ML17193A520
| ML17193A520 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 11/04/1980 |
| From: | Belke W Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17193A517 | List: |
| References | |
| NUDOCS 8011070204 | |
| Download: ML17193A520 (24) | |
Text
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- In the Matter of UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD COMMONWEALTH EDISON COMPANY Docket Nos. 50-237 50-249 (Dresden Station, Units 2 and 3)
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(Spent Fuel Pool Modification)
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SUPPLEMENTAL TESTIMONY OF WILLIAM L. BELKE ON CONTENTIONS 2 and 3 I am employed as a Quality Engineer in the Ouality Assurance Branch, Divi-sion of Engineering, Office of Nuclear Reactor Regulation, U. S. Nuclear Regulatory Commission. A statement of my professional qualifications is attached to this testimony.
Contention 2 states as follows:
. The Application does not show that the quality control and quality assurance programs of Applicant and its contractors are-adequate to assure that tube and rack construction and the boron-10 loading of the Boral in the tubes will meet specifications. (cont. 26 and 27; Am. Cont. J).
RESPONSE
The proposed facility modifications to increase the capacity of the spent fuel storage pool at Dresden Nuclear Power Station, Units 1 & 2, are to be perfonned in accordance with the Conmonwealth Edison Company (CECo) Topical Report No. CE-1.-A, 11Corrunonwealth Edison Company Quality Assurance Program for Nuclear Generating Stations," and the May 11, 1978 license modification application as supplemented.
The CECo Topical Report contains a corrmi'bnent whereby CECo and 8011070~'1
- their individual contractors are required to have a quality assurance program for quality-related activities affecting safety-related items during maintenance, modifications and operations activities. Appendix E, Exhibit 2.6, Appendix A of the Dresden FSAR (Enclosure 1) identifies the sp~nt fuel pool, spent fuel storage facilities and storage equipment (inclusive of tubes and racks) as part of a Class I system which requires the highest degree of control and assurance that all the requirements of the specifications have been met and properly documented.
Consequently, to assure the highest degree of. quality assurance and quality control, tube and rack construction and the boron-10 loading of the boral in the tubes will be subject to the commitments in the CECo Quality Assurance Program which satisfies the requirements of Appendix B to 10 CFR Part 50 and the applicable codes and specifications.
Therefore, the modification, consisting of engineering, material purchase, fabrication and installation, is to be controlled by the Dresden Nuclear Power Station QA implementing procedures that are fonnulated based on the commitments contained in the CECo Topical Report. Section 2, pages 2-2 and 2-3 and Section 4, pages 4-1, 4-2 and 4-3 (Enclosure 2) of the CECo Quality Assurance Program identify and include.controls for verifying contractor quality-related activities to assure conformance to procurement document _require-
. ments including perfonnance and quality-related functions, review of contractor quality control procedures, preparing checklists for witnessing inspection notification points at vendor facilities, inspection and designation of status of incoming material, reviewing inspection procedures and monitoring site con-tractor quality control activities.
- The Convnonwealth Edison Quality Assurance Program (Revision 14), as applicable to the Dresden Nuclear Power Station, has been reviewed and found acceptable by the NRC staff on October 1, 1980.
Region III of the NRC Office of Inspection and Enforcement (OIE) has found that the program has been satisfactorily imple-mented at the Dresden Nuclear Power Station. It is the Region lII position that adherence to the requfrements of the CECo Quality Assurance Program should result in the _acceptable fabrication and installation of the fuel storage racks.
To verify compliance with the CECo QA Program, Region III inspectors will, inspect the spent fuel pool modification activities on a sampling basis in accordance with existing NRC inspection requirements. These include verification of the following:
- 1.
Procurement review to detennine that purchased material meets the require-ments specified by CECo;
- 2. Preparation, review a".'d approval of procedures governing alr activities to be performed during the modification program.
- 3. Receipt and storage inspections of purchased material to determine that CECo has perfonned the required inspection.of purchased material and that requirements for storage of material are being met.,
- 4. Installation inspection to confirm that the following are in conformance with design requirements:
- a. dimensions
- b.
