ML13317B309
| ML13317B309 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/28/1991 |
| From: | Southern California Edison Co |
| To: | |
| Shared Package | |
| ML13317B308 | List: |
| References | |
| SCE-1-A-04, SCE-1-A-4, NUDOCS 9103060205 | |
| Download: ML13317B309 (11) | |
Text
TABLE OF CONTENTS SECTION/
SUBSECTION NO.
TITLE PAGE AMENDMENT/CN #
Table of Contents 17-i 13 38 17-ii 13 38 17-iii 13 List of Tables 17-iv 13 List of Figures 17-v 13 List of Amendments 17-vi 13 13 17.0 Introduction 17.0-1 6
17.0.1 Definitions 17.0-2 13 17.0-3 13 17.0-4 13 17.0-5 12 SECTION I:
QUALITY ASSURANCE DURING THE DESIGN &
13 CONSTRUCTION PHASE Deleted SECTION II:
QUALITY ASSURANCE DURING THE OPERATIONS PHASE 17.2.1 Organization 17.2-1 13 17.2-2 12 17.2-3 13 17.2-4 13 17.2-5 13 17.2-6 13 17.2-7 13 17.2-7a 13 17.2-7b 12 17.2-8 13 17.2-9 13 17.2.2 Quality Assurance Programs 17.2-10 13 17.2-11 13 17.2-12 13 17.2-13 13 17.2-13a 13 17.2.3 Design Control 17.2-14 7
17.2-15 13 17.2-16 13 17.2-16a 5
17.2.4 Procurement Document Control 17.2-17 13 38 17.2-17a 13 38 17.2-18 13 38 17.2-19 13 17.2.5 Instructions, Procedures, & Drawings 17.2-20 13 17.2-21 13 17.2.6 Document Control 17.2-22 5
17.2-23 13 17.2-24 13 2/91 17-i Amendment 13 CN #38 910:3060205 910228 PDR ADOCK 05000206 P
(1)
TABLE OF CONTENTS SECTION/
SUBSECTION NO.
TITLE PAGE AMENDMENT/CN #
17.2.7 Control of Purchased Material, Equipment & Services 17.2-25 13 17.2.7 Control of Purchased Material Equipment and Services 17.2-26 1
17.2-27 13 38 17.2.8 Identification and Control of Materials, Parts and Components 17.2-28 12 17.2-29 13 17.2.9 Control of Special Processes 17.2-30 13 17.2.10 Inspection 17.2-31 5
17.2-32 13 17.2-33 13 17.2.11 Test Control 17.2-34 12 17.2-35 13 17.2-36 13 17.2.12 Calibration Program 17.2-37 10 17.2-38 13 17.2-39 10 17.2-39a 13 17.2-39b 13 17.2.13 Handling, Storage and Equipment 17.2-40 13 17.2.14 Inspection, Test and Operating Status 17.2-4113 17.2-42 13 17.2.15 Nonconforming Materials, Parts or Components 17.2-43 13 17.2-44 13 17.2-45 13 17.2-46 13 17.2.16 Corrective Action 17.2-47 13 17.2-48 13 17.2.17 Quality Assurance Records 17.2-49 13 17.2-50 13 17.2.18 Audits 17.2-51 13 17.2-52 13 17.2-53 13 17.2.19 Quality Assurance Program for Fire Protection Program 17.2-54 13 17.2-55 8
17.2-56 13 38 17.2-57 13 38 17.2-58 13 17.2-59 6
Table 17.2-1 17.2-60 6
Table 17.2-1 (Continued) 17.2-61 6
Table 17.2-1 (Continued) 17.2-62 6
Table 17.2-2 17.2-63 13 Table 17.2-2 (Continued) 17.2-63a 12 Table 17.2-3 17.2-64 13 38 Table 17.2-3 (Continued) 17.2-65 7
2/91 17-ii Amendment 13 CN #38
172.4 PROCUREMENT DOCUMENOONTROL 17.2.4.1 Scope This subsection describes the measures utilized by SCE to control documentation associated with procurement of items and services in compliance with Regulatory Guide 1.123 (reference Table 17.2-1).
