ML20041E712

to QA Program Description for Design & Const Phase

ML20041E712
Person / Time
Site:	South Texas
Issue date:	03/09/1982
From:	HOUSTON LIGHTING & POWER CO.
To:
Shared Package
ML20041E709	List: ML20041E708 ML20041E712 ML20041E727
References
NUDOCS 8203110268
Download: ML20041E712 (60)

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PART A

!!OUSTON LIGtITING AND POWER COMPANY QUALITY ASSURANCE PROGRAM DESCRIPTION SOUTl! TEXAS PROJECT ELECTRIC GENERATING STATION QUALITY ASSURANCE DURING DESIGN AND CONSTRUCTION Revision 3 March 9, 1982 8203110268 820309 PDR ADOCK 05000

7 HOUSTON LIGHTING & POWER COMPANY QUALITY ASSURANCE PROGRAM DESCRIPTION Table of Contents SECTION TITLE PAGE 1.0 Organization 2 2.0 Quality Assurance Program 11 3.0 Design Control 14 4.0 Procurement Document Control 16 5.0 Instruction, Procedures and Drawings 18 6.0 Document Control 18 7.0 Control of Purchased Material, Equipment and Services 19 8.0 Identification and Control of Material, Parts and Components 22 9.0 Control of Special Processes 23 10.0 Inspection 24 11.0 Test Control 25 12.0 Control of Measuring and Test Equipment 26 13.0 Handling, Storage and Shipping 27 14.0 Inspection, Test and operating Status 27 15.0 Nonconforming Materials, Parts or Components 28 16.0 Corrective Action 28 17.0 Quality Assurance Records 29 18.0 Audits 29

f HOUSTON LIGHTING & POWER C0ftPANY QUALITY ASSURANCE PROGRAM DESCRIPTION List of Tables NUMBER TITLE I Plan / Procedures used to Implement Quality for the !!ajor Activities 2 ANSI Standard and Regulatory Guide Compliance List of Figures NUMBER TITLE 1 South Texas Project Internal 0A Relationship 2 Lines of Conmunication HL&P & BPC/ Westinghouse (Contractors)

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QUALITY ASSURANCE PROGRAM DESCRIPTION South Texas Project Electric Generating Station Quality Assurance During Design and Construction Houston Lighting & Power Company (HL&P), as a licensee and as Project Manager for itself and the other owners, has quality assurance responsibility tor design, engineering, procurement, fabrication, construction and operation associated with the South Texas Project Electric Generating Station (STP). Although HL&P has delegated certain of its quality assurance authority to its contractors, it nevertheless retains the responsibility for the quality assurance program controlling all aspects of the STP. As an initial step in fulfilling its responsibility, HL&P establishes quality assurance requirements for the project in a Project Quality Assurance Plan. The Project quality Assurance Plan specifies requirements applicable to prime contractors and HL6P. The HL&P quality assurance staft monitors the performance of hL&P staff and contractors to assure compliance with the Project Quality Assurance Plan.

HL&P has contracted with Westinghouse Electric Corporation (Westinghouse) tor the design, fabrication and quality assurance services for the nuclear steam supply system and with Bechtel Power Corporation (BPC) for plant design, procurement, engineering, construction management, quality assurance services and other related services, including quality assurance services for Westinghouse items upon receipt at the project site. HL&P has contracted with Ebasco Services, Inc. (ESI) for construction services including quality 3 assurance and quality control for its scope of work. This quality assurance program description addresses the HL&P quality assurance program (Part A), the quality assurance program of EPC (Part B), and the quality assuance program of ESI (Part C). The Westinghouse quality assurance program is described in WCAP-8370,' " Westinghouse Nuclear Energy System Divisions Quality Assurance Plan" and is not included in this program description.

, PART A HOUSTON LIGHTING & POWER COMPANY QUALITY ASSURANCE PROGRAM DESCRIPTION South Texas Project Electric Generating Station Quality Assurance During Design and Construction Houston Lighting & Power Company (HL&P), as a licensee and as Project Manager for itself and the other owners, has the Quality Assurance (QA) responsibility for design, engineering, procurement, fabrication, construction, preoperational testing and operation of the South Texas Project (STP) Electric Generating Station.

HL&P's Quality Assurance Plan requires that HL&P, its prime contractors, subcontractors and vendors comply with the criteria established by 10CFR50 Appendix B. It is the intent of HL&P to comply with ANSI N45.2 and the applicable daughter standards and implementing Regulatory Guides as indicated in Table 2. Furthermore, HL6P will assure through programmatic direction that the Prime Contractors and all their subcontractors and suppliers performing nuclear safety-related work comply with 10CFR50 Appendix B, ANSI N45 2, and the Regulatory Guides as referenced herein consistent with their scope of work.

Programmatic direction is defined as the role of the owner in establish-ing the program requirements and ensuring the adequacy of the Prime Design, Engineering and Construction Management Quality Assurance Program. The programmatic direction consists of review and approval of the system teatures initially and continued monitoring of those systems during implementation and further refinement or revision of the systems it the systems need strengthening. The assurance of compliance by tirst level nuclear safety-related suppliers and contractors will be accomplished through the Engineer / Construction Manager's review and approval of the supplier's/ contractor's Quality Assurance Program.

The system monitoring is achieved through audits and surveillance of work in progress.

The HL&P Quality Assurance program is implemented '.n two phases: the design and construction phase as defined by the Project Quality Assurance Plan and the operational phase, including preoperational testing and startup, as defined by the Operational Quality Assurance Plan. The Project QA Plan is described herein. The Operational QA Plan is described in Chapter 17.2 ot tne FSAR.

The combination of these Quality Assurance programs augmented by definitive procedures provide HL&P with the assurance that its quality commitments are met.

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1.0 Organization 11 The organization chart shown in figure 1 illustrates:

(a) groups within HL&P having quality responsibilities (engineering, procurement, construction) and (b) Quality Assurance interdepartmental relationships for the South Texas Project.

12 The Project Quality Assurance Manager, South Texas Project, is responsible for providing the programmatic direction, and administering policies, goals, objectives and methods which are described in the Project Quality Assurance Plan. The HL&P Executive Vice President, Nuclear Group reviews and approves the Project Quality Assurance Plan and has ultimate responsibility for Quality Assurance activities. The Project Quality Assurance Plan interfaces with the corporate Quality Assurance program objectives by describing specific Quality Assurance controls to be established by HL&P and the prime contractors on the South Texas Project.

1.3 Two levels of control have been implemented by HL&P to monitor the effectiveness of the Quality Assurance Programs at the South Texas Project.

a) Corporate level control - Corporate level control is achieved through the direct involvement of the HL&P Executive Vice President, Nuclear Group and corporate audits and vendor surveillance as described below. The Executive Vice President regularly meets with QA management and receives reports on the status or the QA Programs to aid him in evaluating the overall effectiveness. Corporate QA audits and vendor surveillance are conducted under the direction of the Manager, QA to evaluate the overall program effecti 7 ness of HL&P Project QA, Westinghouse and its suppliers. Corporate audits of the Architect Engineer / Construction Manager's activities may be performed as requested by the Project QA Manager.

b) Project level control - Project level control is achieved through Project QA Program approval and monitoring of the effectiveness of implementation by HL&P, prime contractors and subcontractors. The Project QA staff under the direction of the Pri ject QA Manager prepares the Project QA Plan and reviews and approves the Project QA Program for the Architect Engineer / Construction Manager. The monitoring is implemented oy scheduled project audits performed by qualified auditors. Additional monitoring is accomplished by Project QA personnel performing unscheduled selected surveillance of in-process work. HL&P Project QA also maintains the capability to perform inspection verifications of in-process or completed work if determined to be necessary by the Project QA Manager. If necessary the inspections are performed by personnel qualitied in accordance with ANSI N45.2.6.

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1.3.1 Manager, Quality Assurance The Manager, Quality Assurance, has the authority and responsibility to identify, initiate, recommend, or provide solutions to quality related problems and verify the implementation and effectiveness of the solutions. He has the authority to "Stop Work" for cause in the design, construction and operation phase of the nuclear plant. The minimum requirements established for this position are:

a. A college degree in a field of engineering or science, or equivalent experience.

b. Familiarity with nuclear power generation facilities and the related operations.

c. Knowledge of the industry's quality assurance standards and regulatory requirements.

d. Management experience and familiarity with HL&P corporate organizations.

The Manager, Quality Assurance, provides technical guidance and administrative direction to:

a. Houston QA Manager 3

b. Operations QA Manager The Manager, Quality Assurance, reports to the Executive Vice President, Nuclear Group.

1.3.2 Project Qualit*/ Assurance Manager, South Texas Project The Project Quality Assurance Manager, South Texas Project, has the responsibility to identify, initiate, recommend, or provide solutions and authority to solve quality related problems and to verify the implementation and effectiveness of the solutions. He has the authority to "Stop Work" for cause on any quality-related activity of the South Texas Project.

The Project Quality Assurance Manager, South Texas Project, must, as a minimum, have:

a. A college degree in a field of engineering or science, or equivalent experience.

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b. Familiarity with nuclear power generation facilities and related operations.

c. Knowledge of the Quality Assurance standards and regulatory requirements.

d. Management experience and familiarity with HL6P corporate organizations.

The major responsibilities of the Project QA Manager, STP, are:

a. Develop and administer QA policies and, ensure the proper planning, development, implementation, coordination and administration of the Project Quality Assurance Plan.

b. Provide programm..;ic direction on QA related matters to HL6P, and contractor management, and provide the primary interf ace with NRC.

c. Coordinate activities relating to auditing and vendor surveillance in conjunction with the HL&P Support Quality Assurance Manager.

The Project Quality Assurance Manager reports on all quality assurance matters directly to the Executive Vice President, Nuclear Group. The Project QA Manager receives administrative guidance from the Manager, QA. This organizational arrangement provides independence from cost and scheduling influences.

1.3.3 Houston Quality Assurance Manager 3 The Houston Quality Assurance Manager reports on all technical and administrative matters directly to the Manager, QA. This organizational arrangement provides independence from cost and scheduling influences.

The Houston Quality Assurance Manager is 3 responsible for directing all HL&P corporate office auditing, vendor surveillance and technical services activities. He has the authority to "Stop Work" for cause on any quality-related activity of the South Texas Project.

4 The Houston Quality Assurance Manager must, as a 3 minimum, have:

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a. A college degree in a field of engineering or science, or equivalent experience.

b. Familiarity with nuclear power generation facilities and the related operations.

c. Knowledge of the industry's Quality Assurance standards and regulatory requirements.

d. Management experience and familiarity with HL&P corporate organizations.

The major responsibilities of the Houston Quality 3 Assurance Manager are:

a. Provide administrative guidance and direction for the HL&P Corporate Quality Assurance Audit Program.

b. Direct the HL&P NSSS vendor surveillance programs.

c. Manages the Technical Services Organization of the support division.

1.3.4 Project Quality Assurance General Supervisor, guality Engineering The Project Quality Assurance General Supervisor, Quality Engineering reports directly to the Project Quality Assurance Manager, South Texas Project. He is responsible for technical direction and administrative guidance to the discipline Quality Engineering personnel, providing programmatic direction to prime contractors and interfacing with the NRC. He is responsible for directing the onsite audit and surveillance act:t vities. He has the authority to "Stop Work" for cause on any activity related to fabrication and construction.

1.3.5 Supervisor, Quality Systems / Administration The Supervisor, Quality Systems / Administration reports directly to the Project Quality Assurance Manager, South Texas Project. He is responsible for providing technical direction and administrative guidance to the site Quality a

Systems personnel; developing and administering the HL6P Project QA Plan; evaluating the Engineer /

Construction Manager and Constructor QA programs; 3 administering the HL6P STP QA personnel training and certification program; administrative control 5

of HL&P STP project quality assurance procedures and providing mechanisms to correct the QA programs as necessary. He has the authority to "Stop Work" tor cause on any activity related to fabrication or construction.

