ML20141N853
| ML20141N853 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 03/10/1986 |
| From: | Geiger J HOUSTON LIGHTING & POWER CO. |
| To: | |
| Shared Package | |
| ML20141N847 | List: |
| References | |
| OL, NUDOCS 8603180206 | |
| Download: ML20141N853 (61) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COWISSION BEFORE THE AT0 HIC SAFETY AND LICENSING BOARD In the Matter of HOUSTON LIGHTING & POWER Docket Nos. 50-498 OL COMPANY, ET. AL. 50-499 OL (South Texas Project, Unit I and 2)
AFFIDAVIT OF JAMES E. GEIGER ON ISSUE F
- 1. My name is James E. Geiger and I am Manager, Nuclear Assurance, for Houston Lighting & Power Company ("HL&P"). I testified previously in this proceeding on June 16, 1982, as part of a panel with Mr. Donald Krisha and Mr. Clyde Hawn (Geigert e_t, al,., ff. Tr.10580). My educational background and professional qualifications are described in my previous testimony. Since I testified in 1982, my title has changed to Manager, W clear Assurance. In that position, I am responsible for, among other things, the development of the Quality Assurance program for operation of STP. My assignment as Manager, Nuclear Assurance, permits me to focus exclusively on STP (and frees me from responsibility for HL&P's non-nuclear QA programs). The purpose of my Affidavit is to address Issue F, which states:
Will HL&P's Quality Assurance Program for Operation of the STP meet the requirements of 10 C.F.R. Part 50, Appendix B7 8
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- 2. The QA program for operation of STP is described in Section 17.2 of the FSAR, a copy of which, as amended through Amendment 52, is included as Attachment'A to this Affidavit. Attachment B identifies the changes to Section 17.2 which are currently planned and will be incorporated in a future amendment to the FSAR. The HL&P corporate QA policies, commitments, and general criteria and requirements for quality related activities during operation are contained in HL&P's Operations QA Plan (0QAP). The OQAP is, in turn, implemented by procedures that provide detailed instructions to employees performing quality related work. The current version of the OQAP has been in effect since May 1984 with only three minor revisions since that time.
- 3. The QA organirstion planned for operation of STP will be comprised of an Operations QA Division and a Technical Services Division and is depicted in Attachment C to this Affidavit. The QA organization and the Vice President, Nuclear Operations, both report to the Group Vice President, Nuclear. Thus, the Operations QA organization reports to a Management level above that which is directly responsible for power production, and is not a part of Operations. I
- 4. The Operations QA Division is headed by an Operations QA Manager, Mr. John Green. Mr. Green has 22 years of nuclear QA/QC experience with General Dynamics Electric Boat Division, Bechtel Corporation, Gilbert Associates, Inc., Pennsylvania Power & Light Company (PP&L), and HL&P. At PP&L, he was responsible for the Operations QA activities for the i
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Susquenarna Nuclear Project. His certifications include Lead Auditor (ANSI N45.2.23), Level III Surveillance, and Level II NDE for various non-destructive testing techniques. He is a registered Professional Engineer in California.
- 5. The Operations QA Division consists of the Quality Systems, Quality Engineering, and Quality Control groups. The Division is dedicated to day-to-day verification of startup, operation, maintenance, and other activities directly associated with operation of the nuclear units.
Verification of other activities, such as design, procurement, and modification activities conducted during outages, are the responsibility of the Technical Services Division which is described in paragraphs 7-9 below.
The purpose of this organizational structure is to permit the Operations QA Division to focus exclusively on day-to-day verification of operational activities and to free it from responsibility for monitoring activities not directly associated with operation of the nuclear units.
- 6. The Quality Systems group is responsible for trending all deficiency documents, tracking deficiencies through verification of completion of corrective action, developing and controlling the OQAP and QA procedures, maintaining personnel training and certification records, and sunmarizing and reporting results of activities of the QA organization to executive management. The Quality Engineering group reviews quality-related documents and procedures, conducts audits and surveillance of quality-related site activities, and reviews plant modifications performed by the Nuclear Plant Operations Department (NP00). The Quality Control group 3
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develops inspection procedures, conducts inspections of purchased material, Startup, Operations, and Maintenance activities, and reviews quality-related procedures and work documents for appropriate hold and verification points.
- 7. The Technical Services Division is responsible for QA planning and monitoring for design and procurement activities for operation and installation of major modifications. The Technical Services Manager will possess a B.S. in science or engineering (or comparable education and experience), have at least 5 years of management or supervisory experience with nuclear facilities, and at least 10 years QA experience. At the present time, Technical Services consists of a vendor Evaluation /
Surveillance group -- which performs vendor related activities -- and the Design / Procurement group -- which reviews design and procurement documents and performs surveillance of design and procurement activities conducted by H.&P or its contractors.
- 8. Prior to fuel load of Unit 1, the Technical Services Division will include Design / Procurement, Vendor Control, Quality Engineering, and Quality Control functions.
- 9. The Design / Procurement group will continue to perform its current functions but its scope will increase as the responsibility for design and procurement is transferred to H_&P. The Vendor Control group will review vendor quality programs and perform audits and surveillance of vendor activities. The scope of the Vendor Control group's effort will 4
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[' increase as the responsibility for design and procurement is transferred to
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E.AP. The Quality Engineering (QE) group will assure that audits, surveillance, and document reviews related to outage and modification L activities conducted by contractors are performed._ The Quality Control
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(QC) group will manage the inspection effort related to such activities.
Since no such activities are presently being conducted, the QE and QC groups will be created prior to fuel load of Unit 1.- As construction activities H
! continue, personnel within the present Project QA organization (currently I performing construction-related QA functions) will be assigned to staff -
these groups as well. Upon completion of Unit 2, the Project QA l organization will be phased out.
I j 10. The current professional staffing of the Operations QA organization is 45 persons, including 35 in the Operations QA Division and l
! 10 in the Technical Services Division. When fully staffed for two unit
! operation, there will be 44 persons in the Operations QA Division and 16 I
L persons in Technical Services. Almost all managers and supervisors have
! been designated and most of the remaining positions to be filled are staff j level positions.
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l 11. Through their involvement in the activities of the Startup and Nuclear Plant Operations Departments (NP00), the Operationc QA organization is acquiring considerable experience and familiarity with plant equipment, personnel, requirements, and procedures. That experience has been enhanced through the audit, surveillance, inspection, and document l
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review related to activities that are currently underway. These activities will increase as the Project progresses toward operation. In particular, QA personnel have been engaged in auditing and surveillance of Startup activities, witnessing of tests, and review of Startup procedures and test results. QA personnel have also been engaged in auditing and surveillance of activities being performed by the NPOD and by other departments that will support plant operation, as well as review of procedures to be used during operation.
- 12. All employees associated with STP whose activities affect quality currently receive QA indoctrination training presented by the Nuclear Training Department. The QA indoctrination training covers the purpose, policies, and principles of the QA program and the roles and responsibilities of individuls performing activities which affect quality.
Since training for operation of STP must cover other non-QA-related topics (such as security, radiation protection, and energency planning), the General Employee Training (ET) Program will replace the existing QA indoctrination training. The ET Program (which is also presented by the Nuclear Training Department) covers the purposes, policies, and principles of the QA Program for operation of STP and the roles and responsibilities of individuals performing activities which affect quality. In addition, individuals with quality-related responsibilities are required to be familiar with applicable procedures and other quality-related documents. QA personnel attend training on applicable QA procedures and are required to be familiar with applicable QA program documents, industry codes and standards, and regulatory requirements. .
- 13. Management level personnel in the Operations QA organization must have QA experience aad preferably a degree in engineering or science and must be knowledgeable in nuclear power operations and maintenance.
Persons performing inspections will be qualified and certified based on education and experience in accordance with Regulatory Guide (Reg. Guide) 1.58 (1980), ANSI N45.2.6-1978, and as applicable, SNT-TC-1A-1980 (for TOE personnel). Persons performing audits will be qualified and certified based on education, work experience, training, on-the-job performance, and audit participation, in accordance with Reg. Guide 1.146 (1980), and ANSI N45.2.23-1978. Other persons with training or experience commensurate with the scope, complexity, or special nature of the activities to be audited may also assist in audits. Although there is no NRC requirement or industry standard governing qualification or certification of persons performing surveillance, R.&P requires that such persons possess education und experience levels comparable to the requirements of ANSI N45.2.6 for inspection personnel. Certification programs require annual evaluation of personnel performing activities requiring certification to ensure that such personnel remain qualified to perform such activities. Retraining and requalification, as appropriate, are provided.
- 14. In CCANP's Answers to Applicant's Eighth Set of Interrogatories and Requests for Production of Documents (pp. 2-3), CCAPP states that the basis for its contention that HL&P will not implement the QA program for operation of STP in accordance with 10 C.F.R. Part 50, Appendix B, is an anonymous telephone call in which it received allegations regarding an HL&P investigation into the use and sale of illegal drugs at the Project 7
and HL&P efforts to " protect the Operations Group personnel" who were allegedly implicated in such drug use. Appendix B to 10 C.F.R. Part 50, and the Reg. Guides, Standard Review Plan provisions and ANSI standards which contain requirements and criteria for nuclear QA programs do not mention drug use or require programs relating to drug use. Neither do they provide guidance on disciplinary actions to be taken with respect to employees found to be involved in the use or sale of illegal drugs. Therefore, while HL&P has implemented various programs relating to drug use which will continue to be in effect during operation of STP (n, HL&P's Fitness for Duty Program and its Drug and Alcohol Abuse Screening Program), thnse programs are not required by Appendix B nor administered or monitored by the Nuclear Assurance Department. In my more than 27 years of experience in Quality Assurance, including 10 in the nuclear industry, I have never encountered an Appendix B Quality Assurance program that contained provisions regarding the control of the use of illegal drugs by employees.
- 15. Section 17.2 of the FSAR (Attachment A), as modified by Attachment B, describes the QA program for operation of STP including the manner in which the program will meet each of the 18 criteria of Appendix B.
Attachment C depicts the organization of the Nuclear Assurance Department as it will be revised prior to fuel load, as described in paragraphs 5-9 above.
I have reviewed Attachments A, B, and C; and, taken together, they are true and correct to the best of my knowledge and belief.
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- 16. In my professional judgment, the QA program for operation of STP meets the requirements of 10 C.F.R., Part 50, Appendix B.
County of Matagorda i ss.
State of Texas I, James E. Geiger, being duly sworn, certify that I am familiar with the statements contained herein and they are true and correct to the best of my knowledge and belief.
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Subscribed and sworn to before me this /C day of March, 1986.
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ATTACHMENT A STP FSAR 17.2 QUALITY ASSURANCE DURING THE OPERATIONS PHASE Houston Lighting & Power Company (HL&P), as a licensee and as Project Manager for itself and the other owners, has the Quality Assurance (QA) responsibility for design, engineering, procuren.ent, fabrication, construction, maintenance, repair, inservice inspection, refueling, modifications, testing, and operation of the South Texas Project Electric Generating Station (STPEGS).
ML&P's Nuclear Quality Assurance Program requires that HL&P, its prime con-tractors, subcontractors, and vendors comply with the criteria established by 10CFR Part 50 Section 50.55a; 10CFR Part 50. Appendix A, General Design Cri-terion 1; and '10CPR Part 50, Appendix B. It is the intent of HL&P to comply, as defined herein, with ANSI N45.2 and the applicable daughter standards, ANSI N18.7, and implementing Regulatory Guides as defined herein and FSAR Table 3.12-1.
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The HL&P QA Program is defined by the Operations QA Plan. The Operations QA Plan is further augmented by implementing procedures to provide HL&P with the assurance that its quality commitments are met. The QA program described by the Project QA Plan for design and construction activities will be implemented until these activities are complete or the Operations QA program is effective-ly assuring the quality of these activities.
