ML17193B346

Responds to 810403 Request for Addl Copies of Revised Pages to Topical Rept CE-1-A,Revision 16,re QA Program

ML17193B346
Person / Time
Site:	Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle
Issue date:	04/22/1981
From:	Tramm T COMMONWEALTH EDISON CO.
To:	Haass W Office of Nuclear Reactor Regulation
References
NUDOCS 8104270143
Download: ML17193B346 (18)

Text

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89

___ Commcinweallh Edison One First National Plaza: Chicago, Illinois Address Reply to: Post Office Box 767 Chicago, Illinois 60690 April 22, 1981 Mr. W. P. Haass, Chief Quality Assurance Branch - DPM U. S. Nuclear Regulatory Commission Washington, D. C.

20555

Subject:

Commonwealth Edison Company Quality Assurance Program Topical Report CE-1-A Revision NRG Dkts. 50-10, 50-237; 50-249, 50-254, 50-265, 50-295, 50-304, 50*-373, 50-374,. 50-454, 50-455' 50-456 and 50-457 As requested in your letter of April 3, 1981, attached are thirty-six (36) copies of the following listed revised pages to the subject Topical Report numbered ~E-1-A, Revision 16.

Pages:

Cover sheet, title page, Abstract, 2*2, 4-2, 4-5, 7-2, 18-2 Attachments Very truly yours,

YP f ~-.. -<

£. T. R. Tramm o' :Nuclear Licensing Administrator Pressurized Water Reactors Qoo3 s

CE-1-A T()pical Report Revision 16 QUALITY ASSURANCE PROGRAM FOR NUCLEAR GENERATING STATIONS Commonwealth Edison Company

CE-1-A Topical Report January 1976 Rev. 16 - 3/16/81 C 0 M M 0 N W E A L T H E D I S 0 N C 0 M P A N Y QUALITY ASSURANCE PROGRAM FOR NUCLEAR GENERATING STATIONS COMMONWEALTH EDISON COMPANY Post Office Box 767 Chicago, Illinois 60690 Commonwealth Edison

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UNITED ST ATES NUCLEAR REGULATORY COMMISSION WASHINGTON. D. C. 20555 Mr. T. R. Tranm

• Nuclear Licensing Administrator Press uri Zed Water Reactors Conmonwea 1th Edi son Company P.0. Box 767 Chicago, IL 60690

Dear Mr. Tramm:

APR 0 3 1981

SUBJECT:

NRC ACCEPTANCE OF REVISIONS TO QA TOPICAL REPORT We have completed our review of Revision 16 dated :vlarch 16, 1981 to the Commonwealth Edi son Company (CE Co) Topi cal Report No. CE-1-A, II Commonwea 1th Edison Com.pany Qua 1 i ty Assurance Program for Nuclear Generating Stations." This revision concerns minor programmatic changes.

You indicated in your transmittal letter that the topical re-port and this revision ar~ tntended to be applicable to n~cle~r units identified by Dccket Numbers 50-10, 50-237, 50-249, 50-254, 50-265, 50-295, 50-304, 50-373,. 50-374, 50-45~, 50~455~ 50~456, and 50-457.

Based on our evaluation of the proposed changes described in Revision 16,.we find that your revised topical report continues to meet the criteri.a of Appendix.8 to 10 CFR Part 50 and is th~refore acceptable with the exception of certairi potential changes currently under evaluation as noted below.

To use the topical report in future license appliCations.., CECo.need only reference this topical report in Section 17 of the Safety Analysis Report.

We do not intend to repeat our revie\\'1 of this topical report when it is ref~renced in ~n application ~nless changes occur in our acceptance criteria.

Should re.gulatory criteria or regulations change such that*our conclusions about this topical report are invalidated, we will notify you.

You will be given the opportunity to revise and resubmit it should you so desfre.

As noted above, should you desire to reference this topical report in support of quality assurance programs for new nuclear power projects, the basis of our evaluation will be the acceptance criteria included in the latest revision to SRP Sections 17.1 and 17.2 (currently Revision 1).

Appropriate changes may, therefore, be necessary.

Progranmatic changes by CECo to this topical report are to be submitted to the NRC for review prior to implementation.

Organizational changes are to be subm.itted no later than 30 days after announcement.

As a result of the TMI-2 accident, please note that staff re-evaluation of the quality assurance p.rogram for Zion Units 1 and 2 in accordance with an action plan for plants located at relatively high population density sites may result in future changes to this topical report.

