ML13319A850
| ML13319A850 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 07/31/1994 |
| From: | Ray H Southern California Edison Co |
| To: | |
| Shared Package | |
| ML13319A849 | List: |
| References | |
| SCE-1-A-A-17, NUDOCS 9407270248 | |
| Download: ML13319A850 (74) | |
Text
SOUTHERN CALIFORNIA EDISON COMPANY TOPICAL REPORT QUALITY ASSURANCE PROGRAM SCE-1-A APPROVALS MANAGER OF N LEAR OVERSIGHT SENIOR VICE PRESIDENT, OWER SYSTEMS Amendment 17 July 1994 9407270248 940722 PDR ADOCK 05000206 p
TABLE OF CONTENTS SECTION/
SUBSECTION NO.
TITLE PAGE AMENDMENT/CN #
Table of Contents 17-i 17 17-ii 17 List of Tables
.17-iii 13 List of Figures 17-iv 17 List of Amendments 17-v 17 17.0 Introduction 17.0-1 17 17.0.1 Definitions 17.0-2 17 17.0-3 17 17.0-4 17 SECTION I: QUALITY ASSURANCE DURING THE DESIGN & CONSTRUCTION PHASE Deleted SECTION II:
QUALITY ASSURANCE DURING THE OPERATIONS PHASE 17.2.1 Organization 17.2-1 17 17.2-2 17 17.2-3 17 17.2-4 17 17.2-5 17 17.2-6 17 17.2-7 17 17.2-8 17 Figure 17.2.1 - Corporate 17.2-9 17 Figure 17.2.1a - Nuclear Organization 17.2-10 17 Figure 17.2.1b - Nuclear Organization 17.2-11 17 Figure 17.2.2 -
Interface 17.2-12 17 17.2.2 Quality Assurance Programs 17.2-13 17 17.2-14 17 17.2-15 17 17.2-16 17 17.2.3 Design Control 17.2-17 17 17.2-18 17 17.2-19 17 17.2.4
- Procurement Document Control 17.2-20 17 17.2-21 17 17.2.5 Instructions, Procedures, & Drawings 17.2-22 17 17.2.6 Document Control 17.2-23 17 17.2-24 17
.17.2.7 Control of Purchased Material, 17.2-25 17 Equipment & Services 17.2-26 17 7/94 17-i Amendment 17
TABLE OF CONTENTS SECTION/
SUBSECTION NO.
TITLE PAGE AMENDMENT/CN #
17.2.8 Identification and Control of 17.2-27 17 Materials, Parts and Components 17.2.9 Control of Special Processes 17.2-28 17 17.2.10 Inspection 17.2-29 17 17.2-30 17 17.2.11 Test Control 17.2-31 17 17.2-32 17 17.2-33 17 17.2.12 Calibration Program 17.2-34 17 17.2-35 17 17.2-36 17 17.2-37 17 17.2.13 Handling, Storage and Shipping 17.2-38 17 17.2.14 Inspection, Test and Operating Status 17.2-39 17 17.2.15 Nonconforming Materials, Parts or 17.2-40 17 Components 17.2-41 16 17.2-42 17 17.2-43 17 17.2.16 Corrective Action 17.2-44 17 17.2-45 17 17.2.17 Quality Assurance Records 17.2-46 13 17.2-47 13 17.2.18 Audits 17.2-48 13 17.2-49 17 17.2-50 17 17.2.19 Quality Assurance Program for Fire 17.2-51 17 Protection Program 17.2-52 17 17.2-53 17 17.2-54 17 17.2-55 6
Table 17.2-1 Southern California Edison Company 17.2-56 6
Quality Assurance Program Compliance to 17.2-57 6
Guides, Requirements, and Standards -
17.2-58 6
Operation Table 17.2-2 Southern California Edison Company 17.2-59 17 Quality Assurance Program Implementing 17.2-60 16 Procedures Table 17.2-3 Nuclear Oversight Division Activities -
17.2-61 17 Operation 7/94 17-ii Amendment 17
LIST OF TABLES TABLE NO.
TITLE PAGE 17.2-1 Southern California Edison Company 17.2-56
-Quality Assurance Program Compliance to Guides, Requirements, and Standards Operation 17.2-2 Southern California Edison Company 17.2-59 Quality Assurance Program Implementing Procedures 17.2-3 Nuclear Oversight Division Activities 2-61 13 Operation 7/93 17-iii Amendment 13
LIST OF FIGURES IGURE NO.
TITLE PAGE 17.2-1 SCE Quality Program Organization -
17.2-9 17 Corporate Structure 17.2-la SCE Quality Program Organization -
17.2-10 17 Nuclear Generation Department 17.2-1b SCE Quality Program Organization -
17.2-11 17 Engineering & Technical Services 17.2-2 SCE Quality Program, Typical Interface 17.2-12 17 Organization 7/94 17-iv Amendment 17
LIST OF AMENDMENTS Amendment No.
Amendment Date Original October 26, 1976 1
March 1977 2
May 1978 3
April 1980 4
April 1981 (Modified August 1981) 5 December 1981 (Modified March 1982 to incorporate Change Notices 1 through 3.)
6 April 1983 7
June 1984 8
July 1985 9
July 1986 10 July 1987 11 July 1988 12 July 1989 13 July 1990 14 July 1991 15 July 1992 16 July 1993 17 July 1994 7/94 17-v Amendment 17
- 17. QUALITY ASSURANCE O
17.0 INTRODUCTION
This topical report was prepared in accordance with the Nuclear Regulatory Commission's (NRC) "Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants" (NUREG-75/094, Regulatory Guide 1.70, Revision 2, September 1975).
Guidance used in the preparation was obtained from the NRC's "Standard Review Plan" (NUREG-74/087, November 24, 1975).
The purpose of this report is to describe the Quality Assurance Program applicable to those Southern California Edison Company (SCE) nuclear generating stations which reference this topical report on their docket. Deviation from this program if required, will be described in the applicable SAR.
Section 17.2 describes the operational phase quality assurance 17 programs.
The program is applied to all activities affecting the Safety-Related functions of those structures, systems and components which prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public.
It complies with the requirements, guides, and standards listed on Table 17.2-1, as appropriate, for the operational phases of nuclear generating stations. The program also applies to activities governed by the Station Technical Specifications and other activities licensed by the NRC.
SCE as applicant, plant owner and operator, maintains full responsibility for the quality assurance program for all phases of nuclear generating station development and operations.
Other organizations may be delegated the work of establishing and executing portions of the Quality Assurance Program. The quality assurance programs of these organizations and the scope of delegation are as described in the applicable Safety Analysis Report (SAR).
Changes to the SCE Quality Assurance Program will be incorporated into this topical report by amendment. Changes.
will be submitted to the NRC in accordance with the requirements of 10CFRSO.54a.
7/94 17.0-1 Amendment 17
17.0.1 DEFINITIONS
.Following are definitions of terms used in this report.
Additional terms not defined by this subsection are defined in ANSI N45.2.10, as endorsed by Regulatory Guide 1.74.
Architect-Engineer (A-E) - An organization contracted to design, construct and perform backfit modifications to a nuclear generating station.
Accept-As-Is - A disposition to accept a nonconforming item without further work as the deviation is judged not to negatively affect the as-designed quality or function of the item.
Administrative Authority - The responsibility of an individual to direct the work (excluding technical direction) of another individual or group including the responsibility for hiring, firing, salary review, and position assignment of an individual.
See Technical Authority.
Auditor - An individual who performs any portion of an audit, including lead auditors, technical specialists and other such as management representatives and persons in training to become Lead Auditors.
Construction Material Tests -
Physical and chemical testing of
.materials intended for construction use to verify conformance with material specifications.
Consultant - A person or organization retained under contract by SCE to provide expert advice, recommendations, or work.
Corporate Documentation Management (CDM) Centers - The locations where project documents including quality assurance records, are maintained in accordance with established documentation retention and control requirements.
Design Documents - Drawings, P&I diagrams, calculations, 117 or specifications which define items and which are needed to translate engineering concepts into structures, systems and components.
l17 Engineering Review Board (ERB) - Those cognizant individuals responsible for providing approvals of Accept-As-Is or repair dispositions of nonconformance reports.
Engineering Review Process - The procedure used to determine dispositions of nonconforming items.
l17 In-Service Inspection - The planned and periodic nondestructive examinations performed on installed and/or operating structures, systems, and components, as required by Section XI of the ASME Boiler and Pressure Vessel Code.
7/94 17.0-2 Amendment 17
17.0.1 (Continued)
.*In-Service Tests - Testing which is conducted to satisfy the requirements of Section XI of the ASME Boiler and Pressure Vessel code.
Modification Tegts - Those tests performed during or after completion of a modification to demonstrate that the affected structure, system or component can perform its design function and that it is compatible with existing plant systems.
Includes tests similar to those performed during the initial plant construction and startup.
Nuclear Fuel -
Fuel assemblies including but not limited to the following items:
fuel rods, poison rods (where applicable),
spacer grids, control element assembly guide tubes, and end fittings.
117 Nuclear Steam Supply System (NSSS) Supplier - An organization contracted to design and manufacture a nuclear steam supply system for a nuclear generating station.
Qualification - Required acts to select a source for providing items or services.
Preoperational Tests - Tests conducted to demonstrate the capability of items to meet safety-related performance requirements.
Procurement Documents - Contract documents including purchase orders, work assignments, memoranda of changes, and applicable design disclosures.
Project Direction - Direction or instructions concerned with project operations and defining when work is to be accomplished.
Includes coordination and day-to-day direction of activities of project entities receiving technical direction from others.
Project Engineer - The primary engineering interface for 17 Project Management from which project direction is received and the engineering organization from which technical direction is received.
117 Prototype Testg & Tests conducted in support of design activities to demonstrate the adequacy of the design to perform under the most adverse conditions.
Quality-Affecting Activities - Activities of people which either do or could influence quality of Safety-Related items or work, including designing, purchasing, constructing, fabricating, handling, shipping, storing, cleaning, preserving, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, or modifying. Also includes activities required by Station Technical Specifications or otherwise licensed by the NRC.
7/94 17.0-3 Amendment 17
17.0.1 (Continued)
Quality Assurance Functional Direction - Directions regarding quality assurance matters provided by the SCE Nuclear Oversight Division to other organizations which have been delegated the work of establishing and executing portions of the Quality Assurance Program.
Reference Standards - Standards (this is primary, secondary and working standards, where appropriate) used in a calibration program. These standards establish the basic accuracy limits for that program.
Reject - A disposition to remove a nonconforming item from use due to its unsuitability for the intended purpose.
Safety-Related - Applies to the prevention or mitigation of the consequences of postulated accidents that could cause undue risk to the health and safety of the public.
Shop Tests - Tests conducted at the source of fabrication to verify conformance with design requirements stipulated in design disclosure documents.
17 Station Tests - Tests to demonstrate that the work performed by the station staff or contractors is satisfactory and meets established requirements.
Includes operability testing and In-service Testing.
Stop Work - The authority to stop unsatisfactory work and control the further processing, delivery, or installation of nonconforming items.
This does not include the authority to stop station power operations.
Technical Authority - The authority to provide technical direction.
Technical Direction -
Instructions and directions defining technical requirements for an activity.
Technical Specification - Appendix A (Safety) and Appendix B (Environmental) to the operating license of a station issued by the Nuclear Regulatory Commission.
Unreviewed Safety Question - A proposed change, test or experiment involves an Unreviewed Safety Question if:
(1) the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the Safety Analysis Report (SAR) may be increased; or (2) the possibility for an accident or malfunction of a different type than any previously evaluated in the SAR may be created; or (3) the margin of safety as-defined in the basis for any Technical Specification is reduced.
7/94 17.0-4 Amendment 17
17.2 OUALITY ASSURANCE DURING THE OPERATIONS PHASE 7.2.1 ORGANIZATION 17.2.1.1 SCOPE This subsection describes the SCE organizational structure and responsibilities for establishing and executing the Quality Assurance Program for SCE operational nuclear generating stations, in compliance with Regulatory Guides 1.8, 1.28 and 1.33 (reference Table 17.2-1).
