ML20039C046

to QA Program

ML20039C046
Person / Time
Site:	Columbia, Washington Public Power Supply System, Satsop
Issue date:	12/18/1981
From:	Glasscock R WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:
Shared Package
ML20039C042	List: ML20039C041 ML20039C046
References
WPPSS-QA-004, WPPSS-QA-004-R06, WPPSS-QA-4, WPPSS-QA-4-R6, WPSS-QA-4, NUDOCS 8112280353
Download: ML20039C046 (1)

Text

e

{ .

, Revision 6 Effective February 1,1982 OPERATIONAL QUALITY ASSURANCE PROGRAM DESCRIPTION (WPPSS-QA-004)

APPROVED: [2-/I'k Director, Quality Assurance Date ORIGINAL ISSUE: May 10,1978 Washington Public Power Supply System Richland, Washington 99352 bR O O 97 we

_A

g- s, -

l WASHINGTON PUBLIC FOWER SUFFLY SYSTEL1 6

OPERATIONAL PAGE QUALITY ASSURANCE PROGRA31 DESCRIPTION iii LIST OF EFFECTIVE PAGES PAGE REVISION PAGE REVISION i 6 II .1 II .1 -4 G ii 5 II.1-5 5 iii 6 II.1-6 6 iv & v 5 11.1-7 5 1 1-24 6 II.1-8 6 2 2-3 6 II .1-9 & 11.1-10 5 3 3-3 5 11.1-11 6 4-1 & 4-2 5 11.1-12 5 5-1 5 II.1-13-II.1-20 6 6-1 & 6-2 5 II .1 -21 & . I I .1 -22 5 6-3 6 II.1-23 & II.1-24 6 7-1 5 11.1-25 5 7-2 & 7-3 6 II.1-26 6 8-1 & 8-2 5 11.1-27 5 9-1 5 11.1-28 & II.1-29 6 9-2 6 II.2-1 5 10-1 5 II.3-1 5 10-2 6 11-1 & 11-2 5 12-1 & 12-2 5 13-1 5 14-1 5 15-1 5 15-2 6 16-1 5 17-1 & 17-2 5 18-1 5 I-l & I-2 6 II-1 5 w M is R3

s ' WASilINGTON PUBLIC POWER SUPPLY SYSTEM ^"*

. OPERATIONAL PAGE QUALITY ASSURANCE PROGRA31 DESCRIITION 1-1 1 - ORGANIZATION 1.1 PURPOSE This section provides a description of the authorities and responsi-bilities assigned to Supply Systra organizational units and indivi-duals involved in establishing, tnplementing, verifying implementa-tion, and measuring the overall effectiveness of the administrative controls and quality assurance program during the initial testing (pre-operational and startup testing) and subsequent operations phases of Supply System nuclear power plants.

1.2 SUPPLY SYSTEM ORGANIZATION The Supply System organization responsible for establishing, imple-menting, verifying implementation, and measuring the overall effec-tiveness of the administrative controls and quality assurance program for its nuclear power plants is as depicted in Figures 1-1 through 1-7. Portions of these activities may be delegated to ex-ternal organizations qualified to the requirements of this Opera-tional QA Program, hereafter referred to as QA Program, however, the responsibility shall remain with the Supply System.

1.3 MANAGEMENT RESPONSIBILITIES 1.3.1 The Managing Director / Deputy Managing Director is responsible for the establishment of policies and for overall management of Supply System operations. The Managing Director has issued a " Management Statement" which commits the Supply System to design, construct, and operate its nuclear power plants without jeopardy to the health and safety of the public. The Managing Director is the ultimate Supply System authority on matters involving quality. The Managing WFt15 R3

q 9

• CASHINGTON FUBLIC POWER SUFFLY SYSTEM 6

OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 1-2 1.3.1 (Cont'd)

Director / Deputy Managing Director operates through the Director of Quality Assurance, the Director of Power Generation, and the Program Directors (Projects) to provide for all quality assurance and quality-related functions for all Supply System nuclear power pl ants . The Managing Director / Deputy Managing Director arranges through the Directors of Technology, Business Programs, and Safety &

Security for suoport services to all Supply System nuclear power plants in such areas as engineering, fuel management, purchasing, licensing, health physics, and records management.

1.3.2 The Director, Power Generation, reports to the Managing Director, and is responsible for:

a. Safe and efficient operation of Supply System nuclear power plants subsequent to comercial operation.

b. Establishment and monitoring of maintenance systems comon to all nucleai power plants.

c. Generic training of Power Generation staff.

d. Development of corporate programs and procedures for power gen-eration and providing the same to the Program Directors on each project to ensure uniform application.

To accomplish this role, the Director of Power Generation operates through the Plant Managers, the Generation Services Manager, and the Generation Training Manager.

1.3.2.1 The Plant Manaaer for each of the Supply System nuclear power plants reports to the respective project Program Directorate prior to comercial operations. Thereafter, the Plant Manager reports to the Director of Power Generation. Prior to commercial operation, the w>tts m3

, r -

l DASHIN3 TON PUBLIC FOWER SUFFLY SYSTEM 6

OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 1-3 1.3.2.1 (contd.)

Plant Manager has direct comunication access to the Director of Power Generation in order to facilitate coordinated development and uniform application of administrative controls and operational philosophies.

The Plant Manager is directly responsible for safe and efficient operation of the plant in accordance with the requirements of the Operating License, the Plant Technical Specifications, and the Plant Procedures Manual. Some of the specific responsibilities of the Plant Manager are:

a. Planning, coordinating, and directing all test, operation, maintenance, and refueling activities subsequent to the issu-ance of an Operating License.

b. Authorizing all plant modifications subsequent to the issuance of an Operating License.

c. Qualification and training of plant staff.

d. Approval and control of procurement documents for safety re-lated items and services.

e. Controlling purchased equipment and materials intended for plant use,

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

g. Dispositioning of nonconforming items,

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

W>ttS R3

f

• g OASHINGTON PUBLIC FOWER SUFFLY SYSTEM OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 1-4 1.3.2.1 (Cont'd)

i. Implementation of the in-service inspection program.

The Plant Manager operates through the Operations Manager, the Main-tenance Manager, the Technical Manager, the Health Physics / Chemistry Manager *, the Training Supervisor, and the Administrative Super-visor. The plant organization (see Figure 1-3) and functional responsibilities of key plant personnel are described in Chapter 13 of the Final Safety Analysis Report for the applicable nuclear power plant.

• The Health Physics / Chemistry Manager administrative 1y reports to the i Director of Safety & Security.

1 1.3.2.2 The Manager, Generation Training, reports to the Director of Power Generation and is responsible for operations training policy and I guidance for the nuclear plants and for the conduct of central

! training services for ruclear plant operations.

1.3.2.3 The Manager, Generation Services, reports to the Director of Power Generation and is responsible for providing support services to the Plant Managers in acquisition, storage, and reporting of operational and maintenance data; planning and scheduling plant outages for re-fueling and maintenance activities; preparation / coordination for review and approval / transmittal to the Nuclear Regulatory Commission of operating reports required by the applicable plant Technical Spe-cifications; maintenance of a common policy for test and startup for nuclear projects; managing support projects including Emerce.ncy Operating Facilities; and providing central maintenance and non-destructive examination services.

