ML13319A862
| ML13319A862 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/31/1996 |
| From: | Ray H, Slagle K Southern California Edison Co |
| To: | |
| Shared Package | |
| ML13316A192 | List: |
| References | |
| SCE-1-A-02, SCE-1-A-2, NUDOCS 9612160384 | |
| Download: ML13319A862 (87) | |
Text
SOUTHERN CALIFORNIA EDISON COMPANY TOPICAL REPORT QUALITY ASSURANCE PROGRAM SCE-1-A APPROVALS MANAGER 0 NUCLEAR OVERSIGHT EXECUTIVE VICE PR 7NT Amendment 18 October 1996 Change Notice 42 9612160384 961211 PDR ADOCK 05000206 P
ENCLOSURE II
SUMMARY
OF CHANGES INTRODUCED IN Page 1 of I TOPICAL REPORT SCE-1-A Change Notice #42 AS COMPARED TO AMENDMENT 18, Change Notice #41 Reduction in Paragraph Change Introduced Commitment Table of Contents Status update CN-42 No 17.2.1.4 Revised to show current titles and CN-42 No responsibilities in the Nuclear Oversight Division, and deleted title of Manager, Emergency Planning and Public Affairs (EP&PA) 17.2.1.8 Deleted Corporate Security Functions as CN-42 No related to SONGS Security Fig. 17.2.1 Deleted Corporate Security from SCE CN-42 No Corporate Structure
. 17.2.1b Deleted Manager, EP&PA from Engineering CN-42 No
& Technical Services Organization Structure 17.2.2.2 Editorial - added word "operation" CN-42 No 17.2.11.4 Clarified plant equipment that require CN-42 No evaluation for out-of-tolerance conditions 17.2.14.2 Revised title "QC Supervisor to "NOD CN-42 No Supervisor" 17.2.20.2.3 Revised to reflect current OSRC CN-42 No composition. Deleted Deputy Station Manager, corrected title Supervisor of I&C 17.2.20.2.7 Added Licensee Controlled Specifications CN-42 No 17.2.20.5.2.h Deleted incorrect reference to LCS CN-42 No 17.2.20.5.2.1 Added correct LCS reference for snubber CN-42 No records
TABLE OF CONTENTS SECTION/
SECTION NO.
TITLE PAGE AMENDMENT/CN #
Table of Contents 17-i 18 CN-42 17-ii 18 CN-42 17-iii 18 CN-42 List of Tables 17-iv 18 CN-41 List of Figures 17-v 18 CN-42 List of Amendments 17-vi 18 17.0 Introduction 17.0-1 17 17.0.1 Definitions 17.0-2 18 CN-41 17.0-3 18 CN-41 17.0-4 18 CN-41 17.0-5 17 CN-41 17.0-6 17 CN-41 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 18 17.2-2 18 CN-41 17.2-3 18 17.2-4 18 17.2-5 18 17.2-6 18 CN-41 17.2-7 18 CN-42 17.2-8 18 CN-42 17.2-9 17 Figure 17.2.1 - Corporate Structure 17.2-10 18 CN-42 Figure 17.2.1a -
NGS Nuclear Organization 17.2-11 17 Figure 17.2.1b - E&TS Nuclear Organization 17.2-12 18 CN-42 Figure 17.2.2 -
Typical Interface Organization 17.2-13 17 17.2.2 Quality Assurance Programs 17.2-14 17 CN-42 17.2-15 18 CN-41 17.2-16 CN-41 17.2-17 17 17.2.3 Design Control 17.2-18 17 CN-41 17.2-19 17 17.2-20 17 17.2.4 Procurement Document Control 17.2-21 17 17.2-22 17
- 6 17-i Amendment 18 CN-42
TABLE OF CONTENTS SECTION/
SECTION NO.
TITLE PAGE AMENDMENT/CN #
.2.5 Instructions, Procedures, & Drawings 17.2-23 18 CN-41 17.2.6 Document Control 17.2-24 17 CN-41 17.2-25 17 CN-41 17.2.7 Control of Purchased Material, 17.2-26 17 Equipment & Services 17.2-27 17 17.2.8 Identification and Control of 17.2-28 17 Materials, Parts and Components 17.2.9 Control of Special Processes 17.2-29 17 17.2.10 Inspection 17.2-30 17 17.2-31 18 CN-41 17.2-32 17 17.2.11 Test Control 17.2-33 17 17.2-34 17 CN-42 17.2-35 17 CN-42 7.2.12 Calibration Program 17.2-36 17 17.2-37 17 17.2-38 17 17.2-39 17 17.2.13 Handling, Storage and Shipping 17.2-40 17 17.2.14 Inspection, Test and Operating Status 17.2-41 17 CN-42 17.2.15 Nonconforming Materials, Parts or 17.2-42 18 CN-41 Components 17.2-43 18 CN-41 17.2-44 18 17.2.16 Corrective Action 17.2-45 17 17.2-46 17 17.2.17 Quality Assurance Records 17.2-47 13 CN-41 17.2-48 13 CN-41 17.2.18 Audits 17.2-49 13 CN-41 17.2-50 17 CN-41 17.2-51 17 6
17-ii Amendment 18 CN-42
TABLE OF CONTENTS SECTION/
4 SECTION NO.
TITLE PAGE AMENDMENT/CN #
7.2.19 Quality Assurance Program for Fire 17.2-52 17 CN-41 Protection Program 17.2-53 17 CN-41 17.2-54 17 17.2-55 17 17.2-56 6
17.2.20 Administrative Controls 17.2-57 CN-41 17.2-58 CN-42 17.2-59 CN-42 17.2-60 CN-41 17.2-61 CN-41 17.2-62 CN-41 17.2-63 CN-41 17.2-64 CN-41 17.2-65 CN-42 17.2-66 CN-42 Table 17.2-1 Southern California Edison Company 17.2-67 18 Quality Assurance Program Compliance to 17.2-68 6
Guides, Requirements, and Standards -
17.2-69 6
Operation W
able 17.2-2 Southern California Edison Company 17.2-70 17 CN-41 Quality Assurance Program Implementing 17.2-71 16 Procedures Table 17.2-3 Nuclear Oversight Division Activities -
17.2-72 17 CN-41 Operation
- 96 17-iii Amendment 18 CN-42
LIST OF TABLES LE NO.
TITLE PAGE e 17.2-1 Southern California Edison Company 17.2-67 l18 Quality Assurance Program Compliance to Guides, Requirements, and Standards Operation Table 17.2-2 Southern California Edison Company 17.2-70 117 CN-41 Quality Assurance Program Implementing Procedures Table 17.2-3 Nuclear Oversight Division Activities -
17.2-72 17 CN-41 Operation 17-iv Amendment 18 CN-41
LIST OF FIGURES TITLE PAGE SCE Quality Program Organization -
17.2-10 18 CN-42 Corporate Structure 17.2-la SCE Quality Program Organization -
17.2-11 17 Nuclear Generation Department 17.2-1b SCE Quality Program Organization -
17.2-12 18 CN-42 Engineering & Technical Services 17.2-2 SCE Quality Program, Typical Interface 17.2-13 17 Organization S
617-v Amendment 18 CN-42
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 18 March 1996 17-vi Amendment 18
- 17. QUALITY ASSURANCE
17.0 INTRODUCTION
topical report was prepared in accordance with the Nuclear latory Commission's (NRC) "Standard Format and Content of ety 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.