1.3.6 Supervisor, Quality Control The Supervisor, Quality Control reports directly

to the Project Quality Assurance Manager, South Texas Project. He is responsible for technical direction and administrative guidance to the HL&P Quality Control personnel, coordinating inspection of selected fabrication and construction activities, ensuring proper nonconformance identification and assuring that the personnel performing inspections are properly certified. He has the authority to "Stop Work" for cause on any activity related to fabrication or construction.

1.3.7 Quality Engineering (QE) Project Quality Assurance Supervisors The QE Project Quality Assurance Supervisors report to the Project Quality Assurance General Supervisor. They are responsible for technical direction and administrative guidance to the HL&P Quality Engineering personnel in their respective discipline group; conducts audits of the Construction Manager and contractor activities, including QA; interface with NRC during audits; identifying deficiencies; reviewing procedures applicable to their respective discipline; and providing programmatic direction to the prime contractor. They have authority to "Stop Work" for cause on any activity related to fabrication or construction.

1.3.8 Design Of fice/ Procurement Quality Assurance 3 Supervisor 4

The Design Office / Procurement Quality Assurance Supervisor reports directly to the Project Quality-Assurance Manager, South Texas Project. He is responsible for providing technical direction and administrative guidance to HL&P Design Office / Procurement Quality Assurance personnel, 3 coordinating the resolutious of vendor problems identified by HL&P QA, coordinating with site QE personnel for input to vendor surveillance / audit activities and providing programmatic direction to the Engineer / Construction Manager regarding design control, vendor surveillance and auditing 6

functions. He is responsible for directing audits / surveillance of the Engineer's design, procurement and Engineering activities, including QA. He has the authority to "Stop Work" for cause on any activity related to engineering, design, or procurement.

1.3.9 Manager, South Texas Project The Manager, South Texas Project reports to the HL&P Vice-President, Nuclear Engineering and Construction. He has overall responsibility for the engineering, construction, procurement, cost, schedule, and startup of the South Texas Pr oject.

He has authority to "Stop Work" for cause in all activities of the project.

1.3.10 Manager, Support Services The Manager, Support Services reports to the Manager, South Texas Project. He is responsible for procurement, project control services, accounting, project administration, contract administration and records management services.

He has the authority to "Stop Work" for cause in

activities related to purchasing and expediting.

1.3.11 Manager, Engineering The Manager, Engineering reports to the Manager, South Texas Project. He directs project

, engineering personnel in the performance of the 4

owner's review of the design and engineering work performed by the prime contractors. The Manager, Engineering ensures that adequate engineering planning and coordination of solutions to problems and work priorities are established by the prime contractor. He has the authority to "Stop Work" for cause in the engineering and design of all items.

1.3.12 , supervising Project Engineer, Components Engineering The Supervising Project Engineer, Components Engineering reports to the Manager, Engineering.

He is responsible for direction coordination and administration of the components engineering functions. This work includes engineering planning, coordination or solutions to problems, and work priorities in the areas of components and physical design pertormed by the prime contractors. He can recommend "Stop Work" for 7

cause in the engineering and design for those items within his area of responsibility.

1.3.13 Supervising Project Engineer, Site Enginearing The Supervising Project Engineer, Site Engineering reports to the Manager, Engineering. He also receives Project direction from the Project Site Manager. He is responsible for coordinating the site engineering interface in the technical resolution of all site related engineering problems, reviewing field change requests, and site-initiated design change notices. He assists in the release and interpretation of design documents. He can recommend "Stop Work" for cause in the engineering and design for those items within his area of responsibility.

1.3.14 Supervising Project Engineer, Systems Engineering The Supervising Project Engineer, Systems Engineering reports to the Manager, Engineering.

He is responsible for direction, coordination and administration of the Systems Engineering functions. This work includes interfacing with prime contractors in the area of engineered systems, fluid and electrical. He can recommend "Stop Work" for cause in the engineering and design for those items within his area of responsibility.

1.3.15 Leader, Engineering Administration The Leader, Engineering Administration reports to the Manager, Engineering and is responsible for the control, distribution and maintenance of engineering manuals and documents.

1.3.16 Supervising Engineer, Licensing The Supervising Engineer, Licensing reports to the Manager, South Texas Project. He is responsible for overseeing, coordinating and administering the South Texas Project Licensing effort.

1.3.17 Team Leader, Licensing The Team Leader, Licensing reports to the Supervising Engineer, Licensing. He is responsible for coordinating all regulatory activities related to the nuclear safety analysis and licensing of the South Texas Project. He is the chairman of the Incident Review Committee.

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1.3.18 Records Management System Manager The Records Management System Manager reports to the Manager, Support Services. He is responsiole for managing the Records Management personnel and interfacing with the prime contractors and all project organizations with respect to the establishment of systems that control, collect, store and transfer records related to the South Texas Project.

1.3.19 Project Site Manager The Project Site Manager reports to the Manager, South Texas Project. He is responsible for providing technical direction and administrative guidance to HL&P and its prime contractors in the area of construction, site purchasing, security, startup, accounting, construction control and reviewing documents, drawings and specifications related to construction. He also provides administrative guidance for HL&P site engineering.

He has the authority to "Stop Work" for cause in all activities related to construction.

1.3.20 Startup Manager The Startup Manager reports to the Project Site Manager. He is responsible for conducting and recommending for acceptance the f acility startup test program. He reviews and recommends approval of startup test reports, instructions, and procedures which assure conformance to design and safety requirements. The final approval authority for the startup program is the Plant Superintendent's responsibility.

1.3 21 Startup General Supervisor The Startup General Supervisor reports to the Startup Manager. He works as directed by the Startup Manager and assists in the ef fective administration, control, and implementation of the test program.

1.3.22 Construction Superintendent The Construction Superintendent reports to the Project Site Manager. This position is responsible for ensuring that the prime contractors comply with all contractual and construction requirements, evaluates and ensures 4

that work is preplanned, that work packages are 9

l being utilized in a timely and effective manner and provides recommendations for conduct of construction activities.

1.3.23 Construction Engineering Supervisor The Construction Engineering Supervisor reports to the Construction Superintendent. He is responsible for providing technical and administrative support to all HL&P Construction Engineers. He coordinates preparation and issuance of Project Site Procedures.

1.3.24 Construction Area Supervisor (s)

The Construction Area Supervisor (s) reports to the Construction Superintendent. They are responsible for monitoring and surveillance of the prime contractor's construction activities, expediting the resolution and corrective actions of problems identified by QA/QC and verifying that construction planning includes requirements for inspection and testing.

1.3.25 Project Purchasing Manager The Project Purchasing Manager reports to the Manager, Support Services. He is responsible for the overall coordination and administration of purchasing and subcontracting activities for the South Texas Project including the development and implementation of procedures, vendor selection, contract negotiations and preparing purchase orders for those prime contracts to HL&P.

1.3.26 Supervisor (s), Project Purchasing The Supervisor (s), Project Purchasing report to the Project Purchasing Manager. They are responsible for the development and implementation of procedures related to purchasing, material control and contract administration for HL&P direct procurement. They assist in the detection and resolution of procurement problems. The Site Supervisor, Project Purchasing reports for project direction to the Project Site Manager.

1.3.27 Contract Administrator The Contract Administrator reports to the Manager, Support Services. He is responsible for preparing the scope of contrac.ts, implementing procedures and reviewing invoices to assure contract 1

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compliance for prime contractors. He participates in contract negotiations, contract changes and operation monitoring to ensure contract compliance tor prime contractors.

1.4 The organizations or entities listed below may be delegated quality assurance authority within their scope of work.

HL6P has the responsibility to audit and monitor all of the below listed organizations' or entities' performance to assure that their quality programs provide sufficient authority and organizational freedom for personnel performing QA functions and that they are effectively implemented.

a. Houston Lighting & Power Company as a licensee and Project Manager for itself and the other owners has the overall responsibility for design, engineering, procurement, construction, operation and quality assurance activities.

Bechtel Power Corporation and Westinghouse Electric Corporation have contractual responsibility to provide acceptable QA programs to HL&P. The contract provides HL&P the authority to audit and monitor BPC and Westinghouse performance to assure that the Quality Assurance Programs provide for suf ficient authority and organizational freedom to be effectively implemented.

b. Bechtel Power Corporation as the Architect / Engineer and Construction Manager provides HL&P with design, engineering, procurement, construction management, and quality assurance services.

c. Westinghouse Electric Corporation as the Nuclear Steam Supply System (NSSS) supplier provides HL&P with the NSSS design, engineering, procurement, fabrication, and quality assurance services.

d. Ebasco Services Inc. as the Constructor shall provide HL&P 3 with construction quality assurance and quality control services under the direction and as approved by the Construction Manager.

e. Consultants - HL&P utilizes the services of qualified consultants to assist in the performance of quality tasks.

Figure 2 illustrates how these companies interrelate with HL&P for the South Texas Project.

2.0 Quality Assurance Program 2.1 The HL&P Project Quality Assurance program for the South Texas Project has been developed in accordance with the criteria of 10CFR50 Appendix B, ANSI N45.2 and Regulatory Guides as referenced herein, to provide programmatic direction on quality 11

requirements for the prime contractors and subcontractors during design and construction.

2.2 The nuclear safety-related structures, systems and components covered by this program are listed in Section 3.2 of the FSAR.

Westinghouse Electric Corporation provides quality assuraoce services for the items listed in Table 3.2.B-1 of the FSAR until delivery to the site. BPC and Ebasco Services, Inc. ,

provide quality assurance services for the items listed in 3 Table 3.2.A-1 of the FSAR within the scope of their work. BPC provides QA and QC services for Westinghouse items (Table 3.2.B-1) upon teneipt at the site until release for construction, after which ESI provides such services.

2.3 The HL&P Quality Assurance program for the South Texas Project is described by the HL&P Project Quality Assurance Plan. The plan requires that written procedures, training and certifica-tion, issuance of specifications and drawings, and work and inspection planning be accomplished in advance of performing nuclear safety-related activities. HL6P Project Quality Assurance ensures through procedure reviews that this advance preparation is accomplished.

The Project Quality Assurance Plan for the South Texas Project (STP) has in the past been structured in accordance with the Regulatory Guides (RGs) and Industrial Standards that are addressed in the NRC publications " Guidance on QA kequirements During Design and Procurement Phase of Nuclear Power Plants,"

(The Gray Book) Revision 1, dated May 24, 1974 (WASH 1283) and

" Guidance on QA Requirements During the Construction Phase of Nuclear Power Plants," (The Green Book) dated May 10, 1974 (WASH 1309). Presently the regulatory guides and standards listed on Table 2 are in ef fect for the South Texas Project.

2.4 The HLaP Plans and Procedures which are used to implement the quality related activities for each major organization and the reference to the applicable criteria of 10CFR50 Appendix B are

' listed in Table 1. Verification that plans and procedures are

' properly implemented is accomplished by HL6P Quality Assurance through audits, surveillance and regular management assessment of the Quality Assurance Program. ,

2.5 It is the policy of HL6P acting as a licensee and Project Manager for the other owners for the South Texas Project Electric Generating Station (STPEGS) to assure that the design, fabrication, construction, testing, and operation of STP are in conformance with project specifications, procedures, codes, and NRC regulations. It is the responsibility of each organization assigned to the STPEGS to ensure that project procedural review methods include provisions to ensure that the requirements stated in this program description are incorporated into project procedures. The Project Quality Assurance Plan identifies activities and establishes requirements for procedures which identify, initiate and verify the resolution 12 l

of nuclear safety-related quality problems. The implementing procedures call for the resolution of quality problems at the lowest possible authorized level. However, if a dispute is encountered in the resolution of a quality problem which cannot be resolved at lower levels, the Project Quality Assurance Manager, presents the problem ultimately to the HL&P Executive Vice-President, Nuclear Group for resolution.

