ML20236B367

App a to QA Program, from Rev 5 to Updated FSAR

ML20236B367
Person / Time
Site:	Beaver Valley
Issue date:	07/14/1987
From:	DUQUESNE LIGHT CO.
To:
Shared Package
ML20236B258	List: ML20236B255 ML20236B367
References
NUDOCS 8707290088
Download: ML20236B367 (22)

Text

l BVPS-1-UPDATED FSAR Rsv. 5 (1/87)

APPENDIX A

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QUALITY ASSURANCE A.1 QUALITY ASSURANCE PROGRAM A.l.1 Quality Assurance Program - Overall Description A project Quality Assurance Program is in effect for the design, procurement, fabrication, erection and testing of components and systems, operations and maintenance of the Beaver Valley Power l Station Unit No. 1 (BVPS-1). Ultimate responsibility for the Quality )

Assurance (QA) Program rests with the Applicant, Duquesne Light  !

Company (DLC). The program entails quality assurance throughout all phases of this project as follows:

1. Conceptual design j l

2. Detailed engineering and design

3. Assembly and maintenance of quality control documentation for shop and field

4. Vendor selection S. S' surveillance of Vendor's shop inspection

() 6. Witnessing of key shop tests

7. Field inspection and quality control of erection

8. Equipment, installation, and testing specifications

9. Checkout of mechanical, fluid, and electrical systems

10. Star' tup testing  !

11. Periodic inservice performance tests.

4 The detailed working implementation of the Quality Assurance Program i during the design and construction phase was delegated to Stone & i Webster Engineering Corporation (S&W), as agents for Duquesne Light .

Company, and to Westinghouse Electric Corporation, contractor for the I Nuclear. Steam' Supply System. The Quality Assurance Organization  !

shown in Figure A.1-1 describes the relationships which. implemented the Duquesne Light Company Quality Assurance Program during the design and construction phase of BVPS-1.

Specific Duquesne Light company responsibility for auditing the Quality Assurance Program rests with the Quality Assurance Manager, 4 who reports directly to the Senior Vice-President, Nuclear Group. l ;

() A.1-1 87072900B8 870714 PDR ADOCK 05000334 P PDR *

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BVPS-1-UPDATED FSAR Rev. 4 (1/86)

Figures A.2-1 and A.2-2 show the Duquesne Light Company organization for quality assurance during the design and construction phase of BVPS-1. Figures A.2-3 and A.2-4 show the Duquesne Light Company organization for quality assurance for the operations phase of BVPS-1. Figures A.3-1, A.3-2, and A.3-3 show the S&W quality assurance organization. Figures A.4-1, A.4-2, and A.4-3' depict the quality assurance organization of Westinghouse, the supplier of the Nuclear Steam Supply System. The S&W Quality Assurance Coordinator had direct contact with the Duquesne Light, Company Quality Assurance Manager for quality assurance matters, ar well as with the Westinghouse Project Manager during the design and construction ,

phase.

Appendix A is organized as follows:

A.2 -

Duquesne Light Company Quality Assurance Program A.2.1 - Duquesne Light Company Design and Construction Quality Assurance Program applicable at the latest

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revision of the original FSAR (Amendment 18 dated November 1975), BVPS-1 A.2.2 - Present Duquesne Light company operations Quality Assurance Program, BVPS-1 A.3 -

Stone & Webster Engineering Corporation Quality Assurance Program used during the Design and Construction Phase, BVPS-1 A.4 -

Westinghouse Power Systems Division Quality Assurance Plan used during the Design and Construction Phase, BVPS-1 A. S. -

Westinghouse Nuclear Fuels Division Reliability and Quality Assurance Program, BVPS-1 A.l.2 Quality Assurance categories Equipment and structures, whether safety related or not, are subject to engineering review, and shop and field inspection to a degree proportional to the value of the equipment and to its contribution to.

safety, accessibility, reliability and operability.

The three quality assurance categories defined below are not levels of quality per se, but rather denote differences in application of the Quality Assurance Program. Category I and only Category I is intended to include activities affecting structures, systems, portions of systems, and equipment to which the 10CFR50, Appendix B criteria apply, i.e., structures, systems, portions of systems, and components which are safety related. Within that category, there may be differences in the quality specified, depending upon the nature of the component and upon its contribution to public safety (e.g., the A.1-2 i

BVPS-1-UPDATED FSAR Rsv. 0 (1/82) 4 conditions which may affect quality are documented and the corrective

(~ action is verified through the mechanisms provided in the Duquesne

( Light Company, S&W, and Westinghouse Manuals.

A.2.1.17 Quality Assurance Records  ;

The official quality file for the-BVPS-1 is maintained at the S&W Field Quality Control office. This file is monitored and audited by. i the Duquesne Light Company.

i Included in the records maintained are purchase orders, drawings, i I specifications, correspondence, procedures, audit reports, minutes of meetings, quality assurance checklists, codes and standards, and similar material. ,

A file system has been established to assure retrievability of such records. In the case where records are not stored at the site, locations for storage are reviewed and/or approved by the Duquesne  !

Light Company. Vendors retaining records for certain periods of time l are instructed that such records must be submitted to the applicant at the conclusion of his (the vendor) storage responsibility.

i A.2.1.18 Audits The Duquesne Light Company retains the ultimate responsibility for Quality Assurance for BVPS-1. This responsibility is exercised 1 mainly through an audit program. These audits are performed against j the S&W and Westinghouse commitments. These include quality 1 O, assurance / quality control procedures, instructions, and similar information.

specifications, drawings, Internal audits of tne Duquesne Light Company are also documented and maintained in the file.

As ' agents for the Duquesne Light Company, S&W also performs audits at the vendor shops through their Procurement Quality Control Division i and audits at the site through the Field Quality Control Division. I Both divisions are audited periodically by the Duquesne Light ,

Company. l Audit reports are utilized to assess the adequacy of the Duquesne Light Company Quality Assurance Program. A record of all audits is maintained and periodically reviewed to assure necessary follow-up action. Audits are reported at each Project Management Committee Meeting to assure that the necessary level of management is involved l and has an awareness of the audit program.

All audits are performed utilizing a preplanned checklist. The ,

checklist will include address to the specific criteria of Appendix B  !

of 10CFR50, results of previous audits, inspection reports, l t nonconformance reports, adherence to specifications, and other items  !

as identified in the respect 4ve organization quality assurance manuals.

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BVPS-1-UPDATED FSAR Rev. 5 (1/87) e A.2.2 Operations Quality Assurance Program An Operations Quality Assurance Program is established by Duquesne Light Company for the operations phase of BVPS-1. The program is written to conform to the requirements of 10CFR50, Appendix B,

" Quality Assurance Criteria for Nuclear ' Power Plants," and NRC Regulatory Guide 1.33 " Quality Assurance. Requirements (Operations)."

The NRC Regulatory Guides and American National Standards Institute (ANSI) Standards are utilized as indicated in the Attachment to l l

Section A.2. The following exception should be noted: An alternate set of Quality Assurance Terms and Definitions has been developed, i as Appendix A to the Duquesne Light company Quality and is included Assurance Program Manual. The purpose of the Operations Quality Assurance Program is to assure that the installed quality of BVPS-1 is maintained throughout the life of the plant.

The Operations Quality Assurance Program applies to all  ;

safety-related (Category I) structures, systems, and components, l throughout the life of the plant. The Category I structures, I l systems, and components are identified in the Operations Quality l Assurance Program. l I

A.2.2.1 Organization ]

The organizations which have responsibilities for performing activities affecting quality during the operations phase of BVPS-1 lh are shown in the organization chart of Figures A.2-3 and A.2-4. The j operations Quality Assurance Program identifies in detail the functional responsibilities of the organizations within the Duquesne Light Company which participate in quality-related activities.

The Operations Quality Assurance Program is established and managed I by the Quality Assurance Manager, who reports to the Senior Vice-President, Nuclear Group. The Quality Assurance Manager has the authority to report quality matters to any level necessary within the Duquesne Light Company, including: the Chairman of the Board; the President and Chief Executive Officer; the Senior Vice-President, Nuclear Group; the Vice President, Nuclear; the Vice-President, Administrative Services Group and the Vice-President, Power Supply Group in order to establish effective corrective action. The Duquesne Light Company Chairman of the Board, the President and Chief Executive Officer; the Senior Vice-President, Nuclear Group, the Vice President, Nuclear; the Vice-President, Administrative Services Group, and the Vice-President Power Supply Group comprise those members of the Executive management Group who have Nuclear responsibility.

The effort of the Quality Assurance Manager is directed solely to quality assurance. He purposely has no responsibilities for station costs or schedule considerations.

A.2-10 O

Rev. 3 (1/85)

BVPS-1-UPDATED FSAR Sufficient personnel are made available to implement the Duquesne 7- Light Company Quality Assurance Program. The Duquesne Light Company

( Quality Assurance Program provides written policies, procedures, and instructions governing the Quality Assurance activity.

In addition to the Duquesne Light Company Quality Assurance Program, a quality control program is established which- describes the activities performed (at BVPS-1) by .the Director, Operations Quality Control' .and his staff. The Director, operations Quality control reports to the Manager, Quality Assurance.

The Quality Assurance Manager and his staff have sufficient authority and organizational freedom to:

1. Identify quality problems

2. Initiate, recommend, or provide solutions to quality problems through designated channels

3. Verify implementation of solutions to quality problems

4. Control further processing, delivery, or installation of a nonconforming item, deficiency, or unsatisfactory condition until proper dispositioning has occurred.

The Operations Quality Assurance Program delineates in writing the responsibility and authority of the Quality Assurance Manager and

/~ Staff to stop unsatisfactory work pending resolutions of (s)T quality matters.

It is the policy of the Duquesne Light company Quality Assurance Program that the individual group assigned the responsibility for checking, auditing, inspecting, or otherwise verifying that any activity has been correctly performed, shall be independent of the individual or group directly responsible for the performance of that activity.

The qualification and experience levels established for the Quality Assurance personnel are presented in Table A.2-2.

The Duquesne Light Company personnel supporting the quality assurance effort includes those from the Nuclear Group, the Administrative Services Group and the Power Supply Group. Personnel in these groups participating in the program perform their duties in accordance with administrative procedures previously reviewed by the Quality Assurance Unit.

Purchasing Department (Administrative Services Group)

The Purchasing Department is responsible for the purchase of l materials, equipment and services following initial operation. The quality-related activities of the Purchasing Department are documented in written procedures or directives which are issued

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BVPS-1-UPDATED FSAR Rev. 5 (1/87) by the Purchasing Department with guidance, as necessary, from the  !

The Quality Assurance Unit reviews such Quality Assurance Unit.

procedures or directives and conducts periodic audits to assure that they are being effectively implemented. The Purchasing Department is not authorized to change technical or quality requirements without from the appropriate technical or quality authorization ,

organizations. l Nuclear Group The Nuclear Group is headed by the Senior Vice President, Nuclear Group who reports to the President and Chief executive officer of Duquesnc Light Company. Reporting directly to the Senior Vice President, Nuclear Group are the Vice President, Nuclear; Senior Manager, Nuclear Operations; Manager, Quality Assurance; and the Manager, Budget and Fuel Contracts. Reporting to the Vice President, Nuclear are the General Manager, Nuclear Engineering and Records; Manager, Nuclear Construction; Manager, Nuclear Training;. Manager, Administrative Services; and the Manager, Nuclear Safety. Reporting to the Senior Manager are the Manager, Planning and Outage  ;

Management; Plant Manager; Manager, Technical Services; and Manager, I

Radiological Control. All quality-related activities of the Nuclear Group are documented by policies, directives, procedures, manuals, instructions, etc. of a type appropriate to the circumstance. Audits of the Nuclear Group are in accordance with A.2.2.18.

The Plant Manager BVPS is responsible for the safe and efficient operation of BVPS in accordance with the guidelines and requirements of the operating License, Technical Specifications and Station Manuals. His responsibilities include the testing, operation, l maintenance, modification, and repair of BVPS.

The Manager of Technical Services is responsible for supporting the Plant Manager in areas of: procedure preparation to support operations and maintenance groups, refueling, procurement, station I chemistry control, and the shift technical advisory group.

Director, Materials Management reports to the Manager of Technical Services and is responsible for developing and implementing procedures for the receiving, storing, and distribution of ,

replacement parts and materials. Procedures that are administrative l in nature are reviewed by the Quality Assurance Unit.

The Manager of the Quality Assurance Unit is responsible for the l development and implementation of the BVPS Quality Control Program.

The Beaver Valley Power Station Quality Control Program is reviewed by the Quality Assurance Unit. The Quality Assurance Unit conducts planned and periodic audits of the Quality Control Program to assure that it is being effectively implemented.

The Nuclear Engineering and Records Unit is responsible for the design and detailed engineering of modifications and for gen & rating and maintaining as-built drawings and records for the station.

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BVPS-1-UPDATED FSAR Rsv. 5 (1/87)

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' The quality-related activities of the Unit are documented in written procedures or directives which are issued by the General Manager of Nuclear Engineering and Records with guidance as necessary l from the Quality Assurance Unit. The Quality Assurance Unit reviews such procedures or directives and conducts periodic audits to assure that they are being effectively implemented. ,

Power Supply Group The Manager of substations has the responsibility for the performance of limited designated electrical equipment tests at the direction of the Nuclear Group Management (can be requested by NERU as well as the !

Plant Manager) and is responsible for developing procedures governing their activities. The quality-related activities of Substations are documented in written procedures or directives which are issued by the Manager, Substations or his designee, with guidance as necessary from the Quality Assurance Unit. The Quality Assurance Unit reviews such procedures or directives and conducts periodic audits to assure l

I that they are being effectively implemented.

Onsite Safety Committee (OSC)

The Onsite Safety Committee, as required by Technical Specifications, is a special committee composed of experienced and highly skilled Nuclear Group Personnel. The Onsite Safety Committee meets monthly (and when called by the Chairman) and advises the Plant Manager on (s/}

- all matters related to nuclear safety. l Offsite Review Committee (ORC)

The Offsite Review Committee, as required by Technical  ;

functions as an independent safety review and audit Specifications, group to advise the Senior Vice President on all matters concerning i I

safe performance and operation of the nuclear power station. It has the authority to perform periodic nuclear safety audits of plant l operations. The Offsite Review Committee is composed primarily of I personnel outside of the station operating organization, each with experience in a field pertinent to nuclear safety. I l

Contractors l Contractors which perform work on safety-related items shall document l and implement a Quality Assurance Program that addresses all the ,

safety-related activities assigned to the contractor. The Duquesne Light Company Quality Assurance Unit shall review and concur with the contractor's Quality Assurance Program. The contractor's Quality Assurance Program shall be in effect when the safety-related work is started.

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BVPS-1-UPDATED FSAR Rev. 5 (1/87) k-Vendors ]

Vendors supplying safety-related items shall document and implement a Quality Assurance Program that addresses safety-related activities performed by the vendor. The Duquesne Light Company Quality Assurance Unit shall review and concur with the vendor's Quality '

Assurance Program. The vendor's Quality Assurance Program shall be in effect when the safety-related work is started..

A.2.2.2 Quality Assurance Program The Operations Quality Assurance Program:

1. Identifies quality-related functions for the licensed plant and designated responsibilities within Duquesne Light Company for performing those functions, and delegates the authority necessary to meet the assigned responsibilities.

2. Specifies control measures for quality-related documents.

3. Prescribes administrative controls to assure that adequate training and planning are provided and prerequisites are met prior to performance of critical quality achievement, .

quality effective, and quality verification tasks.

4. Provides for testing, inspection, surveillance, and auditing i to prevent, or detect and correct deviations and deficiencies that would degrade the installed plant quality.

5. Provides for accumulation and retention of records that define or attest to the quality of plant strv.ctures, systems, and components.

6. Identifies the safety-related elements of the station.

The Duquesne Light Company Quality Assurance Program is comprised of the Quality Assurance Policy, The Design and Construction Quality Assurance Program and the Operations Quality Assurance Program (appended to this Operations Quality Assurance Program is the Nuclear Fuel Program). The Quality Assurance Policy is prepared by the Quality Assurance Manager and approved by the President and Chief Executive Officer of Duquesne Light Company. The Design and Construction Quality Assurance Program and the Operations Quality Assurance Program are prepared by the Quality Assurance Unit and approved by the Quality Assurance Manager. The Quality Assurance Manager is responsible for the controlled distribution of quality-assurance policies, procedures, and manuals. Table A.2-1 is a matrix which cross references the procedures contained in the operations Quality Assurance Program with the 18 Criteria of Appendix B to A.2-14 L -

BVPS-1-UPDATED FSAR Rsv. 5 (1/87) 10CFR50. Indoctrination and training measures assure that all

/_m\ responsible organizations and individuals are aware of quality

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policies, procedures, and manuals, and have an adequate understanding of these requirements, the methods of meeting such requirements, and the methods of enforcement.

The Duquesne Light Company Quality Assurance Program requires that a management review of the status and adequacy of the Quality Assurance Program be conducted on a biennial basis by the Senior Vice-President, Nuclear Group, or his designee.

The Operations Quality Assurance Program applies to plant operations, maintenance, and modifications associated with safety-related (Category I) structures, systems, and components.

The

• Nuclear Fuel- Program is an appendix to the Operations Quality Assurance Program. The appendix establishes the requirements  ;

necessary for the procurement, fabrication, receipt of fuel  !

assemblies, and administrative controls for the Nuclear Fuel j Program. In addition, this appendix shall be applied to all I activities of Duquesne Light Company's Fuel Contractor as such activities relate to the procurement and fabrication of nuclear fuel assemblies and related components, including control rod assemblies and burnable poison assemblies.

Formal training of all members of the Duquesne Light company Quality Assurance Unit is accomplished in part by seminars and classroom

,/~N courses. Additionally, staff members are encouraged to increase

(_,) their proficiency through courses offered by local and state universities or other industry courses. At various times the Quality Assurance Manager may conduct in-plant indoctrination and training in those areas where he feels it will be of benefit to his staff, or to ,

other Duquesne Light Company organizations engaged in the performance of activities affecting quality.

The quality assurance programs of outside organizations participating i in the maintenance, repair, or modification are reviewed by the l Duquesne Light Company Quality Assurance Unit. This review includes

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the subject of indoctrination and training and shall be to assure I that other organizations adequately provide for indoctrination and l training of their personnel who perform activities affecting quality.

Activities affecting quality shall be accomplished under suitably controlled conditions including:

1. The use of special processes, tools, test equipment, skilled personnel,

2. Proper environmental conditions, such as adequate cleanliness, l

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BVPS-1-UPDATED FSAR Rev. 5 (1/87)

3. Satisfactory evidence of all prerequisites having been met,

4. Adequate testing and inspections performed.

A.2.2.3 Design control i Des!.gn changes which may be necessary during the operating life of BVPS-1 shall be accomplished in accordance with design control ,

measures as described in the Operations Quality Assurance Program.

l The Operations Quality Assurance Program provides measures to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. The Operations Quality Assurance Program includes provisions for assuring that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled.

The design control measures applied to design changes include provisions for the selection and review for suitability of the application of materials, parts, equipment, and processes that are essential to the safety-related functions of structures, systems, and components.

The Operations Quality Assurance Program establishes measures for the identification and control of design interfaces and for coordination l among participating design organizations. These measures require the l i

establishment of procedures among participating design organizations for the review, approval, release, distribution, and revision of documents involving design interfaces.

The adequacy of design changes is verified or checked by appropriate '

l methods such as:

l. Performance of design reviews

2. Use of alternate or simplified calculational methods

3. Performance of a suitable testing program.

If a testing program is used in lieu of other verifying or checking processes, to verify the adequacy of a design feature, the test program will include suitable qualification testing of a prototype unit under the most adverse design conditions.

The Operations Quality Assurance Program re#bires that the verifying or checking process be performed by individuals or groups other than those who performed the original design, but who may be from the same organization.