- field welds
- c. qualification of welders and procedures
- d.
removal of old racks
- e. rack alignment
- f. seismic restraint
- g.
rack fasteners
- h.
corrosion test specimen installation in spent fuel pool
- i. special requirements such as drilling vent holes to prevent swelling j.. final clearance check using dummy fuel element or other go/no-go gage
- 5. Inspection of spent fuel storage racks and fuel to determine:
- a. cleanliness
- b.
obvious defects
- c. identification
- d. appearance and size of welds
- e. technical specifications are being met
- f. fuel storage in acccrdcmce with requfrements 6.. Implementation of admJnistrative controls governing:
- a. control of heavy loads over pool
- b. schedule for examination of specimen
- c.
procedure for periodically checking for swelling and other degradation
- 7. Observation of work in progress to determine:
- a. proper location and orientation
- b.
placement *o.f seismic restraints
- c.
procedural verification
- d.
QC coverage
- 8.
Review* of records:
- a.
receiving inspection
- b.
shop fabrication records*
- c. material certification
- d.
installation records
- e. nonconformance reports
- f.
QA audits Additionally, Region III, OIE, will inspect on a sampling basis other corranitments made by CECo in its spent fuel pool modification application. Through these inspections, Region III will verify that the racks are suitable for service or take necessary measures to prohibit their use until adequate corrective action demonstrates their suitability.
Contention 3 states as follows:
The Application does not demonstrate that rack and tube packaging, transpor-tation, and receipt inspections are adequate to prevent and detect transportation damage.
{Cont. 26 and 27; Arn. Cont. J).
RESPONSE
Section 1; pages 1-2 and 1-3 and Section 2, pages 2-1 and 2-6 {Enclosure 3) of the NRC approved Conmonwealth Edison Company {CECo} Topical Report No. CE-l~A, (Revision 14} "Commonwealth Edison Company Quality Assurance Program for Nuclear Generating Stations," contain a conmitment whereby systems, com_ponents and struc-tures as referenced in the specific section of the applicable unit's SAR will be identified,.-Oesigned, fabricated, erected, tested, and operated in accordance with the CECo Quality Assurance Program which satisfies the requirements of Appendix B to 10 CFR Part 50, and applicable portions of the ASME Code and ANSI Standards.
Appendix E, Exhibit 2.6, Appendix' A of the Dresden SAR (Enclosure 1) contains the listing of those items to which the CECo Quality Assurance Program applies.
Included in this listing are the-spent fuel pool, spent yuel storage facilities, and storage equipment which includes the spent fuel storage racks and tube assemblies. These items, therefore, are subject to the CECo Quality Assurance Program to assure that all the requireinents of the specifications *have been met and properly documented. Quality requirements for rack*and tube packaging, transportation, and receipt inspections will be controlled and performed in accordance with the conmitments contained in the CECo Topical Report CE-1-A, the applicable regulatory guides and ANSI Standards (e.g., Regulatory Guide 1.38 which endorse*s ANSI N45.2.2, "Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Pl ants," and implemented through the Station Procedures Manual and instructions. Region III of the NRC Office of Inspection and Enforcemer.t has found that the program has been satisfactorily implemented at the Dresden Nuclear Power Station. It is the Region III position that adherence to the requirements of the CECo Quality Assurance Program should result in acceptable rack and tube packaging, transportation, and receipt
. inspection to prevent and detect transportation damage in accordance.with the implementing procedures.
To verify compliance wit~ the CECo Quality Assurance Program, Region III inspectors will inspect the rack and tube packaging on a samp!ing basis to show that CECo Quality.Assurance Pr_ogramcommitments are met.
D.
Definitions Prime Contractor
- contractor Subcontractor Class I Material Class II Material Class III Material EXlilBIT 2.6 General Electric Canpany Enclosure l Page l The organization contracted to construct the reactor plant. either an Architect EnQ1neer or EnQineer Constructor.
An orqanization contracted to the contractor for a portion of the work.*
Equipment. material, systems and structures which can have a first order effect on nuclear safety.
Equi~ent, material, systems and structures which do not directly affect nuclear safety.
but are significant for continuous olant ooeration.
All equi~~nt, systems. material or structures not included in* Class I or Class,II.
Nuclear Power Plant The total olant, includinQ the Reactor BldQ.,
Turbine BldQ ** Radwaste and all auxiliaries.
All Non-nestructive TestinQ includinQ, but NOT not limited to, Radioqraohy, Maqnetic Particle.