It includes a description of the interfaces with other organizations who may be delegated the work of establishing and executing portions of the Quality Assurance Program. The methods used for maintaining responsi bility for delegated portions of the Quality Assurance Program are identified as well as the management measures that provide the independence of the SCE Quality Assurance Organization.
17.2.1.2 General Responsibilities During the operational phase, the following departments within SCE are involved in quality-affecting activities:
Departments Responsibilities Engineering and Licensing, Nuclear Safety, Technical Services Environmental Monitoring, Offsite Emergency Planning, Quality Assurance, Design, Fuel Performance, Core Physics, Core Monitoring, Construction, Warehousing, Procurement Engineering, Handling & Shipping of Nuclear Fuel, Special Nuclear Material Accountability, In-Service Inspection, Training, and Refueling Nuclear Generation Station Operation, Maintenance, 17 Surveillance, Testing, Packaging and Transportation of Radioactive Material, Security, Site Emergency Preparedness, Chemistry, Health Physics, and In-Service Testing Business and Records Management and Procedure Financial Services Control Shop Services and Equipment Repair and Calibration Instrumentation Services Power Production Maintenance and Technical Support Performance Support Records Storage, Salvage and Retrieval, Procurement, Transportation of Material and Equipment (except Nuclear Fuel),
Contract Administration and Oversight of Site Security 7/94 17.2-1 Amendment 17
17.2.1.2 (Continued)
The SCE organizational structure of departments involved with 117 implementing the SCE Quality Assurance Program during the operational phase as well as departmental interfaces is presented on Figure 17.2.1, Figure 17.2.1a and Figure 17.2.1b.
117 In addition to the departmental responsibilities listed, Technical Specifications for operating nuclear generating stations describe the Safety-Related functions of the On-Site Review Committee (OSRC), Nuclear Safety Group (NSG), and Independent Safety Engineering Group (ISEG), a summary of these responsibilities is as follows:
Committee/Board/Group Responsibility OSRC Advise the Vice President, Nuclear 17 Generation on all matters related to safety.
NSG Provide independent review and audit of designated activities in the area of safety.
ISEG Provide onsite independent review of station activities and feedback of operating experience.
.The organizational structure, administrative requirements, responsibilities and authorities specific to each committee/
group is described in the Technical Specification for the applicable station and in internal procedures.
The ultimate responsibility for operating, maintaining, repairing, inspecting, testing, refueling, and modifying operational nuclear generating stations rests with the Chairman of the Board. He assigns responsibilities to the various SCE organizations involved in nuclear generating station operations.
The Senior Vice President, Power Systems, reports to the Chairman of the Board and is responsible for Engineering and Technical Services, Nuclear Generation Departments, Shop Services and Instrumentation Department, Fuels, and Power Production. The 17 Senior Vice President is responsible for the establishment of Quality Assurance policies.
The Vice President, Engineering and Technical Services, has been delegated the responsibility for the assurance of implementation of the SCE Quality Assurance Program in compliance with 10CFR50, Appendix B, and other applicable regulations and standards. He is authorized to request the cooperation of all officers and management personnel in support of this program.
7/94 17.2-2 Amendment 17
17.2.1.2 (Continued)
.OSCE corporate management is involved with quality assurance matters on continuing basis by means of regular Officer Council meetings. Nuclear Oversight Division weekly progress reports are prepared for the Vice President, Engineering and Technical 17 Services, and are used, as appropriate, for discussion items at these meetings. These reports usually contain significant progress items, corrective action recommendations, and unresolved items.
In addition, a quarterly report of information suitable for assessment of the status and adequacy of the SCE Quality Assurance Program is submitted to the Senior Vice President, Power Systems, other Nuclear Organization Vice Presidents, and Senior Managers by the Manager of Nuclear Oversight.
The Nuclear Control Board (NCB), which includes corporate officers and upper management personnel of the owners of the San Onofre facility; namely, SCE, and SDG&E, is an additional means 17 by which SCE corporate management is involved with quality assurance matters. As a member of the NCB, the Vice President, Engineering and Technical Services apprises this board of significant quality assurance matters related to station operations and modifications.
17.2.1.3 Nuclear Generation Department The Nuclear Generation Department, under the Vice President, Nuclear Generation, is responsible for operation of nuclear
. powered generating facilities.
The Vice President, Nuclear Generation, is responsible for 17 the safe and reliable operation, maintenance, testing, Security, Chemistry, refueling, and In-service Testing of the units and reports to the Senior Vice President, Power Systems.
17 The Vice President, Nuclear Generation, is responsible for the routine administration and implementation of the Quality Assurance Program at the station, including the following station organization functions, where appropriate:
o Review and approval of Design Documents for station 117 modifications.
o Review-and approval of Procurement Documents.
o Review and approval of administrative and technical procedures.
o Handling and Storage of Material and Equipment at the 17 Station.
o Operation and Maintenance of plant systems and equipment o Conducting Performance Tests and In-Service Testing and 17 Evaluations.
o Refueling 7/94 17.2-3 Amendment 17
17.2.1.3 (Continued) o Review of station operations and surveillance requirements of the Technical Specifications.
o Safety o Security o Training and examination of station personnel.
o Site Emergency Preparedness 17 17.2.1.4 Nuclear Engineering and Technical Services Department The Engineering and Technical Services Department, under the Vice President, Engineering and Technical Services, is responsible for nuclear safety and licensing, nuclear fuel, warehousing, offsite emergency preparedness, and engineering.
Engineering responsibilities include design, maintenance of design bases, drafting services, and supporting the various technical disciplines. Construction responsibilities include technical and administrative direction over project construction personnel and construction management. Other responsibilities include training of staff personnel, Inservice Inspection, Refueling, Environmental Monitoring, Meteorological Data 17 Collection and reviews of Environmental Impact for Nuclear Power Plant Activities.
W he Vice President, Engineering and Technical Services, is responsible for the assurance of implementation of the SCE Quality Assurance Program in compliance with applicable regulations, codes, and standards, including those listed in Table 17.2-1. He is responsible for establishing quality assurance goals and objectives and for assuring that the quality assurance policies are followed and the goals and objectives are achieved.
The Vice President, Engineering and Technical Services, is 117 responsible for apprising the Management of the effectiveness of the Quality Assurance Program. He is involved in the disposition of nonconformances of unusual complexity, and acts upon trending studies that indicate quality problems of a possible generic nature submitted to him by the Manager of Nuclear Oversight.
Direction for implementing the Quality Assurance Program is provided to individuals and groups by the Vice President, 17 Engineering and Technical Services, through the Manager of Nuclear Oversight.
7/94 17.2-4 Amendment 17
17.2.1.4 (Continued)
.The Manager of Nuclear Oversight, reports directly to the Vice President, Engineering and Technical Services, and has the responsibility for development, maintenance, and surveillance of the Quality Assurance Program as described in Quality Assurance manuals. To ensure the Manager of Nuclear Oversight remains independent of any potential line influence within the 17 Engineering and Technical Services Department, he has the authority and obligation to raise quality issues to the Senior Vice President, Power Systems for resolution if need be. The Quality Assurance manuals are reviewed and approved by the Manager of Nuclear Oversight and the Senior Vice President, Power Systems.
Other organizations involved with Quality Assurance Program implementation, as described in Subsection 17.2.1, review and comment on the Quality Assurance manuals, particularly as they apply to their area of involvement. The Manager of Nuclear Oversight, is responsible for identifying any conditions adverse 117 to quality and reporting them to the Vice President and to the Nuclear Control Board (NCB) of which he is a member. In addition, the Manager of Nuclear Oversight, is responsible for surveillance of Quality-Affecting Activities and has the authority to Stop Work or delegate this authority, in writing, to other personnel.
The minimum qualification requirements for the position of Manager of Nuclear Oversight, are as follows:
o Bachelor of Science Degree in one of the engineering disciplines from an accredited college or university.
o Ten years experience in design, fabrication, construction, testing, operation, or quality assurance related to the nuclear power field.
o Management and administrative ability demonstrated by experience and training.
o Extensive knowledge of regulatory requirements for nuclear generating stations.
The Nuclear Oversight Division, under the direction of the Manager of Nuclear Oversight, develops and administers the Quality Assurance Program for the operational phase of nuclear generating stations.
It is comprised of engineers with expertise in the various disciplines required for performing quality assurance and quality control activities. This organization audits, inspects, or otherwise verifies that activities within the scope of the SCE Quality Assurance Program are correctly performed either by SCE or other organizations delegated the work.
The Nuclear Oversight Division has the authority and organizational freedom to:
o Identify quality problems.
Initiate, recommend, or provide solutions through designated channels.
o Verify implementation of solutions.
7/94 17.2-5 Amendment 17
17.2.1.4 (Continued)
- Great synergy and improvement in effectiveness in quality programs have been gained by grouping all oversight groups into one overarching oversight organization; however, it is important that the Quality Assurance and Nuclear Safety Groups retain the 17 necessary independence from line influences and from each other to discharge their quality responsibilities appropriately. To this end, both groups are independently managed, and retain the authority and obligation to raise quality issues to higher levels of management including the Senior Vice President, Power Systems if need be.
Additional activities performed by Nuclear Oversight Division personnel during the operations phase are listed on Table 17.2-3.
117 A Site Quality Assurance Manager and Quality Assurance 117 Supervisors are assigned to the operating nuclear generating station. They are responsible for directing and managing the activities of quality assurance personnel performing the activities described on Table 17.2-3.
A Site QC Manager and QC Supervisors are responsible for directing the activities of site QC personnel. QC personnel provide site inspection of safety related items and activities and non-safety related items and activities when requested by Station or Construction Management.
.The Manager, Safety Engineering, is responsible to the Manager of Nuclear Oversight for ensuring the Nuclear Safety Group (NSG) and Independent Safety Engineering Group (ISEG) Supervisors and assigned NSG and ISEG personnel provide independent review of activities as defined in the station technical specifications.
17 Quality Assurance and Quality Control Managers and Supervisors have the responsibility and authority, delineated in writing, to stop unsatisfactory work and to control further processing, delivery, and installation of nonconforming items.
The Manager of Nuclear Regulatory Affairs reports to the Vice President, Engineering and Technical Services, and provides licensing, corporate health physics and environmental support for nuclear generating facilities.
17 The Manager, Nuclear Affairs and Emergency Planning, reports to the Vice President, Engineering and Technical Services, and provides offsite emergency planning support for the Station.
The Manager of Engineering, Construction and Fuel Services, reports to the Vice President, Engineering and Technical Services, and provides the technical and quality aspects for nuclear engineering and design, core physics, fuel performance, 17 core monitoring, Nuclear Safety Analysis, site engineering support, procurement engineering, construction and retrofit management, design basis documentation, procurement and shipment of nuclear fuel, spent fuel shipping services and special nuclear 17 material accountability.
7/94 17.2-6 Amendrent 17
17.2.1.5 Business and Financial Services 17
.The Manager of Business and Financial Services reports to the Senior Vice President, Power Systems and provides procedure support and records management.
17.2.1.6 Ahop Services and Instrumentation 17 The Manager of Shop Services and Instrumentation reports to the Senior Vice President, Power Systems, and provides equipment repair and calibration for the Station, as requested by division managers.
17.2.1.7 Power Production 17 The Vice President Power Production reports to the Senior Vice President, Power Systems. The Power Production Department, under the direction of the Vice President, Power Production is responsible for providing maintenance services and technical assistance mainly during periods of refueling operations and equipment repair and calibration when requested by Division Managers.
117 The Division Chemical Staff assists generating stations with water chemistry control.
117 The Division Maintenance Organization, provides supervision and manpower capability for major overhauls and equipment repair.
O 17.2.1.8 Performance Support I17 The Procurement and Material Management Department, under the direction of the Vice President, Performance Support, is responsible for procurement of materials and equipment, except nuclear fuel, for nuclear generating stations.
The Manager of Procurement and Material Management reports to the Vice President, Performance Support, and is responsible for 17 procurement of items and services (excluding nuclear fuel),
material shipping, and for preparation, negotiations, and administration of procurement contracts.