17.2.4.2 Procurement Document Control Procurement Documents defining the technical requirements for system changes or modifications at nuclear generating stations are prepared by responsible engineers within cognizant SCE engin eering organizations.
The Procurement Division of the SCE Fuel and Material Management Department is responsible for contract negotiations and the issuance of purchase orders, except for Nuclear Fuel.
Procurement Documents for Nuclear Fuel and spent fuel shipping services are prepared and controlled by the SCE Nuclear Engineering, Safety and Licensing Department. The Nuclear Oversight Division is responsible for performing periodic 13 CN #38 audits, as described in Subsection 17.2.18 to verify effective implementation of procurement document control requirements.
For procurement of items and services by SCE, a multilevel procurement system is established. This system controls the following areas:
a) Extent of procurement document requirements necessary for procurement of items and services.
b) Level of review and approval of procurement documents CN #38 by cognizant engineering personnel.
c) Degree of qualification of the supplier from a quality assurance aspect.
d) Method of product acceptance.
2/91 17.2-17 Amendment 13 CN #38
17..2.4.2 (continued) 0 The procurement system assures that the appropriate technical and quality requirements are specified for procurement of items and services considering the safety related function, 13 complexity of design and manufacturing, degree of inspectability and testability upon receipt and other factors which affect product quality.
Written procedures are established which define the sequential activities necessary for preparation, review, approval, and control of Procurement Documents, both offsite and onsite. These procedures identify the responsible organizations and function of individuals performing the Procurement Document control activities. These procedures are maintained in station files and in manuals as listed on Table 17.2-2.
Procurement Documents, and revisions thereto, are reviewed and approved by responsible engineers to verify that they contain or reference CN #38 technical requirements appropriate to the item or service to be procured, including:
o Regulatory requirements, codes, and industry standards.
o Component-and material identification requirements.
o Design requirements, including drawings and specifications.
o Test and inspection requirements.
o Special process instructions.
o Handling, storage, and shipping instructions.
2/91 17.2-17a Amendment 13 CN #38
17-.2.4.2 (continued) o Documentation to be prepared, maintained, and submitted to SCE for review and approval.
o Records to be retained, controlled, and maintained by the supplier and those to be delivered to SCE prior to use or installation of the item.
CN #38 Procurement Documents prepared by SCE identify the applicable 10CFR50, Appendix B, requirements, regulatory guides, codes, and standards, which must be complied with and described in suppliers' quality assurance programs. These programs are reviewed by the Nuclear Oversight Division.
l13 The control measures described herein apply to original items as well as spare or replacement parts, and to changes to Procurement Documents. The review and approval of Procurement Documents is CN #38 documented prior to release and is available for verification.
17.2.4.2.1 Engineering Construction Projects (ECP's)
Procurement Documents associated with ECP's may be prepared by SCE, an A-E, or other qualified contractors. Determination of responsibility for Procurement Document preparation is made by the SCE Project Manager responsible for the ECP.
2/91 17.2-18 Amendment 13 CN #38
17,2.7.2 (continued) o Nonconforming items are segregated, controlled, and clearly identified until proper disposition is made.
The responsibility for receiving inspection rests with Nuclear Oversight Division personnel.
All Safety-Related material, 13 components, equipment, and services are subject to surveillance and audit by the Nuclear Oversight Division.
Procurement specifications require suppliers to furnish the following records to SCE, as a minimum, with delivered items:
o Certifications that specifically identify the purchased material and equipment, and the specific procurement requirements such as codes, standards, specifications, procedures, and drawings that are met by the items.
o Certifications that identify procurement requirements that were not met, together with a description of those nonconformances dispositioned Accept-As-Is or repair or certifications that identify compliance to procurement document requirements.
Quality Assurance Engineers audit these certifications for CN #38 completeness and accuracy.
13 The verification of the validity of supplier certificates and the effectiveness of the certification system is accomplished as an integral part of the total supplier control and product acceptance program.
Spare or replacement parts for structures, systems, and components are subject to controls at least equivalent to those used for the original equipment.
