ML17194B245
| ML17194B245 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle, 05000000 |
| Issue date: | 06/06/1982 |
| From: | COMMONWEALTH EDISON CO. |
| To: | |
| Shared Package | |
| ML17194B244 | List: |
| References | |
| CE-1-A-ERR-01, CE-1-A-ERR-1, NUDOCS 8208110204 | |
| Download: ML17194B245 (11) | |
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LISTING COVER.ING REVISION OF TOPICAL REPORT CE-l Listed below is Revision 21 dated 6/6/82 to the Commonwealth Edison Company Quality Assurance Program Topical Rep art CE-1:
a2oa110204 *a208.06 PDR ADOCK 05000010 p
PDR Pages:
.Approved 1-3, -1~6, 1-21, 1-23, 1-24, 1-30, 1-31, 1-35, 1-40, 1-42, 3-2, 3-3, 4-3, 5-2, 7-2, 15-2, 15-3, 16-2, 18-2, 18-3
/,~
By: tt/
- Man'7ero uaitjSsurance
.6/6/82
components.
The Program is app ~icable to the maintenance~
- modifica-tion~ operating and refueltng quality assurance activities from 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 operations,
- ~ncluding quality control, are planned and implemented in accordance with procedures necessary to provide Commonwealth Edison Company adequate confidence that a safety-related s~ructure, system or component performs satisfactorily in service.
B. Organizational Respo_nsibilitie s for Maj or Activit:ie s Design Control of design quality is essentially a four-stage process*.
Designs originated by either* the NSSS Supp lier _or Architect Engineer are subjected to internal. rev:iew by the designer and an independent internal party (or parties). The NSSS Supp lier and Architect Engineer designs are evaluated by each other as well as by personnel from one or more Edison departments.
These steps consti-tute the primary design evaluation for all safety-related and ASME Section III items in the Station *.Appropriate: document distribution and control has been established to permit an effective effort in*
this. area.
Comments on designs resulting from these evaluations are presented in letter form~ by telephone (with written follow-up) or in meetings with published minutes.. Edison has final. authority with r~spect to decision making on designs.
Procurement Procurement control and. follow-up for NSSS components is established and maintained by the NSSS Supplier.* Edison and the Architect Engineer evaluate the* NSSS Supplier procurement specifi-cations~ and Edison audits and inspects the NSSS Supp lier control measures.
Procurement of and follow-up oil non-NSSS components and services are directly controlled by Edison, based on the Architect Engineer specifications which have been evaluated by Edison.
The Architect Engineer is used to assist in this effort, as Edison's agent~ as*. requested by Edison.
Construction Construction quali~ assurance is an Edison responsibility.
Edison exercises managerial control of all site construction activi-ties. The-site Quali~ Assurance Group maintains close surveillance of on-site contractor's and other.associated construction quality
. assurance activities.
The NSSS Supp l:fe r furnishes technical and Quality Control assistance for on-site activities relating to the NSSS.
On-site contractors' quality assurance programs are indepen-21 dently evaluated by Edison Quality Assurance.
1-3 Rev. 21 6/6/82 Commonweatth Edieon
e e
Pre-service Testing
.Pre-service testing, consisting of preoperational and start-up testing~ is controlled by Edison.. The Architect Engineer and the
. NSSS Supp lier furnish rough draft test procedures to Edison.
Based o.n these, a final draft is Written by Edison.
This final draft is subjected to internal Edison evaluation and evaluation by the Archi-tect Engineer or the NSSS Supplier as appropriate *. The tests are managed and performed by Edison with technical assistance from the NSSS Supplier as appropriate *. The evaluation of the test results is performed by Edison and confirmed by independent internal Edison evaluations.
Further independent evaluations by the Architect Engineer or the NSSS Supplier are performed as required by Edison.
Operations Commonwealth's managerial and administrative control of the Quality Assurance Program:: for operating nuclear stations, as illus-trated in Figures: 1-0~ 1-1~ and 1-6 includes review and. approval of procedures by the* personnel described in this document.
Qua;I.ity Procedures and. revisions thereto for the Company Manual are concurred. with by the principally involved departments.