17 The Manager of Real Properties and Administrative Services reports directly to the Vice President, Performance Support and is responsible for the corporate records management program.
Corporate Documentation Services operates the Corporate Records Center (CRC) at the Corporate offices which is responsible for storage and retrieval of nuclear records placed in their custody.
Corporate Security reports to the Vice President, Performance Support, and is responsible for oversight of Site Security 17 activities.
117 7/94 17.2-7 Amendment 17
17.2.1.9 Delegated Quality Assurance Work 117
.SCE retains responsibility for the Quality Assurance Program described herein but may delegate quality assurance work to other organizations. Other organizations which may be delegated the work of establishing and executing portions of the Quality Assurance Program during the operational phase are as follows:
o Architect-Engineer (A-E,s).
o Nuclear Steam Supply System (NSSS) Supplier.
o Other suppliers contractors including consultants to SCE.
The quality assurance programs of these organizations and the scope of delegated work is as described in the applicable contract for the work performed. A typical interface organizational relationship between SCE and other organizations delegated quality assurance work is as shown on Figure 17.2-2.
17.2.1.10 Interface for Delegated Quality Assurance Work 117 The SCE Manager of Nuclear Oversight, is responsible to communicate SCE quality assurance requirements directly with quality assurance managers of other organizations delegated the work of establishing and executing portions of the Quality Assurance Program. Compliance with SCE quality requirements and regulatory requirements is verified by means of review and approval of these organizations' quality assurance programs as described in Subsection 17.2.2 and by means of audits as described in Subsection 17.2.18.
Management of other organizations delegated quality assurance work is required to implement a reporting system concerning the delegated quality assurance work they are performing and to regularly review the status and effectiveness of that part of the program they are executing. Further, management of these organizations is required to submit to SCE management reports concerning correction of quality problems identified during SCE surveillance of delegated work.
7/94 17.2-8 Amendment 17
- 0 SCE QUALITY ASSURANCE PROGRAM CORPORATE STRUCTURE CHAIRMAN/CEO SENIOR VICE PRESIDENT POWER SYSTEMS NUCLEAR ORGANIZATIO0N VICE PRESIDENT VICE PRESIDENT VICENPRESIDENT VIC POREMDENT POWER PRODUCTION NUCLEAR GENERATION SERVCES SUPPORT MANAGER OF MANAGER BUSINESS &
PROCUREMENT &
CORPORATE REAL OF FINANCIAL MATERIAL SECURITY PROPERTIES SSID SERVICES MANAGEMENT m
3 OO mz 2
NUCLEAR ORGANIZATION NUCLEAR GENERATION DEPARTMENT VICE PRESIDENT NUCLEAR GENERATION OPEATINS HEALTH OUTAGE EMERGENCY MAINTENANCELCHMSR OPERATIONS PHYSICS TECHNICAL MANAGEMENT SECURITY PREPAREDNESS CHEMISTRY o
00 CD m
on) rTT
-~-4
NUCLEAR ORGANIZATION ENGINEERING AND TECHNICAL SERVICES SENIOR VICE PRESIDENT.
VICE PRESIDENT I
MANAGER OF NUCLEAR OVERSIGHT MANAGER NUCLEAR AFFAIRS &
EMERGENCY PLANNING MANAGER NUCLEAR TRAINING MANAGER SITE SUPPORT SERVICES MANAGER OF NUCLEAR REGULATORY MANAGER OF AFFAIRS ENGINEERING, CONSTRUCTION, &
FUEL SERVICES SCE QUAUTY PROGRAM ORGANIZATION FIGURE 17.2.1b 7/94 17.2-11 Amendment 17
SOUTHERN CALIFORNIA EDISON SCE Senior Management Manager of Nuclear Oversight Typical Architect - Engineer Division Manager Manager of Nuclear Oversight Typical NSSS Supplier Division Manager I
Manager of Nuclear Oversight FiGURE 17.2-2 Legend
-Technicailadministrative Authority
- 0. A. Functional Direction 0I 7/94 7.2-2 Amndrnn~
I
17.2.2 QUALITY ASSURANCE PROGRAM 17.2.2.1 ScoDe This subsection describes the SCE Quality Assurance Program established and implemented for the operations phase of nuclear generating stations, Testing, operation, maintenance, refueling, 117 In-Service Inspection, and modification projects in compliance with Regulatory Guide 1.8, 1.28 and 1.33 (reference Table 17.2-1).
17.2.2.2 Quality Assurance Program The basic policies, goals, and objectives for quality assurance are that SCE personnel have full responsibility to assure that nuclear generating stations are designed, constructed, tested and operated in a manner to protect the health and safety of the public. In this regard, SCE has committed its Quality Assurance Program for the operational phase to be in compliance with the provisions of 10CFR50, Appendix B, and the regulatory guides and standards listed on Table 17.2-1.
The SCE Quality Assurance Program described herein is applied to all activities affecting the Safety-Related function of those structures, systems, and components which prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. A listing of items designated Safety-Related is included in the FSAR for the applicable nuclear generating station. The list for each station is maintained and revised in accordance with written procedures as necessary to reflect changes resulting from the finalization or modification of station design. The Quality Assurance Program also applies to activities governed by the Station Technical Specifications and other activities licensed by the NRC.
In addition, expendable or consumable items necessary for the functional performance of Safety-Related structures, systems and components are subjected to quality assurance requirements as specified in written procedures. These procedures include provisions for review and control in accordance with industry standards and specifications and the Safety-Related function of the expendable or consumable items.
This program includes all Safety-Related activities associated 17 with the operations phase of the nuclear generating station. The program is periodically reviewed by the Nuclear Oversight Division during the operational phase. Revisions are made in a controlled fashion, as necessary, to reflect changes in the program which may be required to improve its efficiency or increase its effectiveness.
7/94 17.2-13 Amendmenc 17
17.2.2.2 (Continued)
The Vice President, Engineering and Technical Services, is 117 responsible for establishing SCE quality assurance policies, goals, and objectives. These policies, goals, and objectives are defined in corporate jurisdiction statements, organization plans, and quality assurance manuals and procedures. These documents transmit the SCE quality assurance philosophy and requirements to all levels of management, groups, and individuals involved with program implementation. Training programs, personnel certifications, meetings, review of working documents, programs and manuals, and management directives, are some of the methods utilized to assure that these policies, goals, and objectives are properly understood and complied with.
The Manager of Nuclear Oversight, is responsible for establishing and maintaining quality assurance manuals in compliance with applicable regulations, codes, and standards as listed on Table 17.2-1, and topical report or FSAR commitments. These manuals are developed by the Nuclear Oversight Division from established quality assurance policies, goals, and objectives, which are mandatory requirements. Controlled distribution of quality assurance manuals is maintained by the Nuclear Oversight Division.
Disputes arising between departments or organizations on any quality assurance matter that cannot be resolved will be
.referred to the Vice President, Engineering and Technical Services, or, if necessary, the Senior Vice President, Power 17 Systems, or to the Chairman of the Board for resolution.
Written and approved procedures, instructions, and revisions thereto, necessary to activate the Quality Assurance Program, originate from departments and organizations within SCE that have jurisdictional responsibility for performing specific tasks. All procedures that support the SCE Quality Assurance Program are reviewed and approved by responsible supervision and management of the originating organization. Station quality affecting 117 procedures are reviewed by the Nuclear Oversight Division and reviewed and approved by the Vice President, Nuclear Generation 17 or Vice President, Engineering and Technical Services, or designated representative. Promulgation and control of the procedures and instructions developed pursuant to the Quality Assurance Program are maintained by the originating organization.
All procedures, except station procedures, are included in Quality Assurance Reference Procedure Manuals maintained by the respective organizations. Station procedures are controlled by the Vice President, Nuclear Generation or the Vice President, 117 Engineering and Technical Services, and are maintained in the SONGS CDM center. Table 17.2-2 presents a list of these manuals and a summary of their contents. By means of inspections and audits, Nuclear Oversight Division personnel verify that these procedures are followed.
7/94 17.2-14 Amendment 17
17.2.2.2 (Continued)
Indoctrination and training programs are established within SCE by those organizations performing Quality-Affecting Activities.
These programs are implemented by appropriate training plans and procedures which describe the scope and objectives. The Nuclear Oversight Division provides assistance in the development and implementation of these programs, as requested, and performs periodic audits to assure effective implementation.
The indoctrination and training programs are established to assure that personnel responsible for performing Quality-Affecting Activities are:
o Instructed as to the purpose, scope, and method of implementation of the quality assurance manuals, procedures and instructions.
o Trained and qualified in the principles and techniques of the activity being performed.
o Retrained, reexamined, and/or recertified, as necessary, to maintain proficiency.
The indoctrination and training programs include, as appropriate, the following types of training:
o Audit techniques.
o Nondestructive testing.
o Specialized technical subjects.
o NRC regulations and guides, and codes and standards.
o Intra-and interdepartmental presentations regarding quality assurance activities and requirements.
o Presentations on the proper use of procedures and instructions affecting quality assurance activities.
A record of each training session is prepared and maintained which identifies the content, attendees, and the date training was conducted.
During design and construction activities, project review meetings are held regularly to assess the design and 117 construction status and provide an interface between the responsible SCE departments and organizations. Schedules are maintained throughout this phase, and as the design and construction progresses, plans are made by the Nuclear Generation Department and Engineering and Technical Services Department for 17 Testing. These plans are reviewed by the Nuclear Oversight Division to assure that the test program is developed and controlled in accordance with the SCE Quality Assurance Program.
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17.2.2.2 (Continued)
The SCE Nuclear Oversight Division verifies that these proce dures are developed and followed by means of inspection surveil lance and audits to assure that Quality-Affecting Activities are performed with-specified equipment under suitable environmental conditions, and that required prerequisites have been satisfied prior to performing these activities. The SCE Quality Assurance 117 Program for the operation of the nuclear generating station is described in detail in subsequent subsections of this topical report. The descriptions follow the criteria presented in 10CFR50, Appendix B.
The Vice President, Engineering and Technical Services, through 117 use of independent consultants, periodically assesses the scope, implementation, and effectiveness of the program to assure that it is meaningful and effectively complies with 10CFR50, Appendix B, criteria. Such an assessment is made within one year following issuance of the NRC operating license, and at intervals not exceeding three years, utilizing qualified individuals and firms. They result in written reports submitted to the Vice President, which are reviewed by the Nuclear Control Board.
117 These reports may be referred to the appropriate departments for response to any findings or recommendations.
For shorter projects, involving plant modifications; such an assessment may or may not be made at the discretion of the Vice President.
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17.2.3 DESIGN CONTROL 17.2.3.1 ScoPe This subsection describes the measure utilized by SCE to plan and control design activities associated with changes or 17 modifications to station systems, in compliance with Regulatory Guide 1.64 (reference Table 17.2-1).
17.2.3.2 Design Control Design activities associated with nuclear generating station changes or modifications may be performed by SCE, and A-E or other qualified contractors. The decision to perform the design activity in-house or contract out is based on the scope and complexity of the change or modification, available engineering manpower, and other considerations.
The SCE Quality Assurance Program includes procedures for establishing and maintaining design control throughout the operational phase of the nuclear generating station. Internal 117 and external design interface control procedures are established which include the review, approval, release, distribution, and revision of documents involving design interfaces with participating design organizations.
117 Changes or modifications to plant systems or equipment require
.approval of the Vice President, Nuclear Generation, or designated 117 representative.
If the Nuclear Safety Group determines that the change or modification involves an Unreviewed Safety Question, approval of the NRC is solicited.
Documentation to be reviewed for this design work includes the necessary calculations and/or analysis, design criteria specifications, drawings, procedures, and instructions to permit a comprehensive review. Deviations from original design standards are reviewed to ensure that the designated quality requirements remain in the design. These reviews are required to provide justification for any differences that may exist between the FSAR, Technical Specifications, and the proposed change or modifications.
Review and approval of SCE-prepared design documents, are performed, per.established quality assurance procedures, by individuals other than the original designer and the designer's immediate supervisor unless specified in design control 17 procedures. These procedures describe the positions responsible for design reviews and other design verification activities and identify their authority and responsibilities.
