ML18089A468
| ML18089A468 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 12/15/1983 |
| From: | Liden E Public Service Enterprise Group |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8312230137 | |
| Download: ML18089A468 (13) | |
Text
,
e PS~G Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038 Nuclear Department December 15, 1983 Mr. Thomas T. Martin, Director Division of Engineering and Technical Programs U. S. Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Martin:
QUALITY ASSURANCE PROGRAM DESCRIPTION SALEM GENERATING STATION NO. 1 AND 2 UNITS DOCKET NOS. 50-272 AND 50-311 Pursuant to your request we are transmitting a draft QA program description ( UFSAR Chapter 1 7) to cla_rJ;Ey--ax:_~_a_;;; ___ ident t f ied in your letter of November 15, 1983. ~--
The details in the draft were discussed by Mr. Glenn Myer of your staff and Mr. William Schultz on December 13, 1983.
It was agreed that the proposed changes appeared to provide the necessary clarification and assurance that commitments would be met.
Unless otherwise directed, the proposed changes will be incorporated in the next scheduled revision to the SGS-USFAR.
Should you have any questions, please do not hesitate to contact us.
cc:
Mr. Donald C. Fischer Project Licensing Manager Mr. James Linville Senior Resident Inspector 8312230137 831615.
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PDR The Energy People Very truly yours,
- A.
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independent auditors from outside the company periodically audit the program for compliance with 10CFR50, Appendix B, and other Regulatory commitments.
The independent audit shall be conducted every two years.
Reports of such audits are made directly to upper management.
PSE&G requires its suppliers and contractors to assume responsibility for establishing and implementing QA/QC programs, as applicable, to meet 10CFR50, Appendix B.
NOQA reviews those programs and conducts appropriate monitoring and auditing as required to assure that suppliers properly implement their QA/QC programs.
The Nuclear Operations QA Program verifies that requirements necessary to assure quality are properly included or referenced in procurement documents.
In addition, PSE&G suppliers are required to extend applicable PSE&G QA requirements to sub-suppliers, as documented in the suppliers' procurement documents.
17.2.1 ORGANIZATION 17.2.1.1 General The Nuclear Operations QA Program, referred to hereafter as the QA Program, assures that adequate administrative and management controls are established for the safe operation of Salem Generating Station.
Implementation is assured by ongoing review, monitoring and audit under the direction of the Manager -
Nuclear Operations Quality Assurance who reports to the Vice President - Nuclear.
Company organization is shown in Figures 17.2-1 through 17.2-4.
Responsibilities for quality assurance related activities are described in the following sections.
17.2.1.2 Nuclear Department The vice President -
Nuclear who reports to the Senior Vice President -
Energy Supply and Engineering is responsible for managing and directing SGS-UFSAR 17.2-2 DRAFT REVISION 2 2540Q:l DECEMBER 14, 1983
- 7.
Provide top management with visibility into the status and adequacy of implementation of the QA Program by reporting significant quality problems and their solutions, and recommending preventive or corrective action to prevent their recurrence,
- 8.
Provide support to other PSE&G departments in order to assure that nuclear facilities are designed, fabricated, constructed, tested, operated, maintained, and modified in a manner which protects public health and safety,
- 9.
Represent the PSE&G Nuclear Operations Quality Assurance at regulatory agency public hearings and other meetings, on matters affecting the QA Program, and
- 10.
Stop work when significant conditions adverse to quality require such action.
The PSE&G policies and organization structure assure that the Manager - Nuclear Operations Quality Assurance has sufficient organizational freedom and independence to carry out his responsibilities.
17.2.1.2.4.1 QA Nuclear Operations Personnel Qualifications Position qualification requirements for QA positions are:
- 1.
A bachelor's degree and/or a high school diploma or equivalent plus two years experience and demonstrated technical ability which may be as an inspector, test engineer, or by special study of quality control techniques, testing and inspection methods, and/or by having acquired working knowledge of and familiarity with the requirements of the applicable Codes and Standards for accomplishing quality activities performed in the nuclear power plant
- industry, The Manager -
NOQA shall fulfill the above qualifications with the addition of the following:
- 1.