1.3.3 The Program Director, for each of the Supply System nuclear projects

. reports to the Managing Director and is responsible for plant W>lls R3

?

""V*

WASHINGTON PUBLIC POWER SUPPLY SYSTEM OPERATIONAL 6 PAGE QUALITY ASSURANCE PROGRAM DESCRIITION 1-5 1.3.3 (contd.)

activities prior to commercial operation. The Program Directorate is described in Chapter 13 of the Plant FSAR.

1.3.4 The Director, Quality Assurance, reports to the Managing Director and is responsible for establishing QA Program requirements, verifying implementation, and measuring the overall effectiveness of the administrative controls and the OA Program. The Director of Quality Assurance is also responsible for directing cerformance of QA/QC functions and for interfacing QA/QC-related activities with the Nuclear Regulatory Commission and the Authorized Inspection Agency. The Director of Quality Assurance or his designated alter-nate has the responsibility and authority to stop unsatisfactory work and control further processing, delivery or installation of nonconforming material during plant operation, maintenance, modifi-cation, and in-service inspection. The Director of Quality Assur-ance has communication channels with all senior management personnel responsible for the perfonnance of quality-related functions. To accomplish this role, the Director of Quality Assurance operates through the Manager of Operational Quality Assurance, the Manager of Procurement Quality Assurance, the Manager of Quality Performance &

Measurements, and the Manager of Plant Modifications Quality Assur-ance. The qualification requirements for the position of Director, Quality Assurance, are described in Appendix I, " Qualification Requirements".

1.3.4.1 The Manager, Operational Quality Assurance, reports to the Director of Quality Assurance and has direct management responsibility for QA/QC functions related to initial testing and subsequent operations phase activities. He has stop work authority to prevent noncon-formances and maintain quality. The Manager of Operational Quality Assurance operates through the Plant QA Managers (located on-site)

WP 115 R3

\ ""V*

WASHINGTON PUBLIC POWER SUFFLY SYSTEM 0

OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 1-6 1.3.4.1 (Cont'd) and staff engineers. The qualification requirements for this posi-tion are as described in Appendix I, " Qualification Requirements".

Some of the specific responsibilities of the Manager, Operational Quality Assurance, are:

a. Establishment of (i) the Operational QA Program Description (WPPSS-QA-004), and (ii) the Supply System Quality Assurance Manual for Operation.

b. Providing functional and administrative direction to the Plant QA Managers for the performance of their activities.

c. Providing supporting QA/QC staff, to the Plant QA Managers in order to assure adequate coverage of peak period activities (such as maintenance, modification, refueling, and in-service inspections).

d. Procurement control and inspection of nuclear fuel.

1.3.4.1.1 The Plant 0A Manaaer for each nuclear plant (located on-site) reports to the Manager of Operational Quality Assurance and is responsible for conducting plant 0A/QC activities in accordance with the Supply System QA Manual for Operation and 0A/QC procedures and/or instructions. He directs the activities of the plant QA Supervisor and the plant QC Supervisor and has the authority and responsibility to issue a stop work order when the activity being performed does not comply with the appli-cable provisions of the Supply System QA Manual for Operation and its implementing procedures. When the unit is operating, the Plant QA Manager may recommend to the Plant Manager that the unit be shutdown. The Plant Manager, however, has the s

Whits E3

' " "V" WASHINGTON PUBLIC POWER SUPPLY SYSTE11 OPERATIONAL 6 PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 1-7 1.3.4.1.1 (Cont'd) final responsibility for the overall evaluation of all aspects and implications of shutting down the operating unit. Qualifi-cation requirements for this position are described in Appendix I " Qualification Requirements". The Plant 0A Manager is speci-fically responsible for:

a. Review of and concurrence with documents affecting safety, including changes thereto, to assure that applicable QA requirements (e.g., the necessary inspection requirements, QC hold points, final documented verification of imple-mented procedures and checklists, methods, and acceptance criteria) have been identified and specified therein.

Examples of documents subject to review and concurrence by QA reviewers are (i) procedures and/or instructions which address: operations, maintenance, technical specifica-tions, in-service inspection and testing, modifichtions, calibration, testing, fuel handlina, and procurement; (ii) plant originated design changes and specifications; (iii) nonconformance and corrective action reports; and (iv) plant originated procurement documents.

b. Surveillance verification of in-plant activities to assure that they are being conducted in accordance with approved procedures and/or instructions. Included in the scope of this surveillance program are: (i) Control room opera-tions; pre-operational, startup, and operational tests; maintenance, modification, repair, and calibration; per-sonnel training; and refueling activities; (ii) activities associated with satisfying technical specifications and inservice inspection and tes!.ing; and (iii) activities associated with the implementation of security, emergency response, fire protection, and radiological protection programs.

Wkt15 R3

CASHINGTON FUBLIC FOWER SUFFLY SYSTEM ""-

OPERATIONAL PAGE QUALITY ASSURANCE PROGR.01 DESCRIPTION 1-8 1.3.4.1.1 (Cont'd)

c. Performance of required inspections, examinations, and measurements associated with maintenance, modification, repair, test, nuclear. fuel receipt, radioactive waste shipping, and refueling activities.

d. Participating in plant staff meetings which involve dis-cussions of daily and projected plant work loads and as-suring croper staffing (QA/QC) levels during peak period activities (such as maintenance, refueling, modifications, or In-Service Inspection).

1.3.4.2 The Manaaer. Procurement Quality Assurance, reports to the '11 rector of Quality Assurance and is primarily responsible for the implementation of surveillance / audit program of off-plant activities performed by the Supply System vendors and the Nuclear Steam Supply System (NSSS) suppliers. Some of the specific responsibilities of the Procurement QA Manager are:

a. Establishing, maintaining, and isstiing a listing of evaluated vendors who are utilized for procurement of safety-related items (other than comercial grade off-the-shelf items as defined in 10CR 21) and services.

b. Planning, coordinating, and performing surveillances and audits of off-plant activities of vendors.

c. Exercising _stop work authority over off-plant vendor's/

contractor's activities to prevent nonconformances and maintain quality.

d. Performing receiving inspection of items other than nuclear fuel.

WWt *S R3

b ' ""**

WASHINGTON PUBLIC POWER SUFFLY SYSTD1 OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 1-9 1.3.4.3 The Manaaer, Quality Performance & Measurements, reports to the Director of Quality Assurance and is primarily responsible for verifying implementation of administrative controls and the quality assurance orogram through the establishment and conduct of an audit program over activities performed by Supply System organizations and to assess the overall effectiveness of the quality assurance program implementation. Some of the specific responsibilities of the Manager of Quality Performance & Maasurements are:

a. Certification of Supply System personnel who are required to be qualified / certified in accordance with SNT-TC-1A and its Supplements.

b. Qualification / certification of audit personnel.

c. Audits of activities performed by Supply System organizations (both on-site and off-site); ident?fying quality assurance pro-gram nonconformances, and if appropriate, recommending solu-tions; evaluating corrective actions; and verifying correction of identified nonconformar. css.

d. Maintenance and control of (i) QA procedures and/or instruc-tions for home-office activities, (ii) the Operational QA Pro-l gram Description (WPPSS-0A-004), and (iii) the Supply System OA Manual for Operation.

i l

l

e. Exercising Stop Work authority as necessary to prevent noncon-formances and maintain quality.

