RC-16-0083, Virgil C. Summer, Unit 1 - Updated Final Safety Analysis Report, Chapter 17
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17.0 QUALITY ASSURANCE 00-01 NOTE 17.1 Section 17.1 is being retained for historical purposes only.
17.1 INTRODUCTION
South Carolina Electric & Gas Company (SCE&G) recognizes the need for a comprehensive, formalized, documented met hod of specifying and verifying that the Virgil C. Summer Nuclear Station design, procurement, construction, modification, maintenance, inservice inspection, and operation has been and will continue to be accomplished without undue risk to the health and sa fety of the public. Cognizant of its responsibilities as an applicant for an operating license, SCE&G has established and will execute an effective Quality Assurance (Q A) Program for Virgil C. Summer Nuclear Station which meets the requirements of Title 10 CFR Part 50, Appendix B. The QA Program provides the necessary systematic activity and adminis trative control to provide checks to assure activities which affect quality and safety-related functions during design, procurement, construction, modification, ma intenance, inservice inspection, and operation are performed in accordance with established requirements. The SC E&G QA Program is applied to those items identified as safety-related in Table 3.2-1.
SCE&G also recognizes that in addition to providing a high degree of confidence that structures, systems, and components; as designed, manufactured, constructed, maintained, and modified; reflect all safety-related requirements, the reliability and availability of the plant will be enhanced by the implementation of the Program. The philosophy used in the QA Program develop ment ensures that systems, components, and structures have optimum quality consistent with safety, reliability, and plant
availability considerations, as well as consideration fo r sound engineering.
17.1.1 QUALITY ASSURANCE DURING DESIGN, CONSTRUCTION, AND MAJOR MODIFICATION The responsibility for the overall nuclear project rests with the SCE&G Executive Vice President Operations. On an independent organizational chain from Production Engineering and Construction, the responsibilit y for administration of the overall QA Program is delegated to t he SCE&G Vice President and Group Executive, Nuclear Operations, who reports to the Executive Vice President Operations. He is assisted in executing this responsibility by the SC E&G Group Manager Nuclear Services, the Manager of QA, Gilbert Associates, Inc. (G ilbert), and other consultants, as needed, who have been or will be retained to impl ement the QA Program. Westinghouse provides a QA Program on the nuclear steam supply (NSSS) structures, systems, and components. Gilbert provides a balance of plant (BOP) QA Program on safety-related structures, systems, and com ponents not included in NSSS sc ope. SCE&G assisted by the Gilbert QA Division and others as agents, audits, thes e programs to assure the effectiveness of the portion of the program performed by G ilbert and Westinghouse. The following sections describe the QA responsibilities and authorities of each major organization during construction and potentially during major outages.
17.1-1 Reformatted Per Amendment 00-01 17.1.1.1 South Carolina Electric and Gas Company The Virgil C. Summer Nuclear Station QA organization chart (Figure 17.1-1) shows the lines of responsibility for design, procurement, construction, and QA for safety-related
activities of the Virgil C. Summer Nuclear Station.
The overall responsibility for this nuclear project rests with SC E&G Executive Vice President of Operations. The executive management responsibility for assurance of provision of an adequate QA Program has be en assigned to the SCE&G Vice President and Group Executive, Nuclear Operations, who is on an independent organization chain from production engineering and cons truction. Execution of this responsibility is by the SCE&G Group Manager Nuclear Services wi th implementation by the Manager of Quality Assurance.
The Gilbert QA Division and other consul tants, as needed, have been and are expected to be retained to assist SCE&G QA in auditing the QA Program on the NSSS and safety-related structures, systems, and co mponents. SCE&G QA and/or their agents audit these programs and perform surveillance to verify compliance with and effectiveness of the overall QA Program.
The SCE&G Vice President and Group Executiv e, Engineering and Construction directs the project construction wit h the assistance of the Gr oup Manager, Construction and Quality Control, the QC Manager (Construction), and the Nuclear Site Manager. Construction is under the overall supervision of the SCE&G Nuclear Site Manager, with quality control (QC) the re sponsibility of the SCE&G QC Manager. Both report independently to the Group Manager of Construction and Quality Control.
The SCE&G Vice President and Group Executiv e, Rates/Purchasing assisted by the General Manager, Purchasing, and the M anager of Production and Construction Purchasing is responsible for procurement of equipment, material, and services.
17.1.1.1.1 Quality Assur ance Program Organization QA Figures 17.1-1 and 17.1-2 show the lines of responsibility for t he QA Program. QA activities pertaining to the design, procurement, fabrication, handling, installation, and testing of safety-related structures, systems, and components are carried out in accordance with procedures that have been devel oped to conform to the 18 criteria as set forth in Appendix B of 10 CFR 50. These procedures are assembled in the SCE&G QA Procedures Manual, the Gilbert QA Manual, the SCE&G QC Manual, the SCE&G Nuclear Engineering Procedures Manual, t he SCE&G Purchasing Procedures Manual, the Westinghouse WRD Quality Assurance Plan, the Daniel Construction Company (Daniel) Construction Procedures Manual, th e Gilbert Project Management Manual and vendor and contractor procedures manuals.
17.1-2 Amendment 97-01 August 1997 The SCE&G QA Program involves personnel from various organizational groups within the company. The general responsibilitie s of these groups are as follows:
- 1. Quality Assurance Group The Group Manager, Nuclear Services provides administrative control and coordination of the role and mi ssion of the QA section. He has the responsibility to evaluate the performance of the QA Program to assure adequacy and allocation of sufficient resources to perform the role and mission. The Group Manager is the link to effective executive corrective action whenever identified. The Group Manager, Nuclear Services through the Vice President Nuclear Operations has the responsibility to identify needed senior m anagement action. T he Manager of QA reports to the Group Manager.
The Manager of QA is re sponsible for the direction and implementation of the to tal QA Program. These responsibilities include:
- a. Preparation and revision of the overall QA Program, assisted as needed by the Gilbert QA Division, Westi nghouse, each group or organization performing quality activities and/or other agents.
- b. Review and approval of the QA Program and associated documents generated by SCE&G and its agents, Gilbert, Westinghous e, Daniel, vendors, and contractors.
- c. Review and/or approve revisions to the QA program and associated documents.
- d. Schedule, perform, and/or direct perfo rmance of audits of SCE&G, its agents, Gilbert, Westinghouse, Daniel, vendors, and contractors; and the surveillance of Daniel, vendors, and contractors.
- e. Audit and approve solutions to safety-related interface problems which arise.
- f. Monitor the status of the QA Program to assure effective implementation.
- g. Identify that appropriate corrective action is taken to accomplish changes where activities do not comply with QA and QC plans or procedures.
- h. Stop work on safety-related stru ctures, systems, and/or components when designated codes, standards, design docum ents, or procedures are not being adhered to and cannot be immediately corrected.
- i. Ensure that the collection, distribution, audit, and filing of all project QA records are accomplished in a controlled manner.
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- j. Notify the Nuclear Regulatory Commi ssion of any significant breakdown in any portion of the QA Program.
- k. Provide for the indoctrination, training and certification of SCE&G QA personnel in the performance of activities affecting quality.
Site QA personnel under the direction of the SCE&G QA Director of Surveillance Systems are responsible for surveillance of site quality-related activities including such areas as receiving, handling, site fabrication, installation, construction and testing. When the scope of work activi ty during construction or major outage warrants it, a Quality Assurance coordinator may be as signed who reports to the Director of Surveillance Systems.
- 2. Nuclear Engineering and Licensing Department During the Construction phase of the project the Nuclear Engineering and Licensing Department, under the dire ction of the Group Manager, Nuclear Engineering and Licensing; w ho is assisted by the Man ager, Nuclear Engineering; the Manager, Nuclear Licensing; the Manager, Independent Safety Engineering Group; and the Manager, Corporate Health Physics and Environmental Programs has the following responsibilities:
- a. Direct the activities of Gilbert through Gilbert's Project Manager and coordinate the activities of the Gilbert, Westinghouse, Dames and More (D&M), other consultants and agents as needed.
- b. Review and approve basic designs as developed by the Gilbert, D&M, and other consultants.
- c. Review bidder's lists.
- d. Review and approve specifications.
- e. Evaluate vendor proposals and make recommendations for procurement sources. f. Participate in, review, and approve the preparation and di stribution of the Safety Analysis Reports, Environmental Reports, and other documentation, as required by the Nuclear Regulatory Commission and other regulatory agencies.
- g. Review and approve amendments to the documents noted in item f, above.
- h. Review and approve Field Change Requests and Engineering change Notices. 17.1-4 Amendment 97-01 August 1997
- i. Review and dispositio n Nonconformance Notices.
- j. Prepare bid documents for SCE&G purchases.
- k. Participate in plant testing and acceptance as required.
- l. Participate in the insp ection program as required.
- m. Participate in the test control program as required.
- n. Perform functions as required in connection with the licensing of the Virgil C.
Summer Nuclear Station.
- 3. Procurement Procurement is the respons ibility of the Vi ce President and Group Executive, Rates/Purchasing who is assisted by t he General Manager, Purchasing and the Manager of Purchasing, Pr oduction and Construction.
- a. Select qualified bidder s with the assistance of engi neering, operating, and QA groups. b. Solicit bids for equipment, materials and services.
- c. Submit commercial, QA, and technica l evaluations to the SCE&G Purchasing Committee which select vendors.
- d. Issue and control chan ges to purchase orders.
- e. Prepare, in cooperat ion with the QA and nucl ear engineering groups, procurement procedures.
- 4. Nuclear Site Manager The SCE&G Nuclear Site Manager has the overall respons ibilities for the construction activities performed on t he site by Daniel, contractors, and subcontractors. Administratively, the SC E&G Nuclear Site Manager reports to the Group Manager Construction and Quality C ontrol and is responsible for the cost and scheduling of the work done on the si te. All work done on the site by the various crafts of Daniel, contractors, and subcontractors is under the jurisdiction of the Daniel Project Manager. The D aniel Project Manager also has the responsibility for compliance with the Daniel QA Manual for Nuclear construction in the fabrication and installation of ASME Code,Section III components. For major modifications, a project manager having the same responsibilities as the Nuclear Site Manager above may be appointed.