17.2.7.2.1 Engineering Construction Projects (ECP's)
Receiving inspection associated with an ECP is performed by SCE, A-E's or contractors in accordance with written procedures which are subject to review by the SCE Nuclear Oversight Division.
l13 Material, equipment, and services purchased through A-E's and contractors for ECP's are controlled as specified in their quality assurance programs. These programs are reviewed and approved by the SCE Nuclear Oversight Division.
l13 2/91 17.2-27 Amendment 13 CN #38
17.2.19.3 (continued) items functioning for the time period required for safe reactor shutdown and maintenance of the reactor in a safe shutdown condition. As a part of the design review measures stipulated above, the following areas as related to fire protection will be specifically reviewed when design documents are released by the associated design organization:
A. Safety-related systems are isolated from unacceptable fire hazards.
B. Redundant safety-related systems are not subject to damage from a single fire hazard.
C. Access is provided to and escape routes established from each fire area for fire fighting personnel and equipment.
D. Accessibility is provided for periodic inspection and maintenance of fire protection equipment.
E. Fire protection equipment is suitable for its intended application as applied to the various plant areas in which it will be required to function.
F. Inspection and testing acceptance criteria are established for fire protection equipment.
G. Compliance with appropriate codes, quality standards and regulatory requirements is specified as related to fire protection.
17.2.19.4 Procurement Document Control Procurement document control measures shall be provided consistent with the provisions of subsection 17.2.4 and this paragraph. These measures shall assure that procurement specifications, purchase orders and associated documents for procurement of fire protection program material, equipment and services contain applicable regulatory requirements, design disclosure documentation, source inspection and audit provisions, codes and standards compliance, quality verification document submittal requirements, and appropriate quality assurance program provisions.
The specification of quality assurance program provisions for suppliers shall be based on the requirements of this Program.
13 The Nuclear Oversight Division is responsible for performing periodic audits, as described in Subsection 17-2.18, to verify CN#38 that applicable requirements are stipulated consistent with the nature and use of the procured material or service.
2/91 17.2-56 Amendment 13 CN #38
17.2.19.4 (continued)
CN#38 17.2.19.5 Instructions, Procedures and Drawings Instructions, procedures and drawings shall be developed and implemented in accordance with the requirements of subsection 17.2.5 and this paragraph. These documents shall include all activities affecting the fire protection program including inspections, tests, administrative controls, fire drills, and training.
For Station and ECP activities, emergency plans and procedures shall be developed to implement fire fighting and control activities. The plans and procedures will include a clear identification of responsibilities, actions, cautions and dangers unique to the plant, including interfaces between Station, ECP, and offsite fire fighting teams and equipment.
17.2.19.6 Document Control Document control measures for the fire protection program shall be provided in accordance with the requirements of subsection 17.2.6 and this paragraph. These provisions shall assure that documents affecting fire protection equipment or activities shall be reviewed for adequacy and approved for release by authorized personnel and shall be distributed to and used at the location where the prescribed activity is performed.
6 17.2.19.7 Control of Purchased Material, Equipment and Services Contractors supplying material, equipment and services for the fire protection program will be subject to source evaluation and surveillance in accordance with the provisions of subsection 17.2.7 and this paragraph. The extent and application of these provisions to the fire protection program will be determined on a case-by-case basis by the design and quality assurance organizations responsible for review and approval of the procurement specifications. This determination shall be based on the complexity of the item being manufactured, the function of the item in service and the degree of inspectability upon receipt and installation at the jobsite.
Documentary evidence will be provided, where feasible, to identify the specific requirements, such as codes, standards or specifications met by the purchased material and equipment.
2/91 17.2-57 Amendment 13 CN #38
TABLE 17.2-3 NUCLEAR OVERSIGHT DIVISION ACTIVITIES OPERATION 113 The following are SCE Nuclear Oversight Division personnel 13 activities during the design and construction of nuclear generating stations including the support of Engineering Construction Projects (ECP's):
- 1.
Perform periodic audits to assure effective implementation CN #38 of procurement document control requirements.
- 2.
Prepare and maintain quality assurance manuals, procedures, and instructions. Maintain quality assurance chapters in FSAR's current. Maintain Topical Reports.