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17.2.3.2 (Continued)
Documentation reflecting a design change is required to be reviewed and approved by the same design groups cognizant in the 117 discipline affected by the change which reviewed and approved the original documentation unless alternative design groups are designated by the Vice President, Nuclear Generation.
117 Alternative design groups shall have access to background information, shall be competent in the specific area of design interest, and shall understand the requirements and intent of the original design.
During the review of the design process, if it becomes evident that the process is not meeting program requirements, Nuclear Oversight shall take appropriate actions in accordance with section 17.2.16, corrective action, or in-line reviews, as appropriate.
Internal procedures describe design review interfaces and review and documentation requirements to assure that the design documentation complies with licensing commitments and contains the following, where applicable:
o Sufficient identification of regulatory requirements and the documents' agreement with these requirements.
o Sufficient identification of the item's functions and incorporation of design bases.
o Adequate delineation of values controlling the item's critical design parameters.
o Sufficient identification of quality standards, test and inspection criteria.
o Specification of appropriate acceptance criteria for tests and inspections.
o Inspectability of item's critical design parameters.
o Suitability for service, including technical evaluation for standard commercial (off the shelf) or previously approved items.
o Incluslon of performance characteristics.
o Accessibility to maintain, repair or inspect the pertinent item while in service.
o Design interfaces have been adequately established and supporting calculations have been checked.
Design controls are applied by SCE, A-E's or contractors, as
.applicable, to such disciplines as reactor physics, seismic, stress, thermal, hydraulic, radiation, and accident analyses.
Consultants may be utilized to review and verify the design of certain items.
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17.2.3.2 (Continued)
Where design verification cannot be adequately accomplished by the design review process, alternate calculations or qualification testing is employed. These alternate methods of design verification are required to be defined in design documentation.
Records of design reviews, and associated design documents are required by internal written procedures to be maintained in the SONGS CDM Center.
The SCE Nuclear Oversight Division is responsible for performing periodic audits, as described in Subsection 17.2.18, of SCE departments, A-E's, and other contractors to verify effective implementation of design control requirements. These audits include verification that appropriate design review records are maintained and deviations from quality standards are controlled.
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17.2.4 PROCUREMENT DOCUMENT CONTROL 17.2.4.1 SCORe 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 are prepared by responsible engineers within cognizant SCE 117 engineering organizations.
The Procurement Division of the SCE Procurement 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 Engineering and Technical Services Department.
117 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 document by cognizant engineering and quality assurance personnel.
c)
Degree of qualification of the supplier from a quality assurance aspect.
d)
Method of product acceptance.
The procurement system assures that the appropriate technical and quality requirements are specified for procurement of items and services considering the safety related function, 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.
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17.2.4.2 (Continued)
O Procurement Documents, and revisions thereto, are reviewed by responsible engineers to verify that they contain or reference 117 appropriate technical and quality requirements 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.
117 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.
117 o
Appropriate quality requirements are correctly stated and include applicable 10CFR50, Appendix B, requirements.
o Quality requirements can be inspected and controlled.
o Adequate acceptance and rejection criteria are specified.
o Provisions are included for documenting and controlling deviations from the Procurement Document.
o Provisions are included for the right of access by the purchaser to the supplier's facilities and records for source inspection and audit.
l17 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 documented prior to release and is available for verification.
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. 17.2.5 INSTRUCTIONS, PROCEDURES. AND DRAWINGS 17.2.5.1 9Pe This subsection describes the measures utilized by SCE to assure that activities-affecting quality are prescribed by, and accomplished in accordance with appropriate instructions, procedures, and drawings.
17.2.5.2 Instructions, Procedures. and Drawings The SCE Quality Assurance Program includes provisions which require that work be accomplished in accordance with documented instructions, procedures, and drawings.
Instructions, procedures, and drawings are prepared, reviewed, approved, and controlled by individuals and organizations which implement Quality-Affecting Activities. These documents specify the requirements and/or methods to be utilized for compliance with the SCE Quality Assurance Program. They include appropriate qualitative and quantitative acceptance criteria, as applicable, to determine that designated activities are accomplished in a satisfactory manner.
Instructions, procedures, and specifications prepared by station personnel for control of design are reviewed and approved by the Vice President, Nuclear Generation, or designated 117 representative.
The Nuclear Oversight Division reviews and approves prior to issuance quality assurance programmatic procedures and procedures which define inspection/nondestructive examination requirements.
In addition, other quality affecting procedures are subject to review by the Nuclear Oversight Division at its discretion.
Appropriate surveillances, audits and assessments will be conducted by the Nuclear Oversight Division to assure that quality affecting instructions, procedures, drawings, and specifications comply with the quality assurance program requirements.
Maintenance, modification and inspection procedures and work order documentation are reviewed by the Nuclear Oversight Division to determine: (1) the need for inspection, identification of inspection personnel and documentation of inspection results; and (2) that the inspection requirements, methods, and acceptance criteria are identified.
Changes to approved instructions, procedures, specifications, and drawings are reviewed and approved in the same manner as original documents.
The SCE Nuclear Oversight Division verifies by means of audits, as described in Subsection 17.2.18, that instructions, procedures, and drawings required for performing Safety-Related activities are controlled in compliance with established program commitments.
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17
17.2.6 DOCUMENT CONTROL 17.2.6.1 Scove This subsection describes the measure utilized by SCE to control the preparation, review, approval, issuance, and distribution of documents affecting quality.
17.2.6.2 Document Control Documentation control, as described herein, applies to the following documents, and changes thereto, as a minimum:
o Design calculations o
Design specifications.
o Design criteria o
Design, manufacturing, construction, and installation drawings.
o Procurement Documents and vendor information.
117 o
Quality Assurance topical report and manuals.
o Manufacturing, inspection, and testing instructions.
o Final Safety Analysis Report (FSAR) and referenced topical reports.
o Updated Fire Hazards Analysis.
117 o
Technical Specifications.
o Test procedures, test instructions, and test results.
o Operating, maintenance and modification procedures and instructions.
o Design change requests and notices.
o Nonconformance Reports.
o Corrective Action Requests.
o Audit Reports.
o Design bases documents.
117 These documents, including changes thereto, are prepared, reviewed, approved, issued, and controlled in accordance with approved written procedures. Procedures are maintained in Station files by CDM and in manuals as listed on Table 17.2-2.
These procedures provide instructions to assure that documents, including changes thereto, are adequately checked, approved, 7/94 17.2-23 Amendment 17
17.2.6.2 (Continued) and released by authorized personnel in a timely manner, and that the documents are transmitted and available at appropriate locations prior to commencement of activities requiring use of the document. Personnel or groups authorized to check, approve, and release documents are identified in quality assurance manuals and procedures.
17 Changes to instructions, procedures, drawings, and other documents are approved prior to implementation of the change.
Changes to documents can be requested by any reviewing or using organization or individual. Such requested changes, however, are subjected to the review and approval as by the same groups cognizant in the discipline affected by the change, unless this work has been delegated to another organization.
Temporary changes to station procedures can be made if the intent of the original procedure is not altered and the change is made according to the requirements of the Administrative Controls section of the applicable Technical Specification.
117 Design information transmitted from one organizational unit to another, including to organizations delegated design work, is documented and controlled by written approved procedures.
These procedures require that design information transmittals identify the status of the design information or document provided and, where necessary, identification of incomplete item which require further evaluation, review or approval.
A file of approved documents is prepared and maintained by CDM for station operations, maintenance, modifications, and testing activities. These documents are updated and copies distributed to designated responsible persons to preclude the use of obsolete or superseded documents.
Documents comprising instructions, procedures, specifications, and drawings prepared by outside contractors for refueling, Inservice Inspection and other station activities are reviewed and approved by the Vice President, Nuclear Generation, or 117 designated representative. These documents are also reviewed by the Nuclear Oversight Division.
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17.2.7 CONTROL OF PURCHASED MATERIAL. EQUIPMENTAND SERVICES 17.2.7.1 Scope This subsection describes the measures utilized by SCE to control the procurement of material, equipment, and services purchased directly or through contractors and subcontractors in compliance with applicable codes and standards.
17.2.7.2 Control of Purchased Material, Equipment and Services Prior to award of purchase order or -contract, suppliers to SCE are subject to technical, and quality assurance evaluations by qualified SCE Engineering and Quality Assurance personnel.
Quality Assurance evaluations of suppliers are not required when quality can adequately be determined by receipt inspection or other acceptance methods. Quality Assurance evaluation may be accomplished by at least one of the following methods:
o Review of objective evidence establishing suppliers' capability to comply with the 10CFR50, Appendix B, criteria applicable to the type of material, equipment, or service to be procured.
o Review/evaluation of the suppliers history of providing similar products which perform satisfactorily in use.
o Review/evaluation for applicability/acceptability of audit/evaluation records generated by utilities/
licensees, contractors or consultants which are acting for SCE.
o Survey of suppliers' facilities and quality assurance programs to determine suppliers' capability to supply a product or service which meets the design, manufact uring, and quality requirements.
Audits/surveys of suppliers are scheduled as described in Subsection 17.2.18.
Results of these evaluations and surveys are documented and forwarded to the Procurement and Material 17 Management Department for maintenance of an information process that provides the status of evaluated suppliers, and to the CDM Center for record retention.
Source verification of suppliers, when required, is performed during fabrication, inspection, testing, and shipment.
This activity is planned and performed in accordance with written procedures to assure compliance to purchase order requirements. These procedures provide for the following:
o Instructions that specify the characteristics or processes to be witnessed, inspected, or verified, and accepted; the method of verification, the extent of documentation required, and those responsible for implementing the instructions.
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- 17.2.7.2 (Continued) o That suppliers comply with all appropriate quality requirements established, as described in Subsection 17.2.4.
o Source verification is performed based on considerations described above and results of previous audits.
Receiving inspection of material, components, and equipment, as further described in Subsection 17.2.10, is performed in accordance with written procedures to assure that:
o Items are properly identified and correspond with the receiving documentation.
o Items and acceptance records are judged acceptable in accordance with predetermined inspection instructions prior to installation and use.
o Inspection records or certificates of conformance are available at the station prior to installation and use.
o Items are identified as to their inspection status prior to forwarding them to a controlled storage area or releasing them for installation or further use.
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.
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.
Supplier's certificates are periodically evaluated by audits, inspections, or tests to assure that they are valid and accurate.
Spare or replacement parts for structures, systems, and
.components are subject to controls at least equivalent to those used for the original equipment.
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17.2.8 IDENTIFICATION AND CONTROL OF MATERIALS. _PARTS AND COMPONENTS 17.2.8.1 Scope This subsection describes the measures utilized by SCE for identifying and controlling material, parts, and components.
17.2.8.2 Identification and Control of Materials, Parts and Components Identification and control requirements for material, parts, and components, including partially fabricated assemblies, are speci fied in SCE Procurement Documents for the item to be purchased and in applicable design and construction specifications, draw ings procedures and instructions for station activities. These requirements are established by cognizant SCE personnel and include the following:
o Items are identified by means which permit trace ability to supporting documentation such as purchase orders, manufacturing and installation/construction records, and quality assurance records and documentation.
o If required by codes, standards, or specifications, materials are traceable to records of heat, batch or lot number.
o Method and location of identification are controlled to assure the function, fit and quality of the item are not impaired.
o Verification of correct identification of material, parts, and components is accomplished and docu mented prior to release for fabrication, assembly, shipment, construction or installation and the record of verification is maintained for the period provided in the governing procurement document, specification, drawing, procedure or instruction.
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17.2.9 CONTROL OF SPECIAL PROCESSES 17.2.9.1 Scope This subsection describes the measures utilized by SCE to control special processes, such as welding, heat treating, cleaning, and nondestructive testing in compliance with Regulatory Guides 1.37, 1.39 and 1.54 (reference Table 17.2-1).