Therefore, staff approval of Revision 16 is contin-gent upon the final resolution of.this separate review activity.

Mr. T. APR 0 3 1981 Please replace our letter of February 2, 1981 with this letter, renumber the report as CE-1-A, Revision 16, and submit 36 copies to the NRC.

Your transmittal letter should identify the nuclear units to which this revised topical will apply.

Should you have any questions regarding our review or if we can provide assistance, please feel free to contact.me or Mr. William Belke at (301) 492-7741.

Sincerely,

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Walter P. Haass, Chief Quality Assurance Branch Division of Engineering

LISTL.~G CO~...RING REVISION OF TOPICAL REPORT CE-1 Listed below is Revision 16 dated 3/16/81*to the Commonweal thEdison Company Quality Assurance Program Topical Report CE-1:

Pages:

Abstract 2-2 4-2, 4-5 7-2 18-2

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Approved* By: d/>~<V¥t~f'?~.

Manager of Quality Ass'urance 3/16/81

LISTING COVERING REVISION OF TOPICAL ~ORT CE-1 Listed below is Revision 15 dated 1/2/81 to the Commonwealth Edison Company Quality Assurance Program Topical Report CE-1:

Pages:

1-2, 1-4, 15-, 1-7, 1-8, 1-10, 1-11, 1-12, 1-13, 1-14, 1-15, 1-17, 1-18, 1-19, 1-22, 1-23, 1-26, 1-27, 1-18, 1-29, 1-33, 1-34, 1-36 2-1, 2-5, 2-6.

3-1, 3-2, 3-3, 3-4 4-1, 4-4 5-2 6-2, 6-3.

7-2, 7-3, 7-4, 7-5 9-1, 9-3 10-1,* 10-2

.11-1, 11-2, 11-3, 11-4 12-2 13-2 15-1, 15.;. 3 16-2, 16-3 17-2 18-1, 18-2, 18-3 Approved 5y:~~~a-n*tL

~~of Quality Assurance 1/2/81

Commonwealth*Edison Company Chicago, Illinois Topical Report CE-1-A January 1976

• Commonweal th Edison Company Quality Assurance Program for Nuclear Generating Stations ABSTRACT Commonweal th Edison's Quality A.ssurance Program which delineates the mandatory requirements a.pd procedilres that :nust be implemented and enforced in conn.action with its nuc.lear generating stations is described in *this report.

The report is divided into 18 sections*, coniorming in for.nat to the 18 Criteria listed in AppendiX B to

. __ 10CFR50., This document presents the Quali ty-*As*surance

• Program to be employed in the design, procurement,. construction, modification, maintenance,** in-service inspection and operating of satety-related systems,. structures and components of the station.. The exec\\,ltion ot the Quality Assurance Program.

Will assure Commonwealth Edison Company that the plant is built and operated to. requirements and with. the *reliabili.ty necessary to sateguard the general public and Company employees*

Overall responsibility :for.the Quality Assurance Program covering the design, construction and operation of the Company's nuclear generating stations is ass.i.gned to the Vice Chairman and authority and responsibility for directing I 16 and administering the Program is assigned to the t'lanager-of Quality.Assurance by the Chairman and President.of Commonwealth Edison Company.

The scope o! this Report covers the total Quality Assurance Program for the lite o! Commonwea1th Edison Company nuclear generating plants commencing with the LaSalle County Station and for the operation period o! Dresden.

Quad Cities and Zion plants.

Rev. 16 3/16/81 Commonwealth Edison

CONTENTS INTRODUCTION

1.

ORGANIZATION A.

Basic Organization Responsibilities B.. Organizational Responsibilities for Major Activities

2.

QUALITY ASSURANCE PROGRAJ.'1

3.

DESIGN CONTROL

4.

PROCUREMENT DOCUMENT CONTROL

5.

INSTRUCTIONS, PROCEDURES AND DRAWINGS

6.

DOCUMENT CONTROL 7.. CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES

8.

IDENTIFICATION AND CONTROL OF MATERIALS, PARTS AND COMPONENTS

9.

CONTROL OF.SPECIAL PROCESSES

10.

INSPECT I ON.

11.

TE.5T.CONTROL

• 12.. CONTROL OF. MEASURING AND TEST EQUIPMENT

~

1-1 1-1 1-1 1-3 2-1 3-1 4-1 5-1 6-1 7-1 8-1 9-1 10-1 11-1 12-1

13.

