ML20003H944

to Operational QA Program Description

ML20003H944
Person / Time
Site:	Columbia, Washington Public Power Supply System, Satsop
Issue date:	05/01/1981
From:	Glasscock R WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:
Shared Package
ML20003H943	List: ML20003H942 ML20003H944
References
WPPSS-QA-004, WPPSS-QA-004-R05, WPPSS-QA-4, WPPSS-QA-4-R5, NUDOCS 8105080218
Download: ML20003H944 (100)

Text

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Effective May 1, 98 OPERATIONAL  !

, QUALITY ASSURANCE l l PROGRAM DESCRIPTION i

(WPPSS-QA-004) i '

APPROVED: 8Y~N Director, Quality Assurance Date

)

ORIGINAL ISSUE: May 10,1978 Washington Public Power Supply System Richland, Washington 99352

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D WASENGTON FUBUC POWER SUFFI.Y SYSTnt "*

OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION MANAGEMENT STATEMENT It is the policy of Washington Public Power Supply System (hereinafter called O the " Supply System") to design, construct and operate its nuclear power plants without jeopardy to the health and safety of the public. In support of this policy, the Supply System has established a Corporate Quality Assurance Program that is described in the following three documents:

1. Quality Assurance Program for Design and

O Cons truction.

2. ASME Quality Assurance Manual (Design and Construction).

3. Operational Quality Assurance Program

O Description (Operations Phase).

The three documents contain the official Supply System Quality Assurance policies.

Adherence by all affected Supply System organizations is mandatory.

The Operational Quality Assurance Program Description meets the applicable

O requirements of 10 CFR 50, Appendix B and shall be implemented by written and approved procedures and/or instructions.

The Quality Assurance Directorate is mandated the responsibility and authority for establishing, administering and assuring implementation of the Supply System Corporate Quality Assurance Program. The Quality Assurance Director has the

. ,-) responsibility and authority, including stop work authority, to perform actions necessary to accomplish this mandate as delineated in the Corporate Quality Assurance Program manuals.

The Quality Assurance Director has my delegated approval authority for the Operational Quality Assurance Program Description and any necessary modifications.

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1. 1. Ls R. L. Ferg n, Managing Director O

Date:y [& /T/ ffR7' O

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O WAsmNGTON PUBUC POWEP. SUPPLY SYSTC4 ""*

OPERATIONAL 5 PAGE QUALITY ASSURANCE PROGRMI DESCRIPTION LIST OF EFFECTIVE PAGES PAGES REVISION ,

,0 1-V 5 1 1-19 5

! 2 2-3 5 3 3-3 5 O 4 4-2 ' 5 5-1 5 6 6-3 5 7 7-3 5 O 8 8-2 5 -

9 9-2 5 -

10 10-2 5

11 11-2 5 0 12 12-2 5 l 13-1 5 14-1 5 15 15-2 5 O 16-1 5 17 17-2 5 18-1 5 I-l - I ^ 5 O II-l 5 II.1 II.1-29 5 II.2-1 5 II.3-1 5 lO 1

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O WAS:-IINGTON PUBLIC PO'7ER SUPPLY SYSTEI.; ""*

OPEll ATION A l.

QUAL.lTY ASSUltANCE PitOGilAM DESGitlPTION iv O

TABLE OF CONTENTS SECTION TITLE PAGE O

Cover Page i Matagement Statement ii List of Effective Pages iii

() Table of Contents iv 1 ORGANIZATION 1-1 2 QUALITY ASSURANCE PROGRAM 2-1 3 DESIGN CONTROL 3-1 O 4 PROCUREMENT DOCUMENT CONTROL 4-1 5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS 5-1 6 DOCUMENT CONTROL 6-1 7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND 7-1 SERVICES O

8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, 8-1 AND COMPONENTS

! 9 CONTROL OF SPECIAL PROCESSES 9-1 10 INSPECTION 10-1

O 11 TEST CONTROL 11-1

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12 CONTROL OF MEASURING AND TEST EQUIPMENT 12-1 13 HANDLING, STORAGE, AND SHIPPING 13-1 14 INSPECTION, TEST, AND OPERATING STATUS 14-1 0 15 NONCONFORMING MATERIALS, PALTS, OR COMPONENTS 15-1 16 CORRECTIVE ACTION 16-1 17 QUALITY ASSURANCE RF. CORDS 17-1 18 AUDITS 18-1 O APPENDIX I QUALIFICATION REQUIREMENTS I-1 APPENDIX II POSITION STATEMENTS Introduction II-1 II.1 Position Statements for WNP-2 II.1-1 O 11.1.1 Regulatory Guide 1.8 II.1-1 O m a 'u

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QUAI,lTY ASSUllANCE PitOGitAM DESCittlTION e v g TABLE OF CONTENTS SECTION TITLE PAGE D

11.1.2 Regulatory Guide 1.26 II.1-2 11.1.3 . Regulatory Guide 1.29 . II.1-3 11.1.4 Regulatory Guide 1.30 II.1-4

, II.1.5 Regulatory Guide 1.33 II.1-6 II.1.6 Regulatory Guide 1.37 II.1-8 11.1.7 Regulatory Guide 1.38 II.1-11 I'. 1.8 Regulatory Guide 1.39 II.1-13 II.1.9 Regulatory Guidt 1.58 II.1-14 II.l.10 Regulatory Guide 1.64 II.1-18 1I.1.11 Regulatory Guide 1,74 II.1-19 1I.1.12 Regulatory Guide 1.88 II.1-20 11.1.13 Regulatory Guide 1.94 II.1-23 I1.1.14 Regulatory Guide 1.116 II.1-24 II.1.15 Regulatory Guide 1.123 II.1-26 II.1.16 Regulatory Guide 1.144 II.1-28 II.l.17 Regulatory Guide 1.146 II.1-29 O II.2 Position Statements for WNP-1/4 II.2-1 II.3 Position Statements for WNP-3/5 II.3-1 l

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WASHINGTON PUBLIC POWER SUPPLY SYSTEL" OPEltATIONAI.

PAGE QUAI.lTY ASSultANCE PitOGilAM DESCilliq' TON 1-1 O

I - ORGANIZATION 1.1 PURPOSE O

Inis section provides a description of tne organizational structure, responsibilities, and linei of communication for the development, implementation, and verification of Supply System's Operational QA O Program, nereafter referred to as QA Program, for its nuclear power plants.

1.2 GENERAL O .

Tne Supply System organization responsiole for estaolisning, execu-ting, and measuring the overall effectiveness of the administrative controls and the QA Program for its nuclear power plants is as de-O picted in Figures 1-1 thecugn 1-5. Portions of these activities may oe delegated to external organizations qualified to the requirements

.of the QA Program, however, the responsibility shall remain with the Supply System.

O 1.3 MANAGEMENT RESPONSIBILITIES 1.3.1 Tne Managing Director / Deputy Managing Director is responsible for O tne establisnment of policies .id for overall management of Supply System operations. The Maneging Director has issued a " Management Statement" wnicn comits Supply System to design, construct, and operate its nuclear power plants witnout jeopardy to tne nealtn and

O safety cf tne puolic. The Managing Director is tne ultimate Supply System autnority on matters involving quality. Tne Managing Di-rector /0eputy Managing Director operates through the Director, Qua-lity Assurance, the Director, Nuclear Safety, tne Director, Power g Generation, and the Program Directors (Projects) to provide for all Quality Assurance / Quality Control functions during initial testing (pre-operational and startup testing) and subsequent operations

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OPEll ATION A1. 6 PAGE QUAL.lTY ASSUltANCE PitOGilA.\1 DESCitil'I'!ON 1-2 3

1.3.1 (Cont'd) pnase activites for all Supply System's nuclear facilities. The s

, Managing Director / Deputy Managing Director arranges througn the Di-rectors of Tecnnical, Contracts and Materials Management, and Admin-istration for support services to all Supply System nuclear facili-ties in sucn areas as engineering, fuel management, purcnasing, nea-O ltn pnysics, and records management.

1.3.2 The Director, Quality Assurance, reports to tne Managing Director /

Deputy Managing Director, and is responsible for establishing, ad-O ministering, and assuring implementation of tne Supuly System Cor-porate Quality Assurance Program during tne design, construction, and operation pnases. To accomplisn tnis role, tne Director, Qua-lit. Assurance, operates througn the Manager, Operational QA & Ser-O vices, the Manager, Venoors/ Audits, and tne Maqager, QA Engineering l

and Systems. Tne qualification requirements for tne position of Director, Quality Assurance, are as descrioed in Appendix 1, "Quali-

f. cation Requirements.

O 1.3.2.1 Ine Manager, Operational OA & Services, reports to the Director, Quality Assurance, and is responsible for monitoring and performing surveillances of activities performed under tne responsioility of O Home-Office-located Supply System organizations. Subsequent to the issuance of Operating License, tne Manager, Operational QA & Ser-vices, is also responsible for monitoring and performing surveil-lances of activities performed under tne responsioility of Plant 9 Managers and Startup Managers. Some of the specific responsiolli-ties of the Manager, Operational QA & Services, include:

a. Development and maintenance of the QA Program.

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o. Establisnment and conduct of an indetendent QA surveillance program over in-plant and Home Office activities performed by g Wel15 R3

D WAS'IINGTON PUBLIC POWEP. SUPPLY SYSTEl.; " " V-OPMit ATION Al. 5 PAGE QUAL.lTY ASSUltANCE PitOGitAM DESCitlPTION 1-3 9 8 1.3.2.1 (Cont'd)

Supply System organizations (otner tnan Engineering Division)

O and vendors.

c. Providing Operational Quality Assurance input to tne training and indoctrination program for personnel performing activities O that affect safety-relate, functions of plant items.

d. Interfacing between tne plants and other Supply System organi-zations to establisn coordinated Quality Assurance support.

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e. Reporting plant-related quality problems to appropriate manage-ment levels to expeoite corrective action.

O f. Providing assistance to other Supply System organizations in QA matters.

g. Periodic review of reports of surveillances, audits, and plant 9 related non-conformances to identify any quality trends wnicn may constitute a need for corrective action in order to pre-clude repetition of non-conformances, and for notifying tne responsioie Supply System organizations tne significant results 9 of sucn reviews for accomplishment of corrective action.

n. Reviewing procurement documents, procedures, and instructions for assuring inclusion of appropriate quality requirements.

rO l 1.3.2.1.1 Tne Operations QA Supervisor for eacn nuclear power plant is located on-site and reports to the Manager, Operational QA & Services, suo-sequent to tne issuance of Operating License. Prior to Operating g License, the Operations QA Supervisor reports to the Project QA Man-l ager, wno also is located on-site. Tne Operations QA Supervisor assures implementation of QA Surveillance program over activities Wklls R3 i 1

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OPIsit ATION Al.

PAGE QUAL.lTY ASSUltANGE PitOGilAM DESCitli' TION 14 1.3.2.1.1 (Cont'd) performed under the responsibility of tne Plant Manager and tne O Startup Manager and is responsible for reviewing plant-originated procurement documents, modification packages, inspection plans, re-ports of nonconformances, procedures, and instructions. Tne Opera-tions QA Supervisor nas direct connunication access to tne Plant O Manager, the Start-Up Manager, and other plant supervisory staff and nas tne autnority to issue a stop wor 4 order, wnen tne activity be-ing perfonned appears not to comply witn tne applicable provisions of the QA Program and implementing proceaures. Wnen tne unit is O operating, tne Operations QA Supervisor may racommend to the Plant Manager that tne unit ce snutdown. Tne Plant Manager, however, nas tne final responsibility for tne overall evaluation of all aspects and implications of snutting down the operating unit.