2.6 HL&P Quality Assurance Department is responsible for conducting a quality oriented indoctrination program for new HL&P personnel who have quality-related functions. The HL&P Project Quality Assurance Plan requires that prior to performing activities affecting quality the personnel are trained, as necessary, in the applicable procedures. The training provides a thorough understanding of the purpose, sanoe, policies, principles, and techniques of the specifir g}ocedures or instructions. When personnel perform special process activities, a training and certification program is established and maintained. Refresher training is conducted as necessary to ensure that proficiency is maintained. Bechtel is required to establish a training program for Bechtel and administer the constructor's training program including refresher training, as necessary, to ensure proficiency is achieved and maintained.

HL&P Quality Assurance audits and surveillances are performed to ensure compliance with these criteria.

2.7 The Project Quality Assurance Manager, is directly responsible for assuring effective implementation of the Quality Assurance program. The qualifications for this position are defined in Section 1.3.

2.8 The HL&P Project Quality Assurance Plan requires BPC to review and approve these procedures which control nuclear safety-related construction activities. It is the responsibility of BPC's Project Quality Assurance to determine that the contractor's procedures require proper equipment, environment and other prerequisites to perform the associated activity. The implementation of these requirements is verified through audits and surveillance by HL&P, BPC, and ESI QA. 3 2.9 The results of the HL&P QA audit and surveillance activities are presented in a periodic report to the HL&P Executive Vice President, Nuclear Group. Regular executive management review of these activities and the direct involvement of the HL&P Executive Vice President, Nuclear Group assures that an objective program assessment of the South Texas Project Quality Assurance programs is being performed.

HL&P STP Quality Assurance reviews and documents approval of the Bechtel Project Quality Program Manual (PQPM); and audits and surveillances are performed by HL&P Quality Assurance to ensure compliance with the BPC PQPM.

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I 2.10 HL&P and Bechtel Project Quality Assurance will establish and document a program for transferring responsibilities and controls for quality-related activities from BPC to HL&P during phaseout of design / construction and plant turnover. This program will be implemented prior to preoperational testing.

This program will be in accordance with and consistent with the requirements of this section and/or 17.2 of the FSAR.

2.11 HL&P is committed to maintaining the Project Quality Assurance Plan as an effective and meaningful document to provide -

programmatic direction to HL&P and the prime contractors on the South Texas Project. When proposed substantive changes to the Project Quality Assurance Plan af fect the docketed Quality Assurance Program description, HL&P will notify the NRC of the change (s) for their review and acceptance prior to implementation.

Organizational changes of a substantive nature will be reported 1 to the NRC within 30 days of announcement.

3.0 Design Control HL&P has the overall responsibility for design and enginee.ing of the South Texas Project and imposes the requirements of 10CFR50, Appendix B, Criterion III, Regulatory Guide 1.64 and ANSI N45.2.11 on the prime contractors and applicable subcontractors.

HL&P has assigned the authority to BPC and Westinghouse to perform the design, engineering and design verification.

HL&P, as appropriate, selects contractors / subcontractors to perform design related tasks. These tasks include but are not limited to the following:

o New design a Special design studies o Design work outside the scope of prime contractors Cnangea to existing design performed by contractors no longer associated with the South Texas Project.

To be eligible to participate in design activities the contractor must be approved to assure he has the capability to perform the design er requested task in accordance with specified requirements.

When a contractor has been selected, HL&P Manager, STP or designee shall ensure that all appropriate design background information with which to perform the task is provided.

HL&P Engineering performs reviews of selected elements of the completed design, design documents and specifications to ensure that contractual requirements are met.

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The HL&P Manager, Engineering is responsible for ensuring that project engineering activities are conducted in accordance with approved engineering procedures. The project engineering organization provides programmatic direction and overview of the engineering activities. The HL&P project engineering activities are conducted in accordance with Project Engineering Procedures (PEP's).

These procedures are delineated in Table 1.

When HL&P has direct responsibility or assumes direct responsibility for conducting design activities, these activities will be conducted in accordance with the requirements of this section and/or the FSAR Section 17.2.3.

HL&P contractors are required to provide the following design control measures in their quality assurance programs:

A design control system is established to document the methods of accomplishing and controlling essential design activities.

Design documents such as calculations, diagrams, specifi cations, and drawings are prepared and records developed such that the final design is traceable to its sources.

• Design activities, documents, and interfaces are controlled to assure that applicable input such as design bases, regulatory requirements, codes, and standards are incorporated into the final design.

Design input requirements, including design criteria, are documented and their selection reviewed and approved.

Design documents include an indication as to their importance to safety and shall specify the quality characteristics, including materials, parts, equipment and processes, that are essential to safety-related aspects ot structures, systems, and components. Design documents also include, as appropriate, acceptance criteria tor inspections and tests.

Design control measures are applied to safety-related items such as seismic, stress, thermal, hydraulic, radiation, and accident analyses, as they apply to the development of design input or as they are used to analyze the design.

Safety-related designs, including Seismic Category 1 designs are verified for adequacy and accuracy through independent objective review of design documents by individuals competent in the subject activity. This verification may include the use of alternate or simplified solution methods or qualification testing, as appropriate.

Design changes, including engineering, vendor, and construction originated changes, are controlled in a manner commensurate with the control imposed on the original design.

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Document distribution is controlled such that all individuals using a design document or its resuits and/or conclusions for turther design work can be notified if the document is revised or cancelled.

Design documentation includes evidence that design control requirements have been satisfied.

Errors and deticiencies in approved design documents, including design methods (such as computer codes), that could adversely arfect safety-related structures, systems and components are documented; and action taken to assure that all errors and deficiencies are corrected.

Deviations from specified quality standards are identified and Procedures are established to ensure their control.

An accurate definition of the quality classes, including systems designated as safety-related is provided.

HL6P Quality Assurance performs audits of HL6P, BPC and Westinghouse to ensure that design controls, requirements, specifications and documents are in accordanca with the design, control criteria.

In addition HL6P Project Quality Assurance reviews selected quality / construction procedures to ensure that the quality requirements of the design specifications are incorporated. HL6P Project Quality Assurance also performs audits and surveillances to ensure that the work is accomplished in accordance with the design requirements and to ' ensure that field changes to the design are processed in accordance with the design control criteria.

4.0 Procurement Document Control To assure that nuclear safety-related items are purchased in a planned and controlled manner, the HL6P Project Quality Assurance Plan establishes basic requirements which are to be used by HL6P and prime contractors in preparing procurement procedures for the South Texas Project. BPC perf orms procurement activities for nuclear satety-related equipment , materials and services, exclusive of the NSSS contract, which is performed by Westinghouse. BPC will approve 3 any Ebasco nuclear satety-related procurements. BPC, and as appropriate, Ebasco verify through contract, vendor surveillance and audit that their suppliers comply with the established requirements.

When HL6P has direct responsibility or assumes direct responsibility tor procurement activities, these activities will be conducted in accordance with the requirements of this section.

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The basic requirements are:

Written procedures are established clearly delineating the sequence of actions to be accomplished in the preparation, review, approval, and control of procurement documents.

• A review of the adequacy of quality requirements stated in procurement documents is performed by qualified personnel knowledgeable in the QA requirements. This review is to determine all quality requirements are correctly stated; they can be inspected and controlled; there are adequate acceptance and rejection criteria; and the procurement document has been prepared in accordance with QA Program requirements.

Documented evidence of the review and approval of procurement documents is provided and available for verification.

Procurement documents identify those quality assurance requirements which must be complied with and described in the supplier's QA Program to meet 10CFR50 Appendix B, ANSI-N.45.2 and applicable ANS1 standards and reg. guides. This QA Program shall be reviewed for adequacy by qualified personnel knowledgeable in quality assurance.

Procurement documents contain or reference applicable design bases, technical requirements including regulatory require-ments, component and material identification, drawings, specifications, codes, and industrial standards, including their revision status, tests and inspection requirements and instructions for such activities as fabrication, cleaning, erecting, packaging, handling, shipping, storing, and inspecting.

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Procurement documents contain as applicable, requirements which identify the documentation to be prepared, maintained, submitted, and made available to the procuring agent for review and/or approval, such as drawings, specifications procedures, inspection and test records, personnel and procedure qualifications, and material and test repcits.

Procurement documents contain the requirements for the retention, control, submittal and maintenance of records.

Procurement documents contain the procuring agency's right of access to Vendor's facilities and records for source inspection and audit.

Changes and/or revisions to procurement documents are subject to at least the same review and approval requirements as the original document.

Purchase documents for spare or replacement parts of safety-related structures, systems and components are reviewed 17

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tor adequacy of quality requirements by qualified personnel knowledgeable in quality assurance. The review is to determine the adequacy of the quality assurance requirements and acceptance criteria relative to the original design.

The evaluation and selection of suppliers are determined by qualified personnel in accordance with written procedures acceptable to HL&P.

Procurement documents, records and changes thereto are collected, stored, maintained and retrievable in a systematic and controlled manner.

HL&P Engineering is responsible for review of selected BPC Procurement Specitications.

HL&P QA, BPC QA, and as appropriate, ESI QA, are responsible' for (3 pertorming audits and surveillance to verity that the requirements have been implemented and that they are effective.

5.0 Instructions, Procedures and Drawings The HL&P Project Quality Assurance Plan requires HL&P, the prime contractors and their suppliers to establish and implement a Quality Assurance Program which is in compliance with 10CFR50 Appendix B, ANSI N45.2 and applicable ANSI standards and reg. guides. Each program is required to be eftective in verifying that the defined activities are accomplished and documented in accordance with written procedures, instructions, and drawings and that they provide quantitative and qualitative acceptance criteria.

HL&P Project Quality Assurance rev1.ws and approves the BPC South Texas Project Quality Assurance Program. To measure the ettectiveness of the prime contractors' quality assurance programs, HL&P Project QA has implemented a monitoring program consisting of audits and surveillances. HL&P Houston Quality Assurance also audits HL&P Corporate organizations that pertorm functions for the South Texas Project, HL&P Project QA and Westinghouse for compliance

- with their respective Quality Assurance Programs.

6.0 Document Control The HL&P Project Quality Assurance Plan and implementing procedures require that HL&P, the prime contractors and subcontractors implement a document control system for nuclear safety-related items for the South Texas Project. The established system ensures that design, engineering, procurement, fabrication, construction, and QA/QC procedures, plans, and changes thereto are reviewed and approved by procedurally authorized groups and that the documents are issued, maintained current and controlled by the use or controlled lists of document holders to ensure that superseded documents are replaced in a timely manner.

18

Measures are established and documented to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto, which prescribe activities affecting quality.

These measures assure that documents, including changes, are reviewed for technical adequacy and the inclusion of appropriate quality requirements and approved for release by authorized personnel and are distributed to and usea at the location where the prescribed activity is performed. Changes to documents are reviewed and approved by the same organizations that performed the original review and approval unless other organizations are specifically designated. The reviewing organizations have access to pertinent background information upon which to base their approval and shall have adequate understanding of the requirements and intent of the original document.

Those participating in an activity are made aware of and use proper and current instructions, procedures, drawings, and engineering requirements for performing the activity. Participating organization have procedures for control of the documents and changes thereto to preclude the possible use of outdated or inappropriate documents.

Document control measures provide for:

o identification of individuals or organizations responsible for preparing, reviewing, approving, and issuing documents and revisions thereto; identifying the proper documents to be used in performing the activity; e

coordination and control of interface documents; e ascertaining that proper documents are being used; o

establishing current and updated distribution lists; o a listing identifying the current revision of instructions, procedures, specifications, drawings, and procurement documents. The list is updated and distributed to pre-determined responsible personnel.

