ML20054J287

Forwards Portions of QA Program,Kv Seyfrit & Wp Haass 810612 & s & BQ-TOP-1,Revision 3A

ML20054J287
Person / Time
Site:	Diablo Canyon
Issue date:	06/18/1982
From:	Crane P PACIFIC GAS & ELECTRIC CO.
To:	Miraglia F Office of Nuclear Reactor Regulation
References
NUDOCS 8206280428
Download: ML20054J287 (18)

Text

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PACIFIC GAS AND E LE C T RI C C O M PANY

, 77 BE ALE STREET, S AN F R AN CISCO, C ALIFOR NI A 94 $06) [T E L}{ M O Pt E; g 15 ) 781 4211

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• P.O. BOX 7 4 4 2, S A N FR ANCISC O, C AllrOR NI A 94120 TELECOPIER (415) 543 7813

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June 18, 1982 Mr. Frank J. Miraglia, Jr., Chief l Licensing Branch No. 3 Division of Licensing U. S. Nuclear Regulatory Commission Washington, DC 20555 Re: Docket No. 50-275, OL-DPR-76 Docket No. 50-323 l Diablo Canyon Units No. 1 and 2 Diablo Canyon Project Quality Assurance Program t -

Dear Mr. Miraglia:

As we previously advised you, recently PGandE retained the J

Bechtel Power Corporation to assist PGandE in bringing Diablo Canyon Units No. 1 and 2 to commercial operation. PGandE and l

l Bechtel have formed an integrated project Organization to obtain that goal. To assure that quality assurance and quality control aspects of the project are applied consistently, a project Quality Assurance Program has been prepared.

Project work to obtain commercial operation of Diablo Canyon Units No. 1 and 2 will be performed in accordance with the enclosed Project Quality Assurance Program. The Program is composed of two parts; (1) the Bechtel Power Corporation Topical Report on Quality Assurance, BQ-TOP-1, Revision 3A and (2) a discussion of the modifications to the topical report to conform to the PGandE/Bechtel project organization.

The Bechtel topical r,eport has been reviewed and approved by the NRC as noted in the cover letter attached to the' report.

8206280428 820618 PDR ADOCK 05000275

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J PACIFIC GAS AND E LE C T RIC C O M PANY

, 77 BEALE STREET, S AN FR ANCISCO, CALIFORNI A 94106 TELEPHONE (415) 781 4211 P.O. BOX 744 2, S AN FR ANCISCO, C ALIFORNIA 94120 TELECOPIER (415) 543 7813 Mr. Frank J. Miraglia, Jr. June 18, 1982 Page 2 Kindly acknowledge receipt of the enclosed material on the enclosed copy of this letter and return it to me in the enclosed addressed envelope.

Very truly yours, Philip A. Crane, Jr.

Enclosure (40 copies)

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QUALITY ASSURANCE PROGRAM 82 J.E 24 R0:10 BECHTEL POWER CORPORATION . /////

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Quality Assurance Topical Report The Bechtel Quality Assurance Program Plan for use by the Bechtel Power Corporation during Project Completion Management of the Pacific Gas and Electric Diablo Canyon Project is described in the NRC-approved Bechtel Topical Report BQ-TOP-1, Rev. 3A, Bechtel Quality Assurance Program for Nuclear Power Plants.

Scope of Responsibility This section describes Bechtel responsibilities for providing quality-related services in Project Completion Management to Pacific Gas and Electric Co. on the Diablo Canyon Project. Bechtel Project Completion responsibilities may consist of design engineering, procurement services, construction completion, and preoperational testing.

Design engineering services include:

o Management of design completion o Preparation of design document and design changes o Preparation of licensing submittals o coordination of design verification activities performed by non-Bechtel entities at the request of PG&E.

Procurement services include preparation of procurement documents and changes for use in subsequent procurement actions by PG&E. In this case, supplier evaluation, control and auditing of suppliers remains a PG&E respon-sibility. Bechtel may undertake purchasing through the Bechtel organization if so requested by PG&E, in accord-ance with requirements of this Program.

Construction completion management will be performed by Bechtel'. Construction completion services may include direct construction activities performed by Bechtel and/

or construction management of contractors.

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PG&E and Rochtel provide porconnel to fora en intsg-rated project team, working under the direction of Bechtel's Project Completion Manager, to provide the above services. PG&E procedures may,be used, amended as necessary to comply with this Quality Assurance

' Program description. *

• r Project Unique Modifications to BQ-TOP-1, Rev. 3A ,

o Introduction Page 3 - Replace Regulatory Guide 1.58 (August 1973) with Regulatory Guide 1.58, Rev. 1 (September 1980).

o Introduction Page 3 - Add Regulatory Guide 1.146

" Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants (Rev. O, 1978)".

o Introduction Page 3 - Replace ANSI Standard N45.2.12 - 1974 with:

Regulatory Guide 1.144 " Auditing of Quality Assurance Programs for Nuclear Power Plants (Revision 1, September 1980).

o Introduction Page 5 - Add to the list of terms and definitions as follows:

21. Project Guidance: Providing advice or counsel on matters concerned with project functions or activities. This may include establishing general requirements or policies, but not specific procedures or instructions.

o Section 1 ORGANIZATION Subsection 1.5.4 Page 11 -

Replace the first paragraph of Subsection 1.5.'4 with Attachment 1.

. o Section 1 ORGANIZATION Subsection 1.6 Page 13 -

Add as first paragraph to subsection 1.6 the Attach-ment 2. ,

o Section 1 ORGANIZATION Subsection 1.6.2 Page 15 -

l Revise item (2) and add item (9) per Attachment 3.

o Section 1 ORGANIZATION Subsection 1.6.3 Page 16 -

Replace the third paragraph of Subsection 1.6.3 with

• Attachment 4.

o Section 1 ORGANIZATION Subsection 1.6.3 Page 17 -

Add as last paragraph to Subsection 1.6.3 the Attach-i ment 5. - .

o Section 1 ORGANIZATION Subsection 1.6.4 Fage 17 -

Replace Subsection 1.6.4 with Attachment 6.

o Section 2 QUALITY ASSURANCE PROGRAM (Subparagraphs 2 and 4), Page 23 - Change Regulatory Guide 1.58 (August 1973) to Regulatory Guide 1.58 Rev. 1 (September 1980).

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^I o Section 2 QUALITY ASSURANCE PROGRAM (Subparagraph 3)

Page 23 - Change ANSI N45.2.12 to ANSI N45.2.23.

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o Section 2 QUALITY ASSURANCE PROGRAM Subsection 2.9 Page 26 - Replace Subsection 2.9 with Attachment 7.

o Section 11 TEST CONTROL - Page 47 -

Replace the third paragraph of Section 11 with f

Attachment 8. *

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o Section 17 QUALITY ASSURANCE RECORDS - PAGE 54 -

Add to the second paragraph as follows:

,] The PG&E " Records Management System" may be used for retention of records in accordance with these criteria.

o Change " Project Procurement Manager" to " Project Materials Coordinator" throughout.

o Change " Field Construction Manager" to

" Construction Superintendent" throughout.

Table 1 "Bechtel Quality Program Do,cuments" Page 57 and 58 Add to Table 1 the Project Documents shown on Attachment 9.

Replace Diablo Canyon Project Team Organization Attachment 10.

Fig. 9 with Fig. 15 Replace Diablo Canyon Project Engineering Organization Fig. 10 Attachment 11.

with Fig. 16 Replace Diablo Canyon Project Construction Organization Fig. 11 Attachment 12. ,

with Fig. 17 Appendix Bechtel Position on QA NRC Regulatory Guides and A ANSI standards:

o Delete 5th paragraph (A-7) on page A-1; delete pages A-7 through A-13 entirely.

o Replace ANSI N45.2.12-1974, Draft 3, Rev. 4, Feb-ruary 22, 1974 with Regulatory Guide 1.144, Rev. 1 September 1980; replace pages A-22 and A-23 with Attachment 13.

ATTACHMENT 1 1.5.4 Division Construction ,

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sanagers of Division Construction provide technical' ano administrative direction to the Construction Department personnel. Managers of Division Construc-tion are assisted by the Chief Construction Quality Control Engineer.

The PG&E Manager Station Construction provides technical direction for construction activities of the integrated project team.

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o ATTACHMENT 2 *

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~ 1, 6 The Project Completion Manager (Fig. 15) is the senior project representative assigned to the Diablo Canyon Project (Units 1 & 2). The Project Completion Manager reports to the Manager, Division Project Operations and-receives project direction from the PG&E Senior Vice President for Facility Development. He receives technical and administrative direction from the Bechtel Division Project Operations Manager. The Project Com-pletion Manager is responsible for providing overall project direction to assure consistent and coordinated application of Bechtel policies and skills for the benefit of the project. The Project Completion Manager's Management Team includes other managers to coordinate activities in engineering, licensing, and the quality program, and to provide guidance to other project managerial personnel.

An Assistant Project Completion Manager at the project site reports to the Project Completion Manager and acts as his representative relative to construction activities at the site.

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O ATTACHMENT 3

2) Assure that drawings, specifications, procedures, and instruc-tions produced conform to project requirements, ownyr or

,, Bechtel standards, applicable industry standards, regulatory -[ .

agency requirements, and the design bases as defined in .

Safety' Analysis Reports.

9) Handle and process open items generated by the Independent Design Verification Program (IDVP), including interface with IDVP consultants.

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ATTACHMENT 4 The project construction organization includes Superin-tendents who are in' direct charge of the crafts (on a project for which Bechtel is assigned direct pon- '[

struction responsibility); Field Engineers who perform field engineering, provide technical guidance and monitoring of construction work; field procurement w- personnel under the Senior Field Procurement Repre-sentative who are responsible for purchase of field-procured items and control of materials prior to release for construction; Startup personnel under the Resident Startup Engineer who are responsible for preoperational and startup testing; and Construction Quality Control Engineers (assigned by and administra-tively and technically responsible to the Chief Construction Quality Control Engineer) who are respon-sible for the Bechtel field quality control program, including performance of all quality verification inspection performed by Bechtel. Construction Quality Control activities are coordinated by the Project Superintendent.

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ATTACHMENT 5 f ~

,The -Resident Startup Engineer is responsible for ,

the development of a preoperational and startup testing program, the preparation of specific preoperational and startup test procedures, and the scheduling and direction of their implementation.

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.- O ATTACHMENT E i

1.6.4 , Project Procurement"

- The PG&E Manager Materials is responsible for PG&E f Procurement activities performed for the Diablo Canyon Project.

The Manager, Division Procurement, is responsible for Procurement activities performed by Bechtel for the

- Diablo Canyon Project-when so requested by PG&E.

The Project Materials Coordinator provides project direction for assigned procurement activities at the project level and project coordination to Project Supplier Quality Supervisors. He receives Technical and Administrative direction from the PG&E Manager Materials and project direction from the Project Manager.

Project Supplier Quality Supervisors report to the Division Supplier Quality Manager for technical and administrative direction. The functions of the Project Supplier Quality Supervisor relative to Bechtel procurements arc:

1) Coordinate project procurement surveillance in-spection activities with project engineering and Procurement Supplier Quality.

2) Comment on technical specifications prior to issurance for bids.

3) Initiate supplier surveys, Supplier Quality Assign-ments, and coordinate supplier audits with Procurement Supplier Quality.

4) Review and accept procurement surveillance inspection reports.

5) Give project direction on project supplier Quality assignments to the Bechtel Supplier Quality Repre-sentative.

Field procurement services are provided by the Construction organization or are obtained through the Project Materials Coordinator for items procured by PG&E. * -

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ATTACHMENT 7 J

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• 2.9 PREOPERATIONAL TESTING AND PLANT TURNOVER The Quality Program described in this report covers design, procurement and construction activities.

Construction activities include peroperational testing

phase activities performed by the Start-up group of j the Diablo Canyon Project Construction Organization.

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ATTACHMENT 8

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Preoperational and startup testing is performed by -

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Ahe'Startup group of the Diablo Canyon Construction ,

organization under the direction of the Resident

- Startup Engineer. Written procedures or checklists are employed and test results are recorded, reviewed,

^. , _ , _. approved and retained. Quality Control performs

- - - surveillance inspection over preoperational and startup testing.

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ATPAOIMDIP 9 DIABID CN1YOJ NUCLEAR PRQJECP

"- QUALITY PROGRAM DOCUMENTS j

ORICIllATIIC REVIBY FOR OA POLICY NJD NJPilORIZItC A11PilORITY PROGilAM REOUIIllyDIPS APPROVAL COffDIPS TfX1]MErffS 1 IHQJECP OA SFPD OA MNJAGER ( B ECitTE L) SFPD OA MNJAGell 00ALITY PROGitN! TOLICY.