O 1.3.2.2 Tne Manager, Vendors / Audits, reports to the Director, Quality Assur-ance, and is responsiole for tne implementation of an independent audit program over activities performed by Supply Systen organiza-O tions and its vendors. The Manager, Venoors/ Audits, is specifically responsiole for:

a. Planning, coordinating, and performing surveillances over off-O plant activities performed by vendors.

o. Developing and maintaining an evaluated vendors list.

'O c. Performing pre-award surveys / evaluations of' vendors.

d. Qualification /certificatioa of audit personnel.

^ e. Planning, scheduling, and performing audits of activities per-h formed oy Supply System ogganizations and its vendors; identi-l fying QA Program non-conformances and, if appropriate, recom-O -.u j

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1.J.2.2 (Cont'd) mending solutions; evaluating corrective actions; and, verifying

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correction of identified nonConformances.

1.3.2.3 Tne Manager. QA Engineering & Systems, reports to tne Director, Qua-lity Assurance, and is responsible for providing centralized support O

to the Supply System nuclear facilities and otner Supply System or-ganizations in QA-related areas. The Manager, QA Engineering and l

Systems, is specifically responsiole for:

O a. Developing, interpreting, and communicating QA requirements for the design and construction pnase activities at Supply System nuclear facilities.

O D. Development and maintenance of tne Quality Assurance Program for Design and Construction and tne ASME Quality Assurance Manual.

.O c. Reviewing procedures / instructions related to tne Engineering Division activities.

d. Interfacing with and performing surveillances of Engineering

'O Division activities.

e. Qualification / Certification of, Supply System personnel wno are required to be qualified / certified in accordance with SNT-TC-1A O and its Supplements.

f. Interfacing witn tne AutnorizeJ Nuclear Inspector (ANI), Autn-orized Inspection Agency, and tne Enforcement Autnority and O <eeping tne ANI informed of progress of the wor < at Supply Sys-tem projects.

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OPEllATIONAl. 5 PAGE QUAI.lTY ASSUltANCE PitOGilAM DESCitIPTION 1-6 O

1.3.3 The Director, Nuclear Safety, reports to the Managing Director / Deputy Managing Director and is responsible for development of corporate nuclear safety policy and standards and for independent nuclear safe-

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ty evaluation of each of the Supply System nuclear projects. The Director, Nuclear Safety, is responsible for establishing a means for all formal contacts with the Nuclear Reguletory Comission on nuclear safety issues pertaining to licensing of each of the nuclear O

projects and is also responsible for providing safety and licensing expertise in support of the nuclear projects. The Director, Nuclear Safety, is Chairman of the Corporate Nuclear Safety Resiaw Board l which functions to provide an independent nuclear safety review of O activities in acc vdance with the Tecnnical Specifications for the applicable nuclear power plant.

1.3.3.1 The Manager, Licensing, reports to the Director, Nuclear Safety, and O is responsible for providing coordinated corporate-level management of licensing activities and for assuring techniral adequacy of licensing submittals. A Licensing Project Manager is assigned for each project and serves as the point of interface with the NRC for O the projects.

1.3.3.2 The Manager, Operational Nuclear Safety, reports to the Director, Nuclear Safety and is responsible for conducting independent evalu-O ations of the adequacy of plant safety programs. An on-site Safety Engineering Group (SEG) for each project reports to the Manager, Operational Nuclear Safety, and is responsible for:

O a. Evaluation of plant operations from a safety' perspective.

b. Evaluation of the effectiveness of the quality assurance program.

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c. Evaluation for technical adequacy and clarity of all procedures important to the safe operation of the facility.

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OPI'.I( ATlUN A 1. 5 PAGE QUAI,lTY ASSUltANCE PitOG! TAM DESCitlPTION

)q 1.3.3.2 (Cont'd)

d. Assessment of the plant performance regarding conformance to O

requirements related to safety.

e. Comparison of the operating experience of the plant and plants of similar design.

f. Assessment of plant nuclear safety programs.

g. Any other matter involving the safety of the nuclear power 3 plant that an independent review deems appropriate for consideration.

1.3.3.3 The Manager, Design & Nuclear Safety Assessment, reports to the 3 Director, Nuclear Safety and provides for assurance that corporate safety decisions are made on a sound technical basis, consistent with current safety technology. Toward this end, the organization provides for review and assessment of the adequacy of plant design, 3 construction, and operation relative to nuclear safety. This orga-nization also provides in-depth technical coordination and support for other Nuclear Safety divisions.

D 1.3.4 The Director, Power Generation, reports to the Managing Director /

Deputy Managing Director, and is responsible for:

a. Safe and efficient operation of Supply System's nuclear power plants subsequent to commercial operation.

b. Establishment and monitoring of maintanance systems common to all nuclear power plants.

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c. Training of Power Genera' ion ;taff. .

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WAS:lINGTON PUBLIC POWEP, SUPPLY SYSTE .: ""V" Ol' Ell ATION Al. 5 l

PAGE QUAL.lTY ASSUltANCE l'llOGilAM DIGCittlTION 1-8 1.3.4 (Cont'd) '

d. Development of corporate programs and procedures for power gen-

)

eration and providing the same to the Program Directors on each project to ensure uniform application.

To accomplish this role, the Director, Power Generation, operates l

through the Plant Managers, the Power Generation Services Manager and the Generation Management Serviccs Ma' nager.

l l 1.3.4.1 The Plant Manager for each of the Supply System nuclear power plants j reports to the respective project Program Director during the period l prior-to-commercial operations. Thereafter, the Plant Manager re-ports to the Director, Power Generation. Prior-to-commercial opera-tion, the Plant Manager has direct communication access to the Di- 1

) rector, Power Generation, in order to facilitate coordinated devel- l opment and uniform application of administrative controls and opera-tional pnilosophies.

) The Plant Manager is directly responsible for safe and efficient operation of the plant in accordance with the Operating License, l

requirements of the Plant Technical Specifications, and the Plant

) Procedures Manual. Some of the specific responsibilities of the Plant Manager are:

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a. Planning, coordinating, and directing all test, operation,

) maintenance, and refueling activities subsequent to the is-suance of Operating License.

b. Authorizing all plant modifications after the issuance of Ope-

) rating License.

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O WAS IINGTON PUBLIC POWEP. SUPPLY SYSTEI.; "'*"

Ol' Ell ATION A1. 5 PAGE QU Al.lTY ASSUltANCE PitOGitAM DESCitIPTION pg 1.3.4.1 (Cont'd)

c. Approval and control of procurement documents for safety rela-D ted items and services.

d. Controlling purchased equipment and materials intended for plant use.

e. Establishment and implementation of a calibration program for Measuring & Test Equipment (including installed instruments covered by the Plant Technical Specifications).

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f. Dispositioning of nonconforming items.

g. Control and maintenance of on-site quality assurance records.

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The Plant Manager operates through the Operations Superintendent, the Maintenance Superintendent, the Technical Superintendent, the Training Supervisor, and the Administrative Supervisor. Reporting O to the Technical Superintendent is a Quality Control (QC) Super-visor. The QC Supervisor, assisted by the QC Inspectors, is respon-sible for the performance of all required QC inspections as identi-fied in the plant procedures. The plant organization (see Figure O l-2) and the functional responsibilities of key plant personnel are as described in Chapter 13 of the Final Safety Analysis Report for the applicable nuclear power plant.

O 1.3.4.2 The Manager, Power Generation Services, reports to the Director, Power Generation, and is reponsible for providing support services to the Plant Managers in the areas of maintenance and training. The '

Manager, Power Generation Services, is also responsible for develo-O ping a common policy for test and startup and providing the same to Program Directors (Projects) for application to Supply System nu-clear projects.

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OPEl( ATION AI. 5 PAGE QUAL.lTY ASSUltANCE PROGitA.\l Di'SCitllTION 1.3.4.3 The Manager, Generation Management Services, reports to the Direc-tor, Power Generation, and is resp.nsible for providing support ser-4 vices to the Plant Managers in such areas as acquisition, storage, and reporting of operational and maintenance data; planning and sch-eduling plant outages for refueling and maintenance activites; and preparation / coordination for review and approval / transmittal to the Nuclear F.egulatory Comission of reports as required by the applic-O able plant Technical Specifications.

1.3.5 The Technical Director reports to the Managing Director / Deputy Man-aging Director and is responsible for providing nuclear power plants O

the technical support in such areas as engineering, nuclear fuel management, environmental programs, etc. To accomplish this role, the Technical Director operates through the Manager, T2chnical Di-vision, and the Manager, Engineering Division.

1.3.5.1 The Manager, Technical Division reports to the Technical Director.

The authorities and responsibilities of the Manager, Technical Di-vision, are described in Chapter 13 of the Final Safety Analysis O'

Report for the applicable nuclear power plant.

1.3.5.2 The Manager, Engineering Division reports to the Technical Director and is responsible for providing support services to the Plant Man-O agers in the following areas:

a. Preparation, review, and approval of design documents pertain-ing to new designs and changes to approved designs that are O necessitated as a result of authorized plant modifications.

b. Control, maintenance, and distribution of a listing (including documents referenced therein) of safety-related structures,

'O systems, and components for eacn nuclear power plant.

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9 WAS'ilNGTON PUBLIC P0t7Ei'. SUPPLY SYSTEL: ""*

OPEltNI'lON Al. 5 PAGE QU Al.lTY ASSUltANCE PitOGilAM DEScitlPTION i.3.5.2 (Cont'd)

c. Traditional and specific engineering functions as described in Chapter 13 of the Final Safety Analysis Report for the applic-able nuclear power plant.

1.3.6 The Program Director for each of the Supply System nuclear projects O reports to the Managing Director / Deputy Managing Director and is responsible for all plant activities prior-to-commercial operation.

To accomplish this role, the Program Director for Supply System Pro-ject WN?-1/4 operates through the Project QA & Safety Manager and b the Plant Manager (see Figure 1-3); the WNP-2 Program Director ope-rates through the Project QA Manager, the Project Manager, and the Plant Manager (see Figure 1-4); and the WNP-3/5 Program Director operates through the Oroject QA Manager and the Plant Manager (see O Figure 1-5).

1.3.6.1 The WNP-l/4 Project QA & Safety Manager reports to the WNP-l/4 Pro-gram Director and has direct communication access to the Director of C Quality Assurance in order to seek resolution of quality problems which cannot be resolved at the project Isvel or which require cor-porate level corrective action. The WNP-1/4 Project QA & Safety Manager is responsible for:

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a. Verification of the implementation of the Corporate Quality Assurance Program at the project level, and g b. Development and implementation of the project safety program.

To accomplish this role the WNP-;/4 Project QA & Safety Manager ope-rates through the Project QA Manager and the Project Health & Safety e Manager.

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OPMitATION A1.

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PAGE QU Al.lTY ASSultANCE PitOGilAM DESCitIPTION

} ___ l-12 1.3.6.2 The Project QA Manager for WNP-1/4 reports to the WNP-1/4 Project QA

& Safety Manager, and the Project QA Managers for WNP-2 and WNP-3/5 report to the respective Program Directors. The Project QA Managers for WNP-2 and WNP-3/5 have direct communication access to the Direc-

! tor of Quality Assurance in order to seek resolution of quality pro-blems which cannot be resolved at the project level or which require corporate level corrective action. Each Project QA Manager is prin-D cipally responsible for assuring implementation of the Corporate Quality Assurance Program, at the project level, during the design, construction, and prior-to-Operating License pre-operational testing activities. Each Project QA Manager is responsible for the perfor-

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mance of only QA-related functions and is free from any responsibil-ities that involve project cosi, and scheduling considerations. Spe-cific responsibilities of each Project QA Manager include:

a. Performing audits of construction activities at the project.