O as applicant, plant owner and operator, maintains full ponsibility 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 10CFR50.54a.
4 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 ined in ANSI N45.2.10, as endorsed by Regulatory Guide 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.
Action Request (AR) -
A single form action system used for 18 documenting, evaluating, and dispositioning equipment problems, CN-41 document/program discrepancies, or human performance concerns.
Action Request Committee (ARC) - A management review group who 18 routinely reviews and processes Action Requests. The ARC is composed of, as a minimum, plant management representatives from CN-41 Technical, Operations, and Maintenance Divisions. The committee is further supplemented by representatives from Design Engineering, Nuclear Oversight, Fire Protection, and others, who provide assistance, as needed, for disposition activities.
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.
AhitecEnrineer (A-E) -
An organization contracted to ign, construct and perform backfit modifications to a W lear generating station.
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.
6 17.0-2 Amendment 18 CN-41
17.0.1 (Continued)
Design Documents - Drawings, P&I diagrams, calculations, or specifications which define items and which are needed translate engineering concepts into structures, systems co1mponents.
118 118 Important to Safety -
Safety related and non-safety related items whose interaction with safety related items require review to assure proper functioning of the safety related items, including the following:
o Non-safety related items whose failure could directly prevent satisfactory accomplishment of safety related functions; o
Non-safety related items relied on in safety analysis or plant evaluations to demonstrate compliance with the fire protection program, environmental qualification program, seismic interaction, ASME Code Section III and XI requirements, ATWS, and station blackout; o
Non-safety related items subject to operability CN-41 requirements contained in the Technical Specifications/Licensee Controlled Specifications limiting conditions for operation; NOTE:
Does not apply to Unit 1 items designated to be funcgtional.
o Non-safety related items credited as protective feature for safety related items in high energy line break analysis; o
Non-safety related items which support the implementation of the quality assurance program related to security, radiological effluent and environmental monitoring, emergency preparedness, health physics and radiation protection, and chemistry.
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.
6 17.0-3 Amendment 18 CN-41
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 ensee Controlled Specification (LCS) - The document which includes most items that were relocated from the Unit Technical Specifications which do not satisfy the requirements of 10CFR50.36 for inclusion as limiting conditions for operation and those requirements that are controlled directly by regulations and related programs as part of the Technical Specification Improvement Program.
(Note: some requirements were relocated to CN-41 the UFSAR or the Topical Report.)
The LCS also may include good practices directed by Engineering or Operations, when deemed appropriate to formalize the practice and specify remedial actions, surveillances, etc.
The LCS includes the administrative controls as well as limiting conditions for operations and related surveillance requirements.
Modification Tests -
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 6'tings.
lear Steam Supply System (NSSS) Supplier - An organization contracted to desian and manufacture a nuclear steam supply system for a nuclear generating station.
Offsite Dose Calculation Manual -
The program controls applied to radioactive effluent and radiological monitoring. These controls include the description of the methodology and parameters used in CN-41 the calculation of offsite doses from radioactive liquid and airborne effluents and provide calculations for alarm/trip setpoints for liquid and gaseous effluent monitoring instrumentation.
Out-of-Tolerance Condition - An out-of-tolerance condition is one in which the as-found setting for the devices is found outside of the allowable value.
The allowable value is offset from the trip 18 setpoint by a combination of setting tolerance and drift, as defined in SONGS Design Standard JS-123-103C, Rev. 1.
Preoperational Tests -
Tests conducted to demonstrate the capability of items to meet safety-related performance requirements.
6 17.0-4 Amendment 18 CN-41
17.0.1 (Continued)
Process Control Program - The program controls applied to the process and effluent radiological monitoring systems which vide information to operators concerning activity levels in cted plant process systems and plant effluents. These CN-41 tems provide early detection of radioactive leakage into normally non-radioactive systems, and provides continuous remote indication and recording of airborne radioactive contamination in the form of particulates and iodines in various plant locations.
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.
117 Project Engineer - The primary engineering interface for Project Management from which project direction is received and the engineering organization from which technical direction is received.
Prototype Tests - Tests conducted in support of design activities 117 to demonstrate the adequacy of the design to perform under the most adverse conditions.
Oualification - Required acts to select a source for providing 6 ms or services.
lity-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.
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.
6 17.0-5 Amendment 17 CN-41
17.0.1 (Continued)
Reportable Occurrences -
Events or conditions which are reportable to the Nuclear Regulatory Commission (NRC) in W
ordance with reporting requirements such as, 10CFR20 CN-41 diation Exposure); 10CFR21 (Defects); 10CFR26 (Fitness for y); 10CFR50.9 (Completeness/Accuracy of Information);
10CFR50.72 (Immediate Notification); 10CFR50.73 (Licensee Event Reports); 10CFR73 (Physical Protection), and other regulatory reporting requirements.
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 rection.
16hnical 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.
6 17.0-6 Amendment 17 CN-41
17.2 OUALITY ASSURANCE DURING THE OPERATIONS PHASE 17.2.1 ORGANIZATION
.2.1.1 SCOPE subsection describes the SCE organizational structure and ponsibilities 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 responsibility 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, Emergency Planning, Nuclear 18 Oversight, 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, 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 Shared Services Records Storage, Salvage and Retrieval, Procurement, 118 Transportation of Material and Equipment (except Nuclear Fuel),
Contract Administration and Oversight of Site Security
@6 17.2-1 Amendment 18
17.2.1.2 (continued)
The SCE organizational structure of departments involved with implementing the SCE Quality Assurance Program during the rational phase as well as departmental interfaces is presented igure 17.2.1, Figure 17.2.1a and Figure 17.2.1b.
In addition to the departmental responsibilities listed, the CN-41 following describes the Safety-Related functions of the On-Site Review Committee (OSRC), Nuclear Safety Group (NSG), and Independent Safety Engineering Group (ISEG).
Additional details CN-41 are described in Subsection 17.2.20.
Committee/Board/Group Responsibility OSRC Advise the Vice President, Nuclear 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, CN-41 responsibilities and authorities specific to each committee/group is described in Subsection 17.2.20 and in internal procedures.
ultimate responsibility for operating, maintaining, airing, 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 President and Chief Operating Officer reports to the Chairman of the Board and is responsible for the SCE Business Units and 18 Shared Services activities.
The Executive Vice President reports to the President and Chief Operating Officer and is responsible for Engineering and 18 Technical Services, Nuclear Generation Departments, Shop Services and Instrumentation Department, Fuels, and Power Production. The Executive Vice President is responsible for the establishment of Quality Assurance policies.
For Nuclear matters, the Executive Vice President reports to the Chairman of the Board.
18
@6 17.2-2 Amendment 18 CN-41
17.2.1.2 (continued)
UNIT STAFF QUALIFICATIONS (Continued)
- Vice President, Engineering and Technical Services, has been gated the responsibility for the assurance of implementation 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.