The Director of* Quality Assurance (Operating} reporting to the*
Manager of* Quality Assurance, verifies. that. the Quality Procedures.
for* Operating. contained in the Comp*any Manual or Station Quality Proc*edures, comply with the policy* described in this document.
Simi.la-rly~ the, Supervisor. Quality* Assurance* (Maintenance) verifies that the Quality Procedures for maintenance, modifications, in-service "inspection and Stores acti.vities comply.
The Manager of Quality* Assurance directs. the:. quality assurance activities covering operations and approves the Quality* Assurance Procedures covering operating~ maintenance~ modifications' in-service inspection* and Stores activities for use in the Station.
Station Procedures and instructions and revisions thereto for the Station Procedures Manual are reviewed and approved as provided in the Technical Specifications.
The station Quality Assurance Engineer or Inspector reporting to the Director of Quality Assurance (Operating) provides surveillance of the preparation and revision of the station operating procedures and instructions.to assure* compliance with the policies* contained in the Quality Assurance Program.
The Quality Assurance Engineers. or Inspectors for maintenance~ reporting to the Supervisor Quality Assurance (Maintenance)~ provide surveillance of the preparation of procedures and instructions for maintenance, modifications, in-service inspec-tions and Stores *activities to assure compliance with the policy contained in the Quality Assurance Program.
Temporary changes to procedures which do not change the intent of the original procedures, may be made with the concurrence of qualified individuals as 1-4
\\ 15 15 Rev. 15 1/2/81 Commonwealth Edison
described by Technical.Specific~tions. Such temporary changes are subsequently reviewed, approved 'and" authorized.in a manner commen-surate to that used for the original procedure_.
Managerial and Administrative Controls Lines of authority and responsibility for the Quality Assur-ance Program are documented and updated, as appropriate, ip the form of organizational charts, functional descriptions of departmental responsibilities or descriptions of key quality assurance positions including th~se providing technical support or audit responsibility.
In general~ the Quality Assurance Program provides* that an activity is verified as being correctly performed, that Quality Assurance activities are performed independent of the individual or group directly responsible for performing a specific activity, and that. quality assurance functions have sufficient authority and organizational freedom to identify quality problems; to initiate, recommend; or provide solutions; and to verify implementation of the solutions.
The-responsibilities for implementation of the Quality Assurance Program are assigned to the Vice Chairman, Executive Vice Presidents~ Vice President (Engineering), Vice President -* Nuclear 14 Operations~ Manager of Station. Construction, Manager of Projects, Vice President (Purchasing), Vice President.* (Divisions) and Manager _
of Quality Assurance.
The.. organizations or personnel named herein and reporting to the Vice* President* (Engineering-),. Vice President of Nuclear Operations~ Manager of Station Construction, Manager of Projects; the Vice President (Purchasing) and Manager of Quality 14 Assurance may assign t'o other organizations or personnel, the work of establishing and executing any part of* the Quality Assurance Program under their cognizance~ but the assigning organizations* or personnel retain responsibility -for-such assignments.
Figures 1-0, l~l and 1-6 illustrate the functional and administrative responsi-bilities of the major organizations and personnel participating in the Quality Assurance Program for operating nuclear stations.
Dashed lines represent the functional responsibility for establishing and administrating the procedures and instructions.
Solid lines repre-sent responsibility for implementing the procedures and instructions.
Dotted lines represent audit responsibility for verifying compliance with the procedures and instructions independent of the person or group.directly responsible for performing the activities.
The specific *responsibilities for the Quality Assurance Program are described in the following paragraphs..
1.1 General As assigned in the. policy statement for the Corporate Quality Assurance Manual by the Chairman and President, the Vice 1-5 Rev *. 14 9-9-90 Commonweatth.Edison
.e Chairman of Commonwealth Edison Company has overall responsibility for the Quality Assurance Program covering the design, construction and operation. of the Company's nuclear generating stations. Similarly assigned~ authority and responsibility is assigned to the Manager of
.Quality Assurance for quality assurance with respect to design, procurement, construction and operation if the. Company's nuclear power stations.
Further, other.authorities and responsibilities are as delineated in the organization section.