HANDLING, STORAGE AND SHIPPING 13-1

14.

INSPECTION, TEST AND OPERATL~G STATUS 14-1

15.

NONCOW'ORMING MATERIALS, PARTS OR COMPONE.~TS AND 15-1 OPERATIONS

16.

CORP.ECTIV'E ACTION 16-1

17.

QUALITY ASSURANCE RECORDS 17-1

18.

AUDITS 18-1 Rev.9 7/16/79 Commonwealth Edison

2..

QUALITY ASSURANCE PROGRAM

2. 1 General.*

The Commonwealth Edison Company has extensive experience with the development, scheduling, Q.esign, constI""'.ic-tion and operation of electric generating facilities. It has pioneered in commercial nuclear power.

Commonwealth Edison

. Company and its consultants and vendors have established designs and specifications for compliance with applicable regulations, ASME Code and National Standards to assure installations. of utmost stiety and reliability.

Commonwealth Edison Company has attained qualified equipment. vendors and contractors through experience, evaluation at vendor plants and site surveillance during plant erection.

These efforts provide assurance that compliance with applicable.

15 design specifications and codes*is-maintained and a high level of reliability is achieved.

2.2 Policy:_

It is the policy of Commonweal th* Edison Co_mpany to assure a high degree of functional integrity of the equipment, structures and safety-related systems of its nuclear generating facilities, the performance of which are essential to the prevention of nuclear accidents that could cause undue risk to the health and safety of the public, or to the mitigation of the consequences of such accidents in the unlikely event they should occur.

These 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 Ill and XI, as referenced in the SAR applicable to a specific unit at the time of engineering., construction and maj9r modific~tions.

Appendix B to 10CFR50, and the mandatory requi.remen~s o:t:_

ANSI N45.2 and N18.7 Standards.

Also, Commonwealth 2-1 Rev. 15 1/2/81 CommonweaJth Ediso11

e Edison commits to comply with 10CFR Part 21 - "Reporting of Detects and Noncompliance" and with. the Regulatory position o! the following Regulatory Guides. and the require-ments o! the following ANSI Standards:

1.a, Rev. 1-R; 1.28, Rev. 2; 1.30, 8-11-72.;* 1.33, Rev. 2; 1.37, 3~16-73; 1.38, Rev. 2; 1.39, Rev. 2; 1.58, Rev. 1; 1.64, Rev. 2; 1.74, 2-74; 1.88, Rev. 2; 1.94, Rev. 1; 1.116, Rev. 0-R; 1.123, Rev. 1; *1.146, 8-80; 1.144, Rev.1. f16 Exceptions or alternatives to this Topical Report for specific 1

plants identified in the Safety Analysis Report or Technical 16 Specification will take precedence over commitments in this I

Topical Report.

It is also the policy of Commonwealtll Edison Company to assure a high degree of functional integrity for its generating facilities so as to achieve high availability of these facilities !or the production o! electrical power and to maintain.overall quality levels which will achieve the foregoing in a.safe, effective.and economic manner.

The Quality Requirements and. Quality Procedures of the Company Quality Assurance Program Manual (see Appendix A

!or Program Manual Index) as described herein, document the 'Written policies and procedures of* the Program and are augmented by other written Department.and Station procedures and instructions:.

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 criteria for nuclear

.power plants o! Appendix B to 10CFR50 "Quality Assurance Criteria !or Nucl~ar Power Plants," and the mandatory requirements of ANSI*N45.2, "Quality Assurance Program Requirements for Nuclear Power Plants* and ANSI N18. 7,.

"Standards for Administrative Control for Nuclear Power Piants. 1i 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 QuaJ.tty.Assurance programs will include the applicable portions o! the Code, Standards and Appendix ~- as they affect the total program.

The overall Commonwealth Edison Company quality assurance program, as a minimum, provides !or* engineering design control, audit and surYeillance o! on-site contractors and. off-site vendors, surveillance and audit of the performance and-quality assurance procedures of the Arehitect Eng-ineer and CECo Engineering, 2-2 Rev. 16 3/16/81 Commonwe_-,,n Edison

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4.

PROCUREMENT DOCUMENT CONTROL

• The procurement documents include equipment specifi-cations or specifications. for* services,_ *each of which are reviewed or evaluated as. described in Sec~ion 3 for design and construction, and design and construction formodi.fications.