SCE corporate management is involved with quality assurance matters on a continuing basis by means of regular Officer Council meetings. Nuclear Oversight Division weekly progress reports are prepared for the Vice President, Engineering and Technical 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 Executive Vice President, 118 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 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 nificant quality assurance matters related to station 1Wrations 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 the safe and reliable operation, maintenance, testing, Security, Chemistry, refueling, and In-service Testing of the units and reports to the Executive Vice President.
118 17.2-3 Amendment 18
17.2.1.3 (continued)
The Vice President, Nuclear Generation, is responsible for the routine administration and implementation of the lity Assurance Program at the station, including the owing station organization functions, where appropriate:
o Review and approval of Design Documents for station 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 Station.
o Operation and Maintenance of plant systems and equipment o Conducting Performance Tests and In-Service Testing and Evaluations.
o Refueling 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 17.2.1.4 Engineering and Technical Services 18 The Vice President, Engineering and Technical Services, is 118 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 Collection and reviews of Environmental Impact for Nuclear Power Plant Activities.
@6 17.2-4 Amendment 18
17.2.1.4 (continued)
The Vice President, Engineering and Technical Services, is responsible for the assurance of implementation of the SCE lity Assurance Program in compliance with applicable lations, codes, and standards, including those listed in le 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 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, Engineering and Technical Services, through the Manager of Nuclear Oversight.
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 Engineering and Technical Services Department, he has the 6
hority and obligation to raise quality issues to the Executive 118 e President for resolution if need be.
The Quality Assurance uals are reviewed and approved by the Manager of Nuclear Oversight and the Executive Vice President. Other organizations 118 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 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.
@6 17.2-5 Amendment 18
17.2.1.4 (continued)
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 individuals with ICN-41 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
' anizational freedom to:
o Identify quality problems.
o Initiate, recommend, or provide solutions through designated channels.
o Verify implementation of solutions.
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 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 Executive Vice President if need be.
118 Additional activities performed by Nuclear Oversight Division personnel during the operations phase are listed on Table 17.2-3.
17.2-6 Amendment 18 CN-41
17.2.1.4 (continued)
The Quality Manager and Supervisors in Nuclear Oversight are assigned to the operating nuclear generating station. They are onsible for directing and managing the activities of onnel performing the activities described on Table 17.2-3.
Designated Nuclear Oversight Quality Managers and Supervisors are responsible for directing the activities of Nuclear Oversight personnel who provide inspection of safety related and non-safety related items and activities when requested by Station or CN-42 Construction Management.
The Manager, Quality Engineering, is responsible to the Manager of Nuclear Oversight for ensuring the Nuclear Safety Group (NSG),
Independent Safety Engineering Group (ISEG) and Engineering/Fuels Group (EFG) supervisors and personnel provide independent review of activities as defined in the station technical specifications and quality assurance program.
Nuclear Oversight Quality 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.
CN-42 The Vice President, Engineering and Technical Services provides 118 the technical and quality aspects for nuclear engineering and design, core physics, fuel performance, core monitoring, Nuclear Safety Analysis, site engineering support, offsite emergency CN-42 planning support, procurement engineering, construction and retrofit management, design basis documentation, procurement and shipment of nuclear fuel, spent fuel shipping services and special nuclear material accountability.
17.2.1.5 Business and Financial Services The Manager of Business and Financial Services reports to the Executive Vice President and provides procedure support and 118 records management.
@96 17.2-7 Amendment 18 CN-42
17.2.1.6 Shop Services and Instrumentation The Manager of Shop Services and Instrumentation reports to the Executive Vice President and provides equipment repair and 118 Wibration for the Station, as requested by division managers.
W02.1.7 Power Production The Vice President Power Production reports to the Executive Vice 18 President.
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.
The Division Chemical Staff assists generating stations with water chemistry control.
The Division Maintenance Organization, provides supervision and manpower capability for major overhauls and equipment repair.
17.2.1.8 Shared Services 118 The Vice President, Shared Services reports to the President and Chief Operating Officer and is responsible Procurement and 18 Material Management, Real Properties and Administrative Services, and Corporate Security.
The Procurement and Material Management Department, under the direction of the Vice President, Shared Services, is responsible 18 procurement of materials and equipment, except nuclear fuel, nuclear generating stations.
The Manager of Procurement and Material Management reports to the Vice President, Shared Services, and is responsible for 118 procurement of items and services (excluding nuclear fuel),
material shipping, and for preparation, negotiations, and administration of procurement contracts.
The Manager of Real Properties and Administrative Services reports directly to the Vice President, Shared Services, and is 118 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.
CN-42
@196 17.2-8 Amendment 18 CN-42
17.2.1.9 Delegated Quality Assurance Work SCE retains responsibility for the Quality Assurance Program described herein but may delegate quality assurance work to other anizations.
Other organizations which may be delegated the of establishing and executing portions of the Quality urance 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.
S agement of other organizations delegated quality assurance k 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.
@84 17.2-9 Amendment 17
SCE QUALITY ASSURANCE PROGRAM CORPORATE STRUCTURE CHAIRMAN/CEO (For Nuclear Matters)
PRESIDENT/COO EXECUTIVE VICE PRESIDENT I
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[NUCLEAR ORGANIZATION SVICE PRESIDENT VICE PRESIDENT VICE PRESIDENT VICE PRESIDENT POWER PRODUCTION NUCLEAR GENERATION ENG/TECH.
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z SCE QUALITY PROGRAM ORGAN IZATIO N FIGURE 17.2.1a 7/94 17.2-11 Amendment 17
NUCLEAR ORGANIZATION ENGINEERING AND TECHNICAL SERVICES EXECUTIVE VICE PRESIDENT VICE PRESIDENT MANAGER OF NUCLEAR OVERSIGHT ICN-42 M NAGER,
_NUCLEAR
- MANAGER, TRAINING SITE SUPPORT SERVICES MANAGER OF NUCLEAR REGULATORY AFFAIRS
- MANAGER, NUCLEAR ENGINEERING & DESIGN
- MANAGER, CONSTRUCTION
- MANAGER, TECHNICAL SERVICES
- MANAGER, NUCLEAR FUEL MANAGEMENT
- MANAGER, PROJECTS SCE QUALITY PROGRAM ORGANIZATION FIGURE 17.2.1b 17.2-12 Amendment 18 CN-42
SOUTHERN CALIFORNIA EDISON SCE Senior Management Manager of Nuclear Oversight Typical Architect - Engineer I
Division Manager Manager of Nuclear Oversight Typical NSSS Supplier Division Manager Manager of Nuclear Oversight TYPICAL INTERFACE ORGANIZATION FIGURE 17.2-2 Legend Technicalladrrinistrative Authority Q. A. Functional Direction 7/94 17.2-13 Amendment 17
17.2.2 QUALITY ASSURANCE PROGRAM 17.2.2.1 Scope subsection describes the SCE Quality Assurance Program ablished 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 maintained and revised in accordance with written procedures ecessary to reflect changes resulting from the finalization modification of station design. The Quality Assurance Program also applies to activities governed by the Station Technical Specifications, Licensee Controlled Specifications, and other activities licensed by the NRC, including the Fire Protection Program as described in Subsection 17.2.19.
