the Purchaser for evaluation.

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev.

7 BASELINE DOCUMENT MATRIX Date June 10, FLORIDA POWER 4 LIGHT COMPANY 198'e9e Of 21 23 This policy assures that all nonconformances affecting safety related functions will be 'reviewed and approved by FPL. In all cases, the supplier's documentation on nonconformances is available for FPL's review.

Re ulator Guide 1.130 ANSI N05.2.0-1972 ANSI N45.2.4-1972, Paragraph 2.5.2 requires that equipment be "suitably marked to indicate date of next required calibration". In lieu of marking equipment, FPL has chosen to control calibration of installed instrumentation and control equipment by maintaining records for each piece of equipment by instrument tag number (or equivalent) to show that established schedules and procedures for calibration have been followed.

Re ulator . Guide 1.100 Rev. 1 ANSI N05.2.12-1977 Regulatory Guide 1.100, Positions C.3 aRb, states in part that applicable elements of an organization's Quality Assurance Program should be audited at least annually or at least once within the life of the activity, whichever is shorter.

ANSI N18.7-4972, Paragraph 0.0 (endorsed by Regulatory Guide 1.33) states in part; "Audits of selected aspects of plant operation shall be performed with a frequency commensurate with their safety significance, and in such a manner as to assure that an audit of safety related activities is completed within a period of two years."

FPL has chosen a two year cycle for auditing elements of the internal and on-site QA Program during the operation phase of plant life following initial fuel loading. FPL's position is that the two year cycle: (1) allows. more in-depth and meaningful audits in each regularly scheduled area, (2) permits more audits of ongoing activities, and (3) in conjunction with the planning and scheduling requirement of TQR 18.0 provides for a comprehensive audit program. The audit frequency requirements of Regulatory Guide 1.100 will be followed during other plants'hases.

TOPICAL QUALITYASSURANCE REPORT APPENDIX C Rev.

7 BASELINE DOCUMENT MATRIX FLORIDA POWER S LIGHT COMPANY June l0, i980 Pe9e 22 ~f 23 In the case of suppliers, an annual evaluation of quality. performance history shall be performed to determine reaudit requirements. Reaudit requirements for suppliers shall be based on the quality performance, and the complexity and criticality of the equipment or service being procured.

=ANSI N05.2.12, Paragraph 0.3.l states: "A brief pre-audit conference shall be conducted at the audit site with cognizant organization management. The purpose of the conference 'shall be to confirm the audit scope, present the audit plan, introduce auditors, meet counterparts, discuss audit sequence and plans for the post-audit conference, and establish channels of communication." FPL will not require the pre-audit conference for audits of limited scope and of'; specific site activities conducted by the Construction and Operations Groups. This conference is omitted because the day-to-day contact of the auditors and plant management, the awareness on the part of plant management that these audits are conducted without pre-audit conferences, and the limited scope of the audits meet the intent of a pre-audit conference.

A'NSI Standard N05.2.12-1977, Paragraph 0.5.l states in part "The audited organizatson shall provide a follow-up report stating the corrective action taken and the da.e corrective action

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was completed". The FPL QA Program requires the QA Department to followup on all action taken by the audited department. This is documented on the corrective action followup form by the QA Department and closed by the QA Department instead of the audited department. This assures that all actions taken by the audited department are verified by the QA Department and that the QA Department concurs with the resolution. We feel that it is appropriate for this to be documented by the QA Department instead of the audited department.

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I TOPICAL QUALITYASSURANCE REPORT APPEIVDIX D Rev. N/A GRAY, GREEN, AND ORANGE BOOK FLORIDA POWER 4 LIGHT COMPANY May 7,1982 MATRIXTO QA PROCEDURES Pege APPEVIDIX D "GRAY, GREEN,,AND ORANGE BOOK-MATRIXTO QA PROCEDURES CANCELLED IN ENTIRETY

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TOPICAL QUALITYASSURANCE REPORT APPENDIX E Rev.

