ML18078A355
| ML18078A355 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 11/06/1978 |
| From: | Mittl R Public Service Enterprise Group |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7811080227 | |
| Download: ML18078A355 (41) | |
Text
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OPS~G i/
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Public Service Electric and Gas Company BO Park Place Newark, N.J. 07101 Phone 201/430-7000 November 6, 1978.
Director of Nuclear Reactor Regulation
- u. S. Nuclear Regulatory Conunission Washington, D. C..
20555 Attention:
Mr. Olan D *. Parr, Chief Light Water Reactors Branch 3 Division of Project Management Gentlemen:
RESPONSE TO REQUESTS FOR ADDITIONAL INFORMATION NO. 2 UNIT SALEM NUCLEAR GENERATING STATION DOCKET NO.
50-311 Public Service Electric and Gas Company hereby submits 40 copies of': its responses to your requests for additional in-formation regarding the Quality Assurance Program.
The in-formation contained herein will be incorporated into the Salem FSAR in an amendment to our application.
Should you have any questions, please do not hesitate to con-tact us.
Attachment The Energy People r1;;;;=s, R. L. Mittl General Manager -
- Licensing and Environment Engineering and Construction
~
I QUESTION 1.44 Identify the management level, abave or outside the QA organi-zation, responsible for the annual review and assessment of the status and adequacy of the Salem operational QA program.
ANSWER Refer to FSAR Appendix D, Section D.5, as amended.
SNGS-FSAR Units 1 & 2
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Amendment 43 P78 62 20
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QUESTION 1.50 Describe the measures which assure that. the error inherent in the calibration standard is less than the error of measuring and test equipment.
ANSWER.
Refer to FSAR Appendix D, Section D.5, as amended.
SNGS-FSAR Units l & 2
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Question 1.52 Describe in Section D.5, "Operational QA Program," the applicability of Section D.1, "QA Overall Approach and Scope," and Section D.2, "PSE&G Quality Assurance Program" to the operations phase of Salem 1 and 2.
Answer:
Refer to FSAR Appendix D, Section D.5, as amended; SNGS-FSAR Units 1 & 2 Amendment 43 P78 151 72 l
Question l.S3 Since the "Introduction and Summary" Section 1 of the FSAR addresses QA program controls in the.form of responses to NRC questions 1.1 thru 1.38 without a reference to these controls in Section D.5, "Operational QA Program," it is requested that the QA controls addressed in Section 1 be incorporated in the applicable subsections of Section D.S.
Also, it is requested that the responses to the above questions be incorporated into Section D.S.
Answer Refer to FSAR Appendix D, Section D.S, as amended.
SNGS-FSAR Units 1 & 2 Amendment 43 P78 lSl 71
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D.5 PSE&G OPERATIONAL QA PROGRAM The Operational QA (OPQA) Program is part of the PSE&G Corporate QA Program.
The OPQA Program assures that adequate administrative and management controls are established for the safe operation of Salem Nuclear Generating Station.
It is comprised of individual quality programs established by those departments shown in Figure D.5-1 which contribute ~o the support of the operating plant.
The OPQA Program is presently implemented for Unit No. 1 and shall be com-pletely implemented for Unit No. 2 at the time of fuel loading.
D.5.1 ORGANIZATION Each individual department responsible for implementation of the Operational QA Program is responsible for establishing an approved program.
The Quality Assurance Department is responsible for the Corporate QA Program of which the Operational QA Program is a part.
Implem~ntation of the Corporate QA Program is assured by ongoing review and e.udit under the direction of the Manager - Quality As-surance who reports to the Vice President - Engineering and Con-struction who :i.s responsible for the annual review and assessment of the status and adequacy of the Corporate QA Program.
The General Manager - Electric Production is responsible for es-tablishing and implementing an approved Electric Production Depart-ment QA Program which is a part of the Operational QA Program and complies with the Corporate QA Program.
The Vice President - Pro-duction is responsible for an annual review of the status and adc-quacy of the Electric Production Department QA Program.
D.5-1
/.44
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The Company's general organization is shown in Figure D.5-1, THE ENERGY SUPPLY. AND ENGINEERING ORGANIZATION Reporting to the Senior Vice President - Energy Supply and Engi-neering are the Vice President - Engineering and Construction, the Vice President - Production, and the Vice President - Fuel Supply.
THE ENGINEERII~G AND CONSTRUCTION DEPARTHENT ORGANIZ/... TION The vice president of the Engineering and Construction Department is responsible for the design, construction, fabrication, instal-lation, preoperational testing, licensing, and quality assurance functions of nuclear generating stations.
The organizational break-down and functional responsib:i.lit:Les within his department are:
The Manager - Quality Assurance is responsible for the epprovnl and coordination of all QA programs established and imµlemented by var-ious C6mpany depnrtments, related to design, Pngineering, construe-tion, modification, maintenance and operation of nuclear generati11g stations.
He is responsibl0 for conducting independent audits, with his staff or consultants, of quality related activities within the various Company departments.
The Mana~er - Quality Assurance has the authority and responsibility to:
(l)
Provide centralized coordination of Quality Assurance func-tions throughout PSE&G for its nuclear facilities.
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D.5-2
(2)
Establish and implement a Corporate Quality Assurance Program that is in conformance with the requirements of 10CFR50, Ap-pendix B.
(3)
Assist in establishing and interpreting quality requirements and policies.