17.2.9.2 Control of Special Processes SCE engineers and technicians performing special processes associated with Safety-Related items are trained, examined, and qualified in accordance with applicable codes, standards, specifications, and other supplementary requirements as applicable. Procedures and equipment utilized in performing these processes are similarly qualified. The Nuclear Oversight Division assures that special processes utilized to modify or examine existing systems or components are performed by qualified personnel utilizing qualified procedures and equipment as specified by Procurement Document or other applicable code or standard.
Inspection records associated with special processes include verification that the activity was performed utilizing qualified personnel, procedures, and equipment. These records, as well as current qualification records of personnel, equipment, and procedures are filed and maintained in the CDM Center.
17 7/94 17.2-28 Amendment 17
17.2.10 INSPECTION 17.2.10.1 Scope This subsection describes the measure utilized by SCE to control the inspection of activities affecting quality in compliance with Regulatory Guides 1.30, 1.58, 1.94, and 1.123 (reference Table 17.2-1).
17.2.10.2 Inspection The SCE Quality Assurance Program requires that activities affecting quality be inspected by individuals other than those that performed the activity being inspected. Inspection of these activities is performed for these items in accordance with written and approved procedures and inspection plans.
Maintenance and modification procedures are reviewed by qualified personnel knowledgeable in quality assurance to determine the need for inspection, identification of inspection personnel, and inspection results documentation.
Approved inspection procedures, instructions, and checklists are provided to perform the inspections and they contain, but are not limited to, the following:
o Identification of characteristics and activities to be inspected.
o Identification of the individuals or group(s) responsible and qualified to perform the inspection operation.
o Acceptance and rejection criteria, both qualitative and quantitative.
o Description of the inspection method.
o Recording evidence of completing and verifying a manufacturing, inspection or test operation.
o Recording inspector or data recorder and the results of the inspection operation.
Activities affecting safe operation of the station are inspected in accordance with Technical Specifications. Specification requirements are incorporated into procedures that detail the 117 specific steps necessary to perform the required inspection.
Qualified personnel conduct inspection activities in support of the overall inspection program.
The Nuclear Oversight Division reviews and audits all documents associated with repair of Safety-Related items and performs inspections and surveillance to verify that appropriate quality assurance requirements are applied and met.
Nuclear Oversight Division personnel perform receiving inspection on material and equipment. This inspection provides assurance that the material and equipment received for installation and use 7/94 17.2-29 Amendment 17
17.2.10.2 (Continued) conforms to the Procurement Document requirements. Consistent with the function of the material or equipment, it may be necessary to perform source inspection at contractors' or suppliers' facilities. The need for source inspection is determined by the SCE Nuclear Oversight Division or other organizations delegated quality assurance work and is based on the following criteria:
o The significance of the activity to the functions of the item.
o Audit results, results of inspections or tests, lack of previous experience with the contractor or supplier, or indications from other areas that source inspection would be prudent.
The Nuclear Oversight Division periodically audits the inspection activities of SCE or other organizations performing inspection work. These audits verify that:
0 Inspection procedures or instructions are developed with necessary drawings and specifications prior to performing inspection operations.
o Inspectors are qualified in accordance with appropriate codes, standards, and training programs and their qualifications are documented and maintained current.
o Modifications, repairs, and replacements are inspected in accordance with the original design and inspection requirements or acceptable alternatives.
o Inspection operations are performed and documented in compliance with the appropriate quality assurance manuals and inspection records are forwarded to the CDM Center.
Mandatory inspection hold points or witness points are specified 17 in Procurement Documents as appropriate at the time of approval of such documents.
If established during the review of contractors or suppliers procedures or plans for manufacturing, examination, test or inspection, these witness and hold points are designated in correspondence from SCE, usually in the contract documents requiring conformance from a supplier or contractor.
Procurement Documents include the requirement that modifications, repairs, and replacements are inspected in accordance with the original design and inspection requirements or acceptable alternatives.
In addition, these documents contain provisions for indirect control for monitoring processing methods, equipment, and personnel where direct inspection is not possible.
Contractors are required to qualify their inspectors in accordance with appropriate codes, standards, and training programs, and to maintain current records of these certifications.
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.17.2.11 TEST CONTROL 17.2.11.1 Scope This subsection describes the measures utilized by SCE to control testing activities in compliance with Regulatory Guides 1.8, 1.30, 1.58, 1.94 and 1.116 (reference Table 17.2-1).
17.2.11.2 Test Control-General requirements All testing conducted in support of station operations or modification programs is documented, and accomplished in accordance with approved test program procedures.
Test program procedures and instructions described herein incorporate or reference:
o Applicable Regulatory Guides and SAR Commitments.
o Applicable codes and standards o
The requirements and acceptance limits contained in applicable design and Procurement Documents.
o Existing station procedural requirements o
Instructions for performing the test.
o Test prerequisites that may include, but are not limited to, the following provisions:
a) Calibrated instrumentation.
b) Adequate and appropriate test equipment.
117 c) Pretest walkdown and briefing d) Completeness of item to be tested.
e) Suitable and, if required, controlled environmental conditions.
f) Mandatory hold points established by designated organizations for inspection or witness activities g) Acceptance and rejection criteria, either qualitative or quantitative.
h) Methods for documenting, recording, evaluating and approving the test data results.
Provisions for personnel training, data collection and storage are contained in other internal SCE documentation.
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17.2.11.2 (Continued)
Tests are conducted in accordance with approved procedures and the results evaluated to determine compliance with established acceptance criteria. Records of tests performed at the station and supplier test records as required to be submitted by procurement documents are forwarded to the CDM Center and are available for audit by the Nuclear Oversight Division.
The test program shall require that modifications, repairs and replacements of items be tested, using the same criteria as the original items.
If alternatives are required, they must be reviewed and approved by the same organization that established the original requirements or by alternate organizations which have been provided sufficient background information.
17.2.11.3 Prototype, Shop and Construction Material Tests Procedures for Prototype and Shop tests are normally prepared by the organizations conducting the test; however, SCE, A-E's, or contractors may prepare these procedures where they have design or procurement responsibility. These procedures require appropriate preparing organization, Nuclear Oversight Division and associated engineering organization review and approval prior to test implementation. Test results are documented, evaluated, and acceptance status verified by qualified individuals within ethe organization performing the test, and witnessed, as appropriate, by an inspector designated by the procuring organization.
Construction material test procedures are prepared by the SCE Nuclear Oversight Division or contractor based on established engineering criteria. Tests are performed and results documented in accordance with these procedures by SCE Nuclear Oversight Division or the Contractor. Deviations from engineering criteria are evaluated by the responsible engineering organization.
17 17.2.11.4 Station Tests Station Tests performed subsequent to operational status are accomplished by the Station Staff in accordance with approved written procedures prepared by or under the direction of the Nuclear Generation Site Department. As a minimum, test results are reviewed, evaluated, and approved by the Cognizant Supervisor prior to declaring the equipment/system operable. Where test results are not acceptable,the test organization is responsible for evaluation of the test and/or results.
In addition, out of tolerance as-found conditions in Technical Specification instrumentation, computers, radiation monitors and adjustable relays shall be reported to Site Technical Services who trend and 117 evaluate this data in accordance with written criteria approved by Station Technical.
Indications of too large and/or too frequent deviations as defined by this written criteria shall be reported by STS by use of a Nonconformance Report to the 17 Technical Division for disposition. The Nuclear Oversight Division performs periodic audits of these test results.
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17.2.11.5 Modification Tests
- Modification Tests are the responsibility of the implementing organization Manager. The implementing organization is respon sible for development of required procedures with technical assistance provided by the responsible engineering organization.
Procedures developed for the final operational test phase are reviewed and approved by the Vice President, Nuclear Generation, Manager or designated representative. Test results are evaluated 117 by the responsible test organization. Deviations of documented test results beyond specified acceptance limits shall be dispositioned by the responsible engineering organization prior to declaring the equipment/system operable. Nuclear Oversight Division personnel are responsible for providing inspection surveillance throughout the testing program.
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17.2.12 CALIBRATION PROGRAM 17.2.12.1 Scope This subsection describes the measures utilized by SCE to control the calibration program used in activities affecting quality.
17.2.12.2 Calibration Control Program The Vice President, Nuclear Generation, is responsible for the control of the Calibration Program. Responsible organizations or 17 individuals, as appropriate, shall maintain the calibration program. This program includes:
o Calibration of permanent plant equipment.
o Calibration and control of measuring and test equipment (M&TE).
o Calibration and control of reference standards.
17.2.12.2.1 A program for the calibration and control of permanent plant 1
equipment has been established to assure compliance with 17 Technical Specification requirements and other requirements appropriate to the equipment.
This program includes the l17 following minimum requirements:
o Method of identification of plant equipment for traceability to calibration test data and the recalibration due date.
o A list of governing regulations, codes, and standards applicable to calibration.
o A method for determining the calibration interval based on required accuracy, purpose, degree of usage, stability characteristics and other conditions affecting the application.
o A system for identifying equipment whose designated period of legitimate use prior to recalibration has expired.
o Calibration procedures, including techniques and methods for adjustment of equipment.
o Individuals authorized to calibrate.
o Method for identification, control and distribution of calibration data, and records.
o Method to assure M&TE used in calibrations have acceptable ranges, precision and accuracy.
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17.2.12.2.1 (Continued) o Provisions for evaluating the components found out of tolerance or where functional tests are found unsatisfactory, including procedures to address the possible safety significance of the situation (i.e.,
possible instances of out of specification conditions or periods of time where limiting conditions for operation were exceeded), and the potential need for remedial action.
o Provisions to ensure that permanent plant equipment when used to provide acceptance criteria for quality affecting activities is within its tolerance requirements.
o A means of determining which equipment shall be included (and excluded) from the calibration control program.
Measuring and test equipment (M&TE) used for the calibration of permanently installed plant equipment which perform safety related functions shall be calibrated to recognized national standards or, if nonexistent, the basis for calibration shall be documented.
The responsible organization manager reviews and approves
.calibration procedures required to support operation, maintenance, repair, modification, refueling, and in-service inspection activities. The SCE Nuclear Oversight Division reviews calibration programs, including those prepared by designated contractors and performs periodic audits to verify conformance with established calibration program requirements.
17.2.12.2.2 A program has been established for the calibration and control 117 of measuring and test equipment (M&TE) that is used to calibrate permanently-installed plant equipment which perform safety-related functions or is otherwise governed by the Quality Assurance Program. This program contains the 17 following requirements:
o Method of identifying M&TE (i.e. serial no., model no., manufacturer, description).
o A list of governing regulations, codes, and standards applicable to calibrations.
o Method of labeling or tagging the equipment to indicate date of next required calibration.
o Method for identification of equipment for traceability to the calibration test data.
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17.2.12.2.2 (Continued) o Method for establishing calibration intervals based on the required accuracy, purpose, degree of usage, stability characteristics, and other conditions affecting the application.
o A system for recalling M&TE whose designated period of legitimate use prior to recalibration o
Calibration procedures including techniques and methods for adjustment of M&TE.
o Identification of individuals, organizations, and companies authorized to calibrate the M&TE. The user of the M&TE will be qualified per Regulatory Guide 1.8 or 1.58 as appropriate.
o Provisions for recording the as-found condition of M&TE being calibrated.
o A method for identifying all permanent plant equipment, defined to be within the program, 117 that has been calibrated with M&TE that is found out of tolerance or inoperative.
o Method for identification, control and distribution of calibration data and records.
o Provisions for proper handling and storage of the M&TE.
o Status of all M&TE is maintained by the organization responsible for the calibration program.
o A means of determining which M&TE shall be included (and excluded) from the calibration control program.
This program specifies accuracy requirements and ensures that 117 the inaccuracy of the standards contribute no more than 1/4 of the total inaccuracy of the M&TE being calibrated. A greater uncertainty may be acceptable when limited by "state-of-the-art".
The responsible organization manager reviews and approves calibration procedures required to implement the M&TE calibration program. The SCE Nuclear Oversight Division reviews the M&TE calibration program, including those prepared by designated contractors, and performs periodic audits to verify conformance with established calibration program requirements.