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 with operation of the nuclear generating station. The program is ICN-42 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.
96 17.2-14 Amendment 17 CN-42
17.2.2.2 (continued)
The Vice President, Engineering and Technical Services, is Wponsible for establishing SCE quality assurance goals and ctives and for assuring that the quality assurance policies 18 e followed and the goals and objectives are met.
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 Q
the Vice President, Engineering and Technical Services, or, if essary, the Executive Vice President, or to the Chairman of ICN-41 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 procedures are reviewed by the Nuclear Oversight Division and reviewed and approved by the Vice President, Nuclear Generation 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 are maintained in the SONGS CDM Center or included in Quality Assurance Reference Procedure Manuals maintained by CN-41 the respective organizations. Table 17.2-2 lists procedure types and an explanation of their purpose. By means of inspections and audits, the Nuclear Oversight Division personnel verify that these procedures are followed.
6 17.2-15 Amendment 18 CN-41
17.2.2.2 (continued)
Station procedures are controlled by the Vice President, Nuclear CN-41 ration and are maintained in the SONGS CDM center.
ineering and Technical Services procedures are controlled by eVice President, Engineering & Technical Services and are maintained in the SONGS CDM Center.
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.
indoctrination and training programs include, as ropriate, 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.
@6 17.2-16 CN-41
17.2.2.2 (continued)
During design and construction activities, project review W
ings are held regularly to assess the design and 17 truction status and provide an interface between the ponsible 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 Testing. These plans are reviewed by the Nuclear Oversight 17 Division to assure that the test program is developed and controlled in accordance with the SCE Quality Assurance Program.
17 The SCE Nuclear Oversight Division verifies that these procedures are.developed and followed by means of inspection surveillance 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 117 Quality Assurance 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 17 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 lowing issuance of the NRC operating license, and at intervals exceeding three years, utilizing qualified individuals and Ws.
They result in written reports submitted to the Vice President, which are reviewed by the Nuclear Control Board.
17 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.
117
@4 17.2-17 Amendment 17
17.2.3 DESIGN CONTROL 17.2.3.1 ScoPe subsection describes the measure utilized by SCE to plan and 1
trol 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
- ge or modification involves an Unreviewed Safety Question, oval of the NRC is solicited. Additional controls related to CN-41 ign are described in Subsection 17.2.20.
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.
@6 17.2-18 Amendment 17 CN-41 L~
17.2.3.2 (Continued)
Documentation reflecting a design change is required to be iewed and approved by the same design groups cognizant in the 17 ipline affected by the change which reviewed and approved original documentation unless alternative design groups are designated by the Vice President, Nuclear Generation.
17 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.
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 Inclusion 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.
@4 17.2-19 Amendment 17
17.2.3.2 (Continued)
Design controls are applied by SCE, A-E's or contractors, as icable, to such disciplines as reactor physics, seismic, ss, thermal, hydraulic, radiation, and accident analyses.
sultants may be utilized to review and verify the design of certain items.
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.
17
@04 17.2-20 Amendment 17
17.2.4 PROCUREMENT DOCUMENT CONTROL 17.2.4.1 Scope subsection describes the measures utilized by SCE to control umentation 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 17 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.
17 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.
17.2-21 Amendment 17
17.2.4.2 (Continued)
Procurement Documents, and revisions thereto, are reviewed by onsible engineers to verify that they contain or reference 117 opriate technical and quality requirements to the item or ice 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.
l17 o
Documentation to be prepared, maintained, and submitted to SCE for review and approval.
117 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.
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.
I 17 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.
l17
@4 17.2-22 Amendment 17
17.2.5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS 17.2.5.1 Scope subsection describes the measures utilized by SCE to assure t activities affecting quality are prescribed by, and accomplished in accordance with appropriate instructions, procedure, and drawings. Additional controls related to instructions, procedures, and drawings are described in CN-41 Subsection 17.2.20.
17.2.5.2 Instructions, Procedures, and Drawings The SCE Quality Assurance Program includes provisions which 18 require that work be accomplished in accordance with documented and approved instructions, procedures, and drawings. These instructions, procedures, and drawings include, as appropriate, quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Controls are established which ensure that instructions, procedures, and drawings are current and accurately reflect plant design and regulatory requirements.
Procedures, instructions, and drawings, and changes thereto, are prepared, reviewed, approved, and controlled by the responsible organization which implement the associated activities. These procedures and instructions specify the requirements and/or methods to be utilized for compliance with the Quality Assurance Program.
18 r to issuance, the Nuclear Oversight Division (NOD) reviews CN-41 approves quality affecting programmatic procedures which describe administrative controls for implementing the Quality Assurance Program, including responsibilities or organizational structure, and procedures which define inspection/nondestructive examination requirements. Applicable maintenance and modification procedures and work order documents are reviewed to determine the applicability of quality witness/hold points.
CN-41 Additionally, other quality affecting procedures are subject to 18 NOD review at its discretion.
NOD periodically reviews the programmatic procedures(s), and changes thereto, which describe the method(s) for procedure development to assure consistency with the requirements of the Quality Assurance Program. Other procedures and instructions are reviewed by NOD as part of periodic audits of the Quality Assurance Program implementation described in Subsection 17.2.18.
18 6
17.2-23 Amendment 18 CN-41
17.2.6 DOCUMENT CONTROL 17.2.6.1 Scope subsection describes the measure utilized by SCE to control 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.
d 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 Updated Final Safety Analysis Report (UFSAR) and ICN-41 referenced topical reports.
o Updated Fire Hazards Analysis.
17 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 6
17.2-24 Amendment 17 CN-41
17.2.6.2 (Continued)
These documents, including changes thereto, are prepared, ewed, approved, issued, and controlled in accordance with oved written procedures. Procedures are maintained in ation 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, 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 Subsection 17.2.5.
CN-41 17 Design information transmitted from one organizational unit to another, including to organizations delegated design work, is tumented and controlled by written approved procedures.
se procedures require that design information transmittals entify 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.
@06 17.2-25 Amendment 17 CN-41
17.2.7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES 17.2.7.1 Scope subsection describes the measures utilized by SCE to 1trol 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 17 documented and forwarded to the Procurement and Material 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:
0 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.
@4 17.2-26 Amendment 17
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 innstructions 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.
responsibility for receiving inspection rests with Nuclear sight 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.
17
@4 17.2-27 Amendment 17
17.2.8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS AND COMPONENTS 81Scope
'issubsection 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.
117
@4 17.2-28 Amendment 17
17.2.9 CONTROL OF SPECIAL PROCESSES 17.2.9.1 Scope subsection describes the measures utilized by SCE to control lecial 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 4
17.2-29 Amendment 17
17.2.10 INSPECTION 17.2.10.1 Scope subsection describes the measure utilized by SCE to trol 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 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 17 specific steps necessary to perform the required inspection.
Qualified personnel conduct inspection activities in support of the overall inspection program.
@6 17.2-30 Amendment 17
17.2.10.2 (Continued) 18 The Nuclear Oversight Division reviews all documents associated CN-41 repair of Safety-Related items, audits selected documents, performs inspections and surveillance to verify that propriate 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 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:
o 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.