(4)
Assure compliance with PSE&G Quality Assurance policies and applicable government regulations including Regulatory Guides, Standards, Codes, etc., as committed in the Safety Analysis Reports.
(5)
Provide top management with visibility into the status and adequacy of the QA Program by reporting significant quality problems and their solutions, and recommending preventive or corrective action to forestall their recurrence.
(6)
Provide support when required by other PSE&G departments in order to assure that nuclear facilities are designed, fabri-cated, constructed, tested and operated in a manner which protects public health and safety.
(7)
Represent PSE&G Quality Assurance Department at regulatory agency public hearings and other meetings.
(8)
Stop work when significant conditions adverse to quality require such action.
The PSE&G policies and organization assure that the Manager -
Quality Assurance has sufficient organizational freedom and inde-pendence to carry out his responsibilities. *The Manager - Quality Assurance discharges his responsibility through the organization shown in Figure D.5-2, QAD Organization Chart.
D. 5-3 I
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. THE CONSTRUCTION DEPARTMENT The General Manager - Construction reports to the Vice President -
Engineering and Construction (see Figure D.5-1).
When the Construc-tion Department is responsible for construction activities, it is
- also responsible for the quality of work during construction.
LICENSING AND ENVIROi\\TMENT DEPARTMENT The General Manager - Licensing and Environment reports to the Vice President - Engineering and Construction.
The Licensing and Environ-ment Department has the technical support responsibility for licensing and environmental matters and the planning and execution of n~ar and long-term environmental impact analyses for nuclear facilities.
THE ENGINEERING DEPARTMENT The General Manager - Engineering reports to the Vice President -
Engineering and Construction (see Figure D.5-1).
The department is composed of divisions representing the various Engineering Disciplines (Mechanical, Electrical, Structural, Controls, and Design).
The Engineering Department when requested by the Electric Production Department:
(1)
Is responsible for all engineering and design of modifica-tions of a generating station.
(2)
Is responsible for designing appropriate quality, reliability and maintainability into station equipment.
(3)
Procures equipment and systems from contractors for modifica-tions.
(4)
Procures consulting services.
D. 5-4
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J (5)
Provides support for operating plants and assigns coordinator for authorized work.
(6)
Provides technical expertise in support of the operation of generating stations.
FUEL SUPPLY DEPARTMENT The General Manager - Fuel Supply reports to the Vice President -
Fuel Supply.
The Vice President - Fuel Supply reports to the Senior Vice President - Energy Supply and Engineering (see Figure D.5-1).
The Fuel Supply Department is responsible for the procurement, sched-uling, and shipment of initial and replacement nuclear fuel.
PROD~CTION DEPhRT~~NT The Vice President - Production reports to the Senior Vice President -
Enercy Supply and Engineering and is responsible for the operation and rnainte::nance of all electric gr>nerating stations.
He discharges his responsibility through the General Manager - Electric Production who has reporting to him the Managers of all generating stations and variot1s technical staff support Managers in areas of Nuclear Opera-tions, Pl?~t Ooerations, Plant Maintenance, System Operations, Methods and the C~ntr~i Maintenance Shop.
These functions are further described in Chapter 12.
The Manager Salem Generating Station is responsible for all operatior1 and maintenance activities at the station.
He rP"orts to the General Manager - Electric Production (see Figure D.5-30...)
The implementation of the Salem EPD Quality Assurance Program is the responsibility of the Manager - Salem Generating Station, assisted D.5-5
by the Station QA Engineer (SQAE) and station QA staff.
The station organization is shown in Figure D.5-3h~ The SQAE reports to the Man-ager - Nuclear Operations and thus is independent of the operations, maintenance and performance departments.
The SQAE conducts a planned surveillance program of nuclear safety-related activities to assure compliance with the quality program.
He maintains communication with and keeps the Manager - Quality Assurance and"the Manager - Salem irafo.-'M~
Generating Station~with regard to quality matters.
Two advisory groups are established to review and evaluate proposed and after-the-fact items related to nuclear safety.
The onsite ad-visory group is designated the Stations Operations Review Com..~ittee (SORC).
Composed of key station personnel, its responsibilities in-clude review of plant operations, reportable occurrences, investiga-tion of Technical Specification violations (with recorrrrncndations to preclude recurrence), and procedure reviews for safety-related ac-ti vi t:i0s or plant modifications.
Recorr:n~cndations of this advisory group are forwarded to the Manager - Salem Gener~ting Station, with copic.::s to the Chairms.n of the Nuclear Review Boarc.i, and the General Manager - Electric Production~
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(The SQAE is invited to all SORC meetings and receives the mi nut.es of the meetings.
He attends them periodically as part of the planned surveillance program.
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The off-site advisory group is the Nuclear Review Board (NRB), which is organized to advise the Vice President - Production in matters af-fecting nuclear safety or relating to plant operation *or modification to the plant design.
The NRB is chartered to perform an independent review of plant activ-ities and cause to have preplanned and written inaependent audits of plant operations conducted.
Support to the Operational QA Program is also provided by various other Company departments/organizations.
The respective organization and responsibilities are as identified.
Each of the support groups maintains their department procedures in compliance with the C0rporate QA Manual.
ENERGY LABORATORY SERVICES The Energy Laboratory is a part of the PSE&G Research Corporation.
The Energy Laboratory is directed by a Vice President who reports to the President of PSE&G Research Corporation which is an independent entity.
The Energy Laboratory performs calibrations-, analyses and evaluations on systems, equipment, and materials as requested by PSE&G departments and is in compliance with the Corporate QA Program.