A program for the calibration and control of Metrology reference standards has been established. This program 17 includes:
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17.2.12.2.2 (Continued) o A list of governing regulations, codes and standards applicable to calibration.
o Method of identification of equipment for traceability to the calibration test data and the recalibration due date.
o Calibration intervals based on the required accuracy, purpose, degree of usage, stability characteristics and other conditions affecting the application.
o A system for identifying equipment whose designated period of legitimate use prior to recalibration has expired.
o Calibration procedures including techniques and methods for adjustment of equipment.
o Provisions for recording the as-found condition of the equipment being calibrated.
o A method for identifying all M&TE that has been calibrated with out-of-tolerance standards.
o Method for identification, control, distribution, and retention of calibration data and records.
o A means of determining which devices shall be included (and excluded) from the calibration control program.
Reference standards are traceable to nationally recognized standards, or if nonexistent, the calibration program includes provisions for documenting the basis for calibration. The complete status of all equipment controlled by the calibration program is recorded and maintained by the organization responsible for the calibration program.
Reference standards used for calibration of lower echelon standards shall have acceptable calibration ranges, precisions and an equal or better accuracy than that of the standard under test, wherever possible, without degrading the measurement accuracy.
The responsible organization manager reviews and approves calibration procedures required to implement the reference standard calibration program. The SCE Nuclear Oversight Division reviews the reference standard calibration program, including those prepared by designated contractors, and performs periodic audits to verify conformance with established calibration program requirements.
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17
17.2.13 HANDLING, STORAGE, AND SHIPPING 17.2.13.1 SCORe This subsection describes the measures utilized by SCE to control handling, storage, shipping, packaging, preservation, and cleaning activities in compliance with Regulatory Guide 1.38 (reference Table 17.2.1).
17.2.13.2 Handling, Storage, and Shipping Cognizant Engineering Managers are responsible for defining 117 handling, storage, shipping, packaging, preservation, and cleaning requirements for items delivered to the station. These requirements are implemented at the Station by Engineering and 17 Technical Services Department warehouse personnel for as long as the items are in storage at the warehouse and by the cognizant Station personnel when the items have been issued for installation. Special nuclear material is received, stored and shipped in accordance with Nuclear Organization procedures.
117 0
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17.2.14 ISETO.TS.ADOEAIGSAU 17.2.14.1 SQo.op This subsection describes the measures utilized by SCE to indicate the status of inspections and test and the associated clearance procedures.
17.2.14.2 Inspection, Test, and Operating Status The methods used to indicate the status of inspections and tests and for the control of status.indicators are described by written procedures. These procedures are prepared and implemented by cognizant SCE organizations performing the inspections and tests.
Periodic audits are conducted by the Nuclear Oversight Division to assure proper implementation of these procedures.
Inspection data sheets are developed, as described in Subsection 17.2.10, to describe the inspection plan and inspection status for each item during the inspection phase. A sign-off by a cognizant inspector is required upon satisfactory completion of each inspection step which provides the record of inspection or test results.
A system of marking with stamps or tags is used to identify the status of material, equipment, work, testing, and operations.
This marking system identifies the inspection status and tests
.performed on individual items. Markings also indicate the status of nonconforming, inoperative, or malfunctioning structures, systems, or components to prevent inadvertent use. The system for control or nonconforming items is described in Subsection 17.2.15.
l17 Appropriate procedures also establish requirements for clearances and tagging of structures, systems, and components to prevent inadvertent use during station operations. These procedures may be independently reviewed by qualified individuals if designated by the Vice President, Nuclear Generation or designee.
117 When inspections or tests are required by design documents for a design change, results of these inspections or tests are documented in appropriate records and logs.
Bypassing or waiving these required inspections, tests, and other critical operations is controlled by written documents that require that justification and approval of the action be documented. The Quality Control Supervisor approves such waivers for inspections related to Safety-Related items.
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17.2.15 NONCONFORMING MATERIALS, PARTS OR COMPONENTS 17.2.15.1 SC29e This subsection describes the measures utilized by SCE to control materials, parts, or components that do not conform to established requirements.
17.2.15.2 Nonconforming Materials, Parts or Components The measures used to control nonconforming Safety-Related items are described by written procedures. These procedures are pre pared and implemented by cognizant SCE organizations delegated the work of controlling nonconformances. The SCE Nuclear Oversight Division conducts periodic audits to assure proper implementation of these procedures and effectiveness of the nonconformance controls.
Deviations pertaining to a characteristic of a material, component, system or structure, from those specified in the design documents are treated as nonconformances. Procedures for processing and controlling nonconforming items contain the following requirements:
o Measures to identify the nonconforming item including criteria for when to issue a Nonconformance Report (NCR).
o Measures to document the nonconforming item, including cause and corrective action.
o Measures to segregate the nonconforming item from acceptable items, where possible.
o Method to review and disposition the nonconforming item, including approval authority.
o Method of notification to the affected organizations.
o Method for evaluating deviations to determine if reportable under the requirements of 10CFR50.55(e),
10CFR21, 10CFR50.72, 10CFR50.73 or the Technical Specifications.
17.2.15.2.1 Site Activities 117 When a nonconforming item is discovered at the Station, an NCR and/or a work order document, as appropriate, will be generated by SCE personnel in accordance with procedural requirements.
Rework/reject dispositions for plant equipment will normally be controlled by the work order document process.
Nonconformance documentation contains the item's identification, description of the nonconformance, dispositioning activities, 7/94 17.2-40 Amendment 17
17.2.15.2.1 (Continued) inspection requirements, approval signatures, and the organizations notified of the nonconformance. Cause and corrective action are also documented. An SCE nonconformance reporting log/system is maintained and indicates the status of each nonconforming item.
Nonconforming items are segregated from acceptable items, where possible, and maintained in a controlled area until properly dispositioned. Nonconforming items discovered in installed items are evaluated to determine their operability as defined by the Technical Specifications and use is controlled until final disposition of the nonconformance and associated disposition implementation.
Stamps or tags are utilized to identify the nonconformance as described in Subsection 17.2.14. Nonconforming items may be dispositioned Accept-As-Is, repair, rework, or reject.
An Engineering Review Process (ERP) is utilized to provide approval of dispositions associated with nonconforming items.
For the dispositioning of nonconformances, the following approvals are required:
Repair or Accept-As-Is Dispositions NOD Supervisor or designee Cognizant Station Functional Manager (Technical, Maintenance, Operations, Health Physics, etc.) or designee or Nuclear Engineering & Construction, Engineering Manager/Supervisor or designee.
Manager, Technical (or designee), or Manager, Nuclear Engineering Design Organization (or designee), separate from the CSFM or NE&C cognizant approval, providing management 16 approval of the disposition.
Reject or Rework Dispositions NOD Supervisor or designee Cognizant Station Functional Manager (Technical, Maintenance, Operations, Health Physics, etc.) or designee or Nuclear Engineering & Construction, Engineering Manager/Supervisor or designee.
Nonconforming items may be authorized for conditional use prior to implementation of the final NCR disposition providing the following conditions have been met:
o The NCR describes the conditional use.
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17.2.15.2.1 (Continued) 0 Use of the item is controlled such that the safety functions of the system are not adversely affected.
o Identification and traceability of the item is maintained.
o The authorization is approved by the same ERP members required for the disposition approval.
When the nonconformance disposition specifies a rework or repair, these actions are accomplished in accordance with approved procedures, drawings and instructions. SCE Nuclear Oversight Division organization personnel verify acceptability of rework and repair dispositioned nonconforming items by reinspection according to methods initially used. When reinspection methods differ from those initially used, methods at least equal to the original inspection are employed. The responsible work organization manager is responsible for assuring that rework and repair activities are accomplished in accordance with approved procedures, drawings, and instructions.. Items are designated as nonconforming and are so identified until rework or repair and the required inspections are satisfactor ily performed.
Rejected or scraped items are promptly removed from the station work areas. The status of these items is displayed by appropriate documentation. Nuclear Oversight Division personnel verify the proper disposition of these items.
The SCE design organization responsible for the affected design document reviews and approves Accept-As-Is and Repair dispositions for design impact.
For an approved disposition, the responsible design organization must issue a written justification for the deviation from the design document or revise the design document in accordance with applicable requirements.
When the participants in the Engineering Review Process cannot agree, the final disposition is made by the Manager of Nuclear Oversight. Significant nonconformances of unusual complexity or involvement are submitted to the Vice President, 17 Engineering and Technical Services, for resolution.
NCRs are maintained in an electronic format.
The electronic records shall be maintained in two separate remote locations. A formal process is established to produce an NCR record that is legible, accurate and complete during the record retention period, life of the plant. Work order documentation and associated inspection records are forwarded to the SONGS CDM Center for retention purposes. Nonconformance data are analyzed by the SCE Nuclear Oversight Division to establish quality trends.
The results of these analyses are reviewed by the Manager of Nuclear Oversight, for possible corrective action 7/94 17.2-42 Amendment 17
17.2.15.2.1 (Continued) and referred to the Vice President, Engineering and Technical 17 Services, when a potentially serious condition is indicated.
Deficiencies identified by 10CFR50.55(e) or 10CFR21 are reported to the NRC prior to issuance of the operating license by the NRC.
Thereafter, deficiencies are reported to the NRC in accordance with Technical Specification requirements, 10CFR21, 10CFR50.72 or 10CFR50.73.
17.2.15.2.2 Contractor and Supplier Activities Nonconformances in onsite contractor work are controlled by SCE in accordance with Paragraph 17.2.15.2.1.
Nonconformances dispositioned Accept-As-Is or repair by off site suppliers must be made part of the inspection records and forwarded to the responsible engineering organization for review and assessment. The responsible SCE engineering organization approves these dispositions for SCE procured items.
Conditions adverse to quality discovered by SCE personnel at a jobsite, contractor's manufacturing facility or design office, or supplier's manufacturing facility, are processed as described in Subsection 17.2.16.
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17.2.16 CORRECTIVE ACTION 17.2.16.1 Scoe This subsection describes the measures utilized by SCE to assure that corrective action is promptly identified and implemented when conditions adverse to quality are determined to exist.
17.2.16.2 Corrective Action As described in Subsection 17.2.15, nonconformance and correct ive action associated with material, parts, or components are.
controlled at a jobsite by the nonconformance reporting system.
Additionally, a system for initiating corrective action associ ated with conditions adverse to quality is controlled by the SCE Nuclear Oversight Division by means of written procedures.
This system implements corrective action system forms to docu ment conditions adverse to quality discovered by SCE personnel at SCE facilities implementing the Quality Assurance Program, at 117 A-E's design offices, and at NSSS Suppliers and other suppliers' facilities. This corrective action documentation is also used for hardware problems discovered at NSSS Supplier or other suppliers' facilities.
Procurement specifications may specify the requirement for SCE approval of nonconforming hardware disposition if discovered by SCE at a supplier's facility.
.The corrective action documentation provides for item or system identification, description of the adverse condition, cause of the condition, corrective action to resolve problem, and the corrective action to prevent recurrence as appropriate to the problems identified.
Corrective action documentation is promptly initiated with a request for corrective action directed to the responsible organization as a result of review, inspection, audit or surveillance activities.
The responsible organization to which corrective action docu mentation is directed determines the cause of the adverse condition, the action taken to resolve the problem, and the action to be taken to prevent recurrence as appropriate to the problems identified. They also provide dates for imple mentation of the corrective action where appropriate. The corrective action documentation is returned to the responsible SCE Nuclear Oversight Division Supervisor for review and concurrence. Revised corrective action documentation is requested if corrective action proposed is unacceptable.
Follow-up reviews, inspections, audits, or surveillance are performed by SCE personnel to verify corrective action implementation. Significant conditions adverse to quality, 0
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17.2.16.2 (Continued) the cause of the-conditions and the corrective action taken to prevent recurrence are identified by the responsible organi zation and reported to cognizant levels of management for review and assessment.
Trending studies may be performed on corrective action data by the SCE Nuclear Oversight Division as directed by the Vice 17 President, Engineering and Technical Services, or the Manager of Nuclear Oversight. Results of trending studies are documented and retained on file in the CDM Center. The Vice President 117 issues directives for corrective action resulting from trending studies, as necessary and assures appropriate management involvement in correcting significant conditions adverse to quality.