8 LIST OF CORPORATE QUALITY Date 3une 10, 1985 FLORIOA POWER f LIGHT COMPANY ASSURANCE PROCEDURES Page of P NUiVIBER/TITLE SECTION DESCRIPTION 1.1 CANCELLED 2.1 CANCELLED (Terms and Definitions contained in the QA Manual Glossary)

'.2 REVISION OF THE TOPICAL QUALITY Provides instructions for the revision of ASSURANCE REPORT the Florida Power R Light Company Topical Quality Assurance Report (FPL TQAR).

2.3 Describes the instructions and methods QUALITY ASSURANCE PROGRAM used for establishing, preparing, issuing,

-0 RE VIEV/ revising and controlling Quality Procedures employed in supporting quality requirements.

2A PREPARATION AND REVISION OF Provides the responsibilities, guidelines QUALITY INSTRUCTIONS and methods used for developing and revising. Quality Instructions, based upon QP's, that involve quality activities within a department or organization and are unique to that activity.

2.5 QUALITYASSURANCE INDOCTRINATION Describes the requirements for the AND TRAINING indoctrination and training of personnel who perform, or are responsible for activities that affect quality.

2.6 CANCELLED 2?

IDENTIFICATIONOF SAFETY RELATED Describes the development and approval STRUCTURES, SYSTEIVIS AND COMPONENTS of documents identifying safety related structures; systems, and components.

2.8 CLEANLINESS CONTROL METHODS Provides criteria for securing good house-V) keeping. Assigns responsibilities for C

0 assuring that the cleanliness of material, Z

E5 systems and structures is maintained.

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TOPICAL QUALITYASSURANCE REPORT APPENDIX E Rev.

LIST OF CORPORATE QUALITY 3une 10, 1985 FLORIDA POWER S LIGHT COMPANY ASSURANCE PROCEDURES Page of 2

P NUMBER/TITLE SECTION DESCRIPTION 2.9 QUALIFICATIONOF QA AUDIT, QC Describes the personnel qualifications that INSPECTION AND CONSTRUCTION TEST are required to assure that competent QC PERSONNEL inspectors, QA auditors, and construction test personnel perform these respective functions.

2.10 HOUSEKEEPING- Describes the responsibilities and controls OPERATING PLANTS for housekeeping at operating nuclear power plants.

2.11 CANCELLED 2.12 FPL QA PROGRAM APPLICABILITY Identifies the applicability of the FPL FOR FIRE PROTECTION SYSTEMS REQUESTS Quality Assurance Program for Fire Protection Systems.

2.13 LICENSING PROCESSING OF NRC Describes the system for providing responses to NRC initiated action requests.

2.10 IMPLEMENTATIONOF ASME XI Describes the program and responsibilities for controlling activities defined by ASME Section XI.

3.1 CANCELLED 3.2 IDENTIFICATIONAND CONTROL OF Describes measures employed for DESIGN INTERFACES identifying and controlling design interfaces, changes in design interfaces, and modifications that affect documents.

3.0 PLANT CHANGES AND MODIFICATIONS FOR Establishes measures for controlling OPERATING PLANTS design changes or modifications in operating nuclear power plants.

TOPICAL QUALITYASSURANCE REPORT APPEiVDIX E Rev.

8 LIST OF CORPORATE QUALITY Date FLORIDA POWER 4 LIGHT COMPANY ASSURANCE PROCEDURES 3une IO 1985 Page of P NUMBER/TITLE SECTION DESCRIPTION 3.5 DESIGN CONTROL AT THE CONSTRUCTION Defines the responsibilities and methods SITE employed for the initiation, review, evaluation, approval and disposition of field initiated design changes and miscellaneous design documents such as field sketches and isometrics.

3.6 CONTROL OF FPL ORIGINATED Covers the preparation, review, and DESIGN approval of design input documents, design analysis specifications, and design verification for safety related design work originated by FPL.