Changes to procu:ement 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 for-NSSS items and by Edison and the Architect Engineer for non-NSSS items to insure that all requirements

• have been incorporated specifically or by reference.

Records pertaining to the review and evaluation of procurement documents involving i.ni tial plant installations and plant modifications will include, *in whole or* in part, minutes of meetings, comment letters, design review records, project* quality assurance audits and.a copy of the original design. document marked with comments or latest revisions.

These records will be kept* in vendor files and/or applicable.

Commo~wealth Edison Company department files during the Engineering, Construction and Operation phases of the generating station.-"*= ".

r 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 for suit-ability of application of standard "off-the-shelf" commercial or previously approved materials, parts and equipment that are safety-related will be imposed on vendors.

Where 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 de~ign requirements. Similarly, the required methods 0£ identi£1cation, preservation and packaging, and methods 0£ controlling conformance to acceptance criteria are covered by these documents.

Quality Assurance Program requirements are included in initial procurement contract and reviewed for acceptability by Quality Assurance to provide for implementation 0£ the approved ;quality assurance program, vendor evaluation, inspection and test planning, v~ndor surveillance, witnessing of inspection control points and 15 4-1 Rev. 15 1/2/81 C.:lrnmonwealth Edison

.~

inspection *um~ntation. Also, requi~nts for vendor documents, such as instruction, procedures, drawings, suecifications and vendor quality assurance records to be prepared, submitted or made available for review or approval are included.

In addition, included in the procurement documents are provisions for right-of-access to vendors' facilities and work documents for inspeci:ion and audit and for vendor reporting and disposition of nonconformance from procurement requirements.

Basic procurement control is by CECo with procurement of major equipment *and items being purchased by the General Oi'f ice Purchasing Department and procurement of standard type materials and items beL~g performed by its satellite purchasing organization at certain-sites.

For procure!Ilents initiated by Project Eng~neering.or the Station Nuclear Engineering Department, i:he ProJect Engineer, prior to submittal of the Engineering Proposal Request ~o the Edison General Purchasing Agent, prepares a suggested list of prospective bidders for each specification ~rom the ~pproved Bidders' List and using input from the Architect Engineer and the cognizant Purchasing Department Buyer.

This.Bidders Lis~ is

~

established using such factors as past experience, experience 01 other utilities, or specific qualification s~--reys (either desk or field surveys are used).

For Code w9rk, the desk survey shall be limited to determination that a supplier or contractor is the holder of a valid Certificate of Authorization.for the scope of work involved or for determining if a supplier or contractor is potentially qualified..The final list of prospective bidders as well as the person agreeing to,the list are indicated on the Nuclear Proposal Request (NUPR) Form and is approved by the Project Silgineering Manager or the Station Nuclear :£ngineering Manager after plant start-up for modif ica-tions or designated alternates.

The persons agreeing. to the list are-key representatives of Project *tngineering and Project Construction or the Station Nuclear Engineeripg and Station

• Construction Departments after plant start-up for modifica-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 Ap'Proved Bidders' List maintained by the Purchasing De"9artment, such bids shall be indicated as trial bids and treated as trial until the bidders are evaluated and approved as acceptable prior to award.

Upon completion of the evaluation of the proposals from approved bidders !or either original plant or plant modifi-cation items or services, the responsible Project Engineer shall have prepared and, ai'ter 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. 16 3/16/81 Commonwealth Edison 16

that the items are ordered from the original equipment supplier or an evaluated and approved alt~rnate supplier.

The bid package and the resulting contracts or purchase order will clearly reference applicable revision dates of appropriate drawings and specifications for the item or service being procured.

Appropriate revisions of ANSI, *ASME or other applicable codes and/ or standards will b~ considered a part of the design requirements and be r~ferenced in the bid package, contract or purchase order.

The bid package and resulting contract or purchase order will contain the reauirements for inspection, testing and inspection documentation.

Commonwealth Edison Company, its contractors, subcontractors and vendors will be responsible for their respective programs by which an approp-riate review and audit will determine that the requirements of this Section have been met.

Procurement documents will identify which records indic.ative o_f quality will be transmitted to Commomveal th Edison and the method of.dispositioning those which.. the vendor retains.