THE TRANSMISSION AND DISTRIBUTION DEPARTMENT The Vice President - Transmission and Distribution reports to the Senior Vice President - Customer Operations.
This organization is responsible for transmitting electric energy to the area of use and D. 5-7
THE TRANSMISSION AND DISTRIBUTION DEPARTMENT (Cont) for distributing.it to the consumers.
It is responsible for the setting and testing of protective relays for the external vital power supplies.
THE PURCHASING DEPARTMENT The General Manager - Purchasing reports to the Vice President -
Corporate Services under the Senior Vice President -
Administra-tion.
The Purchasing Department is responsible for the procurement of materials, equipment, struGtures and services for the corporation.
D. 5-8
D. 5. 2.
PROGRAl*1 The Operational Quality Assurance (OPQA) Program requires that activ-ities affecting nuclear safety be accomplished under suit-ably controlled conditions.
The program takes into account the need for procedures, special controls, cleanliness; processes, test equip-ment, tools and skills to obtain the required quality and the verifi-cation of quality by inspection, test, examination, surveillance and independent review ~nd audit.
The safety-related activities include, but are not limited to:
designing, purchasing, fabricating, handling, shipping, strring, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling and modifying.
These safety-related activities shall be conducted in accordance with Regulatory Guides identified in this section to include but not be lirn-ited to:
- a.
Rcgulc;lory Guide 1.8, "Personnel Selection and Training," 9/75, (endorses Nl8.l).
- b.
Regulatory Guide. 1.30, "Quality Assurance Requirements for the In.stallation, Inspection, and Testing of Instrumentation and Electric Equiprnen t " 8/7 2, (endon.. es N4S. 2. 4).
- c.
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Regulatory Guide. 1._3 7, "Quality Assurance Requirements for Clean -
ing of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants," 3/73, (endorses N45.2.l).
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Regulatory Guide 1.38, "Quality Assurance Requirements for Pack-aging, Shipping, Receiving, Storage, and Handling of Items fer Water-Cooled Nuclear Power Plants," 10/76, (endorses N45. 2. 2).
. f.
Regulatory Guide 1. 39, "Housekeeping Requirements for Water-Cooled Nuclear Power Plants," 3/73, (endorses N45.2.3).
Regulatory Guide 1.58, "Qualification of Nuclear Power Plo.nt Inspection, Examination, and Testing Personnel," 8/73, (endorses N45.2.6).
All PSE&G personnel performing inspection, examination or testing shall be qualified in accordance with this Regulatory Guide, with the following exceptions:
Certification of personnel qualification will not include an expiration date and will remain in effect for the duration of employment in the same classifica-tion of qualification.
Our implementation of ANSI standard N45.2.6, paragraph 2.2.4(5), will be by recording in documents other than the certificates, the date of certification and the bi-yearly re-evaluation of paragraph 2.2.3.
Should the reevaluation result in a reclassification, a new certificate will be issued.
h Regulatory Guide 1.64, "Quality Assurance Requirements for the Design of Nuclear Power Plants," 10/73, (endorses N45.2.ll).
Regulatory Guide 1.74, "Quality Assurance Terms and Definitions,"
2/74, (endorses N45.2.10).
J Regulatory Guide 1.88, "Collection., Storage, and Maintenance of Nuclear Power Pl~~t. Quality Assurance Records," 10/76 * (endorses N45.2.9).
The following is an exception to Regula~ory Guide 1.88:
Engineering and Construction records are being duplicated via microfilm as an ongoing process.
Wh en this activity is completed, Salem records will comply with this Regulatory Guide.
k Regulatory Guide 1.94, "Quality Ass~rance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plan ts; 4/ 76 (endorses N45. 2. S).
Major modifications made to the Salem units will comply with Regulatory Guide 1.94.
To implement these requirements, the OPQA Program requires that s~fety-related activities be:
- a.
Performed in accordance with rcvieued, approved *w-ri t ten pol i-cics and procedure throughout the life of the st~tion.
- b.
Inspected by qualified inspectors to assure that the required quality levels have been achieved.
- c.
Subject to a formal surveillance program conducted by the SQAE, or other qualified supervisory personnel.
- d.
Subjected to systematic audits conducted by the SQAE and the QAD.
The OPQA Program shall apply to those. structures, systems, and com-prep1tr-cJ ponents identified in a Master Equipment List~by the General Manager -
D.5-11
Engineering as being safety related.
Personnel who have the respo~sibility to implement the Operational Quality Assurance Program also have the responsibility and authority to escalate unresolved quality problems to that level of manageoent necessary to effect resolution of the dispute.
This escalation is applied by Quality Assurance Personnel, who are independent of cost and scheduling, to increasingly higher levels of management up to the Senior Vice President - Energy Supply and Engineering as required~
..... li All PSE&G departments, contractors and/or consultants performing safety-related activities at the plant site must conform with the Corporate QA Program; and must work within the framework of the Station's adminis-trative controls.
The Manager - Salem Generating Station shall institute and maintain an Administrative Procedurc:.s Manual for Salem Generating St<J.tion to implement. the detailed requirements of the program.* The index of Ad-ministrative Procedures and a matrix of applicable procedures cross-referenced to Appendix B to 10CFR50 are included as Figure D.5-4, Figure D.5-5 and Figure D.1-3.