3.7 EVALUATIONAND COiVTROL OF CONTRACTOR Describes the evaluation and control of DESIGN FOR NUCLEAR FUEL'ontractor designs components and analysis.

for fuel related ft.l CONTROL OF REQUISITIONS AND -Provides a system to assure that the THE ISSUANCE OF PURCHASE ORDERS appropriate technical and quality require-FOR SPARE PARTS, REPLACEMENT ments are placed upon suppliers who ITEMS AND SERVICES provide materials, equipment, and services for operating nuclear plants as requested by operating plant personnel.

0;2 EVALUATIONOF CONTRACTOR'S BIDS- Provides the basic evaluation factors for TECHNICAL technical evaluations of contractor's bids to supply material, equipment, or services to FPL or FPL's Architect/Engineer.

0.3 CANCELLED

'AREVIEW OF PROCUREMENT DOCUMENTS Applies to all FPL issued purchase orders FOR ITEMS AND SERVICES OTHER and contracts relating to a nuclear power THAN SPARE PARTS plant, except those originated by operating plant personnel.

0.5 PROCUREMENT OF SAFETY RELATED AND Provides a system to assure appropriate IMPORTANT TO SAFETY ELECTRICAL technical and quality requirements are EQUIPMENT placed on suppliers of electrical equipment for nuclear plants.

TOPICAL QUALITYASSURANCE REPORT APPENDIX E Rev.

LIST OF CORPORATE QUALITY ASSURANCE PROCEDURES 3une 10, 198 FLORIDA POWER 8 LIGHT COMPANY Page Of

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P NUMBER/TITLE SECTION DESCRIPTION 5.1.

OPERATING PLANT PROCEDURES Describes measures which ensure that instructions and procedures used in operating plants are identified, prepared, reviewed, approved, issued and revised in accordance with regulatory and FPL requirements.

5.2 BACKFIT PROCEDURES Describes . the generation, review and control of backf it procedures.

6.1 CONTROL OF CONSTRUCTION PRO3ECT Defines responsibilities and methods for CONTRACTOR DRAV/INGS, SPECIFICATIONS the control and issue of contractor

'ND PROCEDURES drawings, specifications and procedures to be used during the construction phase of nuclear power plants.

6.2 CONTROL OF DOCUMENTS ISSUED BY Instructions are provided for controlling FLORIDA POWER dc LIGHT COMPANY documents issued by FPL which prescribe activities af fecting the quality of saf ety related items.

6.3 CANCELLED 6A CANCELLED 6.5 CANCELLED 6.6 DRAWING CONTROL FOR OPERATING NUCLEAR Describes the method to be used for POV/ER PLANTS controlling and updating nuclear safety related drawings for operating plants after turnover from. the design organization.

CO IZ 7.1 RECEIPT INSPECTION OF MATERIALS, PARTS AND COMPONENTS FOR OPERATING PLANTS Provides instructions for receipt inspection of materials, parts and components which have been obtained for 0

use in nuclear safety applications at the Z

8 operating plant site.

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TOPICAL QUALITYASSURANCE REPORT APPENDIX E Rev.

LIST OF CORPORATE QUALITY Date

~ FLORIDA POWER a LIGHT COMPANY ASSURANCE PROCEDURES 3une 10, 1985 Page of P NUMBER/TITLE SECTION DESCRIPTION 7.2 CANCELLED 7.3 CANCELLED 7.0 EVALUATIONOF SUPPLIERS OF SAFETY Provides standards, measures, and guide-RELATED ITEMS OR SERVICES lines for the evaluation of QA Programs of contractors or suppliers supplying items or services.

7.5 I

CANCELLED

~ '1 7.6 ACCEPTANCE OF ITEMS R SERVICES =

Describes the responsibilities and requirements for accepting nuclear safety related items or services that are being procured for nuclear power plants.