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b. Performing surveillances over site contractor's activities.

3 c. Review of non-conformance reports and initiating management corrective action reports, where necessary.

d. Exercising Stop Work authority for quality reasons.

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e. Providing QA coverage, through the *0perations QA supervisor, over activities that are performed under the responsibilities of the Plant Manager and the Startup Manager.

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l l *The specific responsibilities of the Operations QA Supervisor, who reports to the Manager, Operational QA & Services, subsequent to the issuance of Operating License, are t Jescribed in Sect. ion 1.3.2.1.1.

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OPKilATIONA1, 5 PAGE QUAL.lTY ASSUllANCE PitOGitAM DESCitil'I'lON 1.3.6.3 The Health & Safety Manager for WNP-1/4 reports to the WNP-l/4 Pro-ject QA & Safety Manager and is responsible for the development and g implementation of a safety program for WNP-1/4 1.3.6.4 The Project Managers for WNP-2 and WNP-3/5 report to the respective Program Cirectors and are responsible for accomplishing the prior-t - perating License pre- perati n11 testing activities. The WNP-2 O

Project Manager accomplishes this role by providing administrative

, and functional direction to the WNP-2 Startup Manager. The WNP-3/5 Project Manager accomplishes this role through the WNP-3/5 Deputy Project Manager.

1.3.6.5 lhe Deputy Project Manager for WNP-3/5 reports to the WNP-3/5 Pro-ject Manager and is responsible for accomplishing prior-to Operating License ore-operational testing activities by providing functional O

direction to the WNP-3/5 Startup Manager.

1.3.6.6 The Startuo Manager for each of the Supply System nuclear projects is responsible for the performance of initial testing activities at O that project. During the prior-to-Operating License period, the WNP-1/4 Startup Manager receives functional and administrative di-rection from the WNP-l/4 Plant Manager (Assistant Program Director for Operations), the WNP-2 Startup Manager receives functional and O administrative direction from the WNP-2 Project Manager, and the WNP-3/5 Start-Up Manager receives functional direction from the WNP-3/5 Deputy Project Manager and administrative direction from the WNP-3/5 Plant Manager. Subsequent to the issuance of Operating Li-O cense, the Start-Up Manager for each project functionally and admin-istratively reports to the applicable Plant Manager. The duties and responsibilities of the Startup Manager are as described in Chapter 14 of the Final Safety Analysis Report for the applicable nuclear O , ,

power plant.

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OPKit ATION Al.

PAGE QUAL.lTY ASSUltANCE PitOGitAM DESCRilTION j,j4 0

1.3.7 The Director, Contracts & Materials Management reports to the Man-aging Director / Deputy Managing Director and is responsible for pro-viding support services to:

a. Supply System nuclear facilities for procurement and control of materials, equipment, and services.

O b. Technical Division for procurement of nuclear fuel.

l.3.8 Tne Director, Administration reports to the Managing Director / Deputy Managing Director and is responsible for providing support services O

to the Plant Managers and heads of other Supply System organizations in tne following areas:

a. Control and maintenance of corporate records.

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b. Distribution of corporate level policies and procedures.

c. Development of policy and programs for health physics, emer-O gency preparedness and response, industrial safety / fire protec-tion, security, and associated training programs.

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WASHINGTON FUBLIC FOWER SUFFLY SYSTEM "*

l OPERATIONAL 5 PAGE QUALITY ASSURANCE PROGRAM DESCR& TION

. 1-15

O SUPPLY SYSTEM ORGANIZATION r MANAGING DIRECTQR LEGEND DEPUTY MANAGING DIRECTOR T

@$ggATIVE & FUNCTIONAL 0

NUCLEAR SAFETY WNP.1/4 WNP 2 DIRECTOR WNP 3/5 PROGRAM DIRECTOR PROGRAM DIRECTOR PROGRAM DIRECTOR

.O QUALjTY ASSURANCE MATE ALS MGMT TECHNICAL ADMINISTRATION DIRECTOR DIRECTOR DIRECTOR DIRECTOR

!O VENDORS / AUDITS TECHNICAL MANAGER MN ER l

.O QA ENGINEERING ENGINEERING I

& SYSTEMS OlVISION MANAGER MANAGER OPERATIONAL QA Q & SERVICES MANAGER s

POWER l

GENERATION

,O DIRECTOR WNP-1/ 4

• WNP 2 WNP-3e 5 POWER GENERATION GENERATION O PLANT MANAGER PLANT MANAGER PLANT MANAGER SERVICES MGT. SERVICES y MANAOER MANAGER

• PRIOR TO COMMERCIAL OPERATION. THESE POSITIONS REPORT TO THE RESPECTIVE PROGRAM DIRECTORS.

FIGURE 1-1 s B

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WASHING 11)N PUBLIC FOWER SUFFLY SYSTEM ""*

OPERATIONAL 5 enes QUALITY ASSURANCE PROGRAM DESCRIPTION 1-16

) -.

TYPICAL PLANT ORGANIZATION (AT COMMERCIAL OPERATION)

)

MANAGING DIRECTOR DEPUTY MANAGING DIRECTOR

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l POWER GENERATION QUALITY ASSURANCE DIRECTOR DIRECTOR

)

OPERATIONAL QA & SERVICES MANAGER HOME OFFICE SITE PLANT OPERATIONS QA MANAGER SUPERVISOR

)

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _I

) OPERATIONS MAINTENANCE TECHNICAL ADMINISTRATIVE TRAINING SUPERINTENDENT SUPERINTENDENT SUPERINTENDENT SUPERVISOR SUPERVISOR QUALITY CCNTROL

) SUPERVISOR LEGEND ADMINSTRATIVE & FUNCTIONAL REPORTING

---

LINES OF COMMUNICATION

) ,

FIGURE 1 d s

3 wests as

O WASIGNGTON PUBLIC POWER SUFFLY SYSTE1: ""V*

OPERATIONAL 5 PAGE QUALITY ASSURANCE PROGRAM DESCRIPr!ON 1-17 e

WNP-1/4 ORGANIZATION (PRIOR TO OPERATING LICENSE)

D MANAGING DIRECTOR DEPUTY

( MANAGING DIRECTOR P

QUALITY ASSURANCE PROGRAM DIRECTOR DIRECTOR I

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PROJECT QA &

SAFETY MANAGER m

2 HEALTH & SAFETY PROJECT PLANT MANAGER MANAGER QUALITY ASSURANCE (ASST. PROG. DIR -

MANAGER OPERATIONS) 0 1

OPERATIONS QA STARTUP SUPERVISOR MANAGER O LEGEND ADMINISTRATeVE & FUNCTIONAL REPORTING

--- UNES OF CJMMUNICATION

1. THIS POSITION REPL1TS TO MANAGER. OPERATIONAL QA & SERVICES AT OPERATING LICENSE.

2. THIS POSITION REPORT 3 TO DIRECTOR. POWER GENERATION. AT COMMERCIAL OPERATION.

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O WASHINGTON PUBLIC FOWER SUFFLY SYSTEM OPERATIONAL 5 PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 1-18 O

WNP-2 ORGANIZATION (PRIOR TO OPERATING LICENSE)

O MANAGING DIRECTOR DEPUTY MANAGING DIRECTOR O

OUALITY ASSURANCE PROGRAM DIRECTOR DIRECTOR O

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QUAL S ANCE M GR M GE?

1 2 O PERATIONS OUA 1 AS URANCE - R P AGEp O

LEGEND ADMINISTRATIVE & FUNCTIONAL REPORTING

---

LINES OF COMMUNICATION O

1. THIS POSITION REPORTS TO MANAGER OPERATIONAL QA & SERVICES, AT OPERATING LICENSE.

2. THIS POSITION REPORTS TO PLANT MANAGER, AT OPERATING LICENSE.

O 3. THIS POSTION REPORTS TO DIRECTOR, POWER GENERATION, AT COMMERCIAL OPERATION.

FIGURE 1-4 E

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J WASHINGTON PUBLIC POWER SUFFLY SYSTE: **

OPERATIONAL 5 PAes QUALITY ASSURANCE PROGRA.TI DESCRIPTION 1-19 3 --

WNP-3/5 ORGANIZATION (PRIOR TO OPERATING LICENSE)

J MANAGING DIRECTOR DEPUTY MANAGING DIRECTOR O

QUAUTY ASSURANCE PROGRAM m DIRECTOR J DIRECTOR i

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l i I O PROJECT 2 PROJECT MANAGER PLANT GUALITY ASSURANCE MANAGER MANAGER PROJEC NAGER 1

3 O OPERATIONS STARTUP CUAUTY ASSURANCE SUPERVISOR MANAGER O LEGEND ADMINISTRATIVE & FUNCTIONAL REPORTING

---

UNES OF COMMUNICATION O

1 THis POSITION REPORTS TO MANAGER. OPERATIONAL QA & SERVICES. AT OPERATING UCENSE.

2 THIS POSITION REPORTS TO DIRECTOR. POWER GENERATION. AT COMMERCIAL OPERATION

3. THIS POSITION REPORTS FUNCTIONALLY TO THE DEPUTY PROJECT MANAGER UNTIL OPERATING UCENSE.

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WASHINGTON PUBLIC POWER SUPPLY SYSTEM 5 OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 2-1 D

2 QUALITY ASSURANCE PROGRAM 2.1 PURPOSE This section provides an overall description of the QA Program that will be applied to initial testing and subsequent operation and main-O tenance activities throughout the life of Supply System's nuclear power plants.

2.2 GENERAL D

2.2.1 The QA Program and its implementing procedures and/or instructions are or will be structured to comply with the provisions of QA-related Regulatory Guides as identified and modified in Appendix II, "Posi-O tion Statements". A matrix of implementing procedures / instruct 1)ns cross referenced against each criterion of Appendix B to 10CFR1 will be included in this section not later than ninety (90) days prior to the then-current schedule for initial fuel loading.

O 2.2.2 A listing of safety-related items that will be subject to the appli-cable controls of the QA Program is included in the Final Safety Analysis Report (FSAR) for the Supply System's applicable nuclear O power plant. Measures shall be established and implemented to con-trol the maintenance and distribution of this listing (including drawings referenced therein) per Section 6.

D 2.2.3 Applicable provisions of the QA Program shall be implemented by the earliest of the following and shall remain in effect for the life of Supply System's nuclear power plants:

e a. Prior to inception of the activity.

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O WASHINGTON Fb8UC POWER SUFFLY SYSTEM OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 2-2

'O 2.2.3 (cont'd.)

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b. At the time of temporary / permanent transfer of system / component custody to Supply System,

c. Ninety (90) days prior to the then-current schedule for initial

.O fuel loading.

2.2.4 Revisions to the QA Program will be made, as needed, by the corporate Quality Assurance. The Nuclear Regulatory Commission will be noti-

'O fied of a) programmatic changes (except for those that are editorial in nature) for review prior to implementation of these changes, and b) organizational changes of substantial nature within thirty (30) days after announcement.

,O-2.2.5 Managers of Supply System organizations responsible for implementing the applicable provisions of the DA Program shall assure that activi-ties that affect safety-related functions of plant items are per-O formed by personnel who have been indoctrinated and trained. The scope, objective, and method of implementing the indoctrination and training program shall be documented. Proficiency of personnel per-forming activities that affect safety-related functions of plant

.O items shall be maintained by retraining, re-examination, and/or re-certifying, as applicable. Methods shall be provided for documenting

( training.

