ML18102B380
| ML18102B380 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 06/06/1997 |
| From: | Eliason L Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LR-N970364, NUDOCS 9706110275 | |
| Download: ML18102B380 (141) | |
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- Public Service Electric and Gas Company Leon R. Eliason Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1100 Chief Nuclear Officer & President Nuclear Business Unit JUN *6 1997 LR-N970364 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 ENHANCEMENTS TO REQUEST FOR APPROVAL OF CHANGES TO THE QA PROGRAM HOPE CREEK AND SALEM GENERATING STATIONS FACILITY OPERATING LICENSES DPR-70, DPR-75, AND NPF-57 DOCKET NOS. 50-272, 50-311, AND 50-354 Ladies and Gentlemen:
On May 16, 1997, Public Service Electric and Gas Company (PSE&G) submitted a request to change the Quality Assurance (QA) Program for the Hope Creek and Salem Generating Stations, as documented in Section 17.2 of the respective Updated Final Safety Analysis Reports (UFSARs). Based upon discussions with the NRC staff, PSE&G is providing some clarifications and enhancements regarding the previou~ submittal. Details of those clarifications and enhancements are provided in Attachment 1 of this letter. The mark-ups of Section 17.2 of the Hope Creek and Salem UFSARs have been revised to reflect the clarifications and enhancements. Attachments 2 and 3 contain the revised Section 17.2 of the Hope Creek and Salem UFSARs, respectively. None of the clarifications or enhancements affect the basis for concluding that the requirements of 10CFR50, Appendix B would continue to be met. If you have any questions regarding this submittal, please do not hesitate to contact us. Sincerely, Attachments (3) 11 oo9 7 .I!lllll fllll flll{llll(l/llll llllllll llll
Document Control Desk
- JUN 6 19~7 LR-N970364 C Mr. H. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. D. Jaffe, Licensing Project Manager - HC U. S. Nucl.ear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21, Rockville, MD 20852 Mr. L. Olshan, Licensing Project Manager - Salem U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. S. Morris (X24)
USNRC Senior Resident Inspector - HC Mr. C. Marschall (X24) USNRC Senior Resident Inspector - Salem
. Mr. K. Tosch, Manager IV Bureau* of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625 95-4933
Document Control Desk LR-N970364 Attachment 1 HOPE CREEK GENERATION STATION AND SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSES NPF-57, DPR-70, AND DPR-75 DOCKET NOS. 50-354, 50-272, AND 50-311 ENHANCEMENTS TO REQUEST FOR APPROVAL OF CHANGES TO THE QA PROGRAM INTRODUCTION On May 16, 1997, Public Service Electric and Gas Company (PSE&G) submitted a request to change the Quality Assurance (QA) Program for the Hope Creek and Salem Generating Stations, as documented in Section 17.2 of the respective Updated Final Safety Analysis Reports (UFSARs). Based upon discussions with the NRC staff, PSE&G is providing some clarifications and enhancements regarding the previous submittal. Details of those clarifications and enhancements are provided below. None of the clarifications or enhancements affect the basis for concluding that the requirements of 10CFR50, Appendix B would continue to be met. CLARIFICATIONS AND ENHANCEMENTS RELATED TO THE PROPOSED CHANGES Section 17.2.1.1.1 on Page 17.2-4 The following additional changes are being proposed to Section 17.2.1.1.1 on Page 17.2-4: The phrase "for all areas except those non-QA areas under his control" is being added at the end of the second sentence in Section 17.2.1.1.1. A statement is being added to state: "The full attention of the Director will be in support of QA activities and will take precedence over his non-QA activities. In the event of a conflict he will delegate all QA authority to the Manager - Quality Assessment if necessary. The Manager - Quality Assessment has the authority to report directly to the CNO/PNBU for these matters." With regard to the discussion of the deletion of the Nuclear Repair Program from the responsibilities of the Manager - Corrective Action and Quality Services, the following clarification is provided: The Nuclear Repair Program is PSE&G's ASME Section XI repair/replacement program, and additionally, serves to satisfy state of New Jersey requirements .
- Page 1of3
Document Control Desk LR-N970364 Attachment 1 Section 17.2.1.1.1 on Page 17.2-5
- The description of the responsibilities of the Program Manager -
Nuclear Review Board (NRB) is being modified to clarify that his role is a coordination role rather than a performance role. Program Manager's responsibilities would include: 1) providing The support to the NRB to ensure that it can perform its function, 2) providing administrative oversight of the NRB subcommittees and NRB independent reviews, 3) ensuring that all appropriate documents are presented to the NRB, and 4) managing and administering the training requirements for NRB personnel. Figure 17.2-1 The NRB was added as a direct report to the CNO/PNBU. A line is drawn from the Program Manager-NRB to the NRB with a legend indicating that this is a coordination function. The legend also notes that the dotted line from the Manager - Quality Assessment to the CNO/PNBU indicates that the Manager - Quality Assessment reports to the CNO/PNBU. CLARIFICATIONS AND ENHANCEMENTS RELATED TO THE PREVIOUS CHANGES Hope Creek Change Notice 96-118/Salem Change Notice 96-172 Regarding Hope Creek Change Notice (HCN) 96-118 and Salem Change Notice (SCN) 96-172, the following additional information is provided: None of the information contained in NC.VP-PO.ZZ-0010(Q) was deleted when the content of the procedure was transferred to other documents. HCN 97-013/SCN 97-039 This change included the deletion of the list of Engineering responsibilities related to the design control program. This was identified as a reduction in commitment. This change notice will be revised such that the change is no longer considered a reduction in commitment. HCN 97-010/SCN 97-037 This change included the deletion provisions for providing for documenting the basis for calibrations which are not traceable to NIST. This was identified as a reduction in commitment. This
Document Control Desk LR-N970364 Attachment 1 change notice will be revised such that the change is no longer considered a reduction in commitment. HCN 97-017/SCN 97-051 These change notices incorporated changes to reflect organizational changes approved by the NRC associated with Hope Creek License Amendment 97, Salem Unit 1 License Amendment 192, arid Salem Unit 2 License Amendment 175. In these change notices, SORC was added to the list under the administrative procedures section of Table 17.2-1; however, NRB was not. This submittal adds the NRB to the list .
- Page 3of3
Document Control Desk LR-N970364 Attachment 2 PROPOSED HOPE CREEK UFSAR CHANGES
17.2 QUALITY ASSURANCE DURING THE OPERATIONS PHASE Public Service Electric and Gas Company (PSE&G) is responsible for assuring that the operation, maintenance, refueling and modification of the nuclear generating stations are accomplished in a manner that protects public health and safety and that it is in compliance with applicable regulatory requirements. To carry out this responsib~lity, PSE&G developed and implemented a comprehensive Quality Assurance Program that was applicable to the design, construction, and testing phases and is now applied to the operation phase. The Operational Quality Assurance Program is described in the following doeu!l'lento.
- 1. NC.VP PO.ZZ OOlO(Q) I Operational Quality Aoouranee Progra!l'I establishes the Quality Assurance Program.
r,.. Nuclear Administrative Procedures Manualf - (P:f;ttififfiijif.j:tj~:(f):j:)j~~l'j\jtj:.fjf§p~$
~g documents the programs and processes that implement the QA Program.
The QA program provides measures to assure the control of activities affecting the quality of structures, systems, components, to an extent consistent with their importance to safety. The Quality Assurance Program encompasses fire protection of safety-related areas and other activities enumerated in Regulatory Guide 1.33. A planned monitoring assessment and audit program assures effective implementation of the Operational Quality Assurance Program. An assessment is a direct observation of activities and review of documentation to verify compliance/conformance to specified requirements and effectiveness of processes. The program provides coordinated and centralized quality assurance direction, control, and documentation, as required by Nuclear Regulatory Commission (NRC) criteria set forth in 10CFRSO, Appendix B. The program provides for monitoring, assessing and auditing elements of the Fitness-For-Duty (FFD) Program as set forth in 10CFR26 and is applied to and includes non Q-list (i.e. balance of plant) activities and services necessary to achieve safety, reliability, availability and economy in the operation of Hope Creek Generating Station. Applicable NRC Regulatory Guides, codes, and standards, as well as the policy statements contained in the Nuclear Administrative Procedures Manual, are used by PSE&G organizations performing activities affecting safety to prepare appropriate implementing procedures. To assess the effectiveness of the PSE&G Quality Assurance Program, independent auditors from outside the company audit
- the program every 2 years for compliance with 10CFRSO, Appendix B, and other regulatory commitments. Reports of such audits are made directly to upper management .
- HCGS-UFSAR 17.2-1 Revision 8 September 25, 1996
Quality Assurance (QA) policy statements are issued by key management representatives, including the Chairman*and Chief Executive Officer and the Chief Nuclear Officer and President - Nuclear Business Unit (CNO/PNBU) . These policy statements are mandatory throughout the Company for nuclear facilities . Key policy elements, as they apply to nuclear safety, include the following:
- 1. Nuclear safety is of the highest priority and shall take precedence over matters concerning power production.
- 2. The public's health and safety is the prime consideration in the conduct and support of Public Service Electric and Gas Company's nuclear operations and shall not be compromised. All decisions which could affect the health and safety of the public shall be made conservatively.
- 3. The Operational Quality Assurance Program is an essential part of the PSE&G commitment to safe and reliable nuclear power operation.
Applicable program requirements shall be strictly adhered to in the performance of activities covered by the Operational Quality Assurance Program. PSE&G requires its suppliers and contractors to assume responsibility for establishing and implementing Quality Assurance/Quality Verification (QA/QV) programs, as applicable, to meet 10 CFR 50, Appendix B. However, responsibility for the overall QA program is retained and exercised by PSE&G. QA reviews those programs and conducts appropriate monitoring and auditing as required to assure that the suppliers are properly implementing their QA/QV programs. The Operational QA Program verifies that requirements necessary to assure quality are properly included or referenced in procurement documents. In addition, these suppliers' procurement documents include applicable PSE&G quality assurance requirements for items and services provided by their suppliers .
- HCGS-UFSAR 17.2-2 Revision 8 September 25, 1996
17.2.1 Organization The Operational QA Program, referred to hereafter as the QA Program, assures that adequate administrative and management controls are established for the safe operation of the station. Implementation is assured by ongoing review, monitoring, assessment and audit under the direction of the Director - Quality Aoouranee/Nuelear Safety Revic;v, l<IP.8%~?iif' W#i~&nW~MN::~~gM~m~:#:*~#ex:g~~~P~W#\¥:~# :::~pffi:?f~st'.9*1:::f:::9.B~i1i*R¥% mtii ::~Bi~Jff!)RX who reports to the CNO/PNBU .
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- 1. Frequent contacts in staff meetings, QA audit reports, audits by independent auditors, NRC inspection reports and department status reports.
- 2. An annual assessment of the QA program that is preplanned and documented. This assessment addresses the scope, status, and adequacy of the QA program. Corrective action is identified, and tracked.
17.2-3 HCGS-UFSAR Revision 8 September 25, 1996
17.2.1.1.1 Quality Assurance The Director - QA/I>mR_Ph~l~PY~-mm~: ijtjJq ~p Quality AssuraHee/Huclear Safety Review is responsible for defining, formulating, implementing, and coordinating the QA program. He has been delegated the authority and has the independence to interpret quality requirements, identify quality problems and trends, and provide recommendations or solutions to quality problems f'pp:~i!\if :~P~~~:'~§$%ffi~tffe:p§!\'l-*:.#~Mit' q~ ~#¥.~# W19i#~ P:ffi:~:::;@ptjtjp§l.i. He is responsible for approval of the QA/NSR Department Manual used during the operations phase of the nuclear stations. He also is responsible for verifying compliance with established requirements for the QA program through document review, inspection, monitoring, assessments and audits ~BP.::~:$ t;,,:*~&~~* ~§s~F~ :~li8%~::§9pj@!;::,~p$~~!. WAs~fi :nffi%::: s§§p=re+/-i QA provides a centralized coordinating function for QA/QV activities applied to the operations phase. The Director - QA/NSR;Mi?.§.iiff:#xW:rnmrn:r:~#E:t:g,g has the authority and responsibility to stop work, through the issuance of a Stop Work Order, when significant conditions adverse to quality require such action. The PSE&G policies and organization structure assure that the Director - QA/HSR 9-M~f:@;ty@j\~~::::i)!)§.gg]i!~ has sufficient organizational freedom and independence to carry out his responsibilities. mw@:£$.Jii:::~tAH~*Eiffisn>BJ=@&m@::@il@1il@#f..lfJwt;imr::Bii::rn;;r:::~twm?#mJ:swr~M~&:'~s:9:~r'&t:tJ;i~:t~#9<':A1#!+.:g; tMtm~:ur;,r;~sfMl~*r!~m:em~&trs;m:::mwre~::::~sJ@lt4£?ii~m:i:m::::::t:it::::fiu~::::~m~1J;::::g:~:::::~1sstfl:t:~@B::;.1:::1~:::@t++w gw+~$~t:=~::~++.:8?e{::%.?t-ins#\¥:§¥t¥2::::~n~N1#:#i~§%tlW:::P.M~+.::¥:&z:m~§ffe:~*m~!m:;:t~t::ti~g~~~~P=mtt:t~:a~: t,1~~g~f.::,:t =9§.i+wsx:m~:§i~i~}l~wt\~rna~§::::&£~=:u1w!)@P:s#i:F;M:m~t :&~m8:F:s::a:~E:@:sm+.Mme;:::~~:::::~mi\f1:~~w Responsibilities of the Manager - Corrective Action and Quality Servioeo include the following:
- 1. AdmiHistratioH of the Uuelear Repair Pro~ram
-$.\. Review of engineering documents such as equipment specifications, weld procedures, ete. for inclusion of QA requirements.
jt~=* Review and approve specifications for Q-listed materials, equipment, and services. 4:\~. Review of procurement documents for insertion of QA requirements. 5-t!* Conduct of supplier surveys, audits and surveillances .
~:f§:. Evaluation of prospective and existing Supplier QA Programs. -=t-I!i~j. Administration of the Corrective Action Program.
/7. Performing statistical analysis trend reports for management.
17.2-4 HCGS-UFSAR Revision 8
- September 25, 1996
~~$- Monitoring/auditing of nuclear fuel fabrication and installation.
M<:'9. Review of NBU fuel specifications for inclusion of QA requirements .
*!-+/-),.§.. Perform material evaluation activities on items subject to the QA Program.
- 12. Perforffi Code related inspections and test perforffiance.
- 13. Perforffi design change package pre impleffientation review and closure review for oompliance with Inspeotion Hold Points (IHPs) .
- 11. Performing performance based inspections (IHPs)
Responsibilities ooi\l:::%#SAQf]~*~rn;#i:~ of the Manager - Quality Assessment include the following:
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~~)\: Development and implementation of the QA Audit and Assessment Program. ;3.-_$# Performing assessments of contractor activities and evaluation of emergent contractor programs and procedures. §l,: Planning and scheduling of surveillances conducted within the Nuclear Business Unit.
4--:{. Performing station procedure review and concurrence. h§% Preparation and maintenance of the QA/NSR Department Manual, the QA program description in the UFSAR, and the Operational QA Program description in the Nuclear Administrative Procedures Manual . h9:U:::::::::::: Review of the Nuclear Administrative Procedures Manual for compliance with the Operational QA Program.
~ lli~. Performing assessments of PSE&G Program administrative and implementing
procedures (as necessary, these assessments may also include station administrative and implementing procedures)
- .S.'.J;::aj} Conducting QA Program orientation for NBU personnel ~gg administering the training and certification program for QA personnel involved inspection, assessments, and auditing activities, maintaining the training plan, and maintaining QA training records.
in QA
~ 1g. Review of new regulatory requirements for QA program impact. -i-GW~* Coordination of the commitment verification program on a selected basis.
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17.2-5
- HCGS-UFSAR Revision 8 September 25, 1996
Responsibilities of the Manager Nuclear Safety Review are described in Section 13.1. Responsibilities of the Manag-er Licensing- and Regulation are described in Section 13.1.
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17.2.1.1.1.1 Quality Assurance Personnel Qualifications The Director - QA/NSRMm:#f.jj{§?fj}@iN.;ti,i@fi}'\ifi~@f and the QA managers reporting directly to him must each have a combination of 6 years of experience in the field of QA and operations. At least 1 of these 6 years of experience must be in the overall implementation of a nuclear power plant QA program. A minimum of 1 year and a maximum of 4 of the 6 years of experience may be fulfilled by related technical or academic training. Personnel performing inspections, examinations, and test activities (i.e., to verify conformance) are certified as Level I, Level II, or Level III, as appropriate to their responsibilities, also in accordance with Regulatory Guide 1.58. Personnel performing quality assurance audits are certified as auditors or lead auditors, as appropriate to their responsibilities in accordance with Regulatory Guide 1.146. mB.tf@ml?i:+:i:;:~=s~j(fi:~@¥:~:::p;::::1~#i@jfiwt:t~i#ieiffiffi'P:~11:§J;w::::stt~n1:1rnr:::@1iiiR:t#.~s~ntrn1w~xaw~i\::fi¥s~;:m#:
~#~%:::am~9~ffie~e;: =:wrr:~=:~~s!::t:BP:f :;w~:=;::a::~::1in:1mg::f:~*m The Director - Ql't/NSR\jj:9.¥.!\E!ffif:M!ii!1~iE!~i)@g~'kf!g fulfills the above qualifications with the addition of the following:
- 1. Knowledge and experience in quality assurance, !P,~::m'M~:~:ffi¥:Mfi
- 2. High level of leadership with the ability to command the respect and cooperation of company personnel, suppliers, and construction forces,
- 3.
Initiative and judgment to establish related policies to attain high achievements and economy of operations. HCGS-UFSAR 17.2-6 Revision 8 September 25, 1996
17.2.1.1.2 Operational Review
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*.:ith Technical Specification requirements. These audits are generally conducted by QA under esR ~ cognizance.
17.2.1.2 Maplewood Testing Services The Manager Maplewood Testing Services reports to the Director Business and Maintenance Serviees in fossil generation. Maplewood Testin§J Services performs calibrations, analyses, and mraluations on systems, equipment, aad materials, as requested by PSE&G departments, and maintains compliance with its quality assurance program. 17.2.1.3 Deleted
- HCGS-UFSAR 17.2-7 Revision 8 September 25, 1996
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17.2.1.4 Distribution Systems Department The Vice President - Electric Distribution Systems reports to the Senior Vice President Transmission and Distribution. The Distribution Systems Department is responsible for providing support to Hope Creek operations for setting and testing protective relays for the external vital power supplies at the station. 17.2.2 Quality Assurance Program The QA program is designed to comply with the requirements of 10CFR50,. Appendix B, and with fire protection program requirements of Branch Technical Position CMEB 9.5-l. This program is applied to items and activities that can affect the health and safety of the public, i.e., Q, F, and R-designated items and activities. During the operational phase, this includes:
- 1. Structures, systems, and components delineated in Table 3.2-1 and marked as Y in "QA Requirement" column.
- 2. Safety-related activities delineated in Regulatory Guide 1.33 and summarized in Table 17.2-1, Section A and additional NRC requirements contained in Table 17.2-1, Section B.
- 3. Portions of structures, systems, and components whose continued function is not required, but whose failure, caused by a safe shutdown earthquake (SSE) , could reduce the functioning of a Seismic Category I structure, system, or component to an unacceptable safety level; or could result in an incapacitating injury to occupants of
- HCGS-UFSAR 17.2-8 Revision 8 September 25, 1996
the control room as shown in Table 17.2-2 and further delineated in Table 3.2-1 .
- 4. Fire protection systems, including emergency lighting communications, shown in Table 17.2-3, and further delineated in trafning, control of combustibles and ignition sources, firefighting procedures.
and Table 3.2-1 as well as administrative controls, such as fire brigade and
- 5. Radwaste management systems described in Table 17.2-4 and further delineated in Table 3.2-1.
The QA program is applied during the operational phase using a graded approach to the extent consistent with the item's or activity's importance to safety. Where there is an inconsistency between tables (i.e., Tables 3.2-1, 17.2-1, 17.2-2, and 17.2-3), the item will have QA provisions applied until the conflict is resolved and tables revised. These activities are performed in compliance with applicable regulatory requirements that include but are not limited to:
- 1. Regulatory Guide 1.8, Qualification and Training of Personnel for I Nuclear Power Plants
- 2. Regulatory Guide 1.17, Protection of Nuclear Plants Against Industrial Sabotage
- 3. Regulatory Guide 1.26, Quality Group Classifications and Standards for water, steam and radioactive waste containing components of Nuclear Power Plants
- 4. Regulatory Guide 1.29, Seismic Design Classification
- 5. Regulatory Guide 1. 30, Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment
- HCGS-UFSAR 17.2-9 Revision 4 April 11, 1992
- 6. Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation)
- 7. Regulatory Guide 1.37, Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water Cooled Nuclear Power Plants
- 8. Regulatory Guide 1. 38, Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Water Cooled Nuclear Power Plants
- 9. Regulatory Guide 1.39, Housekeeping Requirements for Water-Cooled Nuclear Power Plants
- 10. Regulatory Guide 1.52, Design, Testing, and Maintenance Criteria for Atmosphere Cleanup System Air Filtration and Absorption Units of Light Water Cooled Nuclear Power Plants
- 11. Regulatory Guide 1.54, QA Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants
- 12. Regulatory Guide 1.58, Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel
- 13. Regulatory Guide 1.64, Quality Assurance Requirements for the Design of Nuclear Power Plants
- 14. Regulatory Guide 1.74, Quality Assurance Terms and Definitions
- 15. Regulatory Guide 1.88, Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records
- 16. Regulatory Guide 1. 94, Quality Assurance Requirements for Installation, Inspection, and Testing of Structural 17.2-10 HCGS-UFSAR Revision O April 11, 1988
Concrete and Structural Steel during the Construction Phase of Nuclear Power Plants 17 . Regulatory Guide 1.116, Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and System
- 18. Regulatory Guide 1.123, Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants
- 19. Regulatory Guide 1.137, Fuel-Oil Systems for Standby Diesel Generators
- 20. Regulatory Guide 1.143, Design Guidance for Radioactive Waste Management Systems, Structures, and Components Installed in Light Water Cooled Nuclear Power Plants.
- 21. Regulatory Guide 1.144, Auditing of Quality Assuran.ce Programs for I Nuclear Power Plants
- 22. Regulatory Guide 1.146, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants
- 23. BTP 9.5-1, Appendix A, Guidelines for Fire Protection for Nuclear Plants Docketed Prior to July 1, 1976.
Commitments to Regulatory Guides, with respect to revision level, exceptions, etc, are contained in Section 1.8. The code QA requirements are used for the procurement of systems, components and structures covered by the ASME Boiler and Pressure Vessel Code Section III (classes 1, 2, and 3). The standard QA program controls apply to Q-Listed code items following receipt at the station. In addition, applicable requirements of Regulatory Guide 1.38 are applied to ASME Code procurements where necessary to assure safe shipment. 17.2-11 HCGS-UFSAR Revision 8 September 25, 1996
Substantive changes to the QA program described herein will be submitted to the NRC within 30 days of implementation. Nonsubstantive changes will be identified in the annual UFSAR updates .
- The station General Manager has instituted administrative procedures (SAP) manual.
and will maintain a station Regulatory Guide 1. 33 requires that plant activities a.ffecting quality-related items and services be conducted in accordance with written administrative I controls prepared by management. The procedures and instructions by which plant activities are performed are prepared by the responsible organization as required by Nuclear Administrative Procedures Manual, reviewed by the organization responsible for the activity, reviewed as required by QA and SORC, and 17.2-12 HCGS-UFSAR Revision 8 September 25, 1996
approved by the department manager. Nuclear Administrative Procedures (NAPs) and Station APs and all subsequent revisions thereto are reviewed by QA and SORC and are approved by the Station General Manager. Procedures cannot be implemented unless the review/approval process is accomplished. The Nuclear Administrative Procedures Manual provide a means to accommodate on-the-spot changes to subtier implementing procedures. The routine practice for revising a procedure is to repeat the original review and approval sequence. Implementation of the QA program is verified by means of independent inspections, assessments, monitoring, and audits conducted by QA. QA reviews and analyzes problems affecting quality that occur during the operational phase. Items subject to review include:
- 1. Documented nonconformances occurring at the supplier's facility and those identified during receiving, storage, installation, test, and operation, e.g., Deficiency Reports, Nonconformance Reports, Work Orders, Licensee Event Reports, etc.
- 2. Documented corrective actions taken on conditions adverse to quality and actions to prevent recurrence on significant conditions adverse to quality.
- 3. NRC inspection findings, notifications, bulletins, etc.
The Director - QA/NsR g§g+@~~M f!wtrn::::g¥§:J~¥fal:gff.qt:~a~:M!~n~i!~@:;1:::::::~~+:W.ii§¥::~~~~§:~m~#~ or his )ph,#,;ff designee§, ~Y% has- the authority to stop work through the issuance of a Stop Work Order where continuance of an activity would seriously compromise quality or constitute a persistent and deliberate failure to correct a significant condition adverse to quality. Deoigneeo include the Manager Quality Assessment and the Manager Corrective Action and Quality Services for activities under their cognieance. QA reports significant conditions adverse to quality affecting the quality assurance program to respective management along with: 17.2-13 HCGS-UFSAR Revision 8 September 25, 1996
- 1. Measures taken to improve QA program controls
- 2. Appropriate recommendations to achieve compliance with applicable requirements.
Management polioy and administrative procedures provide all personnel with awareness and d-irection for reporting of defects and noncompliance pursuant to 10CFR21. The QA program requires that safety-related activities and activities affecting the fire protection of safety-related areas, be accomplished under suitably controlled conditions. The program takes into consideration the need for procedures, special controls, cleanliness, special processes, test equipment, tools, and skills to obtain the required quality and the verification of quality by inspection, test, examination, monitoring, assessments and independent review and audit. These activities include, but are not limited to, designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, reworking, repairing, refueling, and modifying. Personnel who have the responsibility to implement the QA program also have the responsibility and authority to escalate unresolved quality problems to the level of management necessary to effect resolution. Escalation is applied by QA personnel to increasingly higher levels of management, up to the CNO/PNBU, as required. Personnel performing Q,F, and R-designated activities are trained or indoctrinated as necessary to assure that suitable proficiency is achieved and maintained. Personnel outside the QA organization who perform inspections and tests are trained and qualified in QA concepts and practices .
- HCGS-UFSAR 17.2-14 Revision 8 September 25, 1996
Orientation is provided for new employees entering QA from other organizations within PSE&G and from outside the company. An outline of the course content and program objective is contained in the QA training and certification program. The training and certification program is designed to familiarize the employee with:
- 1. Codes, regulations, specifications, etc, applicable to nuclear and other power generation equipment
- 2. QA procedures, instructions, specifications, documentation, records, etc
- 3. Auditing and assessment objectives and techniques
- 4. Operational Quality Assurance Program
- 5. Quality Assurance Operational Philosophy
- 6. Other organizations within PSE&G with which QA interfaces QA administers formal QA training sessions for personnel outside the QA organization who perform safety related activities. The content of these training programs, dates of the sessions, and names of the attendees and their individual performance evaluations are documented and retained .
- HCGS-UFSAR 17.2-15 Revision 7 December 29, 1995
Personnel requiring certification are evaluated to establish their qualifications for their respective level and discipline. Recertification is based upon demonstrated continued proficiency or requalification, if necessary. Personnel requiring certification in accordance with Regulatory Guide 1.58 are limited to personnel who perform inspection, test and non-destructive examination (NDE) activities, personnel who perform post design modification testing, and Inservice Inspection Services personnel who perform NDE and tests required by the Inservice Inspection Program. Those above personnel who perform visual examination (VTl, 2, 3) and NDE in accordance with the Inservice Inspection Program are trained, qualified and certified in accordance with a program which additionally meets the prescribed supplementary requirements of ASME Section XI. These personnel receive a periodic training needs assessment to identify additional supportive training needs, as well as, to evaluate individual post-training performance. The assessment period is three years or less. Personnel who are qualified and requalified for their respective level and discipline in accordance with Regulatory Guide 1.8 and ANSI/ANS - 3.1 and direct or supervise the conduct of individual preoperational, startup, and operational inspections and tests, including Technical Specification Surveillances and periodic inspection and test of fire protection equipment, do not require certification per Regulatory Guide 1.58 and ANSI N45.2.6 1978. When a single inspection or test requires implementation by a team or group, personnel not meeting the requirements of Regulatory Guide 1.58 and ANSI N45.2.6 1978 may be used in data-taking assignments or in plant or equipment operation provided they are supervised or overseen by an individual participating in the inspection, examination, or test and the individual is qualified and requalified for their respective level and discipline in accordance with either Regulatory Guide 1.8 and ANSI/ANS - 3.1 or the individual is certified in accordance with Regulatory Guide 1.58 and ANSI N45.2.6 1978 as appropriate. Regulatory Guide 1.58 and ANSI N45.2.6 1978 do not apply to NRC - Licensed Operators and Senior Operators for the performance of duties specified in 10CFR55 "Operator Licenses". The Nuclear Training Center is responsible for the licensed operator training and retraining, in addition to other technical and supervisory training programs .
- HCGS-UFSAR 17.2-16 Revision 8 September 25, 1996
General Employee Training, which is required for all personnel having access to the station, is the responsibility of the Manager °!'ruelear seeurity bi~eotp:i:' :"
- q§~;i;;T,r,;,¥@* ~) wgg §f.
Training programs of supporting organizations are described in their manuals, which are required to comply with the QA program. 17.2.3 Design Control The scope of the design control program includes design activities associated with the preparation and review of design documents, including the correct translation of applicable regulatory requirements into design modification, procurement, and procedural documents. The design control program includes activities such as field design engineering, asso~iated computer programs, compatibility of materials, and accessibility for inservice inspection, maintenance, and repair. Issuance of new drawings and revisions to existing drawings require the implementation of a design change. The term design change as used throughout this document, shall apply to both design and configuration changes. The Nuclear Engineering Manual (NEM) procedures, provide implementation guidance for the intent of Regulatory Guide 1.64, "Quality Assurance Requirements for the Design of Nuclear Power Plants." QA will conduct periodic engineering process assessments which include procedures contained in the ~NEM~. 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.
- 2. Specify applicable codes, standards, regulatory and quality requirements acceptance standards, and other design input in design documents.
- 3. Identify systems, components, and structures that are covered by the quality assurance program.
- 4. Perform design verification for systems, components, and structures covered by the QA Program .
17.2-17 HCGS-UFSAR Revision 8 September 25, 1996
- 5. Perform safety evaluations of proposed design changes, as required.
Sa . Apply Generic 10CFR 50.59 Safety Evaluation, as required,
- 6.
configuration changes that impact the SAR. Prepare documents components. for procurement of equipment, materials, and
- 7. Recommend engineering consultants and laboratories for procurement services and coordinate their activities.
- 8. Review design documents submitted by suppliers (including the Nuclear Steam Supply System (NSSS) supplier) and contractors.
- 9. Specify, or approve as required, inspections and/or tests
- 10. Designate whether they will seek the service of other qualified engineering organizations.
The cognizant engineer is responsible for the identification and completion of design analyses. The purpose of design analysis is to assure that the technical design is accomplished in a planned, controlled, and correct manner. Types of design analyses include, but are not limited to, reactor physics, stress, seismic, thermal, hydraulic, radiation, and accident. Design verification is performed on design analyses, drawings, specifications, and other design documents, as applicable. It is the process of reviewing, confirming, or substantiating the adequacy of design by one or more methods. Design verification is performed on changes to previously verified designs, including evaluation of the effects of those changes on the overall design. In general, design verification is completed prior to installation and in all cases is completed prior to placing the modified system or component into service. 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
- HCGS-UFSAR 17.2-18 Revision 8 September 25, 1996
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 is individually documented and approved in advance by the supervisor's management. Procedural control is established for design documents that reflect the commitments of the UFSAR; this control differentiates between documents that receive formal design verification by interdisciplinary or multi-organizational teams and those which can be reviewed by a single individual (a signature and date is acceptable documentation for personnel certification) Design documents subject to procedural control include, but are not limited to, specifications, calculations, computer programs, system descriptions, and drawings including flow diagrams, electrical single line diagrams, structural systems for major facilities, site arrangements, and equipment locations. Specialized reviews should be used when uniqueness or special design considerations warrant. The responsibilities of the verifier, the areas and features to be verified, the pertinent considerations to be verified, and the extent of documentation are identified in procedures. Control of this function is assured through periodic QA/NSR audits and assessments. Design verification methods comply with applicable requirements of ANSI N45.2.11 and may include, but are not limited to:
- 1.
2. Design reviews Alternate or independent calculations
- 3. Qualification testing.
In the event that the verification method for design modifications is only by test, procedures and instructions will be written which include measures to ensure that: 17.2-19 HCGS-UFSAR Revision 8 September 25, 1996
- 1. Criteria are provided to specify when verification should be by test .
- 2. Where applicable, prototype, component or feature testing will be performed prior to installation of plant equipment. In those cases where this cannot be met, the testing will be deferred but not beyond the point when the installation would be irreversible.
- 3. Tests will be performed under conditions that simulate the most adverse design conditions, as determined by analysis.
Drawings are prepared by, or under the supervision of a designer from information received from the responsible engineer, manufacturer's drawings, etc. The drawings are reviewed and initialed as being checked by another designer or design supervisor. The drawings are approved by the functional supervisor or his designee. Specifications and changes thereto for items covered by the QA program are prepared by Nuclear Engineering and are reviewed by Supplier Assessment for QA content. QA review assures that the documents are prepared, reviewed, and approved in accordance with company procedures and that the documents contain the necessary QA requirements such as inspection and test requirements, acceptance requirements, and the extent of documenting inspection and test results . The Station Operations Review Committee (SORC) reviews proposed changes affecting nuclear safety and makes recommendations concerning implementation of the change to the station general manager. The design change process provides for sign-off of the design change by the appropriate department head for the purpose of identifying required procedure change. If the proposed modification involves a Technical Specification change, or is considered by the SORC to involve an unreviewed safety question (10CFR50.59), the
- HCGS-UFSAR 17.2-20 Revision 8 September 25, 1996
matter is submitted to the Offoite Safety Review Group (OSR) ~HS+~~PS~Y#.~o/gp~#.:9' (~J::jJ for a determination of its safety implication before a license change request is submitted for NRC approval. For Huelear Engineering prepared PBK¥:i'.S ::::§p:g ::t#\#.fi),g#,'%t:$§H \§# design changes, Nuclear Engineering assigns a project team led by a project manager) .!:~@i#~~;i:t~A#~§.. The project team consists of members of various organizations, both internal and external to Nuclear Engineering. The project team members are responsible for providing technical and administrative input to the entire design change process, which consists of design, installation, testing, and closeout phases. The technical and administrative input is guided by the requirements of those organizations which comprise the project team. The project manager ensures that the specific requirements of each organization on the project team are considered to ensure the overall quality of the product. For design changes important to safety, the QA representative on the project team provides input and assures that design changes include quality assurance requirements such as inspection and test requirements, acceptance requirements, test result documentation, and project team compliance with company procedures during preparation, review, and approval of design changes. Updating of records, including drawings, blueprints, instructions and technical manuals, and specifications resulting from design changes, is the responsibility of the Senior Vice President - Nuclear Engineering. Design change procedures provide for the timely update of affected drawings following design change implementation to reflect as-built configuration. 17.2.4 Procurement Document Control Procurement documents and changes thereto for the purchase of Q, F, and R-designated material, equipment, or services are reviewed and approved by QA prior to issuance by the Purchasing Department to the prospective supplier. QA review assures that spare and replacement parts are procured using controls which are commensurate with current QA program requirements. 17.2-21 HCGS-UFSAR Revision 8 September 25, 1996
The review also assures that procurement documents adequately and correctly:
- 1. Identify applicable QA program requirements
- 2. Reference applicable regulatory requirements, codes, and standards
- 3. Provide right of access for source surveillance and audit by QA or its agents
- 4. Provide for required supplier documentation to be submitted to PSE&G or maintained by the supplier, as appropriate
- 5. Provide for PSE&G review and approval of critical procedures prior to fabrication, as appropriate.
Procurement documents require suppliers and contractors of other than commercial grade items to provide services or components in accordance with a QA program that complies with applicable parts of 10CFR50, Appendix B. The requirement for notifying PSE&G of procurement requirements that have not been met is conveyed to the supplier through the standard warranty provisi.on contained in each purchase order. In addition, where 10CFR21 is imposed, suppliers are required to comply with applicable reporting requirements. 17.2.5 Instructions, Procedures, and Drawings Organizations engaged in Q, F, and R-designated activities are required to perform these activities in accordance with written and approved procedures, instructions, or drawings, as appropriate. Simple routine activities that can be performed by qualified personnel with normal skills do not require a detailed written procedure. Complex activities require detailed procedures. The designation of those activities requiring detailed procedures is 17.2-22 HCGS-UFSAR Revision 8 September 25, 1996
made by cognizant department heads and as a minimum, complies with applicable requirements of Regulatory Guide 1.33. Procedures include, as appropriate, scope, statement of applicability, references, prerequisites, precautions, limitations, and checkoff lists of inspection requirements, in addition to the detailed steps required to accomplish the activity. Instructions, procedures, and drawings also contain acceptance criteria where appropriate. The station ~pJ?#9EEW~#¥: General Manager i~#i'!!:Pffi p§Q~P# is responsible for assuring that station procedures are prepared, approved, and implemented in compliance with the Nuclear Administrative Procedures Manual. Documents affecting nuclear safety are reviewed by the SORC for technical content, by QA for QA requirements, and are approved by the responsible station department manager or his designee. The Senior Vice President P,y~§p% is responsible for issuing specifications, drawings, blueprints, procedures, administrative and technical manuals associated with Q, F, and R-designated structures, systems, and components. Approved and implemented modifications and design changes are incorporated in these reference documents for the life of the station. Master lists of current editions or revisions of these documents are maintained by Nuclear ~R~NThffe:~~;::;:§pm§~% En9ineering to assure that only current and approved referenced documents are used. QA reviews and approves selected station procedures that implement the QA program, including testing, calibration, maintenance, modification, rework, and repair. Changes to these documents are also reviewed and approved. In addition, QA is responsible for review and approval of selected specifications, test procedures, and results of testing .
- HCGS-UFSAR 17.2-23 Revision 8 September 25, 1996
17.2.6 Document Control Instructions, procedures, drawings, and changes thereto are reviewed for the inclusion of appropriate QA requirements approved by appropriate levels of management of the PSE&G organizations producing such documents, and distributed on a timely basis to using locations. Measures are provided for the timely removal of obsolete or superseded documents from the using location. Supplier documents are controlled according to contractual agreements with suppliers. The following is a generic listing of key documents for the operational phase, showing minimum organization responsibility for review and/or approval, including changes thereto:
- 1. Design specification - Nuclear Engineering, QA.
- 2. Design modification, manufacturing, construction, and installation drawings Nuclear Engineering, Nuclear M#:ii!f!S@tligB£~ Operations Services, station operations
- 3. Procurement documents initiating Nuclear Business Unit organization, PHroaasin§" Department, Nuclear *=§m!fmM~i!@i}!§!¥.it:ffe§#im Operations Services, QA
- 4. Nuclear Administrative Procedures Manual - Nuclear Business Unit organizations responsible for implementation, QA
- 5. Nuclear Business Unit second tier manuals, including station administrative procedures - cognizant department head, QA
- 6. Maintenance, modification, and calibration procedures for Q, F, and R designated station work activities -
eperatiene
~it9i!iffe:#!;i}'if1fi!§ffi!n¥:a§if, Station
- 7. Operating procedures - station operations
- HCGS-UFSAR 17.2-24 Revision 8 September 25, 1996
- 8. UFSAR - Nuelear Operations Berviees J'J:i8t~'#"9~9~ ~rj.g. ¥~$§+1:!,§~91;1 and other Nuclear Business Unit organizations responsible for implementing applicable sections. In addition, QA reviews subsequent changes to UFSAR sections to the extent necessary for assuring compliance with applicable QA program requirements
- 9. Maintenance, inspection, and testing instruction - Nuclear Business I Unit implementing organizations
- 10. Post modification test procedures - Nuclear Engineering
- 11. Design Change Requests - Nuclear Engineering, QA QA involvement in the work activity includes review of work procedures prior to approval for designation of inspection hold points (see Section 17.2.10), review of completed safety-related Work Orders on a sampling basis, and periodic QA surveillance and assessments.
The establishment and maintenance of a document control system for all instructions, procedures, specifications, and drawings received from the Nuclear Business Unit, or prepared at the station for use in operating, maintaining, refueling, or modifying items and services covered by the QA program, is the responsibility of the Pi!i!~s#:~Mr::::::1::::::ms+/-~m¥f¥~:?,;e,~~:it~P.~e%i Senior Vice President Nuclear Engineering. The Nuclear Administrative Procedures Manual describes the controls for specific documents. Control of station practices is included in the administrative procedures and in department directives authorized by the responsible station department managers. Measures are established to assure that the administrative procedures and department directives are up to date, properly authorized, changed only after the required review and approvals are obtained, and distributed to appropriate personnel. Design change procedures provide for the timely update of affected drawings, following design change implementation, to reflect as-built configuration. Computerized databases maintained by the NEU organization are used to control drawings and specifications. 17.2-25 HCGS-UFSAR Revision 8 September 25, 1996
Revision control of procedures and instructions is accomplished through the control of computerized databases. Controls of software affecting nuclear safety are identified in the Nuclear Administrative Procedures Manual. These controls
- are based on applicable guidelines provided by the NRC and include software review and approval as well as access controls to prevent unauthorized software changes.
17 .2 . 7 Control of Purchased Material, Equipment, and Ser'vices QA maintains an up-to-date listing of approved suppliers of material, equipment, and services covered by the QA program. This list identifies suppliers and contractors who have demonstrated the ability to supply acceptable material, equipment, or services. The list includes manufacturers of commercial grade items. All QA program procurements are made from approved suppliers. The responsible engineer and QA personnel select and evaluate prospective bidders and suppliers. The responsible engineer determines the technical competence of the supplier, while QA evaluates the prospective supplier's QA program for the capability of meeting applicable requirements of 10CFRSO, Appendix B, and for extending applicable program requirements to subtier suppliers. Qualified QA personnel evaluate the prospective supplier's QA capability using one or more techniques, including but not necessarily limited to:
- 1. Evaluation of supplier's or contractor's procedures or manuals and changes thereto
- 2. ASME code stamp approval
- 3. Nuclear Utility Procurement Issues Council (NUPIC) or Nuclear Fuel Users Forum (NFUF) Audits.
- 4. Satisfactory past history of providing similar items 17.2-26 HCGS-UFSAR Revision 8 September 25, 1996
-- -*--------------------~----------
- 5. Survey of supplier's facility The evaluations of the prospective suppliers are conducted using standard checklist form designed to include the 18 quality criteria of 10CFR50, Appendix B, as appropriate.
Surveys of suppliers' capabilities include evaluation of management systems, manufacturing processes and adherence to QA/QV procedures. The results of supplier evaluations are documented by the appropriate checklist form and filed. Supplier control is maintained through a planned inspection, monitoring, and audit program by QA'. QA and the responsible engineer conduct a review of the manufacturing process for complex manufactured items, such as pumps, valves, heat exchangers, vessels, electrical panels, etc. This review establishes critical inspection points and establishes a notification point program for the identified inspection or surveillance activities. The established inspection or surveillance activities are implemented by qualified QA personnel or QA agents. Commercial Grade Items are dedicated in accordance with recognized industry standards, e.g. EPRI NP 5652. Monitoring of suppliers/contractors during fabrication, installation, modification, rework, repair, inspection, testing, and shipment of Q, F, and R-designated materials, equipment, and services, is conducted by qualified QA personnel or QA agents at the supplier' sf contractor's facility or at the generating station. Surveillances are conducted in accordance with written procedures and are designed to assure conformance with procurement requirements, in accordance with the safety significance of the item or service .
- HCGS-UFSAR 17.2-27 Revision B September 25, 1996
Periodic evaluations of the supplier/contractor quality program are conducted, consistent with the importance or complexity of the item or service. Dependent upon the evaluation, additional audits or corrections by the supplier/contractor may be required. Supplier's certificates of conformance are periodically evaluated by audit, inspection, or test to assure that they are valid. Results of these audits, inspections, or tests are documented. Where feasible, replacement parts adhere to the original design criteria (such as Nuclear Steam Supply System (NSSS) components in accordance with NSSS documentation and other code components in accordance with AWWA, AISC, SPCC, and ASME B&PV Code, Section III, 1971 and Summer 1972 Addenda or later) . This provides the intended level of safety, and does not result in redesign of the system. The requirement for appropriate supplier documentation of conformance to applicable code, standard, specification, or other quality requirements is provided by the procurement document. The supplier-provided documentation is reviewed either at the supplier's facility during source surveillance or by Material Compliance Group during material evaluation activities. A data review checkoff is used to document the acceptability of the supplier-provided data and to identify discrepancies. Evaluation of supplier equipment, material, and services is conducted by qualified personnel to verify correct identification, appropriate documentation, and to verify that the item is acceptable and can be released for storage, installation, or use. Nonconforming items identified by the Material Compliance Group are tagged or segregated to prevent inadvertent use. Nonconforming items are controlled as described in Section 17.2.15. 17.2.8 Identification and Control of Materials, Parts, and Components Procurement document controls provide assurance that materials, parts, and components received can be properly identified. The
- HCGS-UFSAR 17.2-28 Revision 8 September 25, 1996
identification is directly marked on the item, or on records traceable to the item. The data review conducted at receiving assures that proper documentation of received items is available. Materials and items received without proper identification are tagged or segregated until satisfactory documentation and identification is obtained. Procedures requfre Q, F, and R-designated materials, parts, and components to be marked or otherwise identified, and require that such identity be maintained either on the item or on records traceable to it throughout receipt, storage, installation, and use. Protection against use of incorrect or defective items is also provided. Material identification and traceability is maintained for rework, repairs, and modifications throughout operation. Organi2mtions whieh iH1pleH1ent requireffients for the identifieation and eontrol of Hlaterials, parts, and eoH1ponents inelude Nuelear Operations Serviees, Nuelear Engineering, station operations and QA for proeureff\ent doeuffient eontrols, and Proeureff\ent and Materials Hanagefftent, station operations aad QA for reeeipt, storage, installation, inspeetion and test aetivities.
,;m~nf::t:t::+s@tiw§Rt::::::\%#st1:::ssn&t1w;n;:::::::::::;9~::::::;:mi!~#:~H~i+/-'~:n::::::::::m¥:~i::t::::::::1:~P:f!if:ssmP:m#~ntiij?:rn::::~¥=$t:tJf:8~ ?f~~iin~W:s?i+/-ffi:~M:::ef.t:1isf::~~%:::::~ffin:~iJ~8s~%::1isi:~~*:rn~n~i!ia%~mim~wr:~&:B1::::m§s+/-m~%::~P&?in~i:~ .
- e#mm?r§::;::. : :M1tri?sPi#*F:'t:::?s?liffii&&tn1e@s#sW:m::::::*=r!:::::r5aff::::::'::B~~man~n;a#::+iw.:sm::::::::eF:':' m9.E~il%1:wx tt;~~HP!#H~#:&.\::fJ{~%$'!F~lJ:\\~'BA##$1~)\\\n!@~\S'i!ii+/-~!ffiiH:t::~m¥M!9!ffiB*i{\\~#f:::::::w,~:~~f\~\p§ffimffi~tt~~:J~#%,
1#Ma :w~:§m£n§:f:af'+ffi#¥:::::e;::::~is+3~¥:!¥H§:~~~~::::::~;i.F.~9#M~:t!ii?~M:::~ttl!Ilt¥9+/-£!f:::Hm¥a~~n~ns#:::;:: 17.2.9 Control of Special Processes Special process controls provide for the use of qualified procedures, equipment, personnel, and documentation of satisfactory completion of an activity. Special processes are generally those processes where direct inspection is impossible or disadvantageous. Procedures have been established for special processes such as welding, brazing, soldering, concreting, protective coating, cleaning, heat treating, and nondestructive examination (NDE) to assure compliance with codes and design specifications. The Senior Vice President - Nuclear Engineering is
- HCGS-UFSAR 17.2-29 Revision 8 September 25, 29*95
responsible for preparing special process procedures such as concreting, protective coating and cleaning, while the g~~~p~~k.~~~W##:-*f ~#S+/-~#~@Ms¥#~£:g~ Director Huclear Operations Services is responsible for preparing specifications for processes such as welding, brazing, soldering, and heat treating and . Nuclear Engineering is responsible for preparing specifications for non-destructive examination (NDE) . These specifications are reviewed and approved by QA_ for necessary quality content. QA monitoring assessments and audits assure that qualification of special processes, equipment and personnel have been satisfactorily performed. Procedures for implementing the requirements of the specifications are prepared either by the Nuclear Business Unit or by supplier personnel, and are reviewed by QA and the appropriate general manager or their designees, with the exception of special process procedures prepared by code suppliers holding a valid certificate of authorization. Qualification records of procedures, equipment, and personnel associated with special processes arc retained as stated in Section 17.2.17. 17.2.lO Inspection A planned inspection program is conducted and documented by personnel appropriately qualified in accordance with Section l 7. 2. 2. The inspection program verifies conformance to the established procedure, code, or standard, consistent with the item's or activity's importance to safety. The inspection program for maintenance and modification activities is based upon the following three important levels of inspection:
- l. Worker Checks Quality cannot be achieved unless the worker performs the activity in a quality manner. The worker is the individual best able to control the quality of work performed. Work steps that contain 17.2-30 HCGS-UFSAR Revision 8 September 25, 1996
elements impacting plant equipment or systems have provisions for signoff by the worker. This worker sign-off establishes accountability for the activity and is acknowledgement that the activity has been performed as specified in the work step.
- 2. Supervisory Inspection - Although the work supervisor may have overall responsibility for the conduct and performance of the work activity, certain conditions at the work location require supervisory inspection to increase confidence that work activities are completed as specified through familiarity of the work activity, work group, or past experience. Supervisory inspections are established in the appropriate work procedure and accomplished through direct observation of the work activity.
- 3. Independent Inspection - Independent inspections are not intended to dilute or replace the responsibility of the worker check or supervisory inspection for quality of work. Independent inspections provide the maximum confidence attainable that the work activity has been performed in accordance with the overall objective. Typical guidelines for establishing independent inspections include conditions similar to the following:
- Work activity affecting redundant equipment or potentially causing cascading failure.
Retest will not verify the applicable attribute. Establishing a baseline in a new process or procedure. It is deemed necessary to maintain confidence in the work process .
- HCGS-UFSAR 17.2-30a Revision 4 April 11, 1992
This guidance is considered by the responsible QA organization in the establishment of inspection activities . Independent inspections are identified as Inspection Hold Points (IHPs) in the applicable work instructions and are performed by individuals independent of the work activity. IHPs cannot be passed without authorization from the applicable management representative responsible for the inspection activity. General guidelines for the inspection criteria are established by QA and incorporated into various administrative and work instructions. Independent inspections are performed by QA or other individuals who are independent of the work activities. If the individuals performing inspections are not part of the QA organization, the inspection procedures, personnel qualification criteria, and independence from undue pressure, such as cost and schedule, are reviewed for acceptability by the QA organization prior to initiation of the activity. Work procedures and inspection instructions include, as required, characteristics to be inspected, method of inspection, acceptance/rejection criteria, required measuring and test equipment, and required reference documents. Documentation includes inspection identification and results of inspection performance . As a result of its review, the Station Operations Review Committee (SORC) may recommend additional or different hold points to the organization performing the work activity. Periodic inspection, other than IHPs, is performed by qualified individuals other than those who performed or directly supervised the activity being inspected. These typically include periodic inspections of the following:
- HCGS-UFSAR 17.2-30b Revision 4 April 11, 1992
- 1. Storage areas
- 2. Housekeeping (general)
- 3.
4. Fire protection equipment Special handling tools and equipment
- 5. NDE visual inspection required by the inservice inspection program.
An independent organization shall perform NDE as required, using qualified individuals other than those who performed or directly supervised the activity. When inspections are performed by individuals other than those who performed or directly supervised the work, but who belong to the same work group, and the activity involves breaching a pressure-retaining boundary, the quality of the work is demonstrated through appropriate testing, unless restrictions such as ALARA considerations prevent such testing. The applicable inspection and retest requirements necessary to assure that modifications, rework, or repairs have been accomplished correctly are included in the design change package, work order, or procedure. The inspection and retest requirements for modification, rework, and repair are based on the original inspection and test program, as well as the nature and scope of the modification or repair activity. Evaluation and review of inspection results are conducted by personnel certified Level II in ANSI/ASME N45.2.6 and SNT-TC-lA, as applicable. A planned and documented QA monitoring program is conducted by QA for Quality Program activities, including the inspection program and personnel qualifications. Monitoring of the
- HCGS-UFSAR 17.2-31 Revision 8 September 25, 1996
implementation of the QA program by station and site contractor personnel is conducted by QA, in addition to offsite supplier activities as appropriate. Conditions adverse to quality found during the conduct of monitoring are brought to the attention of the management responsible for the activity. The Manager - Quality Assessment, or designee, routinely attends and participates in plant work schedule and status meetings to assure that they are kept abreast of day-to-day work assignments throughout the plant and that there is adequate QA coverage relative to procedural and inspection controls, acceptance criteria, and QA staffing and qualification of personnel to carry out QA assignments. 17.2-32 HCGS-UFSAR Revision 8 September 25, 1996
THE INFORMATION ON THIS PAGE HAS BEEN DELETED .
- HCGS-UFSAR 17.2-33 Revision 4 April 11, 1992
THE INFORMATION ON THIS PAGE HAS BEEN DELETED .
- HCGS-UFSAR 17.2-34 Revision 4 April 11, 1992
17.2.11 Test Control Q, F, and R-designated equipment and components that must be tested periodically to assure satisfactory performance, or have been replaced, modified, or repaired, are tested by qualified personnel in accordance with written procedures that provide acceptance criteria based on requirements contained in applicable design and procurement aocuments. Provisions are implemented that assure that nonconformances are corrected or resolved prior to the initiation of the preoperational test program on the item. Retest requirements are provided by engineering specifications or the responsible engineer, or both as were the original test requirements. The Nuclear Engineering@I§g:S;\;~~f):!\M~)jl:p:f~#ffe,#,9,'~ and operations departments are responsible for preparation of test procedures incorporating the engineering parameters. Test procedures prescribe, as applicable:
- 1. Prerequisites, including completeness of test item(s)
- 2. Instructions for performing the test
- 3. Instrumentation and equipment for conduct of the test adequate to the test objective
- 4. Suitable environmental conditions and adequate test methods
- 5. Critical test sequence
- 6. Acceptance criteria.
- HCGS-UFSAR 17.2-35 Revision 8 September 25, 1996
Test results, including verification of above items, are documented and reviewed for acceptability by the qualified department representative. Syoteffl tests perferffled fellewiH§J ffledifieatiefis te Q, F, aHd R desigHated systems require review of toot proeedureo afid toot results by tJ::i.e SORG. The Nuclear Administrative Procedures Manual provides for the use of temporary changes which are controlled in accordance with Technical Specifications. Detailed instructions for implementation of temporary changes are provided. QA performs assessments of selected post modification tests to assure compliance with the test procedure. Test results are reviewed for the following:
- 1. Presentation of proper documentation
- 2. Assurance that tests meet objectives
- 3. Identification and reporting of unacceptable results and initiation of corrective measures.
17.2.12 Control of Measuring and Test Equipment Test equipment, instrumentation, and controls used to monitor and measure activities affecting quality and personnel safety are identified, controlled, and calibrated at specific intervals by cognizant Nuclear Business Unit personnel. Written procedures for meeting these requirements include provisions for:
- 1. Specifying calibration frequency
- 2. Recording and maintaining calibration records
- HCGS-UFSAR 17.2-36 Revision 8 September 25, 1996
- 3. Controlling and calibrating primary and secondary standards
- 4. Determining methods of calibration
- 5. Tracing use on safety-related items.
Measuring and test equipment (M&TE) calibration procedures are prepared in accordance with the applicable supplier's manual requirements, unless specific exemption is approved by the cognizant station department head. M&TE, which is so exempted, is identified by use of a label or tag on the item. Prior use of measuring and test equipment found to be out of calibration is evaluated for possible effect on safety-related items. Measurements are repeated where necessary. Secondary standards are calibrated by certified calibration laboratories and are traceable to the National Institute of Standards and Technology (NIST) , or best industry standards where no NIST standards exist. Implementing procedures will provide for documenting the basis of calibrations which are not traceable to NIST. To the extent permitted by the state-of-the-art, the accuracy of the primary standards used to perform this calibration are at least four times greater than the accuracy of the device being calibrated. The basis of acceptance is documented and authorized, with responsibility assigned to the cognizant department head . Test equipment is marked or otherwise identified to indicate a unique identification number, the latest calibration date and the 17.2-37 HCGS-UFSAR Revision 8 September 25, 1996
next required calibration date. Measuring and test equipment is identified by affixing a calibration label unless the size of the item makes this impractical . Out of calibration identification is used for instruments and controls to indicate this status pending calibration, repair, or replacement. Calibration frequency is based on the manufacturers recommendations. This frequency is adjusted when o~erating experience supports this action. Organizations responsible for implementing measuring and test equipment calibration controls include station, Nuclear t1\'@!#.:!@!iriaride Operatien:s Services, and Maplewood Testing Services. 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 specified, implemented and accomplished by suitably trained personnel in accordance with predetermined work and inspection instructions. Implementing procedures provide for the storage of chemicals, reagents (including control of shelf life), lubricants, and other consumable materials as required. The nuclear materials management group is responsible for control of material in storage, including preservation and shipping controls. The station departments ~9,i??~WRf~~#J]~~#~@1~#.§~ are responsible for system cleanliness and handling of equipment during operational
- maintenance or modification.
equipment requirements. Nuclear Engineering is responsible for specifying Manufacturer's instructions and recommendations, design requirements, and applicable codes and standards are implemented, as appropriate. Compliance with specific handling, storage, or shipping requirements is required. Requirements for new components and spares, where applicable, are included in the procurement documents .
- HCGS-UFSAR 17.2-38 Revision 8 September 25, 1996
17.2.14 Inspection, Test, and Operating Status Nuclear Business Unit procedures are required to specify the periodic tests and inspections required for equipment covered by the QA program, and to include the necessary management controls to assure that such required tests and/or inspections are completed in accordance with specified requirements. Equipment awaiting repairs, under repair, or repaired, and received materials are marked to indicate the status of inspection and test requirements and/or acceptability for use. Procedures provide for tagging valves and switches to prevent inadvertent operation. These procedures control the application and removal of tags and are designed to prevent operation of valves and/or switches that could result in personnel hazard or equipment damage. Valve and equipment status boards or logs are maintained to indicate status. 17.2.15 Nonconforming Materials, Parts, or Components Organizations involved in material receipt, installation, test, design modification and other operating activities are responsible for identifying, and documenting nonconformances. Nonconforming materials, where practical, are segregated to prevent installation or use until proper approvals are obtained. Materials, parts, or components that have failed in service are identified and, where practical, segregated. Procedures control the application and removal of tags. Documentation of the nonconformance includes a description of the nonconformance, review by SNSS §!:ffif:i!:)'::§*P~FtBB#:§~~g§!NSS for Limiting condition for Operation (LCO) applicability when appropriate and the disposition and inspection or retest requirements, as appropriate. The responsible Engineer dispositions each nonconformance report. Dispositions for repair or "use-as-is" are required to be reviewed and approved by QA prior to implementation. Rework or repair of nonconforming material, parts, 17.2-39 HCGS-UFSAR Revision 8 September 25, 1996
or components is inspected or retested or both in accordance with specified test and inspection requirements established by the responsible engineering representative, based on applicable requirements. QA shall verify the satisfactory completion of the disposition of nonconformances. QA and other organizations in the Nuclear Business Unit review nonconformance reports for quality problems, including adverse quality trends, 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 implement corrective action for significant conditions adverse to quality (SCAQ) and conditions adverse to quality identified within their scope of activity. such conditions are documented and controlled by issuance of an action request. The QA Corrective Action Group reviews responses to action requests for adequacy and monitors these action requests through periodic summary and status reports to management. Responses to action requests are based on the four elements of corrective action, which are:
- 1.
2. 3. Identification of cause of deficiency Action to correct deficiency and results achieved to date Action taken or to be taken to prevent recurrence
- 4. Date when full compliance was or will be achieved.
For significant conditions adverse to quality, such as LERs and NRC/INPO/CMAP findings, the QA Corrective Action Group is involved in the review of such conditions and provides oversight to assure timely 17.2-40 HCGS-UFSAR Revision 8 September 25, 1996
follow-up and close out. Items 3 and 4 are optional for conditions adverse to quality .
- Proper implementation of corrective action is verified through surveillance, inspection, assessment or audit, as appropriate.
The station '.~h,~.#~Mig#:jiiii,l';~ general manager SF!Hilf##,2&9#: is responsible for assuring that conditions adverse to quality are promptly identified and corrected for all activities involving station operation, maintenance, testing, refueling, and modification. Administrative procedures that govern station activities covered by the QA program provide for the timely discovery and correction of nonconformances. This includes receipt of defective material, failure or malfunction of equipment, deficiencies or deviations of equipment from design performance, and deviations from procedures. In cases of significant conditions adverse to quality, the cause of the condition is determined, and measures are established to preclude recurrence. Such events, together with corrective action taken, are documented and reported as described in Section 17.2.15. Corrective action is initiated by the responsible department head. QA closely monitors station conditions requiring corrective action. Repetitive deficiencies, procedure or process violations at the station that are not classified as operational incidents or reportable occurrences, or nonconformances under the QA program, are documented ~ via the issuance of an action request. This request provides a formal administrative vehicle to alert management of conditions adverse to quality that require corrective action .
- HCGS-UFSAR 17.2-41 Revision 8 September 25, 1996
17.2.17 Quality Assurance Records Records necessary to demonstrate that activities important to quality have been performed in accordance with applicable requirements are identified and maintained in accordance with Regulatory Guide 1.88, as noted in Section 17.2.2. Records shall be considered valid only when authenticated by authorized personnel. Record types as a minimum, comply with applicable technical specification requirements and include operating logs, maintenance and modification procedures and related inspection results and reportable occurrences. The Nuclear Business Unit is responsible for the permanent storage of station records. The retention period for records; 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 designated location for retention. 17.2.18 Audits Audits of PSE&G and supplier organizations that implement the QA program are performed by QA to verify compliance with the applicable portions of the program, through personnel interview, observation of activities in process, and review of applicable documents and records as required. Performance based assessment should be an integral part of the auditing program and should evaluate activities on the basis of their effect on the safe and reliable operation of the facility. An annual audit schedule is developed to identify the audits to be performed and their frequency. A dominant factor in audit schedule development is performance in the subject area. Audit schedules are revised so that weak or declining areas receive increased audit coverage and strong areas receive less, consistent with the audit schedule frequency requirements of the Code of Federal Regulations and the UFSAR. Audits of the selected aspects of operational phase activities are performed with a frequency commensurate with safety significance and in a manner to assure that at least biennial (2 years) audits of safety related activities are performed. A list of operational phase activities subject to the audit program is provided in the Technical Specifications f#:§pjg:f:9~Hiif]:::;:if:@Wl::ff§:::f~ and in Table 17.2-1. Audits are conducted by audit teams comprised of a certified lead auditor and certified auditors, and technical specialists (when deemed necessary) .
- HCGS-UFSAR 17.2-42 Revision 8 September 25, 1996
Audits are conducted using preestablished written procedures and checklists. Areas of deficiency revealed by audits are reviewed with management and are corrected in a timely manner. Required corrective action is documented and
- verified. Followup action, including reaudit of deficient areas, is performed.
The audit program conducted by QA 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 and requisition documents, instructions, procedures, and drawings
- 3. Inspection programs
- 4. Indoctrination and training
- 5. Implementation of operating and test procedures
- 6. Calibration of measuring and test equipment
- 7. Fire protection
- 8. Other applicable activities delineated in Table 17.2-1.
The audit data is analyzed and a written report of the results of each audit is distributed to appropriate management representatives of the organization(s) audited, as well as other affected management personnel. Included in the report is a statement of QA program effectiveness. QA is audited by independent auditors at least every two years to verify implementation of the corporate QA program. Reports of these audits are directed to appropriate PSE&G management personnel. 17.2-43 HCGS-UFSAR Revision 8 September 25, 1996
TABLE 17.2-1 HOPE CREEK Q ACTIVITIES/SERVICES
- The listing below identifies those activities and Operational QA program applies during operations:
A. Safety-related activities delineated in services, Regulatory to which Guide the
- 1. 33, Appendix A (See Regulatory Guide for further guidance on these activities)
- 1. The procedures that define safety-related processes and programs, and that provide for the control of nuclear operations, and that incorporate regulatory requirements and commitments, will be called administrative procedures. Refer to Section 13.5.1. The following is a partial list of safety-related administrative procedures:
(a) Security Program, (Regulatory Guide 1.77) (b) Equipment Control, e.g., locking and tagging (c) Shift and Relief Turnover (d) . Bypass of Safety Functions and Jumper Control (e) Maintenance of Minimum Shift Complement and Call-In of Personnel (f) Fire Protection Program (FPP) including Inspection by Fire Consultants (g) Communication System.
- ~:~M:::]=]:]:§:;:w~:f:ae:rm@#i~w;11@w~1:::ti#Mi!@!t:smmm11w;~:~:@::r::i::1:2mwi:::
- ~:~@::::::::::::~~:~~:~~l'.F:e&:1@@!!¥!w:ri2:g¥f:Mtf:e~r:
- 2. The general plant operating Procedures at Hope Creek will be called Integrated Operating Procedures (IOPs) . Refer to Section 13.5.2.1.2.
- 3. The procedures for startup, operation and shutdown of safety related BWR systems at Hope Creek will be called System Operating Procedures (SOPs) . Safety related BWR systems for Hope Creek are designated as QA required in Table 3. 2-1.
Refer to Section 13.5.2.1.1.
- 4. The procedures for offnormal or alarm Conditions of safety related BWR systems at Hope Creek will be called alarm response procedures. Safety related BWR systems for Hope Creek are designated as QA required in Table 3.2-1. Refer to Section 13.5.2.1.4.
1 of 3 HCGS-UFSAR Revision 8 September 25, 1996
TABLE 17.2-1 (Cont)
- 5. The procedures for combating emergencies and other significant events, at HCGS will be broken down into two categories:
Emergency Operating Procedures (EOPs) and Abnormal Operating Procedures (AOPs). Refer to Section 13.5.2.1.3.
- 6. The procedures for the control of radioactivity will be broken down into several types to facilitate their use by the appropriate personnel. Structures, systems, and components that control the discharge of solid, liquid, or gaseous radioactive waste to the environment are designated as Quality Group R in Table 3. 2 -1. Refer to Section 13. 5. 2. 2. The following is a representative list of procedures and systems related to the control of radioactivity:
(a) Liquid Radioactive Waste System (b) Solid Waste System (c) BWR Gaseous Effluent System (d) Radiation Protection, including Occupational Radiation Exposure per Regulatory Guide 8.8 (e) Area Radiation Monitoring System Operation (f) Process Radiation Monitoring System Operation (g) Meteorological Monitoring and Data Collection Program (h) Packaging and Transport of Radioactive Material per 10CFR71 (i) Decontamination.
- 7. The procedures for performing Technical Specification required surveillances will be broken down into several types to facilitate their use by the appropriate personnel. Refer to Section 13.5.2.
- 8. The procedures for performing maintenance on safety related BWR systems at Hope Creek will be called maintenance procedures.
Safety related BWR systems for Hope Creek are designated as QA required in Table 3.2-1. Refer to Section 13.5.2.2.5.
- 9. The procedures for chemical and radiochemical analysis, sample collection, maintenance of coolant quality, and maintaining concentrations of harmful agents within prescribed limits will be called chemistry procedures. Refer to Section 13.5.2.2.1 .
- HCGS-UFSAR 2 of 3 Revision 8 September 25, 1996
TABLE 17.2-1 (Cont) B. Additional NRC requirements
- 1. Technical Specification Administrative Controls (a) StatieE: OperatieE:s Review Celftlftittee (SORG)
(b) .Nuclear Safety Review (c) Reportable occurrences.
- 2. Inservice Inspection Plan
- 3. Reporting of Defects and Noncompliance.
- 4. Modifications to Site Grading.
3 of 3 HCGS-UFSAR Revision 8 September 25, 1996
TABLE 17.2-2 SEISMIC II/I -DESIGNATED STRUCTURES, SYSTEMS, AND COMPONENTS A seismic II/I designation is incorporated on the following design document types:
- a. Drawings
- 1. System isometrics
- 2. Area drawings
- 3. Concrete unit masonry details
- 4. Heating & ventilation duct layout
- 5. Control room ceiling layouts
- 6. Floor plans
- 7. Miscellaneous steel drawings
- 8. Piping and Instrumentation Diagrams (P&ID's)
- b. Indices
- 1. Pipe line index
- 2. Equipment index
- c. Specifications
- 1. Acoustical unit ceilings
- 2. Insulation for reactor pressure vessel (RPV) and drywell piping equipment The Seismic II/I identification on drawings and indices is provided in the detail of the document, as necessary, to define "Q" items/boundaries. A "Q" suffix is added to the drawing number of those drawings that identify application of the Seismic II/I QA program.
The Seismic II/I identification on specifications consists of adding a "Q" suffix to the specification number. 1 of 2 HCGS-UFSAR Revision 4 April 11, 1992
TABLE 17.2-2 (Cont) Seismic II/I structures, systems, and components are further delineated in Table 3.2-1 .
- HCGS-UFSAR 2 of 2 Revision O
TABLE 17.2-3 F-DESIGNATED SYSTEMS An "F"-designation system is incorporated on the following design document types as a minimum:
- a. Drawings
- 1. P&IDs for Fire Protection System (FPS)
- 2. FPS safety-related area drawings
- 3. Fire wall location drawings
- 4. Structural steel fireproofing drawings
- 5. Concrete unit masonry details
- 6. Penetration seal details
- 7. Door hardware schedules
- 8. Lighting notes, symbols, and details
- 9. Lighting and telephone plans
- 10. FPS isometrics.
- b. Indices
- 1. Pipe line index
- 2. Equipment index
- 3. Instrument index
- 4. Valve index.
FPS-QA identification system incorporation on drawings and indices is provided in the detail of the document, as necessary, to define "F" items/boundaries. An "F" suffix is added to the drawing number of those drawings that identify application of the FPS-QA program. Specifications are as follows: Deluge water spray and sprinkler system Fire and smoke detection system HCGS-UFSAR 1 of 2 Revision O April 11, 1988
TABLE 17.2-3 (Cont)
- Carbon dioxide systems Installation of carbon dioxide system Portable extinguishers Hose racks for wet standpipe system Horizontal fire pumps Fireproofing of structural steel FPS-QA identification system incorporation onto specifications consists of adding an "F" suffix to the specification number.
Fire Protection Systems, including emergency lighting and communications, are I further delineated in Table 3.2-1 .
- HCGS-UFSAR 2 of 2 Revision 4 April 11, 1992
TABLE 17.2-4 R - DESIGNATED SYSTEMS
- The letter "R" shall be used to identify items of the Radioactive Waste Management system which protect the health and safety of the public, and plant operating personnel from uncontrolled discharge of solid, radioactive waste to the environment.
liquid, or gaseous The radwaste management systems classified as quality group R shall be designated by the use of R-flags on piping and instrumentation diagrams. Quality group R standards shall be those provided in Regulatory Guide 1.143. Radwaste Management Systems are further delineated in Table 3.2-1. 1 of 1 HCGS-UFSAR Revision 4 April 11, 1992 April 11, 1988
- QUALITY ASSUHANCE/NUCLEAR SAFETY REVIEW MANAGE II MANAGER MANA MANAGER conn EC TIVE /\C TIOtl A QUALITY ASSESSr.IEtH QUALITY SESSMENT EMPLOYEE COtlCERNS OU/\LITY SEHVICES -illO.u:cft E 6Jq ALEM)
/(~C4Ct. fAft r;i;t/4t 17.z-J l) fnJ ~ Trt1 c I/£ LJ, PUOLIC SERVICE ELECTRIC AND GAS COMPANY tlOPE CREEK tlUCLEAR GENERATING STATION QUALITY ASSURANCE/
tlUCLEAfl SAFETY REVIEW Updalrd FSl\R Rrvlslon 0, S'pltm~r 25, I 99G r1uu1117.2*1
- QUALITY, NUCLEAR TRAINING &
EMERGENCY PREPAREDNESS CHIEF NUCLEAR OFFICER & PRESIDENT - NBU DIRECTOR - QUALITY, NUCLEAR TRAINING AND EMERGENCY PREPAREDNESS lNRB ~---------, I I I I I I I MANAGER QUALITY PROGRAM MANAGER MANAGER ASSESSMENT MANAGER-NRB CORRECTIVE ACTION EMPLOYEE CONCERNS TECHNICAL OPERATIONS EMERGENCY TRAINING/SERVICES TRAINING PREPAREDNESS MANAGER MANAGER MANAGER PUBLIC SERVICE ELECTRIC AND GAS COMPANY SALEM NUCLEAR GENERATING STATION QUALITY, NUCLEAR TRAINING LEGEND: & EMERGENCY PREPAREDNESS REPORTS TO Updated FSAR Figure 17.2-1 Revision 8 Sheet 1 of 1 COORDINATION September 25, 1996
Document Control Desk LR-N970364 Attachment 3 PROPOSED SALEM CHANGES
17.2 QUALITY ASSURANCE DURING THE OPERATIONS PHASE Public Service Electric and Gas Company (PSE&G) is responsible for assuring that the oper-;ci.tion, maintenance, refueling, and modification of the nuclear generating
- stations are accomplished in a manner that protects public health and safety and that is in compliance with applicable regulatory requirements. To carry out this responsibility, PSE&G developed and implemented a comprehensive Quality Assurance (QA) Program tnat was applicable to the design, construction, and testing phases and is now applied to the operation phase.
The Operational Quality Assurance Program is described in the following doeumento:
- 1. NC.VP PO.ZZ OOlO{Q), Operational Quality Aoouranee Program establishes the Quality Assuranee Program.
~ Nuclear Administrative Procedures Manua1:~J:l'.!:J§f::~::::miiffiB~UJi$,Y,i~~g)!;Ji,~~
~P.$i))-documents the programs and processes that implement the QA Program.
The QA Program provides measures to assure the control of activities affecting the quality function of structures, systems, and components, to an extent consistent with their importance to safety. The Quality Assurance Program encompasses fire protection of safety-related areas and other activities
- enumerated in Regulatory Guide 1.33.
Program. An assessment A planned monitoring assessment and audit program assures effective implementation of the Operational Quality Assurance is a direct observation of activities and review of documentation to verify compliance/conformance to specified requirements and effectiveness of processes. The program provides coordinated and centralized quality assurance direction, control, and documentation as required by Nuclear Regulatory Commission (NRC} criteria set forth in 10CFRSO, Appendix B. The program provides for monitoring, assessing and auditing elements of the Fitness-For-Duty (FFD} Program as set forth in 10CFR26 and is applied to, and includes non Q-list (i.e. balance of plant} activities and services necessary to achieve safety, reliability, availability, and economy in the operation of the Salem Generating Station. Applicable NRC Regulatory Guides, codes, and standards, as well as the policy statements contained in the Nuclear Administrative Procedures Manual, are used by PSE&G organizations performing activities affecting safety to prepare appropriate implementing procedures. To assess the effectiveness of the PSE&G Quality
- SGS-UFSAR 17.2-1 Revision 15 June 12, 1996
Assurance Program, independent auditors from outside the company audit the program every 2 years for compliance with 10CFRSO, Appendix B, and other regulatory commitments. Reports of such audits are made directly to upper management. Quality Assurance (QA) policy statements are issued by key management representatives~ including the Chairman and Chief Executive Officer and the Chief Nuclear Officer and President - Nuclear Business Unit (CNO/PNBU). These policy statements are mandatory throughout the Company for nuclear facilities. Key policy elements, as they apply to nuclear safety, include the following:
- 1. Nuclear safety is of the highest priority and shall take precedence over matters concerning power production.
- 2. The public's health and safety is the prime consideration in the conduct and support of PSE&G's nuclear operations and shall not be compromised. All decisions which could affect the health and safety of the public shall be made conservatively.
- 3. The Operational Quality Assurance Program is an essential part of the PSE&G commitment to safe and reliable nuclear power operation.
Applicable program requirements shall be strictly adhered to in the performance of activities covered by the Operational Quality Assurance Program. PSE&G requires its suppliers and contractors to assume responsibility for establishing and implementing Quality Assurance/Quality Verification (QA/QV} programs, as applicable, to meet 10CFRSO, Appendix B. However, responsibility for the overall QA program is retained and exercised by PSE&G. QA reviews those programs and conducts appropriate monitoring and auditing as required to assure that the suppliers are properly implementing
- SGS-UFSAR 17.2-2 Revision 15 June 12, 1996
their QA/QV programs. The Operational QA Program verifies that requirements necessary to assure quality are properly included or referenced in procurement documents. In addition, these suppliers' procurement documents include applicable PSE&G quality assurance requirements for items and services provided by their suppliers. 17.2.1 Organization The Operational QA Program, referred to hereafter as the QA Program, assures that adequate administrative and management controls are established for safe operation of the station. Implementation is assured by ongoing review, monitoring, assessment and audit under the direction of the Director - Quality Aoouranee/Nuelear Safety Review,
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Company organization is shown on Figures 13.1-1 through 13.1-9 and 17.2-1. Responsibilities for activities affecting quality are described in the following sections. 17.2.1.1 Nuclear Business Unit The Chief Nuclear Officer and President - Nuclear Business Unit (CNO/PNBU) is responsible for managing and directing the nuclear activities of the company. Overall duties and responsibilities of the Nuclear Business Unit (NBU) are provided in Section 13. 1. Vice Presidents, Directors and General managers reporting to the CNO/PNBU are responsible for implementation of QA requirements by their staff. These QA requirements are contained in the Nuclear Administrative Procedures Manual and individual department documents. The CNO/PNBU regularly assesses the scope, status, adequacy, and compliance of the QA program to 10CFRSO, Appendix B, through:
- 1. Frequent contacts in staff meetings, QA audit reports, audits by independent auditors, NRC inspection reports, department status reports.
17.2-3 SGS-UFSAR Revision 15 June 12, 1996
- 2. An annual assessment of the QA program that is preplanned and documented. This assessment addresses the scope, status, and adequacy of the QA program. Corrective action is identified and
- l7.2.l.l.l tracked.
Quality Assurance The DIR QA/HSR P;i:#*-'Stii?.@ :jj:fffS1#¥:!i*=1fiM{: ti')t:::~f:fl §R is responsible for defining, formulating, implementing, and coordinating the QA program. The DIR QA/NSR ff~ has been-delegated the authority and has the independence to interpret quality requirements, identify quality problems and trends, and provide recommendations or so 1 u ti ons to quality probl ems::::'BP:;:~fIB\)),~%~%~:\i:@=g~@\\\ ~hB~~i!fa}fili:f:R~!::;~\F#~~ BPS#}f: g$#.f:gi\#1##§Ji. The DIR QA/HBR ffW is responsible for approval of the QAf afffi NSR Department Manual ~ used during the operations phase of the nuclear stations{ The DIR Q."./N'BR ff~ also is responsible for verifying compliance with established requirements for the QA program through document review, inspection, monitoring, assessments and audits ne£::::@+/-t!Ji$~\f:i::::~¥,s~!ifif~fM~!~fa!tl§#!t9.NM?i#~~:!ifam~#':::mw§\%§#ti#i:PH:' QA provides a centralized coordinating function for QA/QV activities applied to the operations phase. The DIR QA/~rnR:::,:::::¥w#ffe:Bt8ittP~ :::::::©.B.$f.\ffi#:¥foii ::::::ffl¥)t:::rniue: \]:~E has the authority and responsibility to stop work, through the issuance of a Stop Work Order, when significant conditions adverse to quality require such action .
- The PSE&G policies Directop* "*..; * ~a.Ji.ityj, and organization
\])!::::m:;;::::::::i\@Rg!\\]f:lt'!
independence to carry out his responsibilities. has structure sufficient assure that organizational the DIR QA/N'BR, freedom and Wfii~i¥1H++:::::ffe:~P:ffea£ils¥te#:::::::t)~~::::::P:~ilws§ep:=:::*~@11vJffl:r~t!J:::#:¥i?£sf=B:tafi!::::@.!it~sP::~1KJl!%:i#:~t:~nstnw+/-+.: s!i~~rtJ;@:s~s~W:s~==:::?i!#:w::::r;w:~tJ@~n:t:g~:::::~e:s~:Yffi#::t~~m:::::::::=tnt£n~:::::~m~:~::=:::P::tt%,:rn;mm:1:f::1:w&::;::::m1~::'::W4i1m;: e::¥t+/-~%%£~:::::~+/-+/-::::R:E::::~s£e@riMB¥:::::~91:::::~s~r~p,%,Y:~%:::;:::::9E~+/-:~:*=¥J:w*=%~ffe:~~w*=:t&::f:::::::B$s~%~~w:n:::::::&1~: mm~$.:~r::::r: :~9~+mt&::::oo@:!:§§m#:ffe:wtaimttait~r#m2:;~~x' :!Se.2&¥w2:;:18:::::ew;@:s~+xt92mg1~=::::m~M:~~11 f:BP :#~~~~'!'!ffi4f$~~~M Responsibilities of the Manager - Corrective Action and Quality Services include the following:
- 1. PreparatieR aRd H1aiRteE:aRce of the QA/NBR DepartffleRt MaRual, the QA Preg:raffl deooription in the UFB.".R, and the Operational Q.~ Program desoription in the nuclear Aeifflinistrative Procedures Manual.
- 2. Review of the Nuclear Administrative Procedures HaRual for compliaRce with the Operational QA Prograffl.
- 3. Performing assessments of PSE&G Program administrative and implementing:
procedures (as necessary, these assessfflents may also iRclude statioR administrative and implementing: procedures) .
4.
- eaet1:etiag Qi'\ Pregraff\ erieatatiea fer ~ID :i?ersen.
g Rel aeff\iHis teriag the traiaiH§' aHe eertifieatieH pre§'raff\ for Q.7'* :i?ersonnel iHvelved iH iHspeetioH, assesslfteHts aHd at1:eitiHg aetivities, fflaiHtaiHiHg the QA traiHiHg :i?laH, aHe fflaiHtaiHiH§' Q."i: traiHiH§' reaords . SGS-UFSAR 17.2-4 Revision 15 June 12, 1996
S. Review of new regulatory requirements for QA Program impact.
- 6. Coordination of tfie cofflff!itment verification program on a selected basis.
- 7. Administration of tfie Nuclear Repair Program.
B- i. Review of -engineering documents such as equipment specifications, *.veld procedures, etc. for inclusion of QA requirements .
.g. it. Review and approve specifications for Q-listed materials, equipment, and services.
M$. Review of procurement documents for insertion of applicable QA requirements.
+/--+/-*=. Conduct of supplier surveys, audits and surveillances. ~§. Evaluation of prospective and existing Supplier QA Programs. -3:-3-~L Administration of the Corrective Action Program. -+/-47. Performing statistical analysis trend reports for management. +/--5-g. Monitoring/auditing of nuclear fuel fabrication and installation. ~~- Review of NEU fuel specifications for inclusion of QA requirements. +/--:7-ib..
Perform material evaluation activities on items subject to the QA Program. Responsibilities ~i#?,)jij~@~H\§#ffi:B:f:$~ of the Manager - Quality Assessment include the following:
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- SGS-UFSAR 17.2-5 Revision 15 June 12, 1996
- +/-~. Development and implementation of the QA Audit and Assessment Program.
~5. Performing assessments of contractor activities and evaluation of emergent contractor programs and procedures. ~:. Planning and scheduling of surveillances conducted within the Nuclear Business Unit.
47:. Performing station procedure review and concurrence. 5;i4; * ~:m~o~~~q~~;;.'.':t6~.:~$.;~~t.~+/-$#.:§:~::;:;,'.,pili,;f=~i*'~rf ormance'W\~#9?:@\iMf:*=!~ffi[@;
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Performing design change package pre-implementation review and closure review for compliance with Inspection Hold Point (IHP) requirements. Performing Performance Based Inspections'/ .*.*.: (IHPs)
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Rcspoasibilitics of tfic Haaagcr Nuclear Safety Review arc described ia Scctioa 13.1. Reopoaoibilitieo of tfie Haaager Liceaoiag aad Regulatioa are described ia Scctioa 13.1.
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Responsibilities of the Manager Employee ConcernsM*!!itJ*:E8#:J::]L1'.~RPmffiPai: w;~w.P!m$.*l*~~@!f*=i~~~ ::*m#:al~~¥W*Jt:tfaf****9Bij&##:fR.ii**?rw~%P!~i~:*:r!f.mg$.~t;:~********~asM***~a~]**wn~m§ns¥ Jfp~J?:%ij~Wfi~~***:*:M~~~~p are described in Section 13. 1. 17.2.1.1.1.1 Quality Assurance Personnel Qualifications The DIR QA/NsR:));1,\QMis;9#J:fi]@m;;g;,p}t:M*::::~wm::rn~#~9tM~! and the QA managers reporting directly to him tfie DIR QA/N"SR must each have a combination of 6 years of experience in the field of QA and operations. At least 1 of these 6 years of experience must be in the overall implementation of a nuclear power plant QA program. A minimum of 1 year and a maximum of 4 of the 6 years of experience may be fulfilled by related technical or academic training. Personnel performing inspections, examinations, and test activities (i.e., to verify conformance) are certified as Level I, Level II, Level III as appropriate to their responsibilities, also in accordance with Regulatory Guide 1.58. Personnel performing quality assurance audits are certified as auditors or lead auditors as appropriate to their reponsibilities in accordance with Regulatory Guide 1.146. wn~* :w;l.a%:f::ffi¥*f*~iffiii!*:***:*:e*~m*:*:En3:*:****?:~£~~;::::*::mi2Bsmwn~t*:&n~:::::**e~:%:f::~:rn::fns~R~m9~e~**Jt*~mffi~!
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17.2-6 SGS-UFSAR Revision 15 June 12, 1996
The DIR QA/UsRpgpfi\:i#P:!',&@*gp::f:!f:Y=~ ~; ~g-~y fulfills the above qualifications with the addition of the following:
- 1.
2. Knowledge and experience in quality assurance::\~BBlJ~~f:~otY. High level of leadership, with the ability to command the respect and cooperation of company personnel, suppliers, and construction forces.
- 3. Initiative and judgment to establish related policies to attain high achievements and economy of operations.
17.2.1.1.2 Operational Review
&t+/-@iif:@g~~m~:::::::~@ :*~ms~PiRP~~:t:P~fii!@)~9i:]f!f;jjj\iP~BfmfBW+/-i]i§;g~ffiffipffi~!ffi8\i~J:::~lru~:,::e~$;#:~
sn~farn:sP::n::1~w;:;w1~:::::a~: '#~x*~8%~::::~:::~9£B#.1~9!l?W=;w~M:Pi~s!iW#t:tft::imrn~m~mmrn; :i#!+m~NJ:J::Three advisory groups, the Station Operations Review Committee (SORC), ~q~~:j:':\~:ffep;:li:#.## R~NWmwf¥:fig#a:::::r~~:t:I \¥i.e::::9.!~:~@:#¥P¥iffiffe:§~m~n%.f :::~g:~~m:::::::~:P~#:!~§:tw~!.w@ai.§tim P&fi\1~i¥n! i~ Onsite Safety Review Group (SRG) , and the Offsite Safety Review Group (OSR) , are responsible for reviewing and evaluating items related to nuclear safety. The overall responsibilities of these groups are described p~$$.w **:*:.:*:*:*:*:*:*****:*:*:**** in Section 13.4. . The Manager Quality Assessment is ~~~tirn#~lfilii:\j\\\~lfili:i!$~~Th~~\l~\pinvited to all SORC meetings and receives the minutes of the meetings, attends the meetings periodically. m~::':W~¥t= 2¥:t@#'§::9!f:¥J~:f:#m':::ffiA?~g#:!ruM~P:'::::¥!¥wi::::¥s#.sf:'ffi£¥:~:::rn!at:m!:::::::¥::#:::,:::g~~w?P.i~w§+~ :;at: ffe:+/-~2:s1¥:sJmr~~li1::~mfa~itH]@:?a~w~#a!M~:w:t:ifilsJ;:s*:::::B¥tF::M~:tfm::::B.i1!:tt~:~ffi8¥iiMt::]Jf.1r#!W:§:~::::;~:RiBm:§r~£~ gmn~wl%++/-x]:ssB;9§si$9:::::a¥t:g,~:@¥ia~P::::::m::::::s;B$.jp;~:~:~ns~::i:: 17.2.1.2 P4aplewood Teotinq Servieeo The P4anager Haplewood Testing Services reports to the Director Business and Maintenance Services in fossil generation. Maplewood Testing Services performs calibrations, analyses, and O"<l'aluations on systems, equipment, and materials, as requestee by PSB&G departments, and maintains compliance with its quality assurance program .
- SGS-UFSAR 17.2-7 Revision 15 June 12, 1996
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17.2.1.3 Distribution Systems Department The Vice President - Electric Distribution Systems reports to the Senior Vice President Transmission and Distribution . The Distribution Systems Department is responsible for providing support to Salem operations for setting and testing protective relays for the external vital power supplies at the station. SGS-UFSAR 17.2-8 Revision 15 June 12, 1996
17.2.2 Quality Assurance Program
- The QA program is designed to comply with the requirements of 10CFR50, Appendix B, and with fire protection program requirements of Appendix A of Branch Technical Position No. 9.5-1. This program is applied to items and activities delineated in the Salem Q-List that public. During the can affect the health and safety of the 17.2-Sa SGS-UFSAR Revision 14 December 29, 1995
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THIS PAGE INTENTIONALLY BLANK 17.2-Bb SGS-UFSAR Revision 11 July 22, 1991
operational phase, this includes:
- 1. Structures, systems, and components delineated in Table 17.2-1, Section 2.
- 2. Safety-related activities delineated in Regulatory Guide 1.33 and summarized in Table 17.2-1, Section 1.
- 3. Portions of structures, systems, and components whose continued function is not required, but whose failure, caused by a safe shutdown earthquake (SSE), could reduce the functioning of a Seismic Category I structure, system, or component to an unacceptable safety level; or could result in an incapacitating injury to occupants of the control room as shown in Table 17.2-1.
- 4. Fire protection systems, including emergency lighting and communications, as shown in Table 17.2-1.
- 5. Radwaste management systems as described in Table 17.2-1.
The QA program is applied during the operational phase using a graded approach to the extent consistent with the item's or activity's importance to safety. These activities are performed in compliance with applicable regulatory requirements that include but are not limited to:
- 1. Regulatory Guide 1.8, Qualification and Training of personnel for Nuclear Power Plants.
- 2. Regulatory Guide 1.17, Protection of Nuclear Plants Against Industrial Sabotage.
- 3. Regulatory Guide 1.29, Seismic Design Classification.
- 4. Regulatory Guide 1.30, Quality Assurance Requirements for the Installation, Inspection, and Testing of 17.2-9 SGS-UFSAR Revision 15 June 12, 1996
Instrumentation and Electric Equipment.
- 5. Regulatory Guide 1. 33, Quality Assurance Program Requirements (Operation) 6.
Regulatory Guide 1.37, Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water Cooled Nuclear Power Plants. 7. Regulatory Guide 1.38, Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Water Cooled Nuclear Power Plants.
- 8. Regulatory Guide 1.39, Housekeeping Requirements for Water-Cooled Nuclear Power Plants.
- 9. Regulatory Guide 1. 54, QA Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants.
- 10. Regulatory Guide 1.58, Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel.
- 11. Regulatory Guide 1. 64, Quality Assurance Requirements for the Design of Nuclear Power Plants .
- 12. Regulatory Guide 1. 88, Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records.
- 13. Regulatory Guide 1.94, Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel during the Construction Phase of Nuclear Power Plants.
- SGS-UFSAR 17.2-10 Revision 10 July 22, 1990
- 14. Regulatory Guide 1.137, Fuel-Oil Systems for Standby Diesel Generators.
- 15. Regulatory Guide 1.144, Auditing of Quality Assurance Programs for Nuclear Power Plants.
- 16. R~gulatory Guide 1.146, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants.
- 17. BTP 9.5-1, Appendix A, Guidelines for Fire Protection for Nuclear Plants Docketed Prior to July 1, 1976.
Commitments to Regulatory Guides, with respect to revision level, exceptions, etc, are contained in Section 3, Appendix 3A. The code QA requirements are used for the procurement of systems, components, and structures covered by ASME Boiler and Pressure Vessel Code B31.l and B31.7 or evaluated to be an acceptable replacement. The standard QA program controls apply to Q-Listed code items following receipt at the station. In addition, applicable requirements of Regulatory Guide 1. 38 are applied to ASME Code procurements where necessary to assure safe shipment. Substantive changes to the QA program described herein will be submitted to the NRC within 30 days of implementation. Nonsubstantive changes will be identified in the annual UFSAR updates. 17.2-11 SGS-UFSAR Revision 15 June 12, 1996
The station General Manager has instituted and will maintain a station administrative procedures (SAP) manual. Regulatory Guide 1.33 requires that plant activities affecting quality-related items and services be conducted in accordance with written administrative controls prepared by management. The procedures and instructions by which plant activities are performed are prepared by the responsible organization as required by the Nuclear Administrative Procedures Manual, reviewed by the organization responsible for the activity, reviewed as required by QA and SORC, and approved by the department manager. Nuclear Administrative Procedures (NAPs) and station APs and all subsequent revisions thereto are reviewed by QA and SORC and are approved by the station General Manager. Procedures cannot be implemented unless the review/approval process is accomplished. The Nuclear Administrative Procedures Manual provides a means to accommodate on-the-spot changes to subtier implementing procedures. The routine practice for revising a procedure is to repeat the original review and approval sequence. Implementation of the QA program is verified by means of independent inspections, assessments, monitoring, and audits conducted by QA. QA reviews and analyzes problems affecting quality that occur during the operational phase. Items subject to review include:
- 1. Documented nonconformances occurring at the supplier's facility and those identified during receiving, storage, installation, test, and operation, e.g., Deficiency Reports, Nonconformance Reports, Work Orders, Licensee Event Reports, etc.
- 2. Documented corrective actions taken on conditions adverse to quality and actions to prevent recurrence on significant conditions adverse to quality.
- 3. NRC inspection findings, notifications, bulletins, etc.
17.2-12 SGS-UFSAR Revision 15 June 12, 1996
The DIR Q.'\/NBR ,rf;f;(zj~tjtj§#*: ~ *QE~@if~y, ~F i:l;t,id; ?:El\ i:i.;:i;4 . ~~~ ~~'$¢:!'. H91.l~fity ~§:$~\~fi~#i~#¢or pp.~;; designee~, ftae- J.:%y.E; the authority to stop work through the issuance of a Stop Work Order where continuance of an activity would seriously compromise quality or constitute a persistent and deliberate failure to correct a significant condition adverse to quality. Designees include the Manager Quality Assessment for activities conducted at the station and the Manager Corrective Actien and Quality Cervices for supplier activities. QA reports significant conditions adverse to quality affecting the quality assurance program to respective management, along with:
- 1. Measures taken to improve QA program controls.
- 2. Appropriate recommendations to achieve compliance with applicable requirements.
Management policy and administrative procedures provide all personnel with awareness and direction for reporting of defects and noncompliance pursuant to 10CFR21. The QA program requires that safety related activities and activities affecting the fire protection of safety-related areas, be accomplished under suitably controlled conditions. The program takes into consideration the need for procedures, special controls, cleanliness, special processes, test equipment, tools, and skills to obtain the required quality and the verification of quality by inspection, test, examination, monitoring, assessments and independent review and audit. These activities include, but are not limited to, designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, reworking, repairing, refueling, and modifying. Personnel who have the responsibility to implement the QA program also have the responsibility and authority to escalate unresolved quality problems to the level of management necessary to effect resolution. Escalation is applied by QA personnel to increasingly higher levels of management, up to the CNO/PNBU, as required. 17.2-13 SGS-UFSAR Revision 15 June 12, 1996
Personnel performing Q-Listed activities are trained or indoctrinated as necessary to assure that suitable proficiency is achieved and maintained. Personnel outside the QA organization who perform inspections and tests are trained and qualified in QA concepts and practices. Orientation is provided for new employees entering QA from other organizations within PSE&G and. from outside the company. An outline of the content and program objective is contained in the QA training and certification program. The training and certification program is designed to familiarize the employee with:
- 1. Codes, regulations, specifications, etc, applicable to nuclear and other power generation equipment.
- 2. QA procedures, instructions, specifications, documentation, records, etc.
- 3. Auditing and assessment objectives and techniques.
- 4. Operational Quality Assurance Program.
- 5. Quality Assurance Operational Philosophy.
- 6. Other organizations within PSE&G with which QA interfaces.
QA administers formal QA training sessions for personnel outside the QA organization who perform safety related activities. The content of these training programs, dates of the sessions, and names of the attendees and their individual performance evaluations are documented and retained. Personnel requiring certification are evaluated to establish their qualifications for their respective level and discipline. Recertification is based upon demonstrated continued proficiency or requalification, if necessary. Personnel requiring certification in accordance with Regulatory Guide 1.58 are limited to personnel who perform inspection, test, and nondestructive examination (NDE) 17.2-14 SGS-UFSAR Revision 15 June 12, 1996
303acti vi ties, personnel who perform post-design modification testing, and Inservice Inspection personnel who perform NDE and tests required by the Inservice Inspection Program. Those above personnel who perform visual examination (VTl, 2, 3) and NDE in accordance with the Inservice Inspection Program are trained, qualified, and certified in accordance with a program which additionally meets the prescribed supplementary requirements of ASME Section XI. These personnel receive a periodic training needs assessment to identify additional supportive training needs, as well as to evaluate individual post-training performance. The assessment period is 3 years or less. Personnel who are qualified and requalified for their respective level and discipline in accordance with Regulatory Guide 1.8 and ANSI Nl8.l and direct or supervise the conduct of individual preoperational, startup, and operational inspections and tests, including Technical Specification Surveillances and periodic inspection and test of fire protection equipment, do not require certification per Regulatory Guide 1.58 and ANSI N45.2.6 1978. When a single inspection or test requires implementation by a team or group, personnel not meeting the requirements of Regulatory Guide 1.58 and ANSI N45.2.6 1978 may be used in data-taking assignments or in plant or equipment operation provided they are supervised or overseen by an individual participating in the inspection, examination, or test and the individual is qualified and requalified for their respective level and discipline in accordance with either Regulatory Guide 1.8 and ANSI Nl8.l or the individual is certified in accordance with Regulatory Guide 1.58 and ANSI N45.2.6 1978 as appropriate. In addition, Regulatory Guide 1.58 and ANSI N45. 2. 6 1978 do not apply to NRC - Licensed Operators and Senior Operators for the performance of duties specified in 10 CFR 55 "Operator Licenses". The Nuclear Training Center is responsible for the licensed operator training and retraining, in addition to other technical and supervisory training programs. Training programs of supporting organizations are described in their manuals, which are required to comply with the QA program .
- SGS-UFSAR 17.2-15 Revision 15 June 12, 1996
General Employee Training, which is required for all personnel having access to the station, is the responsibility of the r,i:~~@)p#'B#':ffi~W~Jit¥§Y:i1~%~E,qi!1&P*4anager U1;lelear See"1:rity. 17.2.3 Design Control The scope of the design control program includes design activities associated with the preparation and n~view of design documents, including the correct translation of applicable regulatory requirements into design modification, procurement, and procedural documents. The design control program includes activities such as field design engineering, associated computer programs, compatibility of 17.2-lSa SGS-UFSAR Revision 15 June 12, 1996
THIS PAGE INTENTIONALLY LEFT BLANK 17.2-lSb SGS-UFSAR Revision 13 June 12, 1994
materials, and accessibility for inservice inspection, maintenance, and repair. Issuance of new drawings and revisions to existing drawings require the implementation of a design change. The term design change, as used throughout this document, shall apply to both design and configuration changes. The Nuclear Engjneering Manual (NEM) procedures provide implementation guidance for the intent of Regulatory Guide 1. 64, "Quality Assurance Requirements for the Design of Nuclear Power Plants." QA will conduct periodic engineering process assessments which include procedures contained in the +NEM~. 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.
- 2. Specify applicable codes, standards, regulatory and quality requirements acceptance standards, and other design input in design documents.
- 3. Identify systems, components, and structures that are covered by the quality assurance program .
- 4.
5. Perform design verification for systems, components, and structures covered by the QA Program. Perform safety evaluations of proposed design changes, as required. Sa. Apply Generic 10CFR 50. 59 Safety Evaluation, as required, to configuration changes that impact the SAR.
- 6. Prepare documents for procurement of equipment, materials, and components.
17.2-16 Revision 15 SGS-UFSAR June 12, 1996
- 7. Recommend engineering consultants and laboratories for procurement services and coordinate their activities .
- 8.
9. Review design documents submitted by suppliers (including the Nuclear Steam Supply System (NSSS) supplier) and contractors. Specify, or approve as required, inspections and/or tests.
- 10. Designate whether they will seek the service of other qualified engineering organizations.
The cognizant engineer is responsible for the identification and completion of design analyses. The purpose of design analysis is to assure that the technical design is accomplished in a planned, controlled, and correct manner. Types of design analyses include, but are not limited to, reactor physics, stress, seismic, thermal, hydraulic, radiation, and accident. Design verification is performed on design analyses, drawings, specifications, and other design documents, as applicable. It is the process of reviewing, confirming, or substantiating the adequacy of design by one or more methods. Design verification is performed on changes to previously verified designs, including evaluation of the effects of those changes on the overall design. In general, design verification is completed prior to installation and in all cases is completed prior to placing the modified system or component into service. 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 is individually documented and approved in advance by the supervisor's management. Procedural control is 17.2-17 SGS-UFSAR Revision 9 July 22, 1989
established for design documents that reflect the commitments of the UFSAR; this control differentiates between documents that receive formal design verification by interdisciplinary or multiorganizational teams and those which can be reviewed by a single individual (a signature and date is acceptable documentation for personnel certification). Design documents subject to procedural control include, but are not limited to, specifications, calculations, computer programs, system descriptions, and drawings, including flow diagrams, electrical single-line diagrams, structural systems for major facilities, site arrangements, and equipment locations. Specialized reviews should be used when uniqueness or special design considerations warrant. The responsibilities of the verifier, the areas and features to be verified, the pertinent considerations to be verified, and the extent of documentation are identified in procedures. Control of this function is assured through periodic QA/NSR audits and assessments. Design verification methods comply with applicable requirements of ANSI N45.2.ll and may include, but are not limited to:
- 1. Design reviews.
- 2. Alternate or independent calculations.
- 3. Qualification testing.
In the event that the verification method for design modifications is only by test, procedures and instructions will be written which include measures to ensure that:
- 1. Criteria are provided to specify when verification should be by test.
- 2. Where applicable, prototype, component or feature testing will be performed prior to installation of plant equipment. In those cases where this cannot be met, the
- SGS-UFSAR 17.2-18 Revision 15 June 12, 1996
testing will be deferred, but not beyond the point when the installation would be irreversible.
- 3. Tests will be performed under conditions that simulate the most adverse design conditions, as determined by analysis.
Drawings are prepared by, or under the supervision of, a designer from information received from the responsible engineer, manufacturer's drawings, etc. The drawings are reviewed and initialed as being checked by another designer or design supervisor. The drawings are approved by the functional supervisor or his designee. Specifications and changes thereto for items covered by the QA program are prepared by Nuclear Engineering, and are reviewed by Supplier Assessment for QA content. QA review assures that the documents are prepared, reviewed, and approved in accordance with company procedures and that the documents contain the necessary QA requirements, such as inspection and test requirements, acceptance requirements, and the extent of documenting inspection and test results . The Station Operations Review Committee (SORC) reviews proposed changes affecting nuclear safety and makes recommendations concerning implementation of the change to the station general manager. The design change process provides for signoff of the design change by the appropriate department head for the purpose of identifying required procedure change. If the proposed modification involves a Technical Specification change or is considered by the SORC to involve an
&ud[e~r unreviewed safety question (10CFR50.59), the matter is submitted to the ;:::;:;:::;:;.::;:;::::::::::::::::*:*:*=
g~iY:$$.:W,?m§~pQi::::\(¥~!i,:,9[::offsite Safety R:eview Greup (OSR) for a determination of its safety implication before a license change request is submitted for NRC approval.
#fil@fpg::ffia:~MWF#.JP~if:@:f:!fgpj:::p;For Nuelear Eng:ineerin§' prepared design changes, Nuclear Engineering assigns a project team led by a project manager)\i\:::\:!l~lt@:~~j~jf:~g. The project team consists of members of various 17.2-19 SGS-UFSAR Revision 15 June 12, 1996
organizations, both internal and external to Nuclear Engineering. The project team members are responsible for providing technical and administrative input to the entire design change process, which consists of design, installation, testing, and closeout phases. The technical and administrative input is guided by the requirements of those organizations which comprise the project team. The project manager ensures that the specific requirements of each organization on the project team are considered to ensure the overall quality of the product. For design changes important to safety, the QA representative on the project team provides input and assures that design changes include quality assurance requirements such as inspection and test requirements, acceptance requirements, test result documentation, and project team compliance with company procedures during preparation, review, and approval of design changes. Updating of records, including drawings, blueprints, instructions technical manuals, and specifications resulting from design changes, is the responsibility of the Senior Vice President - Nuclear Engineering. Design change procedures provide for the timely update of affected drawings following design change implementation to reflect as-built configuration. 17.2.4 Procurement Document Control Procurement documents and changes thereto for the purchase of Q-Listed material, equipment, or services are reviewed and approved by QA prior to issuance by the Purchasing Department to the prospective supplier. QA review assures that spare and replacement parts are procured using controls which are commensurate with current QA program requirements. 17.2-20 SGS-UFSAR Revision 15 June 12, 1996
The review also assures that procurement documents adequately and correctly:
- 1. Identify applicable QA program requirements .
- 2.
3. Reference applicable regulatory requirements, codes, and standards. Provide right of access for source surveillance and audit by QA or its agents.
- 4. Provide for required supplier documentation to be submitted to PSE&G or maintained by the supplier, as appropriate.
- 5. Provide for PSE&G review and approval of critical procedures prior to fabrication, as appropriate.
Procurement documents require suppliers and contractors of other than commercial-grade items to provide services or components in accordance with a QA program that complies with applicable parts of 10CFR50, Appendix B. The requirement for notifying PSE&G of procurement requirements that have not been met is conveyed to the supplier through the standard warranty provision contained in each purchase order. In addition, where 10CFR21 is imposed, suppliers are required to comply with applicable reporting requirements . 17.2.5 Instructions, Procedures, and Drawings Organizations engaged in Q-Listed activities are required to perform these activities in accordance with written and approved procedures, instructions, or drawings, as appropriate. Simple, routine activities that can be performed by qualified 17.2-21 SGS-UFSAR Revision 10 July 22, 1990
personnel with normal skills do not require a detailed written procedure. Complex activities require detailed procedures. The designation of those activities requiring detailed procedures is made by cognizant department heads and, as a minimum, complies with applicable requirements of Regulatory Guide 1.33. Procedures include, as appropriate, scope, statement of applicability, references, prerequisites, precautions, limitations, and checkoff lists of inspection requirements, in addition to the detailed steps required to accomplish the activity. Instructions, procedures, and drawings also contain acceptance criteria where appropriate. The ~p~:f.qffi#f:~~@lstatien general manager:; §§!U4.~#~§~@p is responsible for assuring that station procedures are prepared, approved, and implemented in compliance with the Nuclear Administrative Procedures Manual. Documents affecting nuclear safety are reviewed by the SORC for technical content, by QA for QA requirements, and are approved by the responsible station department manager or his designee. Nuclear Engineering is responsible for issuing specifications, drawings, blueprints, procedures and administrative and technical manuals associated with structures, systems, and components covered by the QA Program. Approved and implemented modifications and design changes are incorporated in these reference documents for the life of the station. Master lists of current editions or revisions of these documents are maintained by Nuclear ~~ffi##:ij:f,;f.Jpp§P$Engineering and are available at the station to assure that only current and approved referenced documents are used. QA reviews and approves selected station procedures that implement the QA program, including testing, calibration, maintenance, modification, rework, and repair. Changes to these documents are also reviewed and approved. In addition, QA is responsible for review and approval of selected specifications, test procedures, and results of testing .
- SGS-UFSAR 17.2-22 Revision 15 June 12, 1996
17.2.6 Document Control Instructions, procedures, drawings, and changes thereto are reviewed for the inclusion of appropriate QA requirements, approved by apppropriate levels of management of the PSE&G organizations producing such documents, and distributed on a timely basis to using locations. Measures are provided for the timely removal of obsoiete or superseded documents from the using location. Supplier documents are controlled according to contractual agreements with suppliers. The following is a generic listing of key documents for the operational phase, showing minimum organization responsibility for review and/or approval, including changes thereto:
- 1. Design specification - Nuclear Engineering, QA.
- 2. Design modification, manufacturing, construction, and installation drawings Nuclear Engineering, Nuclear (i~:f#W~~Qi.Ope:rnhens Services, station operations.
- 3. Procurement documents - Initiating NEU organization, Purchasing Departfflenl::, Nuclear Biisl:ll!~~§iii,~pijf.i:p%'§Opcratiens Services, QA.
- 4. Nuclear Administrative Procedures Manual NEU organizations responsible for implementation, QA.
- 5. NEU second-tier manuals, including station administrative procedures - Cognizant department head, QA.
- 6. Maintenance, modification, and calibration procedures for Q-Listed designated station work activities ~Q9.m~!i#@J@tt,§:~:~e%rrs~station operations.
- 7. Operating procedures - Station operations.
17.2-23 SGS-UFSAR Revision 15 June 12, 1996
- 8. UFSAR - +;$.p~m:!~i'.f ~p.g 'S~B'fi#;f,.J;C(lj}ruelear Operat:ions Services and other NBU organizations responsible for implementing applicable sections. In addition, QA reviews subsequent changes to the UFSAR
- 9.
sections to the extent necessary for applicable QA program requirements. assuring Maintenance, inspection, and testing instruction - NBU implementing organizations. compliance with
- 10. Post-modification test procedures - Nuclear Engineering.
- 11. Design Change Requests - Nuclear Engineering, QA.
QA involvement in the work activity includes review of work procedures prior to approval for designation of inspection hold points (see Section 17.2.10), review of completed safety-related Work Orders on a sampling basis, and periodic QA surveillance and assessment. The establishment and maintenance of a document control system for all instructions, procedures, specifications, and drawings received from the NBU or prepared at the station for use in operating, maintaining, refueling, or modifying items and services covered by the QA program is the responsibility of the Rf:t~ss@~t::::::g::::::nns+/-~~;;::::=::::!11~wa~!~::::,:='::::§:~gpis eni or Vice President
!iucl ear Engineering. The Nuclear Administrative Procedures Manual describes the controls for specific documents. Control of station practices is included in the administrative procedures authorized by the responsible station department managers. Measures are established to assure that administrative procedures are up to date, properly authorized, changed only after the required review and approvals are obtained, and distributed to appropriate personnel. Design change procedures provide for the timely update of affected drawings, following design change implementation, to reflect as-built configuration. Computerized databases maintained by the NBU organization are used to control drawings, specifications, procedures and instructions .
Controls of software affecting nuclear safety are identified in the Nuclear Administrative Procedures Manual. These controls are based on applicable guidelines provided by the NRC and include software review and approval as well as access controls to prevent unauthorized software changes. 17.2.7 Control of Purchased Material, Equipment, and Services QA maintains an up-to-date listing of approved suppliers of material, equipment, and services covered by the QA program. This list identifies suppliers and contractors that have demonstrated the ability to supply acceptable material, equipment, or services. The list includes manufacturers of commercial-grade items. All QA program procurements are made from approved suppliers. The responsible engineer and QA personnel select and evaluate prospective bidders and suppliers. The responsible engineer determines the technical competence of the supplier, while QA evaluates the prospective supplier's QA program for the capability of meeting applicable requirements of 10CFR50, Appendix B, and for extending applicable program requirements to subtier suppliers. Qualified QA personnel evaluate the prospective supplier's QA capability using one or more techniques, including but not necessarily limited to:
- 1. Evaluation of supplier's or contractor's procedures or manuals and changes thereto.
- 2. ASME code stamp approval.
- 3. Nuclear Utility Procurement Issues Council (NUPIC) or Nuclear Fuel Users Forum (NFUF) Audits.
- 4. Satisfactory past history of providing similar items.
17.2-25 SGS-UFSAR Revision 15 June 12, 1996
- 5. Survey of supplier's facility.
The evaluations of the prospective suppliers are conducted using standard checklist form designed to include the 18 quality criteria of 10CFRSO, Appendix B, as appropriate. Surveys of sup~liers' capabilities include evaluation of management systems, manufacturing processes, and adherence to QA/QV procedures. The results of supplier evaluations are documented by the appropriate checklist form and filed. Supplier control is maintained through a planned inspection, monitoring, and audit program by QA. QA and the responsible engineer conduct a review of the manufacturing process for complex manufactured items, such as pumps, valves, heat exchangers, vessels, electrical panels, etc. This review establishes critical inspection points and establishes a notification point program for the identified inspection or surveillance activities. The established inspection or surveillance activities are implemented by qualified QA personnel or QA agents. Commercial grade items are dedicated in accordance with recognized industry standards, e.g. EPRI NP-5652. Monitoring of suppliers/contractors during fabrication, installation, modification, rework, repair, inspection, testing, and shipment of Q-Listed materials, equipment, and services is conducted by qualified QA personnel or QA agents at the supplier's/ contractor's facility or at the generating station. Surveillances are conducted in accordance with written procedures and are designed to assure conformance with procurement requirements, in accordance with the safety significance of the item or service. Periodic evaluations of the supplier/contractor quality program are also conducted, consistent with the importance or complexity of the
- SGS-UFSAR 17.2-26 Revision 15 June 12, 1996
item or service. Dependent upon the evaluation, additional audits or corrections by the supplier/contractor may be required. Supplier's certificates of conformance are periodically evaluated by audit, inspection, or test to assure that they are valid. Results of these audits, inspections, or tests are documented. Where feasible, replacement parts adhere to the original design criteria (such as Nuclear Steam Supply System (NSSS} components in accordance with NSSS documentation and other code components in accordance with AWWA, AISC, SPCC., and ASME B&PV Code, editions and addenda as applicable to the component or system). This provides the intended level of safety and does not result in redesign of the system. The requirement for appropriate supplier documentation of conformance to applicable code, standard, specification, or other quality requirements is provided by the procurement document. The supplier-provided documentation is reviewed either at the supplier's facility during source surveillance, or by Material Compliance Group during material evaluation activities. A data review checkoff is used to document the acceptability of the supplier-provided data and to identify discrepancies. Evaluation of supplier equipment, material and services is conducted by qualified personnel to verify correct identification, appropriate documentation, and to verify that the item is acceptable and can be released for storage, installation, or use. Nonconforming items identified by the Material Compliance Group are tagged or segregated to prevent inadvertent use. Nonconforming items are controlled as described in Section 17.2.15. 17.2.8 Identification and Control of Materials, Parts, and Components Procurement document controls provide assurance that materials,
- SGS-UFSAR 17.2-27 Revision 13 June 12, 1994
parts, and components received can be properly identified. The identification is directly marked on the item or on records traceable to the item. The data review conducted at receiving assures that proper documentation of received items is available. Materials and items received without proper identification are tagged or segregated until satisfactory documentation and identification is obtained. Procedures require that Q-Listed materials, parts, and components be marked or otherwise identified and that such identity be maintained either on the item or on records traceable to it throughout receipt, storage, installation, and use. Protection against use of incorrect or defective items also is provided. Material identification and traceability is maintained for rework, repairs, and modifications throughout operation.
=t.m¥:P.&!!ffi9f!l:tif98t::==*:'lst::tsemt~:w+::::::rn*ei**r:::m\!J~&:#ffif!l:+Wt:%::::::t.w~&;*:m::rn~;Be;t:*::::99MF:9aiilnt!*'*: ***::*~#m:*:::.,re&e *~iwffii~llim%+/-¥:~¥*%1~,%W!ss+~f!ti?M:*m~m1M~~nm~W***~s!~~****~n$.1+m~*~mwn$.t:*~~*:*::~s*f~~Mt::*~~*t#:ffe:~!i ~@;p~$#§*;::::::*****t1':#29B#WRgti:#,'jfM~BS~#*]*:::sa#.!!9+*******=**ffe:#gf1#8#*'t**=*j~~~~*f,£;.+:i#wt:::9;:::::::***Rlf.~i!Wi~¥ fii~@BMinMHrnt*m!'.s!fg~M:'::::§;t9#\i$.'.~:t:*m;n§i!Ji*+~#:;Qfil::rn::~*oom~sP:;:p,r,lt~i,'H@~~s**'~i@t*i¥W.mi#§:*::~F:~:MF:a~
il~@~efl@fa~+/-ffi§M:::::::w:::::*::::*:t:=::::**=**s!:t*:::::::::::::~e+/-$~Pi*t*::::::::::*~ii*ffia~~~'::.:****::::t*~w.is£~:f:::=::=:*::::::::::~::tr::....:~~tt:::t:::::::t1e+/-~$~
~i.i;#,\!H~P.~tfggTOr!Janizations which iH!pleffient reeyuirefficnts for the iclentifieation and eontrol of materials, parts, and components include Nuel ear Operations Services, Nuclear Engineering, station operations and QA for procureFRent document controls and Prootlrement and Materials Management, station operations and QA for rcoeipt, storage, installation, inspection ancl test activities.
17.2.9 Control of Special Processes Special process controls provide for the use of qualified procedures, equipment, personnel, and documentation of satisfactory completion of an activity. Special processes are generally those processes where direct inspection is impossible or disadvantageous. Procedures have been established for special processes such as welding, brazing, soldering, concreting, protective coating, cleaning, heat treating, and nondestructive examination (NDE) to assure compliance with codes and design specifications. The Senior Rf@'#,:jjj~~pffiqm$¥P - Nuclear Engineering is responsible for preparing special process procedures such as concreting, protective coating and cleaning, while the
- SGS-UFSAR 17.2-28 Revision 15 June 12, 1996
General Manager - :ttESf.:!'%#-M~WDJ;_@:qfi:*p$Huelear Operat:iens Services is responsible for preparing specifications for processes such as weldjng, brazing, soldering, and heat treating. Nuclear Engineering is responsible for preparing specifications for nondestructive examination (NDE). These specifications are reviewed and approved by QA for necessary quality content. QA moni taring assessements and audits assure that qualification of special processes, equipment, and personnel have been satisfactorily performed. Procedures for implementing the requirements of the specifications are prepared either by the NEU or by supplier personnel and are reviewed by QA and the appropriate general manager, or their designee, with the exception of special process procedures prepared by code suppliers holding a valid certificate of authorization. Qualification records of procedures, equipment, and personnel associated with special processes are retained as stated in Section 17.2.17. 17.2.10 Inspection A planned inspection program is conducted and documented by personnel appropriately qualified in accordance with Section 17. 2. 2. The inspection program verifies conformance to the established procedure, code, or standard, consistent with the item's or activity's importance to safety. The inspection program for maintenance and modification activities is based upon the following three _important levels of inspection:
- 1. Worker Checks Quality cannot be achieved unless the worker performs the activity in a quality manner. The worker is the individual best able to control the quality of work being performed. Work steps that contain elements impacting plant equipment or systems have provisions for signoff by the worker.
This worker signoff establishes accountability for the activity and is 17.2-29 SGS-UFSAR Revision 15 June 12, 1996
acknowledgement that the activity has been performed as specified in the work step.
- 2. Supervisory Inspection - Although the work supervisor may have overall responsibility for the conduct and performance of the work activity, certain conditions at the work location require supervisory inspection to increase coqfidence that work activities are completed as specified through familiarity of the work activity, work group, or past experience. Supervisory inspections are established in the appropriate work procedure and accomplished through direct observation of the work activity.
- 3. Independent Inspection - Independent inspections are not intended to dilute or replace the responsibility of the worker check or supervisory inspection for quality of work. Independent inspections provide the maximum confidence attainable that the work activity has been performed in accordance with the overall objective. Typical guidelines for establishing independent inspections include conditions similar to the following:
- Work activity affecting redundant equipment or potentially causing cascading failure.
- Retest will not verify the applicable attribute.
- Establishing a baseline in a new process or procedure.
- It is deemed necessary to maintain confidence in the work process.
This guidance is considered by the responsible QA organization in the establishment of inspection activities .
- SGS-UFSAR 17.2-30 Revision 9 July 22, 1989
Independent inspections are identified as Inspection Hold Points (IHPs) in the applicable work instructions and are performed by individuals independent of the work activity. IHPs cannot be passed without authorization from the applicable management representative responsible for the inspection activity. General guidelines for the inspection criteria are established by QA and incorporated into various administrative and work instructions. Independent inspections are performed by QA or other individuals who are independent of the work activities. If the individuals performing inspections are not part of the QA organization, the inspection procedures, personnel qualification criteria, and independence from undue pressure, such as cost and schedule, are reviewed for acceptability by the QA organization prior to initiation of the activity. Work procedures and inspection instructions include, as required, characteristics to be inspected, method of inspection, acceptance criteria, required measuring and test equipment, and required reference documents. Documentation includes inspection identification and results of inspection performance. As a result of its review, the Station Operations Review Committee (SORC) may recommend additional or different hold points to the organization performing the work activity . Periodic inspection, other than IHPs, is performed by qualified individuals other than those who performed or directly supervised the activity being inspected. These typically include periodic inspections of the following:
- 1. Storage areas.
- 2. Housekeeping (general).
17.2-31 SGS-UFSAR Revision 11 July 22, 1991
- 3. Fire protection equipment.
- 4. Special handling tools and equipment.
- 5. NDE visual inspection required by the inservice inspection program.
An independent organization shall perform NDE as required, using qualified individuals other than those who performed or directly supervised the activity. When inspections are performed by individuals other than those who performed or directly supervised the work, but who belong to the same work group, and the activity involves breaching a pressure-retaining boundary, the quality of the work is demonstrated through appropriate testing, unless restrictions such as ALARA considerations prevent such testing. The applicable inspection and retest requirements necessary to assure that modifications, rework, or repairs have been accomplished correctly are included in the design change package, work order, or procedure. The inspection and retest requirements for modification, rework, and repair are based on the original inspection and test program, as well as the nature and scope of the modification or repair activity. Evaluation and review of inspection results are conducted by personnel certified Level II in ANSI/ASME N45.2.6 and SNT-TC-IA, as applicable. A planned and documented QA monitoring program is conducted by QA for quality program activities, including the inspection program and personnel qualifications. Monitoring of the implementation of the QA program by station and site contractor personnel is conducted by QA, in addition to offsite supplier activities as appropriate. Conditions adverse to quality found during the conduct of monitoring are brought to the attention of the management responsible for the activity .
- SGS-UFSAR 17.2-32 Revision 15 June 12, 1996
The Manager - Station Quality ~g¥§~*ffl~~'!J?,'Assuranee, or his designee, routinely attends and participates in plant work schedule and status meetings to assure that they are kept abreast of day-to-day work assignments throughout the plant and that there is adequate QA coverage relative to procedural and inspection controls, acceptance criteria, and QA staffing and qualification of personnel to carry out QA assignments. 17.2.11 Test Control Q-Listed equipment and components that must be tested periodically to assure satisfactory performance, or have been replaced, modified, or repaired, are tested by qualified personnel in accordance with written procedures that provide acceptance criteria based on requirements contained in applicable design and procurement documents. Provisions are *implemented that assure that nonconformances are corrected or resolved prior to the initiation of the preoperational test program on the item. Retest requirements are provided by engineering specifications and/or the responsible engineer, or both as were the original test requirements. The Nuclear Engineering:~f\ \{~:U&1eifif@\~$ntkri~#de and operations departments are responsible for preparation of test procedures incorporating the engineering parameters. Test procedures prescribe, as applicable:
- 1. Prerequisites, including completeness of test item(s).
- 2. Instructions for performing the test.
- 3. Instrumentation and equipment for conduct of the test adequate to the test objective.
- 4. Suitable environmental conditions and adequate test methods.
17.2-33 SGS-UFSAR Revision 15 June 12, 1996
- 5. Critical test sequence.
- 6. Acceptance criteria.
Test results, including verification of above items, are documented and reviewed for acceptability by the qualified department representative. In addition, the Nuclear Administrative Procedures Manual provides for the use of temporary changes which are controlled in accordance with Technical Specifications. Detailed instructions for implementation of temporary changes are provided. QA performs assessments of selected post-modification tests to assure compliance with the test procedure. Test results are reviewed for the following:
- 1. Presentation of proper documentation.
- 2. Assurance that tests meet objectives.
- 3. Identification and reporting of unacceptable results and initiation of corrective measures.
17.2.12 Control of Measuring and Test Equipment
- Test equipment, instrumentation, and controls used to monitor and measure activities affecting quality and personnel safety are identified, controlled, and calibrated at specific intervals by cognizant NEU personnel.
procedures for meeting these requirements include provisions for: Written
- 1. Specifying calibration frequency.
- 2. Recording and maintaining calibration records.
- 3. Controlling and calibrating primary and secondary 17.2-34 SGS-UFSAR Revision 15 June 12, 1996
standards.
- 4. Determining methods of calibration .
- 5. Tracing use on Q-Listed items.
Measuring and test equipment (M&TE) calibration procedures are prepared in accordance with the applicable supplier's manual requirements, unless specific exemption is approved by the cognizant station department head. M&TE, which is so exempted, is identified by use of a label or tag on the item. Prior use of measuring and test equipment found to be out of calibration is evaluated for possible effect on safety-related items. Measurements are repeated where necessary. Secondary standards are calibrated by certified calibration laboratories and are traceable to the National Institute of Standards and Technology (NIST) , or best industry standards where no NIST standards exist. Implementing procedures will provide for documenting the basis of calibrations which are not traceable to NIST. To the extent permitted by the state of the art, the accuracy of the primary standards used to perform this calibration is at least four times greater than the accuracy of the device being calibrated. The basis of acceptance is documented and authorized, with responsibility assigned to the cognizant department head. Test equipment is marked or otherwise identified to indicate a unique identification number, the latest calibration date, and the next required calibration date. Measuring and test equipment is identified by affixing a calibration label, unless the size of the item makes this impractical. Out-of-calibration identification is used for instruments and controls to indicate this status pending calibration, repair, or replacement. Calibration frequency is based on the manufacturer's recommendations. This frequency is adjusted when operating experience supports this action. 17.2-35 SGS-UFSAR Revision 15 June 12, 1996
Organizations responsible for implementing measuring and test equipment calibration controls include station, Nuclear ~¥9.:.§ffep~fi'§:goperations Serviees, and the Maplewood Testing Services .
- 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 specified, implemented, and accomplished by suitably trained personnel in accordance with predetermined work and inspection instructions. Implementing procedures provide for the storage of chemicals, reagents (including control of shelf life), lubricants, and other consumable materials, as required. The nuclear materials management group is responsible for control of material in storage, including preservation and shipping controls. The station departments #,ij~)f:ff:#$£~~gt::!~flitehl'hi¢e/ :are responsible for system cleanliness and handling of equipment during operational maintenance or modification. Nuclear Engineering is responsible for specifying equipment requirements. Manufacturer's instructions and recommendations, design requirements, and applicable codes and stan dards are implemented, as appropriate. Compliance with specific handling, storage, or shipping requirements is required. Require ments for new components and spares, where applicable, are included in the procurement documents.
17.2.14 Inspection, Test, and Operating Status NEU procedures are required to specify the periodic tests and inspections required for equipment covered by the QA program and to include the necessary management controls to assure that such required tests and/or inspections are completed in accordance with specified requirements. Equipment awaiting repairs, under repair, or repaired, and received materials are marked to indicate the status of inspection and test requirements and/or acceptability for use. Procedures provide for tagging valves and switches to prevent inadvertent operation. These 17.2-36 SGS-UