ML20072Q771
| ML20072Q771 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 03/25/1983 |
| From: | De Lorenzo R WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| GO1-83-0115, GO1-83-115, NUDOCS 8304050316 | |
| Download: ML20072Q771 (152) | |
Text
{{#Wiki_filter:,: - Washington Public Power Supply System P.O. Box 968 3000 GeorgeWashingtonWay Richland, Washington 99352 (509)372-5000 March 25, 1983 G01-83-Oll5 Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, California ' 94596 Attention: R. H. Engelken Regional Administrator
Subject:
NUCLEAR PROJECTS NOS. 1 & 4 DOCKET NOS. 50-460 AND 50-513 QUALITY ASSURANCE PROGRAM DESCRIPTIONS
Reference:
Letter, Olan D. Parr, NRC to J. J. Stein, Supply System, "WPPSS Nuclear Project Nos.1 & 4 - Review of PSAR Amendment No. 22", dated November 18, 1976 As required by the January, 1983 amendment.to 10CFR50.54 (a), attached are the current Quality Assurance program descriptions which are being implemented on WNP-1/4. While we consider the Quality Assurance Program described in the PSAR to be modified by these changes, we have not formally amended the PSAR in accordance with the NRC's direction provided in the
- referenced letter.
A brief explanation of each of the attachments is provided as follows:~ Attachment I - Deviation 17.1-6 Rev. 1 describes the Supply System's current QA Program as the Owner. This revision reflects the current Supply System organization and responsibilities, and reflects general responsi-bilities of Bechtel Power Corporation as the Construction Manager (non-ASME III Div. 2) and United Engineers & Constructors Inc.-(UE&C) as the Architect-Engineer and Construction Manager for ASME III Div. 2 activities. Attachment II - Deviation 17.2-1 Rev. 1 describes UE&C's QA Program as the Architect-Engineer (A/E) and reflects current responsibilities and the current project organization. Attachment 'III - Deviation 17.4-4 Rev. 3 describes the Bechtel QA Program as the Construction Manager for all Quality Class I activities except for ASME III Div. 2. It should be noted that Bechtel's NRC approved. topical report, BQ-TOP-1 Rev. 3A, is a significant' portion of this program description. ! f Oh gjo\ (}W y B304050316 830325 g:.bg PDR ADOCK 05000460 # A' ;PDR t. -
I.. ... t Mr. R. H. Engelken Page Two March 25, 1983 G01-83-Oll5 This program description is necessary to describe Bechtel's Construction Manager responsibilities which they assumed in May, 1981. Attachment IV - Deviation 17.4-5 describes the UE&C QA Program as the Construction Manager for ASME III Div. 2 activities only. This section previously described UE&C's responsibilities as the Construction Manager for Quality Class I non-ASME III Div. 2 activities which are currently being performed by.Bechtel. B&W's QA program description has not been included as an attachment since they are implementing the NRC aprpoved-B&W topical report, BAW-10096A Rev. 4. Should you have any further questions regarding this subject, please advise. 6t+1t W R. . De Lorenzo (/ Program Director - WNP-1 CRE:dm Attachments cc: MD Thadani - NRC, Bethesda JP Laspa, Bechtel Power Corporation w/o (862)' V Mani, United Engineers & Constructors Inc. w/o (897) 5
. WASHINGTON PUBLIC FOWER SUFFLY SYSTEM PSAR DEVIA90N REQUEST WNP. l/4 otV8ATion No. PARAGRAPM no. oATE 17.1-6 Rev. 1 Section 17.1 February 18. 1983
- 3. esan commermswr as o, _May 14, 1986 ausmomany mana smei.uos saa starsusur Deviation 17.1-6 currently describes corporate and project organization prior to corporate level organizational changes and changes in Project QA reporting to Corporate Quality Assurance.
- a. ossanao cammeas unoecars ossenso starsmanr3 Revise Deviation 17.1-6 to reflect current Corporate organization, ' Project QA's '
reporting relationship to Corporate QA and the Project Program Director and incorporate previously approved deviations to Chapter 17.1. i
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1 No changes to PSAR commitments are being made. As noted in 2 above. this chance ( reflects current Supply System orcanization and incornorates oreviousiv anoroved devictions. . ,
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Updated Chapter 17.1 to acc_rately reflect Supply System Corporate and Project organizational structure. This changes does not reduce the Project's connitment to l l 10CFR50 Appendix B and/or the associated daughter standards. l e - y sv. . . , oara j ena. naso ev.
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l V y s CHAPTER 17 QUALITY ASSURANCE I The Washington Public Power Supply System will implement an overall Quality Assurance Program (QA Program) for the desip, procurement, construction and operation of the Supply System's Nuclear Project Nos.1/4 (WNP-1/4) in accor-dance with the requirements of Appendix "B" of 10CFR50. As the applicant, the Supply System is responsible for the plants and will take appropriate actions to assure that they are designed, procured, constructed and operated in accor-dance with sound engineering principles and practices. Systems, components and structures that are safety-related, in the context of 10CFR50 will be designed, specified, f abricated, installed, tested and operated in accordance ) with applicable regulatory requirements, codes, standards, specifications and procedures. The objective of the Supply System is to implement a QA Program
- that is responsive to the requirements of MtC Regulations,10CFR50, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants" by assuring that-l quality related efforts are performed in a controlled manner and are docu-mented to provide objective evidence of compliance. l 17.1 (UALITY ASSURANCE DURING DESIGN AND CONSTRUCTION bashington Public Power Supply System 17.1.1 Organization This Section describes the organizational relationships within the Supply 1
System and assigns the authorities and responsibilities for the administration and implementation of the Quality Assurance Program. Assired authorities and
~
responsibilities demonstrate the organizational freedom of Quality Assurance. This organizational freedom is accomplished through Corporate and Project structures which provide independence from Supply System organizations respon-l sible for " construction". At the Corporate Level, the Director and staff of Licensing and Assurance, and l at the Project (jobsite) Level the Project QA Manager and staff, are complete-ly free from responsibility of cost and scheduling during " construction". .The Director of Licensing and Assurance and the Project QA Manager have the free-dos and authority to identify quality related problems, initiate corrective , actions (including stop work) and recommend or provide solutions and to verify the implementation of corrective actions. l Each nuclear power plant Project is administered by a Project Program Direc- ' tor. The Program Director is directly accountable to the Director of Opera-- -l tions and is responsible for the safe, successful and timely completion of construction, startup, and initial power generation of the projects. The Program Director accomplishes the Project responsibilities by managing and directing the Architect-Engineering Organization (AE), which is performing design;- the Construction Management Organization, (CM), which manages the I
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t g . . _ . . . . . _ . . . _ _ . _ _ . WNP - 1/4 PSAR
- 1. installation subcontrxtqr_s on_ the project; and Project Supply System person- !
nel. The Architect-Engineering Organization and the Construction Management l__ !
--_. ._.0rganizationJRay.be.&_di_ffeteflt or the same entity. _ _ . _
The organizations of the Supply System and Supply System Quality Assurance are f
-~~ -- presented-in-Figures-17.1 and 17.1-2 and 17.1-3. The functional responsi-- - .
_______ bilities _for_.the implementation of the Supply System Quality Assuranc_e Program i
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are assigned as fo1T5ws: ! _ g
.._ Corporate Organization _ . _ _ _ . . - - _ _
_ __. l
-i Ine Man' aging Directormfdhe Supply System has the ultimate responsitrility*
t% -Qualuy acuranca Ernaram. The Managing Director shall assura_that the - m program is implemented and maintained by assigning the appropriate authority' , and responsibility to the Director Licensing and Assurance at the Corporate
- - - -Leyel_and to..the_ Program _ Director at the Projeet Level. . _ . _ . _ . _ _ . . . _ ~
The Dep.J,y' Managing Director is the chief operating officer and has~ oclegated ------ ; ' - - authority to implement. policies of the Managing Director. The Deputy Managing ___ .. _ ; Director is accountable to the Managing Director and is responsible for: , ! a. coordinating and integrating the activities of Supply System organizat' ions f i I '
- ~ ~ ~ ~ - - ~ ~ ~
- b. acting f6~r the"Mahalin) Director as required . _ .. ____ __
_ ~ _ . _ c.____ supporting.and advising the Managing Director on the performance of - l Supply Systeiifunctions and evaluation of such. j
~ '
The Director df Op'e' rations reports and is accountable to the Managing Director for development implementation of policies and programs supporting the design, i
--. ~ ~ ~ ~ ~ construction and Uperational phases of Nuclear Power Project WNP-1 and the-- - - - -
i
- -. . extended construction. delay at WNP-4. The Director of Operations carr_1.es_out .
his responsibilities through the Program Directors. } The Director of Support Services reports to the Managing Director and is '___ for the development and implementation of policies and programs which suppor Fd~e'sTgnT~ construction and operation of Supply System Plants ~1n-- respons_ible. ~ ~ -
- the areas of safety and security. Areas in which the Director provides sup-port for the Projects include industrial safety and fire protection, technical' ~
training, administr_ation and security programs. The Chief Financial Officer reports to the Managing Director. and is responsi-ble for the development of corporate material management and procurement policy, and the. procurement and control of corporate, multi-project and . specialized materials and related services required to support the desipi and construction of Supply System Nuclear Power Plants. i 0
V ( l i WNP - 1/4 l' PSAR i The Technical Director reports to the Director of Operations and has responsi-bility for:
- a. Providing technical and engineering support to the Project.
- b. Assisting the Project engineering organization in providing technical direction to t.9 Architect Engineer.
- c. Assisting the Project in performing technical overview of Supply System activities.
- d. ASME Code consultation to the Project, including interfacing with ASME.
- e. Performing and managing selected technical programs, having applicability to several Projects. including preoperational environmental monitoring, and geology.
- f. Providing independent technical evaluations when requested by the
- Director of Operations. i
- g. ' Overall Supply System records management policy.
The Director, Licensing and Assurance reports and is accountable to the Manag-ing Director and is responsible for the overall development, implementation and verification of the Supply System Quality Assurance, and Nuclear Safety
- and Regulatory Programs to ensure compliance with regulations, codes and standards. These responsibilities include: ,
- a. Interprctation of ASME Code quality assurance requireu.ats and Quality.
Assurance Manual requirements.
- b. Definition, approval, revision and distribution of the Supply System Quality Assurance Manuals to ensure that the manuals adequately describe requirements.
- c. Approval of all Corporate quality affecting implementing procedures and instructions and Project Quality Assurance Instructions.
- d. Determining the adequacy and effectiveness of program implementation.
- e. . Apprising the Managing Director of the effectiveness of the QA and l Nuclear Safety and Regulatory Programs by periodic reporting of activi-- l
- ties, trends, and problems, through established corrective action systems. j i
- f. Exercising the authority vested in the Quality. Assurance organization to
' .cause the acceptance or rejection of materials _and components based on conformance verification to engineering requirements and the requirements-s of the ASME Code. f
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- WNP - 1/4 PSAR j E
9 Ensuring that Quality Assurance and Nuclear Safety and Regulatory , policies and programs provide Project Quality Assurance and Licensing Managers the freedom to inform the Director of Licensing and Assurance of : significant conditions affecting quality. Maintaining cognizance of changing regulatory requirements and providing I
- h. '
controlled interface between the Supply System and regulatory agencies so as to assure that commitment documents receive the necessary degree and ! depth of reviews prior to transmittal. j l
- i. Exercising authority to stop nonconforming work of any Supply System Contractor or Supplier organization; and notification of the Authorized [
Nuclear Inspector ( ANI) of the work stoppage for ASME activities. - l
- j. Ensuring the adequacy, clarity and appropriateness of Supply System Quality Assurance and Nuclear Safety and Regulatory oriented communica-
' tions and coenitments directed to Supply System direct contracts and the Authorized Inspection Agency.
.j
- k. Ensuring that significant conditions affecting quality or Nuclear Safety t and Regulatory Programs, which are identified by Project Quality Assur-
- ance and which are addressed to the Licensing and Assurance Directorate l for resolution, are adequately investigated and/or corrected. j
- 1. Providing licensing support functions in such areas as acquisition and !
) maintenance of nuclear power plant construction permits and operating i l licenser. : i
- m. Administering Corporate and Project Quality Assurance and Nuclear Safety !
and Regulatory Program activities.
- n. Establishment and maintenance of adequate and qualified Licensing and ,
Assurance staffing (on-site as well as off-site) levels based on work ! load analysis. Manager, Construction Quality Assurance The Manager, Construction Quality Assurance reports to the Director, Licensing .; and Assurance and is responsible for the development and implementation of the - Quality Assurance program during the Nuclear Power Plant Design and Construc-tion phases. He is also responsible for Procurement QA, plant modifications, , qualification and certification of Supply System nondestructive examination and inspection personnel, and other personnel recuiring certification; sur- ; veillance of nondestructive examination and has "nspection activities and has. ; the lead role for acquiring and maintaining ASME Certificates of Authorization. ; i The Manager of Construction Quality Assurance is supported by the following: 4
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WNP - 1/4 PSAR i I Manager, Procurement Quality Assurance l The Manager of Procurement Quality Assurance reports to the Manager of Con-struction Quality Assurance and is primarily responsible for the definition and implementation of source surveillance /eudit program for verification of activities performed by the Supply System vendors (including the Nuclear Steam Supply System vendors). l , Project Quality Assurance Manager 4 The Project Quality Assurance Manager reports directly to the Manager, Con-l struction Quality Assurance and is matrixed to the Program Director. Project Quality Assurance Manager is responsible for: .
- a. Verification of the implementation of the Quality Assurance Requirements Manual .
- b. Verifying adequate is:plementation of an approved stop work authority program and directing a stop work order should conditions so dictate.
- c. Assurance of a program for ident(fication and reporting of nonconform-ances.
- d. Verification, by audits and surveillances, that the AE, CM, selected Contractors and other Project organizations are implementing applicable quality requirements.
! e. Ensuring that adequate staffing is obtained to implement the Quality Assurance program at the Project. 4 f. The assignment of adequately trained and qualified / certified personnel to perform quality verification activities.
- g. Overview of AE/CM approval of Contractor procedures and instructions.
- h. Reporting sipiificant conditions adverse to quality to the Program Directors and the Director, Licensing and Assurance. ,
- i. Reporting Quality Assurance problems and trends to the Manager, Construc-tion Quality Assurance for use in developing standards for Quality Assur-ance management systems to preclude repetition of Quality Assurance P roblems .
- j. Approval of all Supply System quality affecting Project implementing procedures and instructions.
Manager, Audits The Manager of Audits reports to the Director, Licensing and Assurance and is responsible for maintaining an organization of qualified auditors responsible for verifying implementation of the Quality Assurance Program as follows: . 4
- e
.- = _ - - -. . - ._ . - _ _ _ .
I WNP - 1/4 j PSAR
- a. Performing Quality Assurance audits of internal Supply System organiza-tions and external organizations (e.g., AE/CM); except for Management Audits,
- b. Developing audit schedules and selecting qualified personnel to perform the activities of this function.
- c. Certification of Audit Team Leaders,
- d. Training of audit personnel,
- e. Participating in audits and providing overview of AE activities.
- f. Periodic review of Corporate and Project audit reports to identify any quality trends which may constitute a need for corrective action.
- g. Maintenance of Audit Records.
Manager, Nuclear Safety & Regulatory Programs The Manager, Nuclear Safetv & Regulatory Programs reports to the Director, Licensing and Assurance and is responsible for formal contacts between the Supply System and the Nuclear Regulatry Commission (RC) on nuclear safety issues pertaining to licensing. The hanager, Project Licensing reports to the Manager, Nuclear Safety & Regulatory Program through the Manager, Regulatory Programs and is responsible for the following:
- a. coordinating and maintaining a working interface between the Supply System and the EC
- b. managing coordinating and participating in .the preparation of all required license applications and supporting documentation
- c. maintaining a working knowledge of all pertinent regulations
- d. assuring review of and providing technical inputs to Safety Analysis Reports
- e. assuring review of regulatory guides for applicabilit,y to the projects.
Project Organization
- a. The Program Director is responsible and accountable to the Director of
. Operations for the safe, successful completion of WNP-1/4 within approved schedules and budgets. The WNP-1/4 Program Director directs overall engineering, program management, construction, and testing. Specific quality related activities are:
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WNP - 1/4 PSAR i
- b. Engineerina
- 1) Review and approve prepurchased equipment and construction specifi-
, cations (hereinafter also called equipment and construction speci- t fications or procurement documents)* and significant changes thereto, to assure that Supply System regulatory, code, and stan-dard rec uirements are included and met, and that they are techni-cally acequate. This review and approval shall be at the system or structure levels which deal with basic concepts of overall plant design and at the cogonent level for critical cogonents. Field initiated changes will be reviewed and approved if the changes ! represent a change in design. Field changes which implement ! l constructability but do not affect the basic design will generally not be reviewed and approved by the Supply System. Included in the ; l responsibility is the completion of a Comment / Resolution Form for ; initial release of a specification and a documented approval sheet ; for subsequent changes. ; t Significant changes are defined as those changes which affect the basic design. Non-Fignificant changes are those which iglement or i enhance constructability but do not change the basic design. l 1
- 2) Reviews applicable drawings for information to assure that they are i
- technically adequate and that appropriate quality control provi- l sions have been included.
- 3) Approves and/or determines the disposition of nonconforming items or material found during site activities as members of the. Noncon- ;
formance Review Board (see Subsection 17.8); j
- 4) Provides personnel to Supply System Quality Assurance 'to assist in !
vendor' surveillance activities and to perform surveillance and : audits of site contractors' and AE's home office activities, as requested. i
- Prepurchased equipment specifications and construction specifications are differentiated as follows i
Prepurchased equipment: Specification wherein the Supply System i purchases ec uipment or material directly from a manufacturer or supplier ant includes all activities through delivery to the site. ; , Construction: Specification wherein the Syply System purchases l site construction activities through a contractor. The ' specification may include a requirement for the contractor to purchase plant equipment or materials for its installation, or may
- only require installation of prepurchased equipment, or both, l
1
~, WNP - 1/4 PSAR . c. Program Management
- 1) Review and approve equipment and construction specifications, and changes thereto, to assure that the contractual requirements delineated in the bidding documents and the general and special conditions sections provide Supply System with the requirements necessary to administer the contract effectively;
- 2) Administers the contracts to assu o that activities affecting l quality are performed in accordance with the requirements specified in the procurement documents, and that when nonconformances are identified, approved corrective action is implemented in a timely f '
and effective manner. - S
- 3) Responsible for quality of the work, implementation of schedules and cost control techniques as well as implementation of the policies and overall objectives of the Supply System.
- d. Licensing
- 1) Review and approve equipment and construction specifications, and significant changes thereto, to assure that PSAR/FSAR commitments aH regulatory requirements are included and met,
- e. Plant Operations
- 1) Responsible for the review and approval of specifications, and significant changes thereto, for the operability and maintainabil-ity of the equipment, systems and structures;
- 2) Provides personnel to Supply System Quality Assurance to' assist in vendor surveillance activities and to perform other surveillance and audit functions, as requested.
- f. Construction Management
- 1) Responsible for construction contract administration to assure that activities affecting quality are performed in accordance with the :
requirements specified in the contract documents, and that when I nonconformances are identified, steps are taken to stop the noncon-forming activity and to assure that resolution is implemented in a j' timely and effective manner. 2). - Assists in verifying acceptability of contract change orders.. 3)- Responsible for Preventive and Corrective Maintenance Activities.
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l WNP - 1/4 l PSAR Major organizations to whom Quality Assurance functions have been delegated j are: ; i a) United Engineers and Constructors, Inc. (OEE) Architect - Engineer and QA Services Construction Management Services as Constructor, ASME III Div 2
- Quality Assurance Services, ASME III Div 2 ;
I b) Bechtel Power Corporation Construction Management and Q4/QC Services f r c) Babcock & Wilcox (B&W) 4 Nuclear Steam Supplier j UEE has been contracted to provide overall Architect-Engineering for { WNP-1/4. In addition, UE&C has been contracted to provide Construction Man-i agement responsibilities as Constructor, including Quality Assurance for ASME : III Div 2 related activities. As AE, UEE is responsible for generation of ! specifications for procurenent of prepurchased equipment and construction l i activities. These contract specifications are sent to the Supply System for review and approval prior to award of contracts. The administration of spec- - ifications is performed jointly by the Supply System and UE&C for prepurchased { contracts. The QA responsibility includes Home Office QA, vendor surveillance and site QA and Construction ( ASME III Div 2). (See Sections 17.2 and 17.4) l Bechtel has been contracted to provide overall Construction Management and i j Q4/QC for WNP-1/4. The Supply System and Bechtel will jointly perform the administration of construction specifications associated with WNP-1/4. (See ! Section 17.4) , B&W has been contracted to provide the Nuclear Steam Supply System which
- includes the responsibility for the QA and Quality Control activities associ-ated with their scope of supply. (See Section 17.3) !
t l 17.1.2 Quality Assurance Program - , l The Supply System QA Program described in Section 17.1 is currently in effect 3 for ongoing quality functions. Section 17.1 delineates in detail the intent ' and substance of the Supply System QA Program. The Supply System Program is - l based upon the Quality Classification as assigned to the structures. compon-ents, and systems in Tables 3.2-1 and 3.2-2. Structures, components, and : ! systems are classified as Quality Class I, II and G in accordance with their design basis or functional requirements. The applicable requirements of Appendix B to 10tJR50 are applied to those items classified as Supply System , Quality Class I due to their relationship to a nuclear safety function. Those l l items classified as Supply System Quality Class II or 6 are not safety related and are not subject to the requirements of Appendix 8 to 10CFR50. Supply i System Quality Class II or G are required to meet applicable commercialistan- ! dards . The Supply System quality assurance classifications are as follows:- t l t w ,-e.m g si qe e __. 9.qge- .m .w- v* y,--6 _- ,-m,w. y- e-'w ,-
l . WNP - 1/4 i PSAR Quality Class I - Any nuclear structure, system, subassedly, conponent ) ! or design characteristic that prevents or mitigates the consequences of a postulated accident that could cause undue risk to the health and safety , of the public. All safety-related items fall within this category. 1 The Sipply System QA Program defines non safety-related items as follows: i ! Quality Class II Augmented - The liquid radioactive waste system and 4 those portions of the solid radioactive waste systems which contain ,
- liquid waste.
I i Quality Class G Augmented - Those portions of the fire protection system protecting safety related equipment or protecting areas which contain ' potential fire hazards to safety related equipment. l Quality Class II - Any structure, system, subassedly, component or i design characteristic which, as a result of being defective, could cause - ! a safety hazard to plant personnel, an extended reduction in unit output, j an unscheduled unit trip, or equipment damage. 4 j Quality Class G - Any non-nuclear portion of the plant to which QA
- requirements am assigned in accordance with the consequence of failure
! and operating costs. If necessry, Quality Class 6 can be upgraded to i Quality Class II. l The Supply System Quality Assurance Program Manual contains the written j policies and procedums structured from the requirements of ANSI N45.2-1971
- and 10CFR50, Appendix B by which the Supply System performs its mlated j quality assurance activities. A matrix of the Supply System QA Program proce-1 dures and the corresponding criteria of 10CFR50, Appendix 8 appears in the j table below followed by description of the scope covered by these procedums, i
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,. , . , - - -' e - - - - - . . ,
WNP - 1/4 PSAR 10CFR50, Appendix B Criteria Supply System QAR I Organization QAR-1 II Quality Assurance Program QAR-2 III Design Control QAR-3 : l IV Procurement Document Control QAR-4 V Instructions, Procedunes and Drawings QAR-5 VI Document Control QAR-6 VII Control of Purchased Material, Equipment QAR-7 and Services VIII Identification and Control of Material, QAR-8 Parts and Components IX Control of Special Processes QAR-9 X Inspection QAR-10 XI Test Control QAR-11 XII Control of Measuring and Test Equipment QAR-12 XIII Handling, Storage and Shipping QAR-13 XIV Inspection, Test and Operating Status QAR-14 XV Nonconforming Materials, . Parts or Components QAR-15 XVI Corrective Action QAR-16 XVII Quality Assurance Records QAR-17 XVIII Audits' QAR-18 l 1 l l 1
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l WNP - 1/4 ! PSAR l
- a. Organization. QAR-1 l l
Establishes an organizational structure that will direct the resources of i the Supply System and its contractors to engineer, design procure, fab- , ricate, manufacture, install, construct and test the Supply System l Nuclear Projects to maximize safety, reliability and efficiency. j P
- b. Program. 04R-2 i l
t Defines the Quality Assurance Program established by the Supply System i for design and construction. Included in this program is a system for ) classifying structures, systems, couponents, design characteristics and ! procurement documents to determine the Quality Assurance activities l associated with each ites. ,
- c. Design Control. QAR-3 Establishes a system of independent reviews to assure applicable quality 4
regulatory, code and design basis requirements are properly translated , into design and procurement documents for each structure, system and l component. The documented review provides a check for design adequacy, inspectability and compatibility with intended usage.
! d. Procurement Document Control QAR-4 l Establishes a system to assure that procurement documents and changes f thereto incorporate the technical and quality assurance requirements i necessary to assure the quality and integrity of procured material, !
equipment and services, j
- e. Instructions. Procedures and Drawings QAR-5 Establishes system defining the re4Jirements and responsibilities con- l trolling the preparation, review, approval and release of instructions, !
procedJres and drawings which implement quality requirements. !
- f. Document Control. QAR-6 :
Establishes a system to control the issuance of documents, including l changes thereto, which prescribe activities affecting quality, j l g. Control of Purchased Material, Equipment and Services 2 QAR-7 Establishes a systen to assure material, equipment and services are procured in accordance with the requirements specified in the procurement > documents. . j 1 ! l I L
- a. _ ___ _ _
. . u__ _ _ _ ._ _
k-8 WNP - 1/4 (' PSAR i
- h. Identification and Control of Materials, Parts and Components, QAk-8 Establishes a system for the identification and control of material, !
parts, components, equipment and partially coupleted assemblies to assure ; that item incorporated into the plant are of proper configuration and, l when necessary, traceable to all supporting quality assurance documenta- ! tion. ,
- i. Control of Special Processes QAR-9 l Establishes ,a system for the control of special processes. f l
- j. Inspection, Q4R-10 ;
Establishes a' system which assures the program requirements for inspec-tion are delineated in the specifications and contracts and assures that i inspection and surveillance activities are performed in accordance with j pre-determined requirements delineated in written instructions in a ! planned and systemacic manner. l
- k. Test Control. QAR-11 Establishes a system to assure that plant testing activities are per- !
formed in accordance with pre-determined requirements, approved and delineated in written instructions. i 1. Control of Measurina and Test Equipment, QAR-12 Establishes a system for the control, calibration and adjustment of ' tools, gauges, instruments and other inspection, measuring, testing and - maintenance devices at specified periods to assure the useage of proper. type, range and accuracy necessary to verify conformance to established i requirements.
- m. Handling, Storage and Shippina. QAR-13 E
Establishes system to control the handling, storage, shipping, cleaning . and pmservation of material, parts, components and equipment in' accor- I dance with writtan and approved procedures, instructions and recommenda-tions,' to assure that the designed integrity and functionality of the
~1 tem are enintained.
- n. Inspection, Test and Operating Status. QAR-14 Establishes a system to indicate the inspection, test and operating' status for all structures, system or components to preclude-the inadver- !
tant bypassing'of their inspection and test requirements and to prevent '; their inadvertent operation. I.
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n-WNP - 1/4 j . PSAR , 1 ,, l o. Nonconforming Material. Parts or Components, QAR-15 i Establishes a system to assure that nonconformar.ces are identified, docu-i mented, segregated or otherwise controlled, prevented from inadvertent i use or installation and that notification of actions taken is transmitted to the affected parties, i p. Corrective Action. QAR-16 l . l Establishes a system to assure that significant conditions adverse to
- quality are identified, the cause determined, documented, brought to the
- attention of upper management, corrected as soon as possible and that i measures are taken to preclude repetition.
1-
- q. Quality Assurance Records. QAR-17 j Establishes a system for the control and maintenance of all . records
- sufficient and necessary to provide objective evidence of the activities
! affecting quality.
- r. Audits. QAR-18 j Establishes a system of audits to be performed-in a planned and' systema-
; tic manner to verify cogliance and effectiveness of the Supply System
- . Quality Assurance Program.
I The Seply System Quality Assurance Program was in effect during the prepara-i tion of the PSAR. i ! S@ ply System Quality Assurance is responsible for establishing Quality Assur-ance policy goals, and objectives through the development and administration j of tFo Supply System QA Program. Tnis program is defined in the Supply System 1 QA Program Manual. developed by the Manager, Construction Quality Assurance, ) and reviewed and approved by the. Director, Licensing and Assurance and q l endorsed by the. Managing Director. , 1 i Supply System QA personnel have the authority and responsibility to perform , an.y actions necessary, including Stop Work Authority, to acconplish their- ., . mandate as delineated in the Quality Assurance Manual. This responsibility-3 and authority is stated in a Management Statement signed by-the Supply System i Managing Director. The Management Statement appears in each Quality Assurance . < t Manual, and is included as_ Figure 17.1-4. In matters of confliet regarding -
- Quality Assurance policies or the Quality Assurance organizations' authority to i enforce them at the working level, the Director of Licensing.and Assurance hasi .
l i direct access to all levels of upper management including the Managing Direc- . tor for satisfactory resolution. .
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- PSAR
- To assure that Supply System personnel performing quality related activities ) are knowledgeable of procedures and requireme.1ts, and will be proficient in f implementing them, the Supply System Quality Assurance Training Program under ! coordination and direction of Corporate Licensing and Assurance is established and documented as required by the applicable Supply System Quality Assurance ! Training Procedure and implementing instructions. This Training Program consists of:
- a. The initial formal training and orientation one receives as to the purpose, scope and implementation of applicable codes and standards, including 10CFR50 Appendix B. This initial training phase also includes specific detailed instruction on the Supply Systm QA procedures and instructions, project specific procedures and other activities which
- directly relate to the employee's job functions. Supply Syste super-visory persomel also indoctrinate and train personnel performing quality i related activities in the principles and techniques of the activity being performed.
I b. on-going instruction by lecture, discussion, and pre-planned presenta-tions, supplemented by outside courses as deemed useful. In addition to the training delineated above, Quality Assurance personnel will , receive training to provide the with an understanding and appreciation of the management of an effective Quality Assurance program. QA personnel will receive orientation and indoctrination to position responsibilities, and to
- applicable codes and standards. This training may be agmented by both inhouse training and attendance at appropriate industry sponsored training sessions, the extent of which will be determined by an evaluation of the prior l
QA experience and knowledge of the exployee, and the comparative requirements of the current QA position. After this training has been completed, such idividuals will be assigned initial work under the direction and guidance of-i qualified, experienced personnel (e.g., Lead Auditors) and will receive'
- on-the-job training to establish and maintain proficiency.
The Supply Systeo position on RC Regulatory Guide requiremets is stated in Section 3.12. These requirements are verified as being included in the design specification during the design review process described in Subsection 17.1.3. The Supply Systa QA Program will comply with the requirements contained in
- 10CFR50, Appendix B, and will comply with the guidance contained in the Supply System positions (Section 3.12) for EC Regulatory Guides, the' RC's Gray i Book, " Guidance on Quality Assurance Requirements During Design and Procurement Phase of Nuclear Power Plants-Revision 1", and the EC's Green .
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Book, " Guidance on Quality Assurance Requirements During the Construction Phase of Nuclear Power Plants". The Supply _ System QA Program's. scope, implementation, and effectiveness is 4
. audited by the Corporate Office audit organization. Copies of all audit raports and correspondence are routinely routed to Supply System Project
. Management, and. Project Quality Assurance so that management can regularly j.
assessithe effectiveness of the. Quality Assurance Program. a ;
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WNP - 1/4
'PSAR Additionally, on an annual basis, management will arrange for an independent lL audit and evaluation of the adequacy of the scope, inplementation, and effec-E tiveness of the Supply System QA Program. This will be accomplished by knowl-edgeable personnel outside the Quality Assurance Organization to assure i L achieving an objective program assessment. Results from this independent review will be reported to the Managing Director.
The Supply System requires its Quality Class I contractors, including UE&C, Bechtel, and B&W to establish and implement Quality Assurance Programs consis-tent with the applicable Criteria of 10CFR50, Appendix B. The Quality Assur-ance programs of UE&C, Bechtel, and B&W are reviewed for coupliance with Appendix B by the Supply System. Quality Class I contractor's Quality ' Assurance programs are reviewed for compliance with Appendix B by UE&C and Bechtel, as appropriate. The details of the UE&C, Bechtel and B&W QA Program are described in Sections 17.2 and 17.4, and 17.3 mspectively. 17.1.3 Design Control The Supply System has organized, and is following, a system of design review. and approval by QA, Engineering, Licensing, Operations, and Project Management of Supply System and UE&C generated procurement documents for Supply System Quality Class I systems, structures, subassemblies, components and design characteristics. UE&C Engineering has been assigned the responsibility to review the remaining design contractor's procurement documents. In all cases, prior to submittal to either the Supply System or UE&C for ' review and/or approval, the design contractors, including UE&C, are responsi-ble for verifying that the design meets the requirements of the specification, is commensurate with good. design practices and that the components can be ~ readily insoected. This verification is achieved by the performance of design reviews, the use of alternate or sinplified calculation methods, or by the performance of a suitable testing program. The verification or checking process is performed by individuals or groups other than those who performed the original design. Were a test program is used to verify the adequacy lof.a specific design feature in lieu of other verification or checking processes, , it includes suitable qualification testing of a prototype unit under the most. i adverse design conditions. Design control measums are applied to items such as the following: reactor physics, stress, thennal, hydraulic, radiation, and , accident analysis; conpatibility of material; accessibility for inservice inspection, maintenance, and repair; and the delineation of acceptance criteria for inspections and tests. Supply System Project Engineering has the primary msponsibility for the tech-nical review and ' approval of. Supply System and UE&C generated prepurchased equipment- and construction specifications. - Each discipline, mechanical, j ! . electrical, ' nuclear, and civil reviews the specifications to assure they are .
- technically adequate. -The depth of this review is outlined in an engineerin l design review check list utilized by the reviewing engineer for each Supply:g 1
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l 4 i . WNP - 1/4 PSAR l System Quality Class I spacification. The design review check list outlines a review of: 1) design requirements, including the appropriate section of the , PSAR and referenced Regulatory requirements; 2) codes and -standants require-ments; 3) classification of characteristics; 4) materials selection adequacy;
- 5) testing requirements; 6) welding requirements; 7) identification and serialization; and, 8) preservation, packaging, and handling.
Supply System Licensing reviews and approves the specifications to assure l conformance to PSAR/FSAR and other regulatory requirements. 4 Supply System Operations myiews and approves the specifications to assure that the item being specified can be inspected, operated and maintained. Supply System Project Management reviews and approves the specifications to assure that the general and special conditions sections contain adequate mquirements for contract administration. Supply System QA reviews and approves the specifications to assure that ade- ! quate requirements are included in the specifications. The QA review assures j that: 1) the specifications contain the necessary QA requirements; 2) the test and special processes are prop'erly identified and contain appropriate-acceptance /mjection criteria; 3) codes and standards are correct; 4) Quality. ' Classifications are identified; and, 5) the applicable generic sections of welding, cleaning, and packaging are included. S@ ply System QA signs the Design Review Route Sheet to indicate review of Comment Issues, and signs the Comment Issue Approval Sheets after assuring the QA requirements are included and that the specifications have been through the i required Supply System design review. (See Subsection 17.1.3.1) Design changes, including field changes, am subject to design control measums commensurate with those applied to the original design and are approved by the organization that performed the original design unless the Supply System has designated another responsible organization. Documentation pertaining to design control'of S@ ply System Quality Class I procurement documents will become part of the objective evidence of the quality of the applicable items, and will be filed and_ maintained in a trace-able, mtrievable, systematic manner. The details of the' design control measures implemented by UE&C and B&W are described in Section 17.2 and 17.4, and 17.3 mspectively. The Supply System QA Program requires that Supply System and UE&C generated l procumment documents be reviewed and approved to verify that requirements have been included which provide for the development and implementation of.a Quality Assurance Program for Supply System Quality Class I items and activi-ties which .specifically comply with 10CFR50, Appendix B criteria.- In addi-
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the contractors and vendors of Supply System Quality Class -I items and tion,ities activ are required to have Quality Assurance Prograss which comply with ANSI N.45.2-1971 and ~ additional requirements as' delineated in the procurement documents.
I WNP - 1/4 l
- PSAR 1 The procurement documents specify that the contractors and vendors of Supply System Quality Class I items and activities develop and inplement design and interface control procedures which assure: ;
- a. The translation of regulatory requirements and design bases correctly ir?.o the design documents;
- b. The incorporation of appropriate quality standards with deviations and changes being controlled;
- c. The application of design control measures to such items as: reactor physics, stmss, thermal, hydraulic, radiation, and accident analysis; compatibility of materials; accessibility for inservice insnection, maintenance, repair; and specifying criteria for inspectiot and test;
- d. That proper selection and accomplishment of desion verification or check-ing methods such as design reviews, alternate calculations, or qualifica-tion testing is performed. litere a test program is used to verify the adequacy of a design, a cualification test of a pmtotype unit.under the most adverse design conditions will be used;
- e. That individuals or groups msponsible for design verification or check-ing are other than those who performed the original design;
- f. Design and specification changes, including field changes, are subject to the same design controls that were applicable to the original design;
- g. Design documents and revisions themto are distributed to responsible individuals in a timely manner and controlled to prevent inadvertent use of swerseded material;
- h. Errors and deficiencies which adversely affect safety related structures, .
systems and couponents in the design process are documented and that appropriate corrective action has been taken;
- i. Design documents, design reviews, records, and changes themto are collected, stored, and maintained in a systematic and controlled manner;
- j. Standard "off the shelf" commercial or previously approved materials, parts, and equipment (that are essential to the safety related functions -
of the structures, systems, and componenets) are selected and reviewed-for-suitability of application. 17.1.3.1 Supply System or UE&C Generated Specifications and Drawings - Swply System or UE&C Engineering prepares Client Comment, Revised Client Comment and Bid Issues of specifications for WNP-1/4.in accordance with all applicable Codes and Standards and QA Procedures utilizing engineering data generated from Technical Memorandums, Project Criteria Documents, PSAR commit-ments and/or Supply System requirements. Calculations and ' specification data ~ are independently reviewed and checked by engineers .experier ad in the appro-priate engineering discipline.
i WNP - 1/4 . PSAR L Supply System or UE&C Engineering prepams specifications and associated draw-ings which are reviewed and approved internally. The Client Comment Issue of the specifications are then sent to the Supply System for review and approval. Client Comment Issues are received by the Supply System and are assigned to a l Reviewing Engineer. Copies of the Client Coraent Issues are also assigned to ' Supply System QA, Licensing, Operations, and Project Management. Each disci-pline reviews the specification .in accordance with the Supply System design review procedums and checklists. The Reviewing Engineer is responsible for the overall review, obtaining signoffs from the reviewers, preparation of the Comment / Resolution form for resolution of comments. For UE&C prepared speci-fications the form is transmitted to UE&C for resolution; for Supply System prepared specifications the form remains with the Reviewing Engineer for resolution. Pages and drawings which are affected by the Supply System review are cor-rected and issued as a Revised Client Comment Issue. This document is , reviewed to assure that comments have been resolved and incorporated based on ' the Comment / Resolution form. The original Supply System reviewers' acceptance l 1 is secured on comments which have been rejected. Rejections which am 1 unacceptable to the Supply System will be resolved and so noted on the Comment / Resolution form. i A Bid Issue is then prepared and sent to the Supply System for final approval. The Reviewing Engineer reviews the Bid Issue. The final Supply System approval is indicated by the signature of the Supply System Program Director on the Bid Issue Approval Sheet. 17.1.3.2 Contractor and Vendor Generated Drawings and Specifications een a contractor or a vendor initiates a design he is required to perform
, design review activities in accordance with internal design review proce-dums. Upon coupletion of this review his design drawings and specifications are forwarded to UE&C Engineering for interface review.
UE&C conducts a review of the drawings and specifications in accordance with
, UE&C procedures which includes measures to control the receipt, approval, and. l transmittal of vendor drawings, and an approval of the proce&ms and specifi- l cations required to be submitted to UE&C in .accordance with the procurement -
documents. l
, The receipt of vendor drawings, specifications and other documents is acknowl-i edged to the Supply System staff via a transmittal which lists 'and describes the material received. Supply System personnel review the attachrents to these transmittals on a selective basis and transmit any comments to UE&C for-inclusion in the document.
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! WNP - 1/4 PSAR 17.1.4 Procurement Document Control
( i All procurement of materials, parts, components, and construction activities for WNP-1/4 is accomplished through prepurchased equipment and construction
. specifications and contracts prepamd by the Supply System, or UE&C for the
- Supply. System. Purchasing is accouplished by award of contracts by the Supply System Board of Directors and The Executive Coinnittee Personnel based on
- j. proposals su%itted in conformance with the specifications.
! Each proposal is evaluated by the Supply System and UE&C. The evaluations include any exceptions taken to the specification requirements. , ; The Supply System @ Program requires that Supply System and UE&C develop and j implement measums which assure that procurement documents are prepared, i reviewed, approved and issued under controlled conditions. These control ! measures have been established and are currently in effect. These measums
! are described in Subsection 17.1.3. In addition, addenda issued prior to bid l opening require a review and approval commensurate to the performed on the
- original procurement document.
i l The Supply System @ Program mquires that Supply System and LE&C generated i procurement documents be reviewed, and approval sheets signed off by Supply i System @ personnel. These reviews verify the inclusion of applicable or zational, program, design control, procurement control, document control,gani-
! identification, special process, inspection, testing, calibration, handling, j storage, shipping, nonconformance control, corrective action, record reten -
i tion, record control, record maintenance, audits acceptance / rejection criteria and other quality requirements. The procurement documents require that con-tractors and vendors of Supply System Quality Class I itens have a QA Program j which meets the applicable requirements of 10CFR50, Appendix B and ANSI-. N45.2-1971. ! In addition, the Syply System @ Program requires th'at Syply System and UE&C i generated procurement documents be reviewed, and approval sheets signed .off by-l Syply System, and UE&C (if UE&C generated) Engineering personnel. These j reviews verify the inclusion of applicable design, regulatory, code, material, testing, metal joining, part identification, spam parts, cleaning, preserva- l t tion, packaging, handling, storage, shipping, installation and other. design ,
- and procurement related requirements.' j I
j The Syply System is responsible for the orientation and training of personnel
- performing quality affecting activities. - The Supply System QA Program l
requires that Sgply System personnel performing quality functions be ade-cuately qualified, thus-providing a mechanism to assure that personnel review-ing procumment documents are sufficiently knowledgeable to verify that proper-quality m1ated requirements have been incorporated. I l t
; WNP - 1/4
- PSAR i
The review and approval of Supply System and UE&C generated procurement docu-ments is documented by the Supply System. This documentation consists of approval sheets, comment / resolution sheets and applicable correspondence. 4 This objective evidence is filed and maintained in a controlled, traceable, j retrievable systematic manner. i Documentation requirements are specifically delineated in the procumment . documents indicating to the bidders, contractors and vendors which documents must be submitted for information or approval.
- Procurement documents include requirements which assure the right of access by
- S@ ply System and/or UE&C personnel to the contractor's operations or the
- vendor's facilities, and their records. QA requirements are incorporated in
- _ procumment documents in accordance with their Quality Class and couplexity.
j Bidders on Supply System Quality Class I documents are required to submit with i their bids a comprehensive QA Plan describing their QA system, policies, t responsibilities and procedums which will be, or are being, inplemented to i control quality throughout all phases from design to final shipment, erection, fabrication, installation, testing or startup, as applicable. t j After bid openings and prior to contract award, bids are reviewed by Supply , i System QA and Engineering Department personnel with assistance from UE&C'Home ' i Office QA and Engineering Department personnel to detensine the acceptability
- of the bidders' QA programs. This evaluation consists of an examination of
, their QA Plan, evaluation of past quality performance based on previous exper-
- ience with Supply System, UE&C, and industry experience, and if a reasonable j judgment cannot be made or the importance of the activity tequires a QA evalu-j ation of the vendor's facilities or contractor's operations, then a QA evalua-i tion will be performed. After completion of the documented bid evaluation, j the Program Director is notified as to the acceptability of the bidder's QA 1 program based on his demonstrated ability of commitment to meet the procure-
! ment document requirements. i j The details of the procurement document control measures implemented by UE&C l and B&W are described in Sections 17.2 and 17.4, and-17.3 mspectively. l 17.1.5 Instructions. Procedures and Drawings i i The Supply System QA Program Manual' delineates the methods by which the Supply i System complies with the criteria of 10CFR50, Appendix B. Implementation of l the Supply System QA Program assures control of the activities affecting l quality. The Supply System QA Program requires UE&C and Bechtel to have based the i development of their QA Program, and the procedures for its iglementation, on the requirements delineated in 10CFR50, Appendix B. UE&C generated procure-I ment documents require that instructions,: procedures and drawings relative to the work being performed will be maintained.in the general work' area and available for reference by the personnel performing the work. _ _ . - _ _ _ . . - _ ___-___.u . _ _ _ _ _ . _ _ . _ - . . . - + . .-~_m_. - _ .. . . . . , . . . _ . , , _.,,.v
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.i Contractors and vendors, including UE&C, Bechtel and B&W, am required to have written instructions, procedures, policies and/or drawings which govern their quality related activities and wnich include appropriate quantitative and qualitative acceptance / rejection criteria. In addition, contractors and vendors, including UE&C, Bechtel and B&W, are required to impose similar docu-mentation requirements on their s@ contractors.
The details of the measures which UE&C, Bechtel and B&W implement to assure the development and issuance of instructions, procedures and drawings are . described in Sections 17.2 and 17.4, and 17.3 respectively. , 17.1.6 Document Control
- ~
Document control is implemented by the Supply System, UE&C, Bechtel and B&W in accordance with the requirements delineated in their respective QA Manuals. These requirements provide measures to assure that appropriate written instructions, procedures, policies, drawings, and procurement documents including changes thereto, are properly reviewed and approved prior to release by personnel assigned review and/or approv:'1 authority as delineated by the QA Program. Changes to these applicable documents require a review and/or approval commensurate to that performed on the original document. These. reviews and/or approvals verify the inclusion of adequate quality _ mquirements - and evaluate the impact of the changes on other project activities. Addi-tionally, issuance of controlled documents is performed by personnel assigned distribution authority as delineated by the QA Program. This controlled issuance is designed to distribute controlled documents in a timely manner to the locations where the applicable activity is being performed and to prevent the use of obsolete or superseded documents. The Supply System QA Program provides for the controlled @ dating of the Supply System QA Program Manual through a process that specifically mquires holders of a controlled copy of the Supply System QA Program Manual' to destroy or return superseded documents. Procurement documents generated by the Supply System,- UE&C, Bechtel and B&W i require that contractors and vendors, including their s@ contractors, of Supply System Quality Class I items have document control procedures in ac:or-dance with 10CFR50, Appendix B. The Supply System Q4 Program document control measures, as delineated in the procurement documents, requims that quality related documentation be-avail-able prior to the performance of the activity to which 'they relate. The Supply System QA Program document control measures pertain as-a minimum to contract specifications, contract drawings,- QA Program Manual procedures, operating procedures, quality related instructions and various process, test' and inspection procedures as delineated in the contract specifications.- t The details of the document control measures implemented by UE&C, Bechtel and -
~
- - B&W am described in Sections 17.2
- and 17.4, and 17.3 mspectively.
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] 17.1.7 Control of Purchased Material. Equipment and Services As described in Section 17.1.4, procurement for WNP-1/4 is accomplished { through procurement documents. These documents contain. sections which l describe the general conditions, special conditions and technical specif.ca-l_ tions which the contractor is required to meet. The requirements of the i general conditions,- special conditions and technical sections are to assure { that purchased material, equipment and services, whether purchased directly or ; j through contractors, conform to design requirements. Measures to control i these activities include a review and approval of procurement documents by j Supply System; source evaluation and selection, vendor surveillance, inspec-j tions, and audits by Supply System and/or UE&C; and receiving inspection of j these items upon receipt at the site. Specifically, QA requirements are incorporated in procurement documents in ! accordance with their quality class and coglexity. Bidders on Supply' System j Quality Class I documents am required to submit with their bids a cogrehen-l sive QA Plan describing their QA systems, policies, msponsibilities and 4 procedures which will be, or are being iglemented to control quality through- l out all phases, from design to final shipment, erection, fabrication, instal-lation, testing, or startup, as applicable. j The Supply System OA Program requims that surveillance of contractors and
- _ vendors be per1'orar,c in accordance with written procedures, and that surveil-
- lance activities u pl:nned and designed to verify and document that the l contractors and vendors are conforming to the requirements of the procurement j document.
i ! In addition, the Supply System QA Program requires that receiving inspection i of items at the site be performed in accordance with written procedums, and i that receiving inspection activites be planned and designed to verify and j document that the material, equipment, or component being received conforms to the requirements of the procurement documents and that the required documenta-l tion is available at the site prior to installation or use. 1 ! The Supply System QA Program mquires that received items will be stored and l handled on a controlled basis with nonconforming items being processed in accordance with the requirements described in Sssection 17.1.15. Documentation pertaining- to the control of purchased material, equipment, and services will become part of the objective evidence of the quality of, the j
- applicable items, and will be filed and maintained in a traceable, mtriev- i f
able, ' systematic manner. The details of the measures which UE&C, Bechtel and B&W iglement to assure the control of purchased material, equipment and services are described in
- Section 17.2 and 17.4, and 17.3 respectively.
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. WNP - 1/4 PSAR 17.1.8 Identification and Control of Materials. Parts and Components The Supply System @ Program requires that Supply System and UE&C generated procurement documents be reviewed and approved to verify that requirements have been included which provide for the development and implementation of measures.for the identification and control of materials, parts, and coupon-ents. In addition, these reviews and approvals assure that identification and matting requirements have been adequaaly delineated and that the location and 4
method of identification and marking do not adversely affect the function or quality of the subject item. The requirements dich are incorporated into the procurement documents provide for a positive system of identification and control of materials, parts, com-ponents and partially conpleted subasseelies while in storage, warehousing and holding areas and during their fabrication, manufacturing, installation and construction. These identification and control measures establish a means by Wich item can . be traced to, and conformance verified, with their applicable documentation. Verification that the items have been properly identified is to be performed
& ring vendor surveillance activities prior to shipment of the items. Identi-fication is further verified during receiving inspection at the site to assure -
that identification status was -not adversely affected during shipping and to provide a verification check if the vendor surveillance ver'fication check was waived. Documentation pertaining to the identification and control of materials, parts f and components will become part of the objective evidence of the quality of
- the applicable ites, and will be filed and maintained 'in a traceable, retrievable systematic manner.
L' The details of the measures which UE&C, Bechtel and B&W implement to- assure the identification and control of materials, parts, and components are described in Sections 17.2 and 17.4, and 17.3 respectively. 17.1.9 Control of Special Processes , The Supply System @ Program requires that Supply System & UE&C generated procumment documents be reviewed and approved to verify..that requirements t have been included which provide for the development and inglementation of l measums for the control of special processes. These requirements specify applicable codes, ' standards, specifications and any special requirements
.necessary for the control.of the delineated special processes.
In addition, the procurement documents specify that special processes will be performed and controlled in accordance with written proce&res and will I further delineate which special processes procedures will be submitted to UE&C for infor ation or approval.
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i WNP - 1/4 PSAR The procurement documents will require that procedures be developed to control such special processes as:
- a. Welding ,
- b. Cleaning , j
- c. Heat Treating l'
- d. Nondestructive Examination
- e. Repairing +
l Essential ingmdients of these procedures shall assure that: ,
- a. Equipment utilized in the perforance, inspection, and control of special processes that require qualification shall be qualified to its intended l usage prior to being installed or used. '
)
- b. Personnel performing any special processes shall be qualified in accordance with applicable standards prior to the performance of work,
- c. Data collected in conjunction with the control of special processes shall include the type of operation, msults, acceptability, action taken when deficiencies were noted, and the identification of inspector and/or data recorder.
Special processes procedures, qualification documentation, inspection and test results will become part of the objective evidence of the quality of the applicable item, and will be filed and maintained in a traceable, retrievable, systentic manner. The details of the measures which UE&C, Bechtel and B&W iglement to assure the control of special processes are described in Sections 17.2 and 17.4,~ and 17.3 respectively. 17.1.10 Inspection The Supply System QA Program requires that Supply System & UE&C generated procurement documents be reviewed and approved to verify that requirements have been included which provide for the development and iglementation of inspection measums. These requirements specify that inspections will be performed by personnel who am independent from the individual or group ' responsible for performing the activity being inspected. In addition, the procurement documents specify that inspection activities will be performed and controlled in accordance with written proce&ms, instruc-tions and/or checklists. These procedures, instructions and/or checklists am required to provide for:
- a. The identification of quality characteristics to be inspected..
i b. The identification-of those indivi&als or the organization msponsible for performing the inspection operation.
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WNP - 1/4 PSAR
- c. Acceptance / rejection criteria.
- d. A description of the method of inspection.
- e. Evidence of completion and certification of inspection operation.
- f. Record of the results of the inspection operation.
The procurement documents fu:-ther require that procedures, instructions, and drawings relative to the work being performed will be maintained in the work , area and available for reference by the personnel performing the work. l f Contractors and vendors are required by the procurement documents to specify the qualification requirements for inspection personnel, and to assure that L each inspector's qualifications are maintained current. The contractors and vendors are further required to perform inspection of modifications, repairs and replacement items, which are made after the initial inspections, in a manner commensurate with the original inspection requirements or to Supply System and/or UE&C approved alternatives. Inspection equipment is required to be calibrated as described in Subsection 17.1.12. ~ UE&C has been delegated the responsibility to perform source inspection activ-ities associated with prepurchased items, and site construction surveillance of ASME III, Division 2 activities. Bechtel has-been delegated the responsi-I , bility to perform site receiving inspection of prepurchased items, and site construction surveillance activities. In addition, Supply System Project Quality Assurance performs surveillance of the activities performed by Supply System site organizations and the AE/CM with sufficient sampling of the ' contractors to provide assurance that the applicable quality requirements are being implemented. Pre-surveillance planning developed by responsible' organi-i zations will define surveillance requirements, acceptance criteria. and-provide docounted results to provitie objective evidence that the particular quality characteristic inspected actually conforms to the specification requirement. Source inspection will be accomplished by the UE&C vendor surveillance group from inspection plans developed by UE&C from the procurement documents. This- ; inspection will assure adequate control of processes to assure that required quality is obtained when inspection is not possible or disadvantageous. ' Surveillance data sheets will become part of the objective evidence of the . l t ! quality of the applicable. items inspected, and will be filed and-maintained in a traceable, retrievable, systematic manner. The details of the inspection measures and/or surveillance activities imple-mented by UE&C Home Office, the applicable Project QA organization and B&W are described in Sections 17.2'and 17.4, and 17.3 respectively.. 1
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4 l . ! WNP - 1/4 PSAR l 17.1.11 Test Control l ) l' The Supply System QA Program requires that Sgply System and UE&C generated j j procurement documents be reviewed and approved to verify that the test
- requirements which are required to be performed by vendors and contractors are specified. The test requirements include adequate test prerequisites, 3
instructions for testing, proper instrumentation, documentation, and evalua-
- tion by qualified, msponsible individual or- group. The procurement documents j require that testing be performed in accordance with written procedures,
- instructions and/or plans which define the overall inspection and test ^
j requirements, the acceptance / rejection criteria and data to be recorded. i. 1 The Supply System QA Program further requins that site testing be monitored in accordance with testing inspection plans which provide for:
- a. An itemized list of the status identification system to be egloyed (i.e., tags numbering system).
i b. An itemized list of the documents to be reviewed or referenced to verify ' the. testing and inspection status of the system or cogonent to be tested.
- c. An itemized list of the tests to be performed. t I d. An itemized list of the testing devices to be utilized.
i l e. A detailed list of acceptance criteria together with adequate space to reflect actual msults. j Construction testing will be performed by the contractors to ensure that the i installation of equipment is done in- accordance with applicable codes and j standard s. These tests include inspection of the equipment during and 3 following installation, integrity tests to verify proper installations, and. ! tests, and inspections to verify cleanliness. i The contractors will be required to iglement Inspection and Test Plans which j define overall inspection and test requirements, criteria for acceptance, and 4- data to be recorded. These plans shall be approved by the Supply System.
- Integrity tests, i.e. hydrostatic, continuity,. resistance, etc. and cleanli-j ness tests will be pe-formed in accordance with Supply System approved proce-
- dures. The contractor will be required to-provide control of installed equip-1 ment in accordance with Supply System equipment-tagging procedJre.
- Upon j- cogletion of contractor installation and testing of a given system, all i associated inspection and test records will be turned over to Bechtel and the '
! Supply System for review and concurrence with results. System inspections _w ill be performed by the Supply System to ensure that equipment is installed , in accordance with design requirements and that the system installation is - coglete. Following resolution of any discrepancies, contractor tags will-be removed, Supply System tags installed, and control of the system will. then be transferred .to the Supply System for functional-testing purposes. . Contractor - i test documentation will become a part of the overall permanent' plant testing. records. b
* -,,.-a , - - - . , , . . , , , - - . ~ . - , , , , . . , . .,. ,
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WNP - 1/4 PSAR Test control documentation will become part of the objective e idence of the quality of the applicable item tested, and will be filed and inaintained in a traceable, mtrievable, systematic manner. The details of the test control measures iglemented by UE&C, Bechtel and B&W are described in Section 17.2 and 17.4, and 17.3 mspectively. 17.1.12 Control of Measurina and Test Equipment - The Supply System QA Program regires that Supply System & UE&C generated procurement documents and Supply System calibration procedures be reviewed and l j approved to verify that requirements have been included which provide for the development and iglementation of measures to control measuring and test equipment. These requirements specify that:
, a. Contractor's and vendor's procedures will describe the calibration tech-nique, calibration frequency, maintenance and control of all . measuring and test instruments, tools, gauges, fixtures, refemnce standants, transfer standards, and non-destructive examination equipment which are to be used in the measurement, inspection, and monitoring of cogonents, l systems, and structures.
- b. Allowable deviations from calibration standants (tolerances) will be specified in the contractor's and vendor's procedums and submitted to the Supply System and/cr UE&C for approval.
- c. Inspection, measuring, testing and maintenance devices are calibrated and adjusted at scheduled intervals against certified standanis having known valid relationships to national standards, when such standards exists,
- d. Calibration intervals for each device are based on the type of equipment, >
required accuracy, intended usage, and other conditions affecting inspec- ; tion, measurement, testing, and maintenance control. , e. Calibration standards are maintained, calibrated and used in an environ-ment having tagerature and humidity controls that am compatible with required accuracy and operating characteristics of the standards. i
- f. Records are maintained that indicate the calibration history ~and the next scheduled calibration date for each controlled device.
- g. Each inspection, measuring, testing and maintenance ' device is properly identified with serial numbers ' or other suitable identification, and has -
its last and next scheduled calibratica dates clearly indicated. . h. Devices that have not been properly maintained or calibrated in accor-
- dane.7 with specified schedules have been identified and removed for service.
I.
.. . -. . -, . . . - . . - - , . - .. - -, . . +
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WNP - 1/4 . I PSAR l l
- I
- 1. An investigation will be conducted and documented to determine th2 i validity of previous ir.spections performed when measuring and test equip- i ment are found to be out of calibration, j Documentation pertaining to the control of measuring and test equipment will bacome part of the objective evidence of the quality of the applicable items, !
, and will be filed and maintained in a traceable, retrievable, systematic j manner. - The details of the measures which UE&C, Bechtel and B&W iglement to assure j the control of measuring and test equipment are described in Sections 17.2 and ' , 17.4, and 17.3 mspectively. 17 .1 .13 Handling. Storage and Shippina ! The Supply System QA Program requires that Supply System and UE&C generated . procurement documents be reviewed and approved to verify that requirements j have been included which provide for the development and iglementation of i appropriate cleaning, preservation, handling, storage and shipping measures. i These requirements specify that procedures will be developed based on the . ! requirements of the procurement documents, with consideration to the need for - l special tools, -equipment and qualified personnel. Cleaning, pmservation, handling, storage and shipping requirements are [ incorporated into the procurement documents to assure that the item's designed ' integrity and ability to function are maintained. Ites delivemd to the site are stored, handled and presened in accordance , with procurement documents. Also, the equipment manufactumr's recommenda- ; tions are to be considered. These functions are performed in accordance with approved procedures and instructions. Site storage, handling and pmservation . are monitored by SS, UE&C QA and Bechtel QC Surveillance Engineers on a sche- j . duled basis and corrective action is taken when required. The SS, UE&C and. i ! Bechtel QC Surveillance Engineers also have follow-up responsibility of - ' corrective action. During the extended construction delay program, preventive maintenance activi- ! ties have been mtained by the Supply System. These functions.are performed ) in accordance with approved procedures and instructions. ; i . i Documentation pertaining to the cleaning, pmservation, handling, storage and i shipping of the item vill become part of the objective evidence of the , quality of the applica!.;e items, and will be filed and maintained in a trace-
~
able, retrievable, systematic manner. l The details of the measures which UE&C, Bechtel and B&W iglement to ' assure j control of the cleaning, pmservation, handling, storage and shipping 'of the l ites am described in Section 17.2 and 17.4, and 17.3 respectively. l l ,
i WNP - 1/4 PSAR 17 .1 .14 Inspection. Test and Operating Status The Supply System QA Program mquires that Supply System and UE&C generated procurement documents be reviewed and approved to verify that requirements have been included which provide fo* the development and implementation of inspection test and operatino status measures. These requirements specify
- that procedures will be deve'oped to assure that specified inspections and tests are performed, and that the acceptability of the items with regard to their inspection, test and operating status are known throughout the manufac-turing, installation and startup testing phases. ,
4 In addition, the procedures are required to specifically delineate the methods by which the inspection, test and operating status of an item will be identi-
. fied and the controls which will be implemented to control the use of the identification methods. The implementation of the status identification system will be designed to preclude the inadvertent bypassing of required inspections or tests, unless formally waived, and to prevent the inadvertent-operation of the equipment.
Documentation pertaining to the inspection, test and operating status of item will become part of the objective evidence of the quality of the applicable ites, and will be filed and maintained in a traceable, retrievable, systema-tic manner. The details of the measures which UE&C, Bechtel and B&W implement to assure inplementation of an inspection, test and operating status system are described in Section 17.2 and 17.4, and 17.3 re,pectively.