The Executive Vice Presidents, Vice President (Engineering);
Manager of Quality Assurance; Vice President Nuclear Operations; Vice President (Divisions); Manager of Station Construction; Ma~ager of Projects and Vice: President (Purchasing) are responsible for implemen-tation of. the Qtiality Assurance Programs as. described herein..
The Manager of' Projects* directs the design~. construction *and pre-operations operating activities involving the project during the initial design and construction of the nuclear unit or for other.
specially established projects after* the unit has been placed into operation~ The Project Managers*, reporting to the Assistant Manager of Projects and the Manager of. Projects, are* responsible for the Project activities involving project engineering, construction, testing~ and *preoperational and start-up operations..
The Projects Department* Engineeri:ng ~- Construction and Operation groups have line respons-ibility* involving the-projec-t: during. the. initial. design, construction and. preoperational operations.. of the nuclear unit.
The ProJect Engineering,_ Project Construction* and Project* Operation g~oups are formulated~ respectively from the* Station Nuclear* Engi-neering and Station~ Construction Departments and the P-roduction Nuclear.* Division-which have functional responsibility* and control of the car-responding P-rojecta Department organizations.
The Project Operation group for a respective'. unit shall rave~. back: to, the-Production. Nuclear Division when: an operating license becomes effective..
The Project Construction and Proje*ct Engineering groups shall revert back; respectively, into the Station Construction and.
Seation Nuclear Engineering* when. the nuclear unit is. placed into commercial operation.
Also, during* the projectized phase, the appli-cable respective Station Construction Department, Station Nuclear Engineering and P-roduction Nuc*lear Division procedures shall cor-res-pondingly a:pp ly to the Project Construction, Engineering and Opera--
tions-activities as est-ablished by interface procedures or documents between: the* Station Construction and Engineering Departments and the Nuciear Division~ respectively, and the related Project groups.
The-Station Nuclear Engineering Manager, report.ing to the Assistant Vice President responsib!e for Station Nuclear Engineering, Nuclear Licensing and Nuclear Fuel Service~, who in turn, reports to the Vice President (Nuclear Operations), has functional responsibi-lity and control during initial design, construction and startup for the activities involving design,. test procedures, and the baseline 1-6 Rev.21 6/6/82 COmmonwealth Edison
- a.
Implementation of the modification and mainten-ance portion of the Quality Assurance Program.
- b.
The preparation and revision of the Station Procedures for the modification and maintenance.
- c.
The completion of documentation showing that the required inspections and tests were performed for.modification, maintenance and material receipts.
He shall also rev].ew and approve receiving inspection documentation.
d..
The proper and satisfactory completion of modific.ation, maintenance and reported correc-tive action.
He shall also review and approve such completion and corrective action.
- e.
The incorporation of approved engineering changes into maintenance and operating
- procedures.
£:..
Completion of ASME Code requirements.
- g.
In-service* inspection and Stores activities..
h..
Adherence* to Technical Specification require-ments where involved with modification, -main-tenance and in-service. inspection activities.
1.5 Production Department Responsibilities 1.5.l Production - Nuclear Division 1.5.1.l Division Vice President and General Manager, Nuclear Stations The Commonwealth Edison Company production stations are divided into two Production 21 Divisions -' Fossil and Nuclear.
The Division 21 Vice President and General Manager in charge of each D~vision is responsible for the safe and reliabla operation and maintenance of the plant assigned to his division.
1-23 Rev.21 6-6-82 CommonweaHh Edison
The Division Vice President and General 21 Manager, Nuclear Stations reports to the Vice Pres.ident (Nuclear Operations) and has line responsibility for the administration, management and direction of all Production Department activities at operating nuclear stations.
During construction and preop era-tion operating activities,. he has functional responsibility and control of Project opera-tion activities and assumes operating.respon-sibility when an operating license becomes effective.
He is responsible for implementa-tion of the Quality Procedures for the Quality Assurance Program. and for development of Station procedures for the Station P~o~edures Manual.
He: is also responsible for obtaining and authorizing the use of services, or required. liaison or* interface with, other Commonwealth Edison. Company departments such as::
Accounting~ Industrial and Public: Rela-tions; Purchasing*~. Engineering, Construc;.tion,.
Materials.Analysis and Operational Analysis.