0 Inspection operations are performed and documented in compliance with the appropriate quality assurance manuals and inspection records are forwarded to the CDM Center.
17.2-31 Amendment 18 CN-41
17.2.10.2 (Continued)
Mandatory inspection hold points or witness points are specified 17
- rocurement Documents as appropriate at the time of approval uch 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.
117 4
17.2-32 Amendment 17
17.2.11 TEST CONTROL 17.2.11.1 Scope B subsection describes the measures utilized by SCE to control sting 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.
@4 17.2-33 Amendment 17
17.2.11.2 (Continued)
Tests are conducted in accordance with approved procedures and S
results evaluated to determine compliance with established ptance 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 the organization performing the test, and witnessed, as appropriate, by an inspector designated by the procuring organization.
truction material test procedures are prepared by the SCE cl ear 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.
117 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.
ICN-42 O
96 17.2-34 Amendment 17 CN-42
17.2.11.4 (Continued)
In addition, out-of-tolerance as-found conditions shall be uated for those instruments that are determined by ineering as supporting safety functions, and are included in e out-of-tolerance program. These include instruments supporting certain Technical Specification/LCS and other surveillance testing, Emergency Operating Instructions and accident analyses parameters. Out-of-tolerance conditions for equipment determined to be within the above scope will be CN-42 documented and dispositioned in accordance with Subsection 17.2.15.
Such out-of-tolerance conditions shall be reported to engineering groups who trend and evaluate this data in accordance with written criteria. Deviations as defined by this written criteria shall be documented and dispositioned in accordance with Subsection 17.2.15. The Nuclear Oversight Division performs periodic audits of these results.
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 the responsible test organization. Deviations of documented results beyond specified acceptance limits shall be spositioned by the responsible engineering organization prior 17 to declaring the equipment/system operable. Nuclear Oversight Division personnel are responsible for providing inspection surveillance throughout the testing program.
O 96 17.2-35 Amendment 17 CN-42
17.2.12 CALIBRATION PROGRAM 17.2.12.1 Scope subsection describes the measures utilized by SCE to control 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 equipment has been established to assure compliance with 117 Technical Specification requirements and other requirements appropriate to the equipment. This program includes the 17 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.
@4 17.2-36 Amendment 17
17.2.12.2.1 (Continued) o Provisions for evaluating components found out of tolerance or where the 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 O
ews calibration programs, including those prepared by ignated contractors and performs periodic audits to verify formance 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 117 Quality Assurance Program. This program contains the 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.
4 17.2-37 Amendment 17
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, 17 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:
4 17.2-38 Amendment 17
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.
4 17.2-39 Amendment 17
17.2.13 HANDLING, STORAGE, AND SHIPPING 17.2.13.1 Scope subsection describes the measures utilized by SCE to ntrol 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 17.2-40 Amendment 17
17.2.14 INSPECTION, TEST, AND OPERATING STATUS 17.2.14.1 Scope subsection describes the measures utilized by SCE to dicate 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, tems, or components to prevent inadvertent use. The system control or nonconforming items is described in Subsection 2.15.
117 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. A Nuclear Oversight Supervisor approves such waivers ICN-42 for inspections related to Safety-Related items.
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96 17.2-41 Amendment 17 CN-42
17.2.15 NONCONFORMING MATERIALS. PARTS OR COMPONENTS 17.2.15.1 Scope s subsection describes the measures utilized by SCE to control 18 terials, 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 Important to Safety items are described by written procedures. These procedures are prepared 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.
Reports of nonconforming conditions adverse to quality are analyzed to identify trends in quality performance. Significant conditions adverse to quality are promptly reported to the appropriate levels of management.
An Action Request Committee (ARC), comprised of management CN-41 representatives, reviews and assesses Action Requests (AR) and functions as an engineering review board. Within this review process, operability assessments and reportability determinations are performed, when required. Additionally, the ARC assigns actions, as appropriate, to address nonconformances.
e n the ARC consensus cannot be achieved on the appropriate rse of action for a significant/complex issue, the final disposition is made by the Manager of Nuclear Oversight.
Significant nonconformances of unusual complexity or involvement are submitted to the Vice President, Engineering and Technical Service, for resolution.
CN-41 18 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:
Measures to identify the nonconforming item including criteria for when to issue a Nonconformance document.
o Measure to document the nonconforming item, including disposition, verification of disposition activities, acceptability of deviations, cause, and corrective action. Nonconforming items will be dispositioned as 18 either rework, reject, repair, or accept-as-is.
CN-41 17.2-42 Amendment 18 CN-41
17.2.15.2 (continued) o Measures to segregate the nonconforming item from 18 acceptable items, where possible.
o Means of notification to the affected organizations.
o Method for evaluating deviations to determine if reportable under the requirements of 10CFR21, 18 10CFR50.72, 10CFR50.73, or the Technical Specifications, CN-41 or the Licensee Controlled Specifications.
CN-41 17.2.15.2.1 Site Activities When a nonconforming item is discovered at the Station, a nonconformance document will be generated by SCE personnel in accordance with procedural requirements.
Nonconformance documents contains the item's identification, description of the nonconformance, dispositioning activities, inspection requirements, approval signatures, and the organizations notified of the nonconformance. Cause and corrective actions are also documented.
A 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 18 ositioned. Nonconforming items discovered in installed items evaluated to determine their operability as defined by the hnical Specifications and use is controlled until the final disposition of the nonconformance and associated disposition implementation. Stamps or tags are utilized to identify the nonconformance.
Nonconforming items may be authorized for conditional use prior to implementation of the final disposition providing the following conditions are met:
o The nonconforming document describes the conditional use.
o 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.
Hard copy nonconformance documents are forwarded to the SONGS CDM for retention and electronic records are maintained in two or more separate remote locations.
@6 17.2-43 Amendment 18 CN-41
17.2.15.2.2 Contractor and Supplier Activities Nonconformances in onsite contractor work are controlled by SCE W
ccordance with Paragraph 17.2.15.2.1.
18 conformances dispositioned accept-as-is or repair by offsite 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 described in Subsection 17.2.16.
6 17.2-44 Amendment 18
17.2.16 CORRECTIVE ACTION 17.2.16.1 Scope
- s subsection describes the measures utilized by SCE to 4sure 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 condition, corrective action to resolve problem, and the rective action to prevent recurrence as appropriate to 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, 4
17.2-45 Amendment 17
17.2.16.2 (continued) the cause of the conditions and the corrective action taken
' prevent recurrence are identified by the responsible organi ion and reported to cognizant levels of management for view 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 patible with the SCE Quality Assurance Program. These systems are periodically audited by the SCE Nuclear Oversight Division
- determine effectiveness of implementation.
'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.
4 17.2-46 Amendment 17
17.2.17 OUALITY ASSURANCE RECORDS 17.2.17.1 Scope subsection describes the measures utilized by SCE to assure t 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).
Additional controls related to quality assurance records, including CN-41 retention requirements, are described in Subsection 17.2.20.5 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.
lity assurance records to be stored and maintained include, are not limited to, the following:
o Records required by the station Technical Specifications, Licensee Controlled Specifications, CN-41 and/or the Quality Assurance Program 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
@6 17.2-47 Amendment 13 CN-41
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
' ignated organization personnel.