In addition to the corrective action system controlled by the SCE Nuclear Oversight Division, other corrective action systems may exist within other SCE organizations which provide a means for identification of the deficiency; documentation of corrective action to resolve the issue and corrective action to preclude recurrence; a means to track the status of the defi ciency; and a means to assure followup and closeout of the corrective action. When these optional systems exist, they shall be defined by written and approved procedures which con tain program elements and administrative controls which are com atible with the SCE Quality Assurance Program. These systems W
are periodically audited by the SCE Nuclear Oversight Division to determine effectiveness of implementation.
A-E's, NSSS Suppliers, and other suppliers are required by contract or procurement specification to implement a corrective action system equivalent to that described herein for their scope of work, including appropriate management involvement in the review and assessment of significant conditions adverse to quality.
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17.2.17 QUALITY ASSURANCE RECORDS 17.2.17.1 Scope This subsection describes the measures utilized by SCE to assure that required design documents and quality assurance records are properly stored, maintained, retained, and retrievable to provide objective evidence of activities affecting quality in compliance with Regulatory Guide 1.88 (reference Table 17.2-1).
17.2.17.2 Quality Assurance Records Corporate Documentation Management Centers (CDMC) are established at predetermined locations for storage, indexing, maintenance, and retention of quality assurance records. CDM Centers are established and maintained by representatives of Administrative Services and Budget and Administration in accordance with the 13 Quality Assurance Program. Documents established as quality assurance records which are released for scheduled retention may be retained by designated organizations other than CDMC. Quality assurance records so retained shall be stored, maintained and controlled as required by Regulatory Guide 1.88.
The Nuclear 13 Oversight Division assures that the requirements for documentation imposed by SCE and regulatory agencies are identified in a documentation list(s) and implemented through written procedures.
Quality assurance records to be stored and maintained include, but are not limited to, the following:
o Records required by the station Technical Specifications o
Operating logs o
Principal maintenance and modification activities o
Abnormal occurrence reports o
Results of reviews, inspections, tests, audits, and material analyses o
Records of monitoring of work performance o
Minutes of On-Site Review Committee meetings and Nuclear Safety Group reports o
Qualifications (certifications) of personnel, procedures, and equipment 7/90 17.2-46 Amendment 13
17.2.17.2 (Continued) o Specifications and drawings, including as-built drawings and stress reports or calculations o
Procurement Documents and purchasing records o
Calibration manuals, procedures, and reports o
Nonconformance and Corrective Action Reports o
Inspection and test records which contain, as a minimum, the following:
a) A description of the type of observation b) Evidence of completion and verification of manufacturing, inspection or test operations c) Date and location of inspections or tests d) Information related to conditions adverse to quality e) Inspector or data recorder identification f) Evidence as to the acceptability of results
.Access to quality assurance records in the CDM Centers is controlled by CDMC personnel and in other organizations by the designated organization personnel. Access control is audited by the Nuclear Oversight Division. Access to and retrieval of 113 quality assurance records which are being maintained within scheduled retention is based on a need to know and is controlled by written procedures.
Requirements and responsibilities for record transmittals, retention, and maintenance subsequent to completion of work are consistent with applicable codes, standards, Procurement Documents, and the station Technical Specifications.
The review, identification, indexing, categorizing and filing of design documents and quality assurance records is accomplished in accordance with written procedures. These procedures include provision for ready identification and retrievability of stored documents.
Documents released for scheduled retention by the responsible organization are protected against deterioration or destruction from fire, flooding, theft, and environmental conditions such as temperature and humidity.
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17.2.18 AUDITS 17.2.18.1 Scope This subsection describes the measures utilized by SCE to verify compliance with, and overall effectiveness of the SCE Quality Assurance Program by means of a system of planned and periodic audits in compliance with Regulatory Guide 1.144 and 1.146 (reference Table 17.2-1).
17.2.18.2 Audits The SCE Quality Assurance Program requires a comprehensive system of planned and periodic audits to verify the effectiveness of the program, and evaluate compliance with applicable 10CFR50, Appendix B, criteria. Quality Assurance audits are planned and performed in accordance with written procedures by Quality Assurance Engineers trained in audit techniques, or other SCE engineers or inspectors as designated by the Manager of Nuclear Oversight. Individuals performing 113 audits do not have responsibilities in the areas to be audited.
Quality Assurance audits provide an objective evaluation of quality-related practices, procedures, and instructions, and the effectiveness of implementation of policy directives.
Audits include the evaluation of work areas, activities,
.processes, items, and the review of documents and records.
The Nuclear Oversight Supervisors are responsible for 113 assuring that sufficient audits are performed in those areas where the requirements of 10CFR50, Appendix B, are being implemented. These areas include, as a minimum, those Safety-Related activities associated with:
o Operation, maintenance and modification.
o Preparation, review, approval, and control of designs, specifications, Procurement Documents, instructions, procedures, and drawings.
o Receiving and plant inspections.
o Indoctrination and training programs.
o Implementation of operating and test procedures and instructions.
o Calibration of measuring and test equipment.
The Nuclear Oversight Division performs a formal, annual, and 113 independent audit of station activities. The Nuclear Safety 7/90 17.2-48 Amendment 13
17.2.18.2 (Continued)
Group's review of actions employed by the On-Site Review Committee provides a continuing surveillance of station activities. The work and documents of the On-Site Review Committee (OSRC) and Nuclear Safety Group are audited by the SCE Nuclear Oversight Division for correctness and verification of conformance with quality requirements.
The following types of audits are performed to assure that quality assurance procedures and activities are meaningful and comply with SCE Quality Assurance Program requirements:
o Internal audits conducted by SCE, A-E's and contractors quality assurance organizations.
o External audits by the SCE Nuclear Oversight Division on A-E's, contractors, and other suppliers.
o External audits by utilities/licensees, Contractors or Consultants acting for SCE. Whenever these audits are utilized by SCE to satisfy SCE audit requirements, the 17 results of the audits are evaluated by SCE Nuclear Oversight to ensure acceptability.
Each supplier's quality assurance program acceptability is determined initially prior to work commencement. This determination is made in accordance with subsection 17.2.7.2.
Audits are scheduled based upon the status of work progress, importance to safety of the activities being performed and prior experience with the organization being audited. These schedules 17 provide for coverage of applicable 10CFR50, Appendix B criteria implementation.
A formal evaluation of suppliers performing continuing work is performed each year. This evaluation determines if a reaudit is 17 required during the upcoming year. This evaluation considers pertinent factors such as the results of other audits, history of performance of product and/or purchased service and effectiveness of implementation of the supplier's quality assurance program.
17 This evaluation is documented and approved by the Manager, of Nuclear Oversight and placed in supplier quality history files.
Regardless of the results of the evaluation, the suppliers performing continuing work are subjected to an initial audit and are reaudited every three years. Audits of suppliers performing limited duration assignments are conducted at least once during the life of the contract.
If at the time of the pre award survey, the supplier is already implementing the same quality assurance program for other customers that he proposes to use on the auditing part's contract, then the pre-award survey may serve as the first triennial audit.
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17.2.18.2 (Continued)
The audit requirement shall not apply to standard off-the-shelf items and bulk commodities where required quality can adequately be determined by receipt inspection of post-installation checkout or test.
Results of audits conducted by the SCE Nuclear Oversight Division are reviewed with the management of the organization audited during exit interviews and are documented in formal audit reports to management. Responsible management in the areas audited implement the necessary actions required to correct deficiencies.
These actions are documented and retained as part of the total audit record. Reaudits are conducted of deficient areas to verify proper implementation of correct actions.
Audit data are summarized and analyzed by the SCE Nuclear Oversight Division and reported to the Manager of Nuclear Oversight and the Vice President, Engineering and Technical 17 Services, on a regular basis. These reports indicate quality trends and the effectiveness of the SCE Quality Assurance Program. The Vice President issues directives for corrective 117 action resulting from these reports, as necessary, and assures appropriate management involvement in correcting significant conditions adverse to quality.
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17.2.19 OUALITY ASSURANCE PROGRAM FOR FIRE PROTECTION PROGRAM The Quality Assurance Program for the fire protection program during the operational phase is designed to conform with applicable requirements of Branch Technical Position APCSB 9.5-1 (5-1-76) Position B.7 and Appendix A (8-23-76) Position C for fire protection program systems and components.
The fire protection program consists of components, procedures, and personnel utilized in carrying out all activities of fire protection including such things as fire prevention, detection, annunciation, control, confinement, suppression, extinguishment, administrative procedures, inspection, testing, maintenance, and training.
17.2.19.1 Organization The organizational structure and responsibilities for establishing and executing the Quality Assurance Program for the fire protection program are generally described in subsection 17.2.19.1.1. Specific responsibilities are applied to the fire protection program are delineated below:
The Vice President, Nuclear Generation, is responsible for the fire protection program controls and the interface controls at 17
- the Station.
The Nuclear Oversight Supervisors are responsible for review, inspection, surveillance and audit of the Quality Assurance Program provisions.
117 The Manager Nuclear Engineering Design is responsible for fire 117 protection program engineering and design performed by SCE and for review of these activities when performed by contractors.
The Project Purchasing Agent is responsible for procurement of fire protection program materials, equipment, and services when purchased by SCE.
The Nuclear Construction Manager is responsible for managing the 117 installation and testing of the fire protection techniques during construction.
17.2.19.2 Quality Assurance Program The Quality Assurance Program shall assure that the requirements for design, procurement, installation, testing and administrative controls for the fire protection program for safety-related items are satisfied. The fire protection systems and components that are included in fire protection program shall be identified by Nuclear Engineering Design for 117 planning of Quality Assurance Program activities.
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17.2.19.2 (Continued)
Activities affecting the fire protection program shall be controlled by written procedures, prepared by participating organizations, that delineate the responsibilities and required actions for implementation of these activities. Measures shall be established within these procedures for special control over he use and storage of combustible materials and for the controlled application of processes involving ignition sources (i.e., welding, flame cutting).
Training and indoctrination of Station personnel in Quality Assurance Program requirements shall be provided in accordance with subsection 17.2.2.
Training and indoctrination of construction personnel will be provided by the Manager, Nuclear 17 Construction, for fire protection during modification activities.
This training shall include familiarization with (1) the location, use and application of fire fighting equipment, (2) planned actions and responsibilities of fire brigade team members and interfaces with offsite fire fighting agencies, and (3) maintenance and inspection requirements for fire protection systems. Similar training will be conducted by contractors during modification activities.
117 Management shall regularly review the quality assurance program status.
17.2.19.3 Design Control For modifications to existing equipment, as far as practicable, design control measures shall be provided consistent with the 17 provisions of subsection 17.2.3 and this paragraph. These measures will provide a defense-in-depth to assure that design provisions are developed and reviewed to prevent or mitigate consequences of a postulated fire as it may affect the performance of safety-related items.
Design formulation and development will be guided by the establishment, during the design phase, of a fire hazard evaluation. The purpose of this evaluation shall be to provide a high level of confidence that no single credible fire could result in an unacceptable consequence by providing fire protection features and systems to maintain safety-related items functioning for the time period required for safe reactor shutdown and maintenance of the reactor in a safe shutdown condition.
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 7/94 17.2-52 Amendment 17
17.2.19.4 (Continued) 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.
The Nuclear Oversight Division is responsible for performing periodic audits, as described in Subsection 17.2.18, to verify that applicable requirements are stipulated consistent with the nature and use of the procured material or service.
17.2.19.5 Instructions, Procedures and Drawings Instructions, procedures and drawings shall be developed and 117 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 activities, emergency plans and procedures 117
.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 117 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.
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 station.
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17.2.19.7 (Continued)
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.
Testing and inspection at the Station combined with certified 117 manufacturer's data, when available, will provide a material and equipment history which will be used as a basis for operation and maintenance of fire protection equipment.
17.2.19.8 Inspection Inspection activities for the fire protection program shall be provided in accordance with the requirements of subsection 17.2.10 and this paragraph.
Inspection of fire protection material and equipment will be provided primarily at the station, with selected source 117 inspection where the item cannot be adequately inspected and tested at the station.