He. is. responsible* for approval of requisitions for the: procurement of services from vendors and contractors.
He provides. liaison between.
the* Regional Nuclear Reg_ulat*oi:y Commission's:
Director o:f* the~ Office of.* Inspection and Enforcement and. the' Office of the. Production Department...
He: is: responsible~ through the: Station Superin-tendent~. for the management of each assigned power station... This includes a-11 activities such as~ operation, maintenance and refueling, and authorization of modifications performed at the Station, compliance-with all regulations and licenses, personnel selections, training and -related activities..
He assigns responsi--
bility* for preparation and implementation of the Station Procedures Manual to the Station Superintendent including the Maintenance Procedures.
The Division Vice President and General Manager, Nuclear* Stations coordinates the planning of each assigned station' s activ-21 ities with the activities of other plants on the Commonwealth Edison Company system and with the System Power Supply Manager.
1-24 Rev. 21 6-6-82 Commonweatth Edison
I
,I 16.0 CORRECTIVE ACTION A corrective action system will. be used to assµre that such items as failures, malf.unctions, deficiencies, deviations, defective material and equipment and nonconformances which are adverse to quality and* might* affect the safe operation of a nuclear*generating station are promptly identified and corrected.
Corrective action measures for nonconformances are included in the design~ source fabrication and on-site construc-tion~. erection and operational ph~ses. Corrective action measures involving deaign will be processed as design change requests.
Corrective action measures in the source fabrication phase are required in the quality assurance programs of individual vendors including the NSSS Supplier.
For the Project. Engineering-Construction phase and modifications undertaken by Station Construction, on-site correc-tive action measures shall consist of a program for:. (1) reporting nonconformanc_es to Engineering by Construction; (2) recording nonconformance reports (NCR.'s) in a log for follow-up by Quality Assurance as to resolution and satisfactory completion; (3) pro~t resolution and approval of corrective actions by-Engineering; (4) assurance by Construction that the corrective action has been taken; (5) sign-off approval and close-out of NCR.'s by Site Quality Assuranc*e that satisfactory corrective action has been taken; and (6) issuance by Engineering of monthly reports indicating the status of. all NCR.'s submitted for resolution.
Implementation of corrective action will be accomplished at th~ source of *deficiency by appropriate contractor personnel as directed by cognizant Edison engineers.
Project or Station Const~uction; as applicable has responsibility for implementation of the correction.
Quality Assurance is responsible for follow-up and final approval th~t the*nonconformances have been corrected satisfactorily.
16-1 Rev. 14 9/9/80 14' 14 Commonwealth Edison
For corrective action noncon£ormances, the Edison Site Quality Assurance Super_intendent~or designee wtll establish and maintain a Noncon£ormance Re~ort (NCR.) Station Log to monitor the prompt resolution and closing of all NCR.'s plus maintain a file of all NRC's or equivalent documents that are submitted by the site for CECo resolution and. approval.
The cumulative monthly deviation report, which indicates the NCR ~umber, ~eviation description and resolution, such as reject, replace~ use-as-is or repair, approval status, date of resolution and. whether corrective action is completed, is distri-buted to involved corporate and line management for inform~tion, review and possible action.
The, responsible manager brings signi-ficant nonconf:ormances to the attention of. corporate management. for action where satisfactory resolution. cannot be achieved by Engi-neering with a. contl:'.actor.
For Operations; corrective* action. identif:ie d from noncon-formances ~ incidents and deviations,. trend studies and audits are verif:ie d for satisfactory completion*. to preclude repetition.
Whel:l correc.tive* action is required to correct nonconformance to Code requirements~ such corrective action shall be made available to the Authorized Nuclear Inspector..
.Any revision to -Travelers involved. with corrective action* related: to nonconformance for station modifications shall. be reviewed with* the Authorized Nuclear Inspector for* his review* and~ insertion of hold. points..
. This:* system* will. provide* follow-up to assure that corrective measures-are effectively imp-lemented.. Also,. signif'icant. conditions ar.e* reported *by the responsible manager and nonconforming items are routinely repo~ed by the responsible engineering organization to appropriate levels: of management *.