, f. Verifying implementation of administrative cor.trols and the l

l quality assurance program by establishing and conducting a surveillance program over activities of off-site Supply System organizations.

Whits R3

WASHINGTON PUBLIC POWER SUPPLY SYSTDI 0

OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 1-10 1.3.4.3 (Cont'd) 9 Reviewing and concurring with administrative directives and procedures of site Supply System organizations,

h. Periodically analyzing nonconformance reports, surveillance reports, aud;t reports, and I&E reports to identify any quality trends and reporting significant results to aopropriate manage-ment for review and assessment.

1.3.4.4 The Manager, Plant Modifications Quality Assurance, reports to the Director of Quality Assurance and has direct management responsibil-ity for QA/QC functions related to plant modification activities that are comparable to activities occurring during the construction phase. The Manager of Plant Modifications Quality Assurance has the stop work authority to prevent nonconformances and maintain quality.

1.3.5 The Director, Technolooy, reports to the Managing Director and is responsible for providing engineering and design control, reactor safety evaluation, nuclear and environmental analysis, plant simu-lator support, nuclear fuel supply, and maintenance / surveillance engineering support as required for each Supply System nuclear plant. The Director of Technology is specifically responsible for:

a. Corporate design contral establishment and maintenance.

b. Design and engineering for plant system design changes and modifications.

c. Planning and over-viewing the implementation of the plant pre-service and inservice inspection.

d. Technical resolution of nuclear safety, licensing, environ-mental, geological, and radiological issues.

Wkt1S R3

t WASHINGTON PUBLIC POWER SUPPLY SYSTD1 6

OPERATIONAL P4GE QUALITY ASSURANCE PROGRA>f DESCRIPTION 1-11 1.3.5 (contd.)

e. Initial fuel supply.

f. Reload fuel supply, design, and licensing,

g. Maintaining a current engineering data base for each plant.

To accomplish this role, the Director Technology, operates through Assistant Directors, Technology-Systems Engineering, Generation Engineering, Nuclear Engineering Services, and Fuels & Environment.

1.3.5.1 The Assistant Director Technology - Systems Engineering, reports to-the Director of Technology and is responsible for:

a. Design and engineering for plant changes and modifications,

b. System engineering support for plant turnover.

c. The control of the plant design data and drafting.

d. Control of Q-list changes,

e. Design procedures and standards required for plant configura-tion control.

1.3.5.2 The Assistant Director Technology - Generation Engineering, reports to the Director of Technology and is responsible for:

a. Environmental and seismic qualification of plant equipment.

b. Preparation, maintenance, and distribution control of pre-service and inservice inspection programs, technical overview of program implementation, and preparation of data repo-ts, w>tts R3

'o WASHINGTON PUBLIC POWER SUPPLY SYSTE!

OPERATIONAL 6 PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 1-12 1.3.5.2 (Cont'd)

c. Materials and welding engineering.

d. Technical program management and licensing issue resolution.

e. ASME Coda interpretation.

f. Maintenance engineering support to the plant staff.

g. Construction engineering support for plant modifications.

h. Coordination and control of the plant design chtige process.

1.3.5.3 The Assistant Director Technoloay - Nuclear Engineering Services, reports to the Director of Technology and is resoonsible for:

a. Providing reliability and related analyses, including probabil-istic risk analysis.

b. Review of nuclear fuel designs.

c. Providing analytical support in areas such as fuel, reactor and plant performance, fuel isotopic concentrations and analysis of off-standard reactor operating conditions.

d. Providing engineering support in acquiring, operatfr.a and main-taining training sinulators,

e. Providing anla,sa; to demonstrate the response characteristics of training simulators and to certify the validity of the simu-lation.

WP 115 R3

""V*

t

'. WASHINGTON PUBLIC POWER SUPPLY SYSTEM 6

. OPERATIONAL PAGE QUALITY ASSURANCE PROGRA.M DESCRIPTION 1-13 1.3.5.3 (Cont'd)

f. Providing plant transient analyses to support operational decision making and to form a basis for reload licensing and technical specification changes.

g. Reviewing, upon request, Reportable Occurance Reports,

h. Reviewing and/or authorizing, upon request, portions of Safety Analysis Reports and Environmental Reports.

1.1.5.4 The Assistant Director Technology - Fuels & Environment, reports to the Director of Technology and is responsible for:

a. Assuring an adequate and timely supply of high-quality fuel for each plant through fuel cycle planning and surveillance, acquisition of fuel and fuel cycle services, technical control administration and coordination of reload licensing.

b. Providing for the effective and efficient utilization of fuel resources by preparing near and long-term planning of procure-ment and inventory strategies.

c. Environmental monitoring and assuring compliance with environ-mental regulations during design, construction and operation.

d. Review of proposed changes to the Environmental Technical Spe-cifications.

e. Providing support to the Plant Managers in the implementation of off-site Environmental Technical Specifications.

f. Performing off-site e.nvironmental, geological and radiological monitoring studies.

Wells R3

" "V *

• WASIIINGTON PUBLIC POWER SUFFLY SYSTEs!

6 OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 1-14 1.3.6 The Director, Safety and Security, reports to the Managing Director and is responsible for development and implementation of policies and programs which support operation of Supply System plants in the areas of safety and security. Areas in which the Director of Safety and Security, provides support for the plant include radiological programs, health physics and chemistry, safeguards and physical security, industrial safety and fire protection, emergency prepared-ness, nuclear safety assurance, and licensing. The Deputy Director of Safety and Security serves as Chairman of the Corporate Nuclear Safety Review Board which functions to provide an independent review of plant activities in accordance with the Technical Specifications for the applicable nuclear power plant. To accomplish this role, the Director of Safety & Security operates through the Manager of Health & Safety Programs, the Manager of Nuclear Safety Assurance, the Manager of Licensing Programs, and the Manager of Security Programs.

1.3.6.1 The Manager, Health & Safety Programs, reports to the Director of Safety & Security and is responsible for the development and coor-dination of Supply System programs for industrial safety & hygiene, health physics, fire protection, medical, and emergency preparedness.

The Manager of Health & Safety Programs is specifically responsible for providing:

a. Assistance to appropriate management in the implementation of their responsibilities for an effective program of personnel safety and loss prevention.

b. Technical assistance and support services in the areas of health physics, radio-chemistry, and emergency preparedness.

c. Dose assessment, dosimetry and bio-assay function.

WP=t ts R3

WASHINGTON PUBLIC PODER SUPPLY SYSTEM OPERATIONAL 6 PAG E QUALITY ASSURANCE PROGRAM DESCRIPTION 1-15 1.3.6.1 (Cont'd)

d. Maintaining a radiation exposure program which meets the intent of as low as reasonably achievable (ALARA).

e. On-site meteorological services.

f. Development and maintenance of emergency preparedness plans and providing related training.

1.3.6.2 The Manacer, Nuclear Safety Assurance, reports to the Director of Safety & Security and is responsible for conducting independent evaluations of the adequacy of plant safety programs. An on-site Safety Engineering Group (SEG) for each nuclear plant reports to the Manager of Nuclear Safety Assurance and is responsible for:

a. Evaluatt on of plant operations from a safety perspective.

b. Evaluation for technical adequacy and clarity of all procedures important to the safe operation of the plant,

c. Assessment of plant performance regarding conformance to re-quirements related to safety.

