Purpose:

This document sets forth the foundations for quality for the FPL Nuclear Division.

Responsibilities: A. Safety Safety is our number one priority. FPL is committed to the safe, reliable and cost effective operations of our nuclear units. B. Quality is everyone's responsibility The term "Quality" includes all those actions that are necessary to achieve safety, reliability, availability, and economy. Quality is the responsibility of everyone working in the Nuclear Division. It is not the exclusive responsibility of Nuclear Assurance or any other particular work group or department. Management and every employee must understand these basic premises and adhere to them to achieve safety, reliability, availability, and economy. Quality means acting in the long term best interests of the company by doing the following: 1. Defining the right job 2. Doing it right the first time 3. Adhering to all valid requirements 4. Serving the needs of the customer C. Management Accountability Every member of supervision is responsible to have a general understanding of regulatory requirements (i.e. 10CFR50 Appendix B) and industry or INPO guidelines pertaining to their area of responsibility, and should continuously assess their organizations compliance with those requirements to identify and correct their own problems. The line organization should not rely on the Nuclear Assurance Department to tell them what the requirements are. However, Nuclear Assurance independently evaluates the compliance of the line organization to those requirements. Our quality system will not function properly unless line management is accountable for applicable quality requirements. D. Nuclear Assurance Department The Nuclear Assurance (QA) Department assesses and reports on the quality of programs, processes, and products through formal audits, surveillance, independent technical reviews, and quality control inspections. However, quality cannot be assessed or inspected into a program, process, or product. Rather, the Nuclear Assurance Department enhances quality through its influence on the behavior of nuclear personnel and how they conduct business. The Nuclear Assurance Department shall:

1. Advise line management, including the Chief Nuclear Officer, on the status of quality, significant quality trends, and the principal threats to quality. 2. Consult line management as requested in areas where the Nuclear Assurance organization can provide independent insights. 3. Promote the principals of quality, safety, and self-assessment in all of our communication opportunities. 4. Improve the way we do business by keeping abreast of the technological advances in the industry. 5. Produce quality assessments that clearly identify performance issues, using available information such as performance trending results and probabilistic safety analyses to focus department resources on activities important to safety. Building Blocks of Quality: A. Self-Assessment Philosophy Individuals are expected to find and correct their own problems through self-assessment. It is the policy of Nuclear Division management to proactively pursue continuous improvements in products and services through the performance of self-assessment activities in each department. Self-assessment activities are a proactive part of the corrective action process whereby the responsible individuals and organizations assess their own products and services, to identify and correct their own problems. The expected results of high quality self-assessment activities are measurable reductions in the frequency and severity of problems or events, and a reduction in deviations from established requirements. Modifications, new personnel, shifted responsibilities, new suppliers, new contractors, new and revised procedures, and policies can be the precursors of quality problems. Since change is such a pervasive and necessary part of our work environment, we put particular emphasis on monitoring the thoroughness of change control measures through pre-emptive or periodic self-assessments. Change must be effectively controlled so that all aspects of the change are done with appropriate foresight and with skeptical monitoring. Independent assessments conducted by Nuclear Assurance are to be primarily directed toward evaluating the effectiveness of the audited organization's self-assessments. In order to do this, Nuclear Assurance needs to check some of the specific attributes of their activities, processes, programs, and services. The first two levels of defense of quality should be fully capable of assessing their own quality. When Nuclear Assurance finds a problem the organization itself did not find, it is an indication of weakness within the organization's self-assessment.