O 2.2.6 The scope, implementation, and effectiveness of the QA Program is routinely audited by the corporate Quality Assurance. Copies of audit reports are presented to Supply System management to provide for assessment of the effectiveness of the QA Program. Additionally, O on an annual basis, the Supply System management arranges for an in-

, dependent audit and evaluation of the adequacy of the scope, imple-mentation, and effectiveness of the QA Program. This is accomplished by knowledgeable personnel outside of corporate Quality Assurance O ="5 n

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WASHINGTON PUBLIC FOWER SUFFLY SYSTEM 5

OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 2-3

o 2.2.6 (cont'd.)

O to assure achievement of an objective program essessment. Results of these independent audits are reported to the Managing Director / Deputy Managing Director.

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WASHINGTON PUBUC FOWER SUFFLY SYSTEM OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 3-1

)

3-DESQNCONTROL 3.1 PURPOSE This section sets forth requirements for the control of new designs, changes thereto, and plant modifications that affect safety-related l

) functions of structures, systems, and components.  !

3.2 GENERAL 1

3 3.2.1 Organizations (both internal and external) participating in the pre-paration, r6 view, approval, and verification of design documents -

(drawings, design input and criteria, specifications, design analy-sis, computer programs, system descriptions, procedures, and instruc-

) tions) associated with new designs, changes thereto, and plant modi-fications shall develop and implement procedures that clearly de-lineate actions to be accomplished. These procedures shall contain provisions to assure that:

D

a. Applicable regulatory requirements and design bases specified in the Final Safety Analysis Report are correctly translated into design documents.

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b. Appropriate quality standards are specified and included in de-sign documents and that changes from such standards are docu-mented, approved, and controlled.

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c. Design analysis (reactor physics, stress, thermal, hydraulic, accident, etc.) is performed, where applicable.

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O WAS IINGTON PUBLIC POWEP. SUPPLY SYSTEI.: " "' S OPEltATIONAL ,

QUALITY ASSUltANCE PflOGilAM DESCitIPTION 3

.)

3.2.1 (cont'd.)

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d. Items such as compatibility of materials, parts, components, and processes selected; accessibility for inservice inspection, maintenance, and repair; and delineation of acceptance criteria 3 for inspections and tests are considered, where applicable, dur-ing the design development and review phases.

e. Errors and deficiencies discovered in approved design documents y

that could adversely affect safety-related structures, systems, and components are documented and that appropriate corrective action is taken.

f. Development, maintenance and use of computer code programs is

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controlled. Where the use of a particular computer code for performing design calculations is specified, such computer code is verified and certified for use.

3.2.2 Where two or more design organizations are involved in the perform-ance of design, necessary interface controls (both internal and ex-ternal) shall be documented and controlled between the participating organizations, particularly in the area of review, approval, release, d distribution and revision of interface documents.

3.2.3 Design verificatinn, to provide assurance that the design meets the specified design inputs, shall be performed by utilizing methods such as design reviews, alternate calculations, or qualification testing.

3.2.4 Design verification procedures shall be establisher! and implemented.

These procedures shall:

3

a. Provide for the determination of the method for design verifica-tion that will be utilized.

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5 OPERATIONAL t PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 3-3

) . i 3.2.4 (cont'd.) .

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b. Provide assurance that the design verificaticn is performed and documented by personnel other than those who performed the ori-ginal design, but who may be from the same organization.

J

c. Identify the responsibilities of the verifier; areas, features, and pertinent considerations to be verified; and the documenta-tion to be generated.

d. Require that where verification method is only by test, the pro-totype, component, or feature testing is perfonned at the earli-est practicable stage.

J e. Require the accomplishment of design verification, in all cases, prior to relying upon the item to perform its safety function.

3.2.5 Design documents shall be reviewed for adequacy by the originating organization unless delegated to another qualified organization.

Such reviews shall be documented and maintained on file.

3.2.6 Changes to approved design documents shall be subjected to design

) control measures comparable with those chat were applied to the ori-ginal design and shall be approved by the same organization that ap-proved the original design, unless delegated to another qualified organization.

J 3.2.7 Measures shall be established to assure that plant personnel and other affected organizations are made aware of design changes /-

modifications that affect the performance of their duties.

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e WASIIINGTON PUBLIC POWER SUPPLY SYSTEI.: **

5 OPERATIONAL QUALITY ASSURANCE PROGRA31 DESCRIPTION 'I4l e

4 - PROCUREMENT DOCUMENT CONTROL e

4.1 PURPOSE This section sets forth requirements for preparatica, review, and approval of procurement doctnents and changes thereto in order to control the quality of vendor furnished safety-related plant items and services.

4.2 GENERAL O

4.2.1 Precedures/ instructions shall be established and implemented to con-trol procurement-related activities such as procurement planning; preparation, review, approval and control of procurement documents; O vendor selection; bid evaluations; and review and concurrence of ven-dors' quality assurance programs. These procedures / instructions shall, clearly delineate tha sequence of actions to be accomplished in

! the preparation, review, and a;; proval of procurement-related docu-O ments and shall identify those positions or groups responsible for performing those actions.

4.2.2 Procurement documents for items (other than commercial grade off-O the-shelf items, as defined in 10CFR21) and for services shall re-quire, where necessary, vendors or subvendors to provide a quality assurance program consistent with the applicable provisions of the QA Program.

O 4.2.3 As deemed necessary, the procurement documents will provide for right of access to the vendor's facilities and records for source inspection / audit by Supply System or its designee.

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.O WASHINGTON PUBLIC POVIER SUPPLY SYSTEL: " " V' 5 l OPERATIONAL QUALITY ASSURANCE PROGRAM DESCRIPTION 4-2 40

4.2.4 Procurement documents shall contain or reference applicable technical I requirements (such as regulations, specifications, drawings, codes,

O and standards), test and inspection requirements, and special process instructions that must be complied with by vendors.

4.2.5 Procurement documents shall contain, as applicable, requirements

~O which identify the documentation (such as drawings, specification,

inspection and test records, personnel and procedure qualifications,

j. Certificates uf Conformance or equivalent certifications, and mater-

O ial chemical snd physical test results) to be prepared, maintained,

! submitted, or made available to supply system for review and/or ap-proval.

4.2.6 Procurement documents shall be reviewed by QA personnel. This review

O will be performed and documented to assure that quality requirements f are correctly stated, that they can be inspected and controlled, and l the procurement documents have been prepared to incorporate appro-

priate provisions of 4.2.2 through 4.2.5.

iO l 4.2.7 Changes (other than those that are of administrative nature) to ap-l proved procurement documents shall be subjected to the same degree of control that was applied during the preparation of original procure-lO ment documents.

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O WAS -IINGTON PUBLIC POWER SUPPLY SYSTEI.: ""-

OPERATIONAL 5 QUALITY AS"URANCE PROGRAM DESCRIITION -Y

.O 5 - INSTRUCTIONS, PROCEDURES, AND DRAWINGS

O 5.1 PURPOSE This section sets forth requirements for instructions, procedures,

-O and drawin;3 for activities that affect safety-related functions of plant items.

i l

5.2 GENERAL

O 5.2.1 Activities that affect safety-related functions of plant items shall be described by and accomplished through implementation of documented

procedures, instructions, or drawings, as appropriate.

O l 5.2.2 Procedures / instructions shall be established to assure that procedures, instructions or drawings include appropriate quantitative (such as dimensions, tolerances, and operating limits) or qualitative g (such as comparative workmanship samples) acceptance criteria for determining satisfactory work performance and quality compliance.

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5 OPERATIONAL PAGE QUALITY ASSURANCE PROGRA31 DESCRIPTION 6-1 JJ 6 - DOCUMENT CONTROL 6.1 PURPOSE This section sets forth requirements for the control of documents pertaining to activities that affect safety-related functions of plant items.

6.2 GENERAL

'3 6.2.1 Procedures / instructions shall be established and implemented to con-trol the issuance of documents such as instructions, procedures, and drawings, including changes thereto, which pertain to activities af-fecting safety related functions of plant items. These procedures /

3 instructions shall provide assurance that:

a. Documents are reviewed for technical adequacy, by qualified in-dividuals, prior to approval for release.

3

b. Procedures / instructions addressing maintenance, calibration, testing, drawings, specifications and etc. are reviewed and con-curred with by qualified QA personnel for quality-related as-O pects prior to approval for release except in unusual situations wherein QA concurrence shall be obtained at the earliest avail-able opportunity.

3 c. Maintenance, modification, rd inspection procedures are re-viewed by QA personnel to assure the need for inspection, iden-tification of inspection personnel, and documentation of inspec-tion results plus necessary inspection requiremer,cs, methods, D and acceptance criteria is orovided.

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D WASHINGTON PUBLIC POWER SUPPLY SYSTEI.: ""**

OPEllATIONAL 5 QUALITY ASSUllANCE PflOGIIAM DESCitIITION 6-2 3

6.2.1 (cont'd.)

3 '

d. Documents are approved for release by authorized personnel prior to implementation.

3 e. Documents are available at the location where prescribed acti-vity will be performed prior to cormiencing the work.

f. Changes (other than those that are of administrative nature) to g

approved documents are reviewed and approved by the same organi-zations that performed the original review and approval unless delegated to other appropriately qualified organizations.

g. Approved changes to documents are promptly incorporated into 3

instructions, procedures, drawings, and other appropriate docu-ments.

h. Obsolete or superseded documents are controlled to prevent their inadvertent use.

6.2.2 Current revision status of documents, such as instructions, pro-cedures, drawings, and specifications shall be identified and main-O tained.

6.2.3 As a minimum, the applicable requirements of this section, shall be applied to the following documents:

D

a. Design documents

b. As-built drawings D

, c. Procurement documents 3 weiis as

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WAS:llNGTON PUBLIC PO)7ER SUPPLY SYSTEI." """*

5 OPEllATIONAL PAG E QUALITY ASSURANCE PROGRAM DESCitIPTION 6-3 3

6.2.3 (cont'd.)

J

d. Operational QA Program Description

e. Final Safety Analysis Report D

f. Procedures and/or instructions for plant modifications, opera-tion, maintenance, inspection, testing and calibration

g. Reports of nonconformances D

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OPEll ATION Al.

PAGE QUAL.lTY ASSUllANCE PitOGilAM DESCitIPTION 7-1 0

7 - CONTROL 0F PURCHASED MATERIAL, EQUIPMENT, AND SERVICES 7.1 PURPOSE O

Inis section establisnes controls to assure that safety-related items and services, whether purcnased directly or througn contractors and subcontractors, conferm to procurement documents.

O 7.2 GENERAL 7.2.1 Procedures / instructions snall be estaolisned and implemented for tne O control of purchased materials, equipment, and services. These procedures / instructions snall clearly descrioe tne actions to be ac-complished and identify those positions or groups responsible for performing those actions.

O 7.2.2 Material, equipment, services and spare / replacement parts (other tnan commercial grade /off-tne-shelf items as defined in 10CFR21) for safety-related structures, systems and components:

O

a. Shall be procured from vendors wnose quality assurance qualifi-cations nave been affirmed, either prior to or after award of the contract, by the corporate Quality Assurance, and O

b. Shall De subjact to the quality assurance program controls and to tecnnical requirements at least equal to the original techni-cal requirements or to revised controls tnat have oeen properly

, reviewed and approved.

7.2.3 Evaluation of vendors, including review and concurrence of vendors' QA programs, snall be performed by QA personnel competent in deter-g mining the ability of vendors to provide acceptable quality prod-ucts.

Source sele 6 tion will be based on one or more ,of the following:

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9 WAS:lINGTON PUBLIC POV/EP. SUFPLY SYSTEI.; "'**

Ol'Mit ATION Al. 5 PAGE QUAL.lTY ASSUltANCE PitOGitAM DESCilli' TION 7-2 9

7.2.3 (Cont'd)

a. The aallity of tne vendor to coinply witn tnose elements of 10CFR50 Appendix 8 applicable to the type of material, equip-ment, or services being procured.

o. A revieu of previous record and performance of vendors who have O provided similar articles of tne type being procured.

c. A survey of the vendor's facilities and QA program to determine his capability to supply a product wnich meets tne design, manu-O facturing, and quality requirements.