7.8 REVIEW AND DISPOSITION OF Describes the responsibilities and SUPPLIER DEVIATION NOTICES requirements for the review and disposition of nonconfoimances identified within a supplier's facility which have resulted or will result in an item which does not fully comply with the FPL procurement document quality and technical requirements. This procedure applies to purchased items which have not yet been shipped.

8.1 IDENTIFICATIONdc CONTROL OF Delineates measures for assuring trace-MATERIALS, PARTS AND COMPONENTS ability, identification and control of AT THE PLANT SITE items from the time they are received through usage at operating plants.

8.2 CANCELLED

TOPICAL- QUALITYASSURANCE REPORT Rev.

LIST OF CORPORATE QUALITY ASSURANCE PROCEDURES 3une 10, 1985 FLORIOA POWER 4 LIGHT COMPANY Page of 6 9 P NUMBER/TITLE SECTION DESCRIPTION 9.1 CONTROL OF SPECIAL PROCESSES Delineates the responsibilities of organ-FOR CONSTRUCTION izations and personnel, and the control and documentation of special processes that are applied to safety related items.

9.2 CONTROL OF SPECIAL PROCESSES DURING Describes measures to assure adequate OPERATING PHASE control over special processes applied to safety related items during the operating phase of nuclear power plants.

9.0 CONTROL OF WELDING FOR NUCLEAR POWER Delineates responsibilities and require-PLANTS ments for control FPL welding processes for nuclear power plants.

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10.1 "MOVED TO 7.2 10.2 CANCELLED 10.3 INSPECTION AND SURVEILLANCE OF Delineates responsibilities and MAINTENANCE ACTIVITIES, OPERATIONS requirements for the inspection and AND FUEL HANDLING surveillance of safety related plant maintenance activities, operation of safety related systems, and fuel handling activities.

10.0 CANCELLED 10.5 CANCELLED 10.6 CANCELLED 11.1 TEST CONTROL - CONSTRUCTION Establishes measures to assure that contractor testing of safety related material during the plant construction phase is controlled, accomplished, and documented.

TOPICAL QUALITYASSURANCE REPORT Rev.

LIST OF CORPORATE QUALITY Date ASSURANCE PROCEDURES 3une 10, 1985 FLORIDA POWER 4 LIGHT COMPANY Page of ge . I SECTION DESCRIPTION 11.2 TEST CONTROL - OPERATION A description of the procedures and practices employed by FPL to control testing of plant functions and material that are within the scope of the QA Program during the plant operational phase.

11.3 TEST CONTROL - PREOPERATIONAL Defines the procedures and practices AND START-UP TESTS employed to demonstrate the capabilities of a nuclear plant to satisfy safety related perf ormance specif ications.

11.0 TEST CONTROL PROGRAM Defines the measures for control of proof test prior to installation, construction tests, preoperational tests, startup tests, operational tests and retests following repairs, replacements or modifications for nuclear safety related systems, structures, and components.

12.1 CALIBRATIONAND CONTROL OF Delineates the responsibilities for MEASURING AND TEST EQUIPMENT implementing the described program for maintenance, calibration and control of measuring and test equipment (Mi!ATE).

12.2 CALIBRATIONCONTROL OF INSTALLED Describes the calibration program, PLANT INSTRUMENTATION AND CONTROL delineates responsibilities, and EQUIP MENT establishes procedures for control over the calibration of installed instrumentation and plant control equipment.

13.1 HANDLING,STORAGE AND SHIPPING OF Establishes responsibilities and procedures MATERIALS, PARTS AND COMPONENTS AT to assure that measures are employed by THE SITE DURING CONSTRUCTION contractors to: (1) control the handling, shipping and storage of material; (2) protect the quality of material by using proper handling, shipping, and storage techniques; (3) effectively control the disposition of discrepant items.

TOPICAL QUALITYASSURANCE REPORT APPENDIX E Rev.