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BVPS-1-UPDATED FSAR Rsv. 5 (1/87) i 1

Design changes at .BVPS-1 after release and acceptance of design

(' ) documents are subject to design control measures commensurate with those originally applied to the design. The Operations Quality Assurance program requires that whenever practical, changes should be reviewed and approved by the individuals or organizations that originally performed the review and approval of the design. In the event that it is not practical for the original individuals or organizations to perform the required review and approval, other responsible individuals or organizations (such as the Nuclear Group, an architect-engineer, or other design organization) will be designated, provided the designated organizations have access to pertinent background information, have competence in the specific design area of interes', and have adequate understanding of the requirements and intent of the original design.  ;

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~ Design control measures will provide for but are not limited to the following:

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1. Reactor physics

2. Stress, thermal, hydraulic, and accident analyses

3. Compatibility of materials

4. Suitability of application of materials, parts, equipment and processing

5. Accessibility for operation, inservice inspection, maintenance, and repair

6. Acceptance criteria for inspections and tests

7. Applicability of codes and standards.

The operations Quality Assurance Program requires that design changes be incorporated into revised design documents, including specifications, procedures, and as-built drawings. The revised design documents will be distributed to responsible individuals and organizations in a controlled manner and obsolete documents will be removed and disposed of in a similarly controlled manner.

The Operations Quality Assurance Program provides measures to assure that changes or deviations from specified design requirements or quality standards are identified, documented, and controlled.

The Quality Assurance Unit has established a comprehensive system of planned and periodic audits of the design organization, whether the design work is performed internally by Duquesne Light l Company or externally by an architect-engineer or consultant.

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BVPS-1-UPDATED FSAR Rev. 5 (1/87)

Design documentation, including design review reports, specifications, drawings, and revisions thereto shall be collected, l

filed, stored, and maintained in a systematic manner.

The Operations Quality Assurance Program requires that all design changes of safety-related items shall be reviewed by the Onsite Safety Committee, and the Offsite Review Committee in accordance with the Technical Specifications, and the requirements of the Operations Quality Assurance Program. Safety analyses are conducted, as appropriate to determine 10CFR50.59 requirements.

i' A.2.2.4 Procurement Document Control The Operations Quality Assurance Program establishes measures to assure that applicable regulatory requirements, design bases, and f other requirements which are necessary to assure quality are suitably I included or referenced in the documents for procurement of material, equipment, and services, whether purchased by Duquesne Light Company, or by its contractors or subcontractors.

For items classified as Quality Assusance Category I, Level A (those items designed and fabricated specifically as safety-related products), the supplier's and contractor's Quality Assurance Programs will be reviewed for compliance with the pertinent provisions of 10CFR50, Appendix B, by the Duquesne Light Company Quality Assurance Unit. The Purchasing Department or its designee shall not issue the

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purchase order for Quality Assurance Category I, Level A items unless the suppliers are on the Duquesne Light Company Qualified Suppliers List.

Off-the-shelf type items used in Category I Systems are classified as Category I, Level C. These items may be purchased from any available supplier. Category I items are receipt inspected and functionally teste'd after installation.

The Operations Quality Assurance Program ' requires that procedures be established which describe the sequence of preparation, review, approval, and control of procurement documents and will identify the responsibilities of the individuals and organizations which are associated with those activities.

The Operations Quality Assurance Program includes provisions for extending applicable requirements of procurement documents to lower i tier subcontractors and suppliers, including purchaser's access to facilities and records.

The procurement documents shall be reviewed to determine that all quality requirements are correctly stated, and to assure that the procurement document has been prepared in accordance with the requirements of the Operations Quality Assurance Program. The review of procurement documents shall be performed by an individual or organization other than the one responsible for preparing the procurement documents, in accordance with the provisions of the Operations Quality Assurance Program.

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When applicable, procurement documents shall contain basic technical

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requirements specifications, including component codes and industrial identification, standards, drawings, including their j revision status, tests and inspection requirements and special -

process instructions, for activities such as fabrication, cleaning, erecting, packaging, handling, shipping, storing, and inspecting.

The procurement documents shall contain provisions which allow access to vendor facilities and records for the purpose of audits and inspections. The procurement document will define the requirements for the retention, control, submittal, and maintenance of records such as drawings, specifications, procedures, qualifications, material, chemical and physical test results.

Revisions or changes to procurement documents will be subjected to the same review requirements as the original document. The review and approval of procurement documents, including any revisions or changes thereto, shall be documented, and such evidence will be maintained and available for verification.

Category I, Level A items may be purchased only from suppliers on the qualified suppliers list. The evaluation and selection of suppliers for the qualified suppliers list, is performed in accordance with the provisions of the Operations Quality Assurance Program. The evaluation and selection shall be based on factors such as: -

1. The ability to meet the established technical and quality requirements set forth in the procurement documents,

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2. Previous performance of the supplier and experience in supplying similar items of the type being procured, i 3. Surveys and evaluations of the supplier's Quality Assurance l

Program.

A.2.2.5 Instructions, Procedures, and Drawings The Operations Quality Assurance Program requires that activities '

affecting quality shall be prescribed by documented instructions, i procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. The instructions, procedures, or drawings, shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

The Be' aver Valley Power Station Manual of Operating" Procedures includes instructions and procedures covering the requirements of NRC Regulatory Guide 1.33 " Quality Assurance Requirements (Operations)",

Appendix A, as they apply to Pressurized Water Reactors. The Manual of Operating Procedures is implemented, enforced, and maintained by the Plant Manager, the Manager of Technical Services, and their

. staffs. These procedures and/or instructions include step-by-step p

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BVPS-1-UPDATED FSAR Rev. 5 (1/87) procedures for operating, and securing the various systems; actions G',iI to be taken in the event of abnormal or emergency conditions and precautions to preclude exceeding system or equipment design. The ,

applicable requirements of ANSI N18.7 - 1972 " Administrative Control for Nuclear Power Plants" were used as guidance in the development of startup, operating, emergency, maintenance, and testing procedures.  ;

Maintenance, repair, modifications, testing, and refueling activities which affect the quality or safety of Category I items are prescribed by documented instructions, procedures, or drawings. These instructions, procedures, or drawings include, as appropriate, the requirements for special tools, test equipment, processes, controls, or skills, in order to attain the required level of quality.