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

e. Assessment of plant nuclear safety programs.

f. Any other matters involving the safety of the nuclear power plant that an independent review deems appropriate for con-sideration.

( we.ns m

WASHINGTON PUBLIC POWER SUPPLY SYSTDI ""**

6 OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 1-16 1.3.6.3 The Manager, licensina Prcorams, reports to the Director of Safety and Security, and is responsible for:

a. Providing coordinated corporate-le>'l management of licensing activities.

b. Providing a coordinated and controlled interface with the Nuclear Regulatory Commission (NRC) on issues pertaining to NRC Operating Licenses,

c. Developing and implementing consistent corporate licensing policies.

d. Assuring technical adequacy 7 # licensing submittals.

e. Review of plant activitics to assure compliance with the environmental licensing commitments.

1.3.6.4 The Manaaer, Security Programs, reports to the Director of Safety &

Security and is~ responsible for overall Supply System security ac-tivities. The Manager of Security Programs is specifically respon-sible for:

a. Administration of a security program which includes pre-employment screening, physical security surveys, and inves-tigations and loss prevention.

b. Management of security force during the operational phase by assuring that physical security is consistent with needs and is maintained within individual plant safeguards security plans,

c. Providing training, administrative, and technical assistance to Plant Managers in the area of plant security.

WP=11S R3

. WASHINGTON PUBLIC POWER SUPPLY SYSTEM 6

OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 1-17 1.3.7 The Director, Business Programs, reports to the Managing Director, and is responsible for providing records management and procurement ,

services. To accomplish this role, the Director of Business f Programs operates through the Manager of Records Management, the Manager of Central Procurament, and the Manager of Central Materials Management.

1.3.7.1 The Manager, Records Manacement, reports to the Director of Business Programs and is responsible for the establishment, maintenance, and implementation of the following:

a. Records control system for obtaining, orocessing, filing, re-trieving, and dispositioning of both corporate and plant records.

b. Distribution control system for corporate procedures.

1.3.7.2 The Manager, Central Procurement, reports to the Director of Busi-ness Programs and is responsible for:

a. Procurement of items and services in response to approved pur-chase requisitions.

• l

b. Preparation, negotiation, administration, and maintenance of l procurement contracts.

l 1.3.7.3 The Manager, Central Materials Mar.agement, reports to the Director i of Business Programs and is responsible for providing the following support functions:

a. Procurement of operational spares.

b. Coding, cataloging, handling, storage, and shipping of procured l

items.

l l

l l w>us as

WASHINGTON PUBLIC FOUER SUFFLY SYSTEM 6

OPERATIONAL PAGE QUALITY ASSURANCE PROGRA>l DESCRIPTION 1-18 FIGURE 1-1 MANAGING DIRECTOR DEPUTY MANAGING DIRECTOR WNP 1,4 WNP.2 WN P-3 / 5 POWER GENERATION PROGRAM DIRECTOR PROGRAM DIRECTOR PROGRAM DIRECTOR DIRECTOR I

SAFETY & SECURITY QUAUTY ASSURANCE TECHNOLOGY DIRECTOR BUSINESS PROGRAMS DIRECTOR DIRECTOR DIRECTOR P IRW@

SUPPLY SYSTEM ORGANIZATION RELATIVE TO OPERATIONAL QA Whits R3

I i

t l WASHINGTON PUBLIC POWER SUPPLY SYSTEM l 6 I OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 1-19 FIGURE 1-2 POWER GENERATION DIRECTOR l

GENERATION GENERATION GERVICES TRAINING MANAGER MANAGER OFF SITE a uma a em e e a uma e m a amm a e e amm a men a um a amm s amus a sum s e asumasu asuseammasusamasasusesusamuuenumaammaum ON-SITE

• WNP 1/4

• WNP-2

• WNP-3/ 5 PLANT MANAGER PLANT MANAGER PLANT MANAGER

_J

• THE56 POSITIONS REPORT TO THE RESPECTIVE PROGRAM DIRECTORATE PRIOR TO COMMERCIAL OPERATION.

POWER GENERATION ORGANIZATION Wbl15 R3

WASHINGTON PUBLIC POWER SUPPLY SYSTEM OPERATIONAL 6 PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 1-20 l

l FIGURE 1-3 PLANT MANAGER ASSISTANT PLANT MANAGER MAINTENANCE OPERATICNS TECHNICAL

^ " " 8' '

MANAGER MANAGER MANAGER C M STRY MANAGER TRAINING ADMINISTRATIVE SUPERVISOR SUPERVISOR

• THIS POSITION REPORTS ADMINISTRATIVELY TO THE DIRECTOR OF SAFETY & SECURITY.

PLANT ORGANIZATION W W115 R3

• " "V

• WASHINGTON PUBLIC POWER SUPPLY SYSTEM 6

OPERATIONAL PAGE QUALITY ASSURANCE PROGRA31 DESCRIPTION j _g FIGURE 1-4 QUALITY ASSURANCE DIRECTOR QUAUTY PLANT PAOCUREMENT OPERATIONAL P

QUAUTY A ANCE QUALITY A ANCE

&M UREMENTS QU L SS 4CE MANAGER MANAGER OFF-SITE iemunie e esusasoma e e e euma e a e a e il amas e ams e e e e e e amus e e e e a e a muu a e e sus e e a sum a e e 4 ON SITE WNP-le 4 PLANT WNP 2 PLANT . WNP-3/5 PLANT QUALITY ASSURANCE QUAUTY ASSURANCE QUAUTY / SSURA*:CE MANAGER MANAGER MANAGER QUAUTY QUAUTY QUAUTY ASSURANCE - ASSURANCE - ASSURANCE SUPERVISOR SUPERVISCR SUPERVISOR

,, QUAUTY CONTROL _ QUAUTY CONTROL , QUAUTY CONTROL SUPERVISOR SUPERVISOR SUPERVISOR

.-+

QUALITY ASSURANCE ORGANIZATION Whits R3

WASHLNGTON PUBLIC POWER SUPPLY SYSTEM OPERATIONAL -

PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 1-22 FIGURE 1-5 TECHNOLOGY DIRECTOR SYSTEMS GENERATION NUCLEAR FUELS &

ENGINEERING ENGINEERING ENG'"E,E"' ENVIRONMENT ASST DIRECTORTECHNOLOGY ERV CES ASST. DR ECTOR TECHNOLOGY ~

QST. @ RECTOR TECHNOLOGY f

TECHNOLOGY ORGANIZATION l

i WktfS R3 m , _- . . _ _ _ . .- _ _ _ _ - ,,

WASHINGTON PUBLIC POWER SUPPLY SYSTEL1 ""**

OPERATIONAL 6 PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 1-23 FIGURE 1-6 SAFETY & SECURITY DIRECTOR HEALTH & SAFETY NUCLEAR SAFETY LICENSING SECURITY PROGRAMS ASSURANCE PROGRAMS PROGRAMS MANAGER MANAGER MANAGER MAi. AGER SAFETY & SECURITY ORGANIZATION W>t15 R3

6 WASHINGTON PUBLIC POWER SUPPLY SYSTEM OPERATIONAL 6

_PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 1-24 FIGURE 1-7 BUSINESS PROGRAMS DMECTOR RECORDi CENTRAL CENTRAL MANAGEP'ENi PROCUREMENT MATERIALS MANAGiR MANAGER MANAG,EMENT g GER BUSINESS PROGRAMS ORGANIZATION l

l l

WASIS R3

WASHINGTON FUBLIC FOWER SUFFLY SYSTEM OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 2-1 2 - OUALITY ASSURANCE PROGRAM 2.1 PURPOSE This section provides an overall description of the QA Program that will be applied to initial testing and subsequent operation and maintenance activities throughout the life of Supply System nuclear power plants.