- 17 .1 .15 Nonconforming Materials. Parts or Components The Supply System QA Program requires that Supply System and UE&C generated procurement documents be reviewed and approved to yerify that requirements have been included which provide for the development and implementation of '
measums to assure control of nonconforming materials, parts.or components. The Quality Assurance program of the Supply System, UE&C, Bechtel, B&W, other contractors, s@ contractors, and vendors will provide for the identification,. documentation, segregation, review, disposition, and notification to affected organizations of nonconforming materials, parts, components, services or other.. program activities at any stage of manufacturing, fabrication, erection,.or-construction- to prevent their inadvertent use or-installation.- Written proce-dures!will provide for the handling,_ processing, dispositioning and reinspec-tion of nonconforming materials, parts, components, services or other program . activities. -
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Nonconforming item shall be identified and marked with a "WLD" tag (when possible); removed to a "WLD" area, roped off, or othenvise segregated (when practical) to prevent their. inadvertent use or installation. 1
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WNP - 1/4 i PSAR i ! 17 .1 .15 .1 Detection and Documentation of Nonconformances ! The detection and documentation of nonconformances detected by the Supply System follows: i a. Site Nonconformances ! All Seply System Project /QA personnel shall have the authority to either
- issue a Hold Tag or assure that the appropriate Contractor / Supplier issue
- its Hold Tag to stop work or control further processing of nonconforming item (s) which may be in direct violation of the following:
! 1) The PSAR/FSAR
- 2) Engineering, construction, or material specifications
- 3) Applicable codes and standards
- 4) Project Quality Assurance Procedures
- 5) Contractor's Quality Assurance Procedures Upon tagging, the individual shall contact the Supply System Site Quality Assurance Repmsentstive who shall assure the timely evaluation and
- appropriate actions to further control the item or activity. If
- determined to be a nonconformance it will be documented by the Supply
! System, either using the UE&C or Bechtel Nonconformance form or brought to the attentica of UE&C/Bechtel QA for their documentation, using the UE&C/Bechtel-NCR. In either case, from the point of origination, the nonconformance will be handled in accordance with the UE&C/Bechtel NCR Procedure described in Section 17.4.
- b. Vendor Nonconformanccs Nonconforming material, parts, components, services, or other program activities detected by Supply System and/or UE&C during vendor surveil-lance activities will be brought to the attention of the Vendor's Quality
. Assurance personnel for their initiation of nonconformance control, using 4 their procedure. Failure of the vendor to take appropriate actions will msult in appropriate corrective actions initiated by the Supply System-or UE&C. c.
-System Nonconformances A system has been established to assure quality discrepancies concerning documentation, procedums, instructions or program activities are identi -
fled,- documented and corrected and that notification of action taken ~ is transmitted to.affected parties. Quality Assurance personnel review AE and Supply System generated pro-curement documents to assure that requirements establishing a system of
- corrective action have been included. This myiew shall be accomplished in accordance with established procedures.
9 -, ,
~I WNP - 1/4 PSAR 17 .1 .15 .2 Review of Nonconformances Nonconformance documents which identify potentially significant deviations (10CFR50.55(e)/10CFR Part 21) are transmitted to the Supply System QA organi-zation. ,
Bechtel QA is msponsible for assuring that a copy of nonconformance documents generated by non-ASME Division 2 contractors and Bechtel which identify potentially significant deviations are transmitted to the Supply System QA organization. UE&C QA is responsible for assuring that a copy of nonconformance documents generated by ASME Division 2 contractors, UE&C Vendor Surveillance and UE&C which identify potentially significant deviations are transmitted to the Supply System QA organization. The Supply System Quality Assurance organization shall assure review of i nonconformance documents to assure that proper corrective actions have been taken to pmelude the repetition of similar nonconformances, that all applica-ble nonconformances have been evaluated by the Nonconformance Review Board (See Section 17.4), and that those nonconformances pertaining to conditions outlined in the requirements of 10CFR50.55(e)/10CFR Part 21 have been properly . processed. l The details of the measures which UE&C, Bechtel and B&W implement to assure the control of nonconforming materials, parts or components are described.in Sections 17.2 and 17.4 and 17.3 respectively. g 17.1.16 Corrective Action The Supply System QA Program requires that Supply System and UE&C generated procurement documents be reviewed and approved to yerify that requimments have been included which provide for the development and implementation of. measures to assure that conditions adverse to quality are identified, evalu-ated, corrective action implemented, certified, documented and reported to the appropriate levels of management. In addition, the cause of significant conditions adverse to quality are required to be identified, evaluated, corrective action inplemented to preclude repetition verified, documented and reported to the appropriate levels of management. The Supply System QA Program requires that Supply System QA assure a review of nonconformance reports and other significant conditions adverse to quali.ty to assure that dispositions have been effected, proper corrective actions have - been taken to pmclude the repetition of similar nonconformances, and that-items pertaining to the conditions outlined in the requirements of 10CFR50.55(e) and 10CFR Part 21 have been properly processed..
~
The procurement documents require the contractor or vendor to take timely corrective action when requested by Supply System and/or UE&C/Bechtel. This requirement is in addition to their own procedure for. implementing corrective _ action -which the procurement documents specify.- 9
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WNP - 1/4 PSAR l Documentation pertaining to corrective actions will become part of the objec-tive evidence of the quality of the applicable items, and will be filed ad
- maintained in a traceable, retrievable, systematic manner.
! The details of the corrective action measures inplemented by UE&C, Bechtel and i B&W are described in Sections 17.2 and 17.4, and 17.3 respectively. 17.1.17 Quality Assurance Records The Supply System QA Program requires that Supply System and UE&C generated
- procurement documents be reviewed and approved to verify that requirements have been included which provide for the development and ieplementation of
- measums to assure that documentation necessary to provide objective evidence
- of the activities affecting quality are generated, reviewed, approved, filed and maintained.
! The procurement documents delineate which documentation is mquired for objec-l tive evidence. The objective evidence requirements include such documentation i as inspection, test, nonconformance, corrective action and audit. reports, as l well as procedures, personnel qualifications, drawings and other procurement documents and related QA documentation. In addition, the procurement documents require that contractors or vendors: , 4
- a. Have written measures to control the filing and retrieval of QA records.
i b. Have QA records which provide sufficient information to permit-i . identification between the records and'the item or activity to which they i apply. i c. Have QA records which are legible, complete, and authenticated and dated i by authorized personnel. L i
- d. Maintain control over the QA records to assure that mvisions are per-formed under controlled conditions'in accordance with written procedures by authorized personnel. Revisions will include the date and identifica-tion of the person authorized to make the revision.
! e. . Maintain their QA records in a retrievable, identifiable manner.
- f. Have their QA records accessible for review by Supply System and/or UE&C/Bechtel.-. I
- g. Have QA record storage facilities'which are constructed and located to
, prevent destruction by fire, flooding, or theft, and to. prevent deterior.- ation from temperature or humidity conditions. Bechtel has been given the overall responsibility to receive, store and main-- tain the QA recort s for the Supply System at the site. - UE&C has been given the responsibility to receive,-store and maintain QA records associated with ASME III Div. 2 activities. l l
.2 _ . _ _ _ __ _ _ _ _ _ _ _ -_ _ _ . - . - _ .- .. i _~ . _.
WNP - 1/4 l PSAR i QA reords will be at the site in a storage facility constructed and located to prevent the contents from being destroyed by fire, flooding or theft, or deterioration by tenperature or humidity conditions. Bechtel Quality Control has been given the responsibility to review QA records l to assure their correctness and completeness. QA record: are required to be submitted to Bechtel in accordance with the requirements of the procurement documents. QA records am utilized to verify that activities affecting quality have in fact occurred, and that ther/ have been performed in compliance with the specified requirements. Analyses of conditions adrerse to quality am performed as indicated in Subsections 17.1.15 and 17.1.16. These analyses utilize QA records as one means of disclosing discrepancies and nonconforming conditions. Further, QA records provide the basis upon which dispositioning, and verification of msolutions are acconplished. UE&C has similar responsi-bility for QA records pertaining to ASME III, Div 2 activities. Safety relate 1 equipment will not be installed until it is assured that either the documentaion proving that the equipment does in fact meet the specifica-tion and code requirements is at the site, or a certification is received stating that this documentation is available and will be furnished, signed by an authorized representative of the manufacturer, and approved by UE&C Engineering with Supply System Engineering concurrence. The details of the Quality Assurance record measums that are implemented by UE&C, Bechtel and B&W am described in Sections 17.2 and 17.4, and 17.3 mspectively. 17.1.18 Audits The Supply System QA Program requires the contractors and vendors, and their s@ contractors, to develop and implement a comprdiensive system of planned and documented audits. These audit activities am required to be performed in - accordance with written procedures or checklists. Audit measures are required to assure that:
- a. Audits are performed by appropriately trained personnel not having responsibility in the areas being audited.
- b. Audits are conducted periodically based on a preplanned schedule.
- c. Audits include an objective evaluation of quality related practices, procedures, instructions, work areas, activities, itens- and documenta-tion. In addition, audits include an evaluation of the effectiveness of implementing conpliance to specified requirements.
- d. Management action is taken to correct deficient areas.
- e. Follow-up audits are performed to verify corrective action and to evalu-ate the effectiveness of implementation.
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l ..- WNP - 1/4 PSAR l r Supply System audit activities are performed in accordance with written proce-
&res by appropriately trained personnel not having direct responsibility for the areas being audited.
Supply System audits determine the adequacy of, and adherence to, the Supply . System QA Program, and the effectiveness of its implementation. This is determined by: ]
- a. The Licensing and Assurance Director, Manager Audits, and the Project QA l l Manager review reports of audits performed by the Supply System on UE&C l Home Office, NSSS Vendor and the Supply System. j
- b. The Project QA Manager reviews reports of audits performed by UE&C, Supply System and Bechtel cuality assurance on UE&C, Bechtel, site contractor and yendor acth . ties.
Supply System audits are performed based on preplanned schedules and audit ) plans, j . The implementation of each applicable Criteria of 10CFR50, Appendix B, is , scheduled to be audited 5y the Supply System annually. Additional follow-up audits my be scheduled to verify implementation of corrective action to-findings identified by audits. The frequency of audits may be increased or decreased based on findings. ! The scope of Supply System audits include:
- a. UE&C's home office, site and vendor surveillance activities. -
- b. B&W's home office, site (if any) and applicable manufacturing activities.
- c. Bechtel's site activities.
- d. Supply System home office and site activities.
Supply System audit msults are documented and reported to the appropriate levels of unagement for corrective action implementation. The responses to Supply System audit findings are verified for implementation and effectiveness
& ring follow-up audits..
Documentation pertaining to audits will become part of the objective evidence ;
.of quality of the applicable items, and will be filed and maintained in a.
traceable, retrievable, systematic manner. l The details of the audit activities inplemented by UE&C, Bechtel and B&W are described in Sections 17.2 and 17.4, and 17.3 respectively. l l
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L WASHINGTON PUBLIC POWER SUPPLY SYSTEM ,. MANAGING DIRECTOR DEPUTY MANAGING DIRECTOR LICENSING & CHIEF SUPPORT ASSURANCE FINANCIAL SERVICES OP IONS OFFICER DIRECTOR -
- DIRECTOR 9
WNP-3 WNP WNP 1 POWER WNP-4/5 PROGRAM
.TECHNR W GENERATION TERMINATION PROGRAM PROGRAM DRECTm DIRECTOR PROGRAM DMECTOR DIRECTOR DIRECTOR DIRECTOR FIGURE 17.1-1 SUPPLY SYSTEM ORGANIZATION PRELIMINARY SAFETY ANALYSIS REPORT SUPPLY SYSTEM NUCLEAR PROJECT NO.1/4 see=i
. - - + -. .- . - - _ . - - . -
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"s W4SHINGTON PUBLIC POWER SUPPLY SYSTEM LICENSING &
ASSURANCE DMECTOR NUCLEAR SAFETY & CONSTRUCTION AUDITS REGULATORY PROGRAMS OUAUTY ASSURANCE MANAGER MANAGER MANAGER
' REGULATORY WNP-114 PROGRAMS - PROJECT GA MANAGER MANAGER i- g I _
WNP-114 PROCUREMENT uCENSW8G - QUAUTY ASSURANCE MANAGER MANAGER' FIGURE 17.1-2 LICENSING E ASSURANCE ORGANIZATION ' PRELIMINARY SAFETY ANALYSIS REPORT SUPPLY SYST3M NUCLEAR PROJECT NO.1/4 eseam
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WASHINGTON PUBLIC POWER SUPPLY SYSTEM DIRECTOR OPERATIONS DONECTOR POWER GENERATION MANAGER REGULATORY PROGRAMS CONSTRUCTION GA PROGRAM DIRECTOR MANAGER PROJECT LICENSING OUAUTY ASSURANCE MANAGER MANAGER FINANCIAL MGMT. & BUSINESS CONTROLS MANAGER MANAGER p________ l l TEST & STARTUP ASST. PROGRAM ASST. PROGRAM PLANT MANAGER DIRECTOR ENGINEERING DIRECTOR CONSTRUCTION MANAGER FIGURE 17.1-3 WNP 1/4 ORGANIZATION PRELIMINARY SAFETY ANALYSIS REPORT SUPPLY SYSTEM NUCLEAR PROJECT NO.1/4 i mi
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- 3.c;q STATEMENT OF POLICY AND AUTHORITY The Supply System is obligated to cogly with applicable Nuclear Regulatory Commission, State and ASE Boiler and Pressure Vessel Code requirements. In particular, the Supply System is consitted to complying with Quality Assurance program requirements specified in 10CFR50, Appendix 8.
This manual is the governing document for work performed by Supply System personnel during the design and construction phases of Supply ' System nuclear power plants. Each manager directing work important to nuclear safety, is responsible for providing necessary instruc- . l tion and training to assure that work is performeo in accordance l with the requimments of this manual. i ) The Director of Licensing and Assurance is responsible for assisting i .
~
other organizations and for verifying conformance to this Quality
- Assurance Requirements Manual through the performance of audits. He is egowered to act on my behalf to stop work which does not comply 1 with this manual. '
l' ) The Director of Licensing and Assurance shall approve the contents , of this manual and any changes thereof, signifying its conformance to applicable Regulatory, State and Code. requirements. Any changes l- to this statement of policy and authority shall be made by me. { j R.' J tunO
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- - Figure 17.1-4 Supply System l j Management Statement
[ - (Taken from Qua'lity Assurance Manual) ' l - Preliminary Safety Analysis Report
- Supply System Nuclear Pro.iect No. 1/4 Q
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WASIfINGTON PUBLIC POWER SUPPLY SYSTEM j PSAR DEVIATION REQUEST , WNP- 1 J ! DEveAT40M MO. pArg ! 17.2-1 (WP) Rev. 1 l PAR AGR APM .se.Section 17.2.15 Feb. 17,1983 1 1
- 3. PSAA COans4TMENT AS OP 7/7E fLAST AMEMOMs Nf DATEls (BMCLUDE SAA STATEMENT) 1 I - Section 17.2 - United Engineers & Constructors Quality Assurance during l design and conttruction ( Architect- Engineerina / QA )
J l 17.7.18i - Nonconformino Material, Parts & Components
- 2. DESaRED CMAMGEs (8MosCATE DESIRED STATEMENT) 4 5 Revised Section 17.2.15 to include the processing and dispositioning requirements
} n revi ni,e l u enn+ained in Roetinn 17.4 . which were only oreviously included I 4n +h4e enetinn h.v reforanco
- s. gATEgggDENT PyeMG SeGeneriCAMCE oP OEv AT oms its wMAT iS BElese PaOPOSEO THAT IS OsPPEnEpBT PaOas PSAn j Thoro are nn channac in nroui n,,e PSAR cnnrnitments with respect to UE&C's reennneihilitioc ac_ the Architect / Enoineer.
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- 4. JUST4PICAT80Ms (La EMPLA4M WHY THE DES 4 RED CMANGE 8S JUST8P4EO AMO as EXPECTED TO SE OSPE88S4SbE SEPORE THE MRCl I
Thie cha nn.o it baine made to comDletel.y seoarate UE&C's responsibilities f me the architoct/Cnninopr at deteribed in Section 17.2 from UE&C'S l roennneihilitioe ac ennetruction Manaaer on the ASME III. Div. 2 activities . ! ne docerihod in Rortion 17.4. l ! 6. SUP#bY SYSTEM APPAOVALas DATE PetEPARED BYs P8tOJECT PAOG AA anE [h Q l} p OATE 1 I d l MG8ME E A BMG OATE
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! 17.2 i QUALITY ASSURANCE DURING DESIGN AND' CONSTRUCTION l' UNITED D GINEERS & CONSTRUCTORS (ARCHITECT-ENGINEERING QA) , 1 icope: This section summarizes the Home Office, site and Vendor. Surveillance activities of the United Engineers and Constructors Quality Assurance ; Progrua as it pertains to .the WNP-1 Irroject. UESC. Reliability and Quality ' Assurance Department \has been assigned the responsibility by WPPSS to provide a quality assurance program which meets or exceeds 10CFRSO, Appendix , B and ANSI N45.2-1971 requirements. This section coordinates that portion of the total quality assurance program for the project with respect to the design, procurement and fabrication of WNP-1 equipment. The terms -1 s " Vendor" and " Contractor" as used throughout this section are interchangeable : because of the connotation that UE&C Vendor Surveillance activity will be conducted in the shops of " Vendors" and " Contractors". Except where indi-cated, the terms " Vendors" and " Contractors" excludes the NSSS supplier-whose quality assurance program is described in Section 17.3. 4 , A' .< . 17.2.1 Orgrnization ' 17.2.1.1 Engineering Function j The UEGC Power Division, headed by the Vice President - Power, is responsible for the design and engineering of nuclear power plants. i~ The Vice President - Power, assigns a project manager to lead the UE&C. effort for the WNP-1 project and supplies the engineering manpower required for its design. . The control of quality-related activities affecting the design and engineering, is performed in.accordance'with the Power Division procedures
'which are approved by the Vice President - Power and the Manager - R&QA..
UE&C Power Division will perform their work in accordance with the + procedures of the Power Division. Work performed by the Division is further controlled'via compliance with detailed project engineering and QA procedures, which is subject to audits performed'by R&QA. A typic'l'a
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" Corporate Organization Chart" is shown in Figure 17.2-1.
17.2.1.2,.,Purchasin? Function-i The Mana' gar - Procurement reports to'the Vice President - Project SupportL Operations andits responsible for. procurement of: equipment to requirements
'specified by the UE&C Power Division.'
[, The procurement; activity on this project provides for the. commercial' evaluation of all'bidJpackages and includes contract administration and expediting'and is;
. performed in1accordance with good procurement practices written into:the contract specifications. ' Contract Administration and Expediting performed by1the Pro --
curement Department:is controlled through A system of' audits byjR&QA.
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It is important to note that the Drocureaant Department cannot waivg or change ~ any engineering or QA repaire:nant'or allog one to be changed g without the prioy , approval of Power Enrinee-ing and R&QA. [, Y- 'y j h1
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Tne responsibility for, quality, assurance'within UE&C reStF,with,/ theWViC4 ( President - Project SuppGrt Operation. The Vice President , , Projact '
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Support operations is on, an'organizatienal inval with the Vice President - ,- g - -
;J Pover and the Vice Precident - Construction allt reporting to,tM Tresident ' g as shown on the typic:a1 Corporate organladti'on ,Ctart, Figure lh 2-1. < _ ,
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[L g* President'- Project Support Operations -tsd; has been delegated full respon- g. sibility for the total quality assuranci,[sctivity wi' thin UE&C whici.fincludes f j 'd , the establishmen;, direction and ganageantut of the QA program on the, pro 3ect. ;j The Manager - RTsQA is also responsible fotI the ifnal review andl approgal of* { ' the program and han,'rufficient authority,and'crg mizational fspodem to:
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v' ,l,.[y', a) Identify' qual [ty: problems.
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s. b) Initiate, racoema% . !or provide solutions . t through designated'
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, f A management statoment by the UE&C Company President in the UE'sCiCor'stte/[ h
QA Manual, instructs all VE&C organization And personnel tg ad'r.ere to.the. UE&C . QA policies and procedures. A statement _by,the Manager REQA Pnd the Project Manager, in the project QA procedures mantial', _ imposes a;similar' reqdirement to the responsible project disciplines and individuale. .The_ Manager, R&QA reports to the Vice President-Project Support Operations as shown on the typical Corporation Organization Chart Figure 17.2-1 and supports the WMP-1 Project-Manager by developing, implementing and managing the quality assurance program. In this way, the R&QA Department maintains a direct and separate comununication channel to higher management which is not directly responsible for'the design ~ effort. ) l
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.ye ,The qualification requirements imoosed for the Manager REQA ares u,
,h { 1. Education - A graduate engineer with a professional registration
;i> or eligible and capable of being registered.
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$ *[l 2. Experience - A minimum of ten (10) years of y.nality assurance j/
. experience in the nuclear, heavy construction or heavy equipment p]'<,l{ , ,
industries. Minimum experience requirements may be reduced by:
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- a. One year for each year of direct experience within the UE&C ;
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-} , R.i.QA department.
'/,/ b. Cne year for each year of direct experience in quality !
;p ! assurance and control on a nuclear power, project.
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/ j c. One year for each year of direct experience in nuclear power
; y plant design engineering.
l p r* /. d. One half year for each year of direct experience in nuclear power plant construction supervision or job engineering. I P.xtensive previous experience in Reliability has allowed the Manager of
~
Reliability and Quality Assurance to establish UE&C's department with a
. dual function. One objective of this dual function is to evaluate the state of the art (Reliability) in the Power Industry. The " Reliability" portion of the R&QA charter has been devoted to literature searching and study of reliability-oriented activitias elsewhere in industry and in providing comununication to the company on these activities. No employee of the function has any significant comulitments to support the Reliability function. It is estimated that more than 95% of R&QA's activities are devoted to developing and implementing the quality assurance program responsive to 10CFR50, Appendix B and N45.2.
The organizational relationship of Reliability and Quality Assurance with ' other UESC functions is shown in Figure 17.2-2. Table 17.2-2 sununarizes the interface between WPPSS and UE&C as related to the various QA program activities. This chart presents those significant interactions between UE&C and WPPSS as related to pertinent design, manufacturing and installation QA activities which are described throughout l l l l 17.2-3 t i I' l "l
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i WNP-1 l , PSAR
! p the revised Chapter 17 of the PSAR.
The R&QA function is composed of personnel who are experienced in the i development and implementation of quality assurance programs for nuclear power plants. The functions major divisions, which are applied to the WNP-1, are as follows: 17.2.1.3.1 Proieet Quality The Project Quality Assurance Manager reports to the Manager-R&QA , thru an Assistant Department Manager and is responsible for the plan-ning, coordination and control of the UE&C Project Quality Assurance Program for WNP-1. The Project QA Manager is responsible for the coordination of the implementaion of the UE&C QA Program with other operating groups within UE&C and with the QA activities of WPPSS and i B&W. 9 The typical Project QA Manager duties and authorities are as follows: i a) Establish and implement the UE&C Project Quality Assurance Program, provide the integration of QA activities, and act as the QA spokesman for assigned projects. b) Provide for R&QA support to UEEC Project Managenaent. c) Provide for the UE&C Quality Assurance interface with WPPSS and B&W. J d) Prepare the Section 17 imputs.to the Safety Analysis Repcrts and'the Project's UE&C Quality Assurance plans and procedures. ]
- e) Provide QA direction through Site Quality Assurance Management in the'
, implementation of the UE&C Project Quality Assurance Program at the site. l f) Provide QA direction in the independent' identification of quality problems, the recommendation of corrective action, and in verifying the implemen-tation of approved solutions. Reporting to the Project QA Manager is m' Supervising Engineer-Project Quality (SE-PQ) and a Field Superintendent-Quality Assurance (FS-QA) . The SE-PQ is responsible to the Project QA Manager for the implementation of the Home Office portion of the UE&C Quality Assurance Program, while the _ FS-QA is responsible for implementation of the QA plan to the site. In carrying out his responsibilities for implementation of-the Home Cffice portion of the UE&C QA program, the SE-PQ is required to assure that Engi-neering and Purchasing are effectively carrying out their portions of the-Program in accordance with their approved procedures. He is required to
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( WNP-1 PSAR d see that other groups within R&QA perform their assigned duties in a timely manner and in accordance with the approved Troject Quality Assurance l Procedures. The typic..tl SE-PQ duties and authorities are as follows: a) Plan and coordinate the UE&C, vendor and contractor audit program with the R&QA Auditing Group. b) Define the extent of QA sutveillance as required by the contract specifi-cations and purchase documents, prepare check plans identifying required documents and surveillance check points for use by UE&C Vendor Surveillance representatives, and schedule plant or source visits in coordination with the Vendor, Procurement Department, and the Supervising Engineer-Vendor Surveillance. . . , , c) Plan and coordinate audits of the QA program and project procedures, including those for engineering specifications, the drawing control system and engineering consultants. d) Plan and coordinate surveillance of the NSS Contractor and NSS ( accessory equipment and material Suppliers. N e) Review of contract specifications, amendments and change orders prepared by Project Engineering. This action pertains to QA requirements, tests, inspections and codes specified for incorporation in the documents. f) Perform bid evaluation of bidders' proposed QA programs and review proposals and other procurement documentation to assure Quality Assurance and Quality Control requirements are met, g) Review and approve Contractor submitted QA Manuals for Q Class I equipment. The FS-QA is responsible to the Project QA Manager for the implementation of the site portion of the UE&C Quality Assurance Program. In carrying out his respon-siblities, the FS-QA is required to assure that site Engineering and Purchasing groups are effectively carrying out their portions of the program in accordance with their approved procedures. The typical FS-QA duties and authorities are as follows: a) Review contract specifications, amendments and change orders prepared by field Construction Support. This review pertains to QA require . i l - 17.2-4 a
s I 1 WNP-1
- PSAR
-i ments, tests, inspections and codes specified for incorporation in the documents.
1. b) Perform bid evaluation of bidders' proposed QA programs and review proposals and other procurement docusentation to assure Quality , Assurance and Quality Control requirements are met. c) Review and approve Contractor submitted QA Manuals and Proc =dures for Q Class I equipment. The Field Quality Assurance organization is described in Subsection 17.4.1. The Supervising Engineer-Quality Systems reports to the Manager-Nuclear Projects < Quality Assurance and is responsible for the performance of the following duties: - a) Review Vendor and Contractor Quality Control procedures pertinent to purchased items and services. This action results in QA control of Vendor and Contractor QC processing procedures throughodt the fabrication, test and installation cycle. , - b) Education and training of personnel performing quality related activities on the WNP-1 project. 17.2.1.3.2 . Vendor Surveillance The Supervising Engineer-Vendor Surveillance reports to the Manager-Quality. Services and is directly responsible for the activities of_.the Vendor Sur-
- veillance Representatives (QAR) . He is responsible for' carrying out the Vendor .l Surveillance program as identified and required by SE-PQ for the WNP-1 project.
The Supervising Engineer-Vendor Surveillance works with the QAR in matters relating to liaison and coordination for the purchased equipment for the -! project.- Typical Vendor Surveillance activities includes i a) Assist in facility surveys at prospective Vendors' and Contractors' plants, if required by tho' Project. ] . I b) Establish and maintain vendor surveillance information files generated' , by surveillance activities. l , l l I e , ;. <
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I WNP-1 PSAR i c) Conducting surveillance of Vendors and Contractors (for off-site work) including NSSS, preparing written inspection reports on the results of the surveillance actions and distributing it in accordance with the l requirements of the QA Program. ' I d) Witnessing, verifying or performing vendor inspection or test operations , and inspection of hardware as identified on the check plan, to the applicable contract requirements. e) Verifying vendor's use of properly approved procedures for the required inspection and tests. f) Conducting final inspection and QA records review (final release) prior to
, shipment for items and services furnished fremt off-site.
4 17.2.1.3.3 Welding Engineering , , , 6 Welding Engineering, under the direction of a Supervising Engineer who reports to the Manager R&QA through the Manager Quality services, consists of personnel with experience in all forme of welding including the writing and qualification of procedures and qualification of personnel. The ! g principal responsibilities of the Welding Group are the followings
, 't a) Assist the Project Quality Group in the review of Vendor and Contractor j submitted welding procedures and their qualification records.
b) Assist and support UE&C Engineering in matters relating to welding requirements in drawings and specifications. c) Provide guidance, advice and assistance to Vendors and Contractors in matters of welding techniques and procedures. 17.2.1.3.4 Audits ' The Audits Group under the direction of a Manager who reports to the Manager R&QA, is composed of personnel with experience in the area of planning and conducting various types of audits. The duties of the Auditing Group are as follows: a) Plan, develop and implement' audits of project activities. b) Schedule audits in coordination with the SE-PQ. I c) Conduct project internal audits. d) Conduct Vendor and Contractor off-site audits. e) Document and distribute report of findings and observations.
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f ! f) Conduct follow-up audits verifying corrective action. i 4 g) Audit UE&C site quality assurance activities. 17.2.1.3.5 Nondestructive Examination I The Nondestructive Examination.(NDE) Group, under the direction of a i Supervising Engineer, who reports to the Manager R&QA through the' Manager Quality Services, consists of personnel with experience in all forms of , NDE including preparation o' procedures and qualification of personnel. In addition, the group has NDE examiners who are qualified to Level III l in accordance with ASNT-TC-1A. The principal duties of the NDE Group are
- as follows
l a) Administer UE&C's program for training, examining and certifying of
- UE&C NDE personnel. , , ,
i , b) Review Vendor and Contractor NDE procedures. f
- c) Provide evaluation'and disposition of NDE problems.
t } 17.2.13 6 Materials Engineering 1 I The Materials Engineering Group, under the direction of a' manager who
-reports to the Manager R&QA, consists of engineers with. expertise in' metallurgy, corrosion, non-metallics and coatings. This group assists' in selecting materials for new applications and assists the Project Engineering and SE-PQ in the resolution of materials and manufacturing i problems. In addition, the Materials Engineering Group has these major ,
, duties: a) Assist the SE-PQ in the review of contract specifications and i procedures for the inclusion of proper materials and processes, f
- b) Review design modifications material. application.'. ,
t ! c) Review Supplier and Contractor submittals for.the selection of a materials and fabrication processes. , d) .. Review Vendor and Contractor cleaning and heat _ treatment procedures.
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e) Investigate and evaluate failures and recosamend disposition of ! materials problems. i-17.2-7 -- n i c e % se '\ p e ,
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. I 17.2.2 Quality Assurance Program 17.2.2.1 Introduction The quality assurance and quality control activities performed on WPPSS Nuclear Project No.1 (WNP-1) are under the control of.or are subject to audit by the Reliability and Quality Assurance Deprtment (R&QA). The department has authority and organizational freedom to identify quality i problems; to initiate, recommend or provide solutions; and to verify imple-l mentation of solutions independent of individuals or groups directly respon-sible for performing a specific activity. . UE&C's Quality Assurance program complies with the NRC Regulatory Guides positions as described in section 3.12, and the applicable requirement,s of 10CFR50, Appendix ,B,,the AEC Grey Book, and 4 the ANSI Standards contained in subsection 17.1.2. 'The basic elements of com-pliance are ?.escribed under subsection 17.2.2.2. A cross index of UE&C proce-dures and the 18 Point Criteria is shown in Table 17.2-1.. The st: uctures, systems and components to be covered by the UE&C QA program are tr.Ose. designated as WPPSS Quality Class I, II Augmented and G Augmented in Table 3.2-2. r ( 4 ( 17.2.2.2 Response to NRC Criteria , l a) Organization _ The Reliability & Quality Assurance Department is responsible for assuring that the QA program established for this project complies J with regulatory and specific project requirements and that the program is properly implemented. The R&QA Department carries out. I the QA program as defined in subsection 17.2.1 which outlines the' structure and responsibilities of the R&QA organization and its. relationship with other corporate departments. Subsection 17.2.1 also defines the department's organizational freedom and indepen-dance for identifying quality problems, including effecting resolu-
'tions and verifying that the solution has been implemented.