Lfauid Penetrant, Ultr~sonic.
E.
ListfnQ of Equipment~ Systems by Class An effective and economical Duality Control Plan aoplies various de-qrees of insoection, co~trol and documentation ranainq frc>m constant s~rve111ance and inspection si~n-offs to a minimum of surveillance based on a samplinQ plan. The deqree of control required is directly related to the critical nature of the system or equitrnent. In order to place the highest degree of control in the proper areas, the systems and structures have been divided into three basic classes as follows:
Class *I Equipment, material, systems and structures, which can have a first order effect on nu~lear safety~
E.2.6-7
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Class II.
Class III EXHIBIT 2.6 Page 2
. Thfs is the most critical class which
.reQuires the highes.t de~ree of control and assurance that all the reauirements
- of the specifications have been met and properly documented.
Equipnent, material, systems and structures whf ch do not directly affect nuclear safety, but are significant for continuous olant operation. Class II systems and material also reauire assurance that the plans and specifications have been met and documented, however, the deQree of control and sur-veillance required for Class II is not as s tri nQent as Cl ass I
- All equipment, systems, material or structures not included in Class I or Class II *. It is intended that good construction workmanshio and control practices be followed ~or*all Class
- I II sys teris.
This manual addresses itself to.Class I and Class II systems and eauipment only and is not intended to acnly to Class III. The list-inCJ. of Class I an~ Class II systems aooears in Section I ~ E. This is a general list and it.is not tailored to an individual nroject.
Detailed lists whfc~ apply to each individual project will be furnish-ed at a later date as Appendix ~ B C or D.
The special demands of SJ?ecfffcations. and Procedures for installation are responsive to the classification of eauipnent and ~vstems by class.
Similarly; demands for deQree of auality assurance will be responsive to this classification.
The q~ality control effort apolied to Class I eauioment and systems shall *be such that there is a high degree of assurance that the re-ouirements of aovernin~ soecificatfons and codes have been met
- E.2.6-8
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EXHIBIT 2.6 CLASS I - NUCLEAR SAFETY
- 1... Nuclear Steam Suoply Systems Page 3 a) b)
Reactor Vessel includina all internals not listed below Reactor Vessel Supports c) d)
e) f)
g) h)
i) j)
Control Rods and Orive System Control Rod Hydraulic System Control Rod Orive Thimble Sur>ports Fuel Elements Core Shroud Core Supports and Upper Core Grind Steam Separator Steam Dryer k)
- 1)
Recirculating Piping System including Valvel and P1111ps All piping connections from reactor vessel up to and including the first isolation valve external to the drywell - (includes a11 Denetrations) m)
Isolation Valves.**
n)
Temporary Control Curtains o)
Primary System Relief Valves p)
Primary System Safety Valves
- 2.
Reactor Emergency Systems a) Isolation Condenser System
- b)
Standby Liauid Control System c)
Core SDray System d)
Low Pressure Coolant Injection System e)
Reactpr Building Closed Lonn Cooling Systen E.2.6-9
EXHIBIT 2.6 e
e
. f)
Contaimient Spray System
- g)
High-Pressu.re Coolant Injection System Page 4 3.. Fuel Storaqe Fac111ties - to include soent fuel and new fuel storage eQuipment.
- 4.
Emergency Electrical Power and Instrunent Control Air Systems
- 5.
a)
Stat;on Battery (125 volt D. C. System) b)
Standby Generator System b.1 Diesel - Generator b.2 Gas Turbine Generator c)
Auxi.11 a ry Power Stat; on d)
Instrunent Control Air System*
InstrLITlentation and Controls a)
Manual Reactor Control System b)
cl Neutron Monitor System d)
In-Core Neutron Monitor System e)
Fuel Rupture Detection System
. f)
Control Rod Instrunentation g)
Reactor Level Instrumentation h)
Recirculation Control Instrt111entation i)
Feeclwater Control Valves and Instrunentation j)
Standby Lfqufd Control System InstrL1T1entatfon k)
Area Monftorf ng System
- 1)
Control Rod PositJnnfn~ System
- 6.
Critical.Structures a)
Drywell, Vents, Torus and Penetrations b)
- Reactor Bufldin!l c)
Control Room E.2. 6-10.