Knowledge and experience in Quality Assurance
- 2.
High level of leadership with the ability to command the respect and cooperation of company personnel, vendors, and operations forces, and
- 3.
Initiative and judgment to establish related policies to attain high achievement and economy of operations.
SGS-UFSAR 2540Q:l 17.2-5 DRAFT REVISION 2 DECEMBER 14, 1983
The Manager and engineers reporting directly to the Manager -
Nuclear Operations Quality Assurance must have a combination of six years experience in the field of quality assurance and operations.
At least one of these six years experience must be nuclear power plant experience in the overall implementation of a quality assurance program.
A minimum of one year and a maximum of four years of this six years experience may be fulfilled by related technical or academic training.
Personnel performing inspections, examinations and test activities are certified as Level I, Level II, or Level III as appropriate to their responsibilities, also in accordance with Regulatory Guide 1.58 as noted.
17.2.1.2.5 Independent Review Groups Two advisory groups are responsible for reviewing and evaluating activities affecting nuclear safety.
The onsite advisory group is designated the Station Operations Review Committee (SORC).
Composed of key station personnel, its responsibilities include review of plant operations and reportable occurrences, investigation of Technical Specification violations (with recommendations to preclude recurrence), and procedure reviews for safety-related activities or plant modifications.
Recommendations of this advisory group are forwarded to the General Manager -
Salem Operations, with copies to the Chairman of the Nuclear Review Board.
The SQAE is invited to all SORC meetings and attends them periodically as part of the pianned surveillance program.
He receives minutes of all the meetings.
The off-site advisory group is the Nuclear Review Board (NRB),
which advises the Vice President - Nuclear in matters affecting nuclear safety or relating to plant operation or modification to the plant design.
The NRB is responsible for performing an independent review of plant activities.
In addition, NRB is responsible for selected planned, independent audits of plant operations in accordance with Technical Specification requirements.
These audits are generally conducted by QANO under NRB cognizance.
The Manager - Nuclear Operations QA is a member of this board.
SORC and NRB organization and responsibilities are delineated in the Technical Specifications.
SGS-UFSAR 17.2-6 DRAFT REVISION 2 2540Q:l DECEMBER 14, 1983
- 5.
All fuel oil samples taken in actions 1-4 above are sent to an independent laboratory within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of the time the sample is taken.
The analysis performed is consistent with Regulatory Guide 1.137 and the analysis report is submitted to the Salem Station within 30 days of receipt of the sample at the laboratory.
- 6.
All fuel oil deliveries, samples taken, and related analysis reports are logged at the station.
When reports indicate that fuel oil quality is not within acceptable limits, station management will take appropriate action to restore it to within acceptable limits.
- 7.
Actions 1-6 above are subject to verification during routine monitoring and audits of the fuel oil program and procedures conducted by NOQA personnel.
- 17.
Regulatory Guide 1.144 "Auditing Quality Assurance Programs for Nuclear Power Plants" 9/80 (endorses N45.2.12)
- 18.
Regulatory Guide 1.146, "Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants", 8/80 (endorses N45.2.23).
- 19.
Branch Technical Position 9.5-1, Appendix A, "Guidelines for Fire Protection for Nuclear Plants Docketed Prior to July 1, 1976", 2/77.
The QA Program is applied to the Fire Protection Program to an extent consistent with the requirements of Section C of Appendix A to BTP 9.5-1.
SGS-UFSAR 17.2-13 DRAFT REVISION 2 2540Q:l DECEMBER 14, 1983
- 4. Nuclear Operations QA Program,
- 5. The QA Program and the organization of major contractors,
- 6. Other organizations within PSE&G with which NOQA interfaces, and
- 7. The general theory, structure, function and mode of operation of nuclear generating stations.
NOQA also offers formal training sessions for personnel in the Nuclear Department and other departments such as Construction, Engineering, Fuel Supply, Research & Testing Laboratory, etc.,
who perform activities related to nuclear operations safety.
NOQA personnel requiring certification are evaluated to establish their qualifications for their respective level.
The qualifications are approved by NOQA management for the required certification level.