] b) Quality Assurance Program The QA program established for WNP-1 consists of specific project QA procedures approved by WPPSS and defined in this subsection-(17.2.2) of the PSAR. UE&C requires Contractors and Vendors providing Quality Class I equipment to implement QA programs that are in compliance. with-the applicable criteria of 10CRFSO, Appendix B, and other ' documents defined in subsection'17.2.2.1.- i l :17.2-8 - - L L e - I
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. c) Design Control l 4
1 Quality assurance procedures define the actions of the Engineering Department and R&QA to assure the application of required design [ basis, codes and standards into the specifications. Through a planned system of reviews and audits, these actions will provide l measures of assurance for compliance. Design and specification l 4 changes will be subject to the same design control measure as are the original specification requirements, { a. J d) Procurement Document Control i UE&C engineering designs are translated into WNP-1 procurement
- j. requirements primarily by means of specifications and drawings.
j- The engineering design requirements, regulatory requirements, quality ' requirements and any other requirements which are necessary to en-sure adequate product conformance are specified and referenced in the contract' specification for materials, equipment and services. ! The control over input, review and approval of quality control and j- quality assurance requirements set forth in procurement specifica - i i tions and approved design drawings is maintained through procedures ! contained in the basic UE&C manuals. k j I' ( e) Instructions, Procedures and Drawings i ('~ . UEEC's quality-related activities on the WNP-1 project are performed i in accordance with the WNP-1 Project Quality Assurance Procedures
- l Manual as described in subcection 17.2.2. This QA Manual defines the
- technical, administrative and quality-related inputs to documents affect-
] ing the quality of WPPSS designated Quality Class I, II Augmented and G j Augmented structures, systems and components. Appropriate qualitative- ] and quantitative acceptance criteria for determining that quality-related i activities have been satisfactorily accomplished are contained in' con-j tract specifications, procedures, drawings and other appropriate documents. l f) Document Control'
; written instructions and procedures for implementing _ document- l
- -control measures are contained in the UE&C Quality _ Assurance l Procedures Manual, Vendors, and Contractors Quality Control'Hanuals i
! and Propurchased and Construction Equipment Specifications. These in:structions and procedures control the issuing of documents such - 4 as specifications and drawings, including authorized changes,- , , and' assure'that the documents and revisions are reviewed for-adequacy and approved for release by authorized. personnel.' .; t . l [ ' g) Control of Purchased Material Equipment and Services , The' quality of purchased' material equipment and services'is
~
f7 controlled through review of, submitted vendor and contractor QA Q programs, data ar.d' drawings, progressive - surveillance at vendors' ., shops, audits,' witnessing of tests and final inspection prior:to ) shipmer. :. Pre-award quality' evaluation of prospective Contractors , 4 i ! _ 17.2-9 l Fy - -
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i WNP-1 l , - PSAR i ( i l t and post-award evaluation of successful bidders are conducted in 4 accordance with subsect!ans 17.2.7.1 and 17.2.7.2 to resure compliance ' with contract requirements. . Vendors and Contractors will be required to submit with their proposal, the necessary evidence to satisfy the QA requirements of the contract to be awarded. UE&C QA at . Engineering i department personnel will ass:ist WPPSS in reviewing the bids to det- ! ermine the acceptability of the bidders QA program. In addition,
- UE&C QA will establish and implement a planned surveillance program covering the material and equipment furnished by the NSSS Supplier.
i h) Identification and Control of Materials, Parts & Components UEEC drawings and specifications include requirements for tha ! identification of materials, parts and components, which directs l the supplier of. WNP-1 safety related equipment to provide a. system
- to assure that these items incorporated into the plant are properly identified and traceable to all supporting,qpality assurance
! documentation. Vendor and contractor identification procedures will be established, maintained end audited to assure implementation. i) Control of Special Processes 4 [ ( UEEC will not be required to perform any special processes, but will impose applicable requirements on Vendors and Contractors, of WNP-1 equipment and services. These special processes include l welding, cleaning, repairing, heat treating, nondestructive testing
- and other processes which affect the quality of a nuclear or engineering safeguard structure, system or component during-fabrica- ,
! tion, manufacturing, installation and construction activities. i UEEC's procurement documents require Vendors and Contractors to control these special processes in accordance with contract require-ments, appropriate codes and standards. Vendors and Contractors will be required to either submit or maintain written procedures and' records of process and personnel qualification for UE&C approval prior to use of the process.- i j) Inspection The quality assurance program of UESC requires participating Vendors and contractors to provide for a controlled system of-inspection of materials, parts,' components and equipment associated with the WNP-1 project. Written and UE&C approved proceduret provide for-this control to assure that the materials purchased are fabricated, tested and delivered in conformance with specification and contract-requirements. . (subsection 17.2.10). k) . Test control-
- l. f ' A program of -testing during vendor and contractor plant'activitiy .
( . will.be performed in accordance withLa pre-established approved ~
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- PSAR
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l } contractor procedure or program based on contract specification {- requirements,-and the results will be fully document M. -These , activities will be subject to surveillance and audit by R&QA for j ' assurance that the test results meet contract specification pre-regt" sites and the approved test procedure requirements.
- 1) Control of Measurement and Test Equipment vendor and Contractor QA programs will establish and provide for the systematic control over the calibration, use, recall and recalibration of test equipment used in their plant operations.
Vendors and Contractors will be required by the procurement docu-ments to provide these calibration control measures within their quality control system with calibrations performed against standards of known accuracy, which will be subject to audit and surveillance
- by UE&C R&QA personnel.
- J* * .
m) Handling, Storage and Shipping vendors and contractors providing equipment will implement an approved program detailing the requirements for handling, storing, cleanliness, preservation and shipping of their equipment. Any [ special requirements for handling and storage of the equissment after ' (' receiving at the site will be contained in UE&C contract specifica-tions. The Vendor will be required to furnish approved instructions for protection of his equipment. n) Inspection, Test and Operating Status l i The UE&C Quality Assurance Program provides for procedures to be developed by Vendors and Contractors for indicating the status of tests and inspections performed at their plants upon materials,
, parts and components. The status of an item is indicated by means of tags or stamps to (a) preclude the inadvertent bypassing of their inspection and test requirements and to (b) prevent their inadvertent operation.
o) . Nonconforming Materials, Parts or Components 1 , The UE&C Quality Assurance Program provides that Vendors and contractors who are suppliers of_WNP-1 equipment, establish and main - tain a system for controlling nonconforming material to preclude : - its use until'it has been properly dispositioned. This system will i be compatible with the UE&C system of NCR control which will assure, that vendor and UEEC processing.and activity procedure nonconform-ances are identified, documented, segregated and dispositioned and-that notification of the actions taken are transmitted to the
. . affected parties. : Provision is also made for implementation of the UE&C program of Nonconformance activity for Mcme Office violations
[ - {- - t
'of UE&C approved procedures and instructions.
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p) Corrective Action 1: i The UE&C QA program provides for the use of available inspection and }- auditing procedures and UE&C vendor or contractor nonconformance and disposition reports to identify and obtain corrective action for conditions adverse to quality. Typical of these conditions are ! procedural inadequacies of the Vendor quality program, failures,
- malfunctions, deficiencies, deviations, defective material and equip-j_ ment and vendor nonconformance to specified requirements. A program j of corrective action control is also implemented for UESC Home Office t Activity.
i ! q) Quality Assurance Records
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The UE&C Quality Assurance program provides for drawings, contract
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- ' specifications and procurement documents to delineate types of quality assurance records that vendors and Jontractors are required
- to prepare, maintain and submit for review and UESC approval. These records will be identifiable and retrievable and will provide the i documentary evidence of quality. UEEC will maintain the WP-1 files i for quality assurance activities and items under UE&C cognizance.
j These files will be available for WPPSS review. i f r) Audits 1 m. l The quality assurance program for the WNP-1 project provides for ! scheduled and unscheduled periodic audits which will verify compliance j with the applicable Management, Engineering, Procurement and QA activities. The audit records of UESC internal practices offer i objective evidence of implementation of and compliance with require-ments, and consistency in the discharge of responsibilities. ; 17.2.2.3 Project Training }' Education and training courses, including indoctrination, are established I by UE&C to provide instructions to UE&C personnel performing activities
- affecting quality. Instructions will be provided by Engineering,
- or Quality Assurance, and documented. Personnel' responsible for 4
quality related activities are instructed as to the purpose,. scope and method- !. of implementing the Corporate Standards Quality Assurance Manual, the Nuclear l' QA Manual, and'the Project QA Procedures. Specialized QA training courses, and certification when applicable, for', . detailed studies 'in specific areas, such as nondestructive examination '(NDE) ,' 4 and auditing, are developed and presented based on evidence of need as
- recognized by management or a requirement of:the.WNP-1 contract. Specialized-training is provided to NDE, Vendor Surveillance, Audit,Isite Qh'and othe'r-4 personnel as applicable and.as described in the Corporate: Standards Quality
- - - Assurance Manual and Project QA Procedures.-
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,- PSAR l
}- l l l .' Personnel performing specialized functions such as NDE, Audits, and I examinations, inspections, and. tests are experienced, trained, examined l a%1 certified to appropriate levels of performance in accordance with , approved procedures responsive to regulations and standards such as Reg-
- ulatory Guide 1.58, ANSI 45.2.23, ASNT Recommended Practices, and ASME Section III, Division 2.
4 17.2.3 Design Control [ UE&C has projee and standard company procedures which clearly define the i control of design activities associated with safety related items. These l procedures define the scope, purpose, responsibilities and step-by-step , procedures utilized in the preparation, review, approval and control of ! design documents, such as specifications, drawings, procedures and instruc-l tions, including changes thereto. These control measures are utilized to -' t ensure that the quality requirements are sufficiently", clearly, and accur- , ately stated in the documents prior to their release, and to ensure that the i
- applicable regulatory requirements and design bases are correctly translated j into these documents. Deviationa and changes from the appropriate quality l requirements are controlled by the review actions outlined in the UE&C !
- project and appropriate company procedures. ,
In order to ensure that suitable design analyses, such as physics, stress,
~
- materials, thermal, hydraulic, radiation and accident, are performed where
, applicable, data wcrk sheets are provided. These data work sheets are l initialed by the reviewers, indicating incorporation of applicable design
- j. analyses.
4 17.2.3.1 Design Control Precedures j The UE&C procedures contain provisions and responsibilities for monitering'. internal disciplines and external organizations to ensure that the design work and procedures described therein are being implemented, and to ensure proper interface between internal disciplines and external organizations. a.
, Ir. order.to ensure that proper selection and accomplishment of design. veri-
- fication methods, such as design reviews, alternate calculations and qualifi-i cation testing, are performed, tne UE&C procedures contain provisions for the extent of, and responsibility for, design verification. The depth and degree of review is established by UE&C Project Engineering Management. The indivi-2 duals or groups responsible _for the design verification are other than those.-
I
~ who performed the original design, and who are designated as being qualified
- by UE&C. Project Engineering Management. . Changes and/or revit, ions to the design' documents are covered my the UE&C
~ . ~ , .
procedures. These procedures require the same review and approval for. changes [ .and/or revisions as the original document. These reviews and approvals are
- 1 ' performed by the'same organizations)that' performed the original tasks,.or delegated to another responsible organization by the design originator.
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' PSAR i
The UE&C procedures contain steps to ensure that approved design documents, . l and revisions or changes thereto, are distributed to responsible individuals i in a timely manner and that obsolete documents are purged from the system. Control of the design documents will be in accordance with subsection 17.2.6. I t , 17.2.3.2 Design Control verification i In order to ensure that measures are provided describing when and'how errors j and deficiencies in the design process are documented and dispositioned, and how corrective actions are determined and implementedi the UE&C procedures l require all safety related items to undergo an independent design review.
- The result of the design review effort is clearly documented.
- Where applicable, the report of the design review is resolved by the respon-sible Discipline Supervising Engineer to the satisfaetibn of UE&C Project Engineering management, with the resolutions being recorded, and filed in a controlled area for future reference.
A camprehensive system of planned and documented audits is utilized on all , phases of the design process by UE&C in accordance with subsection 17.2.18. ; [' Audits are also conducted by WPPSS QA, a qualified unit independent of the * ( design organization, in accordance with subsection 17.1.18.
. Design documents, records and changes thereto are-collected, stored and main- I tained in a systematic and controlled manner in accordance with the provisions
. of the UE&C project procedures.
17.2.4 Procurement Document Control' UE&C engineering designs are translated into WNP-1 procurement requirements
~
primarily by means of specifications and drawings. The engineering design-requirements, regulatory requirements, quality requirements'and any other. requirements which are necessary to ensure adequate product conformance are specified or referenced in the contra'ct specification.for materials, equipment- , and services. The control.over input, review and approval of. quality assur-
. ance requirements set forth in procurement specifications'and approved design drawings is maintained through procedures contained:in the basic UE&C manuals.
17.2.4.1 Procurement Specifications _ a) UEEC company standard procedures,[in addition.to-the:WNP-1 Project.
' Manual'of Procedures'and the WNP-1 Quality Assurance Proceduresy Manual,-clearly define the. basic control of procurement documents i j associated with Quality Class-I items;. These procedures. collectively.
#1 provide compliance with ANSI N45.2.13 (May -1973), " Supplementary.
j . b. . i QA Requirements for Control of. Procurement of Equipment, Material ~
-and Services for' Nuclear Power. Plants" for procurement actions.as
'well as.the procurement documents themselves.-
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( % . , I WNP-1 PSAR I l l i b) WNP-1 purchased equipment contract specifications, provide the technical, quality assurance, processing and administrative re- , quirements as individual sections, each of which are reviewed, approved and controlled in accordance with an established UE&C procedure. d
- 1) The Te,chnical e Sections of the contract specifications are developed and controlled by UE&C engineering which then become the central section from which the contract specification is developed.
- 2) The Vendor and Contractor Quality Assurance requirements
- are developed and controlled by UEEC Reliability and Quality Assurance, and are made part of the contract specification by being inserted into the various technical and administrative sections. Accuracy requirements and provisions for review, filing, maintenance, = =4 nation and access of QA records for purchased equipment and~
services are specified in the contract specification. , J Provisions for requiring Vendors and Contractors-to submit their QA Records Program including applicable proc-cedures for the review and~ approval of QA records are also specified in the appropriate "Technica1 Section" of the (' contract specification. The basic QA requirements sections are sent to WPPSS for review and concurrence prior to their use in a contract specification.
- 3) Special processing requirements are developed by the quality- <
assurance " Technical Support" personnel of the R&QA department. - These requirements provide QA technical support inputs to the design and fabrication of WNP-l' equipment, and are reviewed-and approved by UE&C and WPPSS in accordance with UE&C procedures. The procurement quality control and quality assurance requirements
~
c) are made part of the contract specifications and the process control 4 procedures with the review of Quality Class I,-II Augmented and G Augmented contract specifications being performed by QA personnel in the Reliability and Quality Assurance department. After the review, the signature of the WNP-1 Project. Team Quality-Assurance Engineer on an internal Memo and Document Review Form provides the approval release by the.R&QA department. - Revisions-and addenda to these' specifications are reviewed and approved by the R&QA department in the same manner as the original documents. d) Figure 17.2-3 is a typical. flow chart which depicts the development, flow and approval cycle of WNP-1 contract specifications by UE&C.- Subsequent to the final resolution of UE&C and WPPSS comments, the- , , -contract specification is submitted to WPPSS for final review'and (' approval, after which UE&C distributes and releases the specification for bids.
'17.2-15 1
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t .. . 4 WNP-1 PSAR i I 17.2.5 Instructions, Procedures and Drawings UE&C's quality-related activities on the WNP-1 project are performed in accordance with the WNP-1 Quality Assurance Procedures Manual as described in subsection 17.2.2. This manual provides procedures which describe the technical, administrative and quality-related inputs to those documents affecting the quality of WPPSS designated Quality Class I, II Augmented and G Augmented l structures, systems and components. Appropriate qualitative and quantitative acceptance criteria for determining that quality related activities have been satisfactorily accomplished and contained in specifications, procedures, draw-ings and other appropriate documents. i 17.2.5.1 Procedures - a) " Project Manual of Procedures" is a document of written procedures issued and controlled by UE&C Project Management for the WNP-1 i project which defines the scope of engineering and design work, responsible organizations and administrative practices such as ; correspondence exchange procedure, cost control,. planning and . scheduling procedure, document identificatfon' procedure, etc. The ! Project Manual of Procedures complement the QA Procedures Manual l by detailing those administrative procedures specified in the QA Pro- i cedures Manual as being critical in the implementation of quality- ! 1 related activities on the project. The manual is a controlled document incorporating procedures which are distributed, reviewed, commented on, approved, issued and revised in accordance with an (' approved UE&C procedure. Distribution is in accordance with an l estab)ished distribution list under the control of the UEEC Project ! Engineering Department. j b) Quality Assurance Procedures. Manual is a document of written procedures issued and controlled by UE&C Quality Assurance for the WNP-1 project 6
- th addresses itso?.f to assuring that the WNP-1
- project is engL ..ered, designed, I.recured, fabr e eted, manufactured, installed, erected, constructed, and tested in +,afe, reliable and efficient manner. The.QA procedures have been developed to corres- ,
pond to the criteria of 10CFR50 - Appendix B and the. applicable
~
sections of ANSI N45.2 and detail tho'UESC effort to establish and control the quality-related activities of vendors,-Contractors, UE&C.Constructicn Management, UEsc Engineering, UESC Procurement,l UE&C Project Management and UE&C Quality Assurance. The Qh proce-dures are developed by UE&C Project Quality with support'and assistance by specialists within the.. Reliability & Quality Assurance.-
-Department. Past practices, regulatory requirements, safety _-
analysis reports requirements and UEEC Corporate Standards are' used in the procedure development. 'h.e QA written procedures are_ distributed, reviewed, comment on,' approved, issued and' revised-in accordance with an approved.UEEC procedure. ' Distribution of. these QA procedures is in accordance with an established distribution ~
' list under the control of the UEEC Reliability & Quality Assurance-department.
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17.2.5.2 Drawings a) UE&C issued drawings for WPPSS designated equipment are developed, , issued, reviewed, approved and revised in accordance with dt.* ailed. written procedures outlined in the UE&C WNP-1 Project Manual of Procedures Subsection 17.2.5.1.a. Vendor, Contractor and NSSS Supplier drawings suhaittals are also reviewed, distributed and commented on in accordance with detailed written
- procedures as outlined in the UEEC Project Manual of Procedures.
1 When requested by engineering, the UE&C R&QA department will also contribute to that review to reassure the vendor / Contractor contractual quality ccanitment. 17.2.5.3 safety Analysis Report a) The Safety Analysis Report-for WNP-1 is the principal controlled document which provides information needed to understand the basis for constructing and operating the WNP-1 plant safely and efficiently. As part of the total quality assurance program, the internal review, ' submittal and implementation of amendments and changes to the Preliminary and Final Safety Analysis Report for WNP-1 are'in accordance with detailed written procedures contained in the WNP-1 Project Manual of Procedures. UESC Licensing and Environmental Section personnel coordinate the documenting, reviewing, processing, distribution and submission of amendments and changes to these Safety Analysis Reports. 17.2.5.4 Safety Related Documents e a) "NRC Regulatory Guides" are maintained and distributed throughout UE&C in accordance with an approved UEEC written procedure by UE&C Licensing and Environmental Section personnel. The impact-
; of each Regulatory Guide, on the WNP-1 project,'is considered' by UE&C technical disciplines as it affects the design, fabrication, construction and testing of the equipment.
b) " Reactor and Construction Operating. Experiences" published by the NRC are maintained and distributed in the same manner _as NRC Regula-tory Guides per subsection 17.2.5.4.a. The review and consideration of occurences during operation of other reactors, as they impact the WNP-1 Project, is considered by UE&C Engineering in accordance with written' procedures as defined by the UE&C Licensing and Environmental t Section. L . 17.2 :i 0 e
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WNP-1 PSAR r i 17.2.6 Document co -rol Written instructions and procedures for implementing document control measures are contained in the following project documents as used on the WNP-1 program: ! UE&C W.@-1 Quality Assurance Procedures Manual UEEC Project Manual of Procedures Vendors and contractors Quality control Manual Pre-purchased Equipment Contract Specifications i Construction Contract Specifications These instructions and procedures control the issuing of documents such as specifications and drawings, including authorized changes, and assure that the documents and revisions are reviewed for adequacy and approved for release by authorized personnel. 17.2.6.1 contract Specifications a) UE&C standard company and project procedures clearly define the control of WNP-1 cc? tract specifications associated with safety related items. These control measures assure that the quality requirements are sufficiently, clearly and accurately stated in the specifications prior to their release and that they are distributed in accordance
- ~ with the approved procedure. Revisions and/or changes to'the specifications are covered by the UE&C procedures and will undergo the same reviews and approvals as the original document, with these i
being performed by the same organization that performed the original [ tasks. Obsolete specifications are identified as such, with
- instructions of "not to use" or " destroy" being issued.
l i 17.2.6.2 Drawings a) UE&C drawings, including revisions therto, are. prepared and control-
-led by UE&C Engineering and are reviewed, and approved in accordance with procedures outlined in the Project Manual of Procedures.
Similar procedures govern the review of Vendors and Contractors drawings and revisions to assure compliance with specification
- requirements. .
b) Approved modifications.to drawings are documented in schedules and' listing which are updated and reviewedLon a regular basis to identify current revisions.-~ Design changes incorporated.into drawings-by.the-cognizant' Design EnginOer will be reviewed and approved in~.the same. manner as the original issue.. , 17.2-18
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WNP-1 PSAR r 1 ! '7.2.6.3
. Quality Assurance Procedures a) Quality assurance procedures are prepared and controlled by the Reliability and Quality Assurance department and are reviewed and f approved in accordance with procedures outlined in the UE&C WNP-1
- Quality Assurance Procedures Manual. The procedure defines the i review, approval and control cycle of the QA procedures including 4
changes and revisions thereto and ensures that all recipients have j the latest applicable revision.. j b) All users of the QA procedures are required to destroy obsolete i procedures. Internal compliance with these requiremente ; measured by the UE&C Quality Assurance Audit section through internal ;udits
- conducted in accordance with subsection 17.2.19.
s 17.2.6.4 vendors and Contractor submittals *
- a) Vendor and Contractor, including NSSS, documentation submittals are
- received, procened, distributed and coordinated by the UE&C Engineer-
! ing department. Appropriate documents relevant to QA are distributed 4 to the UE&C WNP-1 Quality Assurance Engineer and other UE&C Techni-l cal Specialists to review for conformance to the QA requirements of i applicable contract specifications, codes and standards. UE&C Engineering collects all generated ccaments, evaluates .! and consolidates them and transmits them to the Vendor or l Contractor. Problem areas developed by the ccaments are l resolved betvaen Engineering and the commentor prior to j transmission to the vendor. 1 j 17.2.6.5 Document Files f a) The UE&C Project Engineering department maintains the project 1 document file which includes the copies of the latest revision of UE&C and Vendor originated drawings, specification and j procedures. In addition, each engineering discipline maintains their own Cocument file which includes the originals of their ' issued drawings, calculations and specification. A master file index is used to facilitate uniformity and improve retrievability. J b) Quality assurance records accumulated at the UE&C Home Office and field offices, are indexed by the site records group and are transmitted to WPPSS for microfilming and permanent storage. . - l c) Obsolete' documents ~are: controlled throughout the project;by written acknowledgement certifying that previous issues have i A[ been collected and destroyed, or by clearly' marking the original. : document as void. Internal compliance with these requirements
~is measured by QA audits.
17.2-19 i _ - 4
s * . WNP-1 PEAR p.. I d) Project distribution of incoming and outgoing documents is controlled by Project Engineering. Distribution is noted by a stamp and copies are distributed to key project personnel. Each category of document, e.g. transmittal letter, corre-spondence, drawings, foreign prints, procedures, etc. has a specified distribution list so that pertinent documents are directed and made av tilable to the cognizant project personnel. The project , engineering group provides additional availability of these documents upon request. e) The central file index consists -f primary categories relating to equipment, documentation, quet ity assurance and other disciplines, reguAatory requirements and project information, etc. This index is supplied to all supervisors, engineers, secretaries and administrators. Use of this index in conjunction with current released lists of specifications, drawings, foreign prints and othe? documentation, provides the latest status gf the project definition. f) A general list of documents that are controlled by document control procedures is as follows: Contract Specification Project Manual of Procedures Project Quality Assurance Procedures Manual Corporate Quality Assurance Manual l Operations Manual - Power Engineering Safety Analysis Reports QA Procedures Regulatory Guides
' Reactor Operating Experiences UE&C Drawings a
g) The documents which are maintained in the project file, but are not controlled by the document control procedures as outlined in subsection' 17.2.6.5.c are as follows: Design Review Reports Systems Descriptions Design Calculations j.. Stress Reports t 17.2-20 ,
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l . WNP-1 PSAR :
- Standard Technical Sections vendor and contractor submittals QC Bulletins 17.2.7 Control of Purchased Material, Equipment and Services The Quality of purchased material equipment and services is controlled through review of submitted Vendor and Contractor QA programs, data and drawings, progressive surveillance at vendors shops,. audits and witnessing of tests and final inspection prior to shipment. After the. bid opening and ,
prior to the award of a contract, vendors and Contractors whose bids. , appear to be the lowest may be required to show evidence of.t! air ability l~ to sat'sfy all QA requirements of the contract to be awarded. UE&C QA and Engineering personnel will assist hPPS'S in reviewing #th'e bids to determine l the acceptability of the bidders QA program. t 17.2.7.1 Pre Award Evaluation a) UE&C Quality Assurance Engineering personnel are responsible , for providing a quality evaluation of prospective contractors-based on the review of submittal documentation. After reviewing. prospective vendor bid packages, UE&C Engineering and Purchasing > review the submitted data on a technical and economic basis i to determine compliance with contract specification and intended l use. UE&C Quality Assurance evaluates the Vendors and Contractors responsiveness and ability to meet the specified quality - requirements. b) At the completion of the QA evalaation, an evaluation report.is ' I submitted to the UE&C WNP-1. Project Engineering Manager in which . is included QA recommendations, and where appropriate, identification , of those Vendors and contractors who are non-responsive to the bid documetas. s k 17.2.7.2 Post-Award Evaluation a) After the award of the contract.for WPPSS Quality Class I equipment the vendor or Contractor QA program and procedures are submitted for UE&C approval in accordance with the applicable contract speci-. . fication and ANSI N45.2, both documents assuring vendor and Contractor..~ compliance with Appendix B of 10CFR50. The successful bidders l ; programs are reviewed by UE&C 'Mality Assurance personnel and the
~
results of this review are transmitted by UEEC Engineering to WPPSS 1 -for their assessment prior to further procurement-activities. l
..17.2-21 4
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1 WNP-1 PSAR l . (- , b) Subsequent to receipt of the contract purchase order, but prior to beginning of fabrication, the vendor or Contractor is required to identify their fabrication process steps including inspections and
, tests. Frou this and the contract specification, UE&C QA will identify the documentation requirements and surveillance actions [
' by utilizing vendor and Contractor fabrication processes, appropriate specifications, drawings, codes and standards. All surveillance j reports are reviewed by UE&C QA and distributed to WPPSS and the j WNP-1 Project Manager. I i j 17.2.7.3 vendor Surveillance Activities 4 a) UE&C Vendor Surveillance activities provide a surveillance. function 4 at the vendor and Contractor off-site facilities, including _NSSS, as a means of verifying that the requirements of the contract speci-fication, purchase documents, approved vendorsprocedures, and all specified codes and standards are being adhered to. b) For pre purchased Quality Class I. II Augmented and G Augmented equip-
- ment ready for shipment, UE&C Veraor Surveillance personnel will per-
- form a final inspection surveillance with the vendor and Contractor
- e inspection personnel in accordance with written procedures and check-l ( '
off lists to verify the identity and conditions of tne items and that the requirements of the contract specification are met. 3 A Qu.111ty Shipment Release form is completed by UEEC Vendor Surveillance personnel and accompanies the shipment to provide evidence to the site
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j . that the equipment has been released for shipment and that all surveil-lance activities have been satisfactorily completed. c) Typical UEEC Vendor and Contractor surveillance and audit activity j during the fabrication cycle is conducted in accordance with sub- ' section 17.2.17, to assure that the vendor and Contractor comply. with quality requirements as defined in the contract procurement-dcuments. l 17.2.7.4 Receiving Inspectior. , Vendor and Contractor receiving inspection is performed in accordance with subsection 17.4.10. 17.2.8 Identification and Control of Materials, Parts & Components UEEC. contract specifications include requirements for the identification'. of materials, parts and components,.which directs the supplier of WNP-1 safety related equipment to provide a system to' assure that these items" incorporated into the plant are properly identified and traceable to all' supporting quality assurance documentation. 17.2-22 i _ _ _ .__._.-__.__._____a-__-----_-_-_w -
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(' l 17.2.8.1 Procurement Documents i The UE&C contract specifications specify that eovipment suppliers (Vendors and ; Contractors) establish procedures which describe the identification and control - of materials, parts and components. When implemented, the Vendor and Contractor program wi11 provide traceability of all parts and materials used in a particular product configuration and will also exercise control over' ; essential procedures, drawings and test documents. UEEC contract specifications'
~
}. also provide the vendor and Contractor with procedural requirements covering ,
- essential aspects involved in the identification and control program. .These procedural requirements provide .for an integrated system so that Vendor and i contractors implement a uniform approach to nonconformances, tagging, corrective-
- a. action, and records to ensure that only specified materials are used through-out production and fabrication. Traceability will be maintained by the ,
; Vendor and contractor by their quality related documentation or by a physical ;
marking system. 1 Ja . 17.2.8.2 Procedure ! a) Vender and contractor identification procedures will apply to
- production materials, bulk raw materials and parts and assemblies at all stages of manufacture from receipt of purchased material to shipinent of the completed article.
l b) UEEC Vendor Surveillance personnel monitor the Vendor and Contractors i implementation of these procedures and verify that the identification i system (i.e. tagging, stamps, markings, etc.) is correct. i 17.2.9 Control of Special Processes-UE&C is not required to perform any special processes, but' imposes applicable. requirements on vendcrs and Contractors of WNP-1 equipment and services.. I , These special processes include welding, cleaning, repairing, heat treating, l nondestructiv, testing and other processes which affect the quality.of a i nuclear or engineering safeguard structure system or. component-during fabri-. cation, manufacturing, installation and construction activities.- UE&C's contract specifications require vendors and Contractors to control these special processes in accordance'with their approved processing procedures, appropriate codes and standards. Vendors and Contractors are required to either submit or : ! maintain written procedures and appropriate' records of procedure and personnel ! qualifications for UE&C review prior to use of the process.- 17.2.9.1 Processing Requirements special' processing requirements documents"for the F.9-1 project.are prepared 4 and controlled by UE&C in accordance with applicable codes and standards and; are included in the contract specification by'UE&C Engineering for fabrication.