The Technical Staff Supervisor verifia s completion of corrective actions for maintenance, repair,. refueling and operation activities.
The Station Quality Assurance Supervisor for mainten-ance and operating issues reports indicating the status of corrective action in progress.
These reports are routed to the Division Vice President and General Manager, Nuclear Stations and the Manager of Quality Assurance and reviewed to assure prompt:
implementation of. the corrective action.
Site contractors and off-site vendors will be required to follow-up on corrective action commitments within their quality program.
The Site Quality Assurance Superintendent or designee will be responsible for surveillance of site corrective action.
The Project Engineering Project Engineer is responsible for assuring that review and evaluation of nonconformance reports are carried out to determine the need of corrective action.
16-2 21 Rev. 21 6/6/82 Commonwealth Edison
- 18. AUDITS*
Audits will be performed by Commonwealth Edison Company and/or its contractors~ subcontractors and vendors to verify the implementation and effectiveness of quality programs under their cognizance.
The number and experience of persons participating in audits will.vary according to the nature and significance of the audit.
Audits under the responsibility of the Manager of Quality Assurance will cover-quality systems for engineering, construction, modifications~ maintenance, in-service inspection and Stores activ-*
ities. Audits: 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 compliance of each operating station to the Quality Assurance Program is assured through review surveil-lance and audit of operations by the Quality Assurance Engineer. or Inspector under the direction of' the Station Quality* Assurance Supervisor who is responsible for operating quality assurance to
- the Director of *Quality Assurance (Operating) and through review, 20 surveillance and audit of maintenance, modifications, Stores and in-service inspection activities by Quality Assurance Engineers or Inspectors (Maintenance) under the direction of the Station Quality Assurance* Supervisor who is responsible for such quality assurance activities to the Supervisor Quality Assurance (Maintenance).
- 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 disruption of 18-1 Rev. 20
~MJ.eri.alth Edison
organizations being audited. An audit plan will be maintained in order to schedule audits of sita c-0ntractors.
Audits of off-site contractors generally will oe conducted in conjunction with plant visits for witnessing inspection points by a qualified auditor.
_-Also~ periodically Quality Assurance will participate in such audits or perform independent audits to assure effectiveness of the program~ compliance to the program and fulfillment of. procurement requirements.
The elements in the quality program, in procurement docu-ments and in related codes and standards, are subject to systems audits.
Also, items received, fabricated and constructed or installed for use by Commonwealth Edison Company in its nuc*lear power plants are subject to audits.
Audits will be performed selectively at various stages of contracts on a varying frequency, based. on the nature and safety significance of the work being done to verify compliance and determine the effectiveness of. procedures, inspections, tests,.
process controls and documentation.
For Code materials, when a Material Manufacturer or Material Supp lier, as applicable, does not*
hold a Quality System Certificate (Materials), the CECo audit frequency shall be at least once annually during the interval in which CECo purchased _material is be-ing controlled by the Material Manufacturer or Material Sl.lpplier....
In addition: to these audits, Quality Assurance: will conduct approximately annually,. overall system audits: of the NSSS, vendor,, th~ Architect Engineer, site contractors~ and involved. Edison Departments.. Audits of: CECo are also performed by the Authorized Inspection Agency as required by-*
the ANSI. N-626 series of Standards.
For operating stations~ periodic. Quality Assurance Depart-ment audits. will be performed. to verify compliance wi~h, and the effectiveness of the program.
Audits covering operating will be performed in accordance with the Technical Specifications under the direction and responsibility of the Director of Quality Assurance (Operating) independent of the. Production Department. Surveillance, in-service inspection and. Stores activities will be performed under the direction and responsibility of the Quality Assurance Supervisor (Maintenance). Audit results and recommendations of corrective action will be documented and reviewed with the management of the Station. Verification of the completion of corrective.action recommended.in audit reports will be performed by the Technical Staff Supervisor or Quality. Control Supervisor.
Follow-up of open station items is tracked by the.Action Item Record's (AIR.) System.
Where an audit item is placed under the Am system. for tracking completion~ approval as to satisfactory completion of corrective action shall be obtained from the responsible station Quality Assurance Engineer or Inspector.
18~2 21 Rev. 21 Commo~ia'fti+Edison