HL&P, BPC and ESI QA perform audits and surveillances to verify that 3 document control systems are in place and effectively implemented.

7.0 Control of Purchased Material, Equipment, and Services The HL&P Quality Assurance Plan and implementing procedures require that HL&P, prime contractors and subcontractors define and document the system and requirements for the control of nucle ar safety-related purchased material, equipment and services.

19

Control and veritication of supplier's activities during fabrication, inspection, testing, and shipment of materials, equipment, and components is planned and performed as early as possible, as required to assure contormance to the purchase order or contractual requirements. These procedures provide tor:

o Requiring the supplier to identify processes to be utilized in fulfilling procurement requirements.

o Reviewing documents required to be submitted by the procurement requirements.

Specifying the characteristics or processes to be witnessed, inspected, or verified and accepted based upon the fabrication schedules; the method of surveillance and the extent of documentation required; and those responsible for implementing these procedures.

Audits, surveillance, and/or inspections which verify that the supplier complies with the quality requirements of his QA program.

Ccatrol and verification of organizations performing services is accomplished by technical verification of data provided, surveillance and/or audit of the activity and review of objective evidence such as certifications, reports, etc.

The selection of suppliers is based on evaluation of their capability to provide items or services in accordance with the requirements of the procurement documents prior to award of contract.

Procurement source evaluation and selection measures are implemented by HL&P and BPC which provide for the identification of the organizational responsibilities for determining supplier capability.

Measures for evaluation and selection of procurement sources, and the results thereof, are documented and include one or more of (a) through (c) and also must include (d) below;

a. Evaluation of the supplier's history of providing an identical or similar product or service which performs satisfactorily in actual use. The supplier's history shall reflect current capability.

b. Supplier's current quality records supported by doc mented qualitative and quantitative information which can ce objectively evaluated.

c. Supplier's technical and quality capability as determined by a direct evaluation of his facilities and personnel and the implementation of his approved quality assurance program.

20

/

, d. Evaluation of bid documents including review for technical

,,, adequacy, quality assurance, and commercial considerations.

Procurement of spare or replacement parts for safety-related

, strudtures, systems, and components is subject to QA program control'd, to codes and standards, and to technical requirements at least equal to the invoked original technical requirements or any properly reviewed and approved revisions.

A Receipt inspection is planned and implemented te assure:

Timely inspection of itemt, upon receipt.

• The material, component, or equipment is properly identified, and corresponds to the identification on the purchase document and receiving documentation.

' o Material, components, equipment and acceptance records satisfy the receiving inspection instructions prior to installation or

- use.

Specified inspection, test, and other records are accepted and

- available at the South Texas Project prior to installation or use where taquired unless otherwise authorized by conditional

, release, o items accepted and released are identified as to their inspection status prior to torwarding them to a controlled storage area or releasing them for further work or installation.

o Coordination of receipt inspection with vendor surveillance activities to verify the required vendor inspection has been performed or a waiver documented.

o Deficiencies if applicable have been resolved prior to shipment.

Suppliers' control and use of Certificates of Conformance when required by procurement documents are evaluated by audits, vendor inspections, or tests to ensure they are valid. The supplier's records shall include a description of those nonconformances from the procurement requirements dispositioned " accept as is" or

" repair," including evidence of acceptance by the purchaser's engineering organization.

Site receiving inspection ensures that, for nuclear safety-related items received at the South Texas Project, there is accompanying l documentation that indicates review and concurrence by the appropriate prime contractor or designee, that the item complies with established requirements or has an authorized waiver prior to shipment. BPC Quality Assurance audits and surveillances are performed to ensure compliance with these criteria.

i 21 i

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HL&P Design Of fice QA ensures by audits / surveillance of the AE/ construction manager's vendor surveillance function that source surveillance and inspection are performed in accordance with the quality assurance program. In addition HL&P QA performs audits and surveillances of activities commencing with receiving inspection at the site to ensure proper controls of purchased material and equipment are exercised and to insure overall compliance..

8.0 Identification and Control of Material, Parts and Components The HL&P Pr$ ject Quality Assurance Plan requires that prime contractors and suppliers establish written procedures which identify, control and ensure traceability of materials, parts and components including partially assembled components. Prime con-tractor's and supplier's procedures shall include the documented verification of correct identification of materials, components and subassemblies, and that the method of identification does not affect the function or quality of the item prior to release of the items for assembly or installation. These procedures musts o Establisu controls to identify and control materials (including consumables), parts, and components (including partially fabricated subassemblies).

Provide a method for identification of quality related materials and parts and to provide traceability to the.

appropriate drawings, specifications, purchase orders, manuf acturing and inspection documents, deviation reports, and physical and chemical mill test reports.

Provide a method for identification'and control of incorrect or defective items. This system includes verification and documentation prior to release for fabrication, assembling, shipping, and installation.

BPC and ESI QA verify that the above criteria are incorporated into 3 the Quality / Construction procedures during the review / approval cycle and then tollows up with audits and surveillances to verify compliance.

In addition HL&P QA performs audits and surveillances on prime contractors for evaluation of the conformance to identification and control criteria.

22

9.0 Control of Special Processes The HL&P Project Quality Assurance Plan requires that written procedures be established by prime contractors and subcontractors for the activities associated with all special processes. For special processes the qualification of personnel, procedures and equipment relating to specific codes, standards, specifications and contractual requirements shall be documented and maintained current.

Special Processes - special manufacturing processes, metallurgical, chemical, material cleaning, welding, plating, and other processes where assurance of the procesa quality is dependent largely on the inherent skill of the operator and cannot be assured by the inspection of articles alone.

Special processes for the South Texas Project include but are not limited to:

• Welding e Heat treating Cadwelding e Nondestructive testing a Chemical cleaning Organizational responsibilities are defined in procedures for qualitication of special processes, equipment and personnel. These responsibilities will include the provision to assure that special processes are performed by qualified personnel using procedures qualified and approved in accordance with applicable codes, standards, or other requirements.

Special processes are performed under controlled conditions by qualified personnel using procedures qualified and approved in accordaace with applicable codes, standards, or other requirements.

For special processes not covered by existing codes or standards the specific equipment, personnel qualification, and procedure qualification rtquirements are defined prior to application of the special processi.

Records are maintained for the qualification of procedures, equipment, and personnel associated with special processes. Records are in sufficient detail to clearly define the procedures, equipment, or personnel being qualified; criteria or requirements used for qualification; and the individual approving the qualification.

HL&P QA ensures that the special process control criteria are met by BPC and ESI review and approval of special process procedures 3 and their performance of audits and surveillances to ensure compliance.

23

4 1

HL&P will retain the capability with a quality control group to  !

perform, as directed by the PQAM, certain special process examinations (NDE) during the inspection verification process.

These examinations will be performed by personnel qualified in accordance with SNT-TC-1A-75 using qualified procedures approved by HL&P NDE Level III personnel.

HL&P QA performs audits and surveillances of special process activities to ensure compliance with all aspects of the Quality Assurance program.

l 10.0 Inspection

~

The HL&P Project Quality Assurance Plan requires the prime contractor for construction and subcontractors to establish and implement an inspection operation whose activities are independent from the group performing the activities beiLd inspected. The training, qualifications and certitications of inspectors include criteria trom appropriate codes, standards, and procedures.

1 Inspector training shall be documented and kept current.

Inspection activities relating to construction, fabrication, installation and testing are documented, kept current and identify all mandatory inspection hold and test points and the criteria to be witnessed by authorized inspectors. Operations and inspections (including rework, replaced items) are performed in predetermined, documented sequences. Deviations or deletions must be accomplished in accordance with approved and documented systems. Inspection procedures include all required inspection operations detined by the specifications, drawings, codes and standards. These

, procedures provide for the following:

1

! a. Identification of characteristics and activities to be inspected

b. A description of the method of inspection

c. Identification of the individuals or groups responsible for i performing the inspection operation

d. Acceptance and rejection criteria

e. Identification of required procedures, drawings, and specifications and revisions

f. Recording the identification of inspector and/or data recorder if applicable and the results or the inspection operation

g. Specifying necessary measuring and test equipment including accuracy requirements and verification of calibration

h. Evaluation of inspection results 24

Where direct inspections are impossible or disadvantageous, in-process monitoring is specified in the inspection procedures and both direct and in-process monitoring are used when control is inadequate without both. All required procedures, specifications and drawings are made available to the inspectors prior to perform-ing inspection. If mandatory inspection hold points are required beyond which work cannot proceed without the specific consent of the designated representative, the specific hold points will be indicated in appropriate documents. Inspection results are documented, evaluated and their acceptability determined by a responsible individual or group.

BPC and ESI QA verify that inspection control criteria are complied 3 with by review and approval of the inspection procedures and by audits and surveillances of inspections.

HL&P QC may occasionally perform inspection verifications as deemed necessary by the Project QA Manager.

HL&P, BPC and ESI QA perform audits and surveillance of inspection 3' activities to ensure compliance with all aspects of the quality assurance program.

The HL&P Inspectors are trained and certified by a program conforming to ANSI N45.2.6 ano as applicable, SNT-TC-1A-75.

11.0 Test Control The HL6P Project Quality Assurance Plan requires that a test control program be developed and documented by the prime contractors and contractors for tests that they are responsible for, which demonstrates that the facility performs in accordance with the South Texas Project requirements and specifications. The training, certification of personnel, calibration and certification of test equipment, system or component status, environmental conditions, inspection hold points and configuration of the items to be tested are included in the procedures. Test results are documented, evaluated and the acceptance status determined by the authorized departments.

Test precedures or instructions provide for the following as required:

a. The inclusion of requirements and acceptance limits contained in applicable design and procurement documents

b. Instructions for performing the test

c. Test prerequisites such as calibrated instrumentation, adequate test equipment and instrumentation including their accuracy requirements, completeness of item to be tested, suitable and controlled environmental conditions, and provisions for data collection and storage i

25

d. Mandatory inspection hold points for witness by Owner and the contractor's inspector (as required)

e. Acceptance and rejection criteria

f. Methods for documenting or recording test data and results

g. Provisions for assuring that test prerequisites have been met

h. Evaluation of results i

BPC and ESI QA verify inclusion of adequate test control criteria by review and approval of test procedures. HL&P, BPC, and ESI QA 3 perform audits and surveillance to verify that the controls are implemented and effective.

The test control activities are an example of a case in which HL&P Project QA monitoring activities and the Operational QA monitoring activities will interface and in some instances overlap. HL&P Project QA procedures will specifically define the responsibilities for this period. -

12.0 Control of Measuring and Test Equipment The HL&P Project Quality Assurance Plan requires the establishment, documentation and implementation of a Measuring and Test Equipment Control System. The system is to inclu'de calibration techniques, specifications, accuracy, frequency and maintenance of all measuring instruments / test equipment used in the measuring, inspection and monitoring of nuclear safety-related items.

Calibration and maintenance data shall be filed and kept current.

Calibration standards are to be traceable to nationally recognized standards where standards exist. If standards do not exist, the basis for calibration of the equipment shall be documented. If measuring or test equipment is found to be out of calibration, missing or lost, an investigation is required to be performed to determine the validity of the use of the instrument and whether '

measurements or tests are required to be reperformed. Reinspection wher required will be documented. c:in Equipment is identified and traceable to the calibration test data and suitably marked to indicate calibration status. Markings include the last day calibrated and next calibration due date.

Measuring and test equipment is calibrated at specified intervals based on the required accoracy, purpose, degree of usage, stability characteristics, and other conditions affecting the measurement.

Calibration of this equipment is against standards that have an accuracy of at least four times the required accuracy of the equipment being calibrated, or when this is not possible, have an accuracy that assures the equipment being calibrated will be within 26

l i

required tolerance and that the basis of acceptance is documented and authorized by responsible uanagement.