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work performed by Vendors and Contractors. 1These processing requitements ( '- _are, continually reviewed, updated, revised and supplemented to provide the. . (. ' latest information pertaining.to codes,' standards and. methods'of-testing.- l17.2 t . l l- -
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[ 17.2.9.2 Process Audit and Surveillance a) UE&C surveillance and audits of Vendor and Contractor processing
- are conducted by Quality Assurance to assure that their -
Special processes are being conducted in accordance with 1 qualified procedures by qualified personnel as prescribed by applicable codes or standards. ! Records are being maintained which document the satisfactory i accomplishment of special processes and which indicate the
- current qualification and certification status of all special
{ process procedures, equipment and personnel. Special process procedures are being regularly reviewed to. ' ~ assure their conformance with latest revisions of codes and standards imposed by contract specification.
- b) Deviations from approved Vendor or Contractor procedures will be-l iden-.ified and reported to the project in accordance with established i project notification procedures.
17.2.9.3 qualification
! (
, vendors and Contractors personnel responsible for performing special processes will be qualified in accordance with the applicable code or regulation. These qualifications will be subject to UEEC review either in the' Home Office or by the UE&C Vendor Surveillance Representatives in the off-site. shops. Personnel employed by the Vendor or contractor to witness,' perform or inspect special- , processes for which qualification and certification is mandatory, shall be
- certified in accordance with the applicable code or. regulation. Active files
, will ba maintained by the Vendor or Contractor, of qualification records of { Vendor or Contractor personnel performing special processes. 17.2.9.4 Process Documentation and Records-
- a) The-control of these special processes by the Vendor or. Contractor will include documentation and records sufficient to ensure that-the requirements of these special process procedures, in accordance with specification requirements, have been met. These records will.
be controlled and retained in accordance with subsectioni17.2.17. b) UE&C Home Office Quality Assurance personnel in their review of the contract specification verify-inclusion of any special process' or process controls, and in' conjunction with UE&C Engineering, review submitted Vendor and Contractor special process procedure.s prior to fabrication. UE&C VendorfSurveillance personnel provide the surveillance effort to assure that vendors and Contractors j j conform to their procedures. l % - 17.2-24 l L l
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17.2.10 Inspection l 3 The UE&C contract specifications require participating Vendors and Contractors to provide for a controlled system of inspection of materials, parts, components and equipment associated with the WNP-1 project. Written Vendor or Contractor procedures provide for this control of inspections to assure
- . that the materials purchased are fabricated, tested and delivered in con-formance with specification and contract requirements. UE&C surveillance -
4 personnel will determine the accept or reject status.of the work and, depend-
- ent upon Vendor or Contractor response, pursue a coursa of action as defined in Subsections 17.2.15.8 and 17.2.16.6.
j- 17.2.10.1 Personnel , l a) UE&C, is not responsible for performing first level inspections.. 4 However, UE&C R&QA Vendor Surveillance representatives will conduct surveillance activities within the scope of the UE&C QA program , associated with vendor and Contractor-inspections, ewaminations ! and other activities at the equipment suppliers plant. UESC Vendor- . Surveillance personnel continually verify that the equipmer.t vendor i and Contractor first level inspection capability is maintained at the high level required for the WNP-1 project.
~
Procedures for maintaining this high standard of inspection ,_ ., capability are developed by the appropriate Vendor or contractor for review and approval by UESC. UESC R&QA Vendor Surveillance assures that vendor and Contractor quality control departments continually monitor, through. examinations, indoctrination programs and orientation and training, the proficiency and independence of their inspection personnel..
- 17.2.10.2 Equipment Supplier - In process inspection and surveillance ,
a) The surveillance. activities associated with the in'-process shop l inspections, tests.and documentation for pre-purchased and Contractor purchased equipment are in'accordance with UESC Quality Assurancei procedures which define in detail UE&C control of purchased items at the Vendor or Contractor plant. b) UEEC surveillance requirements are outlined in.the' contract specifi-cation and summarized as a seweillance check plan. This surveil-lance check plan is prepared by the UE&C WNP-1 Quality Assurance. Engineer developed from the contract specificatien, and outlines , the contract requirements for documentation, testing, inspection ' points, sampling plans,' processing procedures,'and receiving're-l quirements for the. applicable equipment. The check; plan is used bye. . the UEEC Vendor Surveillance representative as a check list guide i for UE&C in-process and final surveillance inspection of the purchased'
. , . . equipment prior to delivery to the site.. The shop inspections ~
' designated are performed by the Vendor'or. Contractor's personnel:
charged with the quality responsibility'and these inspections are [ . verified by UE&C Surveillance.Represectatives.
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i 17.2.10.3 Equipment Supplier - Final Inspection and Release .l l a) When pre-purchased material is to be inspected by UE&C prior to L shipment, the vendor notifies the UESC procurement department, who f in turn notifies appropriate UE&C Vendor Surveillance Quality l Assurance personnel and makes arrangements with Vendor Quality , pers.,nnal for the final inspection at the Vendor plant. Stamping i of Vendor documentation, tagging and completion of a UE&C ship-j ment release form prior to shipping, completes the UEEC sur- .j, veillance inspection effort. A completed documentation package is : , then transmitted by the Vendor with the shipment to the jobsite. l i b) When contractor purchased material for construction contracts is .
- ready for shipment to the site from the off asite contractor plant, the I
! UE&C Vendor Surveillance Representative may participate, when specified, I through surveillance of the Contractors' final inspection and release ' activities at the plant, to the extent necessary to assure that the contractor is conforming to an approved pr,ocedure for such activities. l c) If it is not possible or is disadvantageous to final inspect the
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. equipment at the point of fabrication prior to shipment, then the I
! acceptance inspection of the equipment is implemented at the site [ in accordance with the receiving inspection procedure as defined '! in subsection 17.4.10. ; l 17.2.11 Test control .l t The UE&C Quality Assurance Program establishes a system of control to assure [ that vendor and Contractor test activities are performed in their plants in accordance with requirements which are predetermined, approved ar.3 delineated j in written test plans and instructions. This system will also assure.that. j test results are acceptable and fully documented. .; 17.2.11.1 Test Rwouirements ; a) Test requirements for Vendor and Contractors are delineated in the l contract specifications in conformance with engineering practices and code requirements. Conformance to NRC Regulatory Guides are "+ also considered when the required tests are specified in the contract : specification. b)- Vendor and Contractor written test procedures for. review ant
- audit by UE&C Quality Assurance, describe the method of test control, t.arough verification that tests have been performed in accordance. ,
with specified plans and procedures, and that test.results are within the.specified limits. ' Qualification, and special proof tests when specified in the contract specification require the Vendof or ?} Contractor to prepare test programs adequate for the. application,and 7 . subject to review and. approval by UE&C.. 17.2-26 U 2
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1 l WNP-1 PSAR p-c) W nessing of shop performance tests, nondestructive tests, material tests, acceptance tests, proof tests, and qualification tests as , conducted by the Vendor or Contractor is accomplished by UE&C Engineering or Quality Assurance in accordance with test and j inspection requirements outlined in the contract specification and ; accompanying quality assurance documents. l l 17.2.11.2 Test Eva[ gtion Final test reports and documentation supplied by the Vendor or Contractor are reviewed and evaluated by UE&C against acceptance criteria, operating limits and performance standards. Deviations, discrepancies or questionable test data are reviewed by UE&C Engineering with UE&C Quality Assurance support when required and dispositioned in accordance with the nonconformance procedure-as outlined in the contract specification.
. .a .
17.2.11.3 operating Experience a) When contract specifications allow the use of Vendor or Contracter operating experfence data to demonstrate equipment conformance to operating test requirements, UE&C Engineering corsonnel and, as required, UE&C Quality Assurance personnel assure that the certified data are pertinent to the application and that the operating experience data provides those specifications, features, comparisons,. rationale, susmaries and sources from which a basis for determining the suitability of the data is obtained. b) suitability and acceptability of the operating experience data is reviewed and evaluated as defined in suk sction 17.2.11.2. 17.2.11.4 Test Personnel a) Vendors and Contractors shall assure that personnel employed to perform or interpret the results of testing activities are properly qualified in accordance with their approved procedures. Where code or contract specification requirements specify. qualification criteria for such personnel, the vendor shall be-required to verify that their procedures shall be in accordance with such criteria. 17.2.12 Control of Measuring and Test Equipment , a) UEEC contract specifications require that Vendors and Contractors must have control over the calibration and use of tools, gauges, s instruments and other measuring and testing devices used in activities affecting product quality on designated equipment and services.. The contract specifications also require that-17.2-27
. .i l WNP-1 PSAR
- Contractors procedurer shall s'.escribe the calibration technique, calibration freque..ncy, maintenance and control of all meas,uring and test instrumentation tools, gages, fixtures, l referency standards, transfer standards and nondestructive test equ!pment which are to be used in the measurement,, !
inspection and :nonitoring of components, systems and structures. I b) Where practic.si, allowable deviations from calibration standards i shall be specified in the Contractor's procedures and submftted to UE&C for review. Inspection, testing and measuring equipment items shall be uniquely identified and have traceability to their calibration test data. 17.2.12.1 Procedure a) Vendors and Contractors calibration policy, schedule and - system for the control of measuring and test equipment will be required to be specified in their applicable quality con-trol procedures. These procedures will be reviewed by UEEC project personnal including, when requested,' Quality Assurance personnel for adequacy prior to authorization to use. UE&C Surveillance personnel will provid,e the sur-veillance activity to assure that the vendor or Contractor calibration progress is control-ed as indicated in the proceduras. b) Vendors and Contractors procedures will be expected to assure C proper usage and to establish a system for the control, cal-ibration and adjustment of tools, gauges, instruments and other inspection, measuring, testing and mainter.ance devices. This system is established such that conformance to established O requirements is verified at. specific periods of time to assure the usage of proper type, range and accuracy of the device. 17.2.12.2 Control Requirements Vendor and contractor procedures will be expected to include effective-control requirements as part of their measuring and test equipment calibration program among which are these typical critoria: a) Maintenance end control of primary and secondary standards. t
- b) Measuring capability of standards in acecrdance with Contractor ".
l or Vendor defined tolerance ranges. ; c) Method of correctingi adjusting,'rei.?vnine' tor repair and replace- g , sent of measurement standards.. - Calibration control of new devices end positive identification of -' ' 01 . 3 l calibration status... 't' l t -* i , n - 4 , j 3- 17.2-28' ) ,,V' l-
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WNP-1 PSAR e) calibration instructions. f) Calibration schedule, listing and location for usable test equipment. g) Recalibration review. h) Environmental control limitations and requirements for calibratior 17.2.12.3 Standards of control a) In certain applications, a major factor in obtaining, accuracy,in calibratei on is control of the environment. Vendors and Contractors l will be expected to provide in their calibration program, consideration for the control of the environment where the calibration is to be performed.
* ,2* *
- b) The Vendor and Contractor calibration program shall also consider the accuracy requirements of the measurement param'eter in order to I establish in their procedures the degree and type of environmental control required.
17.2.12.4 Calibration and Control Records j 2 a) Identification of calibration records for Testing and Measuring .i equipment used by Vendor or contractor during in-process and final inspection are established so that equipment can be readily recalled for recalibration or adjustment. These records also serve as-an indication of which devices were used on specific tests'and in-
- spections and also provide for traceability if such devices are found to be out,of calibration and require corrective action.
b) The use of uncalibrated devices shall be cause for rejection.of the j test or the inspection with the dispositirn and corrective action being identified as part of the nonconformance report which is 3 issued. 1 17.2.13 Handling, Storage and Shipping 4 UE&C contract specifications specify the guiding requirements for cleaning, handling, storage and shipping which are used by vendor and contractor as the basis for generating appropriate detailed procedures. These procedures
~
are then subject to UEEC review and approval. When' appropriate, Vendors and contractors also submit similar procedures for application to their equip- ) ment at the n nstruction site.
. . 17.2-29 t
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WNP-1 F3AR l' i \ 17.2.13.1 Procedure a) Vendors and Contractors establish and document procedures to be employed to control cleaning, preservation, handling, storage and shipping of their responsible equipment during the plant fabrication. testing, inspection and subsequent shipping to the site. The pro xdures to be developed cover cleaning, packaging and preserva- ) tion of the material and equipment to prevent damage, deterioration j and loss at the plant. These Vendor and Contractor procedures also contain provisions for utilization of'special covers, special i equipment and special protective environments, such as inert gas . atmosphere, specific moisture content levels and temperature levels attributable to the special maintenance care and cleanliness required ! when the equipment is kept at the site. .l b) The Vendor and Contractor procedures for their equipment also contain suitable provisions for verifying the above conditions. -UEEC. Vendor Surveillance personnel provide the surveillance activity necessary to assure that the vendor or Contractor haf iniplemented his procedures with qualified personnel. Contract specifications govern the UE&C QA Vendor Surveillance inspection of packaging and pre-paration for shipment at th'e Vendor or Contractor off-site plant. A- 17.2.13.2 General Requirements 1
, a) All procedures defining specific packaging, preservation, shipping .'
i and storage of materials shall conform to applicable material codes and standards including consideration of the applicable NRC Regulatory Guide. b) Shipping containers for equipment specified in UE&C contract. specifications, when selected at the option of the_ Vendor or contractor, are utilized where appropriate and in accordance with 1 specific approved criteria. . Protection of equipment during preser- , vation, handling, shipping and storage' requires an assessment of thef allowable protection criteria-by the vendor and contractor. l c) The Vendor and Contractor' procedures will provide instructions for marking and labeling for packaging,' shipment and storage. -These written procedures'contain provisions for the marking of, identifying information on the exterior of shipping containers. The marking is adequate to identify, maintain and preserve the shipment,-including-4 indication.of the presence ~of.special environments or the need for special control. > 17.2.13.3- Cleanliness r a) .UE&C contract specifications specify a cleanliness _' requirement _for
' ~
equipment which is applied by the vendor and Contractor during.and-after fabrications'and during storage and' shipping. The cleaning t- 'and^cleanli, ness control program,:as utilized by the vendor and Contractor, is designed not only?to minimize preoperationalicleaning
~17.2-30L p W =
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WNP-1
,' PSAR of installed cociponents and post-assembly cleaning of components at the plant, but to recommend where applicable site cleaning of equipment and maintenance of equipment cleanliness at the site.
b) vendor and Contractor procedures provide for the facilitation of , cleaning and inspection for cleanliness during fabrication of the equipment. UE&C Vendor Surveillance personnel provide the sur-veillance activity to verify whether the vendor and Contractor has implemented his procedure with properly qualified personnel. t 17.2.14 Inspection, Test and Operating Status The UE&C Quality Assurance Program provides for procedures to be developed. by vendors and contractors for indicating the status of tests and inspections performed at their plants upon materials, parts and components. The status - of an item is indicated by means of tags.and stamps tb Ta) preclude the inadvertent bypassing of their inspection and test requirements and to (b) prevent their inadvertent operation. 17.2.14.1 Item status a) Vendor and Contractor procedures provides for their own tagging. methods to indicate inspection and testing status and acceptance of applicable equipment during plant fabrication. 1 b) Vendor and Contractor items are identified by marking, tagging, labelling or other appropriate means either on.the items or on documents that are traceable to the items. c) Identification of' items in the Vendor-or Contractor plant is directed toward categories of ACCEPT status,. REJECT status, REPAIR or REWORK . status and HOLD status. These status categories allow for the applicable procedure to differentiate between items awaiting-in-- spection, items that have satisfactorily passed inspection and items that are discrepant (see subsection 17.4.14). i d) UE&C Vendor Surveillance effort provides the in-process and final. inspection surveillance' activity to assure that tagging and item identification has been implemented by the. Vendor and Contractor in accordance with the approved procedure. 17.2.14.2 Inspection stamps a) Vendor and Contractor approved procedures and their quality system may; J also use stamps and status indicators, including authority for their' , ' application and removal to control the welding, inspection and NDE l - operations. i-17.2-31 1
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l 4 . L ., _ . . ;- WNP-1 PSAR j l b) The procedure provides for the definition, issuance, control ; and application of these inspection stamps by their own quality i personnel. UE&C Vendor Surveillance personnel. provide the surveillance activity to assure that the responsible Contractor 2 personnel are implementing their approved procedures. 4 17.2.14.3 Surveillance Status 4 During on-going shop work and applicable in-process work at the Vendor or Contractor off-site plant, UE&C Surveillance. representatives issue appropriate inspection reports. These reports serve as notification to the Project, the Owner, and , the Construction Site Personnel, that the UE&C off-site j-. surveillance effort is being implemented. Final release notifications and sign-off of apprcpriate V/S check plan ; surveillance are actions designed to establish completion of
; assigned surveillaL9e activities.
17.2.14.4 Change in Status . a) Ptovisions are made in the UE&C Quality Assurance Program for implementing a change in status of Vendor and Contractor
, items. The inspection status of any item may be changed on the basis of inspection and surveillance, only by instructions from UE&C Quality Assurance, WPPSS Quality. Assurance or Vendor or 4
Contractor Quality Assurance. b) If items are " released" by the Vendor or Contractor and new non-conformances are discovered, they will be handled in accordance
; with Subsection 17.2.15. g 17.2.15 Nonconforming Materials, Parts or Components The UE&C Quality Assurance Program provides that UE&C' and -Vendors, who are Suppliers of WNP-1 equipment, are' required to establish and maintain ~a system for controlling nonconforming material.to preclude its use until
~
4 '
. properly dispositioned. .This system'shall assure ~that UE&C'and-Vendor nonconformances are identified, documented, and dispositioned and that notificacion of the actions-taken are transmitted to the'affected parties. The' program also provides < for the engineering disposition of j nonconforming items. identified at the site..
17.2.15.1 Definitions a) Nonconformances - A nonconformance is a deficiency /in cNaracter-istic, documentation or procedure which renders the quality ~ of an item unacceptable. or indeterminate.' Examples of a , nonconformance include physical defects.. test failure, inaccurate 7 or inadequate documentation or deviation fron ' prescribed: processing' inspection or test-procedures..
'17.2-32
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WNP-1 PSAR b) Deficiencies - Nonconforming conditions detected within UE&C during l activities involving design specifications, program procedures, ! and drawing requirements, related to Quality Assurance, Engineering, Purchasing and Project Management. - These conditions represent departures from an approved procedure. approved design or drawing : which could adversely affect the quality of the activity being l L implemented on the WNP-1 project, t 4 17.2.15.2 Procedure Nonconforming materials, parts, components or pregram procedure activities , may be documented by the organization detecting the nonconformance as ; follows: > t a) UE&C initiated:
- 1) Deficiencies detected against in-house UE&C activities are !
documented using-the UE&C Deficiency Report. These are ' handled as nonconformances subject to investigation, dis-
; , position, acceptance, and close out in accordance with UE&C- j t
approved quality assurance procedures. ~
- 2) Nonconformances detected-at the vendor's plant shall be documented using the UE&C " Vendor Notification Report (VNR)".
Refusal by the Vendor to take action could result in UE&C initiating.the appropriate action in accordance with , applicable project and quality assurance procedures.- ; b) Vendor / Contractor initiatedi
- 1) Nonconformances detected by a Vendor / Contractor'during ,
in-house fabrication / installation shall be. documented , and controlled by the Vendor / Contractor 'on his own ' nonconformance report form. 4 17.2.15.3 Controlling Nonconformance Documentation Forms .I a) UE&C deficiency report forms, for-in-house' use, contain' a - ,
. description of'the nonconforming element activity and the I deficiency. the' disposition,~ verification ~that.the disposition
.was' accomplished. Standard'distributionLof; preliminary and completed deficiency reports is maintained. UE&C VNR forms-
- shall be maintained per the applicable . project' quality assurance ' ,
procedure.. es. '! b) Vendor / Contractor NCR~ forms,'for: Vendor / Contractor. activity'contain , a description of.the nonconforming' item,La recommendedidisposition I and justification, ' ' 17.2-33 , a 4 9
- d. 1 1
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P WNP-1 PSAR and verification by reinspection that the approved disposition was accomplished. Standard distribution of completed NCR's is maintained. , i 17.2.15.4 Maintenance of Nonconformance Records a) Copies of Vendor / Contractor nonconformance documents are transmitted i to UE&C for disposition as specified in the contract specifications. Copies are distributed in accordance with the appropriate project procedures. ; t b) Vendor / Contractor initiated NCR's are maintained in their own files.' c) UE&C initiated deficiency reports and vendor notification reports are l maintained in the quality assurance files. d) All nonconformance reports shall be considered "open" until the non-conformance disposition has been specified, implemented and reinspected in accordance with the appropriate project or quality assurance procedure. *
- i e
17.2.15.5 Disposition Disposition of all nonconformances, shall be noted on the applicable forms with the dispositioning action as follows: a) For Vendor initiated nonconformances, the " rework" and " reject" dis- - positions will be provided by the vendor. For "use-as-is" and
" repair" dispositions, the vendor will submit a Contract Waiver' '
Request as provided for by the centract. ' Approvals of procedures for repair or rework are submitted by the Vendor to UE&C for approval. ; b) Disposition of UE&C " Deficiencies" is determined by the UE&C Project . - Engineering Manager. Dispositions shall be compatible with satisfying the UE&C and WPPSS approved QA and project procedures for.that element - of in-house effort. _, c) As the A/E, UE&C shall approve all dispositions for site generated i nonconformance reports as follows.
- 1) All' site nonconformance reports are submitted to UE&C Site Quality.
. Assurance. Each NCR is evaluated by UE&C Engineering for adequate- .,
disposition or the necessity for Nonconformance- Review Board. (NRB) { approval. The NRB approves dispositions when: required as determined - by reference to-specific criteria and in.accordance with applicable. ! project procedures. 2)- The Nonconformance-Review Board meets as required at~ the con-
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-struction site to reviev'and approve'the disposition of applicable site nonconformances. The NRB'has the following representation:
i
- 17. 2- 34. !
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l
. .. ., I WNP-1 PSAR l
e UE&C Engineering e WPPSS Engineering f e UE&C Quality Assurance e WPPSS Quality Assurance i e WPPSS Construction
- 3) Disposition of all nonconformances at the site are approved by UE&C Project Engineering and are noted on the respective NCR forms with the dispositioning action in accordance with the applicable project procedures.
17.2.15.6 Reinspection l , a) Af ter the responsible organization has performed the required actions to clear the nonconformance, the following action shall be implemented:
- 1) For Vendor / Contractor nonconformances the Vendor's/ Contractor's quality organization shall make the reinspection,-determine acceptability and sign-off the nonconformance document as acceptable.
- 2) For UE&C deficiencies, the UE&C Quality Assurance organization-verifies the dispositian action, evaluates the resolution and signs off the nonconformance document as acceptable.
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-WNP-1 PSAR 17.2.15.7 Accept-Reject Authority l a) Nonconformances (Vendors / Contractors)
Final authority for the acceptance or rejection of nonconformances is as follows: Vendor / Contractor Quality Assurance - for nonconformances discovered by their own QC inspection. b) Deficiencies (UE&C) - Final authority for the acceptance or rejection of UE&C deficiencies is as follows: ^ UE&C Quality Assurance - in accordance with existing project quality assurance procedcres.- 17 2.16 Corrective Action UE&C uses available inspection and auditing procedures and Vendor nonconformance and disposition reports to identify and obtain corrective action for conditions adverse to quality. Typical of these conditions are Vendor quality program or procedural inadequacies, failures, malfunctions, deficiencies,. deviations,
, defective material and squipment and Vendor nonconformance to specified require-ments. ,
17.2.16.1 Corrective Action During Design Effort a) Errors and nonconformances which adversely affect safety related structures, systems and components discovered during the UE&C, Vendor and Contractor design process are documented and resolved by UE&C prior to approval of the document. b) Corrective action for design nonconformances discovered during.
- Vendor or Contractor manufacturing will be documented by the Vendor and reviewed for implementation. . Revisions'to appropriate.
~
design documents, if required, will be accomplished in accordance with UE&C project procedures. 4-
- c) Effectiveness of correctiv,e action is checked by UE&C audits in accordance with subsection 17.2.18.
t 17.2.16.2 Corrective Action Requests a) The UE&C Quality Assurance program'provides that'the' vendor initiate his own Corrective Action Requests in'accordance with an' approved l
, 117.2.-35 i
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WNP-1. l PSAR { procedure and that the vendor responds in timely manner to corrective J . Action Requests written by UE&C Quality Assurance. b) The UE&C Quality Assurance Program provides that practices in which i j- repeated violations of the same nature either'are occuring or would ! occur. require the initiation of a Corrective Action Request _by UE&C' [ Quality Assurance in accordance with an approved procedure. 3 I 17.2.16.3 Implementing Corrective Action b f a) For UE&C corrective action the designated responsible addressee describes the corrective action that he intends to implement l and_ specifies the date by which it will be implemented. If-the corrective action specified is not adequate _or does not meet the )1- intent of the reque.st, UE&C Quality Assurance resolves the differ-ence'in'accordance with an approved procedure. i i 5 b) For Vendor corrective action' initiated by 'tYE&'C Quality Assurance, i the designated responsible Vendor describes the corrective action } that he intends to implement and specifies the date by which it will I be implemented. UE&C Vendor Surveillance personnel maintain an audit and surveillance activity to ascertain the adequacy and intent-of l! - the corrective action in accordance with the approved vendor practice. l
; s A 17.2.16.4 Verification and Analysis i
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i a) When the actual corrective action has been satisfactorily implemented,
; as confirmed by the appropriate surveillance, auditing or other j_ - verification effort, quality assurance personnel will verify satisfactory implementation of the action, date and sign the request form to indicate
! quality assurance approval. Affected activities are then distributed
. copies.
i' b) Corrective action forms are filed and logged and the effectiveness of , the corrective actions is reviewed by Quality Assurance personnel.. Such actions may include stopping the Vendor effort for poor quality ~ performance or stopping the affected activity effort for disregard of t j i approved QA or project procedures.'. , ! c) Feedback information on nonconformances is transmitted from both1 procurement and QA Vendor Surveillance to UE&C Quality:Engineeringa r. The data are analyzed and evaluated by UESC QA and UE&C. Engineering . personnel, after which corrective action is recommended to assist: in controlling and preventing recurrence of nonconformances. d) . Significant deficiencies in design or construction will be repoited ' promptly to WPPSS.' These activities are governed by written procedures.
' i 17.'2-36
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I WNP-1 PSAR j 17.2.16.5 railure to Respond
.( a) Failure to respond either by the Vendor or UEEC responsible per-sonnel to corrective action requests within the allotted time will result in notification of next higher level of management with a 'l requirement for inf vdiate response. Lack of response by manage-ment could result in stoppage of work in the affected area in 2 accordance with approved UE&C Quality Assurance procedures. <
17.2.16.6 Stop Work Authority , a) Stop work authority for "Home Office Activity" rests with the UE&C Project Engineering Manager for the project based on , direction received via a "Stop Work Order" from the Supervising Engineer-Project Quality (SE-QA). Stop work authority for UE&C site activities rest with the UE&C : Project Manager based cn direction received via a "Stop Work I order" from the Field Superintendent-Quality Assurance (FSQA). b) Stop work authority for Vendor and Contractor Off Site Plant !. activity rests withi he tUE&C Project Engih~eeiring Manager for i the project based on direction received via a "Stop Work j Order" from the SE-PQ. ; c) Work may be restarted with the approval of the SE-PQ only after action has been taken by either the "Home Office ! Activity" or the Vendor and Contractor to eliminate the' C_ , nonconformance and the UE&C Project Engineering Manager for , the project has satisfactorily replied to the "Stop Work Order".
. Site activities may be restarted with the approval of the-FS-QA only after action has been taken to eliminate the nonconformance and the UE&C Project Manager has satisfactorily replied to the "Stop Work Order". .
17.2.17 Quality Assurance Records The UE&O Quality. Assurance program provides for drawings, contract ! specifications and procurement documents to delineate the Quality Assurance records that vendors and contractors are required to prepare, maintain { and~ submit for review and approval to provide documentary evidence of , quality. These records must be identifiable and retrievable and include, but are not limited to, drawings', specifications, material test reports,, qualification records of personnel, procedures;and equipment, calibration
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procedures and reports, nonconformance and corrective action reports.and inspection and test records. UE&C will maintain the_WNP-1 Quality Assurance files for activities and' items under UE&C cogni~zance. -_These , files will bi available for_WPPSS' review. 17.2.17.1 Records Requirements ;
. a); Specific records requirements for' Vendors-and Contractors are
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D identified in procurement documents, contract specifications,' codes '
.and standards, and.-in the.UE&C Quality Assurance procedure manuals'
- 17.2-37 .
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s ua
WNP-1 PSAR
- which govern quality associated activities. 'These include records
( of the results of reviews, inspections, tests, audits, material analysis, monitoring of work performance, qualification of personnel, procedures and equipment and other documentation as defined in Subsection 17.2.17. b) The record system at UE&C in the initial phases of the engineering and procurement program includes those quality assurance records. associated with the design, engineering, manufacture, testing and inspection of structures systems and components. This record system
- is initiated with the early concept of the WN;. A project. UE&C quality assurance procedures govern the general and specific require-ments, development, transmittal and receipt, audits, storage, retrieval, and disposition of quality control and quality assurance records.
c) The records that vendors are required to retain are maintained sub-sequent to completion of work in accordance with the applicable codes, standards and procurement documents. d) Records that are shipped with Vendor or Coittractor equipment are transmitted in accordance with the applicable codes, standards and contract procurement documents; and upon receipt ~at the con - struction site (s'ubsection 17.2.17) become the respcusibility.of the appropriate receiving organization. T' 17.2.17.2 Records Accuracy and Traceability ( a) UE&C con *.ract specifications establish the provision for the vendor and Contractor to have a systemized method for verifying and documenting that their documentation is. complete and correct. Vendor records.will provide sufficient information - to permit traceability between the records and'the item or activity to which they apply. Contract specifications direct the Vendor and Contractor to provide a positive method of traceability from documentation to the part. Their method will be defined in procedures. approved by UE&C. b) QA records which are submitted by the Vendor as part of contract specification requirements are continuously reviewed by UE&C. Nonconformances or shortcomings-which are identified through these reviews are immediately reported'to the Veador for cor-
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, rective action. . Review of resubmitted data will provide the extent of vendor positive actions. 17.2.17.3 Records Examination a) All UE&C, Vendor and Contractor quality assurance records for the WNP-1 project are the property of WPPSS and are subject to. review, audit-and inspection by UE&C and WPPSS Quality. Assurance.' Records. are not to be destroyed or otherwise disposed of without written: ! I M 17.2-38 : l 4 p : - ..
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4 . WNP-1 l PSAR I
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t ^; consent of UESC or WPPSS Quality Assurance. UE&C contract ! documents allow for UE&C or WPPSS to acquire possession of any-quality assurance records generated. b) Vendor or Contractor quality assurance records will not be altered, j ' changed, modified,or corrected withoutLproper justifications and in i accordance with a vendor or Contractor procedure which provides for: appropriate review or approval. Any change or correction includes-the date and identification of the person authorized to make the
] ;
j change or correction. I c) UE&C Quality Assurance records are under the same requirements as that'specitied in subsection 17.2.17.3.b. j i " d) Review by UE&C of the Vendor drawing control system'is also , effected to ensure their use of correct revisions of drawings and i procedures. A review of the' vendors in-process inspection fre-
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I
- que.ncy is performed to assure that there are provisions for early.
detection on nonconforming conditions during the manufacturing cycle.. ; verification that NDE and inspection and test requi2.e.2ents of the ; contract have been properly incorporated into the appropriate procedures is also accomplished.