DTAlli.O CN3 YON

• EtCINEER (BECllTEL) DASED 01 DIVISION LOLICY tJilCLEAR OllALITY PROJECT MANAGER AS CDtIPAIND) Ill SPPD ASSilNNJCE M A N U A L STANDARD NQAM (NOAM)

DI A11LO CANYON

• PROJECT PROJECT QA ENGINEER DIVISION CilIEF QllALITY CONTROL (BECllTEL) QC ENGINEER PROCEDURES CON S TitU CTI O tt CONSTR. QC QUALITY CONTROL ENGINEER (BECitTEL)

PROCEDURES RESIONSIBILITIES AND PilG]ECP OA DCINED1 OlIEP CONSTilUCPION PilACPICE FOlt COrlSTRUC-DIAltlA CN1 YON

• FII'LD COtJSTitOC-TIOt1 SUPERIllPDJ- EfCINEDI TION SITE ACPIVITIES CONSTituCTIOl PitCCIDUnis (OUALITY DDff ( BECllTEL)

Pl(CitAM ItEI ATED )

VICE PilLSIDDff, PitOJECP OA DCINEER VICE PRESIDEttP, PROCEDURES FOR CONDUCPItC Itt.E lNGINEERItG

• EtCINEDlltC PROJECT ENGINEERING, MN H IAI. EtCINE10 tit 0 (PG&E) ACPIVITIES (PG&E) f I

PRQ1ECP OA DCINE151 PRQ3ECP DCINElul SUPPLENalPS 'IO DGLE PRQ1ECP R OINEFRI!C PRQ1ECP FNGINEldt ENGINEDutC MANUAL, INSTRUCTIONS Nillutl? NUCESSAltY l

l SUPERVISOR, PROJECP OA ENGINEER MANAGER 00ALITY PROCEDUllES 10!! RI'CDftDS l ItFCORDS MANAGl'MEtTP

' (DEQlTEL) ASSURANCE DEPT. MNIAGD4Dff SYSTIN SYSTIM llANf])OOK RFCOllDS FW1AGF.-

MEtif (PG&E ,

j (ICAE) RECORDS MANAGlHENP I

PROJECT COMPLE- PRQ1ECP OA ENGINElul PROJECT COMPLE_ PROCFDURES COVERING DIAllfD CN1 YON ' INTERFACES BETWEEN TION MANAGER TION MANAGER PROJECT PROCEDURE 9 THE PROJECT TEAM AND EXTERNAL ENTITIES j -

• MAY REPLACE Tile CORRESPONDING STANDARD DOCUMENTS LISTED IN TABLE 1.

ATTACHMENT 10

" DIABLO CANYON .

PROJECT TEAM ORGANIZATION

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.. ATTACHMENT 11 DIABLO CANYON PROJECT PROJECT ENGINEERING ORGANIZATION .

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DESIGN ENGR. E NG R. M AN AGE R E EER OU AL ITY CHIE F CHIE F CHIE F CHIEF CONTROL ENGR. CIVJSTRUCT. E LECT RICAL MECH ANICAL SYST E MS SUPE RVISOR ENGINE E R E NG8NE E R E NGINE E R E NGINE E R M AN AGE MENT PROJECT PROKCT E ENGINEER y gum is sua mim um milm ime a Imm M mEm Imm aus in m num SE l gggggg APE l TECHNICAL &

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' RECEIVES TECHNICAL REVIEW AND APPROVALOF SELECTED DOCUMENTS AND DESIGNS FROM THE PG&E DISCIPLINE CHIEF ENGINEER.

• ' AN EXCEPTION TO THE ABOVE LEGEND IS THAT ADMINISTRATIVE DIRECTION IS ALWAYS

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ATTACHMENT 12 PROJECT CONSTRUCTION ORGANIZATION coar,.

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ATTACHMENT 13 e

Regulatory Guide 1.144 (ANSI N45.2.12-1977, Auditing of Quality Assurance Programs for Nuclear Power Plants) .

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The requirements of the referenced standard as modified and interpreted by the regulatory position will be applied to the Bechtel quality program for safety-related items except as modified or interpreted be' low:

1)

Reference:

Standard Sections 4.3.2.4 and 4.5.1(Investigation).

As an equivalent alternative to the requirements for the audited organization to investigate any adverse audit finding to de-termine and schedule appropriate corrective action, Bechtel's auditing organization may determine the investigatory action and corrective action including action to prevent recurrence pertinent to adverse audit finding. These actions are agreed to by the audited organization. Further, in Section 4.5.1, as equivalent alternative to the 30-day response time, a response time appropriate to the finding is agreed to by the audited and auditing organizations.

2)

Reference:

Regulatory Section C.7, Standard Section 5.2 (Audit Records). Audit records shall include documents as defined in the standard and other documents if necessary to support audit findings.

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Bechtel Power Corporation .

San Francisco Power Division ATTN: Mr. C. D. Statton

> Vice President and General Manager F. O. Box 3965 -

San Francisco, California 94119 Gentlemen:

A series of huclear Regulatory Comission (NRC) inspections have been conducted T.o review your implementation of the Quality Assurance Program applicable to NRC applicants or licensees who have contracted forThese services from the consisted inspections San Francisco of Power Division of Bechtel Power Corporation.

selective examination of procedures and representative Asrecords, a result interviews of these inspec- of personnel and direct observation by the inspectors.

tiens, the NRC Office of Inspection and Enforcement (IE) has concluded that the QA program described in Tepical Report BQ-TCP-1, Revision 3A is being imple-mented satisf actorily. Neither this conclusion nor the remainder of this letter (s

applies to any activities conducted at reat.or sites. .

Meensees and applicants that have ' reference'd the :above Topical Report in their Safety Analysis Reports (or have ad6pted:iheito:il cuality assurance program described in that Topical Report) may at their? 6ption use this Setter. to-fulfin. ~

tneir obligation under 10 CFR Part. 50, Appendix B, triterion~ VII.- that 'rt-quires.

Inem to perfom initial source evaluation /selec' tion audits and subseq'uent periodic., -

audits to assess the quality assurance . program implemen-4 tion-Tne NRC expression of satisfaction with the -implementation of.your:QA program coes not assure that a specific product or' service offered by you totyour~ customer is of acceptable quality, nor does it relieve the applicant or licensee from the general provision of Criterion VII whicCrequires verifi&ation that purchased It is material, equipment, or services confom to the procurement documents.

recogni:ed that in some cases this assurance can be made by the applicant or licer.see witncut audi:s or inspections at your facility.

Continuing ac'ceptability of implementation of your QA program is contingent upon you maintaining a satisfactory level of program implementation, verified through periodic IE inspection, throughout all corporate organization units and nuclear projects encompassed by your program.

Should your program implementation at any time be found unacceptable, you will be in the notified by letter and requested to correct the deficiencies promptly r ,

-ever.: you fail to correct the deficiencies promptly, or if the record of defi .

ciencies is such as o indicate generally poor program implementation, you and 1

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. 15% San Francisc: Power Divisior.

. , _ Docket Nc. 95300522 the applicants and licensees who have referenced your QA program will be notified that the generic implementation of your program is no longer acceptable to the NRC. All of the audit / inspection requirements of Criterion VII, Appendix 5,

~10 CFR Part 50, must then be implemented by the applicants or licensees. The NRC will reinstate its letter of acceptability of implementation of your QA program only after our inspectors have concluded, based on reinspection, that you have

, .,' again demonstrated full compliance. .

Except as noted above, the conclusions expressed in this letter will be effective for three years from the date of issue of the letter. At that time progra=

performance over the previous three year period will be evaluated and this letter reissued, if appropriate.

Tne results of our inspections are published quarterly in the Licensee Contractor and Vendor Inspection Status Reporc (NUREG 0040), which is made available to NRC applicants and licensees, contractors and vendors, as well as to members of the public.

Sincerely.,

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Director e

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%{ / OCT 161980 Mr. R. M. Collins .

Vice President TP0 -

Bechtel Power Corporation P.O. Box 3965 '

San Francisco, CA 94119

SUBJECT:

NRC ACCEPTANCE OF REVISED BECHTEL TOPICAL REPORT ON QUALITY ASSURANCE By letter of December 13, 1979, Bechtel Power Corporation submitted proposed Revision 3 to its Topical Report, BQ-TOP-1. The submittal reflects proposed changes resulting

'from our review of your March 17,1978; April 27,1979; and July 18, 1979 quality assurance topical report submittals and various clarifying discussions between our staffs. The revisions reflect organizational and programatic changes in the Bechtel quality assurance effort.

We find that the December 19, 1979 submittal of the topical report, as changed by the Bechtel letter of October 6,1980, describes an acceptable quality assurance program for the design, procurement, and construction activities within the Bechtel Power Corporation scope of work for nuclear power plants. Therefore, your topical report g

on quality assurance is acceptable, and you may implement it upon issuance. For the s Bechtel Power Corporation quality assurance program description, applicants need only reference this topical report in Chapter 17 of license applications. We do not plan to rereview this topical report unless changes occur.

Should regulatory criteria or regulations change such that conclusions about this topical report are invalidated, we will notify you. You will be given the oppor-tunity to revise and resubmit it should you so desire. Programmatic changes by Bechtel Power Corporation to this topical report are to be submitted to the NRC for review prior to implementation. Organizational changes are to be submitted no later than 30 days after announcement.

Please replace our letter of August 19, 1977 shown in your topical report with this letter, change the revision number to 3A, change the date to October 1980, and forward 36 copies to the NRC. Your submittal should point out the changes by use of a black bar in the margin where a change is made, and the revision number should be adjacent to the bar. In your transmittal letter, indicate to which plant (s) this report will be applicable. ,

Should you have any questions regarding our review or if we can provide assistance, please contact Mr. Jack Spraul or me on (301) 492-7741.

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,)dg alter P. Haass, Chief Quality Assurance Branch Division of Engineering

Enclosure:

Topical P.eport Evaluation

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l C Topical Report Evaluation l

l Report Number: BQ-TOP-1, Revision 3A ,

Report Title; Quality Assurance Program for Nuclear Power Plants .

l Revision Date: October 1980 .. i

l. Originating Organization: Bechtel Power Corporation L Reviewed By: Quality Assurance Branch .

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SUMMARY

OF TOPICAL REPORT lopical report BQ-TOP-1, Revision 3A describes the quality assurance program which the Bechtel Power Corporation applies to those design, procurement, and construction activities involving safety-related structures, ~ systems, and com-ponents of nuclear power plants within the Bechtel scope of work. BQ-TOP-1, Revision 3A comits Bechtel to comply with the requirements of Appendix B to 10 CFR Part 50 and to comply with the regulatory position provided by the NRC (with some exceptions which have been found acceptable by the NRC) in the following Regulatory Guides:

Reculatory Guide Date l 1

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1.28 6/72  ;

( l.30 8/72 i s 1.37 3/73 l.38 3/73 "*

1.39 3/73 '

1.58 8/73 1.64 6/76 1.74 2/74 1.88 10/76 1.94 4/76 1.116 6/76 1.123 10/76 ANSI N45.2.12 (D-3, R-4) 2/74 Bechtel Power Corporation has provided for our evaluation a detailed description of organizations and groups involved in implementing activities required by the quality assurance program and a delineation of duties, responsibilities, and authority of those organizations involved in the quality assurance program.

BQ-TOP-1, Revision 3A describes the measures used to carry out the Bechtel Power Cc poration quality assurance program, and it describes how the applicable require-ments of Appendix B to 10 CFR Part.50 will be satisfied by the administration and implementation of these measures.

SUMMARY

OF REGULATORY EVALUATION We have evaluated the quality assurance program and the organizations responsible

(' for quality assurance functions as described in BQ-TOP-1, Revision 3A. We find that quality assurance policy and direction originate at an acceptably high

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management level and are effectively cannunicated to other parts of the organiza-tion. Those performing quality assurance functions have responsibility and authority commensurate with their duties in implementing the quality assurance program. We also find that measures have been established, to be ~ implemented by written procedures and instructions, which address each of the criteria of Appendix B in an acceptable manner.

- Based on our review and evaluation of BQ-TOP-1, Revision 3A, we conclude that:

1. The organizations and persons perfonning quality assurance functions within Bechtel Power Corporation have the required independence and authority to effectively implement the quality assurance program without undue influence from those directly responsible for costs and schedules, and

2. The Bechtel Power Corporation quality assurance program contains the require-nents and controls which, when properly implemented, comply with the require-ments of Appendix B to 10 CFR Part 50 and the applicable regulatory guides and standards contained in Chapter 17 of the NRC Standard Review Plan (NUREG-75/087, Revision 0).

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TOPICAL REPORT

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(BQ-TOP-1 1 l

BECHTEL

_ O.UALITY ASSURANCE PROGRAM

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FOR NUCLEAR POWER PLANTS

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SQ. TOP 1 REV.3A OCTOBER 1980 8

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FOREWORD AND QUALITY POLICY STATEMENT -

This report establishes the Quality Assurance Program requirements for work performed by or for Bechtel on Nuclear Power Plants designed and/or constructed in accordance with the requirements of the Nuclear Regulatory Commission Regulation 10CTR50, Appendix B, Quality Assur-ance Criteria for Nuclear Power Plants. The program defined in this report shall be followed by all Bechtel entities for nuclear power pro-jects referencing this report in license applications.

The President of Bechtel Power Corporation is authorized to issue revisions to this report and instructions for implementing the program.

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// S. D. Bechtel, Jr.

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BO-TOP.1 REV.3A OCTOBER 1980 l

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ABSTRACT This document describes the Bechtel Quality Assurance Program plan for use by the Bechtel Organization during the design, procurement, and construction of nuclear power plants. This Program plan meets the requirements of the Nuclear Regulatory Commission Regulation 10 CTR 50, Appendix B.

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BQ-TOP-3 Rev. 3A

. ii. October 1980 -

CAVEAT: THIS REPORT HAS BEEN PREPARED BY AND FOR THE USE OF BECHTEL POWER CORPORATION AND ITS RELATED ENTITIES. NO WARRANTIES EXPRESS OR IMPLIED ARE MADE, AND NO LEGAL LIABILITY OR RESPONSIBILITY IS ASSUMED FOR THE ACCURACY, COMPLETENESS, OR USE-FULNESS OF THE INFORMATION OR CONCLUSIONS CON- .

TAINED HEREIN.

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BQ-TOP-1 Rev. 3A iii October 1980

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$ CONTENTS PAGE INTRODUCTION 1 SECTION 1 ORGANIZATION 6

. 1.1 BECHTEL ORGANIZATION 6 1.2 THERMAL POWER ORGANIZATION 6 1.3 PROCUREMENT 7 1.4 MATERIALS AND QUALITY SERVICES .

8 1.5 POWER DIVISIONS S 1.5.1 Management 10 1.5.2 Quality Assurance 10 1.5.3 Engineering 11 1.5.4 Division Construction 11 1.5.5 Division Project Operations 12 1.5.6 Division Procurement 12 1.6 PROJECT ORGANIZATION AND FUNCTIONS 13 7

1.6.1 Project Quality Assurance 13 x 1.6.2 Project Engineering 14 1.6.3 Project Construcuon 16 1.6.4 Project Procurement 17 2 QUALITY ASSURANCE PROGRAM 19 2.1 SCOPE 19 2.2 POLICY 19 2.3 STOPWORK 21 2.4 PROGRAM DOCUMENTATION 22 2.5 PERSONNEL 22 2.6 PROGRAM CONTROL 24 2.7 PROGRAM EVALUATION 24 2.8 MANAGEMENT REVIEW 25 2.9 PREOPERATIONAL TESTING AND PLANT TURNOVER 26 3 DESIGN CONTROL 27 4 PROCUREMENT DOCUMENT CONTROL 31 5 INSTRUCTION' , PROCEDURES, AND DRAWINGS 34 6 DOCUMENT CONThtOL 35 7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, 37 AND SERVICES BQ-TOP-1 Rev. 3A iv October 1980 ,

C' CO.}iTENTS (Cont'd)

PAGE 7.1 SUPPLIER EVALUATION AND SELECTION 37 7.2 -

' SURVEILLANCE INSPECTION 38 7.3 RECEIVING INSPECTION 40 7.4 SUPPLIER AUDITS 42 8 IDENTIFICATION AND CONTROL OT MATERIALS, 43 PARTS, AND COMPONENTS 9 CONTROL OF SPECIAL PROCESSES 44'

10 INSPECTION 45 11 TEST CONTROL 47 12 CONTROL OF MEASURING AND TEST EQUJPMENT 48 13 HANDLING, STORAGE, AND SHIPPING 49 14 INSPECTION, TEST, AND OPERATING STATUS 50 15 NONCONTORMING ITEMS 51 16 CORRECTIVE ACTION 53 17 QUALITY ASSURANCE RECORDS 54 18 AUDITS 55 LIST OF TABLES TABLE l

I BECHTEL QUALITY PROGRAM DOCUMENTS 57 s

t l BQ-TOP-1 l Rev. 3A l v October 1980

N LIST OF FIGURES AND APPENDICES FIGURES

. FIGURE PAGE

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1 THE BECHTEL ORGANIZATION 59 2 THERMAL POWER ORGANIZATION 60

.~ 3 PROCUREMENT 61 4 SUPPLIER QUALITY ORGANIZATION 62 5 MATERIALS & QUALITY SERVICES SUPPORTIVE 63 TO THE THERMAL POWER ORGANIZATION 6 SAN FRANCISCO POWER DIVISION 64

. 7 LOS ANGELES POWER DIVISION 65 8 GAITHERSBURG POWER DIVISION 66 9 PROJECT TEAM ORGANIZATION (TYPICAL) 67

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10 PROJECT ENGINEERING ORGANIZATION 68 L (TYPICAL) 11 PROJECT CONSTRUCTION ORGANIZATION 69 (TYPICAL) 12 DIVISION QUALITY ASSURANCE ORGANIZATION 70 (TYPICAL) 13 QUALITY PROGRAM DOCUMENTS . 71 14 TYPICAL POWER DIVISION PROCUREMENT 72 ORGANIZATION APPENDICES APPENDIX A BECHTEL POSITION ON QA NRC REGULATORY A-1 GUIDES AND ANSI STANDARDS APPENDIX B DIVISION QUALITY POLICIES SCOPE AND RELA-TIONSHIP TO 10 CFR 50, APPENDIX B B-1 sa BQ-TOP-1 Rev. 3A a

vi October 1980 .

h CONFIGURATION CONTROL This list contains the date and revision number for each page in this Topical Report and will be revised when changes are made. ,

Page Rev. No. Rev. Date Page Rev. No. Rev. Date 1 3A October 1980 33 3A October 1980 11 3A October 1980 34 3A October 1980

. 111 3A October 1980 35 3A October 1980 iv 3A October 1980 36 3A October 1980 v 3A October 1980 37 3A October 1980 vi 3A October 1980 38 3A October 1980 vil 3A October 1980 39 3A October 1980 vill 3A October 1980 40 3A October 1980 1 3A October 1980 41 3A October 1980 2 3A October 1980 42 3A October 1980 3 3A October 1980 43 3A October 1980 4 3A October 1980 44 3A October 1980 5 3A October 1980 45 3A October 1980 6 3A October 1980 46 3A October 1980 7 3A October 1980 47 3A October 1980 8 3A October 1980 48 3A October 1980 9 3A October 1980 49 3A October 1980 10 3A October 1980 50 3A October 1980

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11 3A October 1980 51 3A October 1980 12 3A October 1980 52 3A October 1980 13 3A October 1980 53 3A October 1980 14 3A October 1980 54 3A October 1980 15 3A October 1980 55 3A October 1980 16 3A October 1980 56 3A October 1980 17 3A October 1980 57 3A October 1980 18 3A October 1980 58 3A October 1980

. 19 3A October 1980 59 3A October 1980 20 3A October 1980 60 3A October 1980 21 3A October 1980 61 3A October 1980 22 3A October 1980 62 3A October 1980 23 3A October 1980 63 3A October 1980 24 3A October 1980 64 3A October 1980 25 3A

• October 1980 65 3A October 1980 26 3A October 1980 66 3A October 1980 27 3A October 1980 67 3A October 1980 28

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3A October 1980 68 3A October 1980 29 3A October 1980 69 3A October 1980 30 3A October 1980 70 3A October 1980 31 3A October 1980 71 3A October 1980 32 3A- October 1980 72 3A October 1980

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vii BQ-TOP-1 Rev. 3A October 1980

- - CONFIGURATION CONTROL (Cont'd)

Page -Rev: No. Rev. Date Page Rev. No. Rev. Date A-1 3A October 1980 A-15 3A October 1980

< A-2 3A October 1980 A-16 3A October 1980

. A-3 3A October 1980 A-17 3A October 1980 a.-~ October 1980 A-4 3A October 1980 A-18 3A A-5 3A October 1980 A-19 3A October 1980 A-6 3A October 1980 A-20 3A October 1980 A-7 3A October 1980 A-21 3A October 1980 A-8 3A October 1980 A-22 3A October 1980 A-9 3A October 1980 A-23 3A October 1980 A-10 3A October 1980 B-1 3A October 1980 A-11 3A October 1980 B-2 3A October 1980 A-12 3A October 1980 B-3 3A October 1980 A-13 3A October 1980 B-4 3A October 1980 A-14 3A October 1980

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viii BQ-TOP-1 Rev. 3A October 1980

BECHTEL QUALITY ASSURANCE PROGRAM

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FOR NUCLEAR POWER PLANTS INTRODUCTION -

This r'eport describes the Quality Assurance Program applied by Bechtel* to the design, procurement, and construction of nuclear power plants. _ This report is intended to serve as a standard reference for safety -analysis reports, and, for a specific project, requires -only i identification of the Bechtel scope of services and a list of the manuals i from Table 1 applicable to the project to fulfill'the requirements of Chapter 17 prescribed in the " Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants" and Regulatory Guide 1.70, Rev. 2, September 1975, " Additional Information Quality Assurance During Design and Construction." The entire document will be reviewed l annually and revised as necessary. Individuals holding copies of this report as indicated on a controlled copy distribution list will receive copies of all revisions for insertion in their copy. , _

The Quality Assurance Program described in this report is consistent with the Bechtel overall goals and objectives of maintaining the compe-tence of its service and the quality of its end products at contractually required levels. This Quality Assurance Program is applied by Bechtel to those safety-related structures, systems, and components (Q-List items) identified in appropriate sections of the safety analysis report

' for which Bechtel has the responsibility for design , procurement, and/or construction (or construction management). The report does not cover preoperational testing activities.

The term " Quality Assurance" has been defined as "all those planned or systematic actions necessary to provide adequate confidence that an item or facility will perform satisfactorily in service." Quality assurance is recognized as e function of the group performing the work and not the sole responsibility of a . quality assurance group. ,

Quality is achieved through the use of skilled personnel, adequate planning, use of suitable tools and procedures, proper definition of job requirements, and appropriate supervision and technical direction.

Quality is verified through surveillance, inspection, Ittesting, is Bechtel checking, policy and review of work activities and documentation.

that the organization or group that performs the activity (i.e., Engi-neering,. Procurement, Construction, etc.) is responsible for the gener-ation of a quality product. Quality control and quality verification are perfcrmed by individuals who are not directly responsible for perform-ing the work activity. The separation of responsibilities by organiza-tion for performance of the work activities and for performance of quality control and quality verification is discussed in Section 1 of this report.

( *The term Bechtel is employed in this report to identify the Bechtel

'~ Power Corporation and associated companies which may be contractually responsible for all or part of a project. BC-TOP-1 Rev. 3A 1

October 1980

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I Regulatcry Guide 1.58 " Qualification of Nuclear Power Plant Inspec-tion, Examination and Testing Dersonnel (Au-gust 1973)" l h> -

Regulatory Guide 1.64 Quality Assurance Requirements for the De-sign of Nuclear Power Plants, (Rev 2, June 1976)" .

Regulatory Guide 1.74 " Quality Assurance Terms and Definitions (February 1974)" .n.

= Regulatory Guide 1.88 " Collection, Storage, and Maintenance of

- - ~ - Nuclear- Power Plant Quality Assurance Records

- (Rev. 2, October _1976)"

Regulatory Guide 1.94 " Quality Assurance Requirements for Installa-tion, ' Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants (Rev.1, April 1976)" - +

Regulatory Guide 1.116 " Quality Assurance Requirements for Instal-lation, Inspection and Testing of Mechanical Equipment and Systems (June 1976)"

Regulatory Guide 1.123 " Quality Assurance Requirements for Control of Procurement of Items and Services for

" Nuclear Power Plants (October 1976)"

t ANSI Standard " Requirements for Auditing of Quality As-N45.2.12-1974 surance Programs for Nuclear Power Plants.

(Draft 3, Rev. 4, February 22, 1974)"

The terms used in this report follow the definitions provided in ANSI N45.2.10-1973, " Quality Assurance Terms and Definitions," supplemen-ted by the following additional terms and definitions applicable to this report.

1. Administrative Direction ( Administrative _ Supervision):

Responsibility for hiring, salary review, and assignment of an individual.

2. Approve: When used in context with Bechtel review of supplier documents, the word " approve" or words of like import, such as " review" and " accept", shall mean, unless the context clearly indicates otherwise, that the supplier shall, before implementing the information in the document, submit the document, obtain resolution of any comments, and obtain authorization to proceed, and shall not mean that a complete check will be performed. Authorization to proceed shall not constitute acceptance or approval of design details, calculations, analyses , test methods or materials developed or selected by the supplier and shall not relieve supplier from full compliance with contrsctual

{ obligations.

BQ-TOP-]

Rev. 3A 3 October 1980

(c w 14. Review: Examination of any form of documentation for the purpose of establishing acceptability to the requirements of the function represented by the reviewer. Reviews may range from a thorough investigation to a spot check.

Reviews are generally not holdpoints, but signoff evidence

- of review on the documents or records traceable to the documents is required. *

15. Subcontractor: Supplier of ' construction site services, materials, or equipment. On construction management jobs, contractors under direct contract to the client may provide construction site services.

16. Surveillance: A broad term pertaining to and including both monitoring and witnessing.

17. Surveillance Inspection: Review, observation, or inspec-tion of supplier personnel, material, equipment, processes, and test results at random or selected stages of manufac-ture for the purpose of determining if an action has been accomplished or a document (s) prepared in accordance with selected requirements of a contract documtnt(s). Surveil-lance inspection does not take the placrof supplier quality programs or assume any responsibility for such programs or product quality. Surveillance inspection is intended to I provide a degree of added confidence that supplier materi-

\ als and equipment meet specific contract requirements.

l Such inspections will not relieve the supplier or construc-i tion contractor of any responsibilities under the applicable l contract, or act as waiver by Bechtel or Client of any of the conditions thereof.

For additional information, see Section 7, subsection 7.2, l SURVEILLANCE INSPECTION.

l 18. Technical Direction: Instructions and directions defining technical requirements for an activity. This may include furnishing prescribed procedures, technical requirements, i design approaches, specifications, and design details.

l 19. Technical Guidance: Providing advice representing a l preferred method or approach to a function or activity.

l . This may include establishing general requirements or

policy but not specific procedures or instructions.

20. Witness: To watch over, observe, or examine a specific test or work operation which includes signoff responsi-bility.

Whenever an approved ANSI Standard or Draft (or portion thereof) is referenced herein without qualification, all requirements of the Standard l (- as internreted by Bechtel Quality Assurance management :nust be incor-poraud in the program subject to the modifications in Appendix A of tnis report or in individual SARs.

BQ-TOP-1 Rev. 3A 5 October 1980

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SECTION I

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(17.1.1)

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ORGANIZATION 1.1 .BECHTEL ORGANIZATION .

Figure 1provides an organization chart for the Bechtel Organization.

Nuclear power plant work is performed by Bechtel through Bechtel

- Power Corporation (Thermal Power Organization) which includes the three power divisions.- The Thermal Power Organization is managed by -

the President of Bechtel Power Corporation. .

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1.2 THERMAL POWER ORGANIZATION (BECHTEL POWER COR- -

PORATION) '.C

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Figure 2 provides more detailed definition of the Thermal. Power Orga-nization. .

The Thermal Power Organization consists of a general management group

- (Thermal Power Management) and three operating divisions: Gaithers-burg Power Division, Los Angeles Power Division, and San Francisco Power Division.

Thermal Power Management, consisting of the President, Vice President, and a staff, establishes policy and is responsible for providing effective

(._ and close communication among the Power Divisions. A Sponsoring L Corporate Officer is designated for each of the staff functions. The Sponsoring Corporate Officer for Quality Assurance is the Vice Presi-dent, Planning and Quality Assurance. The following are the primary responsibilities of the Sponsoring Officer for Quality Assurance:

o Develops , reviews , and approves new or revised TPO quality policy.

o Provides guidance on quality policy across the divisions (including coordination of quality functions of external organizations, such as M&QS and Procurement).

o Evaluates the effectiveness of the Divisions Quality Assur-ance programs and reports annually on the adequacy of the implementation of the quality programs to the President of Bechtel Power Corporation.

The sponsoring officer for QA has staff support, as required, to assist him in carrying out these responsibilites.

The quality policy statement for the Thermal Power Organization, in-cluding the program described by this Topical Report, is authorized (approved for use) by the President of Bechtel Power Corporation.

The staff of the Thermal Power Management supports and assists the President in carrying out his responsibilities.

(' BQ-TOP-1 Rev. 3A 6 October 1980 l

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(1 The Division Procurement Manager assigned to a Thermal Power Organi-zation Division is responsible for procurement of equipment, materials, and services for projects within that Division. He reports to the re-spective Manager of Procurement TPO for technical guidance as shown in Figure 3. He receives administrative direction from the management of his Division, as shown on Figures 6, 7, and 8.

As shown in Figure 4, the Division Supplier Quality Managers receive I technical direction from the Manager of Procurement Supplier Quality.

Administrative direction is the responsibility of the Division Procurement Manager, as shown on Figure 14. The following ' activities are the 1

- responsibility of the Manager of Procurement Supplier Quality and are accomplished with the assistance of the supplier Quality Managers in each of the Division offices:

1) Prepare, maintain,and implement the Procurement Supplier

. Quality Department Manual

2) Prepare the training and development' program; train and qualify Procurement Supplier Quality personnel

3) Perform surveys and quality program audits at suppliers and offsite subcontractors as required by project and division procedures

4) Prepare and implement inspection plans

5) Provide qualified personnel and perform surveillance in-spection of items: review quality verification documents and release items for shipment

6) Review supplier QA program

7) Coordinate Procurement Supplier Quality Department activ-ities with other quality functions

8) Monitor the adequacy of inspection plans and procedures in I use by Supplier Quality personnel 1.4 MATERIALS AND QUALITY SERVICES The Materials and Quality Services Department (M&QS) is responsible for furnishing specialized metallurgical, quality control, and auditing I services to Bechtel divisions. Figure 5 illustrates the organization of the Materials and Quality Services Department.

M&QS responsibilities are:

1) ho develop and' qualify welding and nondestructive exami- l nation (NDE) procedures

2) To qualify and certify Bechtel nondestructive examination s

personnel BO-TOP-1 Rev. 3A 8 October 1980

- 1.5.1 Management 0' Each division management organization is uniquely suited to the nature of division activities and the -functions directly associated with the office. The typical division management team includes the Division Manager, Manager of Project Operations, Manager of Engineering, Manager of Construction, Manager of Procurement, Manager of Services, Manager 'of Btisiness Development, and the Quality Assurance Manager.

Each of these managers has the direct responsibility and authority for the functions of his department or group.

t 1.5.2 Quality Assurance Quality Assurance Managers provide technical and administrative direc-tion to the Quality Assurance Group within the division. A typical" ~

Division Quality Assurance Organization is: shown in Figure 12. Each '

l Quality Assurance Manager is responsible for:~ .

1) Tormulating Division Quality ' ssurance Policies where necessary to implement or supplement quality policy pre-scribed by the Thermal Power Organization

2) Approving quality assurance procedures and instructions which define responsibilities and functions of quality assurance personnel within his division

- 3) Approving quality-related procedures and manuals pre-pared by departments and projects within his division for conformance to quality assurance policies

4) Formulating audit programs and conducting audits and reviews to assure Bechtel management and clients that the quality assurance programs of the division and its projects conform with policies and requirements of Bechtel and the client. Identifying the need for corrective action and assuring follow-up

5) Providing periodic reports to the Division Manager and the Vice President, Planning and Quality Assurance - Thermal Power Organization, on the status and adequacy of division and project programs and advising of any problems re-quiring special attention

6) Providing and maintaining a qualified and suitably trained staff of quality assurance engineers to carry out required project and staff functions I

1 Formulating programs for maintaining the professional 7) competence of personnel within his organization and provid-ing assistance in training and indoctrination programs for division management, engineering, and construction per-l sonnel whose activities affect quality l

l( BO-TOP-1 Rev. 3A 10 October 1980 1

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,. Formal quality verification inspection and onsite subcontractor / con-( tractor surveillance inspection activities performed by Bechtel are the

' responsibility of Construction Quality Control. The Chief Construction Quality Control Engineer supervises the construction quality verification program and is responsible for administrative and technical direction of the Construction Quality Control Engineers. ,

Chief Construction Quality Control Engineers: _

1) Prepare and maintain standard construction quality control - -

procedures _. m --- . - .

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2) Approve project quality control procedures and instruc-tions ,

3) Hire and assign quality control engineers to the projects - :

4) Train and qualify quality control engineers _

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5) Provide technical and administrative direction to construc-tion quality control engineers 1.5.5 Division Project Operations A Project Manager is assigned to each power project. (A project in-volving engineering only may not have a project manager.) Project

- Managers report to Manager of Project Operations, who provides admin-istrative and technical direction and assures the division's consistent and coordinated application of Bechtel policies and skills for the benefit of the project.

1.5.6 Division Procurement The Manager, Division Procurement, is responsible for Procurement

, activities performed for projects within the Power Division. The Project

! Procurement Manager and his staff are responsible for coordinating Procurement activities for.the project, as described in subsection 1.6.4. [

They receive technical and adminstrative direction from the Manager, Division Procurement, and project direction from the Project Manager.

The Division Supplier Quality Manager receives adminstrative direction from the Manager, Division Procurement (requires review by the Man-ager of Procurement Supplier Quality) and technical direction from the Manager of Procurement Supplier Quality. The Division Supplier Qual-l ity Manager assigns Project Supplier Quality Supervisors to division

! projects and provides them with technical and administrative directions and coordinates with the Manager of Procurement Supplier Quality Department.

Figure 14 illustrates a typical division procurement organization. l I' BQ-TOP-1 Rev. 3A 12 October 1980 i

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

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

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

Procurement Supplier Quality l

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12) Assure that quality assurailce-related procedures and--

manuals prepared by or used for the project meet project quality program. requirements and initiate revisions when-necessary. n . , , . .

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

a. Accuracy of translation of drawing and specification requirements

b. Basis for determining inspection level and sequence

c. Adequacy of inspection method This review provides assurance that the total quality program requirement inclusions are complete. Reviews of plans and instructions can be performed on a generic basis. In that case, the PQAE only verifies that the l review has been performed.

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14) Prepare quality assurance descriptions in Safety Analysis Reports l 1.6.2 Project Engineering The Project Engineer is responsible for the conduct of engineering on his project. The Project Engineer may be assisted by one or more Assistant Project Engineers. The Project Engineer provides project 4

1 direction to the Group Supervisors. He is responsible for ensuring that engineering work under Bechtel cognizance is carried out in accor-dance with the project direction received from the Bechtel Project Manager and the technical direction received from the Engineering Manager. . . ,

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1.6.3 Project Construction A Field Construction Manager is a'ssigned to each nuclear plant project involving construction or construction management assignment, and he is responsible for the project field construction performance. The Field Construction Manager is responsible for assuring that construction activities art performed in accordance with the design requirements as established by project engineering and other applicable requirements.

A typical project construction organization is shown in Figure 11. l The project construction organization includes Superintendents who are in direct charge of the crafts (on projects for which Bechtel is assigned direct construction responsibility); Field Engineers who perform field engineering, provide technical guidance and monitoring of construction I work; field procurement personnel under the Senior Field Procurement Representative who are responsible for purchase of field-procured items and control of materials prior to release for construction; the Field Contracts Administrator who coordinates activities of field subcon-tractors; and Construction Quality Control Engineers (assigned by and administratively and technically responsible to the Chief Construction Quality Control Engineer) who are responsible for the Bechtel field quality control program, including performance of all quality verification inspection performed by Bechtel. Construction Quality Control activi-ties are coordinated by the Field Construction Manager.

n Field quality control is the responsibility of the Project Construction Quality Control Engineer. Construction Quality Control personnel are responsible for quality verification at the construction site. This includes physical inspection of construction performed directly by Bechtel and surveillance inspection on construction work performed by subcontractors (or contractors for construction management activities).

Surveillance inspection by Bechtel Quality Control supplements the quality control program of the subcontractor and determines confor-mance to quality requirements. This surveillance inspection includes either selected physical inspections at prescribed hold points, or obser-vation and witness of inspections performed by subcontractors, quality control personnel, or both.

l Construction Quality Control Engineers:

f 1) Perform Bechtel jobsite quality verification inspection

2) Prepare Bechtel jobsite quality control documentation and maintain construction quality control records

3) Prepare and approve additions to division approved quality control procedures and instructions .

4) Perform surveillance of subcontractor / contractor quality program implementation when the subcontractor / contractor has responsibility for first-level quality control.

BQ-TOP-1 Rev. 3A 16 October 1980

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Project Supplier Quality Supervisors report to the Division Supplier Quality Manager for technical and administrative direction. The func-tions of the Project Supplier Quality Supervisors are:

1). Coordinate ;3roject procurement surveillance ' inspection activities wita project engineering and Procurement Suppli-er Quality -

2) Comment on technical specifications prior to issuance for bids

3) Initiate supplier surveys, Supplier Quality assignments, and coordinate supplier audits with Procurement Supplier Quality

4) Review and accept procurement surveillance inspection reports

5) Give project direction on project Supplier Quality assign-ments to the Bechtei Supplier Quality Representative Field procurement services are provided to the project construction team through the senior field procurement representative at the jobsite. The senior field procurement representative receives project direction from the Field Construction Manager and/or the Project Procurement Manager, (u and technical and administrative direction from the Field Procurement Manager.

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( SECTION 2

% (17.1.2)

QUALITY ASSURANCE PROGRAM 2.1 SCOPE - .

The program described in this report is applied to the design, procure-ment, 'and construction of those structures, systems, and components (items) whose satisfactory performance is required to prevent accidents--

which may cause undue risk to the health and safety of the public or to

. mitigate the consequences of such accidents if they :were -to occur. "

These items are defined as safety related and are identified in the safety analysis report for the project.

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POLICY , .

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The Bechtel Quality Program described in this report is designed to ~

comply with the requirements of the NRC Regulations and the practices prescribed by American National Standards, client requirements, and Bechtel policies. The program assigns the responsibility for quality to the organization responsible for performing the work and includes as a basic requirement that individuals responsible for verifying and checking are independent of the individual or group responsible for performing the work. Additionally, independent review, audit, and surveillance are performed by individuals not affiliated with the organi-zational entities responsible for performance of the work.

The President of Bechtel Power Cor7 oration is responsible for the overall quality policy of the Thermal Pcwer Organization. Division Quality Assurance Managers assist in the development of revisions and/or additions to TPO Quality Policies for review and approval of the

' Vice President, Planning and Quality Assurance. ' Division Quality policies and quality assurance procedures of the divisions are formu-lated by the Quality Assurance Managers in the divisions who receive

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policy guidance from the Vice President, Planning and Quality Assur-

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ance, and report directly to management of the division. Division policies are authorized for use within the division by the Division Manager. Quality assurance practices for individual projects are implemented through the Division Quality Assurance Managers. Project, department, and division quality practices are subject to audit by Quality Assurance.,

Coordination of the Quality Program within the Thermal Power Organiza-tion is the responsibility of the Vice President, Planning and Quality Assurance. The Quality Program is defined by Division Quality Policies -

formulated by Division Quality Assurance Managers.

These policies are implementeil through procedures and manuals 1ssued by the various departments and groups. The implementing procedures are approved for pol.3/ compliance and the program requirements of this report by Quality Assurer.ce management (see Table 1). Project

( quality programs incorporate required division policies and procedures BQ-TOF-1 Rev. 3A 19 October 1980

2.3 STOPWORK The program provides Quality Assurance personnel with stopwork au-

' thority over certain portions of project activity, and this authority is delineated in procedures. In addition, control of further processing of [

unacceptable work is provided by appropriate hold and release points as follows: .

1) Design. Unsatisfactory work with respect to design docu-ments prepared by Bechtel is controlled through the inde-pendent review process (prescribed by written procedures)

. and the refusal of the checker / reviewer to sign off the acceptance of the document which blocks its further pro-cessing and issue for use. - Each non-Bechtel design document for which project engineering has an interface and review responsibility is logged upon receipt and has affixed a standard Bechtel stamp which signifies the status -

of the document ~when it is returned to the originator.

Any status other than permission to proceed automatically sets in motion follow-up and close-out actions.

2) Procurement. Bechtel control over Supplier work is as follows: the Procurement Supplier Quality Representative, when required by procurement documents, must authorize [

supplier release for shipment (for purchased items) and may recommend stoppage of work on selected activities through designated contractual chanruis in situations

'. which, if uncorrected, would render the item unacceptable for release. In cases of gross deficiencies or violations, contractual relief, in-procurement documents provide cluding termination, and these measures can be used when necessary.

3) Construction. Construction Quality Control has two prima-ry mechanisms to control further processing of unaccept-t able work. These are the nonconforming material control system and the authority to refuse acceptance of completed l

I work. Quality Control has authority to recommend stop-page in situations which, if uncorrected, would render the item nonconforming or unacceptable. In cases of con-tractor or subcontractor work, Construction Quality Con-trol exercises controls similar to Procurement in 2) above.

f 1

'k BQ-TOP-1 Rev. 3A 21 October 1980

~

1 b' In addition to the basic indoctrination and training programs and per-formance reviews, certain minimum education and experience guidelines have been established for various positions responsible for managing and directing program activities. While these are used for guidance in selecting candidates for these positions, they are not considered abso-lute requirements when other factors, such as the individual's' demon-strated capability and staff technical support available to him, provide assurance that appropriate . managerial and technical skill will be applied.

The basic qualification requirements for key management positions in the

- quality groups are an advanced degree with five or more years of appropriate management and quality assurance experience, or a bach-elor's degree with eight or more years of appropriate experience.

Additional pertinent experience is considered in lieu of a bachelor's .

degree.

The basic qualification requirements for supervisory and project quality functions, such as Project Quality Assurance Engineer, Project Con-struction Quality Control Engineer, etc., are an advanced degree with

- two or more years of appropriate supervisory and quality-related expe-rience or a bachelor's degree with five or more years of appropriate experience. Additional pertinent (technical) experience is considered in lieu of a bachelor's degree. Records are maintained shewing qualifi-cations of key management, supervisory , and project personnel in quality groups.

The following specific qualification requirements are applied:

1) Personnel performing pressure boundary and structural welding and nondestructive examination are required to meet applicable qualification requirements of ASME Code, SNT-TC-1 A , or other appropriate codes and standards.

2) Quality Control Personnel - Construction Quality Control Engineers and home office Quality Control staff and super-vision will be qualified in accordance with the provisions of Regulatory Guide 1.58 ( August 1973) or SNT-TC-1A, as applicable.

3) Audit Personnel - Personnel performing audits will be qualified in accordance with the appropriate requirements of ANSI N45.2.12.

4) Procurement Supplier Quality Representatives - A formal training program, developed by the Procurement Supplier Quality Department, is required for Supplier Quality Representatives assigned nuclear plant purchase orders.

This program is defined in the Bechtel Procurement Sup-plier Quality Manual (PSQM) and conforms to the applicable i requirements of Regulatory Guide 1.58 (August 1973).

(.

SQ-TOP-3 Rev. 3A 23 October 1980

(' report to the President of Bechtel Power Corporation evaluating the adequacy of the quality assurance program:

1. Quarterly reports by the Division Quality Assurance Man-agers, the Manager of Procurement Supplier Quality, and the Manager of Materials and Quality Services (including their summary of quality problems and audits)

2. The results of Division Quality Assurance Managers quality program coordination meetings, conducted at least semi-annually

3. Audits or reviews of quality activities in the Divisions and support services as directed by the Vice President, Plan-ning and Quality Assurance The above-listed reports and activities are also used 'to recommend action on the part of the Division Quality Assurance Managers, develop new policies, or other action as deemed appropriate by the Vice Presi-dent, Planning and Quality Assurance.

2.8 MANAGEMENT REVIEW Management reviews of the status and adequacy of the quality assurance program are accomplished through periodic reports and presentations by Quality Assurance Management personnel to their respective managers, and through reviews of quality assurance management audit reports.

Meetings are held on a regular basis at both TPO and division manage-ment level. Meetings at the TPO level are coordinated by the office of the Vice President, Planning and Quality Assurance, and the division level meetings are conducted by the Division Quality Assurance Man-ager.

The overall TPO Quality Assurance Program and each Division Quality

! Assurance Program, including support service organization Quality Assurance Programs, are reviewed annually by individuals outside the quality assurance function. These reviews are performed by manage-l ment above or outside the QA organization for TPO and Division Man-i agement. The results of these reviews are documented and submitted to division and corporate management.

l Management reports contain summary data on the status of outstanding

' audit and corrective action items and identify the status of other signif-icant quality program activities which may include items such as training and qualification programs; development o' standard procedures, work plans, and other documents; status of it .:stry standards; and other external issues of interest. These reps:is and discussions combined with other reports on overall division perfcrmance are used by TPO and division management above the level of Quality Assurance Manag'er to assess the scope, implementation, and adequacy of the quality assurance program.

'(

BQ-TOP-1 Rev. 3A 25 October 19m -

er 4

_o

[ SECTION 3 (17.1.3)

DESIGN CONTROL Engineering department policies, standards, design guides, procedures, and instructichs are employed for control of engineering design work to meet technical and regulatory requirements. These controls identify responsibilities and provide procedures to assure that the design re-quirements are correctly translated into the final design. The controls also provide for preparation of appropriate documentation to permit review of the process used and of the results obtained. The controls provide for the identification and specification of appropriate quality standards and for control of changes and design interfaces.

Design criteria are assembled by the project during the initial stages of design. These criteria include the criteria contained in safety analysis reports and other project requirements. The design criteria are main-tained current and serve as a basis for preparation of the final design.

The design control program incorporates measures for identification and control of design interfaces among the various engineering disciplines on the project, between the project and technical support groups within Bechtel, and of such external interfaces as nuclear steam supply system supplier, other equipment suppliers, subcontractors performing design work , and the client (plant owner). These measures include: (a) identification of technical responsibilities of the various design grou?s and provisions for coordination of design documents among them, (.3) description of responsiblities of and provisions for coordination with other design and engineering support groups within Bechtel, and (c) definition of interfaces and control of communication with organizations external to Bechtel.

Essentially all engineering documents are prepared by project personnel and include drawings, specifications, design analyses, system descrip-tions, and technical reports. They are verified or checked in accor-dance with Engineering Department Procedures. Project Group Super-visors (Figure 10) are responsible for all engineering work performed [

within their discipline and for approval of engineering documents prepared within their groups. Procedures and instructions for verifi-cation and checking of drawings, calculations, and specifications are included in the procedures governing the preparation of these docu-ments or in separhte procedures or instructions. These procedures identify the positions responsible for verification or checking and re-quire that design errors are identified and followed up through cor-rection. Verifiers and checkers on the project are required to verify the incorporation of required corrections. Documents cannot be released without. verification or. checking. .

k BO-TOP-1 Rev. 3A -

27 October 1980

When design verification is accomplished by an interdisciplinary design review, the review team will be composed of individuals knowledgeable

(" of the type of system or structure and the requirements thereof. They may or may not have participated directly in the design of that partic-ular system or structure. An individual who has participated directly in the design shall not be responsible for the independent design veri-fication of his , discipline. _

~

The above description of design verification of key design documents ~

satisfies the regulatory position of Reg. Guide 1.64, June 1976.

Design documents other than key design documents, identified above, shall be checked for technical correctness and conformance to design input requirements. -

Engineering Department Procedures establish the extent of checking, the duties of the checker, and the extent of his reponsibility for which he attests with his signature or initials. The signature or initials of-the checker and date affixed on the design document in accordance with the Engineering Department Procedure satisfies the regulatory position of Reg. Guide 1.64, June 1976. Traceability of characteristic signa-tures and initials to the individual will be provided.

TPO designated Chief Engineers coordinate and assist in the preparation l of certain generic " standard" and " guide" documents. Standard docu-ments include design standards, standard details, standard specifica-tions , and technical topical reports. Guide documents include design 7

guides, guide key documents, guide specifications, and Regulatory Guide positions. Generic " standard" and " guide" documents which are pre-engineered to a level suitable for direct project adoption are subject to checking, review, and design verification as described in this Sec-tion . Standard or guide documents which have been qualified by a design verification need only be verified by a project for their applica-bility to project requirements. The acceptability of any significant changes to the qualified standard document must also be verified and documented.

As a matter of policy, Bechtel uses accepted industrial standards, specifications, and materials. Prototype testing is encouraged for equipment suppliers whose components have not previously demonstrated adequate performance. Prototype testing is not normally applicable to Bechtel design work; however, selected design details may be verified by test. When prototype testing is used for design verification, the test requirements are specified by Bechtel.

Design changes, including field changes, are subjected to design con-trol measures commensurate to those applied to the original design.

Checking and review of design changes are performed by the Project Engineering team to the same level as that of the original design.

Changes to design requirements or completed designs produce'd by Project Engineering, which may be proposed by suppliers, subcon-tractors, or Bechtel construction, must be reviewed and accepted by I Project Engineering.

[ BQ-TOP-1 Rev. 3A 29 October 1980

SECTION 4 CL C- (17.1.4)

PROCUREMENT DOCUMENT CONTROL All procurement actions for Q-List items and services, including off-the-shelf _ items and bulk commodities, whether performed by home office or field procurement groups, employ technical and quality requirements 3~ ~ -

established by project engineering.' __ _

4 Project engineering prepares (or provides) the technical and quality-requirements appearing in procurement documents. These activities are governed by the same policies and procedures as those applied to.

design documents. Engineering and ?rocurement department procedures delineate the sequence of quality-re ated action to be accomplished in

< preparation, review, approval, and control of procurement documents and changes thereto. .

Project engineering is responsible for assuring that applicable regula-tory requirements, design bases, sup? lier quality assurance program requirements, and other requirements waich are necessary to obtain and verify quality are included or referenced in the procurement documents.

While the project engineering team is responsible for preparation of specifications for supplier, contractor, or subcontractor quality assur-ance programs, these spec:fications are based upon program policy I formulated by Quality Assurance and guidance providad in approved k Engineering Department Procedures and standard engineering specifica-tions. The specifications are reviewed for appropriate quality program requirements by Project Quality Assurance.

Procurement documents include specific technical specifications for the equipment and services to be furnished which define specific codes, standards, tests, inspections, and records to be applied or furnished.

i The procurement documents also include quality assurance requirements either in separate specifications which define requirements for the supplier's quality assurance program or by incorporating appropriate requirements in the technical specifications and associated documents.

Quality programs may be specified by invoking the appropriate sections and elements of ANSI N45.2-1971, appropriate supplementary ANSI Quality Assurance Standards, and the ASME Boiler and Pressure Vessel Code, as applicable, or by incorporating requirements equivalent to those of these standards. The procurement documents also establish provisions for surveillance, inspection, and audits (including access to the supplier's and subsupplier's facilities and records for audit),

provide for extension of the applicable requirements to subtier procure-ments, include provisions for control and approval of supplier noncon-formances, and establish requirements for preparation and delivery of documentation. ' Specific requirements for documents which must be submitted for review, approval, and/or verification are provided.

BQ-TOP-1 Rev. 3A 31 October 1980

1

(.-

The following describes the sequence of steps for Bechtel Field Pro-curement:

1) Field Engineering prepares requisitions employing technical and quality assurance requirement specifications which

- ' have been established by Project Engineering and have

- been reviewed. by Quality Assurance.

2) The Project Construction Quality Control Engineer reviews the field material requisition to verify inclusion of specified 1 - quality assurance requirements.

3) Field Engineering forwards the material requisition to the Senior Field Procurement Representative.

4) The Senior Field Procurement Representative prepares a bid request package which is forwarded to bidders.

5) Bids are received and reviewed for commercial terms by the Senior Field Procurement Representative and forwarded to Field Engineering for technical evaluation and selection of recommended supplier. Quality program evaluation is normally performed by Project Engineering but may be '

performed by Construction Quality Control or Procurement Supplier Quality.

(

\' 6) The Quality Assurance Engineer reviews and concurs with the evaluation of the recommended supplier's quality assur-l ance program.

Engineering approves the bid recommendation,

7) Field i obtains other necessary approvals, and forwards it to the Senior Field Procurement Representative.

8) After receipt of necessary approvals, the purchase order /

subcontract is issued by the Senior Field Procurement l

Representative.

k BQ-TOP-1 l

Rev. 3A 33 October 1980

(

(l SECTION 5 C (17.1.5)

INSTRUCTIONS, PROCEDURES, AND DRAWINGS The documented instructions and procedures governing the program were identified in Section 2.

Procedures and manuals governing the activities of organizations and groups performing quality-related functions include procedures for the preparation and review of instructions, procedures, and drawings.

Documented instructions from Project Engineering to Construction, subcontractors, and suppliers is in the form of engineering specifica-tions and addenda or change notices thereto, drawings, and drawing change notices. These documents contain, reference, or require pro-cedures and instructions, as appropriate, and provide necessary accep-tance criteria. When approved by Project Engineering, these documents are released for construction work.

Bechtel procurement documents require suppliers and subcontractors to submit specified drawings and procedures to Bechtel for acceptance prior to start of fabrication or construction. Bechtel reviews of these documents are performed to determine that interfacing design features are compatible with overall design and installation requirements and that procedures are acceptable.

t Procedures for construction activities are prepared by Construction and contained in a procedures manual. These procedures describe, define, or specify administrative and functional requirements for performing construction activities. Procedures of this nature include training of personnel; jobsite housekeeping; storage, maintenance, and handling of items; document control; changes to design documents; reviewing sup-plier engineering documents; and field requisitioning of items and services. .

Field Engineering (construction) prepares other procedures when engi-neering documents require amplification to perform various discipline activities associated with fabrication, cleaning, erection, installation, test, repair, modification, etc. , of items.

The requirements, procedures, and instructions for the Construction Quality Control activities are contained in the Construction Quality Control Manual. The elements of this manual include qualifications, indoctrination, certification, and training; inspection, examination, and test control; control of nonconforming items; field procurement control; i

control of measuring and test equipment; documentation and records contrei; final . inspection and . turnover; and contractor and subcontractor l

l Contro} .

Assurance that work is accomplished in accordance with approved in-

' structions, procedures, and drawings is obtained through the various k levels of surveillance, inspection, and audit described in other sections of this report.

BQ-TOP-1 Rev. 3A 34 October 1980

> . i h

SECTION 6 -

2

. (17.1.6) I l

DOCUMENT CONTROL 4 The program documents identified in Section 2 provide means for docu- '

ment control. . These include procedures providing Engineering, Pro- ,

curement Inspection, and Construction controls for the review, approv-al, and release of documents and changes thereto. _,

Documents pertaining to quality-related iteins , as identified in this~

. paragraph, are required to be controlled. The documents listed in' l Table I are on controlled distribution. Instructions, procedures, speci-fications, drawings, procurement documents, inspection plans, design-calculationc, design criteria, field change requests , safety analysis reports, and inspection test procedures are identified by control regis-ters or index lists. Nonconformance reports, supplier -deviation --

reports, corrective action reports, documentary evidence of design reviews, memoranda, and correspondence are identified by logs which '

provide for traceability of closecut action. _

Document control centers for the project are set up in the Project Engineering office and the jobsite. Controlled documents are released, received, controlled, and distribute:i through these centers.

Engineering Department procedures prescribe the requirements for

- preparation, control, and distribution of design documents. Approved w drawings and specifications prepared by Project Engineering are issued to organizations and individuals responsible for performing the work and to those responsible for inspection *. Control registers, issued periodically , identify the drawings, specifications, and other design output documents and their current status.

Transmittal forms are employed to forward drawings and specifications and require that signed receipts be returned from the addressee.

Changes made to approved design documents by Project Engineering or proposed by Field Engineering are reviewed and approved by Project Engineering in accordance with established procedures which provide -

that . changes are reviewed in the same manner as the original issue.

Supplier-submitted documents, such as drawings, specifications, proce-dures, manuals, and other data, are controlled through the use of control logs which provide identification' and status of supplier docu-ments . Tra'nsmittal forms are used to return and show approval status

• Becntel Procurement Supplier Quality Representatives receive copies of the transmittal notices listing the documents and their apprpval

~

status but normally do not receive copies of the documents. These are available at the supplier's plant for the supplier Quality Representative.

(

i BQ-TOP-1 Rev. 3A 35 October 1980 1

r- SECTION 7 C _ ,_

(17.1.7)

CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES 7.1 SUPPLIER EVALUATION AND SELECTION -

Files of suppliers and subcontractors dre maintained by Procurement.

These files identify suppliers and subcontractors who have demonstrated their ability to provide quality material, equipment, or services, or who -

have been established as capable by survey. Suppliers' and subcon .

' tractors' quality history files contain information on scope of services and capability, and results of recent -hop surveys and audits. Peri-odic reports identifying data contained in quality history files are issued by Procurement Supplier Quality to interested groups within the divisions. - -  :.

The Materials and ~ Quality Services Department reviews welding and nondestructive examination procedures for work involving compliance with the ASME Boiler and Pressure Vessel Code and for fabrication of metal structures and protective coating procedures. Materials and Quality Services reviews and evaluates these documents and provid.

Procurement with information for summary listings of the approv; .

vendor information on file. This information is available to projects for assistance in identification and evaluation of qualified sources.

(V Procurement Supplier Quality Department procedures include provisions for source surveys which may be used to supplement data in a supplf-er's quality history file. Requests for source survey are initiated by Purchasing or Engineering in cases where inadequate historical data is available to ' evaluate the supplier's capability to produce the commodity.

Prior to award *, the following technical and quality requirements must be met:

1) Determination by Engineering that the source is responsive to the technical requirements of the specification i 2) Determination by Engineering and Quality Assurance that the supplier or subcontractor quality program is capable of meeting the specified requirements. This may be based on evaluations by Procurement Supplier Quality for manufac-turing* suppliers or Construction QC for jobsite contractor or subcontractor.

• In some instances it may be necessary to place a contract without fully satisfying these criteria. For these cases, the criteria shall be met prior to start of related work activities. .

k BQ-TOP-1 Rev. 3A 37 October 1980

O 1

i

' ~ For' Q-List items, Bechtel Procurement Supplier Quality Representatives

( perform their surveillance inspection in accordance with inspection plans and instructions. These plans are prepared by Procurement Supplier Quality based 'on instructions 'in the Procurement Supplier Quality Department Manual and may be modified by Project Engineering. They provide for identification of witness and hold points, identification of the examinations and tests which are selected to be witnessed by the Bechtel Su'pplier Quality Representative, and documentary evidence of completion of each witness and hold point operation, test, or exami-nation. A supplier may not proceed with the work beyond a hold point without written agreement of waiver of hold points from Procurement

. Supplier Quality based on agreement from Project Engineering and the PQAE.

It is the responsibility of the Supplier Quality Representative to verify, to the extent required by his inspection plan, that the supplier has met the quality requirements contained in the procurement This documents before responsibility the material or equipment is released for shipment.

of the Supplier Quality Representatives is met through surveillance inspection which includes observations and checks at random of selected intervals (or points) of materials of construction, in-process fabrica-tion, heat treatment, welding, examination, testing, dimensions, prepa-quality verification.

ration for shipment, marking, tagging, and Bechtel Supplier Quality Representatives do not perform nondestructive examinations or tests on material and equipment at suppliers' plants.

Such examinations and tests are performed by the supplier and selec-tively witnessed or otherwise monitored by the Supplier Quality Repre-

- sentative.

Typical surveillance inspection plans have sections that describe the scope and define application, establish responsibilities, describe pre-planning activities to be performed prior to making initial contacts with a supplier, describe the activities to be performed during the initial, progressive , and final inspection visits, and describe reporting re-quirements.

Procurement inspection may be performed by resident or area Supplier Quality Representatives assigned to several suppliers. Reports docu-and discrepancies menting inspections performed, tests witnessed, observed are prepared by the Supplier Quality Representative and distributed to appropriate Engineering, Construction, Procurement, and Quality Assurance personnel. Gechtel Supplier Quality Representatives are responsible for assuring that their inspections of material, equip-ment, and specified documentation conform to the requirements of the inspection ' plan and/or instructions and for releasing inspected items for shipment. Bechtel Supplier Quality Representatives have the authority to refuse release of nonconforming material.

k BO-TOP-1 Rev. 3A 39 October 1980

~ '" * *""" """ " '" ' '"' * ' "' "* ' ' " " ' " " * * * " ' ' ' " " * " ' ' '

Cf required to be available at the construction site prior to installation, or use as a conforming item, includes as follows:

1) For Bechtel procured

• and inspected items not covered by l

ASME Boiler and Pressure Vessel' Code requirements, a l

certificate of conformance** (signed by an authorized l

representative of the supplier identifying the specific technical requirements met by the item by referencing the appropriate Bechtel specification and other governing codes and standards) and acknowledgement that the Bechtel Procurement Supplier Quality Representative has reviewed the required documentation and has released the item.

This may be obtained by having the certificate signed by the Bechtel Supplier Quality Representative to verify that he has reviewed - applicable supplier documentation sup-porting the certificate and released the items, or by receipt of a separate teletype or report from the Supplier Quality Representative indicating that his inspection is complete and the item has been released. Receipt of the certificate of conformance and the Bechtel Procurement .

Supplier Quality Representative release constitutes docu-mentary evidence that materials and equipment conform to procurement requirements and may be installed. If the balance of the documentation package required by the procurement documents is received prior to or with the shipment, the certificate of conformance may be waived.

t

2) For Bechtel procured and inspected items covered by ASME Boiler and Pressure Vessel Code requirements, the same requirements prevail as above, plus the appropriate Code Data Report.

3) For Bechtel procured and noninspected items, all quality verification documentation required to be submitted with

- the procurement documents must be reviewed and verified (as a part of receiving inspection) at the construction site by Quality Control personnel, such as Construction Quality Control or Procurement Supplier Quality personnel.

4) For nuclear steam supply system supplier furnished items, appropriate certification from the NSSS supplier in accor-dance with his quality program

• Also applies to cases of Bechtel client (applicant) procured items for which Bechtel is acting as agent for the client.

• • The certificate of conformance conforms to ANSI N45.2.13.

( BQ-TOP-1 Rev. 3A 41 October 198C

k- SECTION 8

- (17.1.8)

IDENTIFICATION AND CONTROL OF MATERIALS,.

PARTS, AND COMPONENTS Identification requirements 'are determined during the generation of specifications and design drawings. Procurement documents provide the requirements for identification of purchased items.

Parts, components, subassemblies and equipment, and partially fabri-cated items may be identified by stenciled or etched markings, strip marking, imprinted tape, color coding, and tags. Large quantities of small items, unless specifically required by code or standard, may be identified as to heat, batch, lot, or specification by applying markings to bags, bins, tanks, or other suitable containers. Identification of installed or assembled items requiring traceability may be transfarred to inspection records or as-built documents if desired and is req.2 ired if markings are hidden or subject to obliteration during fabrication or installation.

Organizations receiving materials, parts, or components verify that these are properly identified and are accompanied by appropriate docu-mentation. Provisions are made for handling and storing items to retain

/ identification and to prevent intermixing.

BQ-TOP-1 Rev. 3A 43 October 1980

e O SECTION 9 (17.1.9)

CONTROL OF SPECIAL PROCESSES The requiri.ments of the ASME Boiler and Pressure Vessel Code are invoked, as applicable, in the Bechtel program. Special processes requiring procedure and/or personnel qualification beyond those re-quired by the code are identified in technical specifications by refer-

' ence to appropriate industry codes and standards, where available, or by specific identification in the technical specification. Supplier and subcontractor special process qualification data are subject to review by Bechtel.

Special processes performed by Bechtel Construction, including welding, nondestructive examination, protective coating, cleaning and flushing,

are performed in accordance with the requirements of applicable codes i and standards. The requirements for welding and nondestructive examination comply with applicable portions of the ASME Boiler and

~

Pressure Vessel code, American Welding Society Standards, and the Society of Nondestructive Testing (SNT-TC-1A and supplements), as applicable. Cleaning and flushing procedures and personnel qualifica-tions conform to the requirements of Regulatory Guide 1.37 (3/16/73).

f

- Other unique special processes or work operations identified by the .

!. ' nuclear steam system supplier or Project Engineering are properly qualified and performed by trained personnel in accordance with spec-ified technical requirements.

Current qualification records of procedures, equipment, and personnel are maintained at the jobsite. Active files are maintained in the home office, and copies are provided to each affected project of qualification records covering special processes and procedures. Projects are re-quired to maintain up-to-date lists of personnel qualifications and/or applicable equipment qualifications for special processes. Controls are provided to assure that personnel qualification records are regularly reviewed, and the appropriate requirements for requalification are implemented. Implementation of these controls is verified by Construc-tion Quality Control personnel and audited by Quality Assurance with the assistance of Materials and Quality Services.

~ - .

BQ-TOP-1 Rev. 3A a 44 October 1980 -

s.

~

r- SECTION 10

( (17.1.10) i INSPECTION As described in Section 7, suppliers' and subcontractors' programs are subject to surveillance inspection by Bechtel Procurement Supplier Quality Itepresentatives and Construction Quality Control Engineers as applicable. ... .

The responsibilities for inspection of Bechtel construction work are identified in Sections 1 and 2. Quality verification inspectionpwitness of testing activities, and evaluation of test results are performed by Construction Quality personnel who are independent of field- engineering and craft supervision. Quality Control Engineers are assigned by and receive administrative and technical direction from the Chief Construc-tion Quality Control Engineer in the division or area office. The over-all inspection program is monitored by resident construction site Quality Assurance personnel and audited by Division Quality Assurance.

Inspection, witness of testing activities, and evaluation of test results are performed in accordance with procedures contained in the Construc-tion Quality Control Manual supplemented by construction quality control instructions, or work operations and planning documents. Inspection planning includes receiving inspection, construction and installation inspection, and testing.

t N Quality control instruction and inspection records are prepared to cover onsite receiving, maintenance, installation, testing, and subcontracted work activities performed during the construction phase. These are the controlling documents used by Quality Control Engineers for perfor-mance of onsite quality verification activities. These identify what inspections are required, the inspection acceptance / rejection criteria, how and by whom the inspections are to be performed, and the se-quence. They are available prior to inspection.

Inspection and acceptance criteria are derived from engineering design documents, supplier information, and construction procedures. Stan-dard inspection instructions to be used on the project are approved by the Chief Construction Quality Control Engineer.

In addition, all work covered by the ASME Boiler and Pressure Vessel Code,Section III, is also subject to independent inspection by autho-rized Code. Inspectors in accordance with the Code rules.

Inspection procedures or instructions and records provide the following information:

1) Reference to applicable documents such as drawings, specifications, and procedures

(.~

BQ-TOP-1 Rev. 3A 45 October 1980

.f SECTION 11 (17.1.11)

TEST CONTROL Tests required to qualify, demonstrate, or assure quality of procured items or completed construction are defined in engineering drawings, specifications, or test procedures.

Construction tests are an extension of construction inspection. Con-

. struction testing is conducted to demonstrate that the equipment instal-lation is complete and that the electrical systems are properly wired.

Test plans or procedures, and test reports and records are used to demonstrate that completed tests have met test objectives.

System cleaning, flushing, instrument and control settings, and perfor-mance demonstration are part of the preoperational and startup test program. Preoperational and startup testing is normally under the control of the client. Bechtel startup engineers may provide assistance to the client in the preparation of startup procedures and supervision of startup tests. Bechtel startup engineers are independent of the construction and the client's operating organization and are qualified to collect, analyze , and evaluate test results in accordance with the requirements of Regulatory Guide 1.28 (6/7/72).

(

L k..

BQ-TOP-1 Rev. 3A 47 October 1980 -

0 (b. SECTION 12 (17.1.12)

CONTROL OF MEASURING AND TEST EQUIPMENT .

The Bechtel Construction Quality Centrol Program provides for calibra-tion, maintenance, and control of measuring and test equipment used by Bechtel in construction. Procedures provide for unique identification of each instrument or equipment item requiring calibration or checking, establishment of calibration schedules based upon the elapsed time or usage cycles, and provisions for identification of calibration status by tags, labels, or markings applied to the item. Records are maintained to show the status of items under the calibration program.

Tnspection procedures require that the inspector check calibration labels or tags as well as apparent proper functioning of the instrument prior to use to assure that the calibration period has not lapsed and the equipment is in proper working order.

The identification of measuring and test equipment used in performing tests is entered in the test records when the validity of the test result is critically dependent on the accuracy of the test equipment.

Calibration standards are traceable to nationally recognized standards, or the basis for calibration is properly documented. Calibration stan-i dards have an uncertainty (error) requirement of no more than 1/4 of b the tolerance of the intended use of the equipment being calibrated. A greater uncertainty (error) is acceptable when limited by the state of the art.

Provisions for contractor's control of measuring and test equipment are included in procurement documents by specifying ANSI N45.2-1971, Section 13. The Bechtel surveillance inspection program of contractor's activities includes review of this element in the contractor's program.

Contractors are required to apply practices similar to those described for the Bechtel program.

Performance and adequacy of supplier, contractor, subcontractor, and l Bechtel construction programs for control of measuring and test equip-ment are verified by surveys or audits performed by Bechtel Procure-ment Supplier Quality, Quality Control, or Quality Assurance personnel, as applicable.

BQ-TOP-1 Rev. 3A 48 October 1980 i

m

(r"n

• SECTION 13 (17.1.13)

HANDLING, STORAGE, AND SHIPPING The requirements for packaging, marking, and shipping are specified in procurement documents for Q-List items by reference to ANSI N45.2.2-1972 or by provision of specific technical requirements which meet the

- intent of this standard.

Procedures for equipment and system cleaning and flushing and clean-ness control conform to the appropriate requirements of Regulatory Guide 1.37 (3/16/73).

For supplier, contractor, or subcontractor work, special handling, stor-age, shipping, and preservation requirements are identified in technical specifications which either provide, or require the vendor or subcon-tractor to provide, the required procedures and instructions. The packaging, handling, and shipping practices of the suppliers are sub-ject to review by Bechtel Procurement Supplier Quality Representatives at the source prior to shipment for compliance with requirements defined in procurement documents.

At the construction site, materials and equipment are received, inspec-ted, stored, and maintained in accordance with standard field proce-dures supplemented by special procedures and requirements issued by i ,

project engineering or furnished by suppliers. Materials and equipment are physically inspected upon arrival at the jobsite and moved into prescribed storage areas or to the installation site if adequate protection is available. Immediate movement to the installation site is pemitted if it would eliminate multiple handling and is compatible with the construction schedule. Special environmental conditions, such as inert gas, specific moisture content levels, and temperature levels prescribed in procedures or specifications, are controlled at the site.

Procedures are provided, as appropriate, for handling special items and for the care and maintenance of material handling equipment. Other-wise , standard material handling methods are used to ensure care and protection against physical damage. Special handling instructions and procedures for major or special items are included in procedures reviewed by Project Engineering or Bechtel construction specialists.

Personnel responsible for handling these major or special items will be qualified to the extent required by these special handling instructions and procedures. Preparation for and performance of rigging operations involving major equipment, such as reactor vessels, steam generators, and pressurizers, are witnessed by Bechtel construction rigging spe-cialists.

k BQ-TOP-1 Rev. 3A 49 October 1980 -

h

SECTION 14 (17.1.4)

INSPECTION, TEST, AND OPERATING STATUS Construction procedures and inspection instructions provide for identifi-cation of inspection status of receipt inspection or work-in-process by using work sequence plans, inspection records, physical locations, tags, markings, or other devices compatible with the item, system, or operation being inspected or tested. Progress of work is entered in

.. records, and status identification is changed to reflect current condi-tions. At the completion of construction, a tagging system is employed to visually indicate the operating status of equipment and systems which are in test or rework. Records of test results are prepared and main-tained.

Work is peformed according to prescribed sequences required to assure quality, and in accordance with the provisions contained in this report.

Inspection points may be deferred or waived without generation of a nonccnformance report only when specifically provided for in the gov-erning procedure. Inspection points can be deferred only when the element can be inspected at a later time in the sequence and a later hold point exists. In these cases, the inspection records or checklists are not completed until the inspection point is picked up at a later date. If physical control of the item is required to prevent its in-advertent use or installation beyond the point where the inspection can be performed, the item is tagged or otherwise identified and condi-i tionally released with a limit placed on future work operations.

Procedures or instructions include identification of the individuals or groups responsible for application and removal of status indicators.

Field Engineering and supervisory personnel are authorized to apply and remove identifying tags, markings , and labels on equipment in accordance with approved field procedures. Quality Control personnel are the only ones authorized to direct application and removal of inspec-tion status indicators. Bechtel, in cooperation with the plant owners' operating personnel, establishes a tagging procedure which delineates those authorized for applying and removing tags during preoperational testing phases. ,

k BQ-TOP-I Rev. 3A 50 October 1980

m

.g SECTION 15 Q (17.1.15)

NONCONFORMING ITEMS Suppliers and subcontractors are required to advise Bechtel of all nonconformance from procurement documents or Bechtel-approved de-signs for which the recommended disposition is " repair" or "use as is.".

Bechtel reserves the right. to accept or reject the disposition. Bechtel _'

requires suppliers to submit proposed repair procedures for major nonconformances for approval by project engineering prior to their use.

. Reports of nonconformances identified by Bechtel personnel are pre-pared by the supplier, Bechtel Procurement Supplier Quality Represen _.

tatives, or Project Engineering to assure complete and adequate docu _

mentation. Copies of completed nonconfortnance reports are forwarded ~~

to the jobsite prior to, or with, the release of the item; or identifi-cation of outstanding nonconformances are included in .the Supplier -

Quality Representative's release. __ _

Nonconformances discovered during Bechtel rt.ceiving inspection or

- construction activities are controlled and documented in accordance with .

a standard Quality Control procedure. The procedure provides for identification and documentation of the nonconformance and control of the item, identifia.s the authority for approval of proposed resolution, and provides for documentation of reinspection results. Important elements of the procedure include requirements to:

f

/ 1) Tag and segregate whenever practical

2) Determine interim dispostion by Project Field Engineering

3) Have Project Engineering approve " repair" or "use as is" dispositions

4) Advise Project Engineering after implementation for stan-dard preapproved repair procedures .

5) Provide conditional release of nonconforming items upon approval of Quality Control and Quality Assurance Quality

6) Review completed nonconformance reports by Repeti-Assurance to establish need for corrective action.

tive nonconformances are reported to higher levels of management for review and resolution on a generic basis.

t l

The authority for disposition of nonconforming items follows the rules for approval of design changes described in Section 3 of this report.

Field Engineering personnel are authorized to provide for disposition involving " reject " " rework" (if Bechtel performed the original work),

or " repair" (for those cases where standard preapproved repair pro-cedures have been provided by Project Engineering). Other " repair" l

and "use as is" dispositions require Project Engineering approval prior k

BQ-TOP-1 l Rev. 3A t

! 51 i October 1980

O SECTION 16 (17.1.16)

CORRECTIVE ACTION ,

The carrective action program provides procedures for prompt identifi-cation and correction of conditions adverse to qualitv which may require corrective action. Corrective action, when initiated, shall be docu-mented. A decision that corrective action is not required need not be documented.

Within the Bechtel program, the identification of situations which may need corrective action is accomplished through review of nonconformance reports, supplier surveillance activities, quality assurance su'rveillance and monitoring programs, and quality assurance audits. Corrective action is controlled and documented by means of corrective action reports and the associated procedure. These provide for (a) the identification and reporting by any member of the project team of situa-tions or occurrences which warrant corrective action, (b) determination of the cause and identification of the corrective action to be taken by the responsible organization, (c) reporting the cause and corrective action to proper level of management, (d) final verification by the Project Quality Assurance Engineer that corrective action has been taken, and (e) review by Quality Assurance management for implication or effect on other work.

Corrective action involving design documents, investigation of cause, and actions taken to preclude recurrence is applied to errors detected after the design document is issued for use. Such errors, detected after the design document is issued for use, are formally documented and are reviewed for corrective action. These are documented by design change notices, revision block entries, or reports, such as supplier discrepancy reports, field nonconformance reports, startup reports, or feedback from utilities during operation of the plant. ~ Significant

. problems are also reviewed for programmatic corrective action by Quality Assurance.

This program also provides for the evaluation of conditions reported which may require reporting to the NRC by Bechtel clients in accor-dance with the requirements of 10 CFR 50.55(e).

BQ-TOP-1 Rev. 3A 53 October 1980

f. - .

h# SECTION 17 -

(17.1.17)

QUALITY ASSURANCE RECORDS The require'ments of Regulatory Guide 1.28 (6/7/72) are applied to Bechtel activities. Records produced as a result of the quality program

._ are prepared and maintained by project groups, suppliers, and subcon-tractors as their work is being performed.

- Project engineering records are retained by the project engineering team as work is performed. It is normal practice to microfilm documents at regular, intervals, unless duplicate copies are available at an alter-nate location. Provisions for collection of completed records in the design office, or at the jobsite, and the criteria for storage and reten-tion recommended in ANSI N45.2.9-1974 are applied to quality records. I Documentation of the design review process is prepared and maintained in accordance with Section 3 of this report. Design changes may be issued on an interim basis by means of change notices. However, these are ultimately incorporated in revisions to the governing documents, unless the change is a limited waiver (e.g., "use as is" on a noncon-formance report) which does not generally apply to the design docu-ment. Copies of released drawings, specifications, technical reports, and similar documents are placed in Engineering office files, Construc-7 tion office files , and submitted to the client. At the completion of q'

engineering , final copies of these records are provided to the client.

Bechtel Engineering retains control of design calculations and analyses.

These are available for review by client and appropriate regulatory bodies.

Supplier records which identify as-built status and verify quality of the work are requested from the supplier and placed in construction site quality record files. In some instances, with the agreement of 'Bechtel and the client, suppliers are permitted to retain custody of certain records if retention procedures and storage facilities are adequate and access is provided to the Bechtel client.

Completed quality verification records, including nonconformance reports for " repair" and "use as is" dispositions, are placed in quality record files. The client and appropriate regulatory groups are provided access to these files while they remain in Bechtel custody. At the completion of the Bechtel assignment, these files are turned over to the client.

The requirements and guidelines for receipt, control, and retention of permanent quality assurance records contained in Regulatory Guide 1.88 (Rev. 2, October 1976), in accordance with provisions of Appendix A of this report and ASME Boiler and Pressure Vessel Code,Section III, are employed for the control of construction site quality record files.

Identification of the reco: and method of turnover to the client are

(' established for each proje client.

arough agreement between Bechtel and the BQ-TOP-1 Rev. 3A 54 October 1980 -

_ e ,

b '

SECTION 18 (17.1.18)

AUDITS A comprehensive program of audits is conducted by Bechtel ' covering the various, activities of the Quality Assurance Program.

The Bechtel audit program includes both monitoring of daily activities conducted by . Quality Assurance personnel at the construction site or home' office as well as formal pericc c team audits - performed by per-

. sonnel independent of project activities. The combination of project and division Quality Assurance management audits of Bechtel activities satisfies the requirement for annual audits of the applicable elements of the Quality Assurance program. Audit activities include the following:

1) Audits of Project Engineering activities by Quality Assur-ance personnel. These audits are planned, scheduled, and documented. Results are reported to the Project Engineer,

. Project Manager, and the immediate functional supervisor of the office Quality Assurance Engineer.

2) Audits of field Construction activities (including con-tractors for Bechtel Construction Management jobs) by Quality Assurance personnel. These audits are planned, scheduled, and documented. Results are reported to the Field Construction Manager, Project Manager, and the

' (' immediate functional supervisor of the Quality Assurance Engineers.

l 3) Audits of Supplier activities by the Procurement Supplier Quality Department. [

4) Audits of Project Engineering, Procurement, Construction, and Quality Control activities by Quality Assurance audit teams under' the direction of Division Quality Assurance Managers, assisted by Materials and Quality Service spe-cialists and others as required. These audits are con-ducted at least annually and results are reported to the management of the function audited, cognizant project management, and division management. A summary of the results of these audits is reported by the Division QA Manager to the Vice President, Planning and Quality Assurance.

5) Audits of division engineering technical staff and services activities performed on an annual basis under the direction of the Division Quality Assurance Managers. These audits cover those groups doing design and/or review oQtside direct control of the Project Engineer. Results of these audits are reported to the manager or supervisor of the

(

l BQ-TOP-1 Rev. 3A 55 October 1980

r (> ,

p ..

TABI.C I '

a .

BCCllTCl, QUALITY PROGRAM DOCtJMENTS .

- Originating Review for QA Policy Authorizing , ,

Document Au thority_ and Program iteqtgrements Approval , , , Contents

' Division Qualily Division QA QA-TPO Division Manager Division policy supplementing policies (Division Manager and implementing TPO Quality QA Manual) .

Policy

'Rechtel Quality Manager-M&QS Q A-T PO" President and Policies and procedures for l Assurance Manual- appropriate overall Hechtel program ASMC Nuclear Authorized Code applicable to ASMC Components (BQAM- Inspection Agency work ASMC 111)

QA-TPO'* Manager Procure- Procurement Supplier l v;

• Procurement Supplier Manager Pro- ment Supplier Quality procedures Quality Manual curement Supplier Quality Quality ': . , -

' Construction Quality Division Chief Division QA Manager Manager Division Definition of responsibilities Control Manual Constr. QC Construction and procedures for Construc-Engineer ',

~

',' " . tion Quality Control activities Division QA Division QA NA Division QA Manager Procedures for conducting l

I'rocedures Manager Division QA activities i

~ '#

' Available on request to appropriate regulatory agencies.

" Includes review by Division QA Managers. ,' ,

4 4 Note: Revisions to these documents require the same review and approval as the original. ,', .

HQ-TOP- 1 llev. 3A October 19(10 1

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APPENDIX A BECHTEL POSITION ON QA NRC REGULATORY GUIDES AND ANSI STANDARDS Page ,

Title A-2 Regulatory Guide 1.30 (ANSI N45.2.4-1972 IEEE 336, Installa-tion, Inspection, and Testing Requirements for Instrumentatfori-and Electric Equipment During the Construction of Nuclear.,

Power Generating Stations)

A-3 Regulatory Guide 1.37 (ANSI N45.2.1-1973, Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants)

A-4 Regulatory Guide 1.38 (ANSI N45.2.2-1972, Packaging, Ship-ping, Receiving, Storage, and Handling of Items for Nuclear Power Plants (During the Construction Phase]) l A-6 Regulatory Guide 1.39 ( ANSI N45.2.3-1973, Housekeeping During the Construction Phase of Nuclear Power Plants)

A-7 Regulatory Guide 1.58 (ANSI N45.2.6-1973, Qualifications of Nuclear Power Plant Inspection, Examination, and Testing

, Personnel)

A-14 Regulatory Guide 1.64, Revision 2, June 1976 (ANSI l N45.2.11-1974, Quality Assurance Requirements for the Design of Nuclear Power Plants)

A-16 Regulatory Guide 1.88, Revision 2, October 1976 (ANSI l N4 5. 2.9-1974, Requirements for Collection, Storage, and Main-tenance of Quality Assurance Records for Nuclear Power

. Plants)

A-17 Regulatory Guide 1.94 (ANSI N45.2.5-1974, Quality Assurance Requirements for Installation , Inspection , and Testing of Structural Concrete and Structural Steel During the Construc-tion Phase of Nuclear Power Plants)

A-18 Regulatory Guide 1.116, June 1976 ( ANSI N45.2.8-1975, I supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems fcr the Construction Phase of Nuclear Power Plants)

~

A-20 Regulatory Guide 1.123, October 1976 ( ANSI N45.2.13-1976, Qualit9 Assurance' Requirements for Control of Procurement of Items and Services for Nuclear Power Plants)

- A-22 ANSI N 45. 2.12-1974, Draft 3, Rev. 4, February 22, 1974, I

(' Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants BQ-TOP-I Rev. 3A A-1 October 1980

APPENDIX A b

Regulatory Guide 1.37 (ANSI N45.2.1-1973, Cleaning of Fluid Systems and Associated -Components During Construction Phase of Nuclear Power Plants) ~ _

The requirements of the referenced standard as modified in the.regula-tory position -will be applied to cleaning activities specified or applied by Bechtel to' safety-related items as modified and interpreted below.

~

1)^ Se'ction 2.1, Planning. The required planning is fre _

quently performed on a generic basis for application to . .

many installations on one or more projects. This results

• ~

in standard procedures or plans for installation and inspec-tion and testing which meet the requirements of the stan-dard. Individual plans 'for each item or system are not normally prepared unless the work operations are unique.

However, standard procedures or plans will be reviewed .

for applicability in each case. Installation plans or proce-dures are also limited in scope to those actions or activi-ties which are essential to maintain or achieve required quality. This is consistent with Section II, Paragraphs 2 and 3 of ANSI N45.2-1971 which provides for examination, measurement, or testing to assure quality or indirect control by monitoring of processing methods. However, final cleaning or flushing activities will be performed in accordance with procedures specific to the system.

f 2) Section 4, Preinstallation Cleanliness. This section states, s

" Items should not be delivered to the point of installation site sooner than necessary unless the installed location is considered a better storage area." As an alternate to this requirement, items may be delivered to the installation site sooner than absolutely necessary when determined to be advantageous for other considerations, for example, re-duced handling or easier access, thereby reducing suscep-tibility to handling damage. In all such cases, equipment stored in place will be protected in accordance with Sec-tion 5 of ANSI N45.2.1.

3) Section 3.1.2, Bechtel interprets the lighting level of 100 footcandles to be guidance. It is Bechtel's normal practice that the lighting level for determining " metal clean" of accessible surfaces of piping and components is determined by the inspector. Typically he uses a standard two-cell flashlight supplemented by other lighting as he deems necessary.

'I t\

RQ-TOP-1 Rev. 3A

• A-3 October 1%0 -

APPENDIX A b 6) Appendix, A 3.4.2, Inert Gas Blankets. There may be

cases involving large or complex shapes for which an inert or dry air purge flow is provided rather than a static gas blanket in order to provide adequate protection due to I difficulty of providing a leakproof barrier. In these cases a positive pressure purge flew may be utilized as an alternative to the leakproof barrier. .

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4 s

BQ-TOP-1 Rev. 3A A3 October 1980

O APPENDfX A h ~

Regulatory Guide 1.58, dated August 1973 ( ANSI N45.2.6-1973, Qualifi-r cation of Nuclear Power Plant Inspection , Examination and Testing Personnel)

The requirements of the referenced stand'ard, as modified -and . inter-

- preted in the regulatory position will be applied to the Bechtel Quality Program during the construction' phase as described in Section 2.5 of 1 this report, subject to the following clarifications:

v

.....e

1) Substitute ~ new Sections 1.1 and 1.2 and modify first paragraph only of 1.3.

Section 1.1, Scope .

4 This standard delineates the requiremehts for'~ qualification of personnel who perform inspection,~ examination, and testing to verify conformance to specified requirements of nuclear facility items (structures, systems, and components of nuclear power plants, fuel reprocessing plants, pluto-nium processing plants, and plutonium fabrication plants) whose sa:isfactory performance is required to prevent postulated accidents which could cause undue risk to the health and safety of the public; or to mitigate the conse-quences of such accidents if they were to occur. The

(' requirements may also be extended to other items of nuclear facilities when specified in contract documents .

Section 1.2, Apolicability l The requirements of this standard apply to personnel who perform inspections, examinations, and tests during fabri-cation prior to and during receipt of items at the construc-tion site, during construction, during preoperational and

- startup testing, and during operational phases of nuclear i

facilities. The requirements of this standard do not apply to personnel who perform inspections for government or municipal autnorities, or who perform as authorized inspec-tors in accordance with the ASME Boiler and Pressure Vessel Code.

The requirements of this standard are not intended to apply to personnel who only perform inspection, exami-nation, or testing in accordance with employer practices which are in compliance with " Recommended Practice No.

S." T-TC-1 A,' since these personnel are certified in accor- I dance kith the requirements of SNT-TC-1A and its appli-cable supplements. The requirements of this standard are optional, at the discretion of the emplcyer, for application to personnel who perform calibration, or to craftsmen who l perform installation checkouts as part of their basic instal-l [

lation responsibility to ready the installation for preopera-l

\ tional testing.

BQ-TOP-1 -

Rev. 3A A-7 October 1980

~

APPENDIX A c

k 4) The requirements of this standard shall apply only to personnel who perform inspection, examination, and testing , and accordingly, Sections 3 and 3.1 shall be revised to read:

3 Qualifications

~.

3.1 General The rec ulrements contained within this section

. define the minimum capabilities that qualify per-sonnel to perform inspections, examinations, and tests which are within the scope of this standard.

There are three levels of qualification. The re-quirements for each level are not limiting with regard to organizational position or professional

- status, but rather, are limiting with regard to functional activities which are within the scope of this standard.

Following is the recommended personnel education and experience for each level. These education and experience recommendations should (be treated to recognize that other factors may provide reason-able) assurance that a person can competently

- perform a particular task. Other factors which may demonstrate capability in a given job are previous performance or satisfactory completion of capability testing.

5) The education and experience requirements shall make provision for personnel who have not graduated from high school, or who have earned an Associate degree. Accord-ingly, paragraphs 3.1.1, 3.1.2, and 3.1.3 shall be revised to read:

3.1.1 Level I ti) Two years of related experience in equivalent inspection, examination, or testing activities, or

~

(2) High school graduation and six months of related experience in equivalent inspection ,

examination, or testing activities, or

- (3) Completion of college level work leading to an Associate degree in a related discipline plus three months of related experience in equiva-lent inspection, examination, or testing activ-fties

(

BQ-TOP-1 Rev. 3A A9 October 1980

APPENDIX A -

(4) Four-year college graduation plus five years f>-

- of related experience in equivalent inspection,

. examination, or testing activities. At least two years of this experience should be asso-ciated with nuclear facilities; or, in lieu of two years' experience, the individual shall have training sufficient to be acquainted thoroughly with the quality assurance aspects

- of a nuclear facility. ~ -

~

~

~

6) ~ Section ~3.2.1, Physical (revise. to read)~: -

Bechtel shall identify any special physical characteristics needed in the performance of each activity. Personnel requiring these characterisitics shall have them verified by examination at intervals. not to exceed one year. . _.,

7) Section'3.2.2, Technical (revise to read):

, _~

~

a. L'evel I Personnel dapabilitlei ~

A Level I person shall be capable of performing the inspections, examinations, and tests that are required to be performed in accordance with documented pro-cedures and/or industry practices. The individual e shall be familiar with the tools and equipment to be

'( - employed and shall have demonstrated proficiency in their use. The individual shall also be capable of determining that the calibration status of measuring and test equipment is current, that the measuring and test equipment is in proper condition for use, and that the inspection , examination, and test procedures are approved.

l b. Level II Personnel Capabilities ,

I

' A Level II person shall have all the capabilities of a Level I person. Additionally, a Level II person shall have demonstrated capabilities in planning inspections, examinations, and tests; in setting up tests, including preparation and setup of related equipment, as appro-priate; in supervising or maintaining surveillance over the inspections, examinations , and tests; in super-vising and certifying lower level personnel; in re-porting inspection, examination, and testing results; and in evaluating the validity and acceptability of inspection, examination, and test results.

\

BQ-TOP-1 Rev. 3A

. A-11 October 1980 .

l APPENDIX A m

TABLE 1 _ ,

MINIMUM LEVELS OF CAPABILITY FOR PROJECT FUNCTIONS Project Function Level ._

L-I L-II L-III . _ .

XJ X '; . X Recording inspection, examination, and testing data _

- - . -- _ x X~ X c d- - X Implementing inspection, ixamination, and testing procedures .

y Planning inspections, evaluations, and tests; X' X

' ~ ~ ~

setting up tests, including preparation and --

setup of related equipment X X Evaluating the validity and acceptability of inspection, examination, and testing results X X Reporting inspection, examination, and testing

'. results X X Supervising equivalent or lower level personnel X X Qualifying lower level personnel X

Evaluating the adequacy of specific -

programs used to train and test inspection, examination, and testing personnel X

Reviewing and approving inspection, examination, and test procedures ,

X Evaluating the adequacy of activities to accomplish inspection, examination, and test objectives 4

(

.~

BQ-TOP-1 Rev. 3A A-13 October 1980

APPENDIX A

(. 4) Section 10, Records. In-process documentation, relating to checking and coordination of drrvings (for example, check and coordination ;3rints) or copies of marked-up specifications used to so;.icit comments shall be retained until the drawing or s'aecification is approved and issued for use outside of Bec;1tel Engineering. Such in-process documents will be . available for review / audit until the document is approved, .but may .be discarded .once the document has been approved. In the first sentence of the

'second-- paragraph. tne phrase ." final design . documents"

~'shall mean those documents 'which are the~ latest revision

~

that has been issued for use. .

5) Regulatory Position, Section C-2: If, in an exceptional circumstance, theioriginators' immediate supervisor is the only technically qualified individual available, the design verification or checking will be conducted by the super-visor with the following provisions: -

a. The other requirements' of Regulatory Guide 1.64 will be met.

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

c. Quality Assurance audits will include review of the

.i frequency and effectiveness of the use of the immediate supervisor to assure that this provision is used only in exceptional circumstances.

(s l

BQ-TOP-1 Rev. 3A -

A-15 Ocicber 1980 l

APPENDZX A Quality Assurance Require-Regulatory Guide 1.94 (ANSI N45.2.5-1974, 1

( ments for Installation, Inspection, and Testing of Stru .

Plants) ,

The reguirements of the referenced standard will be applied to theof s Bechtel Quality Program for construction -

follows:

Any exceptions to ANSI N45.2.5 and/or Regulatory Guide 1.94 will be resolved with the NRC during licensing on an individ-ual project basis.

'(

l I

t li BQ-TOP-1 Rev. 3A October 1980

~ ~ ~ - --

A-17

- APPENDIX A (C'. 5) Section 4.6, Care of Items. Bechtel, acting as Con-

+ ^- structor or Construction Manager, is assumec to have

- authority and is the " responsible organization" for tem-pcrary usage of equipment or facilities unless specifically prohibited by contract or in writing from the client. ail other conditions and consid? rations for temporary use in

- this section will be applied.

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( BQ-TOP-1 Rev. 3A

, A-19 October 1980 .

I APPENDIX A

(' supplier has fulfilled procurement document requirements and whether or not a certification system is effective.

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BQ-TOP-1 llev. 3A A-21 October 1980

APPENDIX A The annual audit requirement shall not apply to standard off-the-shelf items and bulk commodities where required quality can adequately be determined by receipt inspection e or post-installation checkout or test.  %

3.4.3.6, (Verification). Delete this section.

- 6) .Section Section 4.5, Follow-up , By Auditing Organization, will provide adequate coverage of the verification process without resorting to an audit, audit reports, etc. Verifi-cation will be accomplished during the performance of follow-up action by the auditing organization.

7) Section 4.3.3,. Post Audit Conference. Delete the last sentence. The minutes of the post audit conference are recorded and distributed to the attendees and management.

It is not considered necessary to have the auditing organi-zation and the audited organization sign these minutes to signify understanding.

e l'

BQ-TOP-1 Rev. 3A

APPENDIX B DIVISION QUALITY POLICIES, SCOPE, AND RELATIONSHIP TO 10 CFR 50, APPENDIX B Page Title B-2 Nuclear Quality Assurance Manual San Francisco Power Division E-3 Quality Program Manual Los Angeles Power Division

- - B-4 Nuclear Quality Assurance Manual Gaithersburg Power Division t BQ-TOP-1 Rev. 3A B-1 October 1980

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