The Nuclear Training Center is responsible for the licensed operator training and retraining in addition to other technical and supervisory training programs including General Employee Indoctrination which is required for all personnel having access to the station.
17.2.3 DESIGN CONTROL The Nuclear Support Department procedures, approved by the Manager - Nuclear Operations QA, provide implementation direction for the intent of Regulatory Guide 1. 64 "Quality Assurance Requirements for the Design of Nuclear Power Plants".
Within that department, the Nuclear Engineering Department has the following responsibilities:
- 1.
Prepare and update detailed engineering and design documents, including drawings and specifications, for all systems, components and structures, SGS-UFSAR 17.2-17 DRAFT REVISION 2 2540Q:l DECEMBER 14, 1983
changes to previously verified designs including evaluation of the effects of those changes on the overall design.
Design verification is performed by competent individuals or groups other than those who performed the original design with the following exception:
A design verifier may be the design originator's supervisor provided that he did not specify a singular design approach or rule out certain design considerations and did not establish the design inputs used in the design, or if the supervisor is the only individual competent to perform the verification.
This design verification provision requires prior authorization on an individual basis. Control of this function will be assured through periodic QA audits.
Design verification methods include but are not limited to:
- 1. Design reviews,
- 2. Alternate or independent calculations, and
- 3. Qualification testing.
Changes to specifications prepared by the Engineering Department for items covered by the QA Program are reviewed and approved by NOQA to assure that the QA Program requirements are specified.
Specifications are forwarded to NOQA for review and approval of quality and quality assurance requirements.
NOQA performs the same function in this case as during the original design stage.
The SORC reviews proposed changes affecting nuclear safety and makes recommendations concerning implementation of the change to the General Manager -
Salem Operations.
If the proposed modification involves a Technical Specification change or is considered by the SORC to involve an unreviewed safety question (10CFRS0.59), the matter is submitted to the NRB for a determination of its safety implication before a license change request is submitted for NRC approval.
External interfaces with manufacturers, consultants, and other departments, including procedures for the preparation, transmittal, review and SGS-UFSAR 17.2-19 DRAFT REVISION 2 2540Q:l DECEMBER 14, 1983
Salem Operations, additional or different hold points, as a result of their review.
Safety related procedures are reviewed by QA prior to issuance and additional inspection hold points may be added to a procedure.
The hold points must not be passed without authorization from the applicable QA or QC representative.
Typical critical activities include:
- 2. verification of cleanliness prior to closing safety-related systems,
- 3. Verification of reactor trip and Engineered Safety Features initiation setting after adjustment,
- 4. Packaging and loading of radioactive material for
- shipment,
- 5. Hydrostatic testing of safety related systems,
- 6. Acceptance testing of safety related system modifications, and
- 7. Acceptance testing of major repairs on safety related systems.
Inspection of operating activities (work functions associated with the normal operation of the plant, routine maintenance, and certain technical services) may be conducted by qualified individuals other than those who performed or directly supervised the activity being inspected.
These activities typically include periodic inspections of:
- 1. Storage areas,
- 2. Housekeeping (General),
- 3. Fire protection equipment,
- 4. Special handling tools and equipment, and
- 5. NDE visual inspection required by the Inservice Inspection Program.
SGS-UFSAR 17.2-28 DRAFT REVISION 2 2540Q:l DECEMBER 14, 1983
The applicable inspection and retest requirements necessary to assure that modifications or repairs have been accomplished correctly are provided by the design change package, work order, or procedure.
The inspection and retest requirements for modification and repair are based on the original inspection and test program, and the nature and scope of the modification or repair activity.
A planned and documented monitoring program is conducted for Q-Listed activities.
Monitoring of implementation of the QA Program by station personnel is conducted by the SQAE.
NOQA performs monitoring of supplier and contractor activities.
Discrepancies discovered during the conduct of the monitoring are brought to the attention of the management responsible for accomplishment of the activity.
17.2.11 TEST CONTROL Q-listed equipment or components (a) which require seismic or environmental qualification, (b) which must be tested periodically to assure satisfactory performance, or (c) which have been replaced, modified or repaired, are tested by qualified personnel in accordance with written procedures which provide acceptance criteria.