7.2.4 Source verification (vendor surveillance, inspection and audit) snall be commensurate witn tne relative importance, complexity, and quan-O tity of the items or service procured and tne vendor's quality per-formance. In-process and final surveillance requirements of vendor products snall oe determined in advance and performed to assure con-formance witn procurement document requirements. Source verification O is not required to be performed where tne quality of the item can be verified by review of test reports, inspection upon receipt, or other means. Source verification activities shall include evaluation of vendor furnisned Certificates of Conformance and/or vendor's Certifi-O cation System.

7.2.5 Receiving inspection of vendor furnished items Snall be performed to assure tnat:

O

a. Tne item is properly identified and corresponds to the identifi-cation on the procurement document and the receiving documenta-tion.

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O WAS:IINGTON PUBLIC POWEI'. SUPPLY SYSTEI.; ""**

5 OPEll ATION Al.

PAGE QUAL.lTY ASSUllANCE PitOGilA.\1 DESCitIPTION 7-3 D

7.2.5 (Cont'd)

b. The item and the acceptance records satisfy the inspection in-3 struction prior to relying upon the item to perform its safety function.

c. Specified inspection, test, and otner records are complete and C available at the site prior to relying upon the item to perform its safety function.

d. Inspection status of accepted items is identified prior to their O being released for storage, use or further work.

7.2.6 Documentary evidence tnat tne vendor furnished items conform to the procurement requirements shall be retained at the site for the life D of the items.

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WASHINGTON PUBLIC POYlER SUPPLY SYSTE.: ""**

5 OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 8-1 3

8 - IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS

) 8.1 PURPOSE This section sets forth requirements for identification and control of safety-related materials, parts, and components.

8.2 GENERAL Procedures and/or instructions shall be established and implemented for the identification and control of items so as to prevent use of

~

incorrect or defective items. These procedu -as and/or instructions shall assure that:

a. Identification requirements for items are established during initial planning (i.e. during generation of specifications and design drawings).

) b. Identification of the item is maintained by heat number, part number, serial number or other appropriate means.

c. Identification of the item is maintained either on the item or

) on records traceable to the item.

d. The traceability of the item to copropriate documentation, such as specific inspection / test records, code data reports, and

) physical / chemical mill test reports, is maintained when such traceability is required by codes, standards or specifications.

e. Identification of the item is maintained throughout fabrication, 3 shipping, installation and use of the item.

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O WAS:IINGTON PUBLIC POWEI'. SUPPLY SYSTE:.: ""*'

5 OPEll ATION Al.

PAGE QU Al.lT1 AS3UllANCE PitOGilAM DESCilli' TION s

8.2 (Cont'd.)

3 f. The location and metnod (sucn as application of metal tags or markings) of identification do not affe. t the safety-related function of the item, g g. Correct identification of the item is verified prior to release of the item for fabrication, snipping, assemoling and installation.

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9 WAS;IINGTON PUBLIC POWEP. SUPPLY SYSTEL' ""*

OPERATIONAL PAG E QUALITY ASSURANCE PROGRASI DESCRIPTION 9-1 0

9 - CONTROL OF SPECIAL PdfCESSES J

9.1 PURPOSE

, This section sets forth requirements for special process activities which affect safety-related structures, systems, and components.

9.2 GENERAL

) 9.2.1 Special processes are those that require interim in-process controls in addition to final inspection and/or examination to assure achieve-ment of required quality.

!') 9.2.2 Procedures / instructions shall be established and implemented to as-sure adequate performance and control of special processes such as welding, heat treating, non-destructive testing, and chemical clean-ing. These procedures / instructions shall contain provisions for:

O

a. Qualifying the personnel, equipment, and procedures to be uti-lized for performing special processes.

1 C) b. Documenting the evidence (inspection or process results) of ac-ceptable perfonnance of special processes.

l 9.2.3 Special processes shall be performed by qualified personnel utilizing l C) qualified procedures and qualified equipment in accordance with ap-plicable codes, standards, and specifications. For special processes not covered by existing codes or standards, the necessary qualifica-tions of personnel, procedures, and equipment shall be defined in

() appropriate documents.

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'O WASIIINGTON PUBLIC POWER SUPPLY SYSTEL: ""-

5 5

OPERATIONAL PAGE l QUALITY ASSURANCE PROGRA31 DESCRIPTION 9-2

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4 j 9.2.4 Procedures, equipment, and personnel to be utilized for the perform-ance of special processes shall be qualified / certified by Quality j Control / Quality Assurance personnel.

4 9.2.5 Qualification records of procedures, equipment, and personnel associ-

ated with special processes shall be established, filed, and main-

}O tained current.

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O WASHINGTON PUBLIC pot 7ER SUPPLY SYSTEi; ""**

5 OPERATIONAL PAGE QUALITY ASSURANCE PROGRA.\1 DESCRIPTION 10-1 0

10 - INSPECTION 10.1 PURPOSE This section sets forth requirements for inspection of activities that affect safety-related functions of plant items.

10.2 GENERAL 10.2.1 Inspections which provide assurance that safety-related plant items O

and activities conform to applicable specifications, drawings, codes, standards, and regulations, shall be performed and documented in ac-cordance with written and approved procedures, instructions or check lists.

O 10.2.2 Inspection procedures, instructions or check lists will, as appropri-ate, provide for:

O a. Date inspection performed

b. Description of inspection methoc

c. Identification of characteristics and activities to be inspected.

1

d. Acceptance or rejection criteria

e. Identification of required procedures, drawings and specifica-tions.

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f. Specifying necessary measuring and test equipment including ac-p curacy requirements

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l g. Identity of inspector and/or data recorder.

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WASHINGTON PUBLIC POWER SUPPLY SYSTEI.* ""*"

OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCR!ITION 10-2 0

10.2.3 Inspections shall be performed by individuals other than those who performed or directly supervised the activity being inspected.

10.2.4 Individuals performing inspections shall be qualified and the status of their qualifications shall be maintained current.

O 10.2.5 Where mandatory inspection holdpoints are identified in pertinent documents work shall not proceed beyond these holdpoints without the consent of responsible inspection personnel or group.

O 10.2.6 Inspection results shall be documented, evaluated, and their status recorded by a responsible individual or group. ,

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CASHINGTON PUBUC POWER SUFFLY SYSTE1!

OPERATIONAL PAGE QUALITY ASSURANCE PROGRA.\1 DESCRIPTION 11 - 1

)

11 - TEST CONTROL

)

11.1 PURPOSE This section set forth requirements for testing to assure that

) safety-related plant items will perform satisfactorily in service.

11.2 GENERAL

) 11.2.1 Tests required to demonstrate that plant items will perform satisf actorily in service shall be identified, documented, and performed in accordance with written and approved procedures / instructions.

)

11.2.2 Tests will include, as appropriate, the following:

9

a. Prototype qualification tests.

)

b. Proof tests prior to installation.

c. Preoperational and startup tests.

)

d. Surveillance tests during plant operation,

e. Tests associated with plant modification and maintenance activities.

)

11.2.3 Test procedures / instructions shall incorporate or reference, as appropriate, the following:

) *

a. Instructions for performing the test. ,

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O WASHINGTON FUBLIC FOWER SUFFLY SYSTELt 5

OPERATIONAL La

QUALITY ASSURANCE PROGRAM DESCRIPTION 11 - 2

O 11.2.3 (Cont'd.)

!O b. Test prerequisites such as calibrated instruments, adequate test equipment, completeness of the item to be tested, and suitable environmental conditions.

lO c. Mandatory inspection hold points.

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d. Acceptance /rejc; tion criteria.

O e. The requirements and acceptance limits contained in the applicable design documents.

l f. Methods of documenting or recording test data and results.

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g. Provisions for assuring tnat test prerequisites have been met.

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11.2.4 Test results shall be documen*ed, evaluated, and their status lO recorded by a responsible 1.Jividual or group.

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O WASHINGTON PUBLIC POYlEP. SUPPLY SYSTEL" ""-

5 OPERATIONAL QUALITY ASSURANCE PROGRAM DESCRIITION 12 - 1 0

12 - CONTROL OF MEASURING AND TEST EQUIPMENT C

12.1 PURPOSE This section sets forth the requirements to establish those meas-

,C) i ures which will assure that tools, gages, instruments, and other mr.asuring and testing devices used in activities affecting quality are controlled, calibrated, and adjusted at specified periods in order to maintain accuracy within necessary limits.

! 12.2 GENERAL i 12.2.1 Measuring and test equipment (M&TE) shall be calibrated and ad-4 justed using approved procedures / instructions.

! C) 12.2.2 A calibration program for the control and use of M&TE shall be es-j tablished, and implemented. This program, as a minimum, shall pro-I vide for:

i, C)

! a. Unique identification of the item and its traceability to the calibration test data.

j C) b. Labeling or tagging (or otherwise controlling) to indicate the 4

due date of the next calibration.

c. Calibration technique and frequency.

I C)

d. Generation and maintenance of records which indicate the com-plete listing of all items under the calibration system toget-her with their current calibration status, f C)

e. Controlled environment conditions for sensitive and close tol-2 erance M&TE.

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WAS;IINGTON PUBLIC POWER SUPPLY SYSTEI. ""*

OPEllATIONAL PAGE QUALITY ASSUllANCE pit 0GItAM DESCitIITION 12 - 2 0

12.2.3 M&TE shall be calibrated against certified calibrating standards O having known valid relationships to nationally recognized stand-ards. If no national standards exist, the basis for calibration will be documented.

12.2.4 Calibrating standards that are used for calibrating M&TE shall have O

tolerance not greater than one fourth (1/4) the tolerance of M&TE.

Tolerances greater than 1/4 will be acceptable when limited by the state-of-the art. Calibrating standards shall be calibrated against higher level standards.

12.2.5 M&TE shall be calibrated and maintained at specified periods based on the required accuracy, purpose, stability characteristics, and other conditions affecting the measurement.

12.2.6 When an item of M&TE is found to be out of calibration, an evalua-tion shall be made and documented to determine the validity of pre-vious inspection / test results and the disposition to be made of O

items previously inspected / tested.

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13 - HANDLING, STORAGE, AND SHIPPING 13.1 PURPOSE 1

i This section establishes controls for cleaning, handling, storage, packaging, shipping and preservation of safety-related items.

13.2 GENERAL 13.2.1 Cleaning, handling, storage, packaging, shipping and preservation of O items shall be accomplished in accordance with written procedures /

instructions, to prevent damage, loss or deterioration by environ-mental conditions. These procedures / instructions shall be prepared i in accordance with the design and procurement requirements of the O items.

I 13.2.2 When necessary for particular iteins, special coverings, special j equipment and special protective environments, such as inert gas  :

O atmosphere, specific moisture content levels, and temperature levels, shall be specified, provided, and their existence verified.

13.2.3 Responsible personnel shall assure that items are identified, inven-jO toried, adequately packaged to ensure integrity during transit, properly addressed and released and that these activities are docu-mented.

jO 13.2.4 Measures shall be established and implemented to control the storage of chemicals, reagents (including control of shelf-life), lubricants ano other consumable materials for safety-related application.

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40 WASHINGTON PUBLIC POWER SUPPLY SYSTEM 5

OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 14 - 1 iO 14 - INSPECTION, TEST AND OPERATING STATUS

O 14.1 PURPOSE

This section sets forth the requirements for identifying the inspection, test, and operating status of safety-related items.