Calibrating standards will, when possible, have greater accuracy than standards being calibrated. Calibrating standards with the same accuracy may be used if they can be shown to be adequate for the requirements and the basis of acceptance is documented and authorized by responsible management.

BPC and ESI QA review and approve calibration procedures to ensure 3 these criteria are incorporated. In addition, HL&P, BPC, and ESI QA perform audits and surveillances to verify compliance.

l in the conduct of its inspection verifications, as directed by the PQAM, HL&P Quality Control is required to use measuring and test equipment of the appropriate accuracy level which is controlled by procedures meeting the requirements of this section.

13.0 Handling, Storage and Shipping Tne HL&P Project Quality Assurance Plan requires that for nuclear safety-related items, written procedures be developed in accordance with design requirements, specifications and standards to control the cleaning, handling, storage, packaging, shipping and preserva-tion to preclude damage and deterioration by environmental condi-tions. The activities are to be accomplished by appropriately I

trained and experienced personnel.

4 BPC QA and, as appropriate, ESI QA, review and approve quality 3' construction procedures for receiving, handling, storage and cleaning to verify that the appropriate criteria of Regulatory Guide 1.38 and ANSI N45.2.2 are included. Periodic audits and surveillances are conducted by HL&P, BPC, and ESI QA to verify compliance with the procedures.

14.0 Inspection, Test and Operating Status The HL&P Project Quality Assurance Plan requires that the prime

! contractor and construction contractors indicate the current inspection, test and operating status of nuclear safety-related items through the use of stamps, markings, tags or other suitable means. Procedures include the requirements for:

a. Controlling the application and removal of inspection status indicators such as tags, markings, labels, and stamps

b. Documenting the status of nonconforming, inoperative, or malfunctioning structures, systems, and components to prevent inadvertent use

c. Defining and documenting the use, application and removal of inspection tags, labels or markings which identity the status of inspections or tests performed and attest to the acceptability of the structure, system, or component 27

. _ ~ _ _ _ _ _ _ _ _ ,_ _ _ _ _ _ __ _ _ _ _ . . _ . . _ _ ,. . _ _ . . _ . - _ _ _ _-.-

d. Controlling the altering of the sequence of required tests, inspections and other operations.

BPC and ESI QA review and approve these procedures and conduct 3

periodic audits and surveillances to assure compliance. HL&P QA also conducts audits and surveillances to assure compliance.

15 0 Nonconforming Materials, Parts or Components The HL&P Project Quality Assurance Plan requires that HL&P maintains and the prime contractors' Quality Assurance Programs include a system which is documented by written procedures for the identitication, segregation and disposition of nonconforming materials, parts and components. The procedures shall specify the preparation and handling of nonconformance documents, segregation requirements and which groups are responsible for review and disposition of the items. Documentation identifies the nonconforming item; describes the nonconformance, the disposition of the noncontormance, and the inspection requirements; and includes signature approval of the disposition. Nonconformances are corrected or resolution determined prior to initiation of the preoperational test program on the item. Kework, repairs and subsequent reinspection, and tests are conducted in accordance with the original inspection and test requirements or accepted alternatives. These tests shall be performed in accordance with controlleu procedures and contain mechanisms for providing information to the identitying group as to the disposition of the nonconfo rmance. For NSSS items, RL&P coordinates nonconformance resolution through Westinghouse.

HL&P QA performs an evaluation of BPC's and ESl's nonconformance trend analysis. Procedures are established by HL&P to report l3 significant deficiencies during the design, construction, and operations phase to HL&P executive management and to the Nuclear Regulatory Commission in accordance with 10CFR50.55(e) and 10CFR21 l3 where applicable.

.. HL&P, BPC and ESI QA perform periodic audits and surveillance to

, assure compliance. 3 16.0 Corrective Action The HL&P Project Quality Assurance Plan for the South Texas Project requires that a system be established and documented by HL&P and the prime contractors which defines the responsibilities, authoritjes and methods used by specific groups involved in the evaluation of nonconformances and trending to determine the need tor corrective action. The system includes measures to identity the cause of significant conditions adverse to quality, measures to ensure that the root causes are corrected, and measures to ensure that timely action is taken. Follow-up is performed to ensure the ettectiveness of corrective action and that appropriate levels of management are intormed of the results. HL&P, BPC and ESI QA 3 pertorm trend analysis to determine the need for corrective action.

28 i

HL&P, BPC, and ESI QA perform audits and surveillances to assure 3 compliance.

17.0 Quality Assurance Records The HL&P Project Quality Assurance Plan requires that a Quality Assurance record system be developed by HL&P and the prime contractars for the South Texas Project. The record system provides evidence that activities relating to quality are defined, implemented and that inspection and test documents contain a description of the type of observation, reference to nonconformance reports, evidence relating to status of observation, date and inspector indentification.

Quality records shall include reviews, audits, reports, specifications, nonconformance reports, analyses, personnel and equipment qualification procedures.

The Project Quality Assurance Plan requires that HL&P and prime contractors establish requirements to ensure that records generated during the design, procurement, and construction are identifiable, retrievable and meet the requirements of 10CFR50 Appendix B and ANSI N45.2.9 as endorsed by Regulatory Guide 1.88.

As an alternative to the ANSI N45.2.9 Storage Requirements, records may be maintained for the South Texas Project in a two-hour rated fire resistant file room meeting NFPA No. 232 including the following provisions:

An automatic fire suppression system and an early warning fire detection system is utilized.

Records are stored in fully enclosed metal cabinets Smoking and eating / drinking are prohibited within the records storage facility Work not directly associated with record storage or retrieval is prohibited within the records storage facility Ventilation, temperature, and humidity control equipment is controlled where they penetrate fire barriers bounding the storage facility.

HL&P, BPC, and ESI QA perform audits and surveillances to assure 3 compliance.

18.0 Audits The HL&P Project Quality Assurance Plan establishes the. requirement that HL&P, prime contractors and subcontractors develop, document and implement audit activities which are structured in accordance with the requirements or ANSI N45.2.12 for the South Texas Project.

As required by the ANSI standard, results of audits are presented 29

for review to management of the audited organization and, in the case of HL6P performed audits the HL&P Executive Vice President, Nuclear Group. Where indicated HL&P performs followup action.

HL6P has the ultimate responsibility for the auditing of quality related activities on the project. HL&P corporate audits are performed primarily on the HL6P Project QA group, HL&P corporate organizations providing services to the project and Westinghouse.

HL&P Project QA is primarily responsible for audits of the Engineer / Construction Manager, constructor, subcontractors and the HL&P Project team organizations. Cases may arise in which audits may be required by either the Corporate or Project audit groups in the primary area of responsibility of the other group.

The prime contractors and subcontractors perform quality related audits of internal activities and suppliers 01 material, components and systems.

HL&P, BPC and ESl perform supplemental audits when required, based 3 on such factors as significant changes in the Quality Assurance Program, results of trending programs or investigations into the root causes of problems.

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30

TABLE I PLAN / PROCEDURES USED TO IltPLEMENT GUALITY ASSURANCE FOR Tile MAJOR ACTIVITIES 10CFR50 App. B 1.0 Project Quality Assurance Plan Criterion

1. Organization I

2. Quality Assurance Program II

3. Design Control III

4. Procurement Document Control IV

5. Instructions, Procedures, and Drawings V

6. Document Control VI

7. Control of Purchased Material, Equipment VII and Services

8. Identification and Control of Materials, VIII Parts, and Components

9. Control of Special Processes IX

10. Inspection X

11. Test Control XI

12. Control of lieasuring and Test Equipment XII

13. Ilandling, Storage and Shipping XIII

14. Inspection, Tes* and Operating Status XIV

15. Nonconforming Material, Parts, and Components XV

16. Corrective Action XVI

17. Records XVII

18. Auditing XVIII Table 1-1

TABLE 1 Plan / Procedures used to Implement Quality Assurance for the Major Activities 10CFR50 App. B 2.0 Project Specific Quality Assurance Procedures (PSQP) Criterion PSQP-Al Organization & Responsibility of Project QA/QC Personnel I, II A2 Generation and Control of Project Specific V, VI Quality Assurance Procedures A3 Deleted N/A A4 Control of Site Documentation VI A5 Non-Nuclear Site Quality Assurance N/A A6 Document Reviews V, VI A7 Stop Work XV, XVI A8 Trend Analysis Administration XVI A9 Implementation Review (To Be Deleted) II, IV thru XVII A10 Quality Control Administration IX, X All Certification of Quality Control Personnel II, IX, X A12 Indoctrination and Training II A13 Corrective Action XVI A14 Construction QA - Operations QA Interface II, XI, XVII (Future Procedure)

A15 Handling of NRC Inspection Reports & Immediate XV, XVI Action Letters A16 Qualification and Certification of Nondestructive II, IX, X Examination Personnel A17 Deleted N/A 3 A18 Preparation of Project QA/QC Instructions V, VI A19 Quality Assurance Activity Log X A20 Audits XVIII A21 Surveillances XVIII A22 Training and Certification of Project Audit Personnel II, XVIII 3 Table 1-2

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

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TABLE 1 Plan / Procedures used to Implement Quality Assurance for the Major Activities 10CFR50 App. B 3.0 HL6P Support Division Quality Assurance Procedures Criterion SDQAP-1.1 OA Department Organization I, II 2.1 Indoctrination, Training, Certification of HL&P OA II Support Division Personnel 2.2 Training, Qualification and Certification of X Surveillance Personnel 2.3 Training, Qualification, and Certification of II, XVIII Audit Personnel (Formerly OAP-5A Rev. 7) 2.4 Training, Qualification and Certification of NDE IX Surveillance Personnel 3.1 Document Review III 4.1 Procurement of Items and Services VII 7.1 Surveys of Vendors VII 7.2 Evaluation, Control and Issuance of QA Approved VII Vendors List 7.3 Quality Assurance Procedure llL&P Vendor Surveillance VII (Fornerly 0AP-3A) 7.4 Quality Assurance Procedure Use of Approved VII Surveillance Agencies 7.7 Review of Nuclear Steam Supply Systen (NSSS) VII Quality Assurance Records Packages (Formerly OAP-ll Rev. 1) 7.8 Review of Vendor 0A Manuals VII 15.2 Stop Work Procedure XV 16.1 Audit Deficiency Tracking List XVI 16.2 Action Item Tracking System XVI 16.3 Trend Analysis XVI 17.1 Audit Filing (Formerly QAP-5C Rev. 7) XVII 18.1 Auditing QA Programs (Formerly 0AP-5B Rev. 7) XVIII 18.2 Joint Auditing of OA Programs XVIII Table 1-3

TABLE 1 Plan / Procedures used to Implement Quality Assu11nce for the Major Activities 4.0 !!L&P, South Texas Project 10CFR50 App. B Project Engineerine Procedures Criterion PEP- I Introduction II !!anual Provisions III Scope IV Definitions 01 Preparation and Control of Project Engineering VI Procedures 02 Docunent Receipt & Handling N/A 03 Engineering Approval Authority III 04 Reference Docunent Library N/A 05 Performance of Owner's Reviews III 06 Design Change Request N/A 07 Administration for approval of basic design documents III, VI and vendor originated supplier deviation requests (SDRS) 08 Engineering Action Item Tracking N/A 09 Transmittal of Review Comments to External N/A Organizations 10 Project Engineering Organization & Responsibilities I 11 Reporting Design and Construction Deficiencies XV, XVI to NRC 12 Deleted N/A 13 Deleted N/A 14 Designation & Handling of Confidential Security N/A Documents 15 Preparation of Purchase Authorizations N/A 16 Procurement of Engineered Items IV, VII 17 NSSS Proposal Authorization N/A Table 1-4