A.2.2.6 Document Control The Operations Quality Assurance Program establishes measures to control the issuance of documents, such as instructions, procedures, and drawings, affecting the quality of safety-related structures, systems, and components. The measures assure that documents including changes are reviewed for adequacy and approved by authorized personnel.

The Operations Quality Assurance Program includes provisions for assuring that documents, including. changes, are reviewed for adequacy and approved for release by authorized personnel, and are &

distributed to and used at the location where the prescribed activity W is performed, prior to the onset of work.

Changes to approved and released documents shall be reviewed and approved by the same individuals or organization which performed the original review and approval, whenever practical. In the event that it is not pr.actical for the original individuals or organizations to perform the required review and approval, other responsible individuals or organizations will be designated, provided the designated individuals or organizations have access to pertinent background information, have competence in the particular area of interest, and have adequate understanding of the requirements and intent of the original documents.

The Quality Assurance Unit conducts planned and periodic audits of the document control measures, in accordance with the Operations Quality Assurance Program to assure that the measures are being effectively implemented.

A.2.2.7 Control of Purchased Material, Equipment, and Services The Operations Quality Assurance Program establishes measures to assure that. purchased material, equipment, and services whether purchased directly or through contractors and subcontractors, conform to the procurement documents. The measures include provisions, as O

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BVPS-1-UPDATED FSAR Rev. 5 (1/87)

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(_) appropriate, for source evaluation and selection, source inspection, receipt inspection, examination of tests and/or inspection reports

'from the supplier, and examination of objective evidence from the supplier, such as certification of material analysis or' any combination of these. The extent and frequency of source evaluations shall be governed by factors such as the importance, complexity and quantity of items involved and the level of confidence in the supplier established by past performance, his ability to meet the applicable requirements of 10CFR50, and a periodic comprehensive audit of his Quality Assurance Program and implementation.

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The Operations Quality Assurance Program includes measures to assure that source inspections or audits are conducted by qualified personnel to determine conformance to the requirements of procurement documents, specifications, drawings, and applicable codes and standards. Such inspections and/or audits are determined in advance and performed in accordance with written instructions.

Receipt inspection shall be performed by designated individuals, using written predetermined instructions and/or checklists in accordance with the provisions of the operations Quality Assurance Program. The receipt inspection shall include examination of material and equipment to assure that the quality was not impaired ,

during transit, that the correct count was received, and that all i required quality records are at the site prior to use or installation I f of the material or equipment.  !

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Documentary evidence that material and equipment conform to the l l procurement requirements shall be available at the Beaver Valley Site prior to installation or use of such material or equipment.

The Operations- Quality Assurance Program requires that the effectiveness of the control of quality by contractors and suppliers shall be assessed by Duquesne Light Company, 'or its designee at intervals consistent with the importance, complexity, and quantity of the product or service.

A.2.2.8 identification and Control of Materials, Parts, and l Components The Operations Quality Assurance Program requires that measures be established for the identification and control of materials, parts, and components, including partially fabricated assemblies. These l measures shall assure that identification of the item is maintained by heat number, part number, serial number, or other appropriate means, either on the item or on records traceable to the item, as required throughout fabrication, erection, installation, and use of l the item. Physical identification shall be used to the maximum extent possible. Where physical identification is either impractical or insufficient, physical separation, procedural control, or other appropriate means shall be. employed. Identification may be either on the item or on records traceable to the item as appropriate. Where A.2-21 I

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BVPS-1-UPDATED FSAR Rev. 5 (1/87) identification marking is employed, the marking shall be clear, I unambiguous and indelible, and shall be applied in such a manner as .!

not to affect the function of the item. Markings shall be transferred to each part of an item when subdivided and shall not be obliterated or hidden by surface treatment or coatings unless other means of identification are substituted. Traceability shall be identified in procurement documents and by reference to the requirements of applicable codes and standards. i These identification and control measures shall be designed to prevent the use of incorrect or defective material, parts, and components. Materials and equipment received at BVPS-1 shall be i properly identified to correspond with the receiving documentation and quality records.

Identification of installed items shall be retained in order to l 1

provide traceability to associated quality documentation.

These requirements shall be incorporated in written instructions and procedures of various .Duquesne Light Company groups, units and departments as applicable. In addition, vendors and contractors supplying material, equipment and services for Category I systems shall be required to address the applicable Portions of these requirements in written instructions and Procedures.

A.2.2.9 Control of Special Processes I The Operations Quality Assurance Program establishes measures to assure that special processes, including welding, heat treating, and lh non-destructive testing are controlled and accomplished by qualified personnel using qualified procedures in a'ccordance with applicable i codes, standards, specifications, criteria and other special '

requirements.