The Electric Production Department QA Program, as promulgated by the Station Administrative Procedures, shall be approved by the _}fona,£',ei:- -
Salem Generating Station and the Mana_ger - Quality Assurance. Chctl\\je5 1C 't"l/ese. /l~//J/S"Jfa-l;v-e hocedures shall be processed in the same manner.
- Regulat6ry Guide 1.33 (2/78) requires that safety-related plant activ-ities be conducted in accordance with written administrative controls D.5-12
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prepared by management.
These procedures and instructions by which plant activities are performed are prepared by the responsible station department, reviewed by the SQAE for quality requirements, approved by the Department Head responsible for the activity, reviewed by the
.SORC (if safety related), and approved by the Manager - Salem Gen-erating Station.
Procedures cannot be implemented unless the review/
approval process is accomplished.
Station.Administrative Procedures provide a means to accommodate on-the-spot changes to implementing procedures.
The routine practice for revising a procedure is to re-peat the original review c;,d Of/Z0 v/.JL Se.Jt/e/Jt: e
- Personnel performing safety-related activities are trained and/or in-doctrinated as necessary to assure that suitable proficiency is achieved and maintained.
Qualificaticns of supervisory and professional personnel on the; plant staff are in accordance with Regul~tory Guide 1.8, Personnel Selection and Training (9/75).
Training programs of supporting organizations are described in their manuals which comply with the Corporate QA Program.
The training and indoctrination program at the Station includes the followint,;:
- a.
The station department heads (such as Maintenance Engineer and Perforrnarice Engil'1eer) nre responsible for periodically training their-personnel to perform preventive and corrective maintenance on, and inspection of, safety-related systems and components in accordance with*therequirements of the EPD QA Program and re-lated.reference documents.
D.5-1.1 1..
Such training shall be documented in station records.
- b.
General employee training in the following areas shall be given to all station* employees.
- 1.
Quality Assurance
- 2.
Security
- 3.
Industrial Health and Safety
- 4.
- 5.
Radiation Pro tee ti-on D. 5-14
D.5.3 DESIGN CONTROL Changes to the licensed plant design are* controlled by the General Manager - Engineering, who is responsible for the design verifica-tions, specification and drawing preparation, and purchase order documentation for materials and components as specified in the Engineering Department procedures.
These activities include verification that QA provisions'* correct codes and specifications are included.
Design changes to safety-related specifications pre-pared by the Engineering Department are reviewed and approved by the Manager - Quality Assurance to assure that the QA Program require-ments are specified.
The Manager - Quality Assurance performs the same function in this case as he did during the original design stage as presented in Section D.l.
The SORC shall review proposed safety-related changes and make recommendations concerning implementation of the change to the Manager -
Salem Generating Station.
If the proposed modification is consid2rcd by the SORC to be an unreviewed safety matter (10CFRS0.59), the NRB shall make a determination of its safety implication before ~ license ch~nge request is submitted for NRC a.pprovc:l.
Updating of records, including drawings, blueprints,
- and specifications resulting from design change, is the responsibility of the General Manager - Engineering.
D.5.4 PROCUREMENT DOCUV1ENT CONTROL Procurement documents for the purchase of spare parts and items required for maintenance and modification to nuclear safety-related portions of the plant shall identify or reference applicable quality criteria.
The SQl\\E shall review safety-related p::::-ocurt::ment documents initiated at the station to ensure that appropriate QA requirements are specified and that the proposed vendor is approved.
D.5-15
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Procurement documents Shall require suppliers to provide services or components in accordance with a QA Program consistent with 10CFRSO, Appendix B.
QAD shall assure that all safety related procurement documents prepared by any PSE&G department/organization are reviewed for quality content.
D.5.5 INSTRUCTIONS, PROCEDURES AND DRAWINGS All safety-related activities performed by any PSE&G department/
organization shall be preplanned.
Simple routine activities, that can be performed by qualified perso~nel with normal skills, shall not require a detailed written procedure.
Complex activities shall require detailed instructions.
Procedures shall include, as appropriate, scope, statement of applicability, references, pre-requisites, precautions, limitations, and checkoff lists of inspection requirements in addition to the detailed steps required to accomplish the activity.
Procedures shall also contain acceptance criteria where appropriate.
Procedures shall be reviewed and approved prior to implementation.
The Manager -
Salem Generating Station is responsible for assuring that station procedures are prepared, approved, and implemented in cor:1pliance with the Station Ad.minis tr a ti ve Procedures.
Safety-related doctunents shall be reviewed by SORC for technical cont.ent, by the SQ.1\\E for Ql~ requi:::-ements, and ~pproved by the responsible station department head and the.Manager -
Salem Generating Station.
The General Manager -
Engineering is responsible for issuing specifications, drawings, blueprints, instruction manuals and technical manuals ~ssociated with safety-related structures, systems, D. 5-16
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and components.
These reference documents shall be kept up to date for the life of the station by incorporation of approved and implemented modifications or design changes.
Master lists of current editions or revisions of these documents shall be issued by the General Manager - Engineering to the Manager -
Salem Generating Station periodically to assure that only current, approved reference documents are used at the station.
D.5.6 oocmmNT CONTROL A document control system is developed py each organization generat-ing or implementing instructions, procedures and drawings which prescribe activities affecting quality.
The document control system requiros that documents and changes thereto are reviewed for adequacy and approved by authorized personnel prior to use.
The establ5.shment and maintenanc2 of a do.curnent control system for all instructions, procedures, specifications and drawings received from the Er1s:;-:L:1eerinc;:r Dt::)":?..rtm8n t / or prepared c;.t: the sto. ti on for use in operating, muintaining, :::-efueling, or modifying the nuclear safety-related structures, components and systems is the responsibi-li ty of the r~anagc:r - Salen Generating Stat~on.