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d) e)
-'ltlla:irt1*RYY YI-IV Spen,,uel Pool Ventilation Stack
- 7.
Radiation Shielding
- 8.
Control Rod Worth Minimizer System a)
Control and Display Panel b)
Input Buffer Page 5 c)
Digital Conputer and Peripheral Equipment
- 9.
Primary Containnent Inerting System
- 10.
Reactor BuildinQ Nonnal Ventilation System
- 11.
Fuel Storage Pool Filtering and Coolinq System
- 12.
Turbine Bldq. Secondary Coo11nq Water System
- 13.
Condenser Hot Well and All *P1p1nq and Equipment i'l tti.e Condensate and. Feed Return to the Pressure Vessel~ !nclud1n~:
a)
Condensate Pumps b)
Condensate Transfer Punps c)
Air Ejectors and Condensers d)
Gland Stearn Exhauster e)
Condensate Dan1nera11zers f)
Condensate Booster Pumos.
g)
F. W. Heater$
h)
Reactor. Feed Pumps
- 14.
Condensate Storage Tank E.2.6-11
- 1 DRESDEN II &c Ill e CLASS I - NUCLEAR SAFETY
- 1.
. Nuclear Steam SUpply Systems Enclosure l Page 6 a)
Reactor Vessel including all internals not listed below b)
Reactor Vessel Supports c)
Control Rods and Drive System d)
Control Rod Hydra~ic System e)
Fuel Elements f)
Core Shroud g)
Core Supports and Upper Core Grid h)
Steam Separator i)
Steam Dryer j) *Recirculating Piping System including Valves and Pumps k)
All piping connections from reactor vessel up to and
. including the first isolation valve external to the dry-well - (includes all penetrations)
- 1)
Isolation Valves m) Temporary Control Curtains n)
Primary System Relief Valves o)
Primary System Safety Valves
- 2.
Rea.ct or Emergency Systems a)
Isolation Condenser System b)
Standby.Liquid Control System c)
Core Spray System d)
Low Presalire Coolant Injection Syatem APPENDIX A E.2.6-56 I
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y e)
Reactor Building Closed Loop Cooling System
!)
Standby Oas Treatment System g)
Service *Water Bay h)
Containment Spray System g)
High-Pressure Coolant Injection System
- 3.
,Spent Fuel Storage Facilities - Storage Equipment Page 7
- 4.
Emergency Electrical Power and Instrument Control Air Systems a)
Station Battery (125 volt D. C. System) b)
Standby Generator System
- b. 1)
Diesel... Generator ba 2)
Gecria1lsifte Geaep;itgr (_
c)
Auxiliary Power Station d)
Instrument Control Air S.ys~em
- 5.
Instrumentation a.nd Controls a>
Manual Reactor Control System b)
Neutron ~onitor System d). In-Core Neutron.Monitor System
,e)
Fuel Rupture Detection System
!)
Control Rod Instr\\:unentation g)
Reactor Level Instrumentation h)
Recirculation Control Iilstrumentation i)
Feedwater Control Valves and Instrumentation j). Standby Liquid Control System Instrumentation k)
- Area Monitoring System
- 1)
Control Rod Posit,ioning System_
AP?:t:?\\DIX A E.2.6-57
y EXHIBIT *2. 6 e
- 6.
Critical Structures a)
Drywell, Vents, Torus and Penetrations b)
Reactor Building c)
Control Room d)
Spent Fuel Pool e)
Ventilation Stack
- 7.
Radiation Shielding
- 8.
Control Rod Worth Minimizer System a)
Control and Display Panel b)
Input Buller c) *Digital Computer and Peripheral Equipment
- 9.
Primary Containment Inertin.g System Page 8
- 10.
~
Portions of Service Water System used for Reactor Safety System
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APP C:NDIX /\\
E.2.6-58
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Page 1 The quality assurance programs of Commonwealth Edison Company, Architect Engineers and Nuclear Steam Supply System vendors include the requirements of ASME Section III Article NCA-4000, the quality assurance ~riteria for nuclear power plants of Appendix B to 10CFR50 "Quality Assuran~e Criteria !or Nuclear Power Plants,* and the mandatory requirements.of ANSI N45.2, "Quality Assurance Program Requirements !or Nuclear Power Plants* and ANSI N1B.7,
- Standards for Administrative Control for Nuclear Power Plants." The requirements are implemented by means of detailed quality procedures delineating the specific methodology to be used.