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i - 17.2.17.4 Record File and Storage , i a) UE&C's records are maintained at the Home Office and site office and are identifiable and retrievable. These records include among others, drawings, contract specifications, calculations, stress i reports and evidence of design verification. _UE&C maintains these , i l records and the duplicate sets in accordance.with applicable project procedures.' These records-are available for WPPSS or. Regulatory-Agency review and audit. .Upon completion of the work, a complete ~ set of ~ , records will-be available to WPPSS for retention. r b) UE&C's quality records are maintained, identified;and filed at the Home Office and site office as detailed'in approved project. procedures. . UE&C, through audit or surveillance will' assure that . Vendors.and contractors maintain, file and store their QA~ records
- for the equipment or services in'accordance with their QA and~
contractual' comunitments. ; 1
- . 17.2.17.5. Records Retention' 4
i a) Primary responsibility for retention of'QA records-is listed ~
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and identified lin the appropriate UE&C QA-and Project Procedures.. . .
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L17.2-39. w > ~ a a a-4 . s.- ,.. , 4 w.. , . - w. v- ,-w e. ,- - .n.;--- % .e-. ., J y-
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, b). Retention period for QA records will be determined by WPPSS in accordance with guidance afforded by ANSI N45.2-9, Appendix A in which the " lifetime" and "non-permanent" categories for QA: ,
records are indicated." ' 17.2.18 Audits The quality assn ance program for the WNP-1 project provides for scheduled and unscheduled periodic audits which will verify compliance with the applicable Management, Engineering, Procurement and QA activities. The audit records of i UE&C internal practices offer objective evidence of implementation of and 4 compliance with requirements, and consist'ncy e in'the discharge of responsi- { bilities. . 17.2.18.1 Types and cr.tegories a) Audits are being performed as " internal" audits, where audits are performed on specific elements of the WNP-1 Quality Assurance Program; and as " External" -audits, where -erudits are conducted at - Vendors or Contractors facilities to ascertain his conformance to contractural requirements, including engineering specifications,
- codes and standards. Both types of audits are performed in accord-ance with written check lists by quality assurance personnel who, by the nature of their position, are independent from the engineering g and manufacturing disciplines. " Management" reviews will be performed
(' by the UE&C Vice President of Administration on an annual basis to j verify compliance with the established UE&C corporate Qh' program. t .. b) Internal Audits , The general categories of Engineering, Purchasing (Procurement),
- Quality Assurance & Vendor Surveillance are those QA functions of UE&C which are subject to the UE&C internal audit program.:
j In addition, UE&C will perform audits of the UESC site'activitie~a. The effectiveness of the technical portion of the WNP-1 program 4 is also subject to the UE&C cudit program. Prior to conducting
- ~ an audit, the auditor (Team Chairman) prepares a written. checklist
; delineating the characteristics to be audited. The audit is then conducted in accordance with this checklist and upon completion of 7
the audit, the results'are presented, discussed and summarized in a written: audit report. c) External Audits < The purpose of external audits is to determine if the supplier has. provided adequate control over his manufacturing processes ^ connected with the c'omponent being; manufactured. While UE&C QA Vendor. Surveil-lance has the responsibility to perform a QA. surveillance function + for the procurement of purchased items, the UE&C audit function ' has the: responsibility to verify that thefsupplier'is injtlementing-his approved QA system. L
.( 1*/.2-40 s- .
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1 WNP-1 , PSAR > (- d) Management Reviews i t The purpose of.UE&C Management Reviews is to ensure that the , adequacy and status of the Corporate Quality Assurance program i is being accomplished.- Annually the UE&C Vice President Admin-istration u ranges for a corpore 1i review of the activities of i the UE&C Reliability and Quality Assurance department for con- , formance to the provisions of the UE&C Nuclear Quality Assurance Manual. A byproduct of the review is the eventual impact of. the results on various UE&C Nuclear projects including the WNP-1 ; project. The review is conducted under the responsibility and . authority of the UE&C VP Administration and his designated review -! team, selected from areas of corporate management and other activities not having direct responsibilities for UE&C Quality Arsurance Actions. 1
-i 17.2.18.2 Audit Planning a) The Manager - Audits prepares a " Project Audit Schedule" for the WNP-1 .
project identifying QA and technical program elements or activities, . established frequencies per specific project comunitments, dates of audits, including verification audits, auditor (s) and tentative- , _ . dates of subsequent audit. The frequ ncy of scheduled audits is 3 g- at least once annually or at least once within the life of the (- activity, whichever is shorter, or as ; established by the, Marmger- - Audits, in ennjunction with the responsible project QA personnel. After an initial (external) audit, a Suppliers' quality performance history may be re-evaluated annually to determine the need for conducting a re-audit. Results of the evaluation will be documented' and recosamended actions concurred with by responsible R&QA management. The evaluation and subsequent formal re-audit shall consider the criteria as defined in the detailed UE&C QA program procedures. . In any event, suppliers will be audited at least once every 3 years. The Manager - Audits is then responsible for the preparation, sel- .
. ection of audit teams, conducting the audit, post audit-review /
critique, audit report / distribution and completion of.the audit.'-- b) Supplemental audits are conducted as required on the basis.of.the
' ' ~
following factors:
- 1) - Where work and activities have started in areas'not' scheduled for an audit; '
1
- 2) When verbal or written complaints of significant quality deficiencies, nonconforming trends or discrepancies are detected. ;
' 3) Where previous audit of' areas or activities indicates'a need for. additional auditing. .
17.2-41 i , J m- e- e s- %a <w- 6-% Hw* ~<ve- -w- n '-n M + -'m- a
WNP-1 PSAR I (
- 4) When it is suspected that the quality of an item is in jeopardy due to deficiencies in the QA program.
- 5) After award of a contract or purchase order, to ascertain conformance to contr-% ural requirements.
17.2.18.3 Audit Team a) One or more individuals comprise an audit team, although UE&C prefers that a team of at least two " qualified" individuals perform an
- .udit. At least one Quality Assurance Engineer is a member and usually functions as the team leader, with other team members being-selected from various UE&C departments or projects as arranged for by the audit function.
b) The selection of auditors is based on their qualifications, special abilities or expertise and personal characteristics, comunensurate with the complexity or special nature of the activity to be t.udited. c) Suitable training is conducted for auditors as required and deemed necessary which entails on the job guidance and counseling under direct supervision of a lead auditor. Such training shall include planning, performing, reporting and follow-up action involved in conducting audits. . d) An annual assessment of lead auditors is performed by UE&C Audit Function to reflect qualification based on - o Regular, active participation in the audit process. o Working knowledge and understanding of applicable. elements of l NRC 10CFR50 Appendix B, ANSI N45.2 and Supplemental Standards, related to the quality assurance program. o Participation in audit related training and orientation program described in subsection 17.2.18.3.c. f 17.2.18.4 Internal Audit Procedure a) Preparation for the internal' audit-includes reviewing reference documents applicable to the work, activity.or procedure to be audited,.
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. preparation of check lists and a brie.f pre-audit conference'with the 4 Cognizant Activity Supervisor to confirm the audit scope, present the audit plan, introduce auditors and establish' channels of ,
- communication.
1 k 17.2-42
4 o, . l 6
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PSAR ( b) The audit is conducted and upon completion of audit acMons, the audit team holds a critique to inform the responsible management of the result of the audit. ! c) The audit report is issued within a designated time period after , the audit in which the overall results of the audit are sununarized. Copies of the audit report are sent to variods UE&C corporate management levels as defined in the applicable QA procedure. d) . A response in writing to the audit report findings is made to the Manager Audits and the Audit Team Leader by the responsible super- i vision of the activity audited. 'The REQA audit function evaluates and analyzes the reply for. responsiveness to corrective actions and conducts a follow-up action to assure implementation as , scheduled. _
.a w * ,
Failure to respond by the audited activity could result in work ; stoppage of the " activity" in accordance with an approved UE&C Quality Assurance procedure. E
'17.2.18.5 External Audit Procedure ,
a) Preparation for and conducting of " External Audits" proceeds in accord-ance with subsection 17.2.18.4.a thru 17.2.18.4.d except that the Audit Team Leader coordinates with the appropriate Project Engineering and Purchasing Personnel and the QAE for_ scheduling arrangements with-Vendor or Contractor. b) Preparation for and conducting audits of Engineering Consultants proceeds in accordance with subsection 17.2.18.4.a thru 17.2.18.4.d cy. cept > that the Audit Team Leader coordinates with the appropriate Project-Engineering Personnel and the QAE-for scheduling ~ arrangements-with the Engineering Consultant. I 17.2.18.6 Management Review Procedure Management reviews shall be conducted in accordance with the UE&C Corporate-Quality Assurance Manual. 17.2.18.7 Audit File A complete record file is kept of all audits,'which provides UE&C and WPPSS > Management with the means to analyze and evaluate the total WNP-1 Project'. .i Quality Assurance Program. i N_ 17.2-43 , i
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-- WNP-1
( PSAR 17.2.18.8 Audit Analysis a) The monthly status report of QA audit activities is published by the Manager-Audits with distribution.to UEEC project and Corporate Management. The report identifies QA Audit findings from audits ) conducted during the reporting period and records the status of items still pending from previous audits. b) The Manager-Audits uses these reports as the basis for determining the effectivent ., of the various areas of the Project Quality Assurance Program. When unsatisfactory trends-are observed, the Manager-Audits publishes a report to UEEC Corporate Management with~ particular attention to those areas showing the trend. c) The Manager R&QA pursues resolution of those areas of concern which indicate a decrease in tha effectiveness of-the project QA program.
)
17.2-44
I
* 't e WNP-1 PSAR TABLE 17.2-1 UESC PROCEDURE $ - 18 POINT CRITERIA UE&C TITLE 10 CFR 50 Procedure No. Appendix B Criteria QA-1 Organization I QA-2 Quality Assurance Program II QA-2-1 Indoctrination and Training II QA-3 Design control III QA-4 Procurement Document Control IV QA-5 Instructions, Procedures and Drawings IV QA-6 Document Control- VI QA-7-1, 7-2 Control of Purchased Material Equipment VII and Services VIII IX QA-lO Inspection X XI
'XII 9 XIII XIV QA-15 Nonconforming Materials, Parts XV.
or Components QA-16, 16-1' Corrective Action XVI' QA-17 Quality Assurance Records XVII , 1 4
-QA-18, 18-1 Audits XVIII
*~ NOTE: These criteria are-not applicable to UEEC in their. role as Architect-Engineer.
O, s l TABLE 1 , WPPSS, UE&C INTERFACE CHART 3 Respon- e. Review & . Interface Item sibility Initiate Prepare Comument Approve Support Inglement Issue Distribute Control LTf C Q L crganization U U U U, V U - U . - U UE&C QA Program' U U U Ue W U. U - U IS IS U Ivocurement contract Specification U U U U, W U, W . g y g g, g - U U U U, W U, W - U U U .U UE&C QA Procedures UE&C Drawings (Initiated) U U U U, W U - U U U U UE&C Project Procedures .U .U U U, W U, W . U U U U U U U U, W U . U g U- U UE6C Construction Procedures
- g .6 Vendor Procedures Y Y Y ~ Ye U V, U - V V V V t/s 9
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Contractor Procedure .C C C C, U C, U - C C C C NSSS Drawings.- .N N N N, U, V N - N N N N NS$$ Submittals N N N N. U, W N - N N N N vendor Surveillance Planning, Scheduling U U U ~ U, W U U, W impf mant ation V ( - - - 4 LT6C Special , QA Processing g, g g g g g, g , , y , v Contract Documents Vendor & Contractor Audits & Docurwntation U 'U U U U - U U U U UE&C Internal Audits . 'I & Documents U U' U .U U - U U U U
-r NSSS Audits 1 W W W W W U V W W W U = UE&C W = WPPSS -
V = Vendor C = Contractor
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- . WASHINGTON PUBLIC POWER SUPPLY SYSTEM UE&C CORPORATE ORGANIZATION CilART l WPPSS NUCLEAR PROJECT NO.1
- Preliminny Safety Analysis Report
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j 3l . AJ WASHINGTON PUBLIC POWER SUPPLY SYSTEM UE&C R&QA DEPART!DT AND TIIE WPPSS ' NUCLEAR PROJECT NO.1 ORCANIZATIONAL RELATIONS!iIPS Preliminary Safety Analysis Report - l FIG. I7.212'
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Preliminary Safety Analysis Report l FIG. 17.2-3 4A , _, 8'
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PSAR 17.4 00ALITY ASSURANCE DURING DESIGN AND C0i!STRUCTION
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- This section sumarizes the Field Quality Assurance activities assigned to the Bechtel. Power Corporation and United Engineers & Constructors,
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Inc., as they pertain to WMP-1/4 Project si.te activities. The Bechtel Power Corporation has been assigned by the Supply System to - provide a Quality Assurance program to implement the responsibility of-Construction Management and related Quality Assurance services at WNP-1/4.- United Engineers and Constructors, Inc. has been assigned by the Supply . System to provide a Quality Assurance program to implement the responsi-bility of Architect Engineer for WNP-1/4 and Construction Management and related Quality Assurance services as they pertain to ASME III Div. 2 responsibilities as " Constructor". The Bechtel Quality Assur'ance program plan is described in the NRC . approved Bechtel Topical Report, BQ-TOP-1, Rev. 3A.: The Bechtel si: ope of responsibility differs from that indicated in BQ-TOP-1, in that Bechtel does not provide design, engineering, construction, or procurement services
... for WHP-1/4.
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l 4 i WASHINGTON PUBLIC POWER SUPPLY SYSTEM i i PSAR DEVIATION REQUEST WNP- 1/4 1 oav8ATION Mo. PAR AG A Appe No. oATa ! 17.4-4(WP) Rev. 3 Chapter 17.4 3/17/83
- t. PsAn comm:TwamT As or 9 /78; rLAsr AasanomanT oAra): inwcLuos san sTAvansapeT) 1
- puo novin+1nn 17.4 (WD1_17.4-d(WP) Rev. I and Rev. 2 currently defines Bechtel
; onwar enrnnemtinn am tha WNP-1/4 Construction Management Oroanizaticn. =
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- . Revise Section 17.5.2 to indicate that Bechtel is no longer responsible for maintenance (PM) activities. Storage of prepurchased items and inspection i of storage areas is re'tained by Bechtel.
- s. gT,s4gTganvirvmo seonsricAnca or oaviarsoees tu weear is same anososso THAT as oseramant enons esan j _
Revised deviation reflects the change in resocasibilities for dreventive , maintenance from Bechtel to the Sucoly System. l ( 4. JusvericAriom cu axe 6Am wny Tns oasinao CnAnoa is ausvarian Ano is expacTao To es oaransista sarons Tna naca i , OA Pennram ranniraments have not been reduced. This chance only reflects f the channa in racnonsibility of an activity from Bechtel to the Sunolv System. l S. suPP6Y sYsTau AppstovALag j OAT. i enapAnao evi gf g,f, A7. j g /g,p PRoJaCT Petoe A of Tom ~ OAT. k Y$..I $
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w, i - y i MC Carrigan 81 8 CB Organ 823 BDCC '82B ~ GK Dyekman 823 DD O'Sullivan 280 WWT/lb CR Edwards 819 RW Root 821 RB Glasscock 280 EC Hood 817 TJ Houchins 280 ORM 847 November 8,1982 WPBEC-82-5508 Mr. J. P. Lasoa, Project Manager Bechtel Power Corporation - WNP-1/4 P. O. Box 650 - Caller Service Richland, Washington 99352
~. _
Attention: J. L. Ruuc (829.)
Subject:
NUCLdARPROJECTNOS.1&4,CONTRACTC-0462 BECHTEL PRELIMINARY SAFETY ANALYSIS REPORT
Reference:
BECWP-82-6238, same subject, dated October 27,1982 Supply System Project Quality Assurance has reviewed Bechtel's revised WNP-1/4 Quality Assurance Program for the PSAR and has determined that it is acceptable and therefore approved. Any subsecuent revisions or changes to this document must be approved by the Supply System prior to implementation. To assure that no misunderstanding exists relative to the cocument being approved at this time, the revised Quality Assurance Program .. which was provided to the Supply System Project Quality Assurance Manager on October 27, 1982, is attached.
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F. C. Hood Acting Assistant Program si ' c ar - ..rr:truccen .:m WWT:dm Attachment cc: EC Haren, United Engineers . uns truct.wn, ;nc. J'95) , CK Kasch, Cechtel Power Corporation (036) l JL Ruud, Bechtel _ Power Corporatinn (329) an 1-ur-car tTW Tillerv 4eca ' ass n...E : ' l =ct:ca i FC Hood l e. a 2. sewer,:.'. 3 ' 4 i 1- ' CR Erwa.rds 3 - i '
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SUMMARY
OF CHANGES BECHTEL'S Q.A. PROGRAM DESCRIPTION FOR THE SAR SECTION NUMBER ITEM RELATED TO 17.5.2 Deletion of 'Becthel's This Responsibility is Responsibility for Main- Now the Supply System's. tenance of Supply System Purchased Items. k 49g
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Quality Assurance Program t BECHTTL POWER CORPORATION WNP-1/4 I' 17.5.1 Ouality Assurance Topical Report I ~ The Bechtel Quality Assurance Program Plan for use b'y the Bechtel Power Corporation during Construction Management of Washington Public Power Supply System (Supply System) Froject WNP-1/4 is described in the NRC - Approved Bechtel Topical Report BQ-TOP-1, Rev. 3A, Bechtel Ouality Assur-ance Procram for Nuclear Power Plants. l 17.5.2 Scone of Resoonsibility i p This section describes Bechtel responsibilities for providing quality-
- related services in Construction Management- to the Supply System on the WNP-1/4 Project excludhg ASME III, Div. 'II activities. The scope of
! responsibility differs from that indicated in BQ-TOP-1 in that Bechtel does not provide design engineering, procurement services nor perform construction. Therefore, those provisions in BQ-TOP-1 associated with design engineering, procurement services and performance of construction do not apply.
- j. Bechtel will have an Engineering Liaison group under the direction of j the Project Engineering Manager available.to support the Construction Management organization. Engineering personnel will- assist in;coordi-
, nation resolution of generic QA/QC problems with responsible design
~ . engineering groups, interfacing with Supply System licensing personnel, and assisting in engineering /startup interfacing areas.
I Construction Management provisions for quality-related services include: o Receiving including receipt inspection of Supply System purchased items. go Storage of Supply System prepurchased items and inspection of storage areas.
- ~
o Contract / vendor QA' documentation review, retention and ~
- turnover to the Supply System. '
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o QA/QC audit and surveillance inspection over on-site contractor activities. o Administration of the project program for controlling non- ' conforming' items.
~
o Administration of the project program for. control of design ' - doctments. 17.5.3- Project Unique Modification to BO-TOP-1. Rev.~ 3A
'o' Introduction Page 2.-(Replace: Regulatory Guide 1.58 :(August,1973)f with Regulatory Guide 1.58, Rev.c1'(September, 1980)..
co' ' Introduction' Page 2 - Add Regulatory-Guide 1.146 " Qualification l - of. Quality Assurance Program Audit Personnel for Nuclear Power o ' Plants'(Rev.;0 1978)."- T - .
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( b o Section 1 ORGANIZATION Subsection 1.5.1'Page 10 - Add Subsection - 1.5.1 Attachment 1. ' ' . ~ I: o Section 1 ORGANIZATION Subsection 1.5.2 'Page 10 - Replace Subsection
.1.5.2 with Attachment. 2. -
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o Section 1 OP.GANIZATION Subsection 1.5.4 Page 11 - Replace Subsection ' 1.5.4 with Attachment 3. $.
~?,:04: !?Wc@s..g o Section 2 " Duality Assurance Program" .Sub Paragraph 2 & 4' Page 23 -
. change Regulatory Guide 1.58 (Aagust 1973) to Regulatory Guide 1.58 . . , .
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' \ ,'il d o- 'Section 2 "r)uality Assurance Program" .Sub Paragraph 3 ' Page '23 $' &...f[ .t .
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TABLE 1 "Sechtel Quality Program Documents" Page 57 & 58 - Add to Table 1 T the Project Documents shown on Attachment 4. . ,
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NDPENDIX A Bechtel' Position on QA NRC Regulatory Guides ar!d ARSI Standards - s . Pages A-7 thru A-13. Delete in its entirety. ,, APPENDIX B Division Quality Policies. . tope,.and relationship to 10 CFR 50, . .
~
Appendix B - Add Projec' Nuclear Quality Assurance Manual as shown by Attachment 7. .
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.- ATTACHMDIT 1 -
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The Manager of. Projects ('ig.15).is the senior Bechtel representative assigned
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h0 to the MIP-1/4 Project. The Managei of Ptsjects reports to the Division Manager , of Projects operations and services, and is responsible for providing overall . - project direction to assure the consistent and coordinated application of Bechtel policies and skills for the benefit of the WNP-1/4 project. The Manager i of Project's staff includes a Deputy Manager of Projects and other managers to -. coordinate activities in labor, relations, the quality program and administrative services.
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..' ATTACHMENT 2 1.5.2 QUALITY ASSURANCE l
The SFPD QA Manager (SFHO) is independent of the other managers within the division and has the authority to carry out the re-sponsibilities listed below in directing the Division Quality Assurance Program. He is assisted by a staff of Quality Assurance Managers (SFHO) assigned to functional areas of Program, Training, Project QA, and Audit (as shown in Figure 12). The SFPD QA Manager (SFHO) functions ,for the WHP-1/4 Project include: - o Provide technical guidance and concurrence for the WHP-1/4 Project Quality Assurance Program for confor-mance with the requirenents of 10CFR50 .Apendix B. o Formulate and approve Division Quality Assurance Depart-ment Procedures which define responsibilities, authority and functions of SFPD H>me Office staff. Quality Assurance Department personnel. Review and concur with the WNP-1/4 PQAM and revisions. o Maintain an awareness of WNP-1/4 Project status, through Management Audit and, day to oay contact with the Manager of Quality.-and provide assistance to the Manager of Quality .
- to assure timely and effective implementation of the WNP-1/4 Quality Assurance Program.
( ' o Formulate and conduct Management QA Audits to assure com- ' pliance with the WNP-1/4 Nuclear Quality Assuranca Manual (HQAM) and implementing procedures and to identify quality problems; identify the need for corrective action and initiate, recommend, coordinate or provide solutions; and verify implementation of solutions and corrective actions.. o Provide and maintain a qua?ified and suitably trained ' staff i of Quality Assurance Engineers to carry out required project ' and staff functions. Assign Quality Assurance Engineer (s) to the WNP-1/4 Project 'and. provide them with administrative 1 direction through the QA Manager - Projects (SFHO).
.o Formulate and implement pr'ograms to provide indoctrination and training of Quality Assurance Department Personnel to assure that suitable proficiency is maintained.
o From information supplied by the Manager of Quality, provide -* quarterly reports to the Division Manager and the Manager of f. Quality Assurance - BPC evaluating the status and adequacy of' the WNP-1/4 Quality Assurance Program, and advising of any. - problems requiring program revision or special attention in-cluding recomendations for corrective actions. ~ At least annually, a meeting is held with the Division Manager (SFHO) and his staff on-the subject of status and adequacy of t.he Division QA Program. The Manager of- Quality participates in this meeting to cover the status and adequacy of the WNP-1/4 l -
*QA Program.
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[ . 1 ItANAGER OF QUALITY ~
.~ . .
The Manager of Quality receives administrative, technical, and project i direction from tb Hanager of Projects and is responsible for the project .- l and technical direction of the WNP-1/4 quality assurance program. The , j Manager of Quality receives technical guidance for QA and QC from the i SFPD QA Manager and Chief Construction Quality' Control Engineer (SFHO) . l respectively. He is assisted by, and provides project and technica3 o direction to the Project Quality Assurance Engineer and Project Conmuction Quality Control Engineer. (Fig.16). The Manager of Quality is independent of the other line managere within the Project Management organization and has the authority to carry out the responsibilities listed below in directing the' Quality Assurance Program includin5 authority to stop work or control further processing. The Manager of Quality's functions include: s
. W E M~ i '
o' Provide technical and project direction to Quality Assurance - Engineers assigned to the Supply System Projects. ' hormulate and approve, after review ind concurrence by the ' .
. * ' o SEPD Quality Assurance Manager, the WNP-1/4 Quality Program
. description for~the SAR and Quality Assurance Programs as A.
defined in the WNP-1/4 Nuclear Quality Assurance Manual . (NQAM ). The HQAM shall'.be in conformance,with the requirements' of 10CFR50 Appen' dix B, the BPC Quality Program Policy Manual, and J appropriate Project SAR.- .
- o. Formultte and approve after re' view and concurrence by the SFPD-
^
E Quality Assurance Manager, Bechtel's input to the revisions of -
' . [- the WHP-1/4 Quality Assurance program description for the SAR and revisions to the WNP-1/4 NQAM. Coordinate revisions to implementing procedures to improve effectiveness of the Quality - -
Assurance Program and update the program. - , o Formulate and approve after riview and concurrence by the SFPD
. QA Hanager (SFHO)',the Project Quality Assurance Department .
4 Procedures and revisions for Supply System Projects which define . . r'esponsibilities, authority and functions-of Supply 5ystem Projects Quality Assurance personnel. - . o Maintain an awareness of project'. status through contact with the Manager of Projects WNP-1/4, and assure timely and effective in-. . plementation of the Quality Assurance Program. .
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s.' , [ 782 9 ' Direct the perfomance of project audits to assure compliance with Supply System Pmject HQAM's and implementing procedures, and to N D:.dC $'
-1 identify quality problems; identify the need for corrective action %@
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and initiate, recc=end, coordinate or provide solutions; and verify :.: ' "y,'
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,. implementation of solutions and corrective actions. *{
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o Provide quarterly reports to the SFPD QA Manager (SFHO) evaluatin.g the status and adequacy of the Supply System Projects quality [9 3.5.$ 7 assurance program and advising of any problems requiring program
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revision or special attention, including;recomendations for corrective - .
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n ' program requirements applicable to contractors and subcontractors, 5 . . .:@vy-D and '.~ ~ -7/
' approve for use.on the Supply System.
Projects.
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o Coordinate the Quality Assurance and Quality control functions for 5 .W the Supply System Projects with the Division groups having quality %%.t functions, and with groups outside the Division having quality #~%
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() / ATTACHMENT 3 j I i 1.5.4 ..: . DIVISION CONSTRUCTION , ;
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The Manager of Division Construction (5010) provides technical and administrative direction to the Construction Department ' -
.' personnel. The Manager of Division Construction (SFHO) is assisted :
? by Construction Managers (SFHO), Chief Construction Engineers (SFHO) ;
Jwhere assigned, and the. Chief Construction Quality Contro1' Engineer ,
,(SFHO).' ConstrQci; ion Managers (EFHO) are responsible for the -
N
.. management and technical direction of assigned projects, "and for '
" assuring that construction projects are provided with appropriate H- -
personnel and are following . prescribed division practices and pro- <- cedures fGr conduct of construction activities. Chief Construction : Engineers (SFHO) are. responsible for providing division standard work ! procedures to the projects. . . . ! s
- - . ..- 3;. 3,. 4 f ormal F g:ality verification inspection and onsite contractor surveillance- '
inspection-activities performed by Bechtel are the responsibility of - . The Chief Construction Quality Control !
.. Engineer Construction (3FHOG)ality Control.is responsible for providing administrative directio l to the Construction Quality Control Enginetirs assigned to tne 1:NP-1/4 -
~
Project. l (1 functions,The include:Chief Construction Quality Control Engineer's
. ., (SF ,
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\ e provides administrative diritction to the Project Construction m'. Quality Control Engineer. . . . .
7 o Assigns quality coritrol' engineers to the project. ' .
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o Assists with the training and qualif.ication of construction quality control engineers. ,
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o Provides technical guidance 'to the Manager of. Quality for the
. preparation of quality control procedures and instructions.
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. Originating ^. Review for QA Policy and Authorizing Docucients Au thort ty .f.j..:., d ;. _ Program Requirements . _ Approval Contents
.IllP-1/4 Project QA g'. . i, SFPD,-QA Hanagar (SFilo) Hanaaer of Quality pro 0 ram policy. Dased
.luclear Ouality ,M, ', , ' ' Quality Engineer N. '
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on Division policy as contained issurance'Hanual * (flQAH)
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. SFPD-QA Hanager.(SFil0) .
, Manage'r of Procedures for conducting Project QA Engineer ^.,r
* . quality tanual (PQAll) . i, .
, QA activities lHIP-1/4 Project . 7! .-
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' Project QA Epgineer lianager of Responsibilities and proceduret, Construction Construction,'. Quality Quality for. Construction QC activities
,I C:ntr:1 llanual .
(CQC:1) QualityConfrol .
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INIP-1/4 Fleid Construction Project QA Ehgineer Chief Con- Responsibilities and requirement Construction Hanager. GT' .e..
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, . . struction - for construction manag'ement site Procedures :. .
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.: WNP-1/4 PSAR 17.4 00ALITY ASSURANCE DURING DESIGN AND CONSTRUCTION Scooe: This section summari:es the Field Quality Assurance activities assigned to the Bechtel Power Corporation an.d United Engineers & Constructors, Inc., as they pertain to WNP-1/4 Project site activities.
The Bechtel Power Corporation has been assigned by the Supply System to provide a Quality Assurance program-to imple ant the responsibility of-Construction Management and related Quality Assurance services .at Wi;?-1/4. United Engineers and Constructors, Inc. has been assigned by the Supply System to provide a Quality Assurance program to implement the responsi-bility of Architect Engineer for WNP-1/4 and Construction Management and related Quality Assurance services as they pertain to ASME III Div. 2 responsibilities as " Constructor". The Bechtel Quality Assur'ance program plan is described in the NRC .
. approved Bechtel Topical Report, BQ-TOP-1, Rev. 3A. The Bechtel scope of responsibility differs from that indicated in BQ-TOP-1, in that Bechtel does not provide design, engineering, construction, or procuremer.t services
. , , , for UNP-1/4.
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PSP 3.5.3 WNP-1/4 PSAR DEVIATION REQUEST DEV AT ON NO. PSAR VOLUME NO. PA G PH . DATE
- 1. PSAR C0lMITMENT A5 0F 2/75 # (LAST AMEllDMENT DATE): (include SAR statement Section 17.4 - United Engineers & Constructors Quality Assurance During Construction -
(In It's Entirety) 2 DESIRED CHANGE: (indicate desired statement) Revise Section 17.4 to limit the scope of UE&C's Construction Management QA responsibilities to the Quality Class 1, ASME Section III, Div. 2 Project Activities.
- 3. STATEMENT IDENTIFYING SIGNIFICANCE OF DEVIATION: (i.e., what is being proposed that is different from PSAR connitment) -
. There is no change in previous PSAR - h 'tm as
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Section III, Div. 2 Activities. 4 JUSTIFICATION: (i.e., explain why' the desired change is justified and is expected to be defensible before the NRC) This PSAR deviation is required to accurately reflect the transfer of Construction Management QA responsibilities from UEEC to Bechtel.
- 5. WPPSS APPROVALS: DATE PREPARED BY:
INMJ G-s-si WNP-1/4 PROGRAM DI DATE ROGRAM s, OR, EnlGiflEERING DATE
//m' W/p, ASSISTA8NT4 -;- '
TOR, CONSTRUCTION DATE ASSIST y R J ' [+' , 4-?e ?y MANAGER, QA g 'g DATE {
- mrssa #A L; CENS NG PROJECT MKNAGER D / A ->l _ 4-II r i DATE 4-Af@P/ '
M&- O'? & y js yj MANAGER LICENSjNG DATE 4 i, .