B. Four levels of defense-in-depth: 1. Individuals and Work Groups: The first level of defense is provided by individual and work group activities. This is the only level of defense which provides real-time, 100% exposure to conditions adverse to quality. Individuals and work groups contribute by adhering to procedures, training, meticulous and systematic self-checking, implementation of the Quality Program and providing feedback to management. They also inform management of potential and actual conditions adverse to quality as well as opportunities for raising standards of excellence. This requires maintaining a critical questioning perspective as part of every task. Every individual owns the first level of defense. Problems effectively surfaced at this first line of defense are most economically addressed. Problems that are identified by the third and fourth levels of defense or by a self-disclosing event are typically more expensive to solve, may result in equipment damage, and disrupt the organization. 2. Supervision and Management: The second level of defense is made up of all levels of supervision and management from the task leader to senior management. A condition adverse to quality detected by the second level of defense is usually indicative of at least two conditions adverse to quality - the detected condition and a self-assessment weakness in the first level of defense. The second level of defense is responsible for first level performance by ensuring that the first level: a. Understands the standards of performance b. Is appropriately staffed and trained c. Has up-to-date and approved procedures d. Has required tools and equipment e. Receives meaningful coaching and instruction at the job site f. Performs self-assessment and supports a culture of self and independent assessment g. Implements the corrective action process 3. Independent Assessment: The third level of defense, independent assessment, consists of Nuclear Assurance and the site safety review committees: Plant Nuclear Safety Committee (PNSC), Facility Review Group (FRG), and Station Operating Review Committee (SORC). The contribution of the third level of defense is to provide sampling checks of the processes, programs, products, and services of the first and second level, and assess the effectiveness of self-assessment efforts. Any condition adverse to quality detected by the third level of defense is usually indicative of at least three conditions adverse to quality: the detected condition and self-assessment weaknesses in the first two levels of defense. 4. External Observation: The fourth level of defense is made up of non-company organizations such as NRC and INPO. They assess the first three levels, especially with respect to the effectiveness of self-assessment efforts, and provide feedback.

Any condition adverse to quality detected by the fourth level of defense is usually indicative of at least four conditions adverse to quality; the detected condition and self-assessment weaknesses in the first three levels of defense. The Company's Nuclear Review Board (CNRB) members act as if they are part of the fourth level of defense when performing their function of objective assessment from an independent and external perspective. C. Assessing Quality Nuclear Assurance does not directly measure quality. Instead, they identify conditions adverse to quality, as well as practices which enhance quality. Assessments should clearly state the effectiveness of the audited organization in meeting applicable requirements and management expectations, as well as the organizations success in finding and correcting its own problems in a timely manner. When serious performance problems are uncovered by Nuclear Assurance, they will provide the factual basis for any conclusions, and share the process by which those conclusions were arrived at. Additionally, Nuclear Assurance is to appropriately state whether the organization is effectively implementing the Quality Assurance Program. D. Corrective Actions 1. Conditions adverse to quality: Truly isolated conditions adverse to quality are rare. Seldom does anything go wrong due to a single causal factor. We should be skeptical of event investigations reporting only one causal factor. In rare cases in which an event of interest can be attributed to a single causal factor, we should ask whether the fact that there was only a single barrier is another causal factor (inadequate defense-indepth). The causal factors of significant events are the same as the causal factors of non-significant events. The greater the significance of an event, the larger the number of independent causal factors that could have contributed to it, and the larger the number of precursors that should have alerted the accountable personnel. 2. Management prerogative in accepting risk: Management has the responsibility to expend or reduce the resources consistent with the value added. It is a function of management to decide, within the bounds of its regulatory commitments, which risks it will accept and which it will address. When events have multiple causes, it is frequently effective to correct some, but not necessarily all of the casual factors. Management is expected to justify the quality and risk rationale for their decisions. 3. Resources applied commensurate with significance: Problems should be characterized as to their quality and risk impact so resources can be applied prudently in a manner commensurate with the potential impact on the mission of the Nuclear

Division. It is important to determine the quality impact, the pervasiveness, and the potential safety risk of conditions adverse to quality. 4. Human performance: Nuclear Division personnel abide by high standards and strive to complete every task without errors. However, except for the results of sabotage, natural phenomena, and risk-based decisions, adverse events at nuclear power stations are caused, in part, by personnel errors. Personnel errors usually cannot be readily corrected, but their underlying causes may be addressed, if known. The majority of personnel errors are indicative of a breakdown in the plants defense-indepth. It is generally more productive to focus on how the system failed the individual, rather than how the individual failed. Management is expected to focus on failed barriers and underlying causal factors, to find effective ways of addressing the causes of personnel errors. Management Commitment to Quality: Quality is not achieved merely by the correction of identified conditions adverse to quality and their causal factors. Rather, quality is achieved by a solid understanding of quality, and a firm commitment to quality and the corrective action program on the part of management and every member of the nuclear organization. Corrective actions for conditions adverse to quality must address the broader (generic) implications of the identified symptoms and causal factors. Management is expected to understand the self-assessment weakness that prevented timely detection of the problem; correcting a self-assessment weakness has the potential for future prevention or early detection of a host of similar conditions adverse to quality. Acknowledgment: This document is based on "Nuclear Quality Assurance Operational Philosophy," dated 05/30/95 by William R. Corcoran, PhD, PE, and modified by Nuclear Assurance for application at FPL's Nuclear Division.

Approval:

Signature on file Chief Nuclear Officer