2.2 GENERAL 2.2.1 The QA Program and its implementing procedures and/or instructions are or will be structured to comply with the Regulatory Porition of QA-related Regulatory Guides as identified and modified in Appendix II, " Position Statements". A matrix of implementing procedures /

instructions cross referenced against each criterion of Appendix B to 10CFR50 will be included in this section not later than ninety (90) days prior to initial fuel loading. l 2.2.2 A list of safety-related items that will be subject to the appli-cable contro!s of the OA Program is included in the Final Safety Analysis Report (FSAR) for the applicable Supply System nuclear power plant. Changes to this listing shall be controlled by the Assistant Director Technology-Systems Engineering and apprcved by the Plant Manager.

WPflS R3

WASHINGTON PUBLIC POWER SUPPLY SYSTDI OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION 2-2 2.2.3 Applicable provisions of the QA Program shall be implemented by the earliest of the following and shall remain in effect for the life of Supply System nuclear power olants:

a. Prior to inception of the activity,

b. At the time of temporary /oermanent transfer of system / component j custody to the Test-and Startup Organization.

c. Ninety (90) days prior to initial fuel loading.

2.2.4 Revisions to the QA Program will be made by the corporate Quality Assurance. The Nuclear Regulatory Commission will be notified of (a) progrannatic changes (except for those that are editorial in nature) for review prior to implementation of these changes, and (b) organizational changes of substantial nature within thirty (30) days after announcement.

2.2.5 Managers of Supply System organizations responsible for implementing the applicable provisions of the QA Program shall assure that acti-vities that affect safety-related functions of plant items are per-formed by personnel who have been indnctrinated and trained. The scope, objective, and method of implementing the indoctrination and training program shall be documented. Proficiency of personnel per-forming activities that affect safety-related functions of plant items shall be maintained by retraining, re-examination, and/or re-certifying, as applicable. Methods shall be provided for document-ing training.

WW11S R3

WASHINGTON PUBLIC POWER SUPPLY SYSTDI 6

OPERATIONAL PAGE QUALITY ASSURANCE PROGRA31 DESCRIPTION 2-3 2.2.6 The scope, implementation, and effectiveness of the QA Program is l routinely audited by the corporate Quality Assurance. Copies of audit reports are presented to Supply System management to provide for assessment of the effectiveness of the QA Program. Addition-ally, on an annual basis, the Supply System management arranges for an independent audit and evaluation of the adequacy of the scope, implementation, and effectiveness of the OA Program. This is ac-complished by knowledgeable personnel outside of corporate Quality Assurance to assure achievement of an objective program assessment.

Results of these independent audits are reported to the Manaaing Director / Deputy Managing Director.

W>t1S R3 I

WASHINGTON PUBLIC POWER SUPPLY SYSTEL1 OPERATIONAL QUALITY ASSURANCE PROGRA31 DESCRIPTION 6-3 6.2.3 (cont'd.)

d. Operational 0A Frogram Description

e. Final Safety Analysis Report

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

g. Reports of nonconformances

h. Supply System QA fianual for Operation.

WW115 R3

""V" CASHINGTON PUBLIC POWER SUFFLY SYSTD1 1 6

OPERATIONAL PAos QUALITY ASSURANCE PROGRA51 DESCRIPTION 7-2 7.2.3 (cont'd)

a. The ability of the vendor to comply with those elements of 10CFR50 Appendix B applicable to the type of material, equip-ment, or services being procured.

b. A review of previous record and performance of vendors who have provided similar articles of the type being procured.

c. A survey of the vendor facilities and 0A program to determine his capability to supply a product which meets design, manufacturing, and quality requirements.

7.2.4 Source verification (vendor surveillance, inspection and audit) shall be connensurate with the relative importance, complexity, and quantity of the items or service procured and the vendor's quality performance. In-process and final surveillance requirements of vendor products shall be determined in advance and performed to as- sure conformance with procurement document requirements. Source verification is not required where the quality of an item can be verified by review of test reports, inspection upon receipt, or other means.

7.2.5 Receiving inspection of vendor-furnished items shall be performed to assure that:

a. The item is properly identified and corresponds to the identi-l fication on the procurement document and receiving documentation.

l t

i WP 115 m3 i

L

" "V' WASHINGTON PUBLIC POWER SUPPLY SYSTE11 OPERATIONAL 6 PAGE QUALITY ASSURANCE PROGRA31 DESCRIPTION 7-3 7.2.5 (Cont'd)

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

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

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

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

7.2.7 The validity of vendor-furnished Certificates Of Conformance (or equivalent certifications) shall be evaluated by either audits /

surveillances of tha vendor or independent inspection or test of the items. Such evaluations shall be performed at intervals comen-surate with the vendor's past quality performance.

l l

WW115 R3

" "V-WASHINGTON PUBLIC POWER SUPPLY SYSTE11 OPERATIONAL QUALITY ASSURANCE PROGRAM DESCRIPTION '

9-2 t

9.2.4 Procedures, equipment, and personnel to be utilized for the per-formance of special processes shall be qualified / certified by au-thorized personnel from acolicable organizations (e.g. Quality Assurance, Generation Services, Generation Engineering, and Plant organizations, etc).

9.2.5 Qualification records of procedures, equioment, and personnel as-sociated with special processes shall be established, filed, and maintained.

l g f' Y

t l

)

o.,

f e

)

l wetts m3

~"**

WASHINGTON PUBLIC POWEB SUPPLY SYSTEM OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIFFION 10-2 10.2.3 Inspections shall be performed by individuals other than those who performed or directly supervised the activity being inspected. Inspections, in general, will be performed by or under the supervision of the Supply System QA organization. However, personnel from the performing groups (Operations, Maintenance, Technical,

. Test & Startup, etc.) may be utilized for performing certain inspections associated with normal plant opera-tion. When such is the case, the related work proce-dures shall require (a) demonstration of correct perfor-mance of the work through a functional test where the work involves breaching a pressure retaining boundary, and (b) review and concurrence by the Supply System QA organization of qualification criteria of inspection personne! ;rior to initiation of inspection activity.

10.2.4 Individuals performing inspections shall be qualified.

and the status of their qualifications shall be main-tained current.

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

10.2.6 Inspection results shall be documented, evaluated, and their status recorded.

l W W115 ft 3

WASHINGTON PUBLIC FOWER SUFFLY SYSTE11 OPERATIONAL PAGE QUAIJTY ASSURANCE PROGRA.41 DESCRIPTION 15-2 15.2.5 Acceptability of repaired, reworked and replaced item shall be veri-fied and documented by inspecting and/or testing the item in accor-dance with original inspection and/or test requiremerts or approved alternatives.