Documentation shall be maintained for currently qualified personnel, i processes, and equipment in accordance with the requirements of l governing codes and standards. For special processes not covered by j existing codes and standards, or whern the item quality requirements exceed "he requirements of established codes and standards, the i necessa;y qualification of personnel, processes, or equipment shall I be defined.

l These requirements for special processes shall be incorporated in written instructions and procedures prepared by various Duquesne Light Company groups, units and departments as applicable.

In addition, vendors and constructors supplying material, equipment or services for Category I systems shall be required to address the-applicable portions of these requirements in written instructions and procedures. Outside service organizations performing special processes at BVPS-1 shall use procedures which are reviewed and i approved by Duquesne Light Company. ,

I A.2-22 1

I i

l l t m-- _ -- - - - - - - - _ - - - - - - - _ _ - _ - - - _ _ _ _ ---------a

BVPS-1-UPDATED FSAR Rav. 3 (1/85)

A.2.2.15 Nonconforming Materials, Parts or Components

(%

5- The operations Quality Assurance Program establishes measures to control materials, parts or components which do not conform to requirements in order to prevent their inadvertent use or installation. These measures include as appropriate procedures for identification, documentation, segregation, disposition, and notification to the affected organization. The responsibility and authority for the disposition of nonconforming items shall be defined and a method of notification to affected organizations shall be documented in instructions and procedures. Inspection requirements and the acceptance criteria for l repairs, replacements or modifications shall be, as a minimum, equal to those imposed originally.

Nonconforming items shall be reviewed and accepted, rejected, repaired or reworked in accordance with documented procedures. Nonconforming items will be positively identified and, whenever practical, physically separated into hold areas. Access to such hold areas, including the authority for the removal of such items, shall be specified.

outside contractors who identify nonconformances while performing l safety-related work will be required to obtain Duquesne Light company approval of corrective action waivers or to modify a requirement which was specified or approved by the Duquesne Light Company.

These requirements shall be incorporated in the written instructions and procedures of various Duquesne Light Company groups, units and departments as applicable. In addition, vendors and contractors supplying material, equipment or services for Category I systems sha33 r'~}

(_f be required to address these requirements in written instructions and procedures.

A.2.2.16 Corrective Action.

The operations Quality Assurance Program requires that measures be l established to assure that conditions adverse to quality such as failures, malfunctions, deficiencies, deviations, defective material and 3 equipment, and nonconformances are promptly identified and corrected. l In the case of significant conditions adverse to quality, the measures I shall assure that the cause of the condition is determined and i corrective action taken to preclude repetition. The identification of 1 the significant condition adverse to quality, the cause of the i condition, and the corrective action taken shall be documented and 1 reported to appropriate levels of management. Provisions.shall be i established for the maintenance of documents providing objective I evidence that conditions adverse to quality have been identified and corrective action has been taken.

These requirements shall be incorporated in the written instructions and procedures of various Duquesne Light Company groups, units and departments as applicable. In addition, vendors and contractors 2 supplying material, equipment or services

() A.2-27 1

l l _. . _ _ _ _ _ _ - _ - _ _. . _ _ _ . _ _ _ _ _ - _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - -

BVPS-1-UPDATED FSAR Rev. 5 (1/87)

O for Categjory I systems shall be required to address these requirements in written procedures or instructions.

The Duquesne Light Company Quality Assurance Manager has the authority to prepare written notices to the appropriate level of management requesting changes and/or revisions to any program or i procedure which may- have resulted in the generation of repeated nonconformances. In addition, the Quality Assurance Manager may direct the stopping of all work pending corrective action.

A.2.2.17 Quality Assurance Records The Operations Quality Assurance Program requires that sufficient records be maintained to furnish evidence of activities affecting

! quality. The records shall include at least the following:

operating logs and results of reviews, inspecti.ons, tests, audits, monitoring of work performance and material analyses. The records shall also include closely related data such as qualifications of persennel, procedures and equipment. ANSI N45.2.9, " Requirements for j Collection, Storage and Maintenance of Quality Assurance Records for j Nuclear Power Plants", will be used as a general guide for the  !

retention period of records -

.erated during the operation of the  !

plant ., Inspection and test r' ids shall, as a minimum, identify the inspector or data recorder, , , cype of observation, the results, the acceptability, and the cion taken in connection with any deficiencies noted. Records shall be identifiable and retrievable.

Consistent with applicable regulatory requirement, the Duquesne Light company shall establish requirements concerning record retention such as duration, location and assigned responsibility. Provisions include onsite facilities for permanent records retention, including steps taken to assure preservation, protection, controlled access, l and all other applicable requirements.

l The Duquesne Light Company Nuclear Engineering and Records Unit shall be responsible for the retention of records generated during the  !

design and construction of the station and by plant operation.  !

Operational records which are designated to be retained in archives shall be transferred to the Nuclear Engineering and Records Unit.