TABLE I Plan / Procedures used to Implement Quality Assurance for the Maior Activities 4.0 IIL&P, South Texas Project. 10CFR50 App. B Project Engineering Procedures Criterion

!8 Preparation and Control of Specifications III, IV 19 Processing Supplier Deviation Requests III, IV 20 Document Change Notice control (IP) VI, III 21 Design Verification (IP) III 22 Personnel Training II 23 Numbering and Identification of Systems and VI Structures (IP) 24 Design Interface Control (IP) III 25 Preparation of System Design Descriptions (IP) III 26 Preparation of Technical Reference Documents (IP) III 27 Preparation of Diagrams (IP) III 28 Preparation of Drawings (IP) III 29 Preparation of Calculations (IP) III 30 Preparation of Design Reports (IP) III 31 Preparation of 0 6 M Manuals (IP) III, XIV 32 Preparation of ASME Section III Documents (IP) III 33 Preparation of ASME Section VIII Documents (IP) III 34 ALARA Review (IP) II l 35 Issuance and Control of Design Documents (IP) III, VI l

Note: (IP) indicates procedure is in preparation or a proposed procedure and not yet issued for use.

t l

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l Table 1-4a i

TABLE 1 Plan / Procedures used to Implement Quality Assurance for the Major Activities 10CFR50 App. B 5.0 Project Site Administrative Procedures Criterion PSAP-01 Preparation and Control of Project Procedures V 02 Project Directives N/A 03 Telephone Minutes N/A 04 Project Correspondence N/A 05 Processing Project Mail N/A 06 Project Meetings N/A 07 Trip Requests N/A 08 Open Items List N/A 09 Critical Action Items List N/A 10 Monthly Manhour Reporting N/A 11 Processing / Distribution of NRC Correspondence VI 12 Document Review / Comment Process VI 14 Processing Current STP Correspondence / Documents by RMS XVII 15 Obtaining Overdue STP Correspondence N/A 1

6.0 Project Contract Administration Procedures PCAP-50 Authorization of out-of-estimate work N/A

! 51' Not Assigned N/A 1

52 Proposed Contract changes N/A 4

Table 1-5, 1-6

m ._ . _ . _ _ _ . . . - . _ - . _ _ . _ _ _ _ . . _ __ _ . - _ _ . . _ _ _ _ _ _ . . _ . _

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TABLE 1 Plan / Procedures used to Implement Quality Assurance for the Major Activities 10CFR50 App. B 7.0 Project Site Procedures Criterion PSP-01 Preparation and Control of Project Site Procedures  %

4 02 Project Site Organization I 03 Not Assigned

04 Not Assigned 05 Field Change Requests for Engineering Action III 5

06 Deficiency Reporting and Temporary Waiver Request XV 07 Construction Review of Documents VI

. 08 Control of Construction Documents VI, XVII J

3 09 Processing Site Correspondence N/A 4

10 Review and Approval of field procurement requisitions IV 11 Construction Interfacing for Testing & Turnover (IP) II, X

12 Not Assigned 13 Indoctrination & Training II l 14 Equipment Inventory & Maintenance VIII, XIII 20 Issuance of Photo Identification Badges N/A 21 Camera Control (Deleted) N/A 22 Visitor Clearance N/A 23 Vendor Access N/A 24 Vendor Control N/A i

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I Table 1-7 i

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TABLE 1 Plan / Procedures used to Implement Ouality Assurance for the Major Activities 10CFR50 App. B

8.0 Records Management Systens Procedures Criterion RMSP l-1 General Flow of Nuclear and Fossil Correspondence XVII

Within RMS 1-2 Records Management Responsibilities and Interfaces I l-3 Preparation and Periodic Review of RMS Procedures VI l-4 Records Management Personnel Training II 2-1 Records Center Micrographic Section Procedure XVII l 2 Document Logging VI 2-3 Log Maintenance VI 2-4 Docunent Distribution VI 2-5 Storage 6 Maintenance of Nuclear Records XVII i 2-6 Document Checkout XVII 2-7 Correspondence Serial Number Assignment VI 2-8 Correspondence Serial Number Corrections VI 2-9 File Number Assignment XVII 1

l 2-10 NSSS Data Packages Handling XVII Table 1-8

TABLE I Plan / Procedures used to Implement Quality Assurance for the Major Activities 10CFR50 App. B 8.0 Records Management Systems Procedures Criterion R!!SP 2-11 Processing of Current Correspondence / Documents N/A by Data Center 2-12 Preparation of Computer Input Forms for Master N/A Purchase Order Module 2-13 Processing Computer Input Forms By Operations N/A Personnel 2-14 Backfitting Project Records XVII 2-15 Charge Number and Project Code Usage N/A 2-16 To be issued at a later date N/A 2-17 Password Control N/A 2-18 Distribution of STP Spare Parts Correspondence VI Table 1-8a

TABLE I Plan / Procedures used to Implement Ouality Assurance for the Maior Activities 10CFR50 App. B 9.0 Project Licensing Procedures Criterion PLP-01 Preparation & Control of Project Licensing Procedures VI 02 Reporting Design & Construction Deficiencies to NRC (IP) XV, XVI 03 FSAR Change Notices II 04 NRC Inspection & Enforcement Bulletins (IEB), II Circulars (IEC), and Information Notice 's (IN) 05 Personnel Indoctrination training (IP) II 06 Control of NRC Correspondence N/A 08 Organization (IP) I 09 NRC Regulitory Guides, NUREGS, CFR Rule Makings (IP) N/A 10 NRC Inspection Reports (IP) N/A 11 Miscellaneous Industry Correspondence (IP) N/A 12 Verbal Communication N/A 13 control of Nuclear, Licensing Manual (IP) VI 14 Procurement of Items & Services (IP) VII NOTE: 1 (IP) indicates procedure is in preparation or a proposed procedure and has not yet been issued for use.

2 due to a reorganization, licensing is operating to several engineering procedures and will continue to do so until the licensing procedures are issued.

Table 1-9

TABLE 1 Plan / Procedures used to Implenent Ouality Assurance for the Major Activities 10CFR50 App. B 10.0 Project Procurement Procedures Criterion PPP-01 General Procurement VII 02 Establishing Bidders Lists VII r

03 Site Procurement VII 04 Inquiry Issuance VII 05 Proposal Evaluation and Supplier Selection VII 06 Purchase Order and Change Order Preparation, VII Approval and Issuance 08 Training II 09 Preparation and Control of Project V Procurement Procedures li Document Review IV 13 Processing Purchase Order and Change Order VII Acknowledgements i

a l

l l

l Table 1-10

TAPLE 2 ANSI STANDARD AND REGULATORY GUIDE COMPLIANCE The STP Ouality Assurance Program complies with the following ANSI Standards and associated Regulatory Guides except as noted:

STANDARD TITLE ANSI N.45.2-1971 Quality Assurance Progran Require-R.G.I.28 (Rev. 0,6/72) ments for Nuclear Facilities ANSI N.45.2.1-1973 Cleaning of Fluid Systems and Asso-R.G.I.37(Rev. 0,3/73) ciated Components During Construc-(see Notes 8 through 10) tion Phase of Nuclear Power Plants ANSI N.45.2.2-1972 Package, Shipping, Receiving, Storage R.C.I.38 (Rev. 0,3//3) and Handling of Items for Nuclear (see Notes 11 through 16) Power Plants ANSI N.45.2.3-1973 llousekeeping During the Construction R.C.I.39(Rev. 0,3/73) Phase of Nuclear Power Plants (see Notes 17 and 18)

ANSI N.45.2.4-1972 Installation, Inspection and Testing R.C.I.30(Rev. 0,8/72) Requirements for Instrumentation and (see Notes 19 and 20) Electric Equipnent During the Con-struction of Nuclear Power Generating Stations ANSI N.45.2.5-1974 Supplementary Ouality Assurance Re-(see Notes I and 2) quirmeats for Installation, Inspection and Testing of Structural Concrete and Structural Steel During tl.e Construction Phase of Nuclear Power Plants ANSI N.45.2.6-1973 Qualifications of Inspection, R.G. 1.58 (Rev.0,8/73) Examination and Testing Person-Plus Positions C.5, C.6, C.7, nel for the Construction Phase C.8 and C.10 of Rev. I of Nuclear Power Plants ANSI N.45.2.8 - 1975 Supplementary Ouality Assurance Reg. 1.116 (6/76) Requirements for Installation, (see Notes 21 through 23) Inspection and Testing of Mechanical Equipnent and Systems for the Construction Phase of Nuclear Power Plants Table 2-1 1

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

i TABLE 2 ANSI STANDARD AND REGULATORY GUIDE COMPLIANCE (Continued)

ANSI N.45.2.9-1974 Requirements for Collection, Storage R.G. 1.88 (Rev.2,10/76) and Maintenance of Quality Assurance (see Notes 24 through 26) Records for Nuclear Power Plants ANSI N.45.2.10-1973 Quality Assurance Terms and R.G. 1,74 (Rev. 0,2/74) Definitions ANSI N.45.2.ll-1974* Quality Assurance Reauirements for R.G. 1.64 (Rev. 2,6/76) the Design of Nuclear Power Plants

], (see Notes 3 through 7)

ANSI N.45.2.12 - 1977 Requirerents for Auditing of Quality l Rg. 1.144 (Rev.1,9/80) Assurance Programs for Nuclear Power Plants ANSI N.45.2.13 - 1976 Quality Assurance Requirenents for R.G. 1.123 (10/76) Control of Procurenent of Items and (see Notes 27 through 31) Services for Nuclear Power Plants ANSI N.45.2.23 - 1978 Oualification of Quality Assurance 4

R.G. 1.146 (Rev.0,8/80) Program Audit Personnel for Nuclear Power Plants Exception Notes

1. ANSI N.45.2.5-1974, Section 4.8, states " Pumped concrete must be sampled from the pump line discharge". In lieu of this statement, in process strength samples of pumped concrete are taken at the delivery point. Correlation tests of air content, slump, and temperature are performed to verify these plastic properties of the concrete at the placement point in accordance with the following frequency requirements :

A. A minimum of 2 correlation tests are performed for each pumped

! placenent exceeding 200 cu. yds.

B. Otherwise, a minimum of 2 correlation tests per week are performed uhen any individual pumped placement during a week requires delivery of more than one truckload of concrete.

C. During a week when a pumped placement exceeding 200 cu. yds. is made, the correlation tests performed on that placement will

, satisfy the weekly requirement for performing two correlation tests as specified in Item B above.

j Table 2-2 l

l TAELE 2 ANSI STANDARD AND RECULATORY CUIDE COMPLIANCE 1 (Continued)

When any of the specified linits and tolerances on loss of air content, slump, or temperature are exceeded at the placement point, correlation tests between the delivery point and placement point will be accomplished for each 100 cu. yds. of concrete placed as long as limits and tolerances are exceeded. If two consecutive tests are out of tolerance, corrective action will be implerented to adjust the limits for the concrete entering the pump intake so that no concrete from the subsequent trucks will enter the pump intake as long as the tolerances are exceeded.

" Correlation Tests", ' Delivery Point", and "Placenent Point" are as defined in ANSI N.45.2.5-1978, Section 1.4.

2. Sanples and frequency for cadweld testing is in accordance with ACI-359/ASME Section III, Division 2, issued for trial use and comment in 1973, including addenda 1 through 6, (see Sections 3.8.1.6.3 and 3.8.3.6.3 of the STP Final Safety Analysis Peport).

• The following interpretations (Notes 3 through 7) of ANSI M45.2.11-1974 and Regulatory Guide 1.64, Rev. 2-6/76, apply to HL&P, their contractors, and consultants working under HL&Ps Quality Progran.