15.2.6 Where feasible, nonconforming items shall be segregated from other acceptable items and/or uniquely identified as nonconforming until properly dispositioned for use. -

15.2.7 Reports of nonconformances shall be periodically analyzed by the Supply System QA organization to identify quality trends.

Significant results, shall be referred to appropriate management for review and assessment.

W>t tS R3 .

""V-WASHINGTON FUBLIC FOWER SUFFLY SYSTEh!

6 OPERATIONAL QUALITY ASSURANCE PROGRAM DESCRIPTION I-1 APPENDIX _I_

OUALIFICATION REOUIREMENTS The minimum qualification requirements for key Quality Assurance personnel that will be met at the time of initial core loading or appointment to the active positions are as follows:

I.1 Ouality Assurance Director

a. Education: Bachelor Degree or equivalent

• in Engineering or related science.

b. Experience: Ten (10) years experience in the field of quality assurance, or equivalent number of years of nuclear inductry experience in a management position or a combination of the two. At least two (2) years of this ten (10) years experience shall include detailed involvement in the administration of and adherence to the quality assurance program in a significant management rold directly

~

involving nuclear power plants.

I.2 Ooerational Quality Assurance Manager

a. Education: Bachelor Degree or equivalent

• in Engineering or a j related science.

l b. Experience: Six (6) years experience in the field of quality assurance, or an equivalent number of years of nuclear plant experience in a supervisory position, preferably at an operating nuclear plant, or a combination of the two. At least two (2) years of this six (6) years experience shall be nuclear power plant experience in the implementation of the quality assurance program.

I.3 Plant Ouality Assurance Manager

a. Education: Bachelor Degree or equivalent

• in Engineering or wb115 43 i

L

~.

WASHINGTON PUBUC POWER SUFFLY SYSTEM ""*'

OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIITION I-2 I.3 Plant Quality Assurance t'anacer (cont) related science.

b. Experience: Four (4) years experience in the field of quality assurance, or an equivalent number of years of nuclear plant experience in a supervisory position, preferrably at an operating nuclear plant, or a combination of the two. At least one (1) year of this four (4) years expericace shall be in the implementa-tion of the quality assurance program,

c. Training: Shall have acquired familiarization and working knowledge of plant systems, facilities, plans, and programs necessary for the performance of assigned functions in a safe and competent manner.

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

1. High school diploma or GED.

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

3. Qualified as an !!RC senior operator at the assigned plant.

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

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

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

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

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

9. Professional Engineer License.

10. Associated degree in Engineering or a related science.

Wktt$ R3

DASHINGTON FUBLIC FOWER SUFFLY SYSTDI OPERATIONAL 6 PAG E QUALITY ASSURANCE PROGRA.\1 DESCRIPTION II. 1-1 APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" II.1.1 REGULATORY GUIDE 1.8, REV 1-R (Mav, 1977) " Personnel Selection and Training" Sucolv System Position The Supply System will implement the Regulatory Position of Regula-tory Guide 1.8, Rev. 1-R (May, 1977) and the requirements in the endorsed standard ANSI N18.1-1971.

Whits R3

CASHINGTON FUBLIC FOWER SUFFLY SYSTEM 6

OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION II.1-2 APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" 11.1.2 REGULATORY GUIDE 1.26, REV 3 (February,1976) " Quality Group l Classifications and Standards for Water , Steam , and Radioactive-Waste-Containing Components of Nuclear Power Plants" Sucoly System Position The Supply System will implement the Regulatory Position of Regula-tory Guide 1.26, Rev. 3 (February 1976).

e WPitS R3

WASHLNGTON FUBLIC FOWER SUFFLY SYSTEM OPERATIONAL 6 PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION II.1-3 APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" 11.1.3 REGULATORY GUIDE 1.29,~ REV 3 (September 1978) " Seismic Design Classification" Supply System Position The Supply System will implement .he Regulatory Position of Regula-tory Guide 1.29, Rev. 3 (September 1978),

welts m3

""V-WA3HINGTON PUBLIC POWER SUFFLY SYSTDI OPERATIONAL PAG E QUALITY ASSURANCE PROGRA.\1 DESCRIPTION II,y,4 APPENDIX II 11.1 " POSITION STATEMENTS FOR WNP-2" II.1.4 REGULATORY GUIDE 1.30, (Safety Guide 30, August 11, 1972) " Quality Assurance Requirements for the Installation, Inspection and Testing of Instrumentation and Electric Equipment" Supoly System Position The Supply System will implement the Regulatory Position of Regula-tory Guide 1.30, (Safety Guide 30, August 11,1972) and the require-ments in the endorsed standard ANSI N45.2.4-1972 (also designated as IEEE Std 336-1971), subject to the following:

1. Regulatory Position C.1 of Regulatory Guide 1.30 (Safety Guide 30, August 11,1972) states that ANSI N45.2.4-1972 should be used in conjunction with ANSI N45.2-1971, "Ouality Assurance Program Requirements for Nuclear Power Plants". It is the Sup-ply System position that ANSI N45.2-1971 is not applicable for operational chase activities of nuclear power plants. Instead the Supply System will comply with its Position Statement on Regulatory Guide 1.33.

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

wMts m3

.b

DASHINGTON FUBLIC FOWER SUFFLY SYSTEM OPERATIONAL PAGS l QUALITY ASSURANCE PROGRAM DESCRIPTION II.1-6 APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" 11.1.5 REGULATORY GUIDE 1.33, REV 2 (February 1978) " Quality Assurance Program Requirements (Operation)"

Sucoly System Position The Supply System will implement the Regulatory Position of Regula-tory Guide 1.33, Rev. 2 (February 1978) and the requirements in the endorsed standard ANSI N18.7-1976/ANS-3.2, subject to the following:

1. Regulatory Position C.2 of Regulatory Guide 1.33, Rev. 2 (February 1978) implies that the provisions contained in the latest revisions of the Regulatory Guides, listed therein, will be followed. The Supply System will follow its Position State-ments on apolicable Regulatory Guides as described throughout Section II.1 of this Appendix.

2. Section 5.2.13.4 of ANSI N18.7-1976/ANS-3.2: The third para-graph of this section is revised to read, "Special handling tools and equipment shall be inspected and/or tested, as neces-sary, in accordance with written procedures and at specified times to verify that the tools and equipment are adequately maintained."

3. Section 5.2.17 of ANSI N18.7-1976/ANS-3.2 states that inspec-tion of operating activities may be conducted by second-line supervisory personnel or by other qualified personnel not as-signed first-line supervisory responsibility or conduct of the work. The Supply System position is to allow the plant opera-tions' shift supervisors (first-line supervisors) to perform inspections of surveillance tests, orovided that,an after-the-f act review of surveillance documentation is performed by the we.ns na

WASHINGTON PUBLIC POWER SUFFLY SYSTEM OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION II.1-8 APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" II.1.6 REGULATORY GUIDE 1.37, (March 16, 1973) " Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants" Supoly System Position The Supply System will imolement the Regulatory Position of Regula-tory Guide 1.37, (March 16, 1973) and the requirements in the en-do sed standard ANSI N45.2.1-1973 subject to the following:

1. Regulatory Position C.4 of Regulatory Guirte 1.37 (March 16, 1973) states, in part, " Chemical compounds that could contribute to intergranular cracking or stress-corrosion cracking should not be used with austenitic stainless steel and nickel-base alloys". In clarification, the Supply System will abide by the chamical composition limits established by its Nuclear Steam Supply System vendor with regard to control of marking materials, paints, chalk, mineral and organic acids, chemical compounds, materials, solvents and chemicals used for cleaning, and plastic films.