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, PSAR l{
I i 17.4 United Engineers & Constructors Quality Assurance During ':onstruction ' J 4 Scope This section susmarizes the US&C Site Quality Assur-ance program as it pertains to the 18tP-1 Site ASNE Section III, Div. 2 activities. The Project Quality 4 Assurance Program meets or exceeds 10CFR50, Appendix B and ANSI M45.2-1971 requirements. This section des- + cribes that portion of the total Quality Assurance program for the project with respect to the receiving inspection and construction GA activities for the WNP-1 ASME Section III, Div. 2 Equipment and Struc-ture at the Construction Site. The UE&C design and procurement QA related activities are included in l Section 17.2. The term " site contractor" as used throughout thi,s section refers to those contractors having construction site activAty responsibility for providing WNP-1 ASME Section III, Div. 2 Equipment and Services. j f 17.4.1 organization i [ The Project will maintain an independent Site Quality Assurance organisation. Personnel performing quality functions will not be responsible for performing the work which they are inspecting nor will they be res-ponsible for performing the work over which they are providing surveillance. . The Field Superintendent - Quality Assuranos (FSQ4) ' reports to the project Quality Assurance Manager (PQAM) and is responsible for the on-site implemen-tation of the QA program. . The PQAM has acones to the manager Reliability and Quality Assurance thru the '- Assistant Manager R & QA. The FSQk is assisted by a staff with experience in the various' disciplines in--
~
i volved in the ASME Section III, Div. 2 activities. The Field Superintendent Quality Assurance qualifi-cation requirements are
- 1. Education - Technical degree in mechanical, elec-
! ,~ trical, civil, nuclear or me allurgical engineer- ~ l ing, or equivalent, plus special study of quality assurance and control techniques,. testing and inspection methods. I i
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- 2. Experience - Ten years of related experience
- in responsible engineering or Quality Control
, positions may be considered equivalent to i required technical degree. A minimust of five years experience as a Quality Control Super-visor or Engineer or the equivalent in respon-sibility and scope, is a prerequisite for the position.
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WNP-1 PSAR-17.4.1.1 Sita Que.lity Assurance l i ) i The site Oh organization is supervised by the Field Superintendent Quality Assurance and includes Engi-j neers knowledgeable in all phases of construction, j quality assurance and quality control. The Quality _. __ l Assurance interface with Construction Management is , shown in Figure 17.4-1. The Field QA Personnel are - responsible for these activities: _ ._._ - _ - . l- - --~ ~ "~~ a)' Plan, develop and implement audits of site con-
- b) Develop receiving inspection check plans for pre- - - . . .
l . purchased equipment. . - . . . ! c) Develop surveillance check plans for construction activity. , j { i j d) Provide surveillance over material storage,
- handling and control activites.
? j - e) Identify and document nonconforming materials and i conditions. h
'~
j q f) Provide receiving inspection of pre-purchased __ j items. ,
' ~ ~ ~ ~
g) Perform surveillance and audit cf site contractors. l h) Provide Site QA liaison with Client, Engineering, j Construction Management and Site contractors. .
., i
!. 1) Assure necessary QA documentation has been provided, , i reviewed and approved by appropriate personnel. j) Establish and maintain site master-Quality-Assurance Files of records generated by Site j QA or f.urned over to Site QA by others. k) Provide those inspections requested by Construc- 1 , tion Management to verify quality of contractor i construction.- ! l 1 17.4.2 . Quality Assurance Program i The Quality Assurance program is comprised of those planned and systematic actione responsive to the ap-plicable requiremente of ASME Section III, Div. 2 ( 10CFR50, Appendix B and ANSI N45.2-1971 necessary to ( provide adequate confidence that Safety Related Structures, systems and components will perform sat-infactorily in service. The Nuclear QA Manual and changes thereto will be subject to approval by the-client. .
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l ~i. , s. NNP-1 , PSAR 17.4.2 Quality Assurance Program (Continued) The nuclear QA manual forms the basis of the Quality-Assurance program and response to the NRC criteria for site implementation as follows: 17.4.2.1 Response to NRC Criteria a) O_rganization The Project will maintain an independent Site
- Quality Assurance organization.- N Field Superintendent Quality Assurance (FSQA) reports to the UE&C Project Quality Assurance Manager and l is responsible for the on-site implementation of
. the QA program. The FSQA reports directly to the i PQAM in all quality matters. The Project Qh Man-ager has access to the UE&C Manager Reliability and Quality Assurance through the Assistant Man-ager R & QA for administrative directions. The FSQA will be assisted by a steff of experienced i
QA Engineers in various technical disciplines. The organizational interface of the Site gh group is shown on Figure 17.4-1. Site Contractor QC q organizations will be reviewed and approved by Site QA prior to implementation of the contracts. j b) Quality Assurance Program 1 The QA PLogram as described in the Nuclear.QA Manual established for MMP-1 consists of speci-fic QA requirements to be carried out within Project QA's predetermined scope of work at the ' i site. UE&C will require site ocntractors and suppliers providing Quality Class I equipment to
- implement Quality Assurance programs that are in compliance with the applicable criteria of ASME Section III, Div. 2, 10CFR50, Appendix 5 and ANSI M45.2-1971.
c) Design Control Through a planned system of review and approval cycles, design changes and construction revisions , ~. will be controllo1. Errors and deficiencies in' i the design change process which adversely affect safety related structures, systems, or components will be documented and the proper corrective action i taken. Design and specifications including field changes, will be subject to the same design controls
; . applicable to the original design.
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- 17.'4. 2. -1 lessonse to NRC Criteria (Continued) 4
, d) Procurecent Document Control Site QA wi n implement a program of control o'ver site contractor procurement documents, processing.
i and construction proce.dures in order that Con . tractor Quality Assurance programs, as specified, are consistent with the appropriate prov1sions of'10CF150, Appendix 3. The details of the
- contractors program for -spare and replacement ,
parts will be reviewed for coupliance with the Contract Specifications. *
. j
~
e) Instructions.'Proceduresi and Drawings { Ina Project implements a program of control over ' t Site Contractor processes and construction pro- ! ! c'edures, instructions and drawings to assure.
- that all quality related Contractor activities are contro ned. Audit and surveillances of i these activities will be performed to verify ,
-
- these activities by Site QA. -
f) Document Control ,, Provision for maintenance, approval, review, dis- *
. tribution, filing, upd.ating, and a6aitoring of .
Contractor applicable documentation will be
~
implemented as a result of the Project and Con . , tractor Site QA Programs. Document files will be contro ned and maintained to preclude the inad- 3 vertent use by the Contractors of obsolete or
. superseded documents. Document control systems win be established and implemented by 'the. Con-tractors in accordance with Contract Specification .
reouirements. *
. g) Control of Purchased Material. Equipment & Services l . Inspections of materials and equipment at the ,
. construction site win be performed in accordance i- -
with pre-determined inspection' instructions i- prior to their use. Project and Site Contractor *
~
' procedures viu also provide for auditing and
- surveinance activity to assure that qumHey ,
~'
. requirements for accepting and releasing materials
..and equipment including noncomformance activity l
-is being implemented. Control of records win be in accordince with 17.4.17.
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( 17.4.2.1 Response to NRC Criteria (Continued) h) Identification and control'of Materials, Parts, and Components b Identification and control systems using tags and
- stasos will be esployed where appropriate at the i site for pre-purchased and Contractor purchased materials, parts and components to provide iden-tity and traceability of the status of materials, parts and components-thru storage and release for installation. Verification of the correct identi-fication of these items will be accomplished in the program prior to installation.
t i) Control of special Processes The Project (UE&C) will not perform special pro- ' cesses during construction, but the QA program imposes the applicable contarols of procer.ses and personnel on the site Contractors. Special pro . cedures and requiramants for the qualification i -
, and certification of the process and for the , personnel performing these processes will be in-posed. Site QA audit and surveillance of these (e activities will assure that the contractors are conforming to their approved procedures. Docu-mentation and records will be retained and maintained current and active.
j) Inspection ! Site inspection activities of site contractors ' s i affecting quality will be verified through surveillance and audits of these inspections
- of materials, parts and components when received, handled, stored, and' installed. Procedures and' instructions will be implemented to assure that receiving inspections, construction inspections <
and final acceptance inspections are conducted by qualified site contractor personnel to verify acceptability. { Initial receiving inspection of pre-curchased ' s ASME Section III, Div. 2 material, parts and , I components will be conducted by site Quality Assurance personnel to assura, through planning
- and implementation, the acceptability of the material / equipment received at the site..
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. k) Test Control * .
The'QA program for Test Control is delineated in the Contract Specification and provides for the performance .~of tests in conformer ca with Engineer- - ing and tons,truction practices,and. code require-l meats. Storage tests, measuring and test .
~ ~
l* equipnent tests, receiving tests,:insta nation casts, and . ocher field testa are typical of those l tests performed by qualified personnel. Pre ' operational and performance startup tests are in l, , accordance with Chapter ,14 of this USAR. } *
- 1) Control of Haasuring and Test Equipment " - .
j An measuring and testing equipment used at 'the l
'ite s to determine the ecceptabili'ty of material, equipment or installations, win be under control of a site calibration program, with calibrations ,
performed against standards of known accuracy. , The system established by the QA program controls, calibrates and adjusts those tools, gauges, instruments and other inspection > :.sasuring, ~ ( ) ~ testing and .na:.acenance devices used at tee Et'e'.' The system vill also control the usage of the l- . proper type, range and accuracy of the measuring and testing devices including records and docu . - { i mentation pertaining thereto. ' i a) Handline. Storate, and Shioning ,
. . Storage, preservation, handling, and cleaning activities at the sit's are controlled by a QA ,
program administered by'contraictors at the WEP-1 i .i Site. Each site contractor responsible for 1. . administering the storage of site me,terials and equipment provide written, approved procedures Q
- Q ..
defining their program in terms of storage in- - i spection, maintenance, hanA14ng, surveinsace
- I and records activities. .Periodf c sury 411==ea .
and inspection of storage records will enable
'-- Site QA to verify the adequacy of the control,. .
. exami ation, review and filing procedures. ,
. n) Inspaction. Test and Coeratins Status l
i The QA program provides measures for indicating the status of tests and inspections performed on ( . . material, parts and ec=ponents when received,
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- n) tested, inspected, stored and installed at the i construction site. h status of the item is i established by a Project system of tagging which,
- when applied and recorded, prevents their inad-
! vertent operation and precludes the inadvertent j by-passing of their inspection and test require-i monts. ! 0) Nonconforming Materials, Parts, and C - aants h QA program provides that site Contractors
- identify, docinment, segregate,. review and dis-j
- pose of nanconforming materials, parts and com-j ponents at any stage of fabrication, erection or i construction to prevent their inadvertent use or i installation. Nonconformances detected either by l site QA or site Contractors are initiated, con-trolled and documented in accordance with an ap-proved procedure. A Nonconformance Review Board
. 'will be authorized to control site deviations i j and will be representM by key site paraonnel from ~ 'l l
1 ( ( WPPSS and IE&C. The program alac provides for the reinspection of all site affected activities to clear nonconformances. i l p) Corrective Action ! The QA program provides for the identification, i i documentation, reporting and dispositioning of l l those site conditions adverse to quality. h se -* j site conditions adverse-to quality are determin- { ed and corrected to preclude repetition. The 1 contractor. implements an approved program and responds in a timely manner to his own corrective , action requests or to site Qk's. The program also i provides fnr the implamentation, verification, and .
! analysis of corrective actions and assures man-l agement action for lack of response.
I
- q) Quality Assurance Records l ' site master files of QA records will be maintained and controlled by site 94. The On program also
- provides for the acc mulation, organization, cus-tody and retention of QA and QC records by site j Contractors as referes.ced in Contract specifica-
- , tions and the Nuclear QA Manual. Records will i ,' also be reviewed, filed, stored and retained in-
-- 'V 'accordance with approved procedures, i ..
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- 17.4.2.1 Response to NRC Criteria (Continued) q) to provide emplete and acceptable " Turnover" documentation packages. Records,will be identi- i fled and filed to provide accurate retrieval l without delay.
{ r) Audits , , Th's Audit Progran at the site provides for - regularly. scheduled and unscheduled audits of l site quality programs to verify compliance with' approved QA and QC procedures. Audits of the f contractors construction and instanation prac '* i 4
- ticas will assure contractor implementation and '
- compliance with the requirements. . Audits .will - .. !
be performed at the site to verify the a,ctivi- l ties of Project Construction Management and' Site l ' - QA are consistent with the.appro' ed. v procedures [
- and documents gover'ning their site activities. l Record files of audits will be kept to provide , i l ,
j Project Management with a means to analyze and ,
. evaluate the contractor effort. -
. l
. t 17.4.3 Desien Control ,
The .Proj ect, through its detailed procedures for implementung '
- design control on the WNP-1 project, provides the assurance -
f that field design activities of safety related items are !
~
carried out in a planned, controned and orderly manner. The l design activity in the field will be essentially implementa- ~
, tion and control,of design changes initiated in the field..
4 All field design changes will be evaluated ' reviewed and approved 1 in accordance with approved Engineering and QA procedures and ! vin be subject to similar design control as the basic design j document.
- t
. [
l 17.4.3.1 Field Desian Channes , a) Design changes initiated'in the field'will be ,
. subject to a controlled procedure of initiation, ,
evaluation, review, sign-off and implementation. An changes and deviations from the original ~ design will be reviewed for impact on quality
- t s
- control, quality assurance and code requirements * ;l associated with the impact on the design speci- -\
fication. Site Quality Assurance personnel will [ {
** . review such changes and the resulting QA/QC- ;
impact. ,, l f - e: i t .
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^ 17.4.3.1 Field Design Changes (Continued) l
-( b) Approved revisions to design documents will be I
l distributed to Construction Management, Site Qui, .l and Engineering personnel via standard distribu- ! tion lists so that approved changes will be . timely. l
. i c) Errors and deficiencies developed as a result of i these design changes which are found to adversely j affect safety related structures, systems and i components will be documented in accordance with
- l 17.4.15 and corrective action taken in accordance. I with 17.4.16. [
17.4.3.2 change Records f a) Design documents, field design reviews and dasign change records initiated at the site will be l collected, stored,-controlled and maintained in : accordance with written procedures. . l i 17.4.4 Procurement Document Control j The Project implements control over Site Contractor procure- ! [ ment documents through detailed QA procedures describing taese ! activities. Site Contractors who perform work on Quality Class . ; I items will submit for approval by "d.te 94 their Quality i Assurance program which will be consistant with the appropri- i ate provisions' of 10CFR50, AmaMw B. The survey and re- ! view by site QA of Site Contractors qualifications and - .! QA programs are governed by the Nuclear QA panum1 l t 17.4.4.1 Procurement Specifications ' WNP-1 Contract Documents provide those design require-- l ments, Quality Assurance provisionis,. Supplier bidding ! requirements, and general conditions for equipment I delivery anit contractual requirements, which are pack-
~
. aged to provide complete definition of the Contractor / ;
Owner /Engineest responsibility for the purchase of'ENP-1 [ items, materials and. services. The vendor and contrac- l tor procurement documents selectively apply applicable j Quality Assuranca require:ments on their sub-vendors to (
.s reflect basic contract QA requirements., i 17.4.4.2 Site Contractor Documentation i
a) The Nuclear QA Manual contains steps to assure that i ( .! l l
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I I ' 17.4.4.2 Site contractor Documentation (Continued) i the contractor purchased equipment procurement' l a)
- documents for Quality class I equipment indentify those criteria in 10CFR50, Appendix B that must j be complied with and described in the Site Con-l-
tractors QA Program. The details of the. Site Contractors QA Program are submitted with bids ! and reviewed in accordance with subsections j 17.1.4 and 17.2.4. b) The Quality Assurance subsection in the technical .l
- 1. portion of the construction Contract Specifica . l tions specifies to the Site Contractor, those processing and construction submittal requirements i and the administrative submittal requirements-relevant to the Contract QA requirements.
I 4 17.4.5 Instructions, Procejures and Drawings
-Provisions are made for, assuring that all quality related activities on structures, systems and components within
} ~ the Site Quality Assurance program are performed in accor-
- dance with w itten instructions, approved procedures and I issued drawingr. Each Site Contractor, in hia Quality.
Control program, will provide similar control in verify-- . !' ing installation of structures, systems and compcsonts I at the construction Site. 4 i j 17.4.5.1 Procedures i a) The Nuclear QA Manual is distributed and controlled a as defined in the manual. All field changes to the i manual will be issued through and reviewed by site QA personnel. In this way, control of the WNP-1 Nuclear.QA Manual remains within the Site Quslity Assurance Department. -{ b) Construction Procedures and Instruction initiated, 4 by each Site contractor at the site provide clearly __ written documents for performing quality related activites during the WNP-1 project construction-j
- effort.- These will be reviewed, corrected and up- _
dated to reflect changes in const. W on practice ! while maintaining compliance with the quality re-quirements. Instructions and procedures which pro-vide direction in accepting or rejecting quality
- related work are reviewed by site-Quality Assurance
, I personnel to assure that acceptance' criteria have
.been included and clearly' described.
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{ j c) site Quality Assurance will provide an audit and i surveillance function to verify that activities i are being performed in accordance with applicable instructions and procedures. I l 1 i 17.4.5.2 Drawings l ! l l a) Written instructions gove ning the review, approv-j al, release, distribution and revision of design l drawings at the site will be developed by Engineer-l ing. h se procedures will provide for the coordi-nation and approval of changes, thereby maintaining j control of the WNP-1 project design interfaces and l , equipment configuration. t j b) Erroro and deficiencies which sdversely effect safety j related structures, systems, and components discover- ! ed during the construction and installation process l will be documented and resolved prior to incorpora-tion of the change into the drawing. { , l 17.4.5.3 safety Related Documents 1
~ ~~
l a) Construction Experiences published by the Nuclear Regulatory Cosenission are mainemined and distri-buted in tha same manner as NRC Regulatory Guides per 17.2.5.4.a The, review and consideration of these occurrences during construction of nuclear plants, as they impact the WNP-1 project, is in' j accordance with written procedures as defined by { the UE&C Licensing and Environmental Section. .t i i 17.4.6 Document control l The surveillance and audit : esponsibility of contractor j site document control at the construction site resides- ! with Site Quality Assurance. Each Site Contractor will 1 maintain their own document control center for the re-f ceipt and distribution of documents pertinent to the 4 applicable contract. Site QA will audit each site Con- ! . tractor's Document Control System. j l 1% 17.4.6.1 Document Files I a) Site Contractors will distribute documents to the I work location for use at the work location undar a j carefully controlled system of logs, receipts, !. (-
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} 17.4.6.1. Document Files (Continued) i (l ~ l a) and audits by contractors Quality control. Site* Contractors' docusent control system will also include as a minimum provisions for maintenance, j approval, review, distribution, filing, updating,
! and monitoring of their applicable documentation.
4 e i b) Site documentation files will be composed essen- 4 ,
- j. tially of contractual QA documents pertaining to '
each site contract. Typical documents controlled i at the site will include Design specifications, i Manufacturing, Construction and Installation
! Drawings, QA Program Manual and Operating Proce-i dures, Test Procedures and Manufacturing Inspec-l tion and Testing Instructions. The document-i file w2.11 be updated and maintained, as required, ,
{ thereby providing conqplete contract historical QA t data. Site Quality Assurance will maintain the Master QA Records file as part of the site records l i responsibility in accordance with subsection 17.4.17. i l c) Document control of Contractor site files will be ] . verified by Orcject Quality Assurance audits to ! measure and evaluate Site Contractor, Construction-Management and Site QA cogliance with this criteria. i site Quality Assurance will audit and survey re-vised drawings and Engineering and Design change i reports against actual field work performed for i accuracy. f 17.4.7 Control of Purchased Material, F4uipment and Service _s_ t j Receiving inspeccion of materials 'and agaipment upon de-3 livery at the construwtion site is 'perfew=ad and con-l trolled by Site Ok for pre-purchased equipment and by the Site Contractor for contractor purchased equipment in~ { accordance with subsection 17.4.10. Both Site QA and the i site Contractors will assure that as a nimi= =, material- H
-and equipment will be inspected for identification, free-
~
)
dom from. shipping damage,.. availability'of purehamers re-L , lease'and availability of proper quality documentation.
~
l Any discrepancies, including the lack of proper documen-tation will be handled in accordance with the nonconfor-mance procedure as defined in subsection 17.4.15. Upon
- completion of receiving inspection,~~the material'will be j identified as specified in subsection 17.4.14.
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#' 17.4.7.I Surveillance Activities
\
l l I a) Audits and surveillance by the site Quality . ! Assurance organization will assure that the Site l Contractors are complying with the Quality Re- , quirements. This surveillance will verify that procurement requirements,for equipment and ser-I vices are followed and that the Contractors are in accord with Applicable Contract Specifications, Drawings, Manufacturers Instructions, Field Pro-cedures and Codes. b) Contractor procedures for control of their pur-chased material and equipment will be audited by Site QA and assessed for their adequacy in spec-ifying characteristics and processes to be wit-nessed, inspected and verified, and the respon-sibility for their implementation. y c) Site QA will perform audit and surveillance to assure that Site contractors are accepting and releasing items in accordcnce with r;Oroved pro- '~ cedures and that nonconforming items are' con-trolled in accordance with their approved p::o-I cedures. 17.4.8 Identification and Control of M'aterials, Parts and O m ents
- The Contract Specification provides for the identification and
.; control of material, parts, components and equipment for site contractor purchased material and for pre-purchased material. For site contractor purchased material, the contractor imple-ments his own approved procedures. For pre-purchased atterial site QA will provide and-implement the Nuclear QA Manual for-assuring only properly released equipment is used or. installed.- 17.4.8.1 Control Systen_ a) Site cc tractor identification and control proco-- dures will be provided and implemented by the site Contractor using his own tags cr Project supplied i ~ tags per' subsection 17.4.14. The site contractor '
. procedures will' include provisions to preclude the use of incorrect or' defective material, to verify' ^ identification of material prior to release for installation or construction and to assure that-the location and method of identification does not affact the function ~or' quality of the item being_
l identified. j .,- ;.-
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I ( 17.4.8.1 Con *.rol System (Continued) i \ i l b) The Project identification and control system
- employed at the site'for pre-purchased equip-l
- i ment is defined in the Nuclear QA Manual. This p system precludes the use of incorrect or defec-tive items which, based on the use of tags or
{ j tags and stamps, provides identity and trace-ability of the status of materials, parts, com- { l ponents and work opsrations throughout the con-
- j. struction activities.
c) Pre-purchased material received at the site from j a Vendor will be packaged, crated, bundled, sized i and marked in accordance with the applicable con-j tract specification and the approved shipping pro-cedures. Receiving inspection tags will be ap-l j plied as required (subsection 17.4.14). ) 17.4.0.2 Identification of Stored Items a) Stored materials on the site will be inspected i by site QA and site' contractors in accordance ?
- with their approved procedure (subsection 17.4.13).
- Nonconformances detected by the contractor or Site QA at this time will be reported and dis-1 f positioned in accordance with an approved proce-- ,
i dure (subsection 17.4.15) and tagged and isanti-l fled accordingly. If nonconformances are. detect- ] ed on material in storage, additional tagging and 4 identification procedures will be implemented
-to control t%e status. Tags, stamps and storage inspection reports will provide suitable identi-I fication control to preclude'their inadvertent use in construction.-
l 1 1 17.4.9 Control of Special Processes The Project'(UE&C) will not be required to perform any *
'l special processes during the construction of WNP-1 Pro- !
ject, but will impose applicable requirements on the l Site Contractors responsible for construction, instal-j , lation and testing of the! equipment. Procurement doc-unents for construction contracts require site con-tractors to control their special construction pro-
- l. cesses in accordance with appropriate codes and stan-dards. Site Contractors, when indicated in.the speci-l fication, are required to submit written procedures l
.for review and approval.
I 1 4 i I , d 4 , 9 e i . .. 4
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l ., PSAR / - 4 I h' 17.4.9.1 P-ocess Requirements j a) Special process requirements unique to the con . struction activity will be included in the con-1 tract specification with the requirement that when required by the specification, operating j process procedures be submitted for review and l l approval. Review and concurrence of Project ! Quality Assurance will also be required prior to l use. l
- . 17.4.9.2 Qualification i a) Process procedures prepared by Site Contractors requiring qualification, are qualified in accor-i dance with applicable codes and standards for
- erection and construction work performed by the
! Site Contractor Field personnel. Site Quality ' Assurance review and concur with these proce-dures prior to their issue and use at the con- . struction site. Site Quality Assurance is also i , responsible for certifying by audit and surveil-lance that the applicable procedure qualification
- has in fact, been performed as stated.
i b) Process personnel employed at the construction
- site will be qualified by applicable code re-quirements to perform the required process. At the construction site, each Site contractor con-
! trols the qualification awa= %ation, requalifi-cation e==4 nation and retest of their operators as required. Personnel certifications are issued , by the appropriate site contractor and copies are i. ! . maintained in the applicable permanmat record file at the site. .s c) Active files will be maintained by the Site Con-tractor of qualification records of their person-nel performing these special processes. , 17.4.9.3 Process Documentation and Records '1
- a) The control and retention of applicable site ,'
contractor qualzty control records pertaining a
' to special processes used at the construction site will be in accordance with subsection x -
17.4.17 and will include sufficient documentation-and records to ensure that the requirements of
-these special process procedures and specification. 3
.c requirements are current - and.are-being implemented.
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[- 17.4.9.3 Process Documentation and Records (Continued) b) Project Quality Assurance personnel review the , construction contract specifications to verify inclusion of any special process or process con-trol and with Engineering, review and approve all submitted site Contracter special process
- procedures prior to construction or installation.
Site Quality Assurance personnel provide the site surveillance effe!t to assure that Site Contrac-tors conform to Gaeir procedures. 17.4.10 Inspection I a) First level inspections at the site are perform-ed by Site contractors personnel charged with the Quality Centrol responsibility in accords.nce with , approved Site Contractor inspection procedures. 1 Site inspection activities affecting quality will be verified by Site Contractors through a system of inspections of materials, parts and components at the site to assure that Site Contractor pur-chased materials are received, handled,' stored,
-installed and tested in conformance with speci-4 fication and contract requirements. Site contrac-I
( ! tor Quality Control personnel are charged with the ] primary responsibility to determine the accept or _ , , reject status of the site Contractors work and to 1 implement their decision by pursuing a course of action in accordanc's with their approved site pro-cedures. j b) For pre-purchased materials, parts and components g ; received at the site, Site QA will perform those receiving inspections necessary to verify the
- quality.of this in - ing material. Site QA per-sonnel provide a secondary verification of the
~
acceptance status of the worke identifying and reporting of nonconformances-detected by surveil-lance end when required, pursuing a course of action as defined in subtsetion 17.4.16.5 (Stop l Work Authority). l l c) Contractor's procedures shall contain the identi-
, fication of those individuals or the organiza-tion responsible for performing each 4= W on operation with the qualification requirements for the inspection personnel,'and provisions for as-suring that each inspector's qualification is kept current. - Site QA approval of the'Contrac-tor Quality Assurance. organization and the con-h tinued audit and surveillance of their QA program
.will reemphasize the independence of their inspec- l tion organisation.
--16 -
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' 17.4.10.1 Receiving, Planning and Inspection i ,
b a) Pre-purchased Materials { 1
< l. Receiving inspection check plan sheets are , required for the performance of receiving l, inspection by Site QA personnel in addition l i to criteria of acceptance shown on approved l drawings, contract specifications and manu-i facturer's special instructions. These give-additional detailed instructions for the pre-lj purchased material to be inspected upon receipt j at the construction Site. They.are prepared l
by Site Quality Assurance personnel, in advance of the anticipated equipment delivery 1 to the site, if at all possible. i {: 2. Pre-purchased equipment to be installed will be inspected by Site QA personnel at the site
; in accordance with the Nuclear QA Manual. _
This Manual provides for detailed planning by l j site Quality Assurance personnel, visual in-4 spection for shipping damage and identifica-i tion, disposition and tagging of acceptable, j nonconforming, and rejected material and re-1 moval or isolation of rejectable and noncon-l - forming material from receiving areas. Site Quality Assurance personnel also pro-vide the necessary surveillance and audit ac- { tivity of the Receiving Inspection activities to assure that pre-purchased material is' con . j trolled during receiving inspection. i i l b) Contractor Purchased Materials
! 1. Each Contractor develops and implements (after e approval) his own procedure for receiving !
l inspection of Contractor purchased materials i with the procedure assuring that unacceptable ! j material is not inadvertently released for l installation or use. Contractors' procedures also provide for the identification and control
. of material by tagging in the various stages'
.l* of receiving process, to prevent uninspected I or unacceptable material from being used or
$nstalled.
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- 17.4.10.1 Receivint, Planeirr and Intraction (Continued)
( b) Contractor Purchased Materials (Continued)
- 2. The Contractor procedures also provide for
~ che use of his own tags or Project su'pplied tags (Section 17.4.14) throughout his
- receiving inspection process. - -
- 3. Site Quality Assurance will participate, l- through audit and survaillanc's of the .
i Contractor's r.eceid.ng inspection ~ activities; *'
' to the extent necessary to assure that the Contractor is conferzing with his approve,d -
. procedure'for receiving inspection and that
- . the Contractor received material in controlled ,.
as rgquired. , 17.4.10.2 Construccion Plannina and Inavection - , a) Each Site Contractor develops and implements *
~
(after approval) bis own procedure for storage.
- installation, testing, inspection, maintenance, '
- and handling of materials and equipment.
f -
- 5) Approved site contractor quality control -
(~ procedures are provided for the following contractor activities: first level inspections . performed to-assure coup 11ance with the applicable drawings and specification requirements; periodic
~
review of files to assure that contractor filme accurately reflect the work accomplished; monitoring equipment tests' and checks to assure i compliance to procedures; and reporting of non-
. conformances. -
c) Site Quality ' Assurance personnel will provide' those additional inspections requested by Construction Management to verify the quality of -
~ '
contractor construction. , d),. Master surveillance check plans are prepared by Site,QA for surveillance activities to assure the performance of Contractor inspections at
- the construction site. These check plans are * -
sufficiently detailed to determine that the Contractors are complying with their approved T QC inspection procedures and project requirements, t j a)' The follpwing typical surveillance points will D - be ibeluded during cons'truction:- . ]
~ *
, . -18f.,.
g . e .. .O '
, . WNP-1
*. PSAR .
f 17.4.10.2 Construction Planning and Inspection (Continued) (' 1. In-process revi u of Contractor's documentation and data records to assure that required process operations and inspections have been completed I before the work is rendered inaccessible by construction progress and to avoid delay in final release,to test and start-up.
- 2. Test Control (i.e., NDE, pressure, electrical, concrete, etc.).
~ -
3.- Calibration and type of test equipment used.
- 4. Verification of dimensional in w tions.
- 5. Verify drawing status (i.e., configuration, revision, etc.).
- 6. Verify that welding and NDE processes are in accordance with approved procedures and codes.
. 7. Verify personnel certification and qualifica-tion.
( 8. Paint.ing considerations (i.e. , coverage, runs, thickness, certification of compliance, etc.) .
- 9. Shelf life considerations (i.e., gaskets, lubrication, etc.).