The Station Administrative Procedures Manual del8gates the control of specific docurncn ts.
The station control practices shall be found i11 Administrative Procedures and dep~rtment instructions authorized by the responsible department heads.
Me~sures Shall be established to insure that the Administrative Procedures and department instructions are up to date,
+~.t:
are properly authorized, are chan9cd only after review andArequired approvals are obtained 1 and are distributed to cognizant personnel.
D. 5-1 7
.e D.S.7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES Procurement document control shall assure that orders for material and services from suppliers are consistent with applicable code and QA requirements.
The Manager - Quality Assurance is responsible for maintaining a list of approved suppliers of safety related items and services.
All safety related procurements *shall be made from approved suppliers.
Qualification and evaluation of prospective suppliers is performed by the responsible engineer, and the Q,AD.
The responsible engineer determines the technical competence of the suppliers.
The QAD evaluates prospective suppliers' quality assurance prqgramsutilizing one or more techniques including but not necessarily limited to contractor or supplier procedures or manuals, satisfactory past history, ASl*IB code stamp approval, CASE register, or surveys of supplier plants.
The evaluations conducted of the prospective supplier~~ utilize standard checklists/forms designed to include 18 quality criteria of lOCFii.50, Appendix l3 as appropriute.
Surveys or evaluations of supplier capability include evaluation of manage-ment syste~manufacturing process, as well as adherence to QA/QC procedures.
atJd acce;:rra/1ce
()/' Se/lv'/ces The inspect.ion.. of material} or equipr:ii~lit/land vendor documcntution on.
rccli-p-t provicl~s the final verification that it conforms to the appropriate procurement documents.
Procedures shall provide these controls and shall include assignment of responsibility for receiv-ing inspection, documentary evidence of inspection, review responsibility for documents associated with the material, and acceptance pri6r to release* to other departments for service.
Material and equipment shall not be installed or used until it is
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D.5.7 (Cont) accepted by receiving inspection.
These activities shall be con-ducted in accordance with ~cgulatory Guide 1.38.
Receiving inspection at the station during the operational phase shall be performed by PSE&G station personnel as follows~
a)
The storekeeper shall perform receiving inspection and record review for material requiring only a statement of quality by the supplier.
b)
When specific chemical or physical requirements are specified for the material, receiving inspection shall be the responsi-bility of the qualified supervise~ or QC inspector.
cl Station QA personnel shall ieview all receiving inspec~ion results and documentation on material requiring specific quality ~ntation fe>r' accentabj.l i ty.
This re vie:~*: and docuMent~ O/I tl/e cp;;,..~Nc;?(:&/ ~/1/11 C?l1c/
acc'2ptance-sh"~ll beitperformeo. pJ~ior to material being releas2d for install~tion.
Docrn;*;c:11 tc:.:tion of receiving inspection results and vendor supplied documentc:.ition shu.11 be retained at the station.
D.5.8 ID::NTIFICi\\TION &'JD CONTHOL OF.MJ:J'ERI~J.. S, PARTS M7D COViPO~~ENTS Pr*::'>::'UH:r..::..:nt document controls and purchc.sing ccmtrols sho.J.l. provic.112 assurt.lnce that mllterial, parts and components received at the stc:ti on ca:i be p~*operly identified.
Procedures shall be prepared to require that safety-related materials, parts, or components be marked or otherwise identified and that such identity be maintained either on the item or on records traceable to the item throughout receipt, storage, installation, and use.
Protection against use of incorrect or defective items shall be pro\\rided.
D.5-19
D.5.9 CONTROL OF SPECIAL PROCESSES.
Procedures shall be established for special processes such as welding, heat treating and NDE, to ensure compliance with codes and design specifications.
The General Manager - Engineering is responsible for preparing special process specifications, which shall be reviewed and approved by the Manager -
Quality Assurance for necessary quality content.
Procedures for implementing the requirements* of the specifications shall be prepared either by EPD or supplier personnel, and approved by the General Manager - Engineering.
D.5.10 INSPECTION The Station Administrative Procedures specify that appropriate quality control inspection requirements be included within all procedures. Repairs, rework or modifications are accomplished in accordance with the Station Administrative Procedure Program.
This program provides for the conduct of repairs, rework or mod if ica tions in accordance with w~itten instructions and assures that required retest and reinspection are specified and successfully accomplished.
Engin~ering design changes or modifications ~re similarly conducted in accordance with the Administrative Procedure Program augmented by Engineering Department procedm:es.
These procedures provide for the establisl~ent of retest.requirements by the Engineering Department, the specifier of the original requirements, and verifica-tion by the Station Quality Assurance Engineer that the specified retests or inspections have been successfully completed.
The quality assurance review evaluates the QC inspection requirements and their adequacy.
D.5-20
D. 5.10 (CONT)
Inspections shall be performed by personnel who.are qualified in As /Joteq 11J tJ.5:'2. 1tel'YJ ~
accordance with Regulatory Guide 1. 58"other than those _who performed the activity being *inspected.
When the inspection requires special skills (such as radiography), arrangements shall be made to have appropriate inspectors perform this work.
These inspectors may be from within the company or from outside organizations.
Testing (including operational surveillance tests}, repair and maintenance activities shall be inspected by the supervisor responsible for assignment of the men performing the work.
The signature of the respective supervisor on the work package signifies that all inspection and/or test requirements have been satisfactorily completed or with nonconfonnances* as noted.
Station Department Heads are responsihiile for inserting mandatory inspection hold points in procedures they approve.
The Station Ope?rations Review Conunittee * (SORC) may recommend to the Station Manager'* '3.ddi tiona*l or different hold points,* as a result of their review.
The Stat.ion QA Engineer can also rC!quire that additional inspection hold points be ~dded to a procedure.
The Station Administrative Procedure Manual establishes the require-ment that Station Department Heads are responsible for the prepara-tion of procedures for activities affecting nuclear safety and for the SQAE and SORC review of such procedures prior to implementation.
Department ~anuals identify the requirement that hold point inspections must be considered for inclusion in procedures.
When a "Hold for QA Inspection" is identified, a qualifi~d individual assigned by the SQAE will perform the.inspection.
D.5-21
D.5.10 (Cont)
Guidance for determining when "Hold for QA Inspection" points are required is as follows:
a)
Verification of cleanliness prior to closing system.
b)
Verification of Reactor Trip or Safeguard System initiation setting after adjustment.
c)
Weld fit-up on ASME, Class 1 and 2 pressure boundary welds.
d)
Final NDE on Class 1 and 2 welds.
e)
Verification of hydrostatic test pressure and hold time.
f)
Acceptance testing of system modifications.
g)
Acceptance testing of major repairs.
A planned surveillance program for all station performed safety-related activies shall be establiihed.
Surveillance shall be conducted by the SQ.AE and his staff of appropriately qualified personnel.
Surveillance of suppliers will be perform~d by qualified personnel in accordance with the safety significance of the item or service and in accordance with approved, written quality assurance procedures.
D.5-22
.r
.Df.. 5.. 11 gsT cor~TR.
e Safety-relatej equipment or components whjch must be tested periodjcally to assure satisfactory performance, and equipnent and components which have been modified or repaired, shall be tested in accordance with written procedures which provide accept-ance criterja determined from applicable documents.
'Ihe Manager -
Salem Generating Station is responsible for assuring the required testing is performed according to the applicable requirements.
Test procedures shall be prepared, reviewed and approved as re-quired in Section D.5.5.
Original startup test documents may be used where appropriate, or revised as required to reflect new con-figurations or test requirements, System tests performed following modifications shall require both a procedure review and review of test results by SORC.
Evaluation of tes~ results conducted in the periodic test prograrn is performed by the responsible station department supervisor and reported to the SQAE and SORC when significant adverse conditions are disclosed by the test, as determined by the responsible depart-ment.
The SQAE shall maintain surveillance over the conduct of the design change acceptance tests to assure compliance with the test pro-cedure.
- a.
Proper documentation is presented.
He shall review the test results for the following:
- b.
Assurance that tests meet objectives.
- c.
Unacceptable results are identified, reported and corrective measures are initiated.
Retention of test reports shall be as described in Administrative Procedures.
D.5.12 CONTROL OF MEASURING AND TEST EQUIPMENT Safety-related teGt equipment and plant instrumentation and con-trols used to monitor and measure activities affecting quality shall be identified, controlled and calibrated at specific interval~.
Written procedures shall be prepared for meeting these requirements.
All procedures shall meet Section D.5.5 requirements and shall include provisions for:
- a.
Specifying calibration frequency.
- b.
Recording and maintaining calibration records.
- c.
Control and calibration of primary and secondary standards.
- d.
Methods of calibration.
- e.
l "'-Cea bf t /f 'f '7f rJ se ()fl sa.fety-re /~f e4 c; m/~ e.ti lS.
Calibration of measuring and test equipment is the responsibility of the using department.
Secondary standards used are calibrated by certified calibration
~
laboratories and are traceable to the* National Bureau oP Standards J,
or best industry standards.
The accuracy of the primary standards used to perform this calibration are at least greater than the accuracy of the device being calibrated to the extent permitted by the state-of-the-art.
1est equipment shall be marked to indicate the latest calibration date, the next required calibration date.
Out-of-calibratjon labels shall be used on instrumcntc and controls to indicate this status pending calibratlon repair or replacement.
- J D. 5. 13 HANDLING, STORAGE AND SHIPPING The Manager -
Salem Generating Station is responsjble for establishinc a program to control the handling, storage, cleaning and preservation of safety-related material and equipment.
Manufacturer's instructions or recommendations, design requirements, applicable codes and standards shall be implemented as appropriate as shall specific requirements established by the General Manager -
Engineerine.
INSPECTION, TEST AND OPERATING STATUS Procedures shall specify the pe~iodic tests and inspections re-quired for safety-related equipment, including the necessary management controls to assure that such required tests and/or inspections are completed in accordance with specified require-ments.
Equipment awaiting repairs, under repair, repaired, and received material shall be mark~d to indicate the status of inspection and test requirements and/or accepta1:ility for use.
Administrative procedures shall provide for tagging valves and switches to pre-vent inadvertent operation.
These procedures shall prevent operation of valves and/or switches which could result in per-sonnel hazard or equipment damage.
Valve and equi~ment status boards or logs shall be maintained to indicate status.
D.5.15 NONCONFORMING MATERIALS, PARTS OR COMPONENTS Nonconforming materials, parts or components identified during receiving inspection or during performance testing of equipment shall be identified, segregated (where practical) and shall not be installed or used until proper approvals are obtained.
Materials, parts or components which hnve failed in service shall be identi-fied and segregated (where practical).
They may be reworked, re-paired, or scrapped.
The Manager -
Salem Generating Station is responsible for assuring that nonconforming items identified by station personnel are controlled and nonconformances are referred to the proper authority for resolution.
D.5-26 I
D. 5.15 (Cont)
Specific station instruct)ons shall be issued to assure that nonconforming items are controlled by the responsible department head until properly dispositioned.
The SQ,AE shall assure that these controls are effective by surveillance and audit.
Whennonconformances are discovered in safety-related materials, parts, components or systems as the result of inspection, sur-veillance or performance tests, deficiency reports shall be pre-pared by the department discovering the nonconformance.
The action taken to resolve a deficienc~ shall be identified on the deficiency report.
The SQAE shall keep a record of the deficiencies and their corrective action, maintain surveillance over uncorrected matters and periodically report their status in writing to the Manager -
Salem Generating Station, the Manager - Nuclear Operations, and the Manager -
~uality Assurance.
The Manager -
Quality Assurance and the Manager -
Nuclear Operations review deficienty reports and initiate reports to higher management identifying significant quality problems with recommendations for appropriate action.
D. 5. 1.6 CORRECTIVE ACTION Organizations involved in safety-related activities shall be re-quired to maintain corrective action programs commensurate with their scope of activity.
Noncompliances with the OPQ,A Program identified by the Manager -
Quality Assurance shall be documented and con-tro1led by the issuance of a Corrective Action Request (CAR).
The D.5-27
D.5.16 (Cont)
Manager -
Quality.Assurance maintains surveillance of these CARs.
Responses to CARs shall be based on.the four elements of corrective action which are:
- 1.
Identification of cause of deficiency
- 2.
Action taken to correct deficiency and results achieved to date
- 3.
Action taken or to be ta.ken to prevent recurrence
- 4.
Date by when full compliance was or will be achieved.
The Manager -
Salem Generating Station is responsible for assuring that conditions adverse to quality are promptly identified and corrected for all activities involving station operation, main-tenance, testing, refueling and modification.
Administrative pro-cedures which govern safety-related station activities provide for the timely discovery and correction of nonconformances.
This in-eludes defective material being received, equipment failures or malfunctions) deficiencies or deviations of equipment from design performance, and deviations from procedures, In cases of signifi-cant conditions adverse to quality, the cause of the condition shall be determined and measures shall be established to preclude re-currence.
Such events, together with corTective action taken, shall be documented and reported as described in Section D.5.15.
Cor-rective action shall be initiated by the responsible department head.
The SQAE shall maintain close surveillance over such station con-ditions until proper corrective action is taken.
The SQAE has the authority to stop work when significant conditions adverse to quality require such action.
D, 5-2s
D. 5.16* (Cont)
Repetitive deficiencies, procedure or process violations which are not classified as Operational Incidents or Reportable Occur-rences or nonconformances with the EPD Q,A program shall be docu-mented by the SQ,AE by the issuance of a CAR.
The CAR.provides the SQAE with a formal adm*inistrative vehicle to alert managei::ent cf adverse conditions to quality that require corrective action.
Corrective Action Report summaries shall be sent to the Manager -
Salem Gener~ting Station, the Manager -
Nuclear Operations and the Manager - Quality Assurance.
D.5.17
~UALITY ASSURANCE RECORDS Records necessary to demonstrate that activities importnnt to qus.lity have been performe~d in accordance with applicable codes, NRC regulations, standards, specifications, procedures and contracts originated by the station or other departments shall be identified and maintuin~d in accordance with Regulatory Guide 1.88 as noted in D.5.2, itemj.
The station manager shall be responsible for the permanent storage of station records.
The retention period for records, the per-manent storage location, and method of control> identification and retrieval shall be specified by administrative procedure.
Individual station department heads shall be responsible for the submittal of records appropriate to the activity of the department.
D. 5-29
!L' AUDITS Audits shall determine the compliance of oreanizations with the applicable Q,A Manual, with 10CFRSO, Appendix B and with applicable Regulatory Guides, ANSI and/or other Standards, ASME_and/or Codes and other commitments.
The PSE&G QA Department shall conduct audits of quality-related activities by other departments within PSE&q, both on site, at the home office and/or at other PSE&G locations.
Audits of suppliers is the responsibility of QAD.
Areas of deficiency revealed by audits shall be corrected in a timely manner.
Cor-rective action shall be taken, verified and documented.
Follow-up action, including reaudit of deficient areas, shall be performed.
The SQ,AE is responsible for a system of planned periodic audits to verify station compliance with all aspecxs of the EPD Q,A Program and Station Administ~ative Procedures.
The audit program shall be established in accordance with ANSI Nl8.7, 1976.
Audits shall be performed by. qualified personnel who are independent of the area or function being examined, and shall involve coverage of safety-related activities as they are taking place, as well as review of records and documentation in accor-dance with s.n est::1.bli.shed proe;rar:i.
The frequency of audits shall depend updn the criticality of each function and shall be adjusted in view of problems encountered.
Audit and corrective action follow-up by the SQAE and other per-sonncl assigned to auditing shall be conducted in accordance with written procedures and reported to the station manager and the SORC for appropriate action, with copies to the SQ.AE, Manager -
Nuclear Operations and the Manager -
Quality Assurance.
D. 5-30
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AP NUMBER 1
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6 7
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10 11 12 13
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- 15.
16
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- Zl 22 23 24 25 26 27 28 LIST OF ADMINISTRATIVE PROCEDURES TITLE Administrative Procecure Program Station Organization Station Documentation Station Operations Review Committee Operating Practices Operational Incident Reports Reportable Occurrences Station Design Changes, Tests & Experiments Work Order System Inspection Order System Station Records.
Document Control Control of Lifted Leads and Electrical Jumpers Station Training *program Tagq~9' Rules
.Regulatory Material and Inspection/Audit Visits Operational Quality Assurance Program Outstanding Items List Procurement, Receiving, Storage, Issue and Shipping of Spare Parts a.nd Material Deficiency Reports, Testing Deficiency Reports and Corrective Action nequest Cleanliness and Housekeeping Calibration of Measuring and Test Equipment Quali£ication of Inspection, Examination and Test Personnel Radiological Safety Program Control of Station Repair and ~!aintenance Inspection Program for Equipment Covered by Boiler and Machinery Insurance Inservice Inspection Administrative Plan Reporting of Defects and Noncompliances PUBLIC. SERVICE ELECTRIC 'AMO GAS COWPANY of Administrative List SALEll NU CLEAR.* GEN ERAT!rJG* STATIO~I FSAR Amendment Procedures
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10CFRSO APPENDIX B CRITERIA TO ADMINIST.RATIVE PROCEDU.1:1.,_
CRITERION
- ORGANIZATION l 1 (IP. Stntlon llrgnnization CRiTERioN iI -
PROGRAM
- 1.
AP Operntian'1 l Qua! lty A*surunce Prograrn
- 2.
AP Stntlon Operations Revie~ Committee ciH't~iUoil ht -. IJEsit.11 c<iNTR!lL
- 1.
AP Station De*ign Changes, Tests ond Experiments CRITERION IV -
PROCUREMENT DOCUMENT CONTROL 1,
AP Procurement, Receiving, Storage, losue ond Shipping of Spare Parts and Material
- 2.
AP Station Organization
- 3.
AP Station Documentation CRITERION V -
INSTRUCTION, PROCEDURES, DRAWINGS
- 1.
AP Station Documentation
- 2.
AP Operating Practices J,
AP Work Order System
- 4.
AP Station Records
- 5.
AP DocuPent Control 6,
AP Cleanlinc*s and Housekeeping CR ITER IOH V l -
DOClMENT CONTROL
- 1.
AP Station Documentation
- 2.
AP Document Control J.
AP Administrative Procedure Program
- 4.
AP Control o[ Station Repair and Maintenance CRITERION VII -
CONTROL OF PURCHASED MATERIAL, EQUIPMENT, SERVICES
- 1.
AP Procurement, Receiving, Storage, Issue and Shipping of Spare Part* and Material
- 2. 'AP-J - Station Documentation CRITERION VIII -
IDENTIFICATION AND CONTROL OF HATERIAJ.S, PARTS, COMPONENTS I. AP Procurement, Receiving, Storage, Issue nnd Shipping of SpAre Parts ond Material
- 2.
AP Deficiency Report~. Tenting Deficiency Reports ond Corrective Action Requeat CRITERION IX - CONTROi. OF Sl'F.CTAL l'ROCf.SSES
- 1.
AP Station Training Program
- 2.
AP Qualification of lnnpcction, F.xomlnatlon and Test Personnel CRITERION X -
INSPECTION 1,
AP-25
- C9ntrol of S~ntlpn ~rpqJr flfid ttDiKt8Hffn~A
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AP Inscrvice Inspection Administrative Plan CRl1'ERlOl'I Xl - u:sr CON1'ROL 1,
AP Station Design Changes, Tests and Experiments
- 2.
AP Inspection Order Syste~
CRITERIOH XII - COHTROL OF MEASURUIG ANO TEST EQUIPMENT 1,
AP Calibration of Measuring and Test Equipment
- 2.
AP Deficiency Reports, Testing Deficiency Reports and Corrective Action Request CRITERION XIII - HANDLING, STORAGE, SlllPPINC AND PROTECTION Of' ITEMS
- 1.
AP Procurement, Receiving, Storage, Issue and Shipping of Spare Parts and Material
- 2.
AP Radiological Safety Program
- 3.
AP Control of Station Repair and Maintenance CRITERION XIV -
INSPECTION, TEST, OPERATING STATUS
- l. AP Procurement, Receiving, Storcige, J99ue and Shipping Spore Parts and Material
- 2.
AP Deficiency Reports, Testing Deficiency Corrective Action Request Reports and J.
AP Inspection Order System
- 4.
AP Tagglng Rules
- s.
AP Control of Lifted Leads and Electrical Jumpers CRITERION XV - NONCONFORMING MATERIALS, PARTS, COMPONENTS
- 1.
AP Deficiency Repdrts, Testing Deficiency Reports and Corrective Action Request of
- 2.
AP Procurement, Receiving, Storage, Issue and Shipping of Spnre Ports and Material
- 3.
AP Reporting of Defects and Noncompliance~
CRITERION XVI - CORRECTIVE ACTION
- t.
AP Deficiency R~ports, Testing Deficiency Reports and Corrective Action Request
- 2.
Ar Operational Incident Reports J,
AP Reportahle Occurrences
- 4.
AP RcRulatory Material ond Inspection/Audit Visits CRITERION XVII -
RF.CDROS I.
AP Station Records CRITF.RION XVIII - AUDITS
- 1.
Al'-17.18 - Opcrnt!on:il Quality Assurance Program