117 17.2.19.9 Test Control Test controls for the fire protection program shall be
.established and implemented in accordance with subsection 17.2.11 and this paragraph.
The responsibility for implementation of test controls at the Station, including maintenance and periodic retesting of equipment, shall rest with the Vice President, Nuclear 17 Generation.
The responsibility for implementation of test controls during 117 modifications, including maintenance and periodic retesting of equipment, shall rest with the Nuclear Construction Manager.
Interfaces with the Station will be coordinated with the Vice 17 President, Nuclear Generation. Witness of tests performed by SCE will be provided by Nuclear Oversight personnel.
Test controls shall assure that fire protection equipment is fully operational to meet design requirements at the time of installation. Periodic retests will be provided to assure that the equipment remains operable and that it continues to meet design requirements. A test plan shall be established which defines the types, frequency, and detailed procedures for periodic retesting of equipment. Tests results shall be evaluated by the Station or by Construction for acceptance.
Unacceptable results shall be dispositioned in accordance with the requirements of paragraph 17.2.19.12 below.
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17.2.19.10 Control of Measuring and Test Equipment Calibration and control of measuring and test equipment for fire protection equipment shall be in accordance with the provisions of subsection 17.2.12.
17.2.19.11 Inspection, Test and Operating Status Inspection, test, and operating status of the fire protection equipment shall be in accordance with the provisions of subsection 17.2.14.
17.2.19.12 Nonconforming Materials, Parts and Components Control of nonconforming fire protection material and equipment will be provided in accordance with the requirements of subsection 17.2.15.
17.2.19.13 Corrective Action Conditions adverse to maintaining the capability of the fire protection equipment to perform its intended function shall be identified, documented and corrected in accordance with the provisions of subsection 17.2.16.
17.2.19.14 Quality Assurance Records Records which are sufficient to furnish evidence that the requirements of this Program are being met, shall be prepared and 6
maintained in accordance with subsection 17.2.17 and this paragraph. These records include the following:
A. Design documents which form the basis for as-constructed conditions.
B. Documents for procurement which form the basis for manufacturing and inspection of items.
C. Inspection and test records evidencing the degree of compliance of as-constructed items with design and procurement document requirements.
D. Nonconformance and corrective action reports.
E. Audit reports.
17.2.19.15 Audits Audits of the quality assurance program controls as applied to the fire protection program shall be performed in accordance with the provisions of subsection 17.2.18.
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- BLE 17.2-1 SCE QUALITY ASSURANCE PROGRAM COMPLIANCE TO GUIDES, REQUIREMENTS. AND STANDARDS OPERATION NOTE:
Commitments made herein regarding compliance with specific issues of NRC Regulatory Guides and ANSI Standards may be modified in applicable FSAR's.
Guide. Requirement, or Standard Compliance Status Remarks 10CFR50, Appendix B - Quality Assurance Complies Criteria for Nuclear Power Plants and Fuel Reprocessing Plants 10CFR Part 55 - Operators Licenses Complies Regulatory Guide 1.8 - Personnel Complies Endorses ANSI N18.1 Selection and Training (Revision 1, 9/75)
Regulatory Guide 1.28 - Quality Assurance Complies Endorses ANSI N45.2 Program Requirements (Design and Construction) (Safety Guide 28, 6/7/72)
Regulatory Guide 1.30 - Quality Assurance Complies Endorses ANSI N45.2.4 Requirements for the Installation, Inspection, and Testing of Instrumentation and Electrical Equipment (Safety Guide 30, 8/11/72)
Regulatory Guide 1.33 - Quality Assurance Complies Endorses ANSI N18.7 Program Requirements (Operation)
(Revision 2, 2/78)
Regulatory Guide 1.37 - Quality Assurance Complies Endorses ANSI N45.2.1 Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants (3/16/73)
Regulatory Guide 1.38 - Quality Assurance Complies Endorses ANSI N45.2.2 Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Water-Cooled Nuclear Power Plants (Revision 2, 5/77)
Table 17.2-1 (Continued)
Guide. Requirement, or Standard Compliance Status Remarks Regulatory Guide 1.39 - Housekeeping Complies Endorses ANSI N45.2.3 Requirements for Water-Cooled Nuclear Power Plants (Revision 2, 9/77)
Regulatory Guide 1.54 - Quality Assurance Complies Endorses ANSI N1O1.4 Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants (6/73)
Regulatory Guide 1.58 - Qualification Complies Endorses ANSI N45.2.6 of Nuclear Power Plant Inspection, Examination, and Testing Personnel (Revision 1, 9/80)
Regulatory Guide 1.64 - Quality Assurance Complies Endorses ANSI N45.2.11 Requirements for the Design of Nuclear Power Plants (Revision 2, 6/76)
Regulatory Guide 1.70 - Standard Format Complies and Content of Safety Analysis Reports for Nuclear Power Plants (Revision 2, 9/75)
Regulatory Guides 1.74 - Quality Assurance Complies Endorses ANSI N45.2.10 Terms and Definitions (2/74)
Regulatory Guide 1.88 - Collection, Complies Endorses ANSI N45.2.9 Storage, and Maintenance of Nuclear Power Plant Records (Revision 2, 10/76) t a"
Enoss NIN4..
Table 17.2-1 (Continued)
Guide, Requirement. or Standard Compliance Status Remarks Regulatory Guide 1.94 - Quality Assurance Complies Endorses ANSI N45.2.5 Requirement for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants (Revision 1, 4/76)
Regulatory Guide 1.116 - Quality Assurance Complies Endorses ANSI N45.2.8 Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems (6/76)
Regulatory Guide 1.123 - Quality Assurance Complies Endorses ANSI N45.2.13 Requirements for Control of Procurement of Items and Services for Nuclear Power Plants (Revision 1, 7/77)
Regulatory Guide 1.144 - Auditing of Complies Endorses ANSI N45.2.12 Quality Assurance Programs for Nuclear Power Plants (Revision 1, 9/80)
Regulatory Guide 1.146 - Qualification of Complies Endorses ANSI N45.2.23 Quality Assurance Program Audit Personnel for Nuclear Power Plants (8/80)
Regulatory Guide 4.15 - Quality Assurance Complies if invoked for Radiological Monitoring Programs by facility operating 6
(Normal Operation) - Effluent Streams and license the Environment (Revision 1, 2/79)
(D
TABLE 17.2-2 SOUTHERN CALIFORNIA EDISON COMPANY QUALITY ASSURANCE PROGRAM IMPLEMENTING PROCEDURES 10CFR50 Appendix B Criteria Implementing Procedure Documents 1 2 3 4 5 6 7 8 9 10 11 12 13 14 I5 16 17 18 Suuary Quality Assurance Organization Quality Assurance Manual x x x x x x x x X X
x x
x x
x x
X x
Quality Assurance manuals (applicable project) describe the SCE Quality Assurance program policies Quality Assurance Reference x x X X x x x
x x
x X
X x
x for all 1mCFR5O. Appendix Procedures Manual B, criteria and provide appropriate general implementation procedures.
The Reference Procedures Manual provides specific implementation procedures required by the Quality Assurance Organization to implement 10CFR50, Appendix B. criteria.
Nuclear Generation Site Department Station Orders, Procedures, and X x x x x x x x x x
x x
x x
x x
X x
Station orders, procedures 4
Operating Instructions and operating instructions SEinecontain implementation procedures for 10CFR5O, Appendix B, criteria.
U, kD Engineering & Technical Services17 Quality Assurance Reference x x x x x x x x x x
x x
x x
x x
x x
Emphasis of Department Procedures Manual procedures is on preparation and control of drawings, specifications, and procedures, and procurement activities.
Procurement and Material Management Quality Assurance Reference X x X x X x x
x x
Emphasis of Department Procedures Manual Procedures is on control of purchase orders, contracts and vendor proposals and documentation.
(D (D.
-4
Table 17.2-2 (Continued) 10CFR5O Appendix B Criteria Implementing Procedure Documents 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Sumary Shop Services & Instrumentation 16 Quality Assurance Reference x x x x x x x x x x
x x
x x
x x
x Emphasis on metrology Procedures Manual and repair of equipment.
16 Corporate Documentation Services 116 Quality Assurance Reference x x x x x
x Emphasis of Corporate Procedures Manual Documentation Services procedures is on control, retention, and retrieval of documents.
0 O
(D~
17.2-3 NUCLEAR OVERSIGHT DIVISION ACTIVITIES OPERATION The following are SCE Nuclear Oversight Division personnel 17 activities during the operation of nuclear generating stations:
- 1.
Perform periodic audits to assure effective implementation of procurement document control requirements.
- 2.
Prepare and maintain quality assurance manuals, procedures, and instructions. Maintain quality assurance chapter in the 117 FSAR's current, Topical Report, SCE-1-A.
- 3.
Review and approve quality assurance programmatic procedures and instructions prepared by other internal organizations.
- 4.
Evaluate potential supplier's quality assurance manuals.
- 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 SCE organizations and external audits of A-E's or other contractors and suppliers to SCE.
Followup 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 Centers to assure proper filing and retention of appropriate quality assurance documentation.
- 12.
Conduct internal audits of station operations. Followup to verify implementation of corrective action.
- 13.
Provide support to the Onsite Review Committee (OSRC).
- 14.
Provide quality assurance support during refueling and Inservice Inspection and audit these activities.
- 15.
Perform inspection activities as required and assigned.
7/94 17.2-61 Amendment 17
ENCLOSURE 11
SUMMARY
OF CHANGES INTRODUCED IN Page 1 of 2 TOPICAL REPORT SCE-1-A AMENDMENT 17 AS COMPARED WITH AMENDMENT 16 Reduction in Paraqraph Change Introduced Commitment Table of Status update.
17 No Contents List of Organizational changes.
Change Notice 40 No Figures List of Status update.
17 No Amendments 17.0 Deletes preoperational & startup test CN40 No activities.
17.0.1 Editorial changes.
CN40 No 17.2.1.2 Organizational changes.
CN40 No 17.2.1.3 Organizational changes.
CN40 No 17.2.1.4 Organizational changes.
CN40 No 17.2.1.5 Organizational & editorial changes.
17 & CN40 No 17.2.1.6 Organizational & editorial changes.
17 & CN40 No 17.2.1.7 Organizational & editorial changes.
17 & CN40 No 17.2.1.8 Organizational & editorial changes.
17 & CN40 No 17.2.1.9 Editorial change.
17 No 17.2.1.10 Editorial change.
17 No 17.2.2.1 Deletes preoperational & startup test CN40 No activities.
17.2.2.2 Deletes preoperational & startup test CN40 No activities. Organizational changes.
17.2.3.1 Deletes preoperational & startup test CN40 No activities and editorial changes.
17.2.4.2 Organizational and editorial changes.
CN40 No Deletes Engineering Construction Project (ECP) activities.
17.2.5.1 Organizational change. Deletes ECP CN40 No activities.
17.2.6.2 Adds vendor information, UFHA, and design CN40 No base documents. Organizational and editorial changes. Deletes ECP activities 17.2.7.2 Editorial Change. Deletes ECP CN40 No activities.
SUMMARY
OF CHANGES Page 2 of 2 0
Reduction in Paraqraph Change Introduced Commitment 17.2.8.2 Deletes ECP activities.
CN40 No 17.2.9.2 Deletes ECP activities.
CN40 No 17.2.10.2 Editorial change. Deletes ECP CN40 No activities.
17.2.11.2 Organizational and editorial changes.
CN40 No Deletes initial plant tests.
17.2.12.2 Organizational and editorial changes.
17 & CN40 No Deletes preoperational and startup testing activities.
17.2.13.2 Organizational and editorial changes.
CN40 No Deletes ECP activities.
17.2.14.2 Organizational changes. Deletes startup CN40 No
& test manuals and ECP activities.
17.2.15.2 Organizational and editorial changes.
CN40 No 17.2.16.2 Organizational and editorial changes.
CN40 No 17.2.18.2 Editorial changes.
CN40 No 17.2.19.1 Organizational and editorial changes.
CN40 No to Deletes ECP activities.
17.2.19.10