!O 14.2 GENERAL l Procedures / instructions shall be established and implemented for iO identifying the inspection, test, and operating status of plant

items. These procedures / instructions shall include provisions for assuring that

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a. The application and removal of status indicators (stamps, tags, labels, routing cards, physical barriers, etc.) is controlled.

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b. . Items which require inspections and tests are identified and lO controlled to preclude bypassing of such inspections and tests.

1

c. The status of inspections and tests performed upon individual l

plant items is indicated by the use of status indicators or 10 other suitable means.

d. The operating status of nonconforming, inoperative, or malfunctioning installed plant items is documented and O identified to prevent inadvertent operation.

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15 - NONCONFORMING MATERIALS, PARTS, OR COMPONENTS 3 15.1 PURPOSE _

This section sets forth requirements for the control of safety-related items, services, or activities which do not conform to speci-

) fled requirements.

15.2 GENERAL 3 15.2.1 Measures shall be established to control nonconforming items to pre-vent their inadvertent use or installation. These measures shall include, as appropriate, procedures / instructions for identification, review, documentation, segregation, disposition, approval, and noti-

) fication to affected organizations of nonconforming items.

15.2.2 Measures shall be established and documented defining the responsi-bility and authority for determining and approving the disposition of

] nonconforming items.

15.E.3 Nonconformances shall be documented. This documentation shall:

J a. Clearly identify the nonconforming item; and

b. Describe the nonconformance, the disposition of nonconform nce, and inspection / test requirements (where applicable).

h 15.2.4 Nonconforming items shall be reviewed and accepted for use-as-is, rejected, repaired, or reworked in accordance with documented procedures / instructions. The Supply System Quality Assurance shall 3 reviev nonconf ormances to assure that dispositions have been eval-uated and approved.

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15.2.5 Acceptability of repaired, reworked and replaced item shall be veri-O fied and documented by inspecting and/or testing the item in accord-ance with original inspection and/or test requirements or approved alternatives.

15.2.6 Where feasible, nonconforming items shall be segregated from other O.

acceptable items and/or uniquely identified as nonconforming until properly dispositioned for use.

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- PAGE QUALITY ASSURANCE PROGRASI DESCRIPTION "O

16 - 1

16 - CORRECTIVE ACTION I

16.1 PURPOSE O

l This sectic,n sets forth the requirements for identification, 4

correction, documentation, and reporting of conditions adverse to quality such as failures, malfunctions, deficiencies, deviations,

O defective material and equipment, and nonconformances.

16.2 GENERAL jO 16.2.'1 Conditions adverse to quality shall be evaluated and the need for corrective actions determined in accordance with established procedures. These procedures shall provide for prompt identification and correction of conditions.

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16.2.2 For conditions significantly adverse to quality, the corrective l action procedures shall provide for the following: ,

O a. Determination of the cause of the condition.

b. Corrective action so as to preclude repetition of the condition.

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c. Verification of the implementation of the corrective action.

i 16.2.3 Conditions significantly adverse to quality, its cause, and the 10 corrective action taken shall be documented and reported to appropriate levels of management for review and assessment.

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17 - QUALITY ASSURANCE RECORDS 17.1 PURPOSE O

Tnis section sets forth requirements for generation, transmittal, retention, and maintenance of quality assurance records for Supply System's nuclear power plants.

O 17.2 GENERAL 17.2.1 Sufficient records snall be maintained to furniso ?vidence of tne O quality of safety-related plant items and activities. As a minimum these records snall include the following:

a. Operating logs O

b. Results of design reviews, inspections, tests, audits, and material analysis

!O c. Monitoring of work performance

- d. Qualifications of personnel, procedures, and equipment.

lO e. Drawings, specifications, procedures, and procurement documents.

f. Nonconformance and corrective action reports iO

g. Records as required by plant technical specifications.

4 17.2.2 Inspection and test records snall identify the following anere qg applicable:

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17.2.2 (Cont'd)

a. Inspector and/or data recorder .

b. Tne type of observation

c. The date and results of inspection or test.

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d. Acceptability of results.

e. The action taken to resolve any deficiencies noted.

O 17.2.3 Quality assurance records shall be generated (prepared, reviewed, and approved), accumulated, transmitted for incorporation into the records retention system, retained, maintained, and controlled in 0 accordance witn documented procedures and/or instructions.

17.2.4 Ine quality assurance records shall be organized and filed so that eacn document is identifiaole and retrieveole.

O 17.2.5 Tne quality assurance records shall be filed and maintained in facilities tnat provide protection from possible deterioration or damage and shall be controlled to prevent loss.

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18 - AUDITS 3 18.1 PURPOSE This section sets forth requirements for auditing to verify imple-mentation and determine the effectiveness of the QA Program.

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18.2 CENERAL 18.2.1 A comprehensive system of planned and documented audits by the 3 corporate Quality Assurance, shall be carried out to verify compli-ance with applicable aspects of the QA Program. These audits shall consist of both internal audits of Supply System's nuclear power plants and other Supply System organizations and external audits of D Supply System vendors performing activities covered by the QA Program.

18.2.2 Audits shall include the objective evaluation of work areas, acti-vities, processes, and items; review of documents and records; and D quality-related practices, procedures and instructions to determine the effectiveness of implementation of the QA Program.

18.2.3 Audits shall be scheduled based upon the status and safety impor-D tance of the activities.

18.2.4 Audits shall be performed in accordance with written procedures or check lists and conducted by appropriately trained personnel not J having direct responsibilities in the areas being audited.

18.2.5 Audit results shall be documented by auditing personnel and re-viewed by management having responsibility in the area audited.

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18.2.6 Follow-up action on deficiencies shall be accomplished.

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!O APPENDIX I

QUALIFICATION REQUIREMENTS O

The qualification requirements for the position of Director c'- Quality Assurance include having a broad background and working knowledge of nuclear plant engineering, construction, and operating activitiet Also required is O knowledge of Quality Assurance regulations, policies, practices and standards and experience working in Quality Assurance or related activity in reactor design, construction or operation or in a similar high technology industry.

Educational requirements include, as a minimum, a baccalaureate degree or O equivalent

• in Engineering or related science. The Director of Quality Assurance shall have four (4) years of experience in the field of quality assurance, or equivalent number of years of nuclear plant experience in a supervisory position preferably at an operating nuclear plant or a combina-O tion of the two. At least one (1) year of this four (4) years experience shall include detailed involvement in the administration of and adherence to the quality assurance program in a significant management role directly involving nuclear power plants, such as engineering, construction, operation, O etc.

• Equivalency will be determined based upon an evaluation of the following f actors:

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1. High school diploma or GED.

2. Sixty (60) semester hours of related technical education taught at the O college level (900 classroom or instructor conducted hours).

3. Qualified as an NRC senior operator at the assigned plant.

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4. Four (4) years of additional experience in his area of responsibility.

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5. Four (4) years of supervisory or management experience.

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APPENDIX I QUALIFICATION REQUIREENTS

O l 6. Demonstrated ability to communicate clearly (verbally and in writing).

I j 7. Certification of academic ability and knowledge by corporate management.

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] 8. Successful completion of the Engineer-In-Training examination.

9. Professional Engineer License.

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10. Associate degree in Engineering or related science.

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APPENDIX II

" POSITION STATEMENTS" S

INTRODUCTION This Appendix identifies those quality-related Regulatory Guides which the 3 Supply System intends to follow during operations phase of its nuclear power plants. However, where the Regulatory Positions stated in these Regulatory Guides could lead to misunderstanding, or where alternate methods and/or solu-tions are implemented for accomplishment of Regulatory Positions, they are D also described in this Appendix.

This Appendix is organized in three sections.Section II.1 describes Supply System Position Statements applicable to nuclear power plant WNP-2, Section D II.2 is applicable to WNP-1/4, and Section II.3 is applicable to WNP-3/5. The Supply System comitments to comply with applicable Regulatory Guides not addressed in these sections of this Appendix are or will be documented in the applicable Final Safety Analysis Report.

P The Supply System Positions, described in this Appendix, will be incorporated by Supply System organizations in their procedures and/or instructions for applicable activities.

h This Appendix will be revised, as and when necessary, by the Supply System Quality Assurance Director, in accordance with the provisions of Section 2 of the QA Program.

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OPERATIONAL PAGE QUALITY ASSURANCE PROGRA31 DESCRIITION II.1-1

)

APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2"

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II.l.1 REGULATORY GUIDE 1.8, REV l-R (May, 1977) " Personnel Selection and Training"

) Supply System Position Tne Supply System will implement tne provisions of Regulatory Guide 1.8, Rev. 1-R (May, 1977) and the requirements in the endorsed

) standard ANSI N18.1-1971.

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()U Al.lTY ASSUllAS(:E PitO(;llA.il DEF(:ltil' TION q ft_1 ?

a APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" O

II.1.2 REGULATORY GUIDE I.26 REV. J (february 1976) " Quality Group Classifications and Standards for Water , Steam , and Radioactive-Waste-Containing Components of Nuclear Power Plants" O

Supoly System Position Tne Supply System will implement tne provisions of Regulatory Guide O 1.20, Rev. 3 (February 1976).

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) II.1-3 APPENDIX II II.1 " POSITION STATEMENT FOR WNP-2" J

II.l.J REGULATORY GUIDE 1.29,. REV. 2 (Feoruary 1976) " Seismic Design Classification" 3 Supply System Position Tne Supply System wi'1 implement tne provision of Regulatory Guide 1.29, Rev. 2 (Feoruary 1976).

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PAG E QU AI.lTY ASSUltANCE PitOGilAM DESCittlilON s

II.1-4 APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" O

II.1.4 REGULATORY GUIDE 1.30 (Safety Guide 30, Aucust 11, 1972) " Quality Assurance Requirements for the Installation, Inspection and Testing of Instrumentation and Electric Equipment" O

Supply System Position The Supply System will implement the provisions of Regulatory Guide 3 1.30 (Safety Guide 30, August 11,1972) and the requirements in the endorsed standard ANSI N45.2.4-1972 (also designated as IEEE 3td 336-1971), subject to the following:

9 1. Regulatory Position C.1 of Regulatory Guide 1.30 (Safety Guide 30, August 11,1972) states that ANSI N45.2.4-1972 should be used in conjuction with ANSI N45.2-1971, " Quality Assurance Program Requirements for Nuclear Power Plants". It is the 3 Supply System position that ANSI N45.2-1971 is not applicable for operational phase activities at nuclear power plants.

Instead the Supply System will comply with its Position Statement on Regulatory Guide 1.33.

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2. Regulatory Position C.3 of Regulatory Guide 1.30 (Safety Guide 30, August 11,1972) states that the requirements promulgated by ANSI N45.2.4-1972 are also to be considered applicable for g the installation, inspection, and testing of instrumentation and electric equipment during the operational phase of nuclear power plants. It is the Supply System position that the intent of ANSI N45.2.4-1972 will be maintained for all plant modifications.

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QUAL.lTY ASSUltANCE PitOGitAM DESCitil'rlON 3 II.1-5 APPENDIX II II.1 " POSITION STATEENTS FOR WNP-2" O

II.1.4 REGULATORY GUIDE 1.30 (Cont'd)

3. Section 3(3) of ANSI N45.2.4-1972: Checking of records is normally accomplished during periodic surveillances and audits O of the storage facility. The checking of storage records for each individual item prior to installation is not planned.

4. Section 5.1.2 of ANSI N45.2.4-1972: Inspections to verify O housekeeping will be done as stated in the Supply System Position Statement on Regulatory Guide 1.39.