In addition, individual contractor's, fabricator's and vendor's Quality Assurance programs will include the applicable portions of the Code, Standards and Appendix B as they fd!ect the total program. *The overall Commonwe~th Edison Company quality assurance.program, as a m1n;mum, provides for engineering design control, audit and surveillance o! on-site contractors and off-site vendors,
. surveillance and audit of the performance and quality assurance procedures o! the Architect Engiheer;and CECo Engineering, 2-2
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Rev. 14 9/9/SD
- Commonwealth Edison
nit ~'tJT"'e' ~
Ihu"chasing and ConsFection Groups and ~or plant operations Page 2 quality assurance p 8.I:ls covering plant maitAlance, repairs, operations, in-servi e inspections and modi~ic1!ions. For operating stations, the Corporate Quality Assurance Program activities also are covered by written policies, programs, procedures and.instructions included in the Station Proce-
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2-3 Rev.a 6/21/79 Commonwealth Edison I.
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- 4.
PROCUREMENT DOCUMENT CONTROL Page 3 The procurement documents include equipment speci!i-ca tions or service speci!ications, each of which are reviewed or evaluated as described in Section 3 !or design and construction, and design and construction !or modi!ications.
Changes to procurement documents are subject to the same review and approval requirements as the original documents.
Contract or purchase order documents are reviewed by the NSSS Supplier :!9r NSSS items and by Edison and the Architect Engineer !or non-NSSS items to insure that all requirements have been incorporated specifically or by re!erence.
Records pertaining to the review and evaluation o!
procurement documents involving initial plant installations and plant modi!ications will include, in whole or in part,
.minutes o! meetings, comment letters, design review records, project quality assurance audits and a copy of tha original design document marked with comments or latest revisions.
These records will be kept in vendor !iles and/or applicable
.Commonwealth Edison Company department !iles during the Engineering, Construction and Operation phases o! the generating station.
The*quality requirements for each item or service to be procured will be clearly stated in the bid package,
- contracts and purchase orders. Also, the review !or suit-ability of application o! standard "o!!-the-shel!" commercial or previously approved materials, parts and equipment that are safety-related will be imposed on*vendors *. Whero material, equipment, systems or services require contractors to adhere to ASME Code requirements or have ASME Certificates of Authorization, these requirements will be contained in.the procurement documents.
Quality Assurance Program require-ments are included as are regulatory, code, standard and design requirements. Similarly, the required methods o!
identification, preservation and packaging, and methods of controlling conformance to acceptance criteria are covered by these documents.*. Quality Assurance Program requirements are included in initial procurement contract and reviewed
!or acceptability. by Quality Assurance to provide for implementation of the.approved quality assurance program, vendor evaluati.on, inspection and test planning, vendor surveillance, w1 tnessing ot--inspection control point~ and 4-1 Commonwealth Edison
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tr0tnmem.!', '!OC!t _1f!' ~Tlstru~ntm, ~~~l!'tJT'!~, llrawlngs, Enc lo sure ~
, specifications and vendor quality assuranc~ecords to be Page 4 prepared, subm1t19 or made available for *iew or approval are included.
In addition, included in the procurement documents are provisions !or right-of-access to vendors*
facilities and work documents !or inspection*and audit and
!or vendor reporting and disposition of nonconformance from procurement* requirements.
"Basic procurement control is by*CEX:o with procurement of major equipment and items being purchased by the General O!f ice Purchasing Department and procurement of standard type materials and items being.performed by its satellite purchasing organization at certain sites.
For procurement~ initiated by.Project Engineering or 114 the Station Nuclear Engineering Department, the Project Engineer, prior to submittal of the Engineering Proposal Request to the Edison.
General Purchasing Agent, prepares a suggested list*of prospective bidders for each specification !rom the Approved Bidders' List and using input from the Architect Engineer and the
-" *cognizant Purchasing Department Buyer.
This list is established
- using such !actors as past experience, experience of other utilities, or specific qualification surveys (either desk or
!ield surveys are used).
For Code work, the deSk survey shall be limited tp determination that a supplier or contractor is the holder of a**va11d Certificate of Authorization !or the scope o! work invo~ved or !or determining i! a supplier or contractor is potentia1ly qualified.
The !inal zist of prospective bidders ~s well as the person agreeing.to the list are indicated on the Nuclear Proposal Request (NUPR) Form and is approved by the Project Engineering Manager or the Station Nuclear Engineering Manager after plant start-up for modifica-tion~ or designated alternates.
The per~ons agreeing to the list are key repre~entatives of Project Engineering and Project
- construction or the.Station-Nuclear Engineering and Station Construction Departments after plant start~up !or modif ica-tions, Production Department, Purchasing Department and, when.
requested, *the Architect Engineer. Where bids *are obtained from
- prospective bidders from other than those listed on the Approved Bidders' List maintained by the Purchasing Department, such bids shall be indicated as trial bids and treated as trial.
until the bidders are evaluated and approved as acceptable prior to award.
14 :
Upon completion of the evaluation of the proposals.
from approved bidders for -either original plant or plant modifi-cation items or services, the responsible Project Engineer shall 114 have prepared and, after final review and approval indication by the Quality Assurance Coordinator, shall have transmitted to the Purchasing.Department a letter of recommendation and a purchase requisition... The purchase
- 4-2.
Rev. 14 9/9/80 Commonwealth EdlM>n
requisition and/or letter will incorporate,.by reference,
~'r'Tc.ro'.hrl~"'
- those documents s* as specifications, dra'W!Wlgs, proposals, Page 5 supplementary pro'9!;als, etc., and any condlll.ons of award which form the basis for the evaluation and.award.
Edison Purchasing, based on the recomme~dation 1etter, its own evaluation-and the purchase requisition, shall conduct necessary negotiations and clar~!ications and make tbe*award to a bidder on the Approved Bidders* List.
Any changes evo1ving..trom the procurement-activities involving technica1-or quality assurance*
matters, *either for the original purchase or subsequent change orders, shall. be approved by the originator *o.t the purchase or change order req~sition.
The Project Engineering Manager or the Station Nuclear 14 Engineering M~ager after plant start-up w~~ _assi~ ~u!hori~y
!or evaluation o~ the vendor quality assurance-program, prior to
- final* award of*the contract or purchase order, to the responsible Project Engineer who wi11 be assisted in such evaluation by the Director of Quality Assurance (Engineering-Construction).
and the Architect Engineer.* Quality Assurance evaluates all such vendor quality assurance programs.
The Quality Assurance
- Coordiriator assigned to the Station Nuclear Engineering Depart-,
ment is responsible for assur~g that the evaluation is carried out and !or auditing the manuals of bidders being recommended as acceptable for award as to resolution of comments received by Engineering !rom Quality Assurance _and others plus evaluation
. by Engineering.
As part of the vendor quality assurance *program evaluation, the Quality Assurance** Coordinator will assure all.
vendor quality assurance program deficiencies are r~solved.
Concurrence by Quality Assurance shall be required. If the
- vendor program de~iciencies are minor and/or may be corrected by specific procedures !or the work to be done, the resolution may !o~low an award and shall be a conditiQn of the award
- 4-3 114 Rev. :14 Commo~vC~/ttiC\\:crason
Page 1 The Commonweal th Edison Company Qual.1 ty Assurance *. * **
Program includes the qua11ty assurance requirements for operating nuclear power stations. The Program covering operations shall..
comply with the 18 Criteria o! the "Quality Assurance Criteria for Nuclear Power Plants" of Appendix B to 10CFR50 for main-tenance, modification and refueling activities and with Criteria 1, 2, 5, 6, 10, 11, 12, 14, 15, 16, 17 and 18 for operating actiYi ties.* As supplementary Criteria to the 18 Criteria
- described above for Appendix B to 10CFRSO, the Program also*.
complies With Regul.atory Guide 1.33 "Quality Assurance Program Requirements (Operations) n as an. a.cceptable method of complying Commonwealth Edison
v nt?Tosure J, 'P!~e t with the Comm.1ssion4t regulations with regardta overall quality assurance program reqUirements.
The Program shall apply to the quality assurance activities affecting the *safety-related structures, systems and. components.* The Program*is applicable to the maintenance, mod.U'ication, operat1ng and_:refueling qua11ty assurance activities fram the time the Operating License is issued to the end of the operating life of the items. Repairs are performed as maintenance activities and alterations as modifications.
The Program covering 9perations, including quality control, are planned and implemented in accordance
- ** with procedures necessary to provide Commonweal th Edison Company adequate confidence that a safety-related stnicture, system or component performs satisfactorily in service..
1-3 Rev. 2
. 10/25/77_
CommonweaHh Edison
y
- 2.
QUALITY ASSURANCE PROGRAM
- 2. 1 General Page 3 The Commonwealth Edison Company has extensive experience with the development, scheduling, design, construc-tion and operation of electric generating facilities. It bas
- pioneered in commercial nuclear power.
Commonweal th Edison Company and its consultants and vendors have established designs and specifications !or compliance with applicable regulations, ASME Code and National Standards to assure installations of utmost sa.i'ety and reliability.
Commonwealth Edison Company has attained qualified equipment vendors and contractors through experience,.evaluation
- at vendor plants and site surveillance durillg plant erection.
These efforts add assurance that compliance with applicable design specifications and codes is maintained and a high level... of reliabil:i ty is achieved.
~.
. 2.2 Policy
... *'It is the policy*of*commonwealth.Edison Company to assure.a high degree of.tunctional integrity o! the equipment, structures and aa.!ety-related systems of its nuclear generating facill ties,. the performance of which are essential to the prevention of nuclear accidents that coul.d cause undue risk to the health and safety o!. the public, or to the m.1 tigation of the consequences of such accidents in the *.
un11kely event they should occur *. ~ese systems, equipment, and structures will be identified, designed, fabricated, erected, tested and operated *:to the criteria and requirements
- of ASME Boiler and Pressure Vessel Code Sections III and XI, as referenced in the SAR applicable to a specific unit at
- the time of engineeriilg, constrilction and major modifications,
.Appendix B to 10CFR50, and the mandatory requirements of*
ANSI N45.2 and N18. 7 Standards. Also,- CQ.mmonwea1th *
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~---*-- --*-. -*--------* -- ----=---
The Qual1 ty Assurance Pro8'ram applies 1:o adety-related I :
and ASME Section III activities and items and related consumables.
11 The classitication of structures, systems and comJ)onents designated
- as "safety-related" are listed in the respective Safety Analysis L *-
Reports {SAR) of the Stations.
A copy of the SAR or the listing.
(11 will be available in the Operations, Construction, Q\\iality Assur-ance and Engineering areas, as necessary, fo*r reference. Distri-bution of and revisions to this listing is controlled and approved 11 by the Station Nuclear Engineering Department.
The requirements in ASHE Section III, Article NCA-4000 shall be applled to Section III systems and components including concrete containments.
The 18 Criteria of Appendix B o! 10CFR50 will be applied to safety-related systems and components for design, construction, maintenance, re!uelillg, in-service inspection, repair and station modifications. Criteria 1, 2, 5, 6, 10, 11, 12 and 14 to 18 and*Regulatory Guide 1.33 will be applied to operation of safety-related.systems and components.
2-6
. Rev. 11
. 12/21/79 Commonweatth Edison
.PROFESSIONAL QUALIFICATIONS William L. Belke My name is William L. Belke.
I am employed by the U.S. Nuclear Regulatory Ccmnission as a Quality Engineer, Quality Assurance Branch, Division of Engineering, Office of Nuclear Reactor Regulation.
In this position, I. am responsible for the ColllTlission's review and evaluation of the quality assurance programs, as assigned by the Branch Chief, proposed for the design, construction, and operation of nuclear power plants.
I received a diploma from the Academy of Aeronautics (1960), Associate in Science degree from Eastern Connecticut State College (1.972), and a Bachelor of Science degree in Industrial Technology from Central Connecticut State College (1974).
My quality assurance experience includes six years of working for Pratt and Whitney Aircraft as an Aircraft Engine Quality Assurance Assembly and Test Inspector, and 2~ years of working for the Department of the Navy at the Pratt and Whitney facility as a Quality Assurance Specialist.
I joined the Quality Assurance Branch of the Commission in.1974 as a Quality Eng.ineer, my present position. I have participated in five inspection efforts with Region I quality assurance teams at operational plants, and I have performed the review and evaluation. of over 30 quality assurance programs for design and construc-tion and for operations.
Professional Societies Member of Ame~ican Society for Quality Control *
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