17.1-5 Amendment 97-01 August 1997
- 5. Quality Control Manager The SCE&G QC Manager also reports to the Group Manager Construction and Quality Control. The SCE&
G QC Manager supervises the QC efforts at the site in accordance with the SCE&G QC Plan.
The QC organization performs the following major functions but are not limited to these:
- b. Supervise the activities of commercial testing organizations at the site, who are under contract with SCE&G.
- c. Prepare QC procedures for inspection of construction activities.
- d. Stop work on structures, systems, and/or components when work is not in compliance with specified standards, codes, design documents, or procedures.
- e. Be responsible for the testing and in spection of work performed by Daniel, contractors, and subcontract ors at the construction si te except when QC is provided by Daniel (ASME Code Work), or ASME contractors or subcontractors. SCE&G/QC will be respons ible for testing and inspection of piping hangers where the intent of ASME Code r equirements is being met.
- f. Inspect on receipt, material and equipment for conformity to purchase documents and perform acceptance tests as required except when QC is provided by Daniel (ASME Code work).
File test reports, certificates of release, and other documents nec essary to verify quality.
- g. Perform warehousing functions.
- h. Maintain the permanent file for QA records, inspection reports, tests, certificates of release, and other QA documents.
- i. Report potentially significant deficiencies found in construction in accordance with approved procedures.
17.1.1.1.2 Lines of Authority and Communication As noted in Figure 17.1-1, the complex multi-organizational QA Program requires definite lines of authority and communication with contro l by independent checks.
These relationships warrant discussion to illustr ate how overall administrative control of the Program by SCE&G is achieved.
17.1-6 Amendment 97-01 August 1997
- 1. Overall Project The line of authority within the organization cl early provides the flexibility for quality related problems to be identified and resolved. The SCE&G Manager of QA, having a direct line through the Group M anager Nuclear Services to the Vice President Nuclear Operations and the Senior Vice President Power Operations can inform SCE&G top management of unresolved QA issues.
- 2. Quality Assurance The Vice President and Group Executive, Engineering and Construction is made aware of the QC activities by the SCE&G QC Manager through his line of authority to the Group Manager Construc tion and Quality Control.
The QC staff and the independent test l aboratories are under the direction and supervision of the SCE&G QC Manager.
The General Manager, Purchasing, has a direct line of authority through the Vice President and Group Executive, Rates/Purchasing through which the Executive Vice President Finance is kept informed of the status of the purchasing operations.
The line of authority extends downward such that the SCE&G Group Manager Nuclear Services monitors and controls t he direction of QA activities through the Manager, Quality Assurance, hi s staff, QA organization ons ite, the Gilbert Project Quality Coordinator, and other agents, as needed.
As can be seen in Figure 17.1-1, there are five key Group Managers (General Managers) within the SCE&G organization who provide the necessary coordination and communication channels to allow informati on and project status to flow into the QA Program.
- a. The SCE&G manager QA is responsible for the overall functional control of the QA Program and provides guidance and coordination through communications with the Manager, Nu clear Engineering; the Manager, Nuclear Licensing; and the Manager, Purchasing, Production and Construction. The Manager of QA is responsible to review and comment on safety-related (including ASME Code) construction and QC procedures.
Audits and site surveillance are performed to assure that safety-related work (including ASME Code) is accomplished in accordance with the QA Program requirements described herein. This enables the QA functions and responsibilities within the overall administration of the project to be under the guidance and coordination of the SCE&G Manager of QA with the
cooperation of SCE&G management. T hus, problem areas anywhere within the QA Program are resolved through the responsible SCE&G management.
17.1-7 Amendment 97-01 August 1997
- b. The Gilbert Project Qua lity Coordinator provides the SCE&G Manager of QA with a focal point within t he Gilbert organization, thus extending the authority and visibility of the QA Program. By communications with Gilbert project engineering and management, as well as Westinghouse and other vendors, the Gilbert Project Qualit y Coordinator provides the SCE&G Manager of QA with additional information for directing the QA Program.
- c. The SCE&G Director of Site Surveillance and/or QA Coordinator, in close cooperation with the Nuclear Site M anager, SCE&G QC Manager, Daniel Project Manager, the Daniel Project Quality Manager (ASME Code work), and other constructor site manager s assures the understanding and implementation of quality associated requirements.
- d. The SCE&G Construction QC Manager directs inspection and quality item control activities at the construction site except as defined in item e, below.
Reporting offsite to the Manager of Construction and Group Manager Production Engineering, Q uality control and Construction; the SCE&G QC Manager effectively communicates and coor dinates quality activities with the Daniel Project Manager and other contractors for effective implementation of the QC Program.
- e. The Daniel Project Quality Inspector directs the inspection and QC activities required for the ASME Code work. The Daniel Project Quality Inspector reports to the Daniel Proj ect Quality Manager onsite for effective coordination of ASME Code quality activities.
- 3. Functional Relationships The functional relationships within the SCE&G QA Program provide control to assure effective program compliance.
- a. Construction site work is verified by inspection performed by the SCE&G QC and Daniel QC Groups (ASME Code work only) or by contractor or subcontractor QC.
- b. Site QC and construction activities are monitored by a formal surveillance program conducted by the SCE&
G QA organization onsite.
- c. Vendors are required to provide inter nal independent QA Programs to check design and fabrication work unless working under the SCE&G QA Program.
- d. Gilbert QA, SCE&G, QA and/or its agents perform vendor audits and surveillance to verify vendor performance.
- e. Westinghouse, for the NSSS components, is required to provide an internal QA Program (see Section 17.1.1.3).
17.1-8 Amendment 97-01 August 1997
- f. Gilbert, for design and engineering, is required to provide a Design Control Program including internal audits.
- g. SCE&G QA periodically audits Westinghouse, as NSSS supplier, Gilbert as architect-engineer, Gilbert QA Division as QA consultant, Daniel as the constructor, SCE&G QC, and internal SCE&G safety related activities. These or any other contractor or agent utilized during major modification will have equivalent controls imposed.
- h. Daniel QA periodically audits the D aniel ASME Code program onsite, as required to maintain the Daniel ASME Certificate of Authorization.
17.1.1.1.3 Control of Contractors
- 1. General The Virgil C. Summer Nuclear Station QA Program is effectively administered and controlled by SCE&G through close associat ion with, supervision and audit of the contractors who perform the duties and tasks outlined and delineated herein. The QA programs of the contract ors were reviewed by SCE&G QA and/or its agents to assure that they contained adequate requirements and procedures to control the attainment of quality. All contractors performing safety-related work must have a QA Program reviewed and concurred with by SCE&G QA or its agents; unless the contractors are providing only labor for utilization under the direct control of the SCE&G QA Program. In some cases a cont ract specific QA plan, jointly approved by SCE&G and the contractor, may be us ed in lieu of a program manual.
Contractors impose on their subcontractor s a QA program commensurate with the complexity of the item and it s importance to nuclear safety to assure that the high level of quality set forth in the contract documents is maintained.
- 2. Control Methods Major responsibilities for implementation of the various QA activities included in the SCE&G QA Program during design, pr ocurement, and manufacturing have been delegated to Gilbert and Westinghouse. These responsibilities are described in the Gilbert QA Plan and in the Westinghouse Electric Corporation Water Reactor Divisions QA Plan (Reference (1)). Prim ary responsibilities for the construction site QA and QC programs lie with SCE&G QA and the SCE&G QC organizations, respectively. The SCE&G Manager of QA controls, coordinates, and administers the overall QA Program by the use of the following planned and systematic checks of program stat us and progress:
17.1-9 Amendment 97-01 August 1997
- b. Regular QA Program development and implementation status checks.
- c. Scheduled QA Program audits.
- d. QA Program surveillance and corrective measures.
17.1.1.2 Gilbert Associates, Inc.
The corporate organizational chart of Gilbert is shown in Figure 17.1-4. In retaining Gilbert, SCE&G has two distinct groups provid ing professional services in the areas of engineering and QA. Gilbert Power Engineering, Reading, provides the design services of the various engineering departments including, but not limited to, Hydraulic and Civil, Structural, Architectural, En vironmental, Mechanical, Electr ical, Chemical, and Nuclear.
QA services are provided by the Gilbert QA Division as shown in Figur e 17.1- 5. Gilbert has been retained to provide experienced personnel to assist SCE&G with the overall QA Program. The general responsibilities of the Gilbert Power E ngineering, Reading, are described in the Gilbert Project Managem ent Manual and general responsibilities of the Gilbert QA Division are descr ibed in the Gilbert QA Plan.
- 1. Engineering Engineering is responsible through the G ilbert Project Manager fo r the design of all areas of the plant with the exception of the equipment supplied by Westinghouse.
The various engineering disciplin es are responsible for t heir respective areas of design and preparation of specifications and drawings. Engineering specifies the level of quality inspection and test r equirements, acceptance criteria, and documentation requirements.
Any deviation or waiver request from approved drawings, specifications or procedures must be acted upon by the same (or an SCE&G approved equivalent) engineering gr oup which was responsible for the original design. They also review and approve vendor drawings and documents as appropriate. Design reviews are performed by engineering personnel not responsible for the original design. Desi gn document control is under the control of the Gilbert Project Manager.
- 2. Quality Assurance The Gilbert QA Division and other QA agents or consultants assist the SCE&G Manager QA as requested, in implementi ng the QA Program in the areas of specification review, A/E audit, vendor pr oposal review, NSSS supplier audits, vendor surveillance, and construction audits.
17.1-10 Amendment 97-01 August 1997 17.1.1.3 Westinghouse El ectric Corporation The Westinghouse QA Plans are given in Refe rence [1] and [2]. The degree of QA for Westinghouse NSSS components is given in Table 3.2-1.
The original QA Program implemented by Westinghouse for the Virgil C. Summer Nuclear Station was described in Appendix 1C of the Virgil C. Summer PSAR. Over the course of performing the design and initial procurement activities for the Virgil C.
Summer Nuclear Station, the Westinghous e QA Program was upgraded to reflect changes in regulatory requirements and industr y standards as shown in References [1] and [2]. These changes first culminated in WCAP-8370, Revision 7A. This revision of the Westinghouse QA Program was applicable to activities within Westinghouse scope performed for the Virgil C. Summer Nuclear Station which were initiated after January 1, 1975 to October 1, 1977. Subsequently, the present Westinghouse QA Program, which is described in WCAP-8370, Revision 8A, is applicable to activities within Westinghouse scope which were initiated after October 1, 1977 to October 15, 1 979. Presently, the Westinghouse QA Program is described in WCAP-8370, Revision 9, and is applicable to activities within the Westinghouse scope wh ich were initiated after October 15, 1979.
17.1.1.4 Daniel Construction Company Daniel has been retained by SCE&G as t he constructor to perform the actual construction activities at the project site except for specialized phases of the work which will be performed by other qualified contractors and subcontractors. The Daniel organization for the Virgil C. Summer Nuclear Station project is shown in Figure 17.1-6.
Daniel is under the direction of the Daniel Project Manager who is responsible to the SCE&G Nuclear Site Manager. Daniel is responsible for the development and implementation of effective controls over the construction and erection of the
safety-related structures, systems, and components to assure their conformance to the design specifications and drawings, (includi ng the fabrication and installation of ASME Code work). Daniel responsibilities include:
- 1. Selection and indoctri nation of qualified personnel.
- 2. Direct supervision of work performed by the crafts.
- 3. Responsibility for the quality of work done.
- 4. Scheduling and planning of work.
- 5. Preparation of construc tion procedures as indicat ed in Gilbert construction specifications and as determined to be needed by Daniel construction management to complete a quality installation.
- 6. Reporting monthly on the st atus of the construction.
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- 7. Ensuring that only the latest revisions or issues of field documents, i.e., drawings, specifications, procedures, etc., are used for construction.
- 8. Providing the Daniel QA Program for the Daniel scope of work which includes the Daniel QA Manual for ASME Code work.
- 9. Providing the QA, QC, and Constructi on procedures necessary to perform field fabrication and installation of ASME Code stamped work.
- 10. Regularly review the status and adequacy of the construction QA Program being executed by Daniel.
The Daniel QA Program is c ontained in the Daniel Construc tion Procedures Manual and the QA Manual for Nuclear Construction.
Work procedures for performing the assigned construction activities are contained in the Daniel Construction Procedures Manual (procedures for ASME Code work are included).
Construction site QC is performed by SCE&G QC and/or its agents for Daniel activities in accordance with the SCE&G QA Plan and Field Quality Control Plan, except for specialized phases of work by other cont ractors and subcontractors who will perform the required QA and QC; and the ASME Code wo rk by Daniel who will perform the QA and QC required by the Daniel Ce rtificates of Authorization. The construction site QA is provided by SCE&G QA in accordance wit h the SCE&G QA Plan and Manual, except as noted above.
17.1.2 QUALITY ASSURANCE PROGRAM The Virgil C. Summer Nuclear Station QA Program is comprised of planned and systematic activities and independent verification dur ing design, procurement, equipment fabrication, site construction and erection, and system final inspection and testing. This QA Program is organized to provide an integrated plan under the direct control of SCE&G. A system of audit and surveillance provides assurance that
elements of the Program ar e functioning as planned.
17.1.2.1 Applicability The SCE&G QA Program is applicable to those structures, systems, and components classified as safety-related. These items are identified in Sect ion 3.2. The items identified as within West inghouse scope of supply are the responsibility of Westinghouse subject to SCE&G audit, a ssuring appropriate QA measures. The remaining safety-related items are controlle d directly by SCE&G, using the assistance of Gilbert, Daniel, and other contractors for construction and installation. The QA Program is in force throughout the design and construction of the Virgil C. Summer Nuclear Station. During future major mainte nance or modification all or parts of the organizational structure shown on Figure 17.1-1 may be employed commensurate with the complexity of the activity. A QA Coordinator reporting to the Director of S. S. may be assigned if the scope of the activity requi res dedicated QA follow-up. Agents and/or 17.1-12 Amendment 97-01 August 1997 contractors including thos e herein discussed may be employed in accordance with QA program requirements herein specified.
17.1.2.2 Administrative Controls The SCE&G corporate QA policies and procedures are aimed at the goal of obtaining a plant which is safe and reliable in accordance with the requirements of 10 CFR 50, Appendix B. The procedures used in implementing the QA Program incorporate provisions for proceeding to successive levels of management until resolution is obtained, with ultimate reso lution by the Executive Vi ce President, Operations.
The Vice President Nuclear Operations perfo rms a continuing review of the SCE&G QA Program with and through the SCE&G Group Manager Nuclear Services and Manager of Quality Assurance; and repor ts on the effectiveness of t he programs to the Executive Vice President, Operations through the Senior Vice President Power Operations.
The Manager of QA through the SCE&G Group Manager Nuclear Services has been delegated the responsibility for the establis hment, maintenance, cont rol, distribution, and verification of implementatio n of the QA Program by t he Vice President and Group Executive, Nuclear Operations. The Group Manager Nuclear Se rvices shall annually, or as deemed necessary, have the SCE&G QA Program reviewed and revised where required. Affected organizations may submit recommended changes as they see fit.
Proposed revisions, as a result of the QA review or recommended changes by others, are submitted to SCE&G groups having responsibilities in the QA Program for comment prior to revision of the Pr ogram. Conflicting comments are resolved by the SCE&G Manager of QA with the concerned parties. Revisions affecting Code requirements shall be submitted to the Authorized Inspection Agency for acceptance prior to implementation.
The procedures and instructions which govern the activiti es of SCE&G in the design and construction of the Virgil C. Summer Nu clear Station are contained in the QA Manual, the Nuclear Engineer ing Procedures Manual, the QC Procedures Manual, and the Purchasing Procedures Manual. When required by the contract documents, each contractor of safety-related structures, systems, or components is required to develop and implement his own QA Program which is reviewed and audited by SCE&G. Audits of the contractors are c onducted by SCE&G or its agent s to ensure that the QA requirements are met.
The QA procedures in the area of procurement control require the Manager of QA to evaluate and accept contractor's QA Programs, by review of QA information submittals, review of QA activities on active purchase orders, and, where necessary, preaward surveys of the prospective contractor's QA Program, prior to award of a purchase order.
During performance of the contract, SCE&G QA personnel or Gilbert QA personnel, at the request of the SCE&G Manager of QA, will conduct surveillance of the contractor to assure continued implementatio n of the accepted QA Program. These activities are recorded in surveillance reports, and findi ngs of the reports resolved with the contractors.
17.1-13 Amendment 97-01 August 1997 QA personnel, in their reviews of progr ams and special process procedures implementing the QA Program, shall assure that procedures require that all prerequisites for a given action are satisfied, such as the presence and use of suitable equipment (certified or qualified when necessary), a suitable environment for accomplishing the activity, such as adequate cleanliness and lighting levels, and that necessary prerequisites for the activi ty have been met, e.g., prior specified examinations and processing operations or the establishment of test or inspection acceptance criteria. The QA Program r equires that the procedures be prepared and made available for use prior to the need for eac h at the point of use. These special process procedures controlling safety-related work shall be reviewed and concurred with and a "release to fabricate" or "release to work" (for si te activity) granted before work begins in the area, see Section 17.1.7.
17.1.2.3 Indoctri nation and Training The indoctrination and training is described in the indoctrination and training procedures for each organization within SCE&G with qua lity related responsibilities. The procedures require that personnel be familiar with the requirements of their position, and maintain expertise in their specialty. The SCE&G QA organization conducts a training course in the basics of plant familiarization and QA, with detailed emphasis on the conduct of surveillance and audits, for all personnel in the SCE&G QA organization. Expertise is also maintained by continuing experience in surveillance and auditing on the part of each member of the SCE&G QA organization.
The SCE&G Manager of QA shall have a B. S.
Degree in engineering, or its equivalent in experience and/or correspondence courses. He shall be experienced in design, manufacturing, operations, construction, and/
or administration in utility or related industries; have at least 1 year experience in QA management and policies; and be knowledgeable of applicable codes and standards. QA Directors, QA Engineers, and the Site QA coordinator shall be graduates of accredited engineering curricula, or the equivalent, and, preferably, have had exper ience in the design, manufacturing, operation, construction, or QA areas relative to the nuclear and/or utility fields. QA specialists shall be graduates of a two year engineering technica l school or have the equivalent in practical experience and/or correspondence courses.
17.1-14 Amendment 97-01 August 1997 17.1.3 DESIGN CONTROL 17.1.3.1 South Carolina Electric & Gas Company During the construction phase, the SCE&G Nuclear Engineering and Licensing Department performs design control functions relative to design interface control, specification, drawing technical reviews, and SAR deviation control. The Nuclear Engineering and Licensing Depa rtment's Manager, Nuclear Li censing performs design control functions relative to SAR deviation control. The SCE&G activities are described in the SCE&G Nuclear Engineering Procedu res Manual. SCE&G Nuclear Engineering Department monitors; through its reviews of design document s, and SCE&G QA or its agents audits; the design control activities of Gilbert, Westinghouse and other vendors.
17.1.3.2 Gilbert Associates, Inc.
- 1. Design Review and Verification Safety-related design activity is re viewed and verified by a formalized and documented system described by the Gilbert Project Management Manual. The types of review used are:
- a. Checks to compare information presented on a drawing or other document with a definite, stipul ated figure, criterion, or design base, b. Supervisory reviews which are critical inspections of design work, conducted by a superior in a given discipline, of wo rk by a project team member in that discipline, c. Interface reviews by personnel of one discipline or company of work performed by another disci pline or company to determine, with reasonable assurance, that the review er's discipline requirements are provided for, and that specification requirem ents are satisfied for the reviewer's discipline or company, d. Design verification which is indep endent confirmation of design adequacy and compliance with requirements, performed by an individual other than the originator, who did not perform work on the item being reviewed.
Each discipline prepares a Design Verification Status Report identifying each item to be verified and indicating the status of each item. System design may be verified in whole or in parts. When in par ts, separate verification attestations must be completed and the Design Verification St atus Report must define and reflect the verification of each part. Each review and verification must be indicated on the specified form or by signature or refe rence to the acceptance letter of the responsible engineering company on the document reviewed. Suitable equivalent controls will also be maintained during major modifications.
17.1-15 Amendment 97-01 August 1997
- 2. Specification Reviews It is the responsibility of the Gilbert Project Engineer to ensure that the necessary QC and QA requirements are included in the specifications for structures, systems and components for which he has design respons ibility. In addition to reviews by SCE&G and other Gilbert design engineers, s pecifications are reviewed by the Gilbert QA Division and/or the SCE&G QA organization to assure that sufficient quality requirements have been in corporated for safety-rela ted items. Procedures for the review of specifications are c ontained in the SCE&G QA and Gilbert QA Manuals. 3. Design Requirements Control Interface and technical reviews are perfo rmed by Gilbert Proj ect Engineering, the Gilbert QA Division, and/or the SCE&G QA organization. They also review vendor proposals, bills of material, and vendor and construction procedures to verify consistency with Gilbert proc urement specifications. Pr ocedures for these reviews are contained in Gilbert Project Management Manual for Virgil C. Summer Nuclear Station, and the Gilbert QA and SCE&G QA Manuals.
- 4. Design Document Control Design documents are controlled as follows:
- a. Specifications are issued and controll ed from a controlled distribution section which maintains the record copy of s pecifications and a master distribution list. b. Drawings are prepared and checked by designers and draftsmen. After review and approval by the Gilbert Proj ect Engineer, they are issued through a central distribution group. Record c opies and master distribution lists are used to provide assurance that the latest revisions are promptly forwarded to the proper organizations. Lists of latest available revisions of drawings are furnished to those on distribution lists to ensure that the latest revision is in use. c. Changes to the SAR requirements are controlled by use of a form which is initiated by the cogniza nt project engineer.
Significant changes and associated justifications are review ed by the SCE&G Nuclear Engineering and Licensing Department.
- d. Significant field or shop changes to drawings and specifications for safety-related equipment are allowed only after approval by Gilbert and/or SCE&G Manager Nuclear Engineering, or his designee. All authorized changes are documented and cont rolled as described below:
17.1-16 Amendment 97-01 August 1997
- 1) Design initiated changes are accomplished by Engineering Change Notices (ECN's) and are included in the drawings, specifications, and bills of material by subsequent revisi on. ECN's for specifications and bills of materials are approved by t he SCE&G Nuclear Engineering Department before implem entation, unless the ECN is written to implement a previously accepted Field Change Request (FCR), to respond to a letter from SCE&G requesting the change, or to change drawings which did not require original approval by SCE&G.
- 2) Field initiated changes are handled by FCR's. A field engineer requests authorization to make a field change from the SCE&G Nuclear Engineering Department. ECN's are distributed as a followup to reflect the field change after acceptance of the FCR by the SCE&G Nuclear Engineering Department. Mi nor field changes which do not affect the design are documented by the SCE&G QC organization and approved by the resident engineer or SCE&G Nuclear Engineering Department on field prepared "as built documents" (ABD's). Field changes and applicable ABD's are incorporated into revised drawings as directed by
the resident engineer or SCE&G Nu clear Engineering Department. FCR's may be authorized by telephone in accordance with approved procedures.
- 5. Record Accumulation and Control The records associated with the design activity are maintained by the individual design group. Copies of these records are indexed and stored in a safe Record Retention Storage Area. Thes e records are audited by the Gilbert QA Division, the SCE&G QA organization, and/or its agents.
17.1.3.3 Westinghouse El ectric Corporation The Westinghouse Design Contro l Program is described in Reference [1] and Section 17.1.1.3.
17.1.4 PROCUREMENT DOCUMENT CONTROL The procurement of equipment for the Vi rgil C. Summer Nuclear Station involves activities performed by SCE&G, Westingho use, and Gilbert. SCE&G makes the final selection of suppliers, except those under Westinghouse scope of supply. Procurement for the remainder of the plant is referr ed to as BOP. The purchase documents for safety-related equipment include requirements to the extent considered necessary based on safety classification, complexi ty, and other engineering considerations.
17.1-17 Amendment 97-01 August 1997 17.1.4.1 NSSS Purchases NSSS purchases of safety-related structures, systems, and components are controlled under the QA Program described in Reference [1] and Section 17.1.1.3.
17.1.4.2 Balance of Plant Purchases Safety-related BOP structures, systems, and components are procured by the use of procurement specifications which include QA requirements. Procurement documents require the bidder to have a QA Program which meets the requirements of 10 CFR 50, Appendix B unless working under the SCE&G QA Program, or when the quality of the item to be furnished can be verified by receipt inspection, testing, or verification by an independent laboratory or performance testing prior to pl acing the affected system into service. This method is used when nonsafety related items are "upgraded" to safety related application or to confirm the quality of a safety-related commercial grade item.
Any such actions will require QA concurrence prior to utilization. Procurement documents may also require the contractor to give the purchaser such rights as: access
for inspection and audit, review and concurrence with certain special process procedures or instructions, design drawings and specifications, inspection and test records, and QA documents relative to the purchase.
Selected items; such as commercial items, repair parts, and services; may be procured by SCE&G and by the use of Gilbert or SCE&G prepared bills of material and/or SCE&G purchase requisitions. Applicable QA requirements are included in the contract documents.
For purchases made to Gilbert procurement specifications; proposals for materials, equipment, and services are subjected to a technical evaluation by Gilbert Engineering and/or SCE&G Nuclear Engineering with a QA review by the SCE&G QA organization and/or the Gilbert QA Divisi on. Proposals for purchase fr om safety-related bills of material or SCE&G purchase r equisitions are subject to a technical review by SCE&G Nuclear Engineering with a QA review by the SCE&G QA organization and/or the Gilbert QA Division except for the procurement of QA services. Proposals in this latter category are reviewed by the SCE&G QA org anization only. The QA review is based on the requirements of the procur ement specification or bill of material to ascertain that the proposed QA Program is adequate. The te chnical and QA reviews of the proposal request documents assure the inclusion of su ch requirements as correct and accurate regulatory, code, and design statements; technical and quality document preparation and submittal for review or approval, and the retention, control, and maintenance of the records; and acceptance criteria beyond which the vendor would have to request acceptance by SCE&G. These requirement s are placed on the purchase order, including safety-related spar es. SCE&G QA concurrence of acceptable bidders must be obtained before a request for proposal can be forwarded to a potential supplier. The bids are evaluated for technical, quality, and commercial acceptability. A preferred bidder is then selected. The preferred bi dder must be accepted by SCE&G QA before a purchase order can be placed. The SCE&G QA organization and/or the Gilbert QA 17.1-18 Amendment 97-01 August 1997 Division review available qua lity history information and QA Program submittals for the preferred bidder to determine wh ether the bidder is acceptabl e, and where sufficient QA Program information is not available from th ese sources, will perform a preaward survey of the preferred bidder's QA Program, until an acceptable preferred bidder is determined.
For material, equipment, or services purchased from a G ilbert procurement specification; Gilbert prepares a bill of material based on the procurement specification, the successful bidder's proposal, and any ot her pertinent document
- s. The actual provisions of the contract will appear within the bill of material by reference to the specification or incorporation of requirements in lieu of or in addition to the specification within the bill. For material, equipment, or services purchased from a bill of material
without a procurement specificat ion, Gilbert conforms the bill of material to the successful bidder's proposal and other perti nent documents, as necessary. Again, the bill contains the actual requirements in lieu of references to correspondence (pricing excepted). These bills of material are used as contract documents and include technical and quality requirements. The b ill of material is attached to the standard contractual provisions and together they form the purchase order. The bill of material is reviewed and initialed by the SCE&G QA organization and/or the Gilbert QA Division, Gilbert Engineering, and/or SCE&G Nuclear Engineering. The preparation, review, approval, and issuance of bills of material are described in the SCE&G and Gilbert procedures which implem ent the QA Program.
17.1.5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS Each of the organizations involved in safety-related work on the Virgil C. Summer Nuclear Station has been required to pr epare program document s, instructions, procedures, and drawings to describe the work to be accomplished and the method by which the work is to be accomplished. This requirement has been imposed by
contractual requirements, as with Westinghouse, or by spec ifications, as described in Section 17.1.4.
The SCE&G Manager of QA has been assigned t he responsibility to review and concur with the QA Programs and associated documents of SCE&G and it s agents; Gilbert, Westinghouse, Daniel, vendors, and contractors. The revi ew of documents of vendors and contractors may be assigned to the Gilbert QA Division or any other qualified agent by the SCE&G Manager of QA. The reviews are performed to verify that:
- 1. Applicable requirements of 10 CFR 50, Appendix B have been included.
- 2. The plans and associated documents co ver the required design, procurement, manufacturing, construction, and testing activities.
- 3. Adequate internal control methods have been provided for subcontractor activities.
17.1-19 Amendment 97-01 August 1997
- 4. Intended specific work functions are identified and established to afford a status check of planned activities, including the determination of that status (acceptance criteria).
17.1.6 DOCUMENT CONTROL The procedures for the preparation, review, approval, and di stribution of instructions, procedures, and drawings described in Sect ion 17.1.5 require that all specified approvals be obtained prior to the issuance of the documents. These same requirements are imposed on such design and descriptive documents as specifications and SAR's. The required reviews and approv als ensure that issued documents are adequate and correct for the use intended.
The procedures controlling these documents require review and approval of changes to the documents by the same organizations which approved the orig inal document, or SCE&G approved and designated equivalent.
Specifications are issued and controlled from a controlled distribution section which maintains the record copy of all specif ications and a master distribution list.
Drawings are prepared and checked by desi gners and draftsmen. After review and approval by the project engineer, and/or by SCE&G, they are issued through a central distribution group. Record copies and master distribution lists are used to provide assurance that the latest revisions are pr omptly forwarded to the proper organizations.
Construction phase changes to the SAR's requirements are controlled by the use of a form which is initiated by the cognizant project engineer. Significant changes and associated justifications are reviewed by the SCE&G Nuclear Engineering and Licensing Department.
Significant field or shop construction phase changes to drawings and specifications for safety-related equipment are allowed only after written approval by the Gilbert Engineer and/or the SCE&G Group Manager , Nuclear Engineering and Li censing, or his designee as described in Section 17.1.3.2.
All construction drawings, procedures, and s pecifications are issued by the SCE&G Document Control Center, in cluding distribution to Daniel. Construction personnel assigned controlled documents are responsible for maintenance and use of the latest documents as described by construction procedures. Records and reports are developed and maintained as required by construction procedures and are available for review and audit by QA and QC personnel on request.
The issue and control of field constructi on documents such as working drawings, specifications, procedures, and instructions are controlled in such a manner as to ensure that only the latest revisions or issues of the documents are used for construction and erection. Documents onsit e are stamped to identify those being revised, and the area of revision indicat ed to limit use of the documents until the 17.1-20 Amendment 97-01 August 1997 approved Engineering C hange Notice, Field Change Reques t, or revised document is received. Procedures which control the fi eld or engineering changes ensure that any changes made are properly authoriz ed, documented, and distributed.
Document control within Westinghouse is described in Reference [1] and Section 17.1.1.3.
17.1.7 CONTROL OF PURCHASED MATE RIAL, EQUIPMENT, AND SERVICES The procurement of equipment for the Vi rgil C. Summer Nuclear Station involves activities performed by SCE&G, Westingho use, and Gilbert. SCE&G makes the final selection of suppliers, except those under Westinghouse scope of supply. The purchase documents for safety-related equi pment include QA requirements to the extent considered necessary based on safety classification, complexity and other engineering considerations. The Westi nghouse control program is described in Reference [1] and Section 17.1.1.3.
17.1.7.1 Construction P hase Source Selection Upon receipt of bids; the SCE&G QA organization and/or the Gilbert QA Division, SCE&G Nuclear Engineering, and Gilber t Engineering will evaluate the bidder's capabilities, as described in Section 17.1.4.
These evaluations are forwarded to the SCE&G General Manager, Purchasing, and used to select a preferred bidder. The SCE&G Purchasing Committee then selects a vendor, and requests concurrence of the SCE&G Manager of QA.
The SCE&G Manager of QA will accept or reje ct the preferred v endor, on the basis of current QA performance or preaward surve ys conducted by the SCE&G organization, the Gilbert QA Division, or other agents, at the direction of the SCE&G Manager of QA when sufficient current performance information is not available. In some cases, verification of the vendor's QA Program may not be necessary if quality can be verified by receipt inspection, testing, or ve rification by an independent laboratory or performance testing prior to returning the affected system to service. This method is used when nonsafety related item s are "upgraded" to safety related application or to confirm the quality of a safety-related commercial grade item. Any such actions will require QA concurrence prior to utilization. Should the preferred vendor be unacceptable due to a deficient QA Pr ogram, the SCE&G Purchasing Committee selects another vendor, and requests concurrence of the SCE&G Manager of QA.
17.1.7.2 Work Release Vendors or contractors may be required to subm it a Contractor's QA Data Identification Report, including a listing of all special proc ess procedures to be used on the contract.
In such cases the vendor must then submit the relevant manufacturing QC, inspection and test procedures to the owner's QA represent ative. Fabrication cannot begin until all special process and QC procedures have been reviewed and concurred with, and a Release of Fabrication has been issued by the QA representative. The requirement for 17.1-21 Amendment 97-01 August 1997 submittal of a Contractor's QA Data Identification Report will be determined at the qualification of the vendor.
Similar controls exist for contractors ons ite, with the QA Group onsite performing the procedure reviews, and the Director, Surveill ance Systems or Site QA Coordinator or their designees issuing a Release to work indicating procedure concurrence and permitting the contractor to begin work.
17.1.7.3 Audit, Surveillance and Inspection Regular review of each contractor's QA Program status is accomplished by various techniques depending on the cont ractor and stage of program implementation. Audits and surveillance of contractors are generally conducted during contract performance to assure that the contractor maintains an acceptable QA Program. These activities assure that control programs and methods are in place throughout performance. The reports of these activities provide a conti nuing status check to the SCE&G Manager of QA of the contractor's QA capabilities. The frequency of audit and surveillance is determined on the basis of safety classification of the item or service provided, complexity, other engineering considerations, and the current status of the contractor's QA Program, as evidenced by evaluation of the surveillance and audit reports, as well as evaluation of receipt inspections.
The QA specification which is imposed on applicable safety-related vendors, requires the vendor to submit a schedule of major ev ents and all inspections and tests for each procurement. A list of suggested inspection not ification points is also submitted by the vendor on the Contractor's QA Data Identific ation Report. The SCE&G QA organization and/or the Gilbert QA Divisi on selects inspection points as notification points, beyond which work may not proceed until acknowledg ment of satisfactory notification and issues the list to the vendor. The QA r epresentative performing surveillance for the procurement then either performs physical surveillance of inspection, or waives surveillance by letter or TWX. The list of notification points becomes part of the contractual requirements placed on the vendor.
17.1.7.4 Acceptance Where required in the contract document s; a vendor of safety-related material, equipment, or services is required to obtain either a Certificate of Inspection (COI), which records physical surveillance of the ve ndor's final inspection and/or tests, or a Waiver of Inspection (WOI), which records acceptance of the vendor's final inspection and certificate of conformance without physical surveillance. COI's and WOI's are prepared by the SCE&G QA organization and/or the Gilbert QA Division to authorize product shipment. When the requirement exists for a WOI, COI, or Quality Release (in the case of Westinghouse equipment), safe ty-related hardware cannot be accepted onsite without appropria te documentation.
17.1-22 Amendment 97-01 August 1997 17.1.7.5 Documentation When required in the contra ct documents, a vendor of safety-related material, equipment, or services prepares a Contractor's QA Data Identificatio n Report identifying the documentation to be submitted by the vendor in satisfaction of the purchase order requirements, and submits the report to the SCE&G QA organization and/or the Gilbert QA Division. The SCE&G QA organization and/
or the Gilbert QA Division then issues a list of required documentation to the vendor.
The identified documentation becomes a part of the contractual requi rements for the vendor. Westinghouse forwards the QA data package in support of t heir Quality Release to SCE&G within 120 days of the final shipment on orders for the Virgil C.
Summer Nuclear Station project.
17.1.8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS When required in the contract documents; a vendor of sa fety-related BOP items is required to establish and maintain an ident ification system for materials, parts, and components; including partially fabricated assemblies which will assure that identity is maintained on the item or records traceable to the it em throughout fabrication and where required, installation. This identification system is to be capable of preventing the use of incorrect or defective items and veri fying that only correct and acceptable items have been used. Each item shipped to the site is to be identified by its bill of material number or other tagging information as specified in the contract documents.
The existence and implementati on of such a system is one of the areas covered during preaward evaluation and continuing audits and surveillance of each vendor conducted by the SCE&G QA organization, the Gilbert QA Division, or any other agent of the SCE&G QA organization. The surveillance of each vendor shall be conducted to assure that materials, parts, and co mponents on SCE&G products ar e identified, and that this identification can be used to verify the co rrect application of materials, parts, and components for these products.
The Westinghouse program in this area is described in Reference [1] and Section 17.1.1.3.
At receipt onsite, the ident ification of equipment is ve rified and maintained by applying an identification tag giving the bill of mate rial numbers, Westingho use SPIN number, or other suitable identification. This identification tag maintains identification through installation. Control is maintained by the status tags, described in Section 17.1.14, applied by the SCE&G QC organization. Thes e tags are used to identify equipment in the warehouse area and after installati on in the plant prior to startup.
Gilbert has generated an Equipment List, a Valve List, and an Instrumentation List, combining the NSSS and BOP purchase order information, to identify equipment within the Virgil C. Summer Nuclear Station. T hese lists will be used for control of plant equipment identification during construction.
17.1-23 Amendment 97-01 August 1997 17.1.9 CONTROL OF SPECIAL PROCESSES The control of special processes for NSSS vendors is described in Reference [1] and Section 17.1.1.3.
Vendors of safety-related items are required to identify and submit special process procedures for review and concurrence before use when required.
Fabrication may not begin until these procedures have been re viewed and concurred with and the vendor notified of this by the Release of F abrication Procedures from the SCE&G QA representative. Audits and surveillance of vendors conducted by the SCE&G QA organization, the Gilbert QA Division, or other agents of the SCE&G QA organization will assure that the qualific ations of personnel, procedure s, and equipment are obtained and maintained, and that documentation of these qualificat ions is maintained and available. A QA specification identifies the minimum special process procedures to be, as applicable: welding procedures, welding procedure qualifications, nondestructive examination (NDE) procedures, forming and bending procedures, cleaning procedures, heat treating procedures, performance test procedures, hydrostatic procedures, leak test procedures, electrical test procedures, painting procedures, seismic procedure or test results, packaging procedures, st orage procedures, shipping procedures, and procedures for verifying wall thickness of pr essure boundaries of castings and forgings for valve bodies, pump casings, pipe and pipe fittings, etc.
Special process procedures and qualifications of onsite c ontractors are subject to review and concurrence by the QA organization onsite. Site contractors may not begin work until the Release to Work has been issued by the Director, Surveillance Systems or the QA Coordinator. Du ring the performance of site wo rk, the Site QA organization performs surveillance to verify proper and complete implementation of the contractor's special process procedures.
17.1.10 INSPECTION 17.1.10.1 Vendor Inspection The control of inspection for NSSS suppliers is described in Reference [1] and Section 17.1.1.3.
Safety-related BOP vendors must satisfy the requirements of QA specifications. The submission of an Inspection Point Program, describing ins pections to be performed by the vendor, concurrence with inspection procedures, and establishment of notification points are described in Sections 17.1.7 and 17.1.
- 9. The review of the Inspection Point Plan and inspection procedures includes determi nation that the inspections are proper and adequate for the type of item and stage of manufacture or fabrication, to determine that items do or will satisfy the requirement for a qua lity product, and that direct inspection or indirect process monitoring, or both are used as necessary to determine quality. 17.1-24 Amendment 97-01 August 1997 Surveillance and audit of the vendor's QA Program and procedures by the SCE&G QA organization, the Gilbert QA Division, or any other SCE&G QA organization agent assures the existence of program elements requiring qualification or certification of inspectors, the existence and presence of inspection procedures, instructions, and/or drawings necessary to the inspection prior to performance of the inspection, and that items replaced, reworked, modified, or r epaired are reinspected by the original inspection procedure or procedures equivalent to the original inspection procedure. Surveillance performed by the SCE&G QA or ganization, the Gilbert QA Division, or other SCE&G QA organization agents will verify implementati on of such requirements.
The independence of inspection personnel from those performing the activity being inspected is determined during review and ev aluation of the vendor's QA Program at the preaward stage of procurement.
17.1.10.2 Onsite Inspection Onsite inspection of the performance of c ontractors is performed by the SCE&G QC Organization, the Daniel QC Group (for ASME Code work), or by contractors or subcontractors. Test laboratories are utilized in the QC programs as needed. These laboratories are under the direction of the SCE&G QC Manager (except as noted below for ASME Code work). The general responsibilities of these laboratories are as follows:
- 1. Concrete material testing and sampling.
- 2. Concrete testing and sampling.
- 3. Soil testing and sampling.
- 4. Rebar Cadweld testing and sampling.
- 5. Concrete inspections.
- 7. Welding inspection.
Specific responsibilities are se t forth in the SCE&G QC Manual.
The Onsite Laboratory NDE contractor will perform examinations and inspections required, including those required by Daniel in the fabrication and installation of ASME Code stamped work under the direction of the Daniel Project Quality Manager.
The final acceptance of a completed system, structure, or component is based on the completion of a final inspection. This inspection is performed by the appropriate QC organization in coordination wit h the QA group. Installati on acceptance and release for testing will be made only after final inspec tion by QC with concurrence of QA.
17.1-25 Amendment 97-01 August 1997 The Programs of Daniel, site contractor s, and the SCE&G QC organization are reviewed and audited by the SCE&G QA org anization for the program requirements quoted in Section 17.1.10.1, above. The Site QA Staff reviews and comments on inspection procedures before they are implemented, and performs surveillance on the inspections of Daniel, site contractors, and the SCE&G QC organization to assure that the accepted procedures and instructions are implemented. Reports on the surveillance activities are prepared by QA personnel onsit e to apprise the SCE&G Manager of QA of the status of site QC and construction activities.
17.1.11 TEST CONTROL 17.1.11.1 Vendor Testing The control of NSSS supplier testing is described in Reference [1] and Section 17.1.1.3.
As required by contract documents vendors of safety-related BO P equipment shall submit a schedule of major events and inspections and test within six weeks of the receipt of contract documents.
The tests identified on t he schedule are those performed to verify conformance to document r equirements given in such documents as instructions, procedures, drawings, specificat ions, etc. The procedures for control of testing are submitted for review by SCE&G and/or Gilbert or other SCE&G agents and are required to describe what testing is to be performed, when tests will be performed, the instructions provided the person performing te sting, including the acceptance criteria and tolerances, the personnel qualifications required to perform the test, what special environmental conditions must be provided, if any, and the type of report to be prepared to verify that the test results are acceptable. The procedures are reviewed and concurred with by SCE&G, Gilbert, or ot her SCE&G agents. Pr oper performance of tests and test evaluations to the accepted procedures is verified by surveillance of vendor performance and documentation by SC E&G QA, Gilbert QA, or other SCE&G QA agents.
17.1.11.2 Site Testing Site testing by site contractors is perfo rmed to procedures submitted to SCE&G QA organization for review and concurrence as described in Sections 17.1.7 and 17.1.9.
These procedures are reviewed to the require ments described in Section 17.1.11.1.
Site testing performed by Daniel for ASME Code work is performed under the requirements of the ASME Certificate for Dani el at the site to procedures reviewed and accepted by SCE&G QA organization. The performance of tests is subjected to surveillance by SCE&G Site QA to assure that testing is performed in accordance with the accepted procedures.
The evaluation of onsite testing is conduc ted by the contractors, SCE&G Nuclear Engineering, and the SCE&G QA organization with technical assistance from Gilbert, Westinghouse and other contract ors and consultants, as necessary to determine that test results are acceptable.
17.1-26 Amendment 97-01 August 1997 17.1.12 CONTROL OF MEASURI NG AND TEST EQUIPMENT 17.1.12.1 Vendor Controls The control of measuring and test equipment for NSSS suppliers is described in Reference [1] and Section 17.1.1.3.
Vendors and contractors of safety-related ma terials, parts, components and services for the Virgil C. Summer Nuclear Station are required to have a program to control measurement, inspection, and test equipment, as required, by the SCE&G QA Program, unless the quality of items furnished can be established by onsite receipt inspection, test, or other methods as indicated in Se ction 17.1.7.1. The program review and evaluation, surveillance, and audits of each vendor conducted by the SCE&G QA organization, the Gilbert QA Division, or other SCE&G Organization agents assures the existence of an acceptable program. W hen required by the c ontrol document the following will be defined by the vendor:
- 1. A listing of measuring and test devices a ffecting quality that require calibration.
Measuring equipment such as steel rule s, levels and similar equipment will not require calibration when their usage does not require a precise degree of accuracy.
- 2. The method of calibration for each item in the listing specified in item 1 above, including the National Bureau of St andards recognized standard used, for certification of calibrating equipment.
- 3. The established frequency of calibration.
- 4. The method of identification for each item under calibration control.
- 5. The method of determining the calibra tion status of each item, such as the attachment of a sticker showing the last calibration date, date when due for recalibration, and the person's stamp, initia ls or signature who performed the last calibration.
- 6. The type of records that will be maintained.
- 7. The method for determining and recalling equipment when calibration is due.
- 8. The measures to be exercised when equipment that is out of calibration has been found to have been used to accept parts, components, assemblies, etc.
17.1.12.2 Site Controls The SCE&G QC Manager is responsible for maintaining the calibration of tools, gauges, instruments; and other inspection, measuring, and testing equipment and devices used by SCE&G onsite in activi ties affecting quality.
17.1-27 Amendment 97-01 August 1997 The calibration and control procedure approv ed by the SCE&G QC Manager assigns each discipline QC Supervisor the responsibility for establishing the criteria and documents required for the proc urement of test and measuri ng equipment relating to his field of work and for assigning qualified personnel to perform calibrations. He is also responsible for developing checklists or s pecial calibration instructions for all instruments, gauges, tools, and equipment for which specia l calibration and control is required, and for assigning identifying numbers to equipment that requires calibration, as well as classifying the equipment as to standard or field measurement use, and assigning the frequency of calibration.
QC inspectors are responsible for: appl ying a calibration tag upon receipt and at recalibration; the accurate calibration of equi pment; and inspection of equipment prior to use for damage, proper working order, a curr ent calibration tag, and for proper use of equipment in accordance with procedures or manufacturer's instructions.
The Warehouse Supervisor is responsible fo r adequate storage facilities until equipment is issued, and for maintaining an issue log for all instruments, gauges, tools, and equipment showing the discip line QC Supervisor to whom the equipment was issued.
The Document Supervisor maintains record s of calibration and control of test and measuring equipment by retaining the Calibration Record forwarded to him by the discipline QC Supervisor. T he Calibration Record shows identification for each item of equipment, giving the required calibration ac curacy, frequency of calibration, and the date of each calibration for an item of equipment.
Standards are purchased from suppliers which can provide certified traceability to the National Bureau of Standards, when possible.
When this cannot be done, the discipline QC Supervisor documents the calibration met hod to be used, justifying its use. The discipline QC Supervisor establishes t he frequency at which standards are to be recertified.
Each discipline QC Supervisor maintains a recall system for equipment recalibration.
Additional calibrations are required whenev er calibration is suspect, and equipment found consistently out of calibration is repair ed or replaced. Out of tolerance equipment may be used temporarily only if correction fa ctors are available and applied. The discipline QC Supervisor approves all such temporary use and docu ments this use. Accuracy and tolerance of test and measuring equipment shall in no case be of lower order of accuracy than the equipment under test.
Test equipment which is found to be out of ca libration during a periodic test is clearly identified as such, and an evaluation is made by the discipline QC Supervisor of the validity of all equipment test s performed with this equipment since its last acceptable calibration.
17.1-28 Amendment 97-01 August 1997 The QC Group regularly assures that calibration equipment and records are used properly and mainta ined in good order.
The SCE&G/QA organization performs audits and surveillance of the SCE&G QC organization to assure that the requirements of the QC calibration procedure are followed.
17.1.13 HANDLING, STOR AGE, AND SHIPPING 17.1.13.1 Vendor Controls The handling, storage, shipping, cleaning, and preservation control measures used for NSSS suppliers are described in Re ference [1] and Section 17.1.1.3.
The handling, storage, shipping, cleaning, and preservation measures of safety-related BOP vendors and site contractors are controlled by the requirements of current QC specifications.
The QA specifications require documented measures for protection of equipment during handling, storage, and shipping, including the use of specific procedures for control of special environmental contro ls or special han dling equipment and verification of conformance to controls. Periodic ins pections must be programmed for special handling equipment, as necessary, to ensure safe and adequate handling.
The QA specifications require that each item be identified, ma rked, and labeled to provide identity of the item and easy identification of special handling and storage requirements.
The documented measures required by the QA specifications must describe;
- 1. The methods and equipment that will be used for normal handling of items during fabrication, processes, storage, shipping, and installation.
- 2. The measures that will be utilized to protect items requiring special handling, storage, and shipping techniques.
- 3. Identification, marking, and labeling me thods, i.e., stenciling (steel, paint), tag (metal, other).
- 4. Measures that will be used to protect i dentification, marking, and labeling from deterioration and loss of recognition when the method is not a permanent type.
- 5. Special protective environments that will be used for special products.
In addition, vendor procedures for cleaning, painting, packaging, storage, and shipping are regarded as special process procedures , and controlled as described in Section 17.1.9. 17.1-29 Amendment 97-01 August 1997 The SCE&G QA organization, the Gilbert QA Division, or other SCE&G QA agents review the QA Program of vendors, and per form audits and surveillance of vendors to ensure the existence and implementation of these requi rements. The SCE&G QA organization performs audits and surveillance of site contractors to ensure the existence and application of t hese requirements.
17.1.13.2 Site Controls Storage services onsite are provided by the SCE&G QC Group. The QC procedure for storage requires the classification of safety-related items to one of four prot ection levels provided. These are:
- 1. Level D includes those items not so sensitive to the environment as Level C (below), which may or may not require some protection against the elements, airborne contamination, and physical and mechanical damage. Level D items are stored outdoors in an area mark ed and designated for storage.
- 2. Level C items require protection from exposure to airborne contaminants, the environment, physical damage, and g-forces.
Protection from water vapor and condensation may be required, but is not so important as for Level B (below).
Level C items are stored i ndoors or in an environment equivalent to indoors.
Temperature control is not required.
- 3. Level B items are sensitive to environmental conditions and require protection from the effects of temperature extremes in addition to the requirements for Level C, including protection from humidity and vapors. Level B items are stored within a fire resistant, weathertight and well ventilated building or equivalent tear resistant structure. Items are plac ed to allow air circulation, and temperatures are held within a range of 40°F minimum and 140° maximum.
- 4. Level A items are those which are exceptionally sensitive to environmental conditions or require special measures for protection from the effects of high or low temperature, sudden temperature changes , humidity and vapors, g-forces, physical damage, and airborne contamination such as rain, snow, dust, dirt, salt sprays, or fumes. Level A items are stored under conditions similar to those for Level B items, with additiona l requirements such as te mperature control within a range of 60°F to 90°F, relative humidity to less than 60 percent, a filtered ventilation system, and other appropriate requirements.
The storage of items is periodically inspecte d by the SCE&G QC Group to ensure that the storage requirements are being satisfied.
The Constructor and Site Contractors prepar e handling instructions for items which require special handling because of weight, si ze, or fragility. These instructions are reviewed by the SCE&G QA org anization to ensure inclusion of quality criteria. The SCE&G QC Group observes these handl ing operations and the SCE&G QA 17.1-30 Amendment 97-01 August 1997 organization performs surveillance on sele cted handling operations, to assure that accepted handling procedures and instructions are followed, and to preclude damage to the items handled.
Review of handling procedures and instructi ons, and inspection of hoisting and rigging equipment is performed to assu re that appropriate equipment and methods are used in handling.
17.1.14 INSPECTION, TEST, AND OPERATING STATUS 17.1.14.1 Vendor Controls Requirements for the identificat ion of inspection and test stat us for NSSS suppliers are described in Reference [1] and Section 17.1.1.3.
The QA specification requires vendors of sa fety-related items to have, within their material identification and control and noncon formance control progr ams, identification methods to assure that only correct and acceptable materials, parts, and/or components are used in the fabrication, assembly, processing, installa tion, and repair of items. These measures must include provisions for control of nonconformi ng items to prevent further processing of the item by such me thods as segregation, tagging, marking or other positive means. The SCE&G QA organization, the Gilbert QA Division, or other SCE&G QA agents will review vendors programs and perform audits and surveillance of vendors to assure the existence and implementation of these requirements.
17.1.14.2 Site Controls The SCE&G QC Group is responsible for appl ying inspection status tags to items onsite. These tags indicate that an item is accepted, on hol d, conditionally accepted, or rejected.
Items with an ACCEPTED or CONDITIONAL tag applied may be in stalled in plant systems. Items with the CONDITIONAL tag appl ied are subject to further testing or inspection after issuance from the warehouse. Actions taken on items with a HOLD or REJECTED tag applied are de scribed in Section 17.1.15.
Procedure requirements for identification of operating status for preoperational testing are described in Section 13.5.
The programs and procedures for i dentification of inspection, test, and operating status onsite are reviewed and commented on by t he SCE&G QA organization. The SCE&G QA organization conducts audits and surveillance of onsite records and actions to verify the performance of site organizati ons to the accepted procedures.
17.1-31 Amendment 97-01 August 1997 17.1.15 NONCONFORMING MATERIAL S, PARTS, OR COMPONENTS 17.1.15.1 Vendor Controls The requirements placed on NSSS suppliers for control of nonconforming materials, parts or components is described in Reference [1] and Section 17.1.1.3.
Normally the QA specification requires the vendor to establish documented measures to control items when there is evidence of nonconformance to established requirements, including the identification, documentation, segregation, dis position, and notification of all concerned parties of the nonconforming c ondition. The only exception is when the contractor is working under the SCE&
G/QA Program and the nonconformances are processed in accordance with SCE&G/QA Program. The review of nonconformances and disposition authority must be defined. Di spositions may be; accepted "as is", repair, rework, or scrap. The measures must include controls to prevent further processing where justified until the di sposition has been approved. When the disposition is acceptance "as is", repair, or rework; the documentation shall verify acceptability and describe the "as built" item. Approval must be obtained from the SCE&G Nuclear Engineering Department and QA organizations, or their agents, whenever the disposition would result in an item which would not satisfy the contract documents. The request for such approval mu st be in writing to the SCE&G Production Engineering Department, or their agent.
17.1.15.2 Site Controls At receiving inspection, the QC Inspector will identify those items which do not conform to requirements by placing a HOLD or REJECT tag on the item. REJECT items are removed from the site.
HOLD items are placed in segregated storage when practi cal, and maintained there until disposition of the nonconformance. Large items, or those whic h may not practically or physically be segregated shall have t he HOLD tag placed on the item in a conspicuous location.
The QC Inspector or Engineer initiates a De ficiency Notice for the nonconformance, or, after consulting the discipline QC Super visor, a Nonconformance Notice for nonconformances which require SCE&G Production Engineering resolution.
Deficiencies are those nonconformances whic h can be corrected by existing approved instructions or procedures or by replacem ent of a broken or nonconforming part. The discipline QC Supervisor reviews all De ficiency Notices to determine whether a Nonconformance Notice must be prepared.
Deficiency Notices and Nonconformance Notices are distributed to SCE&G QA and other involved organizations.
17.1-32 Amendment 97-01 August 1997 The QC Inspector or Engineer follows disposition action determined by the discipline QC Supervisor and records the completion of action and acceptance of the item, and replaces the HOLD tag with an ACCEPTED tag, or CONDITIONAL tag when further action must be taken after issuance from the warehouse. The completed Deficiency Notice is filed and copies sent to the SCE&G QA organization and other involved organizations.
Nonconformance Notices, except Daniel NCN B's, are sent to SCE&G Nuclear Engineering for determination of disposition, with copies to the SCE&G QA organization and other concerned organizations. SC E&G Nuclear Engineering determines disposition for the nonconformance and forwards the disposition to the SCE&G QC Group for action. SCE&G Nuclear Engineering evaluates the nonconformance to determine whether it should be considered a potential significant deficiency, and be processed by the applicable Nucl ear Engineering procedure.
Comments on the nonconformanc e are obtained from the SCE&G QA organization and a disposition prepared on the Nonconformance Notice. The disposition may involve acceptance "as is", repair, rework, or directi on to classify the item REJECT. Disposition action will be directed by SCE&G Nuclear Engineering. The SCE&G QC Group, and the SCE&G QA organization, under direction of the Director of Surveillance Systems or the QA Coordinator, follow-up on corrective action and assure that the QC Inspector or Engineer completes the disposition action portion of the Nonconformance Notice, documenting the final condition of the item , and forwards the form to the Document Supervisor for retention in the files.
Minor civil, mechanical and electrical cons truction items which do not comply with the design documents but do not affect the des ign of the structures, systems, or components, may be documented on "As-Built Documents" (ABD's). ABD's are filed with the associated quality records, and may be incorporated into drawing revisions as described in Section 17.1.3.2.
The discipline QC Supervisors analyze the logs of Deficiency Notices and Nonconformance Notices to determine whether any trend exists or any correction should be made to construction or QC procedures, and reports on this analysis quarterly to the SCE&G QC Manager.
Conformance to the SCE&G QC and SCE&G Nuclear Engineering procedures for the control of nonconformances is assured by audit and surveillance by the SCE&G QA
organization and the Site QA organization.
17.1-33 Amendment 97-01 August 1997 17.1.16 CORRECTIVE ACTION 17.1.16.1 Vendor Controls The corrective action controls for the NSSS supplier are described in Reference [1] and Section 17.1.1.3.
The QA specification requires vendors of safe ty-related items to have corrective action measures to assure that conditions adver se to quality are pr omptly identified, documented, and corrected. The only excepti on is when the contractor is working under the SCE&G/QA Program and the correct ive measures are accomplished in accordance with the SCE&G/QA Program.
These measures must identify the responsibilities for identification of the need for corrective action, and the preparation and approval of corrective action. The cause of the detrimental condition must be determined. When the corrective action is taken to preclude repetition of significant nonconforming conditions, the corrective actions must be monitored to assure that the corrective actions are effective. Guideli nes for determining the need for corrective
action must be given in the measures, and management distribution for notification identified.
The SCE&G QA organization, the Gilbert QA Division, or other SCE&G QA agents evaluate the vendor's QA Program to ens ure the existence of adequate corrective action measures, and perform surveillance of the vendors to ensure the implementation of these measures.
17.1.16.2 Site Controls The SCE&G QA organization conducts audits and surveillance of organizations and contractors performing safety-related acti ons, and prepares reports on these audits and surveillances. Whenever a condition is discovered which indicates a significant
omission of controls in an approved QA Program, or a deficient QA Program, a Corrective Action Request (CAR) is issued.
The CAR must be acknowledged by the responsible individual and corrective acti on initiated to correct the condition.
The SCE&G Site QA staff al so reviews Nonconformance No tices, Deviation Notices, and As-Built Documents; and evaluates and examines the trend analysis data gathered by the SCE&G QC Group described in Section 17.1.15.2, to determine the existence of conditions significantly adverse to quality requiring the issuance of a CAR.
The SCE&G QC Group and the Site QA staff follow the implementation and effectiveness of corrective action.
SCE&G has established a Field Review Bo ard and assigned it prime responsibility for identification and follow-up onsite corrective action.
17.1-34 Amendment 97-01 August 1997 The Field Review Board is composed of the SCE&G QC Manager as chairman, the SCE&G Nuclear Site Manager, the Daniel Pr oject Manager, the Dani el Project Quality Manager (for ASME Code activities), SCE&G Group Manager, Nuclear Engineering and Licensing, the SCE&G Manager of QA and the SCE&G Group Manager Production Engineering QC and Construction or their designee as permanent members. Other temporary members may be included to lend technical support as the need arises.
Each permanent member designates a replacement to act in his stead in the case he is absent. The Field Review Board reviews major Deficiency and Nonconformance Notices, change requests, stop work orders, and SCE&G QA Corrective Action Request as deemed necessary by its members, and qual ity trend analyses. Through review of these documents overall site quality performanc e is evaluated. Requests for corrective action are made for the purpose of improvements to construction and quality control operations.
The SCE&G QC Group ensures implementat ion of Field Review Board specified corrective action. The SCE&G QC Group also conducts trend analyses of deficiencies and nonconformances for presentation to the Field Review Board, as described in Section 17.1.15.2.
17.1.17 QUALITY ASSURANCE RECORDS 17.1.17.1 Vendor Records The program for control of QA records for NSSS suppliers is described in Reference [1]
and Section 17.1.1.3. In addition, the data packages in support of the Westinghouse Quality Release are forwarded to SCE&G fo r retention and storage at the Virgil C.
Summer Nuclear Station.
The QA specification requires vendors of safety-related items to submit a list of required documentation as a part of the Contractor's QA Identification Report. The SCE&G QA representative then prepares t he list of minimum required documentation based on this submission and transmits it to the vendor for compliance. The required documentation package is forwarded to SCE&G for retent ion and storage at the Virgil C. Summer Nuclear Station.
The following are examples of the minimu m records to be forwarded to the owner:
- 1. NDE reports.
- 2. Material test reports (shall be availa ble for review prior to fabrication).
- 3. Final inspection reports/certificates.
- 4. Performance test reports.
- 5. Code data inspection reports.
17.1-35 Amendment 97-01 August 1997
- 6. Hydrostatic and leak test reports.
- 7. Electrical test reports.
- 8. Design changes/specification deviation requests.
- 9. Radiographs.
- 10. Weld maps and joint history records.
- 11. Verification of wall thicknesses.
The vendor's inspection and test procedures must require documentat ion of results and acceptability, identification of the inspector or data recorder, the type of observation performed, action taken to resolve nonconformi ng conditions, and t he indexing of the documents for ready retrieval. Data re lated to the qualification of personnel, procedures, and equipment used to perform special processes is a part of the vendors records. Document packages bear identific ation of the owner (S CE&G), the owner's purchase order number, and the station name. The vendor must provide secure and fire-resistive or other acceptable storage for the nonreplacable records.
When required by contract documents, the data packages forwarded to SCE&G by the vendor's will include, in addition to QA records specified in procurement packages, a
certificate of conformance, a Certificate of Inspection or Waiver of Inspection provided by SCE&G QA or its agent and an index of the require d documentation, and the documentation.
The existence of requirements for these actions is verified by audit, and their implementation by surveillance by the SCE&G organization, the Gilbert QA Division, or other SCE&G agents, and by audits of data packages onsite conducted by the Site QA organization.
17.1.17.2 Site Controls The preparation and retention of documents onsite is controlled by the QA specification for site contractors and the SCE&G QA Plan and SCE&G QC Procedures. The requirements for inspection and test document preparation are as given in Section 17.1.17.1, above.
During the construction phase the SCE&G QC Group maintains the Plant Numerical Records System, which is the permanent file for QA records at the Virgil C. Summer Nuclear Station. Complete records are maintained covering all aspects of QC activity.
Inspection reports, fabrication and te st procedures, radiographs and other nondestructive examination test reports, and any other documentati on as required by applicable procedures, specifications, codes and standards are retained and handled in accordance with written procedures. Re ceiving record reports, documentation 17.1-36 Amendment 97-01 August 1997 packages and other records are placed in the permanent QA file where they are available for record, information, and QA audit. The storage area affords protection against destruction or deterioration caused by fire, water, humid ity, temperature, tornadoes, insects and rodents as required by the QA and QC procedures and all records are required to be indexed for proper placement and ready retrieval. Access to the permanent files is controlled by the SCE&G QC Group through the site Documents Supervisor, who controls access to the records vault and files.
The SCE&G QC Group inspects equipment data packages against the package index before placement in the Plant Numerical Records System, and directs indexing and placement of the package. The SCE&G QA organization audits these records to assure that data packages are correct and complete.
SCE&G has prepared a Records Accumulation and Retention Chart giving the retention
period for plant records by the type of re cord, and the SCE&G QC procedure for record filing and retention requires t hat the retention requirement s be adhered to. The Chart is revised as necessary to assure adequate identification, accumulation and retention of records. The SCE&G QA audits the site records filing and retention function to assure conformance to the SCE&G QC procedures on QA record filing and retention.
17.1.18 AUDITS The overall SCE&G Audit Program is compos ed of two sources of input, surveillances and audits. In the SCE&G program an audit is normally a broad based multi Appendix B criteria programmatic evaluat ion which considers "could it work" system functionality. Surveillance is normally much narrower in scope (one or several criteria) and is deeper penetrating into examining sufficient evidence of actual work activity (in-process or documentation) to confirm satisfactory resu lts. Extensive system surveillance (system attribute and type II) provide a much sharper, more detailed conclusion of the implementation status and adequ acy of any QA program pr ovided that a series of surveillance is evaluated to cover all applicable criteria. A lead auditor is able to judge QA program compliance and adequacy by a thorough evaluation of surveillance report, corrective action, followup, and quality history. In the most positive case a combination of surveillances may confirm adequacy and impl ementation of a comp lete QA program therefore may, upon evaluation and documentation by a certified lead auditor, preclude the need for audit. In the most negative case, the evaluati on will identify to the lead auditor where further audit activi ty should be concentrated.
17.1.18.1 Internal Audits The internal audit program of Westinghouse is described in Reference [1] and Section 17.1.1.3.
17.1-37 Amendment 97-01 August 1997 The Gilbert Design Control Program incl udes procedures requiring audits of each Project Engineer, Project Management, and the Service Department, using the Gilbert QA Division as a consultant to the Gilbert Utilities Division. These audits are conducted across all Project lines to assure that the Design Control Program is operating successfully. Audits are conducted in accordance with the Gilbert QA Manual procedures with formal written reports transmi tted to Department Heads for resolution, with copies to the Engi neering Manager and Project Manager involved. The Departmental Head response is transmitted to the QA Audit Team Leader for evaluation. When necessary to assure that adequate action is taken in response to audits, reaudit is scheduled during subsequent design control audits.
The SCE&G QA organization conducts audits/surveillances of the SCE&G activities affecting quality to assure compliance with the SCE&G QA Plan, the QA Manual, the Nuclear Engineering Procedures Manual, the Purchasing Procedures Manual, the SCE&G Site QC and Inspection Plan, and the Field QC Procedures Manual. These audits/surveillances are scheduled to cover each area of SCE&G performing safety-related work annually, or as frequently as deemed necessary to ensure that policies and procedures are effective.
The QA specification requires all vendors of safety-related mate rials, equipment, or services to conduct audits to determine the effectiveness of the v endor's QA Program.
A description of the following is required of each vendor:
- 1. The criteria for determining when and at what frequency audits will be performed, 2. The system that will be used to conduct the audits, 3. How the audit findings, corrective actions, and results will be documented and to whom they will be distributed, and
- 4. The titles and duties of persons having responsibility for the audit.
17.1.18.2 External Audits The audit program for suppliers of NSSS mate rials, equipment, or services is described in Reference [1] and Section 17.1.1.3.
Safety-related BOP purchases are made by SCE&G purchase order, and each vendor of safety-related materials, equipment, or se rvices is required to have a QA Program consistent with the complexity and importance of the materials, equipment, or services to be provided. The SCE&G QA organization, or the Gilbert QA Division or other SCE&G QA agents, conduct audits of each of these vendors to assess their program, and evaluate the capability of their vendor evaluation programs, including the audits conducted by the vendors.
17.1-38 Amendment 97-01 August 1997 The SCE&G QA organization conducts audits and surveillance of vendors of safety related materials, parts, components, and services to verify continuing existence of an acceptable QA program. The audits and surveillances are conducted and reports are forwarded to the management of the vendor for response to the deficiencies identified during the audit, and to concerned managem ent within SCE&G. The frequency of audits and surveillance are comm ensurate with the item or service to be provided.
Each vendor which is required to have fo rmal written QA program will be audited at least once during the performance of his work and vendors performing work over an extended period of time will be evaluated at least annually and audited on a triennial basis. Sufficient system surveillance or ot her inspection, testing, and verification defined in 17.1.7.3 will be performed to satisfy the intent of and preclude the need for audit, when properly evaluated and documen ted by a certified lead auditor.
The SCE&G QA organization, or the Gilbert QA Division as agent for the SCE&G organization conducts audits of Westinghouse WRD to determine the effectiveness of the NSSS QA Program. The SCE&G QA organization audits Gilbert to determine the effectiveness of the Gilbert QA Program for BOP design.
Personnel from the Gilbert QA Division acting through the Gilbert Project Quality Coordinator, may participate in or conduc t these audits as agents of the SCE&G QA organization.
The SCE&G QA organization also audits the Gilbert QA Division and Gilbert Project Quality Coordinator to assure that the requirements of the Gilbert QA Program are being applied as described in the Gilbert QA Plan for the SCE&G project.
17.1.18.3 Audit Requirements SCE&G conducts audits under the following r equirements, and requires its agents, the NSSS supplier, contractors, and vendor s to have an audit program applying similar requirements, consistent with the comple xity and importance of the materials, equipment, or servic e being provided.
In all cases, audits are performed by a group which does not have direct responsibility for the area being audited. Audits are conducted in accordance with established procedures by appropriate individuals with the necessary education, training and experience. The areas of design, proc urement, shipping, storage, installation, manufacturing, and construction are audited for conformance to previously established QA requirements which have an effect on product quality. Audits include a review of completed and accepted operations, a review of documentation and records, and an evaluation of the adequacy and effectiveness of QA Program systems. Procedures for audits to be performed by the SCE&G QA organi zation are contained in the SCE&G QA Manual. 17.1-39 Amendment 97-01 August 1997 When required to fully assess a preferred bidder's QA Progr am, a pre-award survey is conducted to determine whether the bidder ha s an effective QA Program. Audits of each vendor or contractor are conducted as frequently as necessary during the term of a contract to determine that an effective QA Program is being appl ied. The frequency of audits is scheduled commensurate with the item or service being provided and the vendor history of supplying quality related items or services.
An SCE&G QA Procedure provides guidelin es and a format for the preparation of reports on audits conducted by SCE&G QA personnel. Program audit results are reported to the management of the organization being a udited and to SCE&G QA management. The organization's QA m anagement in cooperation with SCE&G QA management take appropriate action to ensure corrective action when it is required. The SCE&G QA organization reviews and analyzes pertinent quality assurance reports
and data submitted for information by cont ractors and reports generated by agents of the SCE&G QA organization.
Similar controls on the preparation of audit reports and the forwarding of reports to management are required of vendors and contractors.
17.1.19 REFERENCES 1. "Westinghouse Electric Corporation Water Reactor Division Quality Assurance Plan," WCAP-8370.
- 2. "Nuclear Fuel Division Quality Assurance Program Plan," WCAP-7800.
17.1-40 Amendment 97-01 August 1997