The bid package and resulting contract or purchase

• order will contain., as applicable, the requirement for the contractor to have and implement a quality assurance program

. which has been approved.by CECo for purchased safety-related and ASME Code materials, equipment and services to an extent consistent.with their importance to.safety and will state the

• e:*ontrols which will eXist between. the purchaser and* :'selle*r. ~i*n.

requesting and accepting changes lli"'lder the purchase order or contract.

Also, revisions to such quality assurance programs shall be submitted to CECo for review and acceptance during the term of the contract or order.

Procurement of spare parts or replacement items will be subject to controls at least equivalent to those*used for the original equipment.

4-5 Rev. 16 3/16/81 16 16 Commonweaith Edl!!On

7.

7.1. General v

CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES*

The control of the quality of purchased material, equipment and services is achieved ~'lrough the evaluation of vendors, surveillance of their operations and required source

. inspection, documentation, receiving inspection and retention of quality records.

Both Edison and the NSSS Supplier have direct ~rocurement functions for the Station.

The Architect Engineer offers recommendations to Edison on vendor selection and reviews vendor efforts as directed by Edison.

Edison will inspect and audit the NSSS Supplier control of purchased material, equipment and services.

Edison has the responsibility fo~ on-site control of Edison and the NSSS Supplier purchased material, equipment and services.

Contractors and suppliers furnishing.material,

• equipment and services to CECo for items within the jurisdiction of ~s Quality. Assurance Program will be selected on the basis of demonstrated capability to provide.

a product, process-- or service, in**accordance *with the*_*

• design specifications and contract *provisions.

The purpose of this Section is to define the quality system elements and related;policies which assure the quality of purchased ~terial, equipment and services through the evaluation of vendors, surveillance of.their operations, required source inspection, documentation, receiving inspection and retention of quality records.

As applicable, the Project Engineering :Project Engineer_ j 14*

or* the Station.Nuclear Engineering Department Project Engineer

,.. in conjunction with Quality Assurance will require a Quality Assurance Program in accordance with ANSI N45.2 or ASME Boiler and Pressure Code Section III from vendors or contractors

• consistent with the importance of the. proc~ement to station safety and operation and the requirements of ASME Section III and 10CFR50 *Appendix B.

In addii;ion, Edison's procurement

• documents will provide noti..fication to vendors and contractors that the provisions of 10CFR Part 21 apply.

7-1 Rev. 14 9/9/80 C.ommonwea!th Zdison

Control and approval of subcontractors quality assur-ance programs, procedures and personnel qualification, are the responsibility of the.speci.fic contractor involved.

Such contractor actions are to oe documented and will be subject to audit 'uy CECo.

7.2 Evaluation of Vendors An evaluation of vendor capability will be required for ASr1E Section III and sa.fety-related items.

Where valid records of vendor capability and quality performance are not available to CZCo, a survey of the supplier's facilities, capa-bilities and quality assurance system will be ~ade by CECo or its designated representative.

?or items requiring ASHE Code conformance, vendors :nust be able to meet ASaE Code requil"ements.

The Project Engineering and Station Nuclear Engineering Department Quality Assurance Coordinator will ::ie responsible for assuring that vendor or contractor Quality Assurance Program evaluations are carried out.

The Purchasing Department will

~aintain the Approved Bidders' List for contractors and suppliers of ASME and safety-related items.

AdC.ition of vendors to the Approved Bidders'* List shall only be made upon approval by Station Nuclear Engineering l:!aJ1ager and* the Hanager of Quali 7.y Assurance, or their*designees, as to meeting technical and quality assurance requirements.

For vendors or contractors to be placed on the Company Approved Bidders' List for ASME or safety-related items or work, a controlled copy of their Quality Assurance Program shall be as~igned to the CECo Nanager of,Quality *Assurance *

. Section 9.0 of this report, 11C6ntrol of Special Processes," establishes the evaluation and assessment of certain process and inspection capabilities o~ the vendor such as welding, heat treatment, and nondestructive. examination.

Past performance of a contractor/vendor will be considered during procurement activities by CECo.

Prior to contract or purchase order award, the bidder's capability and quality perfor-.

mance will be reviewed relative to the product, process, or service :16 being procured. If records are inadequate, a survey of the bidder's' facilities prior to award may be required.

Such SUI"'Teys will include, as applicable, review of.facilities, organization, quality assurance program and experience, existing controls, knowledge of special processes, possession of a current ASI*'!E Certificate of Authorization, and an understanding of, and a willingness to meet contractor or purchase order requirements.

7.3 Surveillance of.Vendor Operations*

Source.surveillance will pe carried out through.notifi-cation points established as a condition of procurement of sa.fety-related or AS~!E Section III items.

Special consideration will be given for surveillance during manu.facture when one of the following is involved:

7-2 Rev. 16 3/16/81 Commonwealth Edison

.Y *

18.

AUDITS

• Audits will be performed by Commonwealth Edison Company and/or its contractors, subcontractors and vendors to verify the implementation and effectivet:.ess of quality programs under their cognizance.

The number and experience of persons partic.ipating in audits will vary according to the nature and significance of the audit.*

• Audi ts under the responsibility of the r1anager of Quality Assurance will cover quality systems for engineering, construction, modifications, maintenance,*.

in-service inspection and Stores activities*.

Audi ts will be performed to evaluate the implementation of the quality assurance programs and the adherence-to procedures and controls.

Certifications and records will also be evaluated *

. Product audits assess the effectiveness of inspections and tests that are specific to the fabrication, installation,

.construction, testing and operation of an item..

The performance and c*ompliance of each operating station to the Quality Assurance Program is assured through

• review surveillance and audi-t-~of. -,operations by* the***-Qual~ ty --

Assurance Engineer or Inspector w*ho is responsible to* the Director of Quality Assurance (Operating) and through review, surveillance and audit of maintenance, modi-ficati*ons, Stores

• activities and in-service inspection by the Quality Assurance.

Engineer or Inspector (i1aintenance) who is responsible to the Supervisor Quality Assurance (Haintena...-1ce).

Audits will be conducted using checklists or an agenda approved by responsible Quality Assurance.

Department personnel and will be conducted to evaluate compliance with all aspects of the Quality Assurance Program.

Audits will be initiated early to assure effective quality assurance during* design, procurement, manufacturing, construction and installation, inspection and test and be performed efficiently in order to achieve a minimum* of interference with work in progress and minimum 18-1 R.ev. 15 1/2/81 Commonwe<alth Edison 15

• e disruption of organiza~ions being audited.

An audit plan will be mainta~ned in order to schedule audits of site contractors.

Audits of off-site contractors generally will oe conducted in conjunction with plant visits for witnessing inspection points oy a qualified auditor.

Also, periodicaJ.J.y 1~uali ty Assurance will participate in such audits or perform independent audits to assure effectiveness of the program, compliance to the program and fu.l.fillmen"t of procure-ment requirements.

The elements in the quality program, in procure-ment documents and in related codes and sta~dards, are subject to systems audits.

Also, items received, fabricated

. and constructed or installed for use by Commonwealth Edison

• Company in its nuclear power plants are subject to audits.

Audits will be perfor:ned selectively at various stages of contracts on a varying frequency, based on the nature and safety significance of the work being done to verify compli-ance and determine the effectiveness of procedures, inspections, tests, process* controls and. documentation.

For Code materials, when a ~*1ateriaJ. Manu£acturer or Material Supplier, as applicable, does not hold a Quality System Certifica.te 0-1Iaterials), the CECo audit frequency shall be at least once an.'1.ually during the interval in which CECo purchased material is being controlled oy the Material Manui'acturer or Material Supplier.

In addition to these audits, Quality.Assurance wilLcon_duct. approximately annually, overall system audits-of the NSSS vendor, the Archi-

. tect Engineer," site contractors, and involYed Edison Deoartments.

16 Audi ts of CECo. are also performed by the Authorized Inspec*tion Agency as required by the ANSI N626 series o.f Standards.

For operating s*ta.tions, periodic Quality As.surance Department audits will be performed to verify compl~ance*with, and the effectiveness of the program.

Audits covering operating will 'be performed in accordance with tb.e Tecanical Specifica-tions under the direction and responsibility of the Director of Quality Assurance (Operating) independent of the Production Department.

Surveillance, in-service inspection a.."'ld Stores activities will be performed under the direction and responsi-bility of the Quality Assurance Supervisor (Maintenance).

Audit results and recommendations of corrective action will be documented and revi.ewed with the management of the Station.

Verification of the completion of corrective action recommended in audit reports will be performed by the Technical Staff Super-visor or Quality Control Supervisor. *Follow-up of open station items is tracked by the Action Item Record's (AIR) System.

Approval as to satisfactory completion of corrective action shall be obtained from the responsible station Quality Assurance Engineer or Inspector.

18-2 Rev. 16 3/16/81 Commonwealth Edison