The Director, Operations Quality Control, shall be responsible for the generation of inspection quality records and the transferring of  ;

l such quality records to the Nuclear Engineering and Records Unit for j permanent lifetime retention. j i

l The Duquesne Light Company Nuclear Engineering and Records Unit shall I be responsible for the generation and maintenance of a document j listing the location and type of all pertinent documents which will i 1

be stored offsite. l A.2-28 i

l 1

.BVPS-1-UPDATED FSAR Rsv. 5 (1/87) i

- A.2.2.18 Audits

\- The Operations Quality Assurance Program requires that a comprehensive system of planned and periodic audits be carried out to l verify all aspects of the quality as.surance program and to determine ,

the effectiveness of the program. Audits shall be performed in accordance with written procedures or checklists by appropriately trained personnel not having direct responsibilities in the areas being audited. Audit results shall be documented and reported to management having direct responsibility in the area audited.

Responsible management will take the necessary action to respond to  :

- any deficiencies or nonconformances identified in the audit report. l Follow-up action, including re-audit of deficient areas, will be I taken as necessary to assure that all deficiencies or nonconformances  !

noted have been corrected.

The Duquesne Light Company Quality Assurance Unit is responsible for the auditing of all company groups, units or departments as well as company contractors or subcontractors participating in the Duquesne Light Company Quality Assurance Program. These audits include, but are not limited to:

1. Audits to provide an objective evaluation of quality-related procedures, instructions, and practices,

2. Audits to evaluate the effectiveness of the implementation of these procedures, instructions, and practices,

3. Audits to determine the adequacy of work areas, activities, and processes,

4. Audits to verify that required documentation and records are complete and are adequately controlled and maintained.

These audits will be performed at a frequency commensurate with their importance as well as the quality record of the group involved.

Audits will be performed with pre-planned audit checklists. Audits may be announced or unannounced. Audit reports will be prepared on a timely basis by the person (s) performing the audit. The audit report will clearly identify any nonconformances or deficiencies and will assign the responsibility for disposition. Copies of all audit findings and recommendations are transmitted to the appropriate management level of the organization involved as well as the Senior Vice President, Nuclear Group. The audit program shall include vendor surveys / audits necessary to prepare and maintain a qualified suppliers list as described in Section A.2.2.4.

The audit program is supplemented by the Offsite Review Committee which performs audits within the Nuclear Group to assess the technical adequacy of procedures as well as their implementation.

The Offsite Review Committee, as determined by the Technical specifidhtions, audits the station operations including the

( A.2-29 l _ . _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _

BVPS-1-UPDATED FSAR Rev. 5 (1/87) performance of both equipment and operating personnel. The Offsite Review Committee may delegate the responsibility for the actual  ;

auditing to a separate group but reviews the results of any such 1

audits and initiates action to correct deficiencies as a result of the audit.

In addition, the Operations Quality control Department performs the necessary checks, records reviews, and inspections to verify that safety-related activities were performed in accordance with ,

applicable codes and standards and were done by qualified personnel using written procedures, and that appropriate data was obtained, evaluated, results dissemina'ted, and that required records were maintained.

The Duquesne Light Company Quality Assurance Program will be audited I on a biennial basis by the Senior Vice-President of the Nuclear Group or his designee to assess the status and adequacy of the program.

O O

A.2-30

"N. ., ,

1 CHIEF SENIOR VICE ORC PRESIDENT ----

NUCLEAR GROUP 1

l I VICE PRESIDENT - . -

BV-2 NUCLEAR PROJECT SENIOR MANAGER GENERAL MANAGER NUCLEAR NUCLEAR ENGR.&

OPERATIONS RECORDS l MANAGER MANAGER MANAGER BUDGET AND PLANNING AND NUCLEAR FUEL CONTRACTS OUTAGE MGMT. CONSTRUCTION PLANT MANAGER

[0SC H MANAGER NUCLEAR TRAINING i MANAGER MANAGER

'--- TECHNICAL ADMIN. SERVICES SERVICES MANAGER MANAGER NUCLEAR RADIOLOGICAL SAFETY CONTROL SAPS DCCOMISSION PROJECT

@ INDUSTRIAL SAFETY RESPONSIBILITY h UNTIL UNIT 2 COMMERCIAL OPERATIONS h SECURITY RESPONSIBILITY j @ FIRE PROTECTION PROGRAM AND ISEG RESPONSIBILITY GWIB %

u.__-__._._

REV. 5 Q-87)

PRESIDENT CHAIRMAN OF AND r---------~ THE BOARD EXECUTIVE OFFICER l

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,___________. .____J POWER SUPPLY ADMINISTRATIVE GROUP SERVICES GROUP l VICE PRESIDENT VICE PRESIDENT l

L l SYSTEM OPERA 110NS GENERAL SERVICES i & TELECOMMUNICATIONS GENERAL MANAGER l GENERAL MANAGER I

MANAGER SUBSTATIONS MATERIALS MANAGEMENT MANAGER MANAGER OPERATIONS I PURCHASING OUALITY CONTROL SYSTEM DEVELOPMENT DIRECTOR DIRECTOR GENERAL MANAGER

" SYSTEMS ENGINEERING L D E R MANAGER , APER]UR.,n

! CARD OA ENGINEERING /

, PROCUREMENT DIRECTOR g g.gl4 Aperture Q ' '

L ^ 8sER%I ec R "5 FIGURE A.2-3 l

DUQUESNE LIGHT COMPANY OUALITY ASSURANCE ORGANIZATION l

OPERATIONS PHASE BEAVER VALLEY POWER ST ATION UNIT NO.1 UPDATED FINAL SAFETY ANALYS]S REPORT g101M00ffm/ -

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