5. Section 5.2.1 of ANSI N45.2.4-1972: Tests will include those O listed as appropriate. The manufacturers' recommendations shall be considered. The test procedure will specify the actual test to be performed.

O 6. Section 9 of ANSI N45.2.4-1972: The Supply System position, stated herein, does not address the codes and standards listed and/or referenced in this paragraph. Such position will be developed in the future, if the need arises.

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7. Appenoix A " Supplementary Provisions for Multi-Unit Stations" to ANSI N45.2.4-1972 is not considered applicable to WNP-2.

O 8. Appendix B " Additional Codes, Standards and Guides" to ANSI N45.2.4-1972: Refer to Supply System Position on Section 9 of l ANSI N45.2.4-1972.

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APPENDIX II II.1 " POSITION STATEMENTS-FOR WNP-2" O

II.1.5 REGULATORY GUIDE 1.33 REV 2 (February 1978) " Quality Assurance Program Requirements (Operation)"

'O Supply System Position l

l l The Supply System will implement the provisions of Regulatory Guide q 1.33, Rev. 2 (February 1978) and the requirements contained in the lO ' endorsed standard ANSI N18.7-1976/ANS-3.2, subject to the following:

f

] 1. Regulatory Position C.2 of Regulatory Guide 1.33, Rev. 2 j (February 1977) implies that the provisions contained in the

]g latest revisions of the Regulatory Guides, listed therein, will be followed. The Supply System will follow its Position j Statements on applicable Regulatory Guides as described j throughout Section II.1 of this Appendix.

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2. Section 5.2.13.4 of ANSI N18.7-1976/ANS-3.2: The third paragraph

of this section is revised to read, "Special handling tools and

! equipment shall be inspected and/or tested, as necessary, in ac-c rdance with written procedures and at specified times to verify lO l

that the tools and equipment are adequately maintained".

i j 3. Section 5.2.17 of ANSI N18.7-1976/ANS-3.2 states that inspec-tion of operating activities may be conducted by second-line

supervisory personnel or by other qualified personnel not l assigned first-line supervisory responsibility for conduct of the work. The Supply System position is to allow the plant i operations' shift supervisors (first-line supervisors) to per-

'O form inspections of surveillance tests, provided that an 'after- *

$ the-f act review of surveillance documentation is perfonned by the i

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APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" J

II.1.5 REGULATORY GUIDE 1.33 (Cont'd.)

Operations Supervisor (a second-line supervisor) or by other j personnel not assigned first-line responsibility for the conduct of the work.

4. Sections 5.2.19.1 and 5.2.19.2 ;f ANSI N18.7-1976/ANS-3.2 e describe rules of practice for preoperational and startup test program. The Supply System intends to comply with the provi-sions of these sections. In cases, where conflicts exists between these sections and Regulatory Guide 1.68, the Supply g System will comply with the implementation of Regulatory Guide 1.68 as described in Chapter 14 " Initial Test Program" of the Final Safety Analysis Report.

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APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" O

11.1.6 REGULATORY GUIDE 1.37 (March 16, 1973) " Quality Assurance Require-ments for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants" O

Suppl _y System Position The Supply System will implement the provisions of Regulatory Guide g 1.37 (March 16,1973) and the requirements in the endorsed standard ANSI N45.2.1-1973, subject to the following:

1. Regulatory Position C.4 of Regulatory Guide 1.37 (March 16, g 1973) states, in part, " Chemical compounds that could contribute to intergranular cracking or stress-corrosion cracking should not be used with austenitic stainless steel and nickelbase al-loys". In clarification, the Supply System will abide by the g chemical composition limits established by its Nuclear Steam .

Supply System vendor, with regard to control of marking mate-rials, paints, chalk, mineral and organic acids, chemical com-pounds, materials, solvents and chemicals used for cleaning, and plastic films.

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2. Regulatory Position C.5 of Regulatory Guide 1.37 (March 16, 1973) states, in part, "Specifically, tools which contain mate-rials that could contribute to intergranular cracking or which, U

because of previous usage, may have become contaminated with g

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APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" O

II.1.6 REGULATORY GUIDE 1.37 (Cont'd.)

such materials should not be used on surfaces of corrosion-O resistant alloys". In clarification, the Supply System will abide by the chemical composition limits established by its Nu-cidar Steam Supply System vendor, with regard to control of grinding tools and materials, wire brushing tools and materials, O chipping tools and materials, and sanding tools & materials.

3. Section 2.1 of ANSI N45.2.1-1973 states, in part, " Planning for cleaning activities shall include a review of the system and O component design specifications and drawings. In clarification of this requirement, a review of system and component design specifications and drawings will be required for only those mod-ifications which change the design of a fluid system.

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4. Section 2.3 of ANSI N45.2.1-1973, last sentence, is revised to read, " Test reports shall include an evaluation of the accept-ability of inspection and test results and provide for identify-O ing the individual who performed the evaluation."

5. Section 3.1.2.1 of ANSI N45.2.1-1973 states, in part, " Scattered areas of rust are permissible provided the aggregate area of rust does not exceed two square inches in any one square foot O

area." The Supply System considers this two square inch limit as a guide only. Adequate discretion by experienced personnel will be used in all cases.

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APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" b

II.1.6 REGULATORY GUIDE 1.37 (Cont'd.)

6. Section 3.1.2.5 of ANSI N45.2.1-1973 states, in part, "There J shall be no evidence of organic contamination in the effluent water or on the filter." The Supply System intends to comply with this requirement. The presence of organic contaminition will be determined visually or by feel.

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7. Section 4 of ANSI N45.2.1-1973, second sentence, is revised to read, " Inspections, examinations, or tests for cleanliness shall be perfonned if it is suspected that cleanliness has been af-3 fected by transportation to, or storage at the installation site."

8. Section 7.4 of ANSI N45.2.1-1973 requires checking of' cleaning 3 solutions for effectiveness of inhibitors (if used). In clari-fication of this requirement, the effectiveness of inhibitors (if used) will be determined by documentation in technical lit-erature or manufacturer's or vendor's reconinendations.

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APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" O

II.1.7 REGULATORY GUIDE 1.38,' Rev. 2 (May,1977) " Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Water-Cooled Nuclear Power Plants" O

Supply System Position The Supply System intends to implement the provisions of Regulatory

.O Guide 1.38, Rev. 2 (May, 1977) and the requirements in the endorsed standard ANSI N45.2.2-1972, subject to the following:

1. Section 3.2.1 (1) of ANSI N45,2.2-1972: Temperature and humid-

$O ity control considerations frir packaging of Level A items are not considered applicable ta nuclear fuel assemblies unless recomended otherwise by tne nuclear fuel manufacturer. The Supply System will abide by the manufacturer's recomendation.

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2. Section 3.5.2 of ANSI N45.2.2-1972, last sentence, is revised to read as, " Tapes used for identification rather than sealing which are not near a welding operation may remain indefinitely IO (see also Appendix section 3.5.2 for additional requirements)."

4

3. S'.ction 3.7.1 (1) of ANSI N45.2.2-1972: The Supply System may use cleated, sheathed boxes for loads up to 1,000 pounds rather

!O than 500 pounds limit imposed here. This type of box has been tested by WNP-2 Nuclear Steam Supply System vendor, and been found safe for loads up to 1,000 pounds. Other national stand.

ards allow the 1,000 pounds designation; see Federal Specifi-cation PPP-B-601.

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APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" 3

1I.1.7 REGULATORY GUIDE 1.38, Rev. 2 (May, 1977) (Cont'd.)

4. Section 6.1.2 (1) of ANSI N45.2.2-1972: Temperature and humid-

?) ity controls required for the storage of Level A items are not considered applicable for nuclear fuel assemblies unless recom-mended otherwise by the nuclear fuel manufacturer. The Supply System will abide by the manufacturer's recommendation.

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5. Section 6.4.2 (6) of ANSI N45.2.2-1972: Provisions of this section, concerning periodic rotation and the degree of rota-tion of shaf ts of rotating equipment, while in storage, will be 3 complied with unless recommended otherwise by the manufac-turers. The Supply System will abide by the manufacturers' recomendation.

3 6. Appendix Sections A3.4.1 (4) and A3.4.1 (5) of ANSI N45.2.2-1972: During printing of the standard, a transposition occurred between the last sentences of these sections. The Supply System will comply with the correct wording which reads 3 as follows:

A3.4.1 (4), last sentence: However, preservatives for inacces-sible inside surfaces of pumps, valves and pipe for systems

, containing reactor coolant water shall be the water flushable J

type.

A3.4.1 (5): The name of the preservative used shall be 47di-

_ cated to facilitate ': ouch up.

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11.1.8 REGULATORY GUIDE 1.39, REV. 2 (September 1977) " Housekeeping Requirements for Water-Cooled Nuclear Power Plants"

) Supply System Position The Supply System will implement the provisions of Regulatory Guide 1.39, Rev. 2 (September 1977) and the requirements in the endorsed 3 standard ANSI N45.2.3-1973, subject to the following:

Section 2.1 of ANSI N45.2.3-1973 requires the establishment of cleanness requirements for housekeeping activities on the basis of zone 3 designations. The Supply System considers these zona designation and the requirements associated with each zone as impractical for implementation during the operation phase. Procedtres or insructions for housekeeping activities, which include the ar,plicable requirements 3 outlined in Section 2.1 of ANSI N45.2.3-1973 ard which take into account the radiation control considerations, security considerations, and cleanness requirements, will be developed on case by case basis for maintenance and modification work to be performed.

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APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" 3

II.1.9 REGULATORY GUIDE 1.58, Rev.1 (September 1980) " Qualification of Nuclear Power Plant Inspection, Examination and Testing Personnel" Supply System Position The Supply System will comply with the provisions of Regulatory GuHe 1.58, Rev. 1 (September 1980) and the requirements in the endorsed standard ANSI /ASME N45.2.6-1978, subject to the following:

3

1. Regulatory Position C.1 of Regulatory Guide 1.58, Rev. 1 (September 1980) states that the guidelines provided by Regulatory Guide 1.8 should be followed in lieu of guidelines of ANSI /ASME N45.2.6-1978 for qualification of personnel (a) who approve pre-operational, startup, and operational test procedures and test results and (b) who direct or supervise the conduct of individual preoperational, startup, and operational tests. Supply System 3 takes exception to this regulatory recommendation as the approved version of Regulatory Guide 1.8 (endorses ANSI N18.1) does not contain guidelines addressing the subject personnel.

3 Instead, those Supply System personnel who approve pre-operational, startup and operational test procedures and test results will be qualified in accordance with the Supply Systen Position Statement on Regulatory Guide 1.8. Supply System perso nel who direct or 3 supervise the conduct of individual pre-operatlonal, startup and operational tests will be qualified to the appl! cable requirements of ANSI /ASME N45.2.6-1978.

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II.1.9 REGULATORY GUIDE 1.58 (Cont'd.)

2. Regulatory Position C.5 of Regulatory Guide 1.58, Rev. 1

) (September 1980) implies that individuals who review and approve inspection, examination, and testing procedures and those who evaluate the adequacy of such procedures to accomplish the in-spection, examination, and test objectives, should meet the Level III capability requirements delineated in Table 1 of ANSI /ASE

) N45.2.6-1978. Not all Supply System personnel perfoming the types of cited functions will meet the Level III capability re-quirements of Table 1 of ANSI /ASME N45.2.6-1978. However, per-sonnel performing the cited functions will be determined by Supply

) System canagement through evaluation of their education, training, and experience to be fully qualified and competent. The basis for the determination will be documented.

3. Section 1.2 of ANSI /ASME N45.2.5-1978, fourth paragraph, states that the requirements of this Standard apply to personnel of the owners and their suppliers. In clarification, the extent of ap-plication of the requirements of ANSI /ASME N45.2.6-1978 to Supply

) System suppliers will depend upon the nature and extent of mate-rials or services furnished, and as further described in Supply System Positions on Sections 2.4 and 3 of ANSI /ASvE N45.2.6 - 1978.

) 4 Section 2.1.2 of ANSI /ASME N45.2.6-1978 implies that personnel performing non-NDE type of inspections, examinations, and testing will be formally cert!f'M. The Sucply System does not plan this

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II.1.9 REGULATORY GUIDE 1.58 (Cont'd.)

formal certification. Instead, the Supply System will select such g personnel to predetermined qualification requirement for the spec-ified task based on their education, experience, and training.

Formal training records, when used as the basis for qualification, will be maintained on file.

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5. Section 2.4 of ANSI /ASME N45.2.6-1978 requires issuance of formal certification to individuals and specifies the details of the in-formation to be included in the certificate. The Supply System does not plan to issue formal certificates to individuals perform-O ing inspections, examinations, and testing, that fall within the s: ope of ANSI /ASME N45.2.6-1976 and Regulatory Guide 1.8. How-ever, information similar to the one described in this section of the Standard will be available in documented forni attesting that O the individual is capable of performing the assigned task (s). The Supply System will use a similar approach in evaluating its sup-pliers' compliance with this section of the Standard.

O 6. Section 3 of ANSI /ASME N45.2.6-1978 divides the capability re-quirements of inspection, examination, and testing personnel into three levels, namely Level I, level II, and Level III. The Supply System will not assign these levels to its personnel performing O inspection, examination, and testing activities. However, the selection of personnel for particular tasks will be such as to match the capabilities to the types of tasks, and maintain the O

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II.1.9 REGULATORY GUIDE 1.58 (Cont'd.)

intent of the three levels. The judgement to determine that a g' person's qualifications and capabilities meet the intent of a certain level of inspection, examination, and testing function is made by the normal management process, using established adminis-trative and personnel procedures. Documentation for such justifi-3 cation will be maintained on file. A similar approach will be used to evaluate qualifications of non-NDE personnel of Supply System suppliers.

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II.1.10 REGULATORY GUIDE 1.64, REV. 2 (June 1976) " Quality Assurance Requirements for the Design of Nuclear Power Plants" O Supply System Position The Supply System will implenient the provisions of Regulatory Guide ~

1.64, Rev. 2 (June 1976) and the requirements in the endorsed standard O ANS'I N45.2.11 - 1974, subject to the following:

Regulatory Position C.2 of Regulatory Guide 1.64, Rev. 2 (June 1976) states that individuals performing design verification should not have g imediate supervisory responsibility for the individual performing the design. It further states that while design verification by the imediate supervisor is encouraged, it should not be construed that such verification constitutes the required independent design tg verification. It is Supply System Position that in case the designer's immediate supervisor is the most technically qualified individual available in the organization to perform a design verification by design review, this review may be conducted by the O supervisor, providing that:

a. the justification is individually documented and approved in advance by the supervisor's management; and O ,

b. Quality Assurance audits cover frequency an.1 effectiveness of use of supervisors as design verifiers to guard against abuse.

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11.1.11 REGULATORY GUIDE 1./4 (February 1974) " Quality Assurance Terms and Definitions" J Supply Systern Position The Supply System will implement the provisions of Regulatory Guide 1.74 (February 1974) and the quality assurance terms and definitions J in the endorsed standard ANSI N45.2.10 - 1973, subject to the following:

1. Regulatory Position "C" of Regulatory Guide 1.74 (February 1974) 3 specifies certain documents recomended to be included in the definition of " procurement documents", defined in ANSI N45.2.10 -

1973. The Supply System will use the following definition:

g Procurement Documents - Purchase requisitions, purchase orders and contracts with attachments necessary to specify/ verify requirements.

2. Section 2 of ANSI N45.2.10 - 1973: The definition of 3

" specification" is revised to read as follows:

Specification - A statement of a set of requirements to be satisfied by a product, a material, a service or process 3

indicating, whenever appropriate the procedure by means of which it may be determined whether the requirements given are satisfied.

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II.1.12 REGULATORY GUIDE 1.88, REV. 2 (October 1976) " Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Ret.crds."

3 Supply System Position The Supply System will implement the provisions of Regulatory Guide 1.88, Rev. 2 (October 1976), and the requirements in the endorsed 3 standard ANSI N45.2.9-1974, subject to the following:

1. Regulatory Position C.2 of Regulatory Guide 1.88, Rev. 2 (October 1976) endorses the 4-hour fire rating requirements for J a single records storage facility as described in Section 5.6 of ANSI N45.2.9-1974. The Supply System modifies this 4-hour rat-ing requirement of ANSI N45.2.9-1974 to 2-hour fire rating re-quirement. Accordingly, the Supply System will comply with a D substitute to third, fourth, and fifth paragraphs of Section 5.6 of ANSI N45.2.9-1974 which reads, "Where a single record storage is maintained, the QA records shall be maintained in either:

O a. A 2-hour vault meeting NFPA (National Fire Protection Asso-ciation) No. 232-1975 without additional provisions; or

b. 2-hour rated file containers meeting NFPA No. 232-1975 3 (Class B) without additional NFPA provisions; or

c. 2-hour rated fire resistant file room meeting NFPA No. 232-1975 with the following addition 11 provisions:

g (1) Early warning fire detection and automatic fire sup-pression shall be provided, with electronic super-vision at a constantly attended central station.

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11.1.12 REGULATORY GUIDE 1.88 (Cont'd)

(2) Records shall be stored in fully enclosed metal cabi-O nets. Records shall not be permitted on open steel shelving. ilo storage of records shall be permitted on the floor of the facility. Adequate access and aisle ways shall be maintained at all times throughout the p facility.

(3) Work not directly associated with records storage or retrieval shall be prohibited within the records stor-D age facility. Examples of such prohibited activities include but are not limited to: records reproduction, film developing, and fabrication of microfiche cards.

D (4) Smoking and eating / drinking shall be prohibited throughout the records storage facility.

(5) Ventilation, temperature, and humidity control equip-ment shall be protected inside with standard fire-door dampers where they penetrate fire barriers bounding the facility."

p 2. Section 3.2.2 of ANSI N45.2.9-1974 is revised to read, "Index -

The quality assurance records shall be indexed. The indexing system (s) shall include, as a minimum, record retention times and the location of the records within the record system. The indexing system (s) shall provide sufficient information which

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can be used to identify item (s) or activity (ies)."

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11.1.12 REGULATORY GUIDE 1.88 (Cont'd)

3. Section 5.4.3 of ANSI N45.2.9-1974 is revised to read, "Special 3 Processed Records - Provisions shall be made for special proces-sed records (such as radiographs, photographs, negatives, and microfilm) to prevent damage from excessive light, stacking, electromagnetic fields, and temperature. These provisions will

) be delineated in procedures and/or instructions which will in-corporate, or take into consideration, available manufacturers' recomendations."

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II.1.13 REGULATORY GUIDE 1.94. REV. 1 (April 1976) " Quality Assurance Requirements for Installation, Inspection, and Testing c' Structural Steel During the Construction Phase of Nuclear Power Pla ts" O -

Supply System Position Regulatory Guide 1.94, Rev.1 (April 1976) and the endorsed standard O ANSI N45.2.5-1974 are not considered applicable to operations phase activities. However, the guidance provided by Regulatory Guide 1.94, Rev. 1 (April 1976), where appropriate, will be utilized for those applicable operational phase activities that are comparable to O activities occurring during the construction phase.

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I1.1.14 REGULATORY GUIDE 1.116, REV. 0-R (May 1977) " Quality Assurance Requirements for Installations, Inspection, and Testing of Mechanical Equipment and Systems" O

Supply System Position The Supply System will implement the provisions of Regulatory Guide 0 1.116, Rev. 0-R (May 197/) and the requirelents in the endorsed standard ANSI N45.2.8-1975, subject to the following:

1. Regulatory Position C.3 of Regulatory Guide 1.116, Rev. 0-R o (May 1977) recommends that the requirements of Section 5 of ANSI N45.2.8-1975 pertaining to preoperational tests, cold functional tests, and hot functional tests should be used in conjunction with Regulatory Guide 1.68. The Supply System will o comply with the implementation of Regulatory Guide 1.68 as described in Chapter 14 " Initial Test Program" of the Final Safety Analysis Report.

!O 2. Section 2.3 of ANSI N45.2.8-1975, last sentence is revised to

read, " Test reports shall include an evaluation of the acceptability of inspection and test results and provide for identifying the individual who performed the evaluation."

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3. Section 2.8.2 of ANSI N45.2.8-1975 states, " Records of calibration shall be included in inspection and test results."

Supply System does not intend to include calibration records in

, inspection and test results. Instead, the calibration records j will be maintained in a separate file.

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11.1.14 REGULATORY GUIDE 1.116 (Cont'd.)

4. Section 2.9.e(6) of ANSI N45.2.8-1975 states, "Cvidence that

) engineering or design changes are documented and approved prior to install ation." The Supply System may permit installation of an item prior to approval of the related engineering or design change provided procedural controls, requiring avidence of engineering or

) design change approval prior to placing the affected item into service, are instituted.

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II.1.15 Regulatory Guide 1.123, Rev.1 (July 1977) " Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants" 3

Supply System Position The Supply System will implement the provisions of Regulatory Guide J 1.123, Rev. 1 (July 1977), and the requirements in the endorsed standard ANSI N45.2.13-1976, subject to the following:

1. Regulatory Position C.3 of Regulatory Guide 1.123, Rev.1 (July

) 1977)

During printing of the Regulatory Guide, an error occurred in the last sentence. The Supply System will comply with the correct wording which reads as follow:

3 While Section 9 of ANSI N45.2.13-1976 addresses elements of the Purchaser's corrective action system, these same elements are applicable to the Supplier's corrective action system when one is required.

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2. Section 1.3 of ANSI N45.2.13-1976: The Supply System will comply with the aefinition of " procurement documents" as stated in Supply System Position Statement on Regulatory Guide 1.74

, (February 1974).

3. Section 3.2.2. of ANSI N45.2.13-1976: The first sentence of this Section is revised to read:

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II.1.15 Regulatory Guide 1.123 (Cont'd.)

" Technical requirements shall be specified in the procurement 3 documents by reference to or inclusion of applicable specific drawings, necessary portions of specifications, codes, regulations, procedures, or instructions (including revisions thereto) needed to accurately describe the products or services 3 to be furnished."

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11.1.16 REGULATORY GUIDE 1.144, REV.1 (September 1980) " Auditing of Quality Assurance Programs for Nuclear Power Plants."

Supply System Position O.

The Supply System will implement the provisions of Regulatory Guide 1.144, Rev. 1 (September 1980) and the requirements in the endorsed standard ANSI N45.2.12 - 1977, suoject to tne following:

] Section 4.4.4 of ANSI N45.2.12-1977 requires the audit report to include an evaluation statement regarding tne effectiveness of the l quality assurance program elements that were audited. Since the O

audit oy its very nature is an evaluation of the quality assurance program effectiveness, the audit report itself is considered to be an evaluation of the quality assurance program effectiveness. This sec-tion of tne Standard, is tnerefore, revised to read as, "A Summary of O Audit Results."

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11.1.17 REGULATORY GUIDE 1.146, ( August 1980) " Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants"

) Supply System Position, The Supply System will implement tne provision of Regulatory Guide 1.146 (August 1980) and the requirements in tne endorsed standard

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ANSI N45.2.23-1978.

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3 This section will be developed at a later date.

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l This section will be developed at a later date.

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