17.2.1 Organization-17.2.1.1 Authorities and Duties.
17.2.1.1.1 Nuclear Assurance (NA) Denartment: The organization l 48 primarily responsible for establishing and executing.the HL&P QA Program, 1 42 which includes QA for fire protection, is EL&P QA. l 48 !
The QA organization during operation is shown in Figure 17.2-1. The size of the QA organization, including the inspection staff, is based on the antici-pated QA/QC involvement in operation and maintenance activities and by a sur- -
vey of site QA staffs of other utilities with nuclear power plants in opera-tion. 42 Individuals responsible for performing the QA functions, assuring the QA pro-gram is established and executed, and verifying that an activity has beau
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correctly performed are as follows:
Manager. Nuclear Assurance 48 i
The Manager, MA, is responsible for the development of the QA Program. The Manager, NA, has the authority to-identify, initiate, recommend, or provide solutions to quality related problems and verify the implementation and effec-- 42 tiveness of the solutions. This position has the independence to conduct i
QA/QC activities without undue pressure of cost or schedule. The Manager, NA, l 48 "
has the authority to "stop work" for cause in engineering, design, procure-ment, fabrication, modification, preoperational testing, and operations phases 42 of the nuclear plant.
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17.2-1 Amendment 48
STP FSAR o The Manager, NA, reports to the Group Vice President, Nuclear, who has overall responsibility for Quality Assurance at STPEGS. The position of Manager NA, 48 is on the same or higher organiratien level as the highest line manager re-sponsible for performing activities affecting quality as shown in Figure 17.2-2. 42 The Manager, NA, reviews and approves the Operations QA Plan, and changes 48 thereto. Final approval is provided by the Group Vice President, Nuclear.
Safeteam Mananer The Manager of the Safeteam department is responsible for the investigation of employee concerns.
The Safeteam Manager reports to and receives direction from the Manager, NA. -~
42 Ooerations Ouality Assurance (OA) Mananer The Operations QA Manager is casponsible for assuring that an adequate QA program is developed and implemented for safety-related systems, components, structures and activities at STPEGS. These responsibilities commence upon completion of construction of the equipnent or system and turnover to the Startup group (Release for Test (RFT)). l 48 The Operations QA Manager has the independence to conduct QA/QC activities without undue pressure of cost or schedule and is free from non-QA duties to 42 assure that the Operations QA program is being implemented.
The Operations QA Manager reports to and receives technical direction from the Manager, NA.
Ooeratiens Ouality Assurance (QA) General Suoervisor 48 The Operations QA General Supervisor is responsible for verifying compliance with all quality-related manuals and procedures which are implemented for the STPEGS through planned and systematic audits and surveillances. These activi- 42 ties are entirely related to QA and free from non-QA duties.
The Operations QA General Supervisor reports to and receives technical and l48 administrative direction from the Operations QA Manager.
44 Ooerations Ouality Control (OC) General Supervisor 48 The Operations QC General Supervisor is respopsible for geordinating inspec-tion of selected fabrication, construction, modification, maint enance, testing
'and material receiving activities, ensuring proper nonconformance identifica-tion and assuring that the personnel perfora.ing inspections are properly cer- 42 tified. These activities are entirely related to QA and free from non-QA activities.
The Operations QC General Supervisor repos ts to and receives technical and l 48 administrative direction from the Operations QA Manager.
17.2-2 Amendn'ent 48
STP FSAR Technical Services General Sunervisor 48 is responsible for performing ven-The Technicalvendor dor surveillance, Services audits,General and relate Supervisor [d activities as reques Operations QA Manager. 47 The Technical Services General Supervisor reports to and receives technical and administrative direction from the Manager, NA.
Pro inc t OA Sunervisor Desien and Procurement 48 The Project QA Supervisor Design and Procurement is responsible for the QA' activities associated with Design and Procurement and reports to the Opera-tions QA Manager for those functions performed utd ar the auspices of Operation QA Plan. .,_
17.2.1.1.2 Nuclear Plant Ooerationj Department: The Nuclear Plant Operations Department is responsible for all aspects of the nuclear plant post-fuel load testing, operation, and maintenance including Radiation Protec-tion and Fire Protection Programs.
42 Vice President . Nuclear Plant Onerations The Vice President Nuclear Plant Operations is responsible for staffing STPEGS with qualified personnel and acquiring and coordinating the assistance of internal and external organizations for the testing, startup, operation, and maintenance of STPEGS.
The Vice President, Nuclear Plant Operations reports to the Group Vice Presi- 46 dent, Nuclear.
Plant Mananer The Plant Manager has prime responsibility for the safe operation of the -
STPEGS. The plant staff, under the direction of the Plant Manager, develops detailed procedures and instructions for testing, operation, and maintenance.
The Plant Manager is responsible for emergency preparedness and radiological g monitoring of the STPEGS.
In addition, disputes over corrective action taken in response to conditions i adverse to quality are normally resolved by the Plant Manager. Should this resolution not be satisfactory, the disputing parties may take the matter to higher management for resolution.
The Plant Manager reports to the Vice President, Nuclear Plant Operations.
17.2.1.1.3 Noelear Enninegina and Construction Departments: The Nu-clear Engineering and Construction Departments are responsible for the design l 46 engineering, design control, cocotruction, prerequisite testing, preoperation- g al testing, records management, and nuclear fuel' management.
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17.2-3 Amendment 48
4' STP FSAR Muclear v.. inee rine and Construction Denartments 46 The Group Vice President, Nuclear. is responsible for design engineering, con-struction, modification, and design reviews for STPECS. In addition, the )42 Group Vice President, Nuclear is responsible for plant licensing activities. l48 nuclear fuel design, fuel acquisition, and fuel management and for providing a l42 records management system. ,
1 Manamer. Enaineerina l46 .
The Manager, Engineering, is responsible for coordinating design engineering, construction, and modification tasks, and design reviews for STP.
i The Manager, Engineering, reports to the Group Vice President, Nuclear.
17.2.1.1.4 Purchasine and Services Denartment: The Purchasing and Services Department provides for the procurement and storage of equipment, material and services for STPEGS.
Vice President . Purchasine and Services The Vice President, Purchasing and Services is responsible for the procurement of equipment, material, and services including the coordination of procurement document review, and receipt, handling, and storage of equipment and materials 42 at STPEGS.
The Vice President, Purchasing and Services reports to the Group Vice Presi-dent. Aduinistrative.
17.2.1.1.5 Security Division: The Security Division is responsible for the development and coordination of security practices and procedures for the company, and advising and assisting heads of company facilities in the estab-h lishment and maintenance of physical security at STPEGS.
i- Director of Security
- The Director of Security is responsible for the development of the security ,
program, for providing security services, and for administration of the Site Access Authorization Program.
The Director of Security reports to the Group Vice President, Administrative.
17.2.1.1.6 Personnel Relations Division: The Personnel Relations Divi-sica screens HL&P employees in conjunction with the Site Access Authorization Program.
Mm===ar. Personnel Relations The Manager, Personnel Relations is responsible for supporting the Site Access Authorization Program in the screening of HL&P employees.
The Manager, Personnel Relations reports to the Vice President, Human
- Resources.
17.2-4 Amendment 48
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. STP FSAR 17.2.1.2 Establishina Policies an als. QA policies and goals for l 42 HL&P are defined in the Operations QA pfan. The Group Vice President, Nuclear, who has overall responsibildy for Quality Assurance, will review and , 46 approve the Operations QA Plan and all revisions. g The Manager, NA, is responsible for the development of the QA Program. The l 48 minimum requirements established for this position are:
- 1. A bachelor degree in science or engineering, or an equivalent combina-tion of education and experience.
- 2. Five years experience in the management of quality assurance. Fifteen years experience in industry quality assurance standards, and federal and state regulatory requirements.
- 3. Familiarity with nuclear power generation facilities and the related operations.
- 4. Knowledge of the industry's quality assurance standards and regulatory requirements.
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- 5. Management experience and familiarity with HL&P corporate organizations.
The departmental procedurec and revisions which control the quality-related work performed by HL&P organizations described in Section 17.2.1.1 will be reviewed by the Operations QA Manager or his designee.
17.2.1.3 Ormanizational Independence. The reporting arrangement uti-lized by the QA Department ensures that those personnel charged with responsi-bility for verifying compliance with QA Program requirements have the organ-izational freedom to:
- 1. Identify quality problems.
- 2. Initiate, recommend, or provide solutions. '
- 3. Verify implementation of solutions.
The reporting arrangement, as illustrated on Figure 17.2-2, is such that per-sonnel responsible for verifying compliance with quality requirements do not have direct responsibility for the performance of the work being verified and report to the Operations QA Manager.
The Manager, NA, has the authority to "stop work" for cause in engineering. l 48 design, procurement, fabricacion, modification, testing and operation a,. tivi- l 42 ties. This authority in QA matters has been granted by the Group Vice Presi-dent, Nuclear.
The Manager, NA, provides technical and administrative direction to the Opera-tions QA Manager and the Technical Services General Supervisor. 48 The Operations QA Manager provides technical and administrative , direction to l 42 the Operations QA General Supervisor and the Operations QC General Supervisor. l 48 17.2-5 Amendment 48
STP FSAR As further described in Section 17.2.4, the QA program provides for a review i
of procurement documents, including contracts and subcontracts. This review ensures that the procurement documents include a requirement that suppliers of
, safety-related materials or services have a quality program commensurate with the scope of the purchase order and when required, submit a copy of their QA i program for review and approval by HL&P. The submitted QA manual or program description is reviewed for compliance with HL&P's QA program requirements; one of these requirements is that the contractor or subcontractor's QA group has sufficient organizational freedom to identify and follow up on problems.
17.2.1.4 Delemation of QA Functions. The entire HL&P QA program for
'~ perations o will be established by HL&P personnel. During normal operations, the QA program will be executed by.HL&P personnel who may be assisted by sub-contract personnel. During startup, refueling, maintenance, and inservice inspection, first-level quality control inspection and nondestructive examina-tion (NDE) activities may be subcontracted. However, HL&P will retain respon-
- sibility for the total QA program, and HL&P QA personnel will perform audits and surveillance (s) of subcontracted QA activities.
When first level quality control inspection and nondestructive examination are performed by HL&P personnel, the personnel shall be qualified and certified in accordance with applicable codes, standards, procedures, and other regula-tions. Monitoring and surveillance of the quality control and nondestructive examination activities shall be performed by Operations QA personnel.
17.2.2 Quality Assurance Program 17.2.2.1 QA Progras. EL&P has established the Operations QA Program 42 for the operations phase of the South Texas Project Electric Generating Station (STPEGS), which includes prerequisite, preoperational, and startup testing, operation, maintenance, refueling, inservice inspection, and modifi-cation. The HL&P QA Program for the operations phase complies with 10CFR Part 50, Secti n 50.55a; 10CFR Part 50, Appendix A, General Design Criterion 1; 10CFR Par 6 1. Appendix B; and, the regulatory guides and standards listed in Table 3.12-1. Appendix B criteria are satisfied as described in Section 17.2.
- Section 17.2.1 identifies the organizations responsible for implementing the 1
QA program. Each criteria in Chapter 17.2 further defines the organizational I responsibilities for implementing specific criteria requirements.
. 17.2.2.2 Identification of Safety-Related Items and Services. The HL&P QA Program described herein is applied to all activities affecting the safety-related functions of those structures, systems, and ensponents which prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of tie public. These safety-related structures, systems, and components coctrolled by the QA program are listed in Section 3.2, along with their associated fire protection sytteas.
The fire protection program is part of the overall HL&P QA program and is therefore under the management control of QA. Fire protection QA program i
17.2-6 Amendment 48
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STP FSAR criteria are being implemented as part of the EL&P @ Program under 10CPR50, Appendix B. /
In addition, expendable or ccasumable items necessary for the func.tional per-formance of safety-related structures, systeza, and components are subjected to quality assurance requirements as specified in written procedures. These procedures include provisions for review and control in accordance with indus-try standards and opecifications and the safety-related function of the ex-pendable or consumable item.
17.2.2.3 Develoosent of the QA Proeram. The Operations @ Progres
- shall be fully implemented 90 days prior to initial fuel loading. The @
Program shall be implemented throughout the operating life of the STPEGS.
Activities, prior to full @ Program implementation, shall be controlled by -
procedures developed and implemented prior to the performance of the activity.
These procedures shall be reviewed, approved, and controlled in accordance with Sections 17.2.5 and 17.2.6.
17.2.2.4 QA Pronram Documents. The @ Program shall be implemented with plans, procedures, and instructions to ensure effective control of all quality activities. The relationship of various manuals is shown on Figure 17.2-3.
Figure 17.2-3 lists the typical procedures that will be developed to implement 42 the @ Program. Provisions for procedure consolidation, separation, dele-tions, additions, or minor program changes do not permit including a complete listing of implementing procedures.
17.2.2.5 Policies and Goals. It is the policy of RL&P, acting as a licensee and Project Manager for the other owners of the South Texas Project Electric Generating Station (STPEGS), to assure that the design, procurement,
, construction, testing, and operation of the STPEGS are in conformance with specifications, procedures, codes, and NRC regulations. It is the responsi-
- bility of. each organisation supporting the STPEGS to ensure that the require-l ments stated in this quality assurance program are incorporated into proce-dures. Adherence to those procedures is mandatory for all EL&P organisations and for all contractors or vendors providing items or services covered by the
@ program.
The Operations @ Plan identifies activities and establishes requiremerts for
, procedures which identify, initiate, and verify the resolution of safety-related quality problems. The implementing procedures call for the resolution of quality problems at the lowest possible authorized level.
i However, if a dispute is encountered in the resolution of a quality problem which cannot be resolved at lower levels, the Manager, Nuclear Assurance, l 48 presents the problem to the Group Vice President, Nuclear, for resolution.
42 17.2.2.6 Personnel Indoctrjaggion and Training,. General indoctrination 49 and training programs shall be provided for the general office and plant site Q260.
personnel to assure that they are knowledgeable regarding quality programs and 56N requirements. The requirements for training ML&P personnel are described in Section 13.2 The training of plant operating personnel is the responsibility l 42 17.2-7 Anendment 49
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1 of the Nuclear Training Department. Records of training shall be maintained to demonstrate compliance with the qualification requirements. Personnel performing complex, unusual, or potentially hasardous work shall be instructed 1
in special indoctrination or briefing sessions. Emphasis shall be on special requirements for safety of personnel, radiation control and protection, unique features of equipment and systems, operating constraints, and control requirements in effect during performance of work. Where required by codes and standards, personnel are trained, qualified, and certified according to written procedures in the principles and techniques of performing specific activities described in Sections 17.2.9.17.2.10,17.2.11 and 17.2.18 to ad-dress audit activities.
Personnel performing surveillance testing activities shall be similarly trained in accordance with written procedures.
l Training will be conducted in a time frame adequate to allow personnel to -
prepare for their job responsibilities and prior to commencing safety-related work. Proficiency of personnel shall be maintained by retraining, re-examining and/or recertifying in accordance with requirements and proce-42 dures which control initial training, examining and certifying.
In addition to general employee training and indoctrination described above, departmental and Training Department Procedures provide for training of per-sonnel who perform quality-related work. These procedures provide for train-ing in the principles and techniques of the activity involved and for mainte-nasce of proficiency of personnel by retraining, re-examining, and/or recerti-fying to an extent commensurate with the safety significance of the activity.
The procedures address documentation of:
- 1. Scope, objective, and method of implementing the training progrse.
- 2. Date and content of the training sessions, attendees and results where appropriate.
17.2.2.7 Control of Activities. The Operations QA Plan requires the QA review and/or approval of procedures which control safety-related activities.
i The procedures shall require the use of the proper equipment, completion of prerequisites for starting an activity, and suitable environment for perform-ing the activity. Procedures will comply with the appropriate standards pre-
- scribed for such safety-related activities.
QA personnel will attend planning, scheduling and status meetings affecting safety-related activities as necessary to assure adequate QA coverage and program application exists.
17.2.2.8 Manamement Revigs. The implementation of the QA program re-quirements shall be verified through independent sad integral control activi-
! ties. The QA Organisation under the Manager, MA, shall conduct audits, sur- l48 1 veillances, and inspectior.s of the operating plant and of the interfacing ;
organi.sations' quality-related activities. 42 i i
The results of the audits, surveillance, and inspection activities shall be presented in a periodic report to the Croup Vice President, Nuclear. The l 46 l I
17.2-8 Amendment 48
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Group Vice President, Nuclear, assures that an objective program assessment of l42 the STPEGS QA Program is being performed.
1 Management assessments shall be conducted to assess EL&P's implementation of 46 the Operations QA Program. These assessments will be conducted by organiza-tions independent of the activities performed. The Group Vice President, Nuclear, shall define the scope of the assessment and determine the schedule.
The results of these assessments are transmitted to the Group Vice President, Nuclear.
EL&P may use the services of architect-engineer firms NSSS suppliers, fuel fabricators, constructors, and others which provide or augment EL&P's efforts during the operational phase. These organizations shall be required to work under a QA program to provide control of quality activities consistent with the scope of their assigned work. The QA programs of such contractors or --
consultants shall be subject to review, evaluation, and acceptance by QA prior i to initiation of activities affected by the program. 42 17.2.2.9 System Turnover. Construction activities will be controlled
, by the STPEGS QA Program Description. The Construction Manager has been '
assigned the responsibility for developing procedures for the control of l 1
system turnover. These procedures, the EL&P Startup Manual, and the Opera-tions QA Plan shall control system release for test, phasecut of construction i activities and turnover of plant systems for operations. i 17.2.2.10 FSAR Channes. EL&P is committed to maintaining the FSAR as 49 !
an effective and meaningful document to provide programmatic direction on Q260. .[
STPEGS. Changes to the QA program, as described in the PSAR, will be pro- SON cessed in accordance with 10CFR50.54(a).
When changes are made to the organizational elements only in the FSAR, appro-priate notification will be made to the NRC within 30 days of implementation.
! 17.2.2.11 Connuter Code Proarams. The development, control, and use of computer code programs which affect safety-related items will be conducted in !
accordance with the Operations QA Plan. Prior to use of a computer code pro-
- gram in a safety-related activity, the appropriateness of the program to the activity shall be verified. In additional, all such programs shall be appro- ,
priately certified for use. l 42 17.2.3 Design Control l
l 17.2.3.1 Desian Centrol Measures. Procedures shall be established to
- control the preparation and review of design documents. These procedures I
shall ensure that design activities provide the correct translation of regula-tory requirements and design bases Lato specifications, drawings, written procedures, instructions, and other design documents.
i I
Design requirements and changes thereto shall be Identified, documented, re- i viewed, and approved to assure incorporation of appropriate quality standards in design documents. Design requirements and quality standards shall be de-i scribed to an appropriate level of detail in designieriterial Any exceptions l cs...
17.2-9 Amendment 49 w---, , , . , - - + - - - - . - , y,w., ,, --.-ge-s-
to quality standards will be documented. Design \criterid for modification to '
structures, systems, and components shall include the design bases described in the FSAR. Design \gj;igggig shall be reviewed by QA for seismic and quality 4
\ group qualityclassification, standards for selection of quality standards, and deviations from acceptability.
. 17.2.3.2 Anolication Review. A review for application suitability of materials, parts, equipment, and processes that are essential to the functions of safety-related structures, systems, and components is done as part of the design document preparation and review process. The procedures which govern l the preparation and review of design documents require the use of valid industry standards and specifications in the application suitability review.
Review of standard "off the shelf" commercial materials, parts, and equipment l
- for suitability of application with safety-related structures, systems, and components will be conducted prior to selection. __ ,
2 ~17.2.3.3 Desian Process. Design activities involving reactor physics;
- stress, thermal, hydraulic, and accident analysis; materials compatibility; and accessibility for maintenance, inservice inspection, and repair will be performed according to approved procedure by appropriately qualified individu-als. Results of analyses will be appropriately verified and documented.
4 Delineation of acceptance criteria for inspections and tests will be specified by procedure. All such acceptance criteria will satisfy the requirements of applicable standards or be approved by appropriately qualified individuals.
17.2.3.4 Desien Review and Verification. The design process shall include design verification by qualified persons to assure that the design is 42 adequate and meets specified design input. Design control procedures shall 1
specify requirements for the selection and performance of design verification.
Design verification shall be either by design review, alternate calculation, qualification testing, or by a combination of these. The depth of design i verification shall be commensurate with the importance of the system or compo-nent to plant safety, complexity of the design, and similarity of design to
- previous designs.
If verification method is performed only through qualification testing, the following requirements shall be met:
- 1. Procedures shall provide criteria that specify when verification should be by test.
- 2. Prototype, component, or feature testing shall be performed as early as possible prior to installation of plant equipment, or prior to the point when the installation would become irreversible.
4 3. Verification by test shall be performed under conditions that simulate the most adverse design conditions as determined by analysis.
~
Procedures shall identify the responsibilities of the verifier, the features to be verified, and the documentation required. Design verification shall be
- performed by qualified verifiers who are not directly responsible for the design or the design changes. However, in unusual cases the designer's 17.2-10 Amendment 48
STP FSAR supervisor may perform the verification if the supervisor is the only techni-cally qualified indiviuual and the need for the supervisor to perform the review is approved an6 documented in advance by the supervisor's management.
Design verification will normally be performed prior to release for procure-mene, manufacture, installation, or use by another organisation in other de-sign setivities. Prceptions shall be justified and documented. Procedures shall en trol the justification of exceptions and the completion of the veri-fication of all affected design output documents, prior to relying on the com-ponent, system, or structure to perform its function.
Design' analyses shall be sufficiently detailed as to purpose, method, assump-tions, design requirements, references, and units to permit an independent review by a technically qualified person. Computer codes shall be verified to be' certified for use, and it shall be verified that their intended purpose is _
, specified.
Procedures shall identify that design documents are reviewed by QA to assure that the documents are prepared, reviewed, and approved in accordance with procedures; that design documents describe the extent of documentation required; and that adequate acceptance criteria for inspection and tests are }
, included.
Procedures shall control the action to be initiated to resolve design errors and deficiencies that could adversely affect safety-related structures, sys-tems and components and assure that changes are controlled. The actions taken to prevent recurrence of the error shall be documented.
17.2.3.5 Desien Interfaces. The design interfaces between organiza-l tions shall be identified and controlled under the Operations QA Plan and ;
- procedures which shall address the division of design responsibility among the STPEGS plant staff, Nuclear Engineering and Construction, and contractors.
Procedures shall specify the lines of communication ar.d distribution of design information. Procedures shall identify the organisations responsible for design reviews and approval for each design organisation. Procedures shall ;
control the release and distribution of design documents to prevent the inad- -
vertent use of superseded design information. ,
17.2.3.6 Desien Ch===es. Changes to the plant design may be necessary to correct operational deficiencies, incorrorate improvements, or to comply with new regulatory requirements. Procedures shall specify requirements for ;
the review and/or approval of design changes by the organisations that re- ,
viewed and/or approved the original design. Design control activities may be delegated to others provided they have access to pertinent background and technical information. Design changes, including field changes wi21 he sub-ject to the same design controls that were applied to the original design.
Design changes 'shall be communicated to appropriate plant personnel. Design ,
- l. changes will be checked against as-built drawings prior to closing out the design change process.
l l
i
! 17.2-11 Amendment 48 !
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STP FSAR 17.2.4 Procurement Document Control 17.2.4.1 Procurement Document Content. Procurement document control measures shall assure that appropriate regulatory requirements, design bases, and other requirements are included in the procurement process. Originating and reviewing organization procedures shall require that the following be included _or invoked by reference in procurement documents as appropriate:
- 1. Applicable regulatory, code, and design requirements, including applica-ble material and component identification requirements, drawings, speci-fications, standards, inspection and test requirements, special process instructions and handling, preservation, cleaning, storage, packaging and shipping requirements. These requirements shall equal or exceed the original requirements and be sufficient to preclude repetition of de-facts. __
ss 2. Extent that supplier QA program shall comply with 10CFR50, Appendix B, and the QA program requirements of other nationally recognized codes and standards, as applicable.
ss 3. Requirements for supplier documents, such as instructions, procedures, drawings, specifications, inspection and test records, and suppliers' QA records to be prepared, submitted, or be made available for HL&P review or approval.
x 4. Requirements for HL&P's right of access to supplier's facilities and work documents for inspection and audit.
'N 5. Requirements for extending apnlicable HL&P procurement requirements to 42 lower-tier suppliers and subcontractors, including HL&P's access to facilities and records.
- 6. Requirements for supplier reporting to HL&P nonconformances to procure-ment document requirements and conditions for their disposition.
! s 7. Requirements for the retention, control, and maintenance of supplier QA records. Supplier-furnished records shall include:
- a. Documentation that identifies the purchased item and the specific procurement requirements (e.g., codes, standards, and specifica-tions) met by the item.
- b. Documentation identifying any procurement requirements that have not been mat.
l
- c. A description of those nonconformances from the procurement re-quirements dispositioned " accept .a is" or " repair."
l l
- 8. Requirement for the supplier to submit a copy of its QA program descrip-
, tion.
I
- 9. Requirements for the performance of maintenance receipt inspection checks where applicable.
l l
l 17.2-12 Amendment 48 L
- 10. Applicability of 10CFR21, Reporting Requirements.
Review of purchasing documents by QA personnel shall verify that quality requirements are correctly stated, verifiable, and controllable; that acceptance / rejection criteria are included; and that the documents have been prepared, reviewed, and approved in accordance with HL&P's QA program require-ments.
17.2.4.2 Procur== ant Document Frenaration and Review. Responsibility
- for procurement is a joint effort of all the departments within the Nuclear Group. The department requesting the material or source provides technical content. QA reviews the request for quality requirements and the Purchasing and Services Department is responsible for commercial provisions.
The sequence of preparation, review, approval, and issuance of procurement ~~
documents is generally as follows:
i
- 1. Purchmae Reaufsitions Furchase Requisition forms shall be used to initiate the procurement of safety-related materials, parts, components and services. Procurement may be initiated by any Nuclear Group Department or Stores Department personnel.
Purchase Requisitions shall include material and component identifica-tion ~ requirements, drawings, specifications, inspection and test requit e-meats, and special process instructions as appropriate. Commercial 4 '3 items shall rely on proven design and utilise verification methods by -
the purchaser in lieu of supplier controls.
Purchase Requisitions for safety-related materials, parts, components, or services shall be reviewed by the cognisant technical organisation and QA personnel to verify that adequate technical and quality require-i ments, respectively, have been specified. The reviews for technical and quality requirements shall be performed by someone other than the origin-ator of the requisition.
- 2. Purch==e Orders ==A Contracts Purchase Orders and Contracts are prepared and issued by the Purchasing l and Services Department, and establish fer the suppliers the technical and quality requirements which must be met. These documents also estab-lish the commercial conditions for the procurement action.
Purchase Orders and Contracts shall accurately reflect the technical and t quality requirements established by the Purchase Requisition. If during
! the bid negotiations with the supplier it becomes necessary or commer-I cially desirable to change the technical or quality requirements, such
- changes shall be presented to the cognizant technical organization which l approved the original requirements for approval.
- 3. Channa Controls Additions, modifications, esceptions, and other changes to procurement document quality and technical requirements shall require a review and 17.2-13 Amendment 48 l
I
. -- . _ - - . = - - _ _ - .
STP FSAR approval equivalent to that of the original document. Commercial con-sideration changes may not require review and concurrence by the origi-nator.
17.2.4.3 Sunolier Selection. Suppliers of safety-related items or services shall be required to submit copies of their QA program description, as required by procurement documents defined in Section 17.2.4.1, with their b id s . The supplier's QA program description shall be evaluated prior to the issuance of a purchase order or execution of a contract and acceptability i
shall be documented. The process by which suppliers are judged a capable procurement source is described in Section 17.2.7.
42 Procurement documents covering safety-related spare or replacement parts shall i
impose standards consistent with those specified for the original equipment or by a properly reviewed and approved revision. The procurement of spare parts __.
4 or , replacement parts will be subject to the QA program controls in effect at the time of the procurement.
17.2.5 Instructions. Procedures and Drawinns 17.2.5.1 Igggg. The safety-related activities associated with the operations phase shall be accomplished in accordance with documented instruc-
. tions, procedures, and/or drawings. These activities include design, procure-
. ment, warehousing, construction, installation, maintenance, modification.
. inspection, testing, operation, and auditing. The Operations QA Plan requires that such safety-related work be performed according to procedures. The Oper-ations QA Manager or Operations QA General Supervisor, as appropriate, will l 48 review and concur with procedures and revisions thereto for compliance with
, the HL&P QA Program,10CFR50 Appendix B, and applicable federal regulations.
- The review is documented and the comments on the current procedure revision will be maintained for verification.
17.2.5.2 Accentance Criteria. Documented instructions, procedures, and j drawings will include appropriate quantitative and qualitative acceptance t criteria for determining that prescribed activities have been satisfactorily 42 accomplished. Such instructions, procedures, and drawings will be reviewed and approved for compliance with requirements appropriate to their safety classification by individuals qualified to do so.
17.2.6 Document Control l
17.2.6.1 Scone Documents. Scope documents and their revisions which i
control activities affecting safety-related structures. systems, and compo-l nents shall be prepared and reviewed by knowledgeable individuals, and ap-proved by authorized personnel prior to release for use in accordance with approved procedures. '
?
l Departments responsible for program implementing documents shall be required l
to provide and assure the necessary review snd approval for instructions, Procedures , and drawings. Review and approval assures that issued documents l include proper quality and technical requirements, and are correct for intend-ed use. ,
17.2-14 Amendment 48
STP FSAR 17.2.6.2 control of Issuance and Revision. The Operations QA Plan requires procedures to be developed for the issuance of instructions, proce-dures, and drawings. The controls for issuing documents include:
- 1. Documents and revisions are sent to persons or locations on a list of controlled copy holders.
- 2. Controlled document holders acknowledge, in writing, receipt and inser-tion of documents and revisions thereto.
- 3. The availability of documents at the point of use prior to commencing an activity.
- 4. Temporary changes to procedures.
'~
- 5. Maintaining master lists of the various documents which indicate the 1atest revisions of instructions, procedures, and drawings.
The documents which are subject to the administrative controls outlined in this section include but are not limited to:
- 1. Departmental procedures
- 3. Plant procedures
- 4. Drawings
- 5. Procurement documents
- 6. Design documents
- 7. Modification procedures .
- 8. Manufacturing, inspection, and testing instructions
- 9. Test procedures
- 10. Design change requests
- 11. Nonconformance and Corrective Action Reports
, 12 FSAR
- 13. Interdepartmental Procedures.
T'no Plant Manager is responsible for distribution of controlled documents i
generated or received on site and for which plant personnel have the prepara-
, tion and final approval or external interface responsibility. Addit ionally ,
individual departments are responsible for controlling documents generated or reviewed in the department for which the department has preparation and final approval or external interface responsibility.
- I 1
17.2-15 Amendment 48 i
i 1
l Current documents shall be distributed to and used at the location where the
- prescribed activity is performed. Clearly identified controlled copies of i documents shall be used to perform an activity. Uncontrolled copies shall be clearly identified.
17.2.6.3 Grouns Resnonsible for Review and Anoroval. The managers of the individual departments performing quality-related work for STP are respon-sible for reviewing and approving their departmental procedures and changes 42 thereto. Departmental procedures and changes thereto are reviewed by the Operations QA Manager or designee prior to issuance for use.
The Manager, MA, reviews and approves the Operations QA Plan, and changes l48 thereto. The Group Vice President, Nuclear approves the Operacions QA Plan, l 46 cad changes thereto. The Operaticas QA Manager approves the plant QA proce-dures.
The Plant Manager is responsible for the approval of plant procedures, l instructions, and revisions thereto. Safety-related plant procedures are reviewed by the Operations QA manager, or designee, prior to issuance for use.
l Safety-related plant procedures shall be reviewed, by an individual knowledge-cble in the area affected by the procedure, no less frequently than every two years to determine if changes are necessary or desirable. This review shall ,
be performed by a member of a designated review group as an independent activ- 47
- ity that is at least as rigorous as the initial procedure review. A general revision to a procedure constitutes a review.
i In order to ensure that procedures in current use provide the best possible
~
l_
l instructions fcr performance of the work involved, systematic review of proce-dures shall be accomplished following an unusual incident, such as an acci-dent, an unexpected transient, operator error resulting in a significant cvent, or equipment modification to a system.
Maintenance, modification, and inspection procedures shall be reviewed by the QA organization to determine that necessary inspection requirements, methods, f cad acceptance criteria have been identified and acceptance criteria meet ,
, ' original design criteria.
Changes to documents shall be reviewed and approved by the same department,
- l. group, or organisation that performed the original review and approval; unless cnother department, group, or org.anisation is delegated this responsibility.
Organizations which review and approve documents shall have access to perti-1 nent information and knowledge of the intent of the original document.
17.2.7 Control of Purchased Material, Equipment, and Services 17.2.7.1 11221 Materials, equipment, spare or replacement parts, and services procured for SIPECS shall be required to conform to procurement docu-ments as prescribed in Section 17.2.4. Written procedures shall be estab-l lished to control quality activities associated with the procurement of aste-rial, equipment, and services including:
l j
I 17.2-16 Amendment 48 4
r , --- ,-.- ,, n n-,-.--n ,- n-.- -n,a,,,,_--~ . .,--n_,.- ~ - - - , , ~ , - - - ~ _ - , - , -
- 1. The preparation, review, and change control of procurement documents as described in Section 17.2.4.
- 2. Procurement source evaluation and selection;
- 3. Bid evaluation and award;
- 4. Verification activities (surveillance, inspection, and audit) required by the purchaser; i 5. Control of nonconformances as described in Section 17.2.15;
- 6. Corrective action regarding procurement as described in Section 17.2.16;
- 7. Material, equipment, and service acceptance;
- 8. Control of QA records;
- 9. Audits of the procurement program as described in Section 17.2.18.
17.2.7.1.1 Source Evaluation and Selection: Procurement source evalua-tion and selection involves Q&, Engineering, Purchasing and Services, and STPEGS plant personnel. These organisations participate in the qualification evaluation of suppliers in accordance with written prccedures. 42
} Measures for the evaluation and selection of procurement sources shall be specified in procedures and may vary depending on the complexity and safety classification of the item or service. When procurement source evaluations are performed, the information to be considered shall include one or more of the following:
i
- 1. Experience of users of identical or similar products of the prospective
- supplier, NRC Licensee Contractor and Vendor Inspection Program (LCVIP) reports, ASME Certificates of Authorization, Coordinating Agency for -
Supplier Evaluation (CASE) Register listing, HL&P records accumulated in
, previous procurement actions, and EL&P product operating experience may i be used in this evaluation. When an LCVIP letter of confirmation or CASE register is used to establish a supplier's qualification, the docu-
[ mentation will identify the " letter" or " audit" used. Supplier history shall reflect recent capability. Previous favorable quality experience l with suppliers may be an adequate basis for judgements attesting to suppliers' capability.
I 2. An evaluation of the supplier's current quality records supported by documented qualitative and quantitative information which can be objec-tively evaluated. This may include review and evaluation of the supplier's QA Program Manual, procedures, and responses to question-naires, as appropriate.
- 3. A source evaluation of the supplier's technical and quality capability as determined by a direct evaluation of facilities and personnel (audit, survey, or surveillance) and QA program implementation.
i I
17.2-17 Amendment 48 I
Procurement source evaluations involve a review of technical and quality con-siderations to an extent considered appropriate by each participant. Techni-cal considerations include the design or manufacturing capability and techni-cal ability of suppliers to produce or provide the design, service, item or component. Quality considerations include one of the previously stated meth-ods of supplier evaluation and a consideration of a supplier's current QA program or capabilities.
. Planning of verification activities to be employed for ites or service accep-
! tance shall begin during the purchase requisition or contract preparation and
- review stage. The extent of the verification activities will vary and be a
- function of the relative safety significance, complexity of the purchased item or service, and the supplier's past performance. The verification activities include vendor surveillance, receipt inspection or post-installation testing.
~~'
Verification activities are planned to assure conformance to procurement docu-ment requirements. Procedures shall establish the organisational responsibil-ities for identifying the required verification activity, documenting the verification method to be performed, the organization responsible for
, performing the verification, and documenting the verification.
. 17.2.7.1.2 Monitorina of Sunnliers. Acceptance by vendor surveillance may be considered when the item or service is vital to plant safety; or the 4
quality characteristics are difficult to verify after receipt; or the item or service is complex in design, manufacture, inspection, or test. Vendor sur-t veillance involves a physical presence to monitor, by obse' vation, r designated activities for the purpose of evaluating supplier performance and product 42 acceptance.
Vendor surveillance assures conformance to the procurement document require-ments by the use of a vendor surveillance plan. A surveillance plan will be developed in accordance with engineering procedures and the surveillance plan t will be reviewed by QA. The surveillance plan shall specify the characteris-tics or processes to be witnessed, inspected or verified, and accepted; the method of surveillance; and the documentation required.
, 17.2.7.1.3 Receivina Inspection: Receiving inspection shall be used for acceptance of items to procurement document requirements. However, when other methods (vendor surveillance) are utilised, receiving inspection shall be used to verify that items have not sustained damage due to handling, shipping, or storing.
Operations QA/QC personnel shall perform receiving inspections in accordance with written procedures. On complex or special items, other plant personne; 4
may assist QA/QC personnel in performing receipt inspection. The QA/QC per-socnel responsible for acceptance inspection shall be qualified in accordance with Sectica 17.2.10.1.1. Plant personnel assistieg in receipt inspection activities shall be qualified in accordance with Section 13.1.3.
L 3
Receiving inspection activities shall include: i
- 1. Identifying materials, parts, and components and their status upon receipt by tagging or other acceptable means of identification or i J" g 17.2-18 Amendment 48 l
STP FSAR segregating and controlling items in receiving hold areas separate from the storage facilities for acceptable items. Identification of items ,
shall correspond to the identification required by procurement documents l and acted on receiving documentation. i
- 2. Verification of items for this acceptance, including examination for shipping damage, corrections of identification, and specified quality documentation.
3.- Inspecting or testing, where appropriate, using approved procedures and calibrated tools, gauges, and measuring equipment for verification ac-ceptance of items, including off-the-shelf items.
- 4. Itema determined to be acceptable for use shall be identified with an accept tag or other acceptable means of identification prior to release __
for storage or use.
- 5. Received items which do not conform to procurement documents are con-trolled and segregated (if practicable) and processed in accordance with Section 17.2.15.
Acceptance by post-installation test may be utilized following one of the preceding verification methods. Post-installation testing may be used for acceptance verification when it is difficult to verify item quality character-istics, the item requires an integrated system checkout or test, or the item cannot demonstrate its ability to perform when not in use. Engineering speci-fications shall be used for developing post-installation test instruction requirements and acceptance documentation. Post-installation testing is the 42 responsibility of the Plant Manager and is witnessed by QA/QC personnel at specified QA hold points.
17.2.7.1.4 Acceptance of Procured Items and Service: Acceptance of items and services shall be based on one or more of the following:
- 1. Written certifications
- 2. Supplier audit or surveillance
- 3. Source inspection
- 4. Receiving inspection
- 5. Post-installation test Documentary evidence from the supplier that procured items meet procurement quality requirements such as codes, standards, or specifications will be main-tained at the plant site. Such evidence shall be provided by the supplier at the time of source or receipt inspection for review and verification before acceptance.. The documented evidence will be retrievable and available at the plant site prior to installation or use of the procured item.
17.2-19 Amendment 48
STP FSAR 17.2.7.1.5 Vendor Surveillance. Suppliers' Certificates of Conformance cre periodically evaluated by audits, independent inspections, or tests to casure that they are valid and results are documented. When acceptance is based on supplier audit or vendor surveillance, documented evidence shall be
- furnished to the plant receiving organization.
17.2.7.2 Audits of Sunoliers. The HL&P QA audit program, discussed in Section 17.2.18, provides for periodic scheduled audits of suppliers, contrac-tors, subcontractors, and others performing safety-related work. The audit cchedule is prepared and updated by QA. Frequency of these audits is based on the safety, complexity, and quality requirements of the item or service being furnished.
17.2.8 Identification and control of Materials, Parts, and Components
~~
17.2.8.1 Identification Reauirements. The design control documents, as controlled by Section 17.2.3, require that specifications and drawings include cypropriate identification requirements for materials, parts, and components.
Receipt inspection, as discussed in 17.2.7, shall verify that the item identi-fication complies with specification or drawing requirements. The verifica-tion will ensure that material and item identification can be traced to the cypropriate documentation, such as specifications, drawings, purchase orders, manufacturing and inspection documents, NCRs, and physical or chemical test reports. The receiving inspection procedure shall require that the method and l location of the identification does not affect the function or quality of the item being identified.
42 i
17.2.8.2 Maintenance of Identification. Upon completion of receiving inspection, materials, parts, and components are turned over to the Stores '
Department for control and storage. The Stores Department shall develop pro-cedures for the control, storage, and issuance of material, parts and compo-nents.
Procedures shall specify that identifiestion be maintained, either on the item cr on records traceable to the item, and verified as required throughout fab-
!- rication, erection, installation, and use of the item. The identification must be verified and documented as being correct prior to release for fabrica-tion, erection, installation and/or use of the item.
l 17.2.9 Control of Special Processes 17.2.9.1 Special Processes. Special processes are those special manu-facturing processes, inspections, tests, and other processes which require the qualification of the procedures, technique, and personnel to assure the
- quality of the process. These special processes include, but are not limited to
- 1. Welding
- 2. Heat Treating I
17.2-20 Amendment 48
--- - - _ . , . _ _ _ _ _ _ _ , - _ _ _ _ _ . . _ _ _ _ , _ _ _ , _ . _ _ _ - - _ _ , . . m.__ _ - - - _ _ _ _ _ . . _ _ _ _ _ _
- . . _ - - - . - - - _ . . . - . . _ ~ . . - - .
- 3. Nondestructive Testing (NDT) l
- 4. Chemical Cleaning
- 5. Protective coating i
Special processes are performed under controlled conditions by qualified per-sonnel using procedures qualified and approved in accordance with applicable codes, standards, or other requirements. For special processes not covered by existing codes or standards, the specific equipment, personnel qualification, and procedure gustification requirements are defined prior to application of .
the special process.
17.2.9.2 Snecial Process Qualification. Procedures shall be estab-lished for the qualification of special processes, equipment, and personnel. __.
- These procedures shall define the organisational responsibilities for the qualification process. The Nuclear Plant Operations or Nuclear Engineering and Construction Departments shall qualify RL&P special process procedures, equipment, and personnel. QA shall concur with the qualification of 'special ,
process procedures, equipment, and personnel. 2 i ^_ _S -
42 17.2.9.3 Control of Outside Contractors. Qualified outside organisa-
! tions may be employed to perform special processes and shall be required to conform to the requirements described in this section. Special process proce-i dures submitted by an outside organisation in accordance with procurement i document requirements shall receive a technical review by the responsible engineering organisation and a quality review by QA personnel.
17.2.9.4 Records Control . Records shall be maintained and kept current l for the qualification of procedures, equipment, and personnel associated with special processes. Records are in sufficient detail to clearly define the procedures, equipment, or personnel being qualified; criteria or requirements i used for qualification; and the individual approving the qualification.
i 17.2.9.5 Oualification of NDT Fersonnel. Nondestructive test personnel shall be qualified in accordance with procedures established per the require-ments of the American Society for Nondestructive Testing Standard SNT-TC-1A i 1980 and ASME B&FV Code Section XI as applicable.
17.2.10 Inspection 17.2.10.1 Inspection Fronram. A program for the inspection of safety-related activities at STFECS shall be established to verify conformance with applicable documented instructions, procedures, drawings, and specifica-tions.
48 17.2.10.1.1 gualification of Insnectors. QC personnel performing inspections shall be qualified and certified in sceordance with procedures .
which meet the requirements of RG 1.58 and as applicable 5NT-TC-1A,1980 42 t t
l I L
17.2-21 Amendment 48 t
STp FSAR edition. Inspections and process monitoring which serve an inspection func-tion shall be performed by personnel qualified to perform assigned inspection tasks and who are other than the individuals who performed or directly super-vised the activity and do not report to the same immediate supervisor.
When inspections sesociated with normal operations of the plant are performed by individuals other than those who performed or directly supervised the work, but are within the same group, the following controls shall be met:
- 1. The quality of the work can be demonstrated through a functional test 42 when the activity involves breaching a pressure retaining ites.
- 2. The qualification criteria for inspection personnel are reviewed and found acceptable by the QA organisation prior to initiating the inspec-tion. _
17.2.10.1.2 Insoection Process: The inspection program shall be con-ducted in accordance with approved procedures. Inspection procedures, l 48 instructions, or checklists shall provide for the following:
1.'
~
Identifiestion of characteristics and activities to be inspected; 2 qualification requirements for the individuals performing the inspec-tion;
- 3. Acceptance and rejection criteria;
- 4. A description of the method of inspection;
- 5. Verification of completion and certification of the inspection, and a record of the results of the inspection operations;
- 6. Identification of required procedures, drawings, specifications, and 42 revisions;
- 7. Specifying the necessary measuring and test equipment including accuracy requirements and calibration due dates if applicable;
- 8. Review and evaluation of the inspection results.
Inspection instructions, procedures, and supporting documents shall be provided to inspection personnel for use prior to performing inspection activ-ities. Inspection results shall be documented and procedures shall prescribe the review and approval authority of inspection results.
17.2.10.1.3 Process Monitoring: Process monitoring of work activities, equipment, and personnel shall be utilized as a control method if direct in-spection of processed items is impossible or impractical. The monitoring of processes shall be performed to verify that quality-related activities are being performed in accordance with docussented instructions, procedures, drawings, and specifications.
17.2-22 Amendment 48
STP FSAR' 17.2.10.1.4 Sunoortina Inspections: Both inspections and process moni-toring shall be used when control of the activity is inadequate without both.
Need for such monitoring shall be determined prior to initiation of the activ- 42 ity, if possible, or may be stipulated later if circumstances warrant.
17.2.10.2 Mandatory Inspec t ions . Mandatory inspection hold points are established by the organization performing the work, or operations QA person-nel. Witnessing or inspecting of hold points by QC shall be required before 48 work can proceed. For onsite work, plant procedures and work instructions shall be reviewed by QA personnel, for concurrence with the established man-datory hold and notification points. Hold points for wcrk performed in vendor facilities are established by vendor surveillance plans, as described in Section 17.2.7.
17.2.10.3 Acceptance. Procedures shall be established for processing inspection data, evaluation of inspection data and. final acceptance of inspec- -
tion data. The qualified inspector performing the inspection is responsible for the inmediate evaluation and acceptability of inspection results. The QA/QC Supervisor or designee is responsible for reviewing and evaluating inspection results to assure errors are not made in the recording of data. -
computations, drawings or specification interpretations. 42 17.2.11 Test Control 17.2.11.1 Test Proaram. A test program shall be developed to demon-strate that safety-related structures, systems, and components will operate to maintain plant parameters within normal bounds or will operate to put the plant .in a safe condition if parameters exceed normal bounds in service.
17.2.11.1.1 1s. gag: Test programs include prerequisite and 48 preoperational/ acceptance tests, initial startup tests, surveillance tests, and equipment tests including those associated with plant maintenance, modifi-cation, procedure changes, and the acceptance of purchased material.
' Procedures shall be established for scheduling and performance of surveillance testing to assure that the necessary quality of systems and components is maintained, that plant operations are within the safety limits, and that lin-iting conditions of operation can be met._ The testing frequency shall be at g i least as frequent as prescribed in the Technical Specifications. Qualified 7
plant staff personnel will perform surveillance tests.
l Test performed following maintenance or modification shall satisfy the origi-l nal design or test requirements or acceptable engineering determined alterna-tive.
17.2.11.1.2 Personnel Qualifications: HIAF personnel and contracted personnel performing test activities, including developing and implementing
( test procedures and evaluating and reporting of test results, shall be trained l and qualified in accordance with RG 1.58, (as specified in Table 3.12-1).
i Documented evidence of test personnel qualifications shall be maintained at the plant.
i
! 17.2-23 Amendment 48
17.2.11.1.3 - Preonerational and Startuo Tests: The preoperational and startup test program is described in Chapter 14.
17.2.11.2 Test Procedures. Testing shall be performed in accordance with approved procedures. Test procedures shall control when a test is required and how the test is to be performed. Test procedures provide the following as necessary:
- 1. The requirements and acceptance limits contained in applicable design and procurement documents;
- 2. Instructions for performing the test, including prerequisites and cau-tion or safety notes and in sufficient. detail that the test cperator interpretation is not required;
- 3. Specific test equipment with the accuracy required for performing the activity;
- 4. Provisions for data collection and storage; 1'
- 5. Acceptance and rejection criteria;
- 6. Mandatory inspection hold points for witness by QC inspector;
- 7. Provisions for assuring that test prerequisites have'been met; 42
- 8. Provisions for control of jumpers, lifted leads, or safety tags;
- 9. Provisions for returning a system to normal configuration upon comple-tion of the test;
- 10. Special considerations for suitable environmental conditions shall be noted on the test procedures, as necessary.
17.2.11.3 Data Recordine. Evaluation. and Retention. Test data shall be recorded and test results reviewed and approved by qualified individuals or groups. Test procedures, test data, and test data evaluations shall be retained as part of the plant record.
17.2.12 Control of Measuring and Test Equipment
. 17.2.12.1 Calibration Fronram. The calibration and control program established for STPEGS shall assure that tools, gauges, and instruments esin-i tain their required accuracy. The Plant Manager shall be responsible for the implescutation of the calibration prograe. Each organization shall be respon-sible for assuring that the measuring and test equipment (MTF) it uses has been properly calibrated.
i
, I j . I l
- 17.2-24 Amendment 48
STP FSAR Procedures shall be established for control and calibration of NTE. The procedures provide- for the following: ,
i
- 1. Identifying NTE that require calibration, the required calibration fre-quency, the applicable calibration procedure, the group responsible for calibration, the setpoints and accuracy requirement for the item, the calibration results, the equipment maintenance history, the date of the last calibration, and the due date for the next calibration.
- 2. Identification of each piece of MTE with a unique serial number traceable to the test data.
3.
A calibration label will be attached by NTE to indicate the calibration due date. If this label. interferes with the equipment function or is impractical, the calibration label will be attached to the equipment __
case.
- 4. Calibration frequency, based on the required accuracy, purpose, degree of usage, stability characteristics, and other conditions affecting the measurement.
- 5. A requirement for reference standards to have an uncertainty error of no
- more than one-fourth of the tolerance of the equipment being calibrated, i unless the minimum uncertainty is limited by the state of the art. In these cases, standards shall have an accuracy that assures the equipment being calibrated will be within the trauired tolerance and that the 42 basis of acceptance is documented.
- 6. Traceability of reference and transfer standards to nationally recog- I
, nized standards, and provisions for documenting the basis for calibra-tion where national standards do not exist.
- 7. Documented investigations to determine the validity of previous inspec- -
tions and tests performed when measuring and test equipment is found to be out of calibration. The investigations shall evaluate the necessity of repeating original measurements, inspections, tests, or calibrations ,
to establish the acceptability of such items.
- 8. Repair or replacement of calibration, measuring, and test equipment l
! consistently found to be out of calibration.
Inspection, test, maintenance, repair, and other procedures shall include provisions to assure that NTE used in activities affecting quality are of the ,
proper range, type, and accuracy to verify conformance to requirements and test parameters.
Special calibration and control measures shall not apply to rulers, tape sea-sures, levels, and other devices if normal commercial practice af fords ade-quate accuracy.
t I
i 17.2-25 Amendment 48
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STP FSAR 17.2.12.2 Records. Records of HL&P plant calibration activities shall be maintained by the plant staff.
17.2.13 Handling, Storage, and Shipping Safety-related material, equipment, and components shall be handled, stored, shipped, cleaned, and preserved to assure that the quality of items is main-tained from fabrication through installation.
Procedures shall be developed for the storage and control of safety-related materials and equipment to minimize the possibility of damage or lowering of quality while in storage. Material and equipment shall be stored at locations chich have a designated storage level. The various storage levels shall be procedurally defined and shall have prescribed environmental conditions. The storage conditions shall be in accordance with design and procurement require-ments to preclude damage, loss, or deterioration due to harsh environmental - - ~
conditions. Items having limited calendar or operating life shall be identi-fied and controlled to preclude the use of items whose shelf life or operating life has expired.
Procedures shall be developed for storage of chemicals, reagents, lubricants, cad other consumable materials, which will be used in conjunction with I
safety-related systems.
Storage conditions commensurate with the safety classifica't ion of the materials will be maintained.
The overall program for control of handling, storage, and shipping complies 42 with RG 1.38, (Reference Table 3.12-1).
17.2.13.1 Special Procedures. Procedures shall be prepared for items that require special handling and shall be available prior to the items being handled. Other items not addressed by special procedures shall be handled in cecordance with sound material handling practice. Operators of special han-d1ing and lifting equipment shall be experienced or trained in the use of the cquipment.
f.
17.2.13.2 Inspection. Procedures shall be established which identify cpecial handling tools and equipment for routine maintenance and inspection.
Routine inspections shall verify the acceptability or nonconformance of equip-gent and rigging.
17.2.13.3 Procurement Controls. Procurenient documents and procedures shall identify packaging requirements for safety-related iten.s during ship-
- ping, handling, or storing. The packaging protection specified may vary in degree consistent with the itema' appropriate protection classification.
17.2.13.4 Storane Surveillance. Stores Department procedures shall require periodic surveillance of stored items to verify specific protective savironmental requirements for particular equipment that may be in effect.
t i
4 17.2-26 Amendment 48
. STP FSAR The QA surveillance program shall provide for routine surveillance of stored items to verify compliance with storage requirements.
17.2.13.5 Records. Records shall be maintained to document activities for handling, shipping, and storing safety-related items.
17.2.14 Inspection, Test and Operating Status
.17.2.14.1 Status Procren. Procedures shall be developed for identifi-cation of inspection . test, and operating status of safety-related structures, systems and components. These procedures will provide for:
- 1. Identification of the inspection, test, and operating status of struc-tures, systems, and components throughout fabrication, installation, and test; __
- 2. Control of the application and removal of inspection and welding stamps and status indicators, such as tags, markings, labels, and stamps;
- 3. Identification of the status of nonconforming, inoperative, or malfunc -
tioning structures, systems, or components to prevent inadvertent use.
This function is performed by various HL&P organizations in accordance with approved procedures; 42
- 4. Methods to control altering the sequence of required tests, inspections, and other operations on safety-related structures, systems, and compo-nents are subject to the same controls as the original review and approval;
- 5. Administrative control of nondestructive test reports and status indica-tors;
- 6. Verification of the application of welding stamps;
- 7. Administrative control of hold and equipment status tags used in the plant.
17.2.14.2 Insoection and Test Status. The inspection and test status of items received at the Plant shall be identified in accordance with proce-dures. The QC receipt' inspector shall identify acceptability of the inspec- l 48 tion by affixing the appropriate tag to the item where practical.
The cognizant Operations Unit Supervisor shall be responsible for maintaining sufficient knowledge of system or equipment tests or inspections in progress to control the overall plant operation. Personnel performing tests or inspec-tions shall keep the Operations Unit Supervisor or Control Room Operator advised of the current status of tests or inspections in progress which may affect plant operations. 42 f
17.2-27 Amendment 48
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17.2.14.3 Operatina Status. The operating status of systems, struc- l and components that are in the process of maintenance, modification, 4, inspection, or refueling shall he controlled by a tagging system.
- 1_ .agging procedures shall include:
- 1. Authorisation for requesting that equipment be removed from service;
- 2. Checks which must be made before approving the request;
- 3. Approval to remove equipment from service;
- 4. Responsibility and action necessary for isolating the equipment; and
^
- 5. Responsibility and actions necessary for returning the equipment to operating status. __
17.2.14.4 Nonc onformine Item Status. Nonconforming items or structures shall be identified with a nonconformance hold tag in accordance with Section 17.2.15 to prevent inadvertent use.
17.2.14.5 Manufacturine Insnection and Test Status. Procurement docu- '
ments shall require suppliers of safety-related items to maintain the status
,. of required inspections or tests throughout the manufacturing process to pre-clude inadvertent bypassing of such inspections and tests.
EL&P QA vendor surveillance personnel or designee shall perform selective surveillance or inspection as required by the procurement documents to verify adherence to inspection and test status requirements.
17.2.14.6 Seouence Ch==-e Control. Procedures shall include the con- 42 4
trol of the sequence of required inspections, tests, and other operations when important to quality. To change these controls the individual procedure must be changed and shall require the same review and approval that was received by the original procedure.
17.2.15 Nonconforming Material Parts, and Components 1
17.2.15.1 Nonconformance Control. Procedures shall be established for
- i. the control of identified nonconformances to prevent the inadvertent use of defective or indeterminate items. Items that deviate from approved specifica-l tions, codes, drawings, or other applicable documents are considered as non-i conforming. These procedures shall provide for documenting the nonconforming ites or nonconforming activity.
- Nonconformance documentation shall identify the specifics of the nonconfor-mance and serve as a notification of the responsible organization. The non-conformance documentation shall state the particular drawing, procedure, spec-l ification, or other requirement not met; shall state the disposition; shall ;
record the review and approval of the disposition; shall indicate the rein-spection of the ites, if applicable; and shall record the closure authority of the nonconformance.
i 17.2-28 Amendment 48 s
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-To prevent the inadvertent use or installation of_ nonconforming items, they shall be clearly identified where practical to indicate their unacceptable status, and if possible they are segregated until the nonconformance is prop-erly dispositioned.
Material nonconformance disposition categories are:
- 1. "Use-as-is";
- 2. "Rej ect" ; 42
- 3. " Rework" in accordance with documented procedures; and
- 4. -" Repair" in accordance with documented procedures.
Procedures shall identify.the individuals or groups responsible for providing
the disposition of nonconformances. The "uss-es-is" and " repair" disposition of nonconforming items shall be approved and justified in writing by Engineer- 49 ing prior to implementation. The disposition and recommended action are Q260. i i reviewed by QA and approved by the Plant Manager or the Startup Manager as 57N appropriate, prior to implementation.
Repaired and reworked items shall be ninspected to inspection criteria at
- least as stringent as those applied to the original work. Reinspection re-sults are documented on nonconformance reports, inspection reports, or other suitable type document by QC personnel. %
17.2.15.2 Supplier control. Procedures shall provide for the control of further processing or delivery of nonconforming or defective items found at a supplier facility pending a decision on their disposition. When a contrac- 42
, tor, supplier, or service organization identifies a nonconforming item and recommends a "use-as-is" or " repair" disposition, concurrence of the responsi-ble HL&P Engineering group with the disposition is required.
17.2.15.3 Conditional Release. Nonconforming material, parts, and components may be installed after the effect of their installation has been evaluated and the installation approved by the Plant Manager, Engineering, and l 48 the Operations QA Manager. Nonconforming items which may not be installed are i those which because of their makeup and intended use cannot.be returned to
, their original state after being installed and those which if installed in and later removed from a system, structure, or component, would cause degradation.
Except for proof testing, installed nonconforming items are not energized, used, or placed in service until the action required by the disposition has 42 been completed and reinspected.
17.2.15.4 Trend Analysis. Deficiencies reported shall be analyzed by the QA Department for identification of unsatisfactory quality trends. The results of these analyses shall be reported to the affected organization and executive management. Significant adverse trends shall be handled in accor-dance with Section 17.2.16.
17.2-29 Amendment 49 h
17.2.15.5 Renortable conditions Significant conditions during plant operations involving a defect or noncompliance in a delivered component or service which could create a substantial safety hasard shall be reported to the Nuclear Regulatory Commission pursuant to the requirements of 10CFR21 during operation and 10CFR50.55(e) during the preoperational test phase.
~17.2.16 Corrective Action 17.2.16.1 Identification and Correction. Procedures shall be estab-lished to assure that conditions adverse to quality are promptly identified, reported, and corrected to preclude recurrence. Corrective actions associated with the resolution of deficiencies identified in Nonconformance Reports, Corrective Action Reports, audits and surveillance findings are processed in 42 accordance with Sections 17.2.15, 17.2.16, and 17.2.18, respectively.
These deficiency reporting mechanisms identify conditions adverse to quality in systems, components, equipment, processes, and procedures. The action for disposition of the deficiency is documented on the appropriate deficiency report forms. The QA Organization will track the status of all deficiencies.
Deficiency reports identify conditions adverse to quality in all safety-related activities. The corrective action for problems identified by deficien-cy reports are determined by the responsible organisation and reviewed by QA.
The QA Organisation verifies satisfactory completion of the corrective action.
Unacceptable completion of corrective action is identified by QA and returned to the the responsible organization for correction. This may result in suspen-sion of the activity.
Disputes over corrective action are normally resolved by the Plant Manager or during initial testing by the Startup Manager. Sheuld this resolution not be 48 satisfactory, the parties may elevate the matter to higher management for resolution.
Corrective action documentation shall include documentation of the cause, and the action taken to correct and to preclude the recurrence of similar condi-ticas adverse to quality.
42 17.2.16.2 Sinnificant Conditions Adverse to Ouality. Procedures which <
identify and track deficiencies shall require management review of each report to determine if the condition is siguificant. For significant conditions adverse to quality, the cause of the condition and the corrective action taken ,
to preclude repetition shall be documented and reported to appropriate levels of management for review and assessment. Significant itema or conditions identified at STPEGS shall be reviewed and corrective action shall be recom-mended on conditions adverse to safety regarding operating procedures.
l l 17.2-30 Amendment 48 l
l 1
'STP FSAR 17.2.17 Quality Assurance Records r v
17.2.17.1 Sufficiency of Records. Procedures shall be developed to assure that sufficient records are maintained to furnish evidence to activi-ties affecting quality. The program for QA records control shall meet the i requirements of 10CFR50, Appendix B, and BG 1.88 (Reference Table 3.12-1).
To assure that proper documents are identified as QA records and properly stored, procedures shall identify those documents which are defined :o be QA records . Procedure (s) shall identify the retention time for each document, with retention time being consistent with applicable codes, standards, and procurement documents. These records include, but are not limited to: plant history; operating logs; records of principle maintenance and modification activities; reportable occurrences and other records required by the Technical
?' Specifications; results of reviews, inspections, tests, audits, and material analysis; monitoring of work performance; qualification of personnel, proce-
'~
r dures, and equipment; drawings, specifications, procurement documents, ware-housing documents, calibration procedures and calibration reports; sad, non-conformance'and corrective action reports.
4 The records control program provides evidence that activities relating to i
quality are defined, implemented, and that inspection and test documents con-tain: a description of the type of observation; the identification of ,
inspector or data recorder; the date and inspection or test results; accept-ability of the results; reference to nonconformance reports; and reference any
- action taken in resolving any nonconformances.
17.2.17.2 Record Identification and Retrievability. To ensure that QA records are identifiable and retrievable, a computerized records managestat system has been developed. This system provides for a unique alphanumeric identification code affixed to each document. Registers are provided which list all QA records and their identification codes. The system provides the ability to cross-reference the identification code with other possible identi- -
fiers of the document (i.e., specification number, purchase order number, class-bin number, equipment name). QA records are stored on photographic l media; the file location of any document is available from the computer.
i 17.2.17.3 Protection of Records. QA records shall be stored in a per-manent records storage facility which complies with RG 1.88 (Reference Table 3.12-1).
17.2.18 Audits -
17.2.18.1 Audit Proeram. A comprehensive audit program in compliance with RG 1.144 shall be established and implemented by HL&P to verify internal '
and external quality activity compliance with the Operations QA Program. The
! audit program shall assure that applicable elements of the program have been l
developed, documented, and are effectively implemented and shall p'rovide for l
reporting and reviewing audit results by appropriate levels of management.
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l 1 17.2-31 Amendment 48 i
STP FSAR The audit system shall include internal and external audits. The system shall be planned, documented, and conducted to assure coverage of applicable ela-ments of the Operations QA Program, and overall coordination and scheduling of 42 audit activities. Audit planning shall be based on an audit plan which is issued annually, as a minimum, by the QA Organisation and includes the organ-isation and activity to be audited, audit frequency, and schedule. The annual audit plan shall be approved by the Manager, NA. l48 Audits shall be conducted using written plans in accordance with QA proce-dures. The procedures require evaluation of work areas, activities, proces-ses, goods, services, and th'e review of documents and records for quality related practices, procedures, and instructions to determine the effectiveness of the implementatica of OQAP and compliance with 10CFR50, Appendix B. The following areas are included in the audit program:
- 1. Operation, maintenance, and modifications;
- 2. Preparation, review, approval, and control of designs, specifications, procurement documents, instructions, procedures, and drawings;
- 3. Material control instructions;
- 4. Indoctrination and training programs;
- 5. Implenectation of operating and test procedures; 42
- 6. Calibration of measuring and test equipment;
- 7. Corrective action and nonconformance control;
- 8. Performance of the plant staff, including training records;
- 9. Startup testing and administrative controls; and
- 10. Plant inspection activities.
An individual audit plan shall identify the audit scope, the requirements, the applicable documents, and written procedures or checklists as sppropriate.
l The audit plan and any necessary reference documents shall be available to the j audit team members.
l l External audits shall be conducted by QA as a measure for the evaluation of l procurement sources and as a postaward source verification of conformance to j procurement documents. Audits conducted by other organizations, including t
other utilities or A/Es, may be employed as a means of postaward source veri-I fication in lieu of RL&P performed audits.
17.2-32 Amendment 48 L
l Applicable elements of suppliers' QA programs shall be audited on a frequency that is based upon the status and safety classification of the activities being performed. Audits are generally initiated when sufficient work is in progress to determine whether the organisation is complying with the establish-ed quality requirements. Subsequent contracts or contract changes which signi-ficantly change the scope of activities by the same supplier shall be consi-dered in establishing audit requirements.
17.2.18.2 Audit Frecuencv. Internal audits shall be conducted by QA and shall be performed with a frequency commensurate with their safety significance. An audit of all safety-related activities shall be completed in accordance with formal audit schedules within a period of two years. Supple-mentary to the biennial requirement to audit all safety-related activities, the following program elements shall be audited at the indicated frequencies: -
- 1. The results of actions taken to correct deficiencies that affect nuclear safety and occur in facility equipment, structures, systems, or method of operation - at least once per six months.
- 2. The conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions - at least once per twelve months.
- 3. The performance, training, and qualifications of the facility staff !
including training records and supervisory evaluations - at least once per twelve months.
Supplemental audits shall also be conducted when (1) significant changes are 42 made in functional areas of the QA Program, such as significant reorganisation or procedure revisions; or (2) when it is suspected that the quality of the item is in jeopardy due to deficiencies in the QA Program; or (3) when a sys-tematic, independent assessment of program effectiveness is considered neces-sary.
Periodic review of the audit program shall be performed by the independent review body or by a management representative at least semiannually to verify that audits are being accomplished in accordance with the requirements of the
, QA Program.
17.2.18.3 Audit Team. An audit team consists of one or more qualified person (s). A qualified lead auditor shall be appointed as the audit team leader. The audit team leader shall be responsible for the written plans, checklists, team orientation, audit notification, preaudit conference, audit performance, postaudit conference, reporting, and follow-up activity to assure corrective action. The audit team leader shall report conditions requiring immediate corrective action promptly to the appropriate management of the audited organisation. Other audit findings will be identified to the audited i organisation at the postaudit conference. Formal audit reports shall be prepared and submitted to the audited organisation within thirty days after the postaudit conference.
17.2-33 Amendment 48
1 17.2.18.4 Auditor Qualification. Audits shall be performed by quali-fled personnel. Procedures shall establish qualification requirements for lead auditors and auditors. Auditor qualifxcation requirements shall include education and work experience; training, on-the-job performance, and audit participation. Procedures shall include requirements for maintaining audit proficiency by auditors through regular and active participation in the audit process, training, or review of procedures, codes, standards, and other appli-cable documents.
Other personnel may assiet in the conduct of audits, such as technical spe-cialists, management representatives, or auditors in training. Such personnel selected for auditing assignments shall have training or experience commensu- 42 rate with the scope, complexity, or special nature of the activities to be audited. Personnel performing audits shall have no direct responsibility for the area audited. __
17.2.18.5 Audit Results. Records shall be collected, stored, and main-tained in accordance with the requirements in Section 17.2.17.
Audit reports shall be distributed to the audited organization as well as the appropriate executive management for their review and evaluation.
Audit results shall be periodically reviewed by the QA Organisation for quality trends and overall audit program effectiveness. The results of these reviews shall be reported to appropriate management in periodic summary reports of audit activities.
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17.2-34 Amendment 48
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ATTAct4ENT B Planned changes to FSAR 17.2 Page/Section 17.2-2/17.2.1.1.1 Delete the description of the SAFETEM Manager from this section since SAFETEAM is described in Chapter 13.
17.2-4/17.2.1.1.5 Nuclear Security now reports to V.P., Nuclear Plant Operations.
17.2-4/17.2.1.1.6 Personnel Relations is now Employee Relations.
Human Resources is now Human and Information Resources.
17.2-5/17.2.1.2 Revise "The departmental procedures and revisions" to read
" Procedures and revisions."
17.2-6/17.2.2.2 Clarify that QA program for fire protection is under control of QA not the fire protection program itself.
17.2-8/17.2.2.6 Delete "to address audit sctivitie.s" to provide consistency in reference to 17.2.9, 17.2.10,'17.2.11, and 17.2.18.
17.2-16/17.2.6.3 '
Delete " Departmental" as other tspes of procedures are also reviewed 17.2-21/17.2.9.2 Add Nuclear Assurance as an organization which qualifies special processes, procedures, etc.
17.2-23/17.2.10.2 Revise "QA" to read QA/QC throu @ t.
Figure 17.2-1 Revise as shown in Attachment C.
Figure 17.2-2 Revise: Vice President HLsnan Resources to read Vice President Human and Information Resources Revise: Personnel Relations to read Employee Relations Delete: Security from Group VP Adnin.
Add: Nuclear Security to Vice President Nuclear Plant Operations
. o ATTACHMENT C 4 Bous10N LICIITIIIC & FouRR CENealff amare saa atensmaamre ggpagygggry CROUP VICE PRESIDENT NUCLEAR (1)
MANAGER IGUCLEAR ASSURANCE (2)
Operatione QA Technical Services Manager (2) Manager (Vacant) (2)
Ops QA Ops QC l proj ect echnical Servicea Quality Quality General Ceneral Supervisor r,emeral Supervison Engineerlag Control Sepervisor (2] Supervisor (2) Destga (1) (Later (Later) 21 (2)
Procurement (2) l l l l l l Supervisor Vendor Ops QA Ops QA quality C;.arational Ops QC Ops qc Evaluation / Serve 111ance Serv. Serv. Systems Support Supv. Supv (1) .
Elec/I6C Mech /IIDE (2) Programe Elec/IEC Mech /NDE (2) (2) (2) (2) (2)
(1) Offsite Organization (2) Onatte Organization Figure 17.2-1 Programunatic direction pending filling
- of Technical Services Manager position
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
HOUSTON LIGHTING & POWER ) Docket Nos. 50-498 OL COMPANY, ~ET AL. ) 50-499 OL
) '
(South Texas Project, Units 1 )
and 2) )
MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD Pursuant to 10 C.F.R. 5 2.749(a), Applicants hereby submit a statement of raaterial facts as to which there is no genuine issue to be heard in conjunction with their motion for summary disposition of Issue F.
(1) HL&P's Quality Assurance Program for the operation of STP (the STP Operations QA program) is described in Attachments A, B, and C to the March 10, 1986, Affidavit of Mr. James E. Geiger (attached).
(2) The STP operations QA program includes appro-priate plans for inspections, audits, surveil-lance, documenting, tracking and trending of deficiencies, review of vendor quality programs, and other monitoring of STP quality related programs. Affidavit of Mr. James E. Geiger at 11 5-9.
L-
f (3) The STP operations QA program includes appro-priate requirements for personnel qualifica-tion, experience, and training. Affidavit of Mr. James E. Geiger at 11 11-13.
(4) The STP operations QA organization will have a staff and organization sufficient to perform its functions in compliance with Appendix B. Affidavit of Mr. James E. Geiger at 11 5-10 and Attachment C.
(5) The STP operations QA organization is struc-tured to provide organizational independence in the performance of its functions. Affida-vit of Mr. James E. Geiger at 1 3.
(6) ~The STP operations QA program satisfactorily addresses each of the 18 Criteria of Appendix B. Affidavit of Mr. James E. Geiger at 1 15 and Attachments A and B.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
HOUSTON LIGHTING & POWER ) Docket Nos. 50-498 OL COMPANY, ET AL. ) 50-499 OL
)
(South Texas Project, Units 1 )
and 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Motion For Summary Disposition On Issue F" have been served on the following individuals and entities by deposit in the United States mail, first class, postage prepaid, or by arranging for delivery as indicated by asterisk, on this 12th day of March, 1986.
Charles Bechhoefer, Esq.* Brian Berwick, Esq.
Chairman, Administrative Judge Assistant Attorney General Atomic Safety and Licensing For the State of Texas Board Panel Environmental Protection U.S. Nuclear Regulatory Division Commission P.O. Box 12548, Capitol Station Washington, D.C. 20555 Austin, TX 78711 Dr. James C. Lamb, III Kim Eastman, Co-coordinator Administrative Judge Barbara A. Miller 313 Woodhaven Road Pat Coy Chapel Hill, NC 27514 Citizens Concerned About Nucicar Power Frederick J. Shon* 5106 Casa Oro Administrative Judge San Antonio, TX 78233 U.S. Nuclear Regulatory Commission Lanny Alan Sinkin*
- Washington, D.C. 20555 Christic Institute 1324 North Capitol Street Mrs. Peggy Buchorn Washington, D.C. 20002 Executive Director citizens for Equitable Ray Goldstoin, Esq.
Utilities, Inc. Gray, Allison & Becker Route 1, Box 1684 1001 Vaughn Building Brazoria, TX 77422 807 Brazos Austin, TX 78701-2553
_2_
Oreste Russ Pirfo, Esq.*
Robert G. Perlis, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ,
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ATTACH >ENT B Planned changes to FSAR 17.2 Page/Section 17.2-2/17.2.1.1.1 Delete the description of the SAFETEAM Manager from this section since SAFETEAM is described in Chapter 13.
17.2-4/17.2.1.1.5 Nuclear Security now reports to V.P., Nuclear Plant Operations.
17.2-4/17.2.1.1.6 Personnel Relations is now Employee Relations.
Human Resources is now Human and Information Resources.
17.2-5/17.2.1.2 Revise."The departmental procedures and revisions" to read
" Procedures and revisions."
17.2-6/17.2.2.2 Clarify that QA program for fire protection is under control of QA not the fire protection program itself.
17.2-8/17.2.2.6 Delete "to address audit activities" to provide consistency in reference to 17.2.9, 17.2.10, 17.2.11, and 17.2.18.
17.2-16/17.2.6.3 Delete " Departmental" as other types of procedures are also reviewed.
17.2-21/17.2.9.2 Add Nuclear Assurance as an organization which qualifies special processes, procedures, etc.
17.2-23/17.2.10.2 Revise "QA" to read QA/QC throughout.
Figure 17.2-1 Revise as shown in Attachment C.
Figure 17.2-2 Revise: Vice President Htnan Resources to read Vice President Human and Information Resources Revise: Personnel Relations to read Employee Relations Delete: Security from Group VP Adnin.
Add: Nuclear Security to Vice President Nuclear Plant Operations
ATTACHMENT C ,
MOUSTUIl LICHTIIIC & pondEE CDIFANT M 8A8 ASSWRAaICE BEpARTIEIIT CROUP VICE PRESIDENT If0 CLEAR (I)
MANAGER NUCLEAR ASSURAIICE (2)
Operations QA Technical Services Manager (2) Manager (Vacant) (2)
~
Ops QA Ops QC Froj ect Technical Servicea quality Quality General Ceneral Supervisor General Supervison Engineering Control Supervisor (2) Supervisor (2) Design (1) (Later (Later)
Frocurement 2) (2)
(2) l l l l l l Supervisor Vendor Ops QA Ops QA quality Operational Ops QC Ops QC Evaluation / Surveillance Supw. Supw. Systees Support Surv. '
Supe (1) .
Elec/IEC Mech /NDE (2) Prograss Elec/I&C Mech /NDE (2) (2) (2) (2) (2)
(1) Offaite Organization (2) Onsite Organisation Figure 17.2-1 Programmatic direction pending filling
- of Technical Services Manager Position
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
HOUSTON LIGHTING & POWER ) Docket Nos. 50-498 OL COMPANY, ET AL. ) 50-499 OL
)
(South Texas Project, Units 1 )
and 2) )
MATERIAL FACTS AS TO WHICH THERE IS NO GENUIN.- ISSUE TO BE HEARD Pursuant to 10 C.F.R. 5 2.749(a), Applicants hereby submit a statement of material facts as to which there is no genuine issue to be heard in conjunction with their motion for summary disposition of Issue F.
(1) HL&P's Quality Assurance Program for the operation of STP (the STP Operations QA program) is described in Attachments A, B, and C to the March 10, 1986, Affidavit of Mr. James E. Geiger (attached).
(2) The STP operations QA program includes appro-priate plans for inspections, audits, survell-lance, documenting, tracking and trending of deficiencies, review of vendor quality programs, and other monitoring of STP quality related programs. Affidavit of Mr. James E. Geiger at 11 5-9.
O 6
(3) The STP operations QA program includes appro-priate requirements for personnel qualifica-tion, experience, and training. Affidavit of Mr. James E. Geiger at 11 11-13.
(4) The STP operations QA organization will have a staff and organization sufficient to perform its functions in compliance with Appendix B. Affidavit of Mr. James E. Geiger at 11 5-10 and Attachment C.
(5) The STP operations QA organization is struc-tured to provide organizational independence in the performance of its functions. Affida-vit of Mr. James E. Geiger at 1 3.
(6) The STP operations QA program satisfactorily addresses each of the 18 Criteria of Appendix B. Affidavit of Mr. James E. Geiger at 1 15 and Attachments A and B.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION k': MAR 141980'" G1
~~
Dodsnwas BEFORE THE ATOMIC SAFETY AND LICENSING BOARD y EnggggyjtCE In the Matter of ) 6>
)
HOUSTON LIG;'ING & POWER ) Docket Nos. 50-498 OL COMPANY, ' t AL. ) 50-499 OL
)
(South Texas Project, Units 1 )
and 2) )
I CERTIFICATE OF SERVICE l I hereby certify that copies of " Applicants' Motion For Summary Disposition On Issue F" have been served on the following individuals and entities by deposit in the United States mail, first class, postage prepaid, or by arranging for delivery as indicated by asterisk, on this 12th day of March, 1986.
l Charles Bechhoefer, Esq.* Brian Berwick, Esq.
Chairman, Administrative Judge Assistant Attorney General Atomic Safety and Licensing For the State of Texas
- Board Panel Environmental Protection l
U.S. Nuclear Regulatory Division Commission P.O. Box 12548, capitol Station Washington, D.C. 20555 Austin, TX 78711 Dr. James C. Lamb, III Kim Eastman, Co-coordinator Administrative Judge Barbara A. Miller 313 Woodhaven Road Pat Coy Chapel Hill, NC 27514 Citizens-Concerned About Nuclear Power Frederick J. Shon* 5106 Casa Oro Administrative Judge San Antonio, TX 78233 U.S. Nuclear Regulatory Commission Lanny Alan Sinkin*
- Washington, D.C. 20555 Christic Institute 1324 North Capitol Street Mrs. Peggy Buchorn Washington, D.C. 20002 Executive Director Citizens for Equitable Ray Goldstein, Esq.
Utilities, Inc. Gray, Allison & Becker Route 1, Box 1684 1001 Vaughn Building Brazoria, TX 77422 807 Brazos 78701-2553
' Austin, TX 1
F
,$ 1
- 2 '-
Oreste Russ Pirfo, Esq.*
Robert G. Perlis, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Ac.omic Safety and Licensing Appeal Board U.S. Nucl.Ar Regulatory Commission Washington, D.C. 20555 Docketing and Service Section Office'of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 itRC-
- By Messenger 1
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