Access control is audited by Nuclear Oversight Division. Access to and retrieval of 113 lity 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, and the Quality Assurance Program. The review, identification, indexing, CN-41 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 temperature and humidity.
@6 17.2-48 Amendment 13 CN-41
17.2.18 AUDITS 17.2.18.1 Scope subsection describes the measures utilized by SCE to rify 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).
Additional controls related to CN-41 audits are described in Subsection 17.2.20.
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 Nuclear Oversight personnel trained in audit ICN-41 techniques, or other SCE engineers or inspectors as designated by the Manager of Nuclear Oversight. Individuals performing 13 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.
Nuclear Oversight Supervisors are responsible for 13 uring that sufficient audits are performed in those areas ere 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
@6 17.2-49 Amendment 13 CN-41
17.2.18.2 (Continued)
Group's review of actions employed by the On-Site Review ittee provides a continuing surveillance of station vities. The work and documents of the On-Site Review 0mmittee (OSRC) and Nuclear Safety Group, as described in CN-41 Subsection 17.2.20 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 results of the audits are evaluated by SCE Nuclear 17 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.
117 its are scheduled based upon the status of work progress, ortance 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.
6 17.2-50 Amendment 17 CN-41
17.2.18.2 (Continued)
Regardless of the results of the evaluation, the suppliers orming continuing work are subjected to an initial audit are reaudited every three years. Audits of suppliers forming 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.
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 W vices, on a regular basis. These reports indicate quality nds and the effectiveness of the SCE Quality Assurance ogram. 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 QUALITY ASSURANCE PROGRAM FOR FIRE PROTECTION PROGAM The Quality Assurance Program for the fire protection program ing the operational phase is designed to conform with icable requirements of Branch Technical Position APCSB 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 Managers are responsible for review, ICN-41 inspection, surveillance and audit of the Quality Assurance Program provisions.
17 9
Manager Nuclear Engineering Design is responsible for fire 117 Stection program engineering and design performed by SCE and for review of these activities when performed by contractors.
The Purchasing Agent is responsible for procurement of ICN-41 fire protection program materials, equipment, and services when purchased by SCE.
The Nuclear Construction Manager is responsible for managing the 17 installation and testing of the fire protection techniques during construction.
17.2.19.2 Ouality 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 17 planning of Quality Assurance Program activities.
@6 17.2-52 Amendment 17 CN-41
17.2.19.2 (Continued)
Activities affecting the fire protection program shall be trolled by written procedures, prepared by participating nizations, that delineate the responsibilities and required Oaions 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 personnel responsible for fire protection and modification activities shall include familiarization with the location, use and application of CN-41 fire fighting equipment and maintenance and inspection requirements for fire protection systems.
Similar training will be provided to contractors during modification activities.
Managerment 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 117 provisions of subsection 17.2.3 and this paragraph. These measures will provide a defense-in-depth to assure that design Wvisions are developed and reviewed to prevent or mitigate sequences of a postulated fire as it may affect the formance 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 6
17.2-53 Amendment 17 CN-41
17.2.19.4 (Continued) services contain applicable regulatory requirements, design e
losure documentation, source inspection and audit provisions, s and standards compliance, quality verification document Wmittal 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.
.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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17.2-54 Amendment 17
17.2.19.7 (Continued)
Documentary evidence will be provided, where feasible, to ntify the specific requirements, such as codes, standards or
- cifications met by the purchased material and equipment.
Testing and inspection at the Station combined with certified 17 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.
17 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
- Stion, including maintenance and periodic retesting of ipment, shall rest with the Vice President, Nuclear 17 1neration.
The responsibility for implementation of test controls during 17 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.
- 94 17.2-55 Amendment 17
17.2.19.10 Control of Measuring and Test Equipment Calibration and control of measuring and test equipment for protection equipment shall be in accordance with the isions 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 Ouality Assurance Records Records which are sufficient to furnish evidence that the requirements of this Program are being met, shall be prepared and 6
ntained in accordance with subsection 17.2.17 and this IV graph.
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.
9 17.2-56 Amendment 6
17.2.20 ADMINISTRATIVE CONTROLS 17.2.20.1 Independent Safety Engineering Group (ISEG)
.20.1.1 Function The ISEG shall function to examine plant operating characteristics, NRC issuances, industry advisories, Licensee Event Reports and other sources of plant design and operating experience information which may indicate areas for improving plant safety.
17.2.20.1.2 Composition The ISEG shall be composed of at least five dedicated full-time engineers.
Each shall have a Bachelor's Degree in Engineering or Physical Science or equivalent and at least two years professional level experience in his field. Off duty qualified Shift Technical Advisors may be used to fulfill this requirement.
17.2.20.1.3 Responsibilities CN-41 The ISEG shall be responsible for maintaining surveillance of plant activities to provide independent verification(
that these activities are performed correctly and that human errors are reduced as much as practical.
17.2.20.1.4 Authority ISEG shall make detailed recommendation for revised
- cedures, equipment modifications, maintenance activities, operations activities or other means of improving plant safety to Nuclear Organization management.
17.2.20.1.5 Records Records of activities performed by the ISEG shall be prepared, maintained, and forwarded each calendar month to Nuclear Organization management.
Not responsible for sign-off function.
6 17.2-57 CN-41
17.2.20.2 Review and Audit 17.2.20.2.1 On-site Review Committee (OSRC) 912.20.2.2 Function The Onsite Review Committee shall function to advise the Vice President, Nuclear Generation on all matters related to nuclear safety.
17.2.20.2.3 Composition The Onsite Review Committee shall be composed of the:
Chairman:
Vice President, Nuclear Generation CN-42 Member:
Manager, Operations Member:
Manager, Technical Member:
Plant Superintendent SONGS Units 1, 2, & 3 Member:
Supervisor, Plant Maintenance Instrumentation ICN-42 Member:
Manager, Health Physics Member:
Manager, Chemistry Member:
Manager, Maintenance Member:
Manager, Nuclear Systems Engineering Member:
Manager, Electrical Systems Engineering Member:
Manager, Power Generation Member:
San Diegl 1 as & Electric Representative, Senior Engineer B.S. degree in Engineering or Physical Science plus at least four year professional level experience in his field. At least one of the four years experience shall be nuclear power plant experience.
17.2.20.2.4 Alternates All alternate members shall be appointed in writing by the OSRC Chairman to serve on a temporary basis; however, no more than two alternates shall participate as voting members in OSRC activities at any one time.
17.2.20.2.5 Meeting frequency The OSRC shall meet at least once per calendar month and as convened by the OSRC Chairman or his designated alternate.
17.2.20.2.6 Quorum The minimum quorum of the OSRC necessary for the performance of the OSRC responsibility and authority provisions of these requirements shall consist of the Chairman or his designated alternate and four members including alternates.
@196 17.2-58 CN-42
17.2.20.2.7 Responsibilities The Onsite Review Committee shall be responsible for:
- a.
Investigation of all violations of the Technical Specifications or Licensee Controlled Specifications ICN-42 including the preparation and forwarding of reports covering evaluation and recommendations to prevent recurrence to the Nuclear Safety Group (NSG).