LIST OF CORPORATE QUALITY 3une 10, 1985 FLORIOA POWER II LIGHT COMPANY ASSURANCE PROCEDURES Peae ~f 8 9 P NUMBER/TITLE SECTION DESCRIPTION 13.2 CANCELLED 13.3 CONTROL OF RESERVED CENTRALLY STORED Provides the requirements for the issuance ELECTRICAL CABLE and controls of centrally stored electrical cable for use in all operating nuclear power plants.

. 10.1 INSPECTION, TEST, AND OPERATING Specif ies the respective responsibilities "STATUS DURING PLANT OPERATION of FPL personnel and the measures employed for identifying the status (Inspection-Test-Operation) of plant structures, systems and comp onents.

10.2 I~

".INSPECTION TEST AND OPERATING Provides requirements and responsibilities

"'.STATUS DURING PLANT CONSTRUCTION f'r the identification of the inspection, test and operating status of plant equipment up to turnover of the plant to the operating organization.

15.1 CONTROL OF NONCONFORMING MATERIALS, Specif ies the responsibilities of FPL PARTS, OR COMPONENTS - PLANTS UNDER departments and the process for CONSTRUCTION exercising control over materials, structures, or activities that do not conform to specifications so that inadvertent use or installation does not occur.

15.2 CONTROL- OF NONCONFORMING MATERIALS, Defines the objectives and responsibilities PARTS, OR COMPONENTS - OPERATING for controlling nonconforming items or PLANTS services in order to prevent their inadvertent use, installation or application to operating nuclear power plants.

16.1 CORRECTIVE ACTION Establishes the respective responsibilities of FPL personnel and the procedure for assuring that conditions identif ied by the FPL QA Department as being adverse to quality, are corrected.

TOPICAL QUALITYASSURANCE REPORT Rev.

8 LIST OF CORPORATE QUALITY Date ASSURANCE PROCEDURES 3une 10, 1985 FLORIDA POWER a LIGHT COMPANY Page Gf P NUMBER/TITLE SECTION DESCRIPTION 16.2 CANCELLED (Combined with 16.1) 16.3 CANCELLED (Combined with 16.1) 16.0 EVALUATINGAND REPORTING OF Specifies the measures and responsibilities DEFECTS AND NONCOMPLIANCES FOR within Florida Power 2 Light to assure SUBSTANTIAL SAFETY HAZARDS IN compliance to 10 CFR Part 21.

-'CCORDANCE WITH 10 CFR PART 21 16.6 CANCELLED

. 17.1

,- THE COLLECTION AND STORAGE OF Identifies records and documents required QUALITYASSURANCE RECORDS FOR to substantiate quality; and, describes NUCLEAR POWER PLANTS measures employed for their maintenance, retention and retrieval.

18.1 CONDUCT OF QUALITYASSURANCE Provides instructions for conducting DEPARTMENT QUALITYAUDITS audits of FPL Quality Assurance Program activities.

18.2 CANCELLED 18.3 CANCELLED 184 CANCELLED

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TOPICAL QUALMYASSURANCE REPORT APPENDIX F Rev.

TOPICS TO BE ADDRESSED IN Date May 7 l932 FLORIOA PQWFR 4 LIGHT COMPANY SAFETY ANALYSIS REPORTS P898 I Gf I The FPL Topical Quality Assurance Report is the statement of Florida Power R Light Company Quality Assurance Program Requirements which do not vary with plant site.

These stated requirements form a description of the FPL Quality Assurance Program which does not contain identification of the involvement of principal contractors such as the Architect/Engineer, Nuclear Steam Supply System vendor, or Constructor. The contractor involvement in the Program will be described in the plant Safety Analysis Report. In addition, other detailed aspects of the Quality Assurance Program vary from plant-to-plant or with plant site. These aspects will also be described in the plant SAR.

The requirements of the FPL Quality Assurance Program'shall apply to the nuclear safety related structures, 'systems and components as defined in the applicable plant SAR.

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