Retest requirements following repair or modification are provided by engineering specifications and/or the responsible engineer, as were the original test requirements.
The Operational Test Group is responsible for preparation of test procedures incorporating the engineering parameters.
SGS-UFSAR 17.2-29 DRAFT REVISION 2 2540Q:l DECEMBER 14, 1983
- 1. Specifying calibration frequency,
- 2. Recording and maintaining calibration records,
- 3. Controlling and calibrating primary and secondary standards,
- 4. Determining methods of calibration, and
- 5. Tracing use on safety related components.
Prior use of measuring and test equipment found to be out of calibration is evaluated for possible effect on safety related equipment or functions.
Measurements are repeated where necessary.
Secondary standards are calibrated by certified calibration laboratories and are traceable to the National Bureau of standards (NBS) or best industry standards where no NBS standards exist.
The accuracy of the primary standards used to perform this calibration is at least greater than the accuracy of the device being calibrated to the extent permitted by the state-of-the-art.
Test equipment is marked to indicated the latest calibration date and the next required calibration date.
out-of-calibration identification is used for instruments and controls to indicate this status pending calibration, repair, or replacement.
17.2.13 HANDLING, STORAGE, AND SHIPPING The control of handling, storage, cleaning, and preservation of material and equipment covered by the QA Program is the responsibility of the various departments involved in these activities.
The Nuclear Material Control Group is responsible for control of material in storage, including preservation and the application of appropriate shipping controls on items or materials shipped from the station.
The station departments are responsible for system cleanliness and handling of equipment during operational maintenance or modification.
Nuclear Engineering is responsible for specifying equipment requirements (performance characteristics, operational characteristics, special storage and handling characteristics).
Manufacturers' instructions and recommendations, design requirements, and applicable codes and standards are implemented, as appropriate.
Compliance with specific handling, storage or shipping SGS-UFSAR 17.2-31 DRAFT REVISION 2 2540Q:l DECEMBER 14, 1983
and/or retested in accordance with specified test and inspection requirements established by the cognizant engineer based on applicable code requirements.
NOQA reviews the disposition of all reports of nonconforming conditions and verifies completion of the disposition.
NOQA and other organizations in the Nuclear Department review nonconformance reports for quality problems and initiate reports to higher management, identifying significant quality problems with recommendations for appropriate action.
17.2.16 CORRECTIVE ACTION Organizations involved in activities covered by the QA Program are required to maintain corrective action programs commensurate with their scope of activity.
Noncompliances with the QA Program identified by NOQA are documented and controlled by the issuance of an Action Request.
NOQA reviews action requests for quality trends and periodically reports the results of these reviews to management.
Responses to Action Requests are 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 taken to prevent recurrence, and
- 4. Date when full compliance was or will be achieved.
Proper implementation of corrective action is verified through monitoring or audit as appropriate.
SGS-UFSAR 17.2-33 DRAFT REVISION 2 2540Q:l DECEMBER 14, 1983
Design and construction records are replicated via microform and stored in record facilities at the generating station and at off-site locations.
The General Manager -
Salem Operations is responsible for the permanent storage of station records.
The retention period for records, the permanent storage location, and methods of control, identification, and retrieval are specified by administrative procedure.
Individual station department heads are responsible for submitting applicable department records to the Technical Document Room for retention.
'17.2.18 AUDITS Audits of PSE&G and supplier organizations which implement the QA Program are performed by NOQA to verify compliance with the applicable portions of the Quality Assurance Program.
Audits are conducted by audit teams comprised of a certified lead auditor and certified auditors.
Audits are conducted using pre-established written procedures and checklists.
Areas of deficiency revealed by audits are reviewed with management and are required to be corrected in a timely manner.
Required corrective action shall be documented and verified.
Follow-up action, including reaudit of deficient areas, is performed.
The audit. program conducted by NOQA includes, but is not limited to, the following activities covered by the QA Program.
- 1. Operation, maintenance, and modification,
- 2. Preparation, review, approval, and control of design, specifications, procurement documents, instructions, procedures, and drawings, SGS-UFSAR 17.2-35 DRAFT REVISION 2 2540:Ql DECEMBER 14, 1983