- b.
Review of all Reportable Events.
- c.
Review of unit operations to detect potential nuclear safety hazards.
- d.
Performance of special reviews, investigations or analyses and reports thereon as requested by the Vice President, Nuclear Generation or the NSG.
- e.
Review and documentation of judgment concerning prolonged operation in bypass, channel trip, and/or repair of defective protection channels of process variables placed in bypass since the last OSRC meeting.
17.2.20.2.8 Authority The Onsite Review Committee (OSRC) shall:
- a.
Render determinations in writing with regard to whether or not items considered under item a) of responsibilities above constitute unreviewed safety questions.
- b.
Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Vice President, Engineering & Technical Services and the NSG Supervisor of disagreement between the OSRC and the Vice President, Nuclear Generation; the Vice President, Engineering & Technical Services shall have responsibility for resolution of such disagreements.
17.2.20.2.9 Records The Onsite Review Committee shall maintain written minutes of each OSRC meeting that, at a minimum, document the results of all OSRC activities performed under the responsibility and authority provisions of these requirements. Copies shall be provided to the Nuclear Safety Group.
@96 17.2-59 CN-42
17.2.20.3 Technical Review and Control 17.2.20.3.1 Activities The Vice President, Nuclear Generation shall assure that each procedure and program which affect nuclear safety, and changes thereto, is prepared by a qualified individual/
organization. Each such procedure, and changes thereto, shall be reviewed by an individual/group other than the individual/group which prepared the procedure, or changes thereto, but who may be from the same organization as the individual/group which prepared the procedure, or changes thereto.
- b.
Proposed changes to the Appendix "A" Technical Specifications or the Licensees Controlled Specifications (LCS) shall be prepared by a qualified individual/
organization.
The preparation of each proposed Technical Specifications or LCS change shall be reviewed by an individual/group other than the individual/group which prepared the proposed change, but who may be from the same organization as the individual/group which prepared the proposed change.
Proposed changes to the Technical Specifications and the LCS shall be approved by the Vice President, Nuclear Generation.
CN-41
- c.
Proposed modifications to unit nuclear safety-related structures, systems and components shall be designed by a qualified individual/organization. Each such modification shall be reviewed by an individual/group other than the individual/group which designed the modification, but who may be from the same organization as the individual/group which designed the modification. Proposed modifications to nuclear safety-related structures, systems and components shall be approved prior to implementation by the Vice President, Nuclear Generation or by the Manager, Technical as previously designated by the Vice President, Nuclear Generation. Minor configuration changes which do not involve a change to the design bases of a structure, system, or component, do not require approval by the Vice President, Nuclear Generation or the responsible technical manager.
- d.
Individuals responsible for reviews performed in accordance with the requirements specified above shall be members of the nuclear division management staff, previously designated by the Vice President, Nuclear Generation to perform such reviews.
Each such review shall include a determination of whether or not additional, cross disciplinary, review is necessary.
If deemed necessary, such review shall be performed by the appropriate designated review personnel.
@6 17.2-60 CN-41
17.2.20.3.1 (continued)
- e.
Proposed tests and experiments which affect station nuclear safety and are not addressed in the UFSAR, Technical Specifications, or the LCS shall be reviewed by the Vice President, Nuclear Generation, or members of the nuclear division management staff, as previously designated by the Vice President, Nuclear Generation.
- f.
The Site Security Plan shall be reviewed at least once per 12 months. Recommended changes to the Site Security Plan shall be approved by the Vice President, Nuclear Generation and transmitted to the NSG Supervisor; implementing procedures shall be prepared and approved in accordance with the Licensee Controlled Specifications.
- g.
The Site Emergency Plan shall be reviewed at least once per 12 months.
Recommended changes shall be approved by the Vice President, Nuclear Generation and transmitted to'the NSG Supervisor; implementing procedures shall be prepared and approved in accordance with the Licensee Controlled Specifications.
CN-41
- h.
The Vice President, Nuclear Generation shall assure the performance of a review by a qualified individual/
organization of every unplanned release of radioactive material to the environs including the preparation and forwarding of reports covering evaluation, recommendations and disposition of the corrective action to prevent recurrence to the NSG Supervisor.
The Vice President, Nuclear Generation shall assure the performance of a review by a qualified individual/
organization of changes to the Process Control Program, Offsite Dose Calculation Manual, and radwaste treatment systems in accordance with Licensee Controlled Specifications.
- j.
Documentation of each of the activities performed under Subsection 17.2.20.3 shall be maintained in accordance with Subsection 17.2.20.5.
- 6 17.2-61 CN-41
17.2.20.4 Nuclear Safety Group (NSG) 17.2.20.4.1 Function O
Nuclear Safety Group shall function to provide independent iew and audit of designated activities in the areas of:
- a.
nuclear power plant operations
- b.
nuclear engineering
- c.
chemistry and radiochemistry
- d.
metallurgy
- e.
instrumentation and control
- f.
radiological safety
- g.
mechanical and electrical engineering CN-41
- h.
quality assurance practices 17.2.20.4.2 Composition NSG shall consist of a Supervisor and at least three staff specialists. The Supervisor shall have a Bachelor's Degree in Engineering or Physical Science and a minimum of six years of professional level managerial experience in the power field.
,Wh staff specialist shall have a Bachelor's Degree in ineering or Physical Science and a minimum of five years of fessional level experience in the field of his specialty.
The NSG shall use specialists from other technical organizations to augment its expertise in the disciplines noted above. Such specialists shall meet the same qualification requirements as the NSG members. Consultants shall be utilized as determined by the NSG Supervisor to provide expert advice to the NSG.
17.2.20.4.3 Review The NSG shall review:
- a.
The safety evaluations for 1) changes to procedures or systems and 2) tests or experiments completed under the provision of Section 50.59, 10CFR, to verify that such actions did not constitute an unreviewed safety question.
6 17.2-62 CN-41
17.2.20.4.3 (continued)
- b.
Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in Section 50.59, 10CFR
- c.
Proposed tests or experiments which involve an unreviewed safety question as defined in Section 50.59, 10CFR.
- d.
Proposed changes to Technical Specifications, LCS, or Operating License.
- e.
Violations of codes, regulations, orders, Technical Specifications, license requirements, or of internal procedures or instructions having nuclear safety significance.
- f.
Significant operating abnormalities or deviations from normal and expected performance of unit equipment that affect nuclear safety.
- g.
All Reportable Events.
CN-41
- h.
All recognized indications of an unanticipated deficiency in some aspect of design or operation of structures, systems, or components that could affect nuclear safety.
I.
Reports and meetings minutes of the Onsite Review 17.2.20.4.4 Audits Audits of unit activities shall be performed under the cognizance of the NSG. These audits shall encompass:
- a.
The conformance of unit operation to provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months.
- b.
The performance, training and qualifications of the entire unit staff at least once per 12 months.
- c.
The results of actions taken to correct deficiencies occurring in plant equipment, structures, systems, or method of operation that affect nuclear safety at least once every 6 months.
- d.
The performance of activities required by the Quality Assurance Program to meet the criteria of 10CFR 50, Appendix B, at least once per 24 months.
17.2-63 CN-41
17.2.20.4.4 (continued)
- e.
Any other area of unit operation considered appropriate by the Nuclear Safety Group or Vice President, Nuclear
- f.
The Fire Protection Program and implementing procedures at least once per 24 months.
- g.
An independent fire protection and loss prevention inspection and audit shall be performed annually utilizing either qualified offsite licensee personnel or an outside fire protection firm.
- h.
An inspection and audit of the fire protection and loss prevention program shall be performed by an outside qualified fire consultant at intervals no greater than 3 years.
17.2.20.4.5 Authority The NSG shall report to and advise the Nuclear Organization management of the results of their reviews.
17.2.20.4.6 Records Records of NSG activities shall be prepared and maintained in CN-41 accordance with Subsection 17.2.6 and Subsection 17.2.20.
Report of reviews and audits shall be distributed monthly to the Vice Wident, Nuclear Generation and to the management positions onsible for the areas audited.
17.2.20.5 Record Retention In addition to the applicable record retention requirements of Title 10, Code of Federal Regulations, the following records shall be retained for at least the minimum period indicated.
17.2.20.5.1 The following records shall be retained for at least five years:
- a.
Records and logs of unit operation covering time interval at each power level.
- b.
Records and logs of principal maintenance activities, inspections, repair and replacement of principal items of equipment related to nuclear safety.
- c. All Reportable Events submitted to the commission.
- d.
Records of surveillance activities; inspection and calibrations required by the Technical Specifications.
17.2-64 CN-41
17.2.20.5.1 (continued)
- e. Records of changes made to procedures required by the Technical Specifications and Licensee Controlled Specification.
- f. Records of radioactive shipments.
- g. Records of sealed source and fission detector leak tests and results.
- h. Records of annual physical inventory of all sealed source material of record.
17.2.20.5.2 The following records shall be retained for the duration of the Unit Operating License:
- a. Records and drawing changes reflecting unit design modifications made to systems and equipment described in the Updated Final Safety Analysis Report (UFSAR).
- b. Records of new and irradiated fuel inventory, fuel transfers and assembly burnup histories.
- c. Records of radiation exposure for all individuals entering radiation control areas.
- d. Records of gaseous and liquid radioactive material released to the environs.
- e. Records of transient or operational cycles for those unit components identified in Table 3.9-1 of the UFSAR.
- f. Records of reactor tests and experiments.
- g. Records of training and qualification for current members of the unit staff.
- h. Records of in-service inspections performed as required by Licensee Controlled Specifications.
ICN-42 I. Records of quality assurance activities (not included in the five year retention list above) that are required by the Quality Assurance Program.
- j.
Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10CFR 50.59.
96 17.2-65 CN-42
17.2.20.5.2 (continued)
- k. Records of meetings of the OSRC and the NSG.
- 1. Records of the service lives of all snubbers, including the date at which the service life commences and associated installation and maintenance records within CN-42 the scope of Licensee Controlled Specification 3.7.108.1.
- m. Records of secondary water sampling and water quality.
- n. Records of reviews performed for changes made to the Offsite Dose Calculation Manual (ODCM) and the Process Control Program (PCP).
96 17.2-66 CN-42
SCE UAL
'AW BLE 17.2-1 SCE QUALIT URANCE PROGRAM COMPLIANCE TO UIDES, 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 Criteria Complies 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 Endorses ANSI N45.2.4 Requirements for the Installation, Inspection, an 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)
NOTE:
Clarification (Revision 2, 2/78) for compliance with ANSI Ni 8.7 is provided in a letter from the NRC, dated Feb. 22, 18 1996
SUBJECT:
Proposed Revision to SONGS 2 &3 Quality Assurance Program Regulatory Guide 1.37 - Quality Assurance Endorses ANSI N45.2.1 Requirements for Cleaning of Fluid Systems and Cmle Associated Corn onents of Water-Cooled Nuclear Power Plants (3/6/73)
=9 Regulatory Guide 1.38 - Quality Assurance Complies Endorses ANSI N45.2.2 0
Requirements for Packaging, Shipping, Receiving, Storage, and Handling of tems for Water-Cooled rD Nuclear Power Plants (Revision 2, 5/77)
Cpe 0,
bl 17.2-1 (Continued)*
Guide, Requirement, or Standard copliance 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 N101.4 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 and Complies Content of Safety Analysis Reports for Nuclear Power Plants (Revision 2, 9/75)
O Regulatory Guides 1.74 - Quality Assurance Terms Complies Endorses ANSI N45.2.10 and Definitions (2/74)
Regulatory Guide 1.88 - Collection, Storage, and Complies Endorses ANSI N45.2.9 Maintenance of Nuclear Power Plant Records (Revision 2, 10/76)
CD CD
able 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 Quality Complies Endorses ANSI N45.2.12 Assurance Programs for Nuclear Power Plants (Revision 1, 9/80)
Complies Endorses ANSI N45.2.23 Regulatory Guide 1.146 - Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants (8/80)
Complies if invoked Regulatory Guide 4.15 - Quality Assurance for by facility operating 6
Radiological Monitoring Programs (Normal license Operation) -
Effluent Streams and the Environment (Revision 1, 2/79)
CL 9~
BLE 17.2-2 SOUTHERN FORNIA EDISON COMPANY QUALITY ASSURANCE PROGRAM IMPLEMENTING PROCEDURES 10CFRSO Appendix B Criteria Implementing Procedure Documents 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Summary Quality Assurance Organization Quality Assurance Manual x x x x x x x x x x
x x x x a
x x
x Quality Assurance manuals (applicable project) describe the SCE Quality Assurance program policies Quality Assurance x x x x x x x
x a
x x
x x
x for all IOCFR5O, Appendix 1l7 Procedures 8, criteria and provide appropriate general implementation procedures.
The Quality Assurance CN-41 procedures provides specific implementation required by the Quality Assurance Organization to implement 10CFRO, Appendix B, criteria.
Nuclear Generation Site Department Station Orders, Procedures, and x a x x x x X a
a ax x p
x x
x x
Station orders, procedures Operating Instructions and operating instructions contain implementation procedures for OCFR5O, Appendix B, criteria.
Engineering & Technical Services Department Quality Assurance x x x x x x x x x x
x x
x x
x x
x x
Emphasis of Department Procedures procedures is on ICN-41 preparation and control of drawings, specifications, and procurement ICN-41 acti viti en.
Procurement and Material Management Quality Assurance Reference x
x x x x a x x
Emphasis of Department Procedures Manual Procedures is on control of purchase orders, contracts and vendor proposals and documentation.
CD CL CD C-)
prcdre-o 1CR0 Apedx
,citra
able 17.2-2 (Continued)
.10CFR50 Appendix er ia Implementinq Procedure Documents 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Summary Shop Services & Instrumentation 116 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 16 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.
I rD CL
=4q I-.
TABLE 17.2-3 NUCLEAR OVERSIGHT DIVISION ACTIVITIES OPERATION following are SCE Nuclear Oversight Division personnel 17 vities 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 CN-41 and instructions prepared by other internal organizations as described in Subsection 17.2.5.
- 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.
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.
17.2-72 Amendment 17 CN-41