- 3.
Review and approve quality assurance procedures and instructions prepared by other internal organizations.
- 4.
Evaluate potential supplier's quality assurance manuals.
CN #38
- 5.
Perform quality assurance preaward surveys of potential suppliers' facilities and quality assurance programs.
- 6.
Perform inspection and surveillance at supplier's facilities.
- 7.
Conduct internal surveillances, audits, and assessments of CN #37 SCE organizations and external audits of A-E's or other contractors and suppliers to SCE.
Reaudit to verify implementation of corrective action.
- 8.
Initiate nonconformance reports, corrective action reports, and follow-up to assure proper implementation of corrective action.
- 9.
Participate in and provide quality assurance training.
- 10.
Provide written reports to management regarding status of quality assurance activities, corrective actions required, or unresolved problems.
- 11.
Support the Corporate Documentation Management Center to assure proper filing and retention of appropriate quality assurance documentation.
2/91 17.2-64 Amendment 13 CN #38
SOUTHERN CALIFORNIA EDISON COMPANY TOPICAL REPORT SCE-1-A CHANGE NOTICE Change Notice Number:
38 Affected Amendment:
13 Affected Pages:
17-i, 17-ii, 17.2.17, 17.2-17a, 17.2-18 17.2-27, 17.2-56, 17.2-57, 17.2-64 Description of Change:
The Nuclear Oversight Division in-line review and approval of procurement documents is being revised to reflect the use of audits/surveillances to monitor the adequacy of the procurement document control process. Procurement documents will no longer be reviewed and approved as an in line function by the Nuclear Oversight Division.
Appropriate audits/ surveillances will be conducted to assure.that procurement documents include appropriate quality requirements.
Reason For Change (including basis for concluding that the change satisfies the criteria of 10CFR50, Appendix B, and the quality assurance program commitments previously accepted by the NRC):
The organizations presently responsible for development, review and approval of procurement documents are required to assure that these documents contain appropriate quality assurance requirements. The Nuclear Oversight Division will assure through appropriate audits and surveillances that process controls are maintained by the responsible organizations, related to procurement documents, to achieve compliance with regulatory requirements contained in 10CFR50 Appendix B. Criteria IV, V, VI, VII and XVII.
SCE has performed evaluations which we conclude indicate that continued in-line reviews of procurement documents are not identifying discrepancies that affect quality. The results of these evaluations are summarized as follows:
Of 4145 procurement documents reviewed by the Nuclear Oversight Division, 2.4% were returned for minor deficiency resolution. Examples of deficiencies included:
Missing Signatures Information incomplete/need clarification Requirements need clarification These deficiencies for the most part, represent minor administrative processing errors that are not safety significant and would be corrected during the normal course of events.
All document deficcies were corrected and cnitment to aQtions to prevent recurrence was obtained from the organization involved.
We believe our resources can be more effectively utilized, consistent with NRC regulations, by oversight techniques which emphasize in-depth assessments of the entire procurement document control process and its results with particular attention to the Commercial Grade Issue and NUMARC initiatives.
Corrective Action Which Would Be Taken if Unacceptable Quality Levels are Indicated If as a result of the audits/surveillances, unacceptable quality levels are indicated, corrective action measure to be undertaken by the Nuclear Oversight Division will include issuance of corrective action documents to the responsible organization(s).
If the SCE Corrective Action system does not provide adequate results, the in-line review of procurement documents by the Nuclear Oversight Division will be reinstated.
Conclusion This Change Notice is submitted in accordance with 10CFR50.54 (a)(3) on the basis that it provides for more effective use of SCE resources to provide high quality procurement documents in compliance with NRC regulations. We believe that the results of our evaluation demonstrate that continued in-line reviews by Nuclear Oversight are of low payback and that replacement of the in-line reviews with in-depth audits/surveillances which emphasize assessments of the entire procurement document control process including receipt inspection results will provide for high quality procurement documents.
Change x
does
____ does not reduce commitments previously accepted by the NRC.
Approvals:
Manager of Nucl6gr Oversight Senior Vice Pr dent Date Submitted to NRC: February 28, 1991