- 10. Other inspection parameters as required.
i f) Each Site Contractor develops and implements (after approval) his own procedure for storage, installation, testing, inspection, maintenance and handling of site Contractor purchased mater-
.ials and equipment. Site Quality Assurance audit and surveillance activities assure that the site Contractor is conforming with his approved pro-cedures for this effort.
(
( . i WMP-1 I ,' PSAR
- .i l 17.4.10.3 . Final Acceptance Inspection l 'a) The inspection activity associated with verifying and establishing the acceptance of completed items l which have been, installed and erected on the, Con-t i struction site are in accordance with approved site l Contractor proaedures. These procedures provide for, an a mini ==, the following requirements
- ;
{ i
! Specific steps to be followed for verifying work-
{ manship, lack of damage and acceptability of ma-j terial and equipent. !- . Method and steps for supporting data review as-
- sociated with the installation effort.
j i Method of recording changes, reinspecting pre-i viously accepted material and establishing accept-3 ance status of modified material. j , Definiticn of that portion of work required to be l completed in a Construction operation before in-
- ac?essability would limit the acceptance inspec-l tion (Removal, replacement and modifications in-1 -
spection). I b) UE&C Field Quality Assurance personnel, through audit and surveillance of the Site contractors final accept- ,i ance inspection activities, assure that the Site Con-j tractor is conforming with his approved procedure for i final acceptance inspection and i.he removal and re-- -i placement effort and that the turr.over documentation - l , package for the equipment is complete and acceptable. 't* ! c) UE&C Field QA performs a Final verification which iden- [ tifies as a minimum the following: ! Listing of applicable documentation which shall be
- considered as substantiating the quality _of the item,-
f activity or installation. i .. Listing of those visual observations, including clean-i s liness, lack of damage, painting, etc., which shall be.
~l
- - considered as affecting the physical quality of the item-l or activity.
Statement that outstanding NCR's have been resolved and , hold tags have been cleared. l l ! 2o-i I L-_ 2 -. -. ,
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, . _ ,' WNP-1 PSAR i 17.4.11 Test Control :
The Nuclear QA Manual for the Construction Site estab- -{ lishes a system of control to assure that Site contrac-- ! tors' test activities are performed in accordance with ; predetermined contractor requirements, approved and i delineated in written test procedures and instructions. t < This system will also assure that these site test re-sults are acceptable and fylly documented. 17.4.11.1 Test Requirements-f a) Test requirements for site' contractors during { Construction and installation at the job site i are delineated in the contract spscifications ! in conformance with good engineering and Con- ; struction practices and code repairements. l Conformance to NRC regulatory guides are alup l considered when the required tests are speci- : fied in the Contract specification. [ s j b) Site contractors written test procedures for l review and audit by Site Quality Assurance, j describe the method of inspection'and test con-trol, and verification that tests have been performed in accordance with specified test pro-cedures and instructions, and that test results are within the specified limits. , I c) Storage tests provide a periodic check of stored ' i ! equipment which are conducted in accordance with _ l Site Contractor and Project Epproved written test i instructions. Measuring and. test equipment checks ! provide periodic calibration checks in accordance l
- with 17.4.12 as defined in the appropriate approv- ;
ed contractor procedures. Receiving tests provide , I
. continuous inspection test control based on Project approved test documentation for pre-purchased ma-i terial and contractor approved test documentation >
l for Contractor purchased materials. Tests perform-l -
. ed to verify installations are in accordance with l
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WNP-1 PSAR 3 ( 17.4.10.3 c) (CONTIWED) Other unique attributes of the item or system necessary for final acceptance,.such as code stamps, markings, identification, punch list, etc. i i 1 e 9 I'
-2oa-G n ,
I'* i~ .. WNP-1 PSAR , g. 17.4.11.1 Test Requirements (Continued)_ ! c) written procedures and verified by contractor personnel charged with the Quality Control rasponsibility for the installation. d) Records of all field tests and field check re- ! sults are fully documented and available for audit by Site Quality Assuranca. Assurance is maintained, by this Site QA audit and surveil-lance function, that adequate test instruman-tation and qualified personnel are used in the performance of these tests.
- 17.4.11.2 Pre-Operational and Start-up Test a) Plant pre-operational testing and start-up phases of construction are in accordance with Chapter 14 l of this PSAR. The system of QA Surveillance and Auditing implemented at the Construction site will be further developed, as contractual respon-
. sibiliti-as are defined, to assure that the pre-operational and start-up activities have been
. carried outi in accordance with specifications and procedures.
17.4.12 Control of Measuring and Test Equipment
- All. measuring and testing equipment which is used to determine the' acceptability of materials, equipment or installations at the site is under control of a site control and calibration program maintained ac- ' '
cording to written procedures contained in the UEsc Nuclear QA Mancal and Site Contractors' Quality As-surance programs. .Siter Quality Assurance perform auditing and surveillance of this program to ensure that it is functioning properly. i , 17.4.12.1 Procedure
~
i a) The UE&C Nuclear QA Eanual and Site Contractors' approved procedures establish a system for the con-trol, calibration and adjustment of. tools, gauges, [ instruments and other inspection, measuring, test-
'ing and maintenance devices used at the site. This - ; system is established such that conformance to estab-lished requirements is verified by site Quality As-surance at specific periods of time to~ assure the usage of proper. type, range and accuracy of the device.
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- - WNP-1 -
PSAR 17.4.12.1 Procedure (Continued) b) Prior to releasing *for use, measuring and test . equipment is identified by the Site Contractor (e.g., color codes, tags, labels, stamps, seri-alization) to indicate that it has been calibrat- , ed, when tho'next calibration is due and who per- i formed the calibration. c) Schedules are established by the Contractor and I records are maintained to assure that calibra-tion is performed periodically and has been fully documented. Site Quality Assurance per-sonnel audit and survey these schedules to ver-ify contractor conformance to these procedures. 17.4.12.2 Control Requirements a) Site' Contractor approved procedures require that-
. the following detailed control requirements shall
- be implemented at the site as part of the site j
measuring and test equipment calibration program.
- 1) Maintenance and control of the appropriate standards facilities with the associated records.
- 2) Establishing identification methods of de-vices under enlibration control. _
- 3) Method of correcting, adjusting, returning for repair and replacement of measurement i standards. -
, 4) Calibration control of~new devices and- establishing of calibration guidelines.
- 5) Qualification of personnel using these
" measuring devices".
- 6) Provision for frequency of surveillanca
-activity.
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( , [.. WP-=1 PSAR f 17.4.12.3 Standards of Control ;
) e, .
t g a). Primary and secondary standards,are, maintained,
- at a proper site, facility *b((hC,teQons,1b1C - ,,
Site Cont:: actor along with dertification', data'."-
- Calibration of site measuring devices are per- l formed in acccrdance with guidelinas is* National !
- Bureau of Standards-(NBS) maiiddis,fAS1M iisadali' '
f and equipaient manufacturers rAconsiddat' ions. j { Site. Contractor procedures provide for these {
~
~- ' b)O calibrat' ions to'; hare cartil'iillisiviicini'Esice-
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- . ;t-
' abfe to theENBB an'6is 6iTirfsiblind under !
applicable controlled conditions of: . l Temperature. ; Temperature ' rat:e of- changs" d ' ~ ~- 'T . ;
- - . . e
- Relative hunidity -
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l
%gg . . .. . i . f
. 'c) Site Contrhe'tb'r"carib'estibn .ft>aeaty'.chatts--
provide requirenants for frequency.af calibra-tion' and' a certifies.)&rcent: af:accurac able' to- the, NBS' for' primarf standards e.g., .(y itrace- ! M==anional, pressure, electrical, thermal, j i weight), secondar~y standards and. general *. test ! instruments. .. . ?- . .. ... ! t 17.4.12.4 Calibration and Control Records l a) Identification of calibration records for testing
- l and measuring equipment used by Site Contractors l during receiving,. storage, constructfon and' i installation inspections and tects are established _
l so that equipment can be readily recalled for. ! recalibration or adjusament. These site recores- !
- also serve as. an. indication of which devices were l
- . used'on specific tests and inspections, and also '
i provide for traceability if such devides are
- l found to' be out of calibration- and require
' j
~
corrective action.~ .
- b) The use of uncalibrated equipment constitutes a :
rejection of the site test or site inspection { with the disposition identified as part of the ! nonconformance report which is issued. {
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. .> - 17.4.13 Handlint. S'torate and Shitoinz -
! (. . Site " storage" of material and equipment and the prograa for - l .,
. ' imple:nencing control of "istorage" areas are in accordanca .with.
written procedures based on the contract specification require- ! j ments, suppliers recon: endation and accepted practices. Site. l
- QA provides the audit and..survainance activity to assure that- -
1 the Site Contractors dre implenenting approv.ed " storage" I procedures wich qualified personnel.
- In this section, " storage" (in quotes) pertains to storage.
- preservation, hasidling and chaning activities.
~
j 17;4.13.1 Procedura .
" Storage" 6f site materials and equipment' win *
- l . . a) , . ,
ba ~under the responsibility of Contrace, ors, - ,' whether equipment is pre-purchased or purchased'
. by installing Site Contractors, wigh che .
. contract specification providing the require- '
l ments for these activities. , ,
- .~ -
b) Contractors responsible for .the ad=4n4=tration
~
of the pre-purchased equipment "storaga" l , ,
' ~ -~
s program $mplementf written, approved proc.edures ~-
- which provide for " storage" inspection 7'~ "-~ ~ '
l.
" storage" maintenance, " storage" h== m =g, 1
" storage" surveinance and generating all
~
" storage"-records. Site Quali;y Assurance ~
. personnel provide the audit and sury. m .ne. (
j ,- - - activity to assura inplementation*of these ~
,_ procedures. s 1
c). Site Contractors responsibla for " storage" of , j ,, Contractor purchased equipment develop writtaa ,,,
. r procedures which are'submitt6d for review and 9 o
'. . Japproval. Site Quality Assurance personnel -
- d. .
- provide the audit and survainance , activity to 's,[
assure Contractor implementation of his '
.- -;;.'proceduras. -
- I 17.4.13.2 Storaes Cateitories and Requirements a) The Site Quality Assurance Program;provides s .
i .
- for establishing and maintaining various categories of storage on the ' site. Each Vendor and Con' t ractor procedure for the delivery,-
receiving inspection and site' ' storage of equip-. ment provi. des the requirements from which the. type of storage is selected and applied.
, ,,23_
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- PSAR i
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[ 17.4.13.3 Periedic Inspection and Surveillance _; a) Audit and surveillance of " storage" activities on the site is provided by Site Quality Assur- j c.nce to assure that Site Storage Contractors ! are implementing approved procedures. b) Storage inspection procedures provide for ini-tial and periodic inspection of stored equip- ; ment to assure that the integrity of the equip- ! ment has not been compromised when received and l
- during storage, and that specified maintenance j requirements have been performed. Schedules of l inspections are established by the contractor for materials in storage with unsatisfactory conditions being brought to the attention of ;
responsible parties, in accordance with Contrac- ! tual p ocedures, for corrective action. Adequate i record's of storage inspection are mainte.ined by . l the appropriate Contractor to show satisfactory I condition or report of unsatisfactory condition. l 17.4.13.4 Records and Handling f l a) " Storage" procedures provide for each " Storage" l Contractor to administer his " storage" program j by means of a system of records, logs, and re- l porting. Contract- al documents provide how I such " storage" records pertaining to quality l are to be controlled, evamined, reviewed and' .: file.l. l 17.4.14 inspection, Tese and Caratir,s Status i The Nuclear QA Manual provides w sures for indica- l ting the str.tus of tests and inspecHr== performed. ! upon materials, parts and components when received, ! tested, inspected, stored and installed at the con- l struction site. The status of the item is estab- l lished by a Project system of tagging which,-when j applied and recorded, prevents their inadvertent .' operation and precludes the inadvertent bypassing i [ . of their inspection and test requirements. , l l 17.4.14.1 Item Status
. Inspection and test status are defined in the ,
j . general categories described below ; I Le . w l- . L. - - i.-. -
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i a *, .. .. -
%NP-l' -
l ~- . -
] PSAR , ,
[ 17 . .*. . *. '. 1 tea = Status (C6atinen; ' ( a) ACCEPT status is assigned to materials, parts - and components voich are inspected and found '
- satis. factory for construction use, and in confor-r.ance with applicable contract specifications.
I This status is recorded and thd materials, parts t and components are released to warehouse facili-ties, storage areas or fabrication and erection areas. : b) REJECT stacus is. ass'igned to materials, parts ' and componen'es which are inspected. and found
~
unsatisfactory for construction use, and not in accordance with applicable contract specifica-tions. This status is recorded and rejected ite=s are segregated to a controlled reject area until such time that a disposition'is'
. made. If segregation of rejected waterials is not practical, the items are physically tagged .
. to clearly show status. Nonconforming material
- identified with a "RFJECT" tag is subjected to the nonconforming material control procedure ~as -
described in 17.4.15. ,- [ c) EOLD status is assigned to materials, parts and
\- .
., components ,that have been identified as non-conforming and are avaiting disposition of an
~
- 3. attribute.which differs from specification
.]," requirements. The hold status is identified on a written record and the ites-is appropriately tagged. Such items are segregated from accepted
. iteas until a disposition of the hold status is. .
made. For natorials, parts and components which
~
are released for limited work, avaiting dispo- t 4 sition of a nonconformance, a " Conditional Release" is assigned. d) CONDITIONAL RELEASE status is assigned to
,' _' naterials, parts and components that have not.
p
. . r.i been fully accepted for use, but which are con- '
'- dicionally released to relocate, store in place l
" ' or install to a point where the item can'ba
- - removed or corrected without damage or contami- * ,
nation to the associated permanent plaut equipment . l
. or structures. This status-is recorded and con-trolled in accordance with written 1.rocedures. -
l e) N.?AITING INSPECTION status is assigned to materials, parts and components.that have been received at the site and are awaiting:
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- WNP-1 l PSAR
[.. s 17.4.14.1 Item Status (Continued) i e) 1. Inspection '
- 2. Identification f 3. Documentation -
l 1 17.4.14.2 Records and Stamps
- a) Gubsequent.to material and equipment installt,-
i tion, the inspection, test or operating status
- is indicated by attached tags or by traceable records such as inspection check plans, inspec-tion reports, or routing forms. Sole authority l
for the attachment and removal of these tags l rests with the applicable quality control or- ] ganization. , t ! b). Lots of materials which can be identified by j heat number, lot number, etc., may be identi- l +
.fied with a single tag, providing the tag is l . marked to completely identify the lot. When j physical size or material composition precludes
- f tag attachment (e.g. , comer.t, aggregate, sand, I
I i (' etc.), the inspection status is identified on traceable records. j c) After construction and installation testing is. J completed and accepted, WPPSS procedures pro- ) vide for the attachment of test accepted tags to the system or structure. This evcedure provides for the continuation of equipment 4 status identification through the pre-opera-l tional test period and final system testing by' ! WPPSS. t c) Appropriate inspection stamps (e.g., welding, NDE, radiography, inspection, etc.', when i utilized by the site contractors and site Quality Assurance personnel, are applied to documents (e.g. , dispatch orders, etc.), .to provide notice to the site cont actor instal-j lation functioz. that equipment and parts have i been inspected.- Issuance, application and re- } moval of these stamps is under strict control' of Sito Contractor and Site Quality Assurance to prevent use_by anyone other than the person to whom it was issued. i I - J. s .
- 9 f
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- WNP-1 I
PSAR l (n , Nonconforming Materials: Parts and Components 17.4.15 l The hoclear QA Manual provides for the identification, I documentation, segregation, review, disposition and i notification to affected organizations of nonconforming j materials, parts and components at any stage of manu- ' facturing, fabrication, erection or construction to prevent their inadvertent use or installation. Written > procedures provide for the handling, processing, and dispositioning of nonconforming materials, parts or components. 17 4.15.1 Nonconformances A noncc.nformance is a deficiency in characteristic, documentation or procedure which renders the quality of an item unacceptable or indeterminate. Examples ' of nonconformance include physical defects, test failure, inaccurate or inadequate documentation or deviating from prescribed processing, inspection or test procedures. 17.4.15.2 Procedure (' a) Nonconforming materials, parts, components or-' ! j ( activities at the site are documented by the Site Contractors and Site QA by use of the Project Nonconformance Report form. b) Nonconforming items are identified and marked with a " hold" tag (when possible), removed to a site " hold" area, roped off, or otherwise ' segregated to prevent their inadvertent use. The dispositioned NCR is returned to the or-ganization responsible for' carrying out the corrective action. 17.4.15.3 Controlling NCR Forms (Site) a) NCR forms for site activity provide for similar requirements, explanations, justifications,. concurrences, dispositions, corrective actions,
. reinspections and approvals. Distribution,of ~. preliminary and completed NCR forms is stcndard and they are maintained in accordance with an establishe.?. procedure.
b) Control of nonconformances by Site contractors l is evaluated by' Site Quality Assurance' audits- ; during performance of the work. l 4
~29-
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l . . . i -. *? ', - WNP-1 i' _ PSAR
/
- 17.4.15.4 Maintenance of NCR Records
! a) A log is maintained by the Site Qcality j Assurance for NCF's initiated at the site. 4 l b) A log is maintained by the site contractor j for contractor initiated NCR's listing as a j minimum, the date, number, item and noncon-formance description and disposition. 3 i c) All site NCR's remain "open" until disposition ' [ has been resolved, implemented and reinspected and the NCR completed (cleared). e l , 17.4.15.5 Nonconformance Review Board a) All site nonconformances are submitted to Site Quality Assurance. Each NCR is evaluated for-l adequate disposition or the necessity for Non-l conformance Review Board (NRB) approval. The j NRB approves diarasitions when required as ! determined by referenes to specific criteria { and in accordance with applicable project pro-l . cedures. ! ~ b) The Nonconformance Review Board meets as ( required at the construction site to review j- and approve the disposition of applicable site nonconformances. The NRB has the following representations i
- 1. UE&C Engineering ,
j 2. WPPSS Engineering i
! 3. UESC Quality Assurance 1
- 4. WPPSS Quality Assurance
- 5. WPPSS Construction 17.4.15.5 Disposition 4
Disposition of all nonconformances at the site are approved by Project Engineering and are noted on the respective NCR forms with the dispositioning action in accordance with the Nuclear Qh Manual. 17.4.15.7 Reinspection r
. After the responsible' organization has performed the required actions to clear the nonconformance,.
the originating organization's QA inspects the ites,
~
2
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i . 4 .
- WNP-1
.. PSAR [ x 17.4.15.7 Reinspection (Continued) j determines its acceptability and signs off the nonconformance as approved. l 17.4.15.8 Reporting ' ( Copies of all nonconfermance reports are submitted to site Quality Assurance when originated, when - - j dispositioned and again when cleared. l 17.4.16 Corrective Action i { The Nuclear QA Manual provides for procedures for ! identifying, documenting, reporting to management and ; l dispositioning those site. conditions adverse to quality. i The program also provides a method for assuring that ! site conditions adverse to quality are determined and corrected'tc, preclude repetition. - i j 17.4.16.1 Cortactive Action Requests t j . a) The Nuclear QA Enual requires that the Site l contractor, initiate Corrective Action Requests in accordance with an approved procedure when the i ' contractor is found to be operating in such a way that his coennitted QA/QC program cannot be 7 -implemented as required. The contractor is also i require + % respond in a timely manner to correc-
- tive .u%s requests written by site Quality As-suranen i
! b) Tk pA Program requires that a corrective action . regnest be initiated by site Quality Assurance ' can site construction practices indicate that t i repeated violations of the same nature are occuring. 17.4.16.2 Implementing Corrective Action i a) Fcr project corrective action-implementation, l + the designated responsible party describes the corrective action that he intends to ir.plement and specifies the date by which it will be in-plemented. If corrective action specified is
.not adequate or does not meet the intent of the request, site Quality Assurance resolves the
' difference in accordance with an approved procedure..
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i ..'A , j '. WNP-1 - , PSAR
. (/
j 17.4.16.2 Implementing Corrective Action (Continued) s l b) For Site Contracto'r corrective action initiat-j ed by Site Quality Assurance, the designated . responsible site contractor describes the { corrective action that he intends tio implement and specifies the date by which it will be in-4 plemented. Site Quality Assurance maintains i a site audit and surveillance activity to 1 ascertain the adequacy and intent with the j approved contractor procedure. 17.4.16.3 verification and Analysis -- a) When actual corrective action has been satis-l factorily implemented, the Field Superintendent Quality Assurance verifies the implementation i of the corrective action on the Corrective Actio'n Request, dates and signs the request . form to indicate Quality Assurance approval of acceptable action. Standard distribution ! of the information to affected activities is j - then implemented.
,/ ~ b) Site contractor and Project corrective action
(" forms are filed and logged and the effective-ness of the corrective actions are reviewed by Site Quality Assurance. Such actions may in'- clude stopping the site contractor 4= W ion or construction effort for poor quality perfor-mance or stopping the Project construction man-agement effort for disregard of approved QA or . Project procedures. j c) Feedback information on nosconformances is j obtained from site contractors and Project Construction Management by Site Quality As-surance. The data are analyzed and evalu-ated by Project Engineering and QA personnel, after which corrective action is re h ad to assist in controlling and preventing recurrences i of site nonconformances.
~ . d) Significant differences in design and const$ruc-tion will be documented and reported promptly.
Ynese activities are governed by written pro-cedures. e) Effectiveness of corrective action is checked by site QA audits in accordance with 17.4.18. a
, , - -e,.. 9- .
intP-1
- PSAR
# 17.4.16.4 Failure to Respond
\
a) Failure to respond either by the Site Contrac-i tors or Project Construction Management to . Corrective Actior Requests within a reasonable [ time will reault in notification of the site Contractor or contractor Management with a , requirement for ismediate response. Lack of response will rer. alt in stoppage of work in the affected area in accordance with the Nuclear ' QA Manual. 17.4.16.5 Stop work Authority a) Stop work authority for site activity rests with the Project Manager based on direction received via a "Stop Work Order" from the i Field Superintendent Quality Assurance. b) Work may be restarted with the approval of the j Field Superintendent Quality Assurance only after - l action has been taken to eliminate the noncon- ' I formance and the responsible party has satis- . factorily replied to the "Stop Work Order". ; 17.4.17 Quality Assurance Records , ! i i Site Quality Assurance is responsible for the main-tenance and control of the WNP-1 Site Quality Assurance Master Files. During construction of the ASME Section l III, Div. 2 Containments. Applicable records will be 'l
- naintained throughcut the receiving, storage, construction, i installation and testing phases of the project and will be ,
collected at the site to form a permanent file of den. w .- ; tation-furnished by the Project. The Nuclear QA Manual i describes the method for the accmmlatica, organization, i custody and retention'of QA and QC records for materials, ; equipment and activities at the construction site. ! 17.4.17.1 Site Record Requirements l
- a) Quality rt wrds requirements for site contrac-tors are defined in the applic2ble Construction contract specification, codss and s+mndmeds and in the Nuclear Quality Assurance Manual whi'ch govern quality associated site activities.
These records include, but are not' limited to, results ol' receiving a'nd storage inspections, . Site QA surveillance and audits, construction and installation tests, material analysis, moni-
' (-
\ toring of work performance, NCR's,' maintenance.
' reports, corrective action requests, qualifica :
tion of personnel, procedures and equipment and.
. other documentation.
l . I
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, WNP-1 PSAR f 17.4.17.1 Site Record Requirements (Continued) ( N b) Records are identified with the system, struc-ture or components to whi:h they pertain and are filed (17.4.17.3) to provide accurate re-trieval without undue delay. Records will be _. maintained in accordancw with ANSI M45.2.9, ;
" Requirements for Collection, Storage and Main- )
tenance'of Quality Assurance Records for Nuclear Power Plants". Contract specifications direct the Site Contractor.to provide a positive method of traceability from documentation to installation , of the part. j 17.4.17.2 Site Records Review l
, 1 a) Site Quality Assurance implements an audit and surveills.nce. effort of Contractor inspection 1 groups in order to be assured that each site !
contractor is following approved methods of , I verifying acceptability of their data. Sur- . veillance of reports and inspection data ap- , plicable to (1) vendor generated documenta-tion for pre-purchased equipments (2) contractor generated documentation for contractor purchased equipment ands (3) site centractor generated documentation, is implemented to assure proper approvals and acceptances. b) The review of records (data) at site receiving areas for pre-purchased equipment'is initiated performed, approved and filed by Site Quality , Assurance in accordance with the Nuclear QA Manual. This data review confirms that the - data, as received, is consistent with the con-tract documents. ' c) The review of records (data) at site receiving areas for site contractor purchased equipment, is initiated, performed and recorded by con-tractor personnel in accordance with an approved ' procedure. This records review is to check the documentation received for availability and [ technical adequacy against required documentation as defined in the Contractor Procurement documents. d) The review,of records at turnover for' pre-pur-chased and contractor purchased equipment _at the construction site is initiated,-performed and O e A
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WNP-1 [ PSAR i 17.4.17.2 Site Records Review (Continued) d) recorded by Site Quality _ Assurance. This records review is to check the available documentation ) used for the equipment installation against the i l required documentation and to verify the complete-l ness and acceptability of turnover documentation j package for the equipment. l l 17.4.17.3 Site Records File I ! a) The Master QA file'contains records pertinent to Quality control and Quality Assurance and will be located within the offices of the Site Quality . Assurance. Access to these master files will I - be controlled by the Project Quality Assurance i Manager. Authorized representatives of site
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QA, inspection agencies and audit personnel will be permitted access to the Master files under the direct supervision of the Field Superintendent Quality Assurance. b) The Master Quality Assurance File will consist of: Purchase Documents which contain data 1. packages received with the components
- and associated documentation whether purchased by the Project or a contractor.
- 2. General Documents such as surveillance reports, nonconformance reports and cor-rective action requests. i
- 3. Ccaponent Docmments which consists of~a copy of all Receiving Records Review.
. 1. Systems Documents which censists of a copy ;
of .all Data Review Receiving and Data Re- l view Installation Records. l
- 5. Site contractor Documents. The original ,
site contractor files will be maintained by the contractor until turned over to
'- Site QA during tha course of construction.
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WMP-1 PSAR ( 17.4.17.3 Site Records File (Continued) l c) 'Ib provide protection apinst loss or destruc-l tion, records will be maintained in accordance l with' ANSI N45.2.9. Documents shall be indexed ! and microfilmed in accordance with appropriate
,rocedures. )
l d) QA records filed as part of the Site Master ! } i Quality Assurance Files shall be indexed, cross- 1 referenced, filed and controlled in accordance 1 with the Nuclear Qh Manual. - 17.4.17.4 site Records Storage I - a) The Master Quality Assurance files will be lo-cated in a suitably protected environment at the construction site for storage of qua2.ity , related records generated during the procure- I ment and construction phases of the project, , and will serve the function'of providing readily accessible documentary evidence of ' compliance with the quality :;equirements of - equipment and installation specifications and applicable codes and standards. ( - b) QA records storage facilities at the site will, be constructed and located as to protect con-tents from possible destruct. ion by causes of fire, flood ag, larceny, vandalism, rodeuts. and from possible deterioration by a ocabina-tion of extreme variations in temperature and humidity conditions. ' c) Access to Quality Assurance Record storage facilities will be restricted to desigr.ated individuals within the Site Quality Assurance-organization responsible for safekeeping of the documents. 17.4.17.5 Site Records Retention
-e I a) All records will be retained during the site-construction effort, at the end of which,
!- retention periods (i.e., life time, nonper- j
-manent time period) for the records will be assigned.
b) Site contractors will maintain their on-site QA files, and original records shall not be { removed from the site.without prior approval-
-of Site Quality Assurance. i l
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( PSAR t J c) All records are the prope'rty of the owner and
- shall not be destroyed or otherwise disposed
> of without the written consent of the owner.
All records shall be turned over to the Owner or his agent after completion of construction. G 4
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I PSAR ^ 17.4.18 Audits i The Site QA Audit Prog *am provides for regularly i scheduled and unscheduled audits of each site con-tractor's Quality Assurance program which will serify their compliance with their approved QA and QC proce-dures. These audit records of the contractors con-struction and installation practices offer objective evidence of implementation of and compliance with re-quirements, and consistency in the discharge of their _ site responsibilities. 17.4.18.1 Types and Categories 4 Audits will be performed on Site Contractors, to 1 verify that u tivition and items are in conformance with specified requirements and to ascertain that the procedures and other documents governing their res-pective site activities and construction items con-tain sufficient requirements to assure that the quality specified is achieved. -These audits will be performed by Site Quality Assurance Personnel who, by the nature i of their positions, are independent from the Manufac-turing and Cons.truction disciplines and who have no , responsibility for ,the site activities being audited. , a) Site Contractor Audits. . The audit program of site contractors activities is implemented by the Field Superintendent Quali-
- ty Assur2nce. The FSQA defines the scoce, so-
' lects auditors, schedules audits and follows up '
on corrective actiens. The auditor (team chair-man) prepares a written checklist delineating the characteristics to be audited. The audit of the-activity is then conducted in'accorcance with this checklist and upon completion of the audit, the result. are presented, discussed and su mar-ized in a written report. 1".4.18.2 Audit Planning
. a) The general schedule for the activities for,which x audits are required is established defining the-frequency of a'udits for each activity; dates of audits, if feasible; including verification audits,
. auditor (s) and tentative dates of subsequent audits.
The frequency of audits in any particular site acti-vity is predicated bys' t 9
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l 17.4.18.2 Audit Planning (Continued) a) 1. The level of activity in the particular 1 area, as dictated by the stages c." con-struction.
- 2. Results of previous audits of that par-ticular site contractor activity.
- 3. Adverse indications through an analysis of nonconformance reports or complaints.
Unless otherwise determined by the above con ~ ditions, each area will be audited on an annual
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- b) The audit categories enecapassing quality re-lated activities will be based on the applicable criteria of 10CFR50, A &Mv B, and ASME Section
. III, Div. 2 by Site Quality Assurance. Audits of
- these site activities include an evaluation of procedures in use in the area being checked, the i effectiveness of their implementation and a sam- -
pling of the area output and associated documents and records. 17.4.18.3 Audit Team *
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a) The r(glirements for audit team selection and par-ticipation for site Contractor audits, audit pre-paration, planning and reporting, and suitable I training and the maintenance of proficiency records for auditors of construction activity are in accor- ' dance with the Nuclear QA Manual. 17.4.18.4 Audit Procedure - a) PreparatiN for the site contractor audit by the Audit Team Leader entails coordination with the appropriate Site contractor QA personnel for scheduling arrangements. a b) Site audits are performed in accordance with'the-Nuclear QA Manual. - c) A complete record file is kept of-audits per-formed, which provide Project Management with the means to' analyze and ' evaluate tho' contractor in ~ plementation of the' Quality Assurance program. i a
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s-lf)i s' - l NNP-1 PSAR l 17.4.18.5 Site Audit Analysis ,i . a) A monthly site audit status report of site Oh findings will be published by the FSQ4 with dis-tribution to the appropriats Project Management personnel. The report will identify findings of site audits conducted during the reporting period and record the status of items stil,1 pend-ing free previous site audits. h) FSQA uses these repor u .e.s the basis for' deter-4 mining quality trends developing in the various areas of the site Quality Assurance Program for the project. c) FSQA pursues resolution of those areas of concern which indicate a decrease in the effectiveness of the Site Oh program for the project. j d) Unsatisfactory trends will be resolved by'the i FSQA in accordance with Section 17.4.16. . 4 t F s e 9 9 , t i 6 e 1 .
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