2. Regulatory Position C.5 of Regulatory Guide 1.37 (March 16,1973')

states, in part, "Specifically, tools which contain materials that could contribute to intergranular cracking or which, because of previous usage, may have become contaminated with WW115 23

WASlHNGTON FUBLIC FOWER SUFFLY SYSTEM OPERATIONAL PAGE QUALITY ASSURANCE PROGRA31 DESCRIPTION g APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" II.1.7 REGULATORY GUIDE 1.38, Rev. 2 (May, 1977) " Quality Assurance Re-quirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Water-Cooled Nuclear Powe'r Plants" Sucoly System Position The Supply System will implement the Regulatory Position of Regulatory Guide 1.38, Rev. 2 (May, 1977) and the requirements in the endorsed standard ANSI N45.2.2-1972 subject to the following:

1. Section 3.2.1 (1) of ANSI N45.2.2-1972: Temperature and humi-dity control considerations for packaging of Level A items are not considered applicable to nuclear fuel assemblies unless recommended otherwise by the nuclear fuel manufacturer. The Supply System will abide by the manufacturer's recommendation.

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

3. Section 3.7.1 (1) of ANSI N45.2.2-1972: The Supply System may use cleated, sheathed boxes for loads up to 1,000 pounds rather than 500 pounds limit imposed here. This type of box has been tested by the WNP-2 Nuclear Steam Supply System vendor and I found safe for loads up to 1,000 pounds. Other national stand-ards allow the 1,000 pounds designation (see Federal Specifica-tion PPP-B-601).

I i

WP119 R3

WASHINGTON PUBLIC POWER SUFFLY SYSTEM 6

OPERATIONAL PAGE QUALITY ASSURANCE PROGRA3I DESCRIPTION II.1-13 APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" 11.1.8 REGULATORY GUIDE 1.39, Rev. 2 (September, 1977) " Housekeeping Re-quirements for Water-Cooled Nuclear Power Plants" Sucoly System Position The Supply System will implement the Regulatory Position of Regula-tory Guide 1.39, Rev 2 (September, 1977) and the requirements in the endorsed standard ANSI N45.2.3-1973 subject to the following:

Section 2.1 of ANSI N45.2.3-1973 requires the establishment of cleanness requirements for housekeeping activities on the basis of zone designations. The Supply System considers these zone designa-tion and the requirements associated with each zone as impractical for implenentation during the operations phase. Procedures or in-structions for housekeeping activities, which include the applicable requirements outlined in Section 2.1 of ANSI N45.2.3-1973 and which take into account the radiation control considerations, security considerations, and cleanness requirements, will be developed on I case by case basis for maintenance and modification work to be performed.

WP415 R3

WASHINGTON PUBLIC POWER SUPPLY SYSTEM l

OPERATIONAL 6 QUALITY ASSURANCE PROGRA31 DESCRIPTION II.1-14 APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" II.1.9 REGULATORY GUIDE 1.58, Rev. 1 (September, 1980) " Qualification of Nuclear Power Plant Inspection, Examination and Testing Personnel" Sucoly System Position The Supply System will implement the Regulatory Position of Regu-latory Guide 1.58, Rev 1 (September,1980) and the requirements in the endorsed standard ANSI N45.2.6-1978 subject to the following:

1. Regulatory Position C.5 of Regulatory Guide 1.58, Rev. 1 (September 1980) implies that individuals who review and ap-prove inspection, examination, and testing procedures and those who evaluate the adequacy of such procedures to accomplish the inspection, examination, and test objectives, should meet the Level III capability requirements delineated in Table 1 of ANSI /ASME N45.2.6-1978. Not all Supply System personnel per-forming the types of cited functions will meet the Level III capability requirements of Table 1 of ANSI /ASME N45.2.6-1978.

However, personnel performing the cited functions will be de-termined by Supply System management (through evaluation of their education, training, and experience), to be fully qualified and competent. The basis for the determination will be documented.

2. Section 1.2 of ANSI /ASME N45.2.6-1978, fourth paragraph, states that the requirements of this Standard apply to personnel of the owners and their suppliers. In clarification, the extent of application of the requirements of ANSI /ASME N45.2.6-1978 to Supply System suppliers will depend upon the nature and extent WPflS R3

WASHINGTON PUBLIC F0WER SUPPLY SYSTD1 0

OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION II.1-15 APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" II.1.9 REGULATORY GUIDE 1.58 (cont'd) of materials or services furnished, and as further described in Supply System Positions on Section 2.4 and 3 of ANSI /ASME N45.2.6-1978.

3. Section 2.1.2 of ANSI /ASME N45.2.6-1978 implies that personnel l performing non-NDE type of inspections, examinations, and test-ing will be formally certified. The Supply System does not plan this formal certification. Instead, the Supply System will select such personnel to predetermined qualification re-quirements for the specific task based on their education, ex-perience, and training. Formal training records, when used as the basis for qualification, will be maintained on file.

4. Section 2.4 of ANSI /ASME N45.2.6-1978 requires issuance of for- l mal certification to individuals and specifies the details of the information to be included in the certificate. The Supply System does not plan to issue formal certificates to indivi-duals performing inspections, examinations, and testing that fall within the scope of ANSI /ASME N45.2.6-1978 and Regulatory Guide 1.8. However, information similar to that described in this section of the Standard will be available in documented form attesting that the individual is capable of performing the assigned task (s). The Supply System will use a similar ap-proach in evaluating supplier compliance with this section of l the Standard.

Whits R3

" "V

• WASHINGTON PUBLIC POWER SUFFLY SYSTEM 6

OPERATIONAL PAG E QUALITY ASSURANCE PROGRAM DESCRIPTION II.1-16 APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" 11.1.9 REGULATORY GUIDE 1.58 (cont'd)

5. Section 3 of ANSI /ASME N45.2.6-1978 divides the capability re-quirements of inspection, examination, and testing personnel into three levels, namely Level I, level II, and Level III.

The Supply System will not assign these levels to its personnel performing inspection, examination, and testing activities.

However, the selection of personnel for particular tasks will be such as to match the capabilities to the types of tasks and maintain the intent of the three levels. The judgement to de-termine that a person's qualifications and capabilities meet the intent of a certain level of inspection, examination, and testing function is made through the normal management process l

by using established adminstrative and personnel procedures.

~

Documentation for such justification will be maintained on file. A similar approach will be used to evaluate the qualifications of non-NDE personnel of Supply System suppliers.

WP115 R3

WASHINGTON PUBLIC FOWER SUPPLY CYSTEM OPERATIONAL 6 PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION II.1 17 l

l l

1 APPEilDIX II II.1 "POSITIOT1 STATE!!E!!TS FOR WilP-2" THIS PAGE IS I.'lTE!!TIO!! ALLY LEFT BLAtlK.

t Oas . .>.

wk115 R3

% ""V*

WASHINGTON FUBLIC FOWER SUFFLY SYSTD1 OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION M-18 APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" II.1.10 REGULATORY GUIDE 1.64, Rev. 2 (June, 1976) " Quality Assurance Re-quirements for the Design of Nuclear Power Plants" Sucoly System Position The Supply System will implement the Regulatory Position of Regula-tory Guide 1.64, Rev 2 (June 1976) and tile requirements in the en-dorsed standard ANSI N45.2.11-1974 subject to the following:

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

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

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

WW11S R3

WASHINGTON FUBUC FOWER SUFFLY SYSTE!

6 OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIITION II.1-19 APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" II.1.11 REGULATORY GUIDE 1.74, (February 1974) " Quality Assurance Terms and Definitions" Sucoly System Position The Supply System will implement the Regulatory Position of Regula- l tory Guide 1.74, (February 1974) and the quality assurance terms and definitions in the endorsed standard ANSI N45.2.10-1973, subject to the following:

1. Regulatory Position "C" of Regulatory Guide 1.74 (February 1974) specifies certain documents recommended be included in the definition of " procurement documents", defined in ANSI N45.2.10 - 1973. The Suoply System will use the following

~

definition:

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

2. Section 2 of ANSI N45.2.10 - 1973: The definition of "specifi-cation" is revised to read as follows:

Specification - A statement of a set of requirements to be sat-isfied by a product, a material, a service or process indicat-ing, whenever appropriate, the procedure by means of which it may be determined whether the requirements given are satisfied.

w>tts R3

WASHINGTON PUBLIC POWER SUPPLY SYSTEM 6

OPERATIONAL PAG E QUAI.ITY ASSURANCE PROGRA31 DESCRIPTION II.1-20 APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" 11.1.12 REGULATORY GUIDE 1.88, REV. 2 (October 1976) " Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records."

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

1. Regulatory Position C.2 of Regulatory Guide 1.88, Rev. 2 (October 1976) endorses the 4-hour fire rating requirements for a single records storage facility as described in Section 5.6 of ANSI N45.2.9-1974. The Supply System modifies t'his 4-hour rating requirement of ANSI N45.2.9-1974 to 2-hour fire rating requirement. Accordingly, the Supply System will comply with a-substitute to the third, fourth, and fifth paragraphs of Section 5.6 of ANSI N45.2.9-1974 which reads, "Where a single record storage is maintained, the 0A records shall be maintained in either:

a. A 2-hour vault meeting NFPA (National Fire Protection As-sociation) No. 232-1975 without additional provisions or

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

c. 2-hour rated fire resistant file room meeting NFPA No.

232-1975 with the following additional provisions:

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

WP 135 R3

' ""V" WASHINGTON PUBLIC FOWER SUFFLY SYSTEM OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION II.1-23 APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" 11.1.13 REGULATORY GUIDE 1.94, REV. 1 (April 1976) " Quality Assurance Re-quirements for Installation, Inspection, and Testing of Structural Steel During the Construction Phase.of Nuclear Power Plants" Sucoly System Position Regul& tory Guide 1.94, Rev. 1 (April 1976) and the endorsed standard ANSI N45.2.5-1974 are not considered applicable to operations phase activities. However, the Regulatory Position of Regulatory Guide 1.94, Rev. 1 (April 19761, where appropriate, will be implemented for those applicable . operational phase activities that are compar-able to construction chase activities.

Whits R3

WASHINGTON FUBLIC FOWER SUFFLY SYSTC!

OPERATIONAL 6 QUALITY ASSURANCE PROGRA31 DESCRIPTION II.1-24 APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" II.1.14 REGULATORY GUIDE 1.116, REV. 0-R (May 19771 "Ouality Assurance Requirements for Installations, Inspection, and Testing of Mechani-cal Equipment and Systems" Supoly System Position The Supply System will implement the Regulatory Position of Regula-tory Guide 1.116, Rev. 0-R (May 1977) and the requirements in the endorsed standard ANSI N45.2.8-1975, subject to the following:

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

2. Section 2.3 of ANSI N45.2.8-1975, last sentence is revised to read, " Test reports shall include an evaluation of the accepta-bility of inspection and test results and provide for identify-ing the individual who performed the evaluation."

3. Section 2.8.2 of ANSI N45.2.8-1975 states, " Records of calibra-tion shall be included in inspection and test result ." Supply System does not intend to include calibration records in in-spection and test results. Instead, the calibration records will be maintained in a separate file.

w>tts m3

- t '

"'V*

WASHLNGTON FUBLIC F0WER SUFFLY SYSTD1 6

OPERATIONAL PAGE QUALITY ASSURANCE PROGRAM DESCRIPTION II.1-26 APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" II.1.15 Regulatory Guide 1.123, REV. 1 (July 1977) " Quality Assurance Re-quirements for Control of Procurement of Items and Services for Nu-clear Power Plants" Sucoly System Position The Supply System will implement the Regulatory Position of Regula-tory Guide 1.123, Rev. 1 (July 1977) and the requirements in the endorsed standard ANSI N45.2.13-1976, subject to the following:

1. Regulatory Position C.3 of Regulatory Guide 1.123, Rev. 1 (July 1977): During printing of the Regulatory Guide, an error oc-curred in the last sentence. The Supply System will comply with the correct wording which reads as follows:

While Section 9 of ANSI N45.2.-13-1976 addresses elements of the Purchaser's corrective action system, these same elements j are apolicable to the Supplier's corrective action system when one is required.

?. Section 1.3 of ANSI N45.2.13-1976: The Supply System will com-ply with the definition of " procurement documents" as stated in Supply System Position Statement on Regulatory Guide 1.74 (February 19741

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

w>tts na L

, . y

, WASHINGTON FUBLIC POWER SUFFLY SYSTDI OPERATIONAL PAGE QUALITY ASSURANCE PROGRA.\1 DESCRIPTION II.1-28 APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" 11.1.16 REGULATORY GUIDE 1.144, REV. 1 (September 19801 " Auditing of Qual-ity Assurance Programs for Nuclear Power Plants."

Sucoly System Position The Supply System will implement the Regulatory Position of Regula- l tory Guide 1.144, Rev.1 (September 1980) and the requirements in the endorsed standard ANSI N45.2.12-1977, subject to the following:

Section 4.4.4 of ANSI N45.2.12-1977 requires the audit report to include an evaluation statement regarding the effectiveness of the quality assurance program elements that were audited. Since the audit by its very nature is an evaluation of the quality assurance program effectiveness, the audit report itself is considered to be an evaluation of the quality assurance program effectiveness.

Therefore, this section of the Standard is revised to read "A Sumary of Audit Results."

W>t1S R3 -

....y -

• V-WASHINGTON FUBLIC FOWER SUFFLY SYSTEM OPERATIONAL 6 QUALITY ASSURANCE PROGRAM DESCRIPTION TI.1-29 APPENDIX II II.1 " POSITION STATEMENTS FOR WNP-2" II.1.17 REGilLATORY GUIDE 1.146, (Auoust 1980) .

" Qualification of Ouality Assurance Program Audit Personnel for Nuclear Power Plants" Sucoly System Position The Supply System will implement the Regulatory Positien of Requia-tory Guide 1.146, (August 1980) and the requirements in the endorsed standard ANSI N45.2.23-1978.

l l

I wk115 R3

_