3. Section 3.1, Design Input Requirenents, General. This section implies that all necessary design input (as listed in Section 3.2) should be available prior to the start of a design activity. In practice, certain design activities are initiated before the firm input requirenents are available. (For exanple, foundation. designs prepared based on prelininary infornation or equipment sizes and mounting, embedded conduit run based on preliminary estinates of circuit requirements, etc.) The design phase QA program will be structured to ensure that all necessary design input is available before completion of final design of the work affected by the input, and that final design input is available for use in verification of the final design.

4. Section 4.a. Design Process, General. Paragraph 3 inplies traceability back from final design to the source of design input.

In practice, a literal interpretation of this is not always possible.

For example, final design drawinns do not identify the related calculations. This paragraph will be interpreted to mean that it shall be possible to relate the criteria used and analyses perforced to the final design documents and that record files will permit location of analyses supporting specific design output documents.

Table 2-3

TABLE 2 ANSI STANDARD AND RECULATORY CIIII)E COMPLIANCE (Continued)

5. Section 4.2, Design Analyses. This section inplies a requirerent for retention of all calculations. In principle, it is cuisidered good practice for the responsible engineer or engineering organization to retain all final calculations, and this will be done for all nanual calculations covered by the program. Ilowever, for computer progrars only docunentation of the design input, assumptions made in the analyses, results obtained, and evidence of verification will be retained since permanent retention of all versions of all computer programs is not considered practical or necessary if suf ficient information is available for a competent individual to verify the results using the input and assumptions.

6. Section 10, Records. In process docunentation, relating to checking and coordination of drawings (for example, check and coordination prints) or copies of narked-up specifications used to solicit connents shall be retained until the drawing or specification is approved and issued for use outside of Engineering. Such in process documents will be available for review / audit until the docunent is approved, but may be discarded once the document has been approved.

In the first sentence of the second paragraph the phrase " final design docurents" shall mean those docurents which are the latest revision that has been issued for use.

7. Regulatory Position, Section C-2: If, in an exceptional circumstance, the originators' immediate supervisor is the only technically qualified individual available, the desien verification or checking will be conducted by the supervisor with the following provisions:

a. The other requirements of Regulatory Guide 1.64 will be cet.

b. The justification will be individually docurented and approved by the next level of supervision.

c. Quality Assurance audits will include rer.ew of the frecuency and effectiveness of the use of the inmediate supervisor to assure that this provision is used only in exceptional circumstances.

P. Section 2.1, Planning. The required planning is frequently performed on a generic basis for application to nany installations on one or more projects. This results in standard procedures or plans for installation and inspection and testing which reet the requirements of the standard. Individual plans for each iten or systen are not normally prepared unless the work operations are unique. Ilowever, standard procedures or plans will be reviewed for applicability in each case. Installation plans or procedures are Table 2-4

TAHLE 2 ANSI STANDARD AND RECULATORY CUIDE COMPLIANCF (Continued) also limited in scope to those actions or activities which are essential to maintain or achieve required quality. This is consistent vith Section II, Paragraphs 2 and 3 of ANSI N45.2-1971 which provides for examination, censurenent, or testing to assure quality or indirect control by ronitoring of processing nethods.

However, final cleaning or flushing activities will be perforced in accordance with procedures specific to the systen.

9. Section 4. Preinstallation Cleanliness. This section states, "Itens should not be delivered to the point of installation site sooner than necessary unless the installed location is considered a better storage area." As an alternate to this requirenent, items may be delivered to the installation site sooner than absolutely necessary when determined to be advantageous for other considerations, for exanple, reduced handling or caster access, thereby reducing susceptibility to handling danage. In all such cases, equipment stored in place will be protected in accordance with Section 5 of ANSI N45.2.1.

10. Section 3.1.2, HL&P interprets the lighting level of 100 footcandles to be guidance. It is HL6P's normal practice that the Ifghting IcVel for deternining "netal clean" of accessible surfaces of piping and components is deternined by the inspector. Typically he uses a

standard two-cell flashlight supplerented by other lighting as he deems necessary.

!!. Section 2.7, Classification of Itens. The four-level classification system may not be used explicitly. However, the specific requirements for each classification as specified in the standard will be applied to the items suggested in each classification and for similar iters.

Classification differing from Section 2.7 will be considered acceptable provided no degradation is assured; for exarple, electric motors designed for outside service ray be stored in level C area rather than a level B.

12. Section 6.2, Storage Areas. Pararraph 6.2.1 requires control and linited access to storage areas. In If eu of and to amplify this paragraph, the following will be applied:

" Access to storage areas for levels A, B, and C will be controlled by the individual (s) responsible for material storage." Level D itens will be stored in a site area which will have access control consistent with Zone IV of ANSI N45.2.3-1973. While the areas will be posted to linit access, other positive controls (other than that for the overall site area) or guards nay not he provided.

Table 2-5

TABLE 2 ANSI STANDAFD AND REGULATORY CUIDE COMPLIANCE (Continued)

13. Section 5.5, Correction of Nonconfornances. This section provides for " rework" and "use as is" dispositions for nonconforming items.

As an alternate, the " repair" disposition (as defined in ANSI N45.2.10-1973) will also be used.

14. Section 6.2.4, Storage of Food and Associated Items. Controlled areas, within storage areas, will be established for the storage of food, drink, and salt tablets. These areas will be controlled through normal supervision and inspection.

15. In Section 8, the control of docunentation and records shall he in accordance with Section 17 of this Progran Description.

16. Appendix, A 3.4.2, Inert Cas Blankets. There ray be cases involving large or conplex shapes for which an inert or dry air purge flow is provided rather than a static gas blanket in order to provide adequate protection due to difficulty of providing a leakproof barrier. In these cases a positive pressure purge flow cay be utilized as an alternative to the leakproof barrier.

17. Section 2.1, Planning. The required planning is frecuently performed on a peneric basis for application to many installations on one or more projects. This results in standard procedures or plans for installation and inspection and testing which neet the requirements of the standard. Individual plans for each iten or systen are not normally prepared unless the work operations are unique. However, standard procedures or plans will be reviewed for applicability in each case. Installation plans or procedures are also limited in scope to those actions or activities which are essential to maintain or achieve required quality.

18. Alternative equivalent zone designations and requirements ,nay be utilized to cover those situations not included in the subject standard; for example, situations in which shoe covers and/or coveralls are required but material accountability is not. In addition, zones night be combined into the next nore restrictive category in order to reduce total number of zones.

19. Section 1.2, Applicability. The standard is applied to the itens and systens identified in Paracraph 1.1.1 and to additional systers depending on the nature and scope of the work to he performed and the inportance of the iten or service involved.

Table 2-6

TABLE 2 ANSI STANDARD Af;D REGULATORY CUIDE COMPLIANCE (Continued)

20. Section 2.1, Planning. The required planning is frequently perforned on a generic basis for application to rany installations on one or nore projects. This results in standard procedures or plans for installation and inspection and testing which ecet the reouirerents of the standard. Individual plans for each item or system are not normally prepared unless the work operations are unique. However, standard procedures or plans will be reviewed for applicability in each case. Installation plans or procedures are also lirited in scupe to those actions or activities which are essential to raintain or achieve required quality.

21. Section 1.1, Scope. The term "important items" will be interpreted to apply to those activities or quality attributes of an iten or service that could affect a nuclear safety-related characteristic.

For exanple, if a barrier is required for leakage control, but serves no structural function, the leaktight characteristic would be considered "important", but appearance, dirensional requirenents, and structural features would not necessarily be considered inportant; or if a pump casing is required for coolant boundary integrity, but the pump does not have to operate to provide for nuclear safety, those attributes which affect its operation would not be considered important from the standpoint of nuclear safety.

Section 2.1, Planning. The required planning is frequently performed on a generic basis for application to many installations on one or more projects. This results in standard procedures or plans for installation and inspection and testine which neet the requirenents of the standard. Individual plans for each iten or system are not normally prepared unless the work operations are unique. However, standard procedures or plans will be reviewed for applicability in each case. Installation plans or procedures are also limited in scope to those actions or activities which are essential to maintain or achieve required quality.

22. Section 3.3, Process and Procedures. The terns " installation site,"

" installation area," and " site" used in this standard shall be interpreted as follows:

a) " Installation site" or " site" will be interpreted the same as

" construction site." When applied to docunents, these ray be at the central office or work area document control station.

b) Installation area - Inmediate proximity of location where work is to be performed.

Table 2-7

TABLE 2 ANSI STANDARD AND REGULATORY CUIDE COMPLIANCE (Continued)

23. Section 3.5(e), Site Conditions. This requirement will be applied only if subsequent correction of adjacent nonconfornances could danage the iten being installed.

Section 4.6, Care of Items. IIL&P retains the authority and is the

" Responsible Organization" for temporary usare of equipment or facilities unless specific (i.e. on a casa by case basis) or general authority is granted in writing to the Construction Manarer's organization.

24. Section 1.4, Definitions. Quality Assurance Pecords - A docurent is considered completed when it has finished full processing and has been issued for use in design, procurenent, const ruction, or nanufacturing.

25. Section 1.4. Definitions. Authentiented Hecords - Those records which are clearly identified as a statement by the individual or organization holdiny responsibility. Ilandwritten sicnatures are not required if the docunent or printout is clearly identified as a statenent by the reporting individual or organization.

26. For Appendix A, an installation shall be considered to be in an "as constructed" condition if it is installed within the tolerances established by Project Enrincering indicated in the design output documents.

27. Section C.3 of the Herulatory Guide - A corrective action system nay, depending upon complexity and/or importance to safety of the iten or service provided, be inposed upon the supplier. When a corrective action systen is imposed on a supplier, the applicable elenents of Section 9.0 of the standard will be included and its frplementation will be verified.

28. Sect,f on C.4 of the Perulatory Guide - Applicable inforration concerning the method (s) of acceptance of an item or service will be made available to receiving inspection personnel.

29. Section 4.2.a of the Standard - When evaluation of a supnlier is based solely on historical supplier data, these data will prirarily include !!L6P's or a prime contractor's records that have been

accumulated in connection with previous procurerent actions. Data l that includes experience of users of identical or sinilar products of the prospective supplier and product operatine experience will be used if they become available; however, such data are norrally available only to those involved in plant operations.

1 l

Table 2-8

l TABLE 2 ANSI STANDARD AND RErULATORY GUIDE COMPLIANCE (Continued)

30. Se.ction 10.2.d of the Standard - The requirements of this section are interpreted as follows: The person attesting to a certificate shall be an authorized and responsible employee of the supplier and shall be identified by the supplier.

31. HL&P's position relative to ANS1 N45.2.13-1976, Section 10.2.f, verification of the Validity of Supplier Certificates and the Effectiveness of the Certification System, is as follows: The verification of the validity of supplier certificates and the effectiveness of the certification system are accomplished as an integral part of the total supplier control and product acceptance program, and no separate HL&P system exists that addresses itself solely to such verification. The degree of verification required will depend upon the typa of item or service and their safety importance. The means of verification may include source witness / hold points, source audits, and document reviews; independent inspections at the time of material receipt; user tests on selected commodities, such as concrete components; and tests after installation on selected components and systems. All of these means verify whether or not a supplier has fulfilled procurement document requirements and whether or not a certification system is effective.

Table 2-9

I EXECUTIVE VICE-PRESIDENT,

. NUCLEAR GROUP ICE- MESIDEE PROJECT MANAGER S QUALITY ASSURANCE C U 10 MANAGER PROJECT QUALITY SYSTEMS / OPERATIONS SOUTil TEXAS QA GENERAL ADMINISTRATION PROJECT SUPERVISOR SUPERVISOR QA MANAGER SUPERVISING QUALITY CONTR01. DESIGN OFFICE / Il0USTON 3 ENGINEER, _ PROCUREMENT LICENSING SUPERVISOR QA SUPERVISOR QA MANAGER MANAGER PROJECT MANAGER, ENGINEERING SITE MANAGER SUPPORT SERVICES I

Figure 1 1

llL6P k"~""N4Nh y

BPC/ WESTING 110USE (CONTRACTORS )

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EXECUTIVE .

g BPC/ WESTING 110USE VICE-PRESIDENT, (CONTRACTORS)

NUCLEAR GROUP \ MANAGEMENT JL \

jg

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R NG O^ ^

NUC 'E NG (- \

AND CONSTRUCTION MANAGER -

MANAGEMENT MANAGEMENT JL A \

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. IILGP and BPC/ NESTING 110USE (CONTRACTORS)

FIGURE 2

o* ,

'l PART B J

BECHTEL POWER CORPORATION QUALITY ASSURANCE PROGRAM DESCRIPTION e.

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION QUALITY ASSURANCE DURING DESIGN AND CONSTRUCTION

-l l REVISION 3 i

MARCII 9, 1982

\

Rev. 3

u. -

BECHTEL QUALITY ASSURANCE PROGRAM DESCRIPTION

-FOR THE SOUTH TEXAS PROJECT INTRODUCTION The Bechtel Quality Assurance Program Description used by the Bechtel Power Corporation for the South Texas Project is described in the NRC approved Bechtel Topical Report BQ-TOP-1, Rev. 3A, Bechtel Quality Assurance Program for Nuclear Power Plants and the modifications and additions described below.

SCOPE OF SERVICES Bechtel Power Corporation is responsible for Engineering, Procurement and Construction Management activities at the South Texas Project. This activity includes receiving, storage, maintenance, receiving inspection and Quality 3 Assurance functions. Bechtel Construction Management is responsible for management of the construction and quality assurance / quality control activities of the contractor (s). Construction Management consists of planning, scheduling, monitoring and evaluating the contractors construction and quality assurance / quality control activities.

The construction, field engineering, and quality control activities defined in the topical will be the responsibility of the contractor (s). The contractor (s) will be responsible for submitting to Bechtel, for approval, a quality program which is consistent and compatible with the applicable sections of Bechtel's Topical Report.

The following is a description of the South Texas Project modifications to meet the scope of the project and client requirements.

1.5.4 Division Construction Managers of Division Construction provide technical and administrative direction to the Construction Department personnel. Managers of Divi-sion Construction are assisted by Construction Managers and Chief Con-struction Engineers, where assigned. Construction Managers are respon-sible for the management and technical direction of assigned projects, and for assuring that construction projects are provided with appropriate personnel and are following prescribed division practices and procedures for conduct of construction activities.

1.6.1 Project Quality Assurance .

The project quality assurance program is directed by the Project Quality Assurance Manager who is responsible to assure that quality assurance actions listed below are accomplished in accordance with the requirements of the project

1) Coordinate the functions of the project quality program.

, l l

2) Coordinate project quality-related activities of Engineering, Pro-curement, and Construction.

3) Audit and surveillance of project quality-related functions and aoherence to procedures. Advise management of the status of program implemantation.

Conduct prescheduled project audits and supplemental audits directed by the Project Quality Assurance Manager.

4) Review supplier and subcontractor quiity assurance program requirements in procurement documents, conditional releases of nonconforming items at the construction site, and completed quality verification records packages prior to turnover to the client,

5) Concur with evaluation of recommended supplier's quality assurance program in accordance with subsection 7.1.

6) Take stopwork action when warranted.

7) Identify quality problems, initiate documented action leading to a solution, and verify implementation of solutions.

8) Review project plans and schedules for quality-related activities to assure timely and effective implementation of the quality assurance functions for the project.

9) Serve as the focal point for project communication on matters relating to the project quality assurance program.

10) Provide periodic reports to the Division Quality Assurance Manager and Project Manager evaluating the status of the project quality assurance program and advising of any problems requiring special attention.

11) Coordinate quality assurance functions within the project and with groups outside the division, such as M&QS and Procurement Supplier Quality.

12) Assure that quality assurance-related procedures and manuals prepared

by or used for the project meet project quality program requirements and initiate revisions when necessary.

4

13) Review, prior to use, Procurement Quality Surveillance Inspection plans and Quality Control instructions for clarity and the existence of the information described in Sections 7 and 10. In addition, evaluate the adequacy of selected plans and instructions by performing an in-depth review of:

a. Accuracy of translation of drawing and specification requirements.

b. Basis for determining inspection level and sequence.

c. Adequacy of inspection method.

This review provides assurance that the total quality program require-ments inclusions are complete. Reviews of generic plans and instruc-tions can be performed on a generic basis. In that case, the PQAM only verifies that the review of the generic plan or instructions has been performed.

u, .

14) Review and approve constructor and contractor quality programs. 3

15) Prepare quality assurance descriptions in Safety Analysis Reports.

16) Review Nonconformance Reports and other quality problem related documents to determine trends, identify significant deficiencies, and recommend appropriate corrective action.

The field quality assurance program includes the capability to perform:

Receiving inspection of pennanent plant material and equipment.

Maintenance and storage inspection of permanent plant equipment and 3 material in Bechtel's custody.

Review of receiving and Bechtel QC documentation.

Surveillance inspection of work performed by contractors. This inspec-tion supplements the quality programs of the contractors who have re-sponsibility for their work and quality verification.

Surveillance inspection includes either selected physical inspection at pre-scribed hold points and observation or witness of inspections performed by the contractor. /

Reviewing quality control documentation.

Reviewing Bechtel and/or contractor quality documentation.

Providing technical direction to testing laboratories and inspection subcontractors.

Reviewing supplier quality verification document packages for complete-ness and traceability to the item (s).

Identifying quality problems, initiating action' leading to solutions, and verifying implementation of solutions.

Reviewing contractors / subcontractors quality verification documents.

Reinspection of contractor completed work may be imposed as deemed necessary.

1.6.3 Project Construction Management A Field Construction Manager is assigned to each nuclear plant project involving construction or construction management assignment, and he is responsible for the project field construction perfonnance. The Field Construction Manager is responsible for assuring that construction acti-vities are performed in accordance with the design requirements as esta-blished by project engineering and other applicable requirements.

The project construction management organization is shown in Figure 11. 3

a, The contractors are assigned first-level responsibility for the control of the quality of their work. Their perfonnance is coordinated and 1

monitored by the Bechtel field organization. The Bechtel Quality Assurance organization performs documented audits and surveillances and has the capability to perform surveillance inspection.

In cases where the contractors are responsible for quality verification inspection or other quality assurance functions, the contract documents incorporate the requirements for the contractors quality assurance pro-gram. Contractors' quality assurance and quality control personnel are required to have the appropriate authority, organizational freedom, and independence within their own organization. Contractors' program require-ments are specified by incorporation of the requirements of Reg. Guide 1.28 (6/7/72) or the ASME Boiler and Pressure Vessel Code,Section III, as appropriate. In the event that the contractor is unable to provide an acceptable program, Bechtel may assume quality verification inspection responsibilities or these may be contracted to another organization.

J 4

SOUTH TEXAS PROJECT CONSTRUCTION MANAGEMENT ORGANIZATION MANAGER OF C0hsTRUCT10N PRO JE CT QU Atit .

ASSURAN CE D E PUTY M AN AGE R MANAGER OF CONSTRUCTION I I I I I I PROJECT FIELO COST AND PROJE CT PROJE CT $UPE Rv150R $1TE ' '

PROJECT SERVICES CONST RUCit0M CONTRACT GUAllTT A

$UPE R VISO R E N GIN E E R SCHE DULING ASSURANCE MANAGER AD MINIST R AT O R A$$URANCE

$UPE RVISO R I

AUDITS QU ALIT Y $URVElLLANCE FIE L O 38'IIY A$sURANCE -

- PROCUREMENT SUPERVISOR pggy

$UPE R VISO R T R AINING

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$UPE R VISO R CONSTRt1CT10N CONSTRutit0M $U ERV SOR g ggE MANAGER

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AR E A!P Ult 0iNG AR E A/8 UILDING ARE A/JUIL0 LNG FED C0 R CT $ HEDU G SUPE RVISO R SUPT R VISO R SUPE R VISO R ENGINEER ADMINIST R AT O R $UFT RVISOR i i I I I I CONT R ACT COST ENGINEER $

, ADMINIST R ATOR$ SCHEDULER $

ME C H ANICA L /N UC L E A R PIPING

= = = tlNE3 0F COORDIN ATION E LE CT RICAL n g y,3 INST RUUE NT ATIO N I

FIGURE 11 PAGE 5

! The following is a modification to Appendix "A" of the topical which describes Bechtel's position on Regalatory Guide and ANSI standards:

Reg. Guide 1.58 Rev. O, 8/73 Dlus pasitions C.5, C.6, C.7, C.8 ANSI N45.2.6, 1973 and C.10 of Rev. 1 Reg. Guide 1.144 Rev. 1, 9/80 ANSI N45.2.12, 1977 Full Compliance - No Exceptions Reg. Guide 1.146 Rev. O, 8/80

ANSI N45.2.23, 1978

[.

Full Compliance - No Exceptions i

4 F

1 5

i I

t

, _ . _ . _ . ~ _ , _ . . _ _ _ _ _ _ _

Attachment A is a modified Table 1 to the topical which describes Bechtel's Quality Program Documents.

Attachment A ,

t Page 1 of 2 ,

TABLE I ,

BECHTEL QUALITY PROGRAM DOCUMENTS Originating Review for QA Policy Autnorizing Document Authority and Program Requirements ApprJval Contents Los Angeles Power . Division QA N/A Division Manager Division policy supple-Division QA Manual Manager menting and implementing TP0 Quality Policy

• Bechtel Quality Manager-C&S/R&E QA-BPC** President and Policies and procedures Assurance Manual- Division QA Manager appropriate for overall Bechtel ASME Nuclear Authorized Code program applicable to

~ Components (BQAM- Inspection Agency ASME work ASME III)

• Procurement Supplier Manager Pro- QA-BPC** Manager Procure- Procurement Supplier Quality Manual curement ment Supplier Quality procedures Supplier Quality Quality Division QA Division QA N/A Division QA Procedures for conducting Procedures Manager Manager Division QA activities a

• Available on request to appropriate regulatory agencies.

4

• • Includes review by Division QA Managers.

Note: Revisions to these documents require the same review and approval as the original.

BQ-TOP-1 Rev. 3A

Page 2 of 2 I 4

TABLE I (CONTINUED) '.

BECHTEL QUALITY PROGRAM DOCUMENTS Originating Review for QA Policy Authorizing Document Authority and Program Requirements Approval Contents 1

Engineering Designated Division QA Manager *** Manager of Definition :.f responsi-Department Procedures Individuals Engineering *** and procedures for design and Instructions design review, and docu-ment control in the engineering departments Construction Construction Division QA Manager Manager Division Responsibilities and Procedures (Quality Construction practice for construction Program related) site activities including.

standard work plans Procurement Manuals Procurement QA-BPC** Cognizant Procedures for home offic-(Quality Program Procurement and field procurement related) Managers necessary to follow TP0 Quality Policy M&QS Procedure and Manager M&QS QA-BPC** Manager M&QS Policies and procedures Policy Guides (Quality for perfonning M&QS Program related) functions Project Manuals Pro- Cognizant Project PQAM Cognizant Note 2

cedures (Quality Team Member Managers Program related)

• • Includes review by Division QA Managers.

• • • Area office EUP's are reviewed and approved by the area office Qd Manager and area office Manager of Engineering.

Notes: 1 Revisions to these documents require the same review and approval as the original.

2 There are provisions for. project unique modifications to the above documents to delineate specific project requirements but not depart from the program requirements of this report ' Review and approval authority for such modifications are defined within the governing proced..es.

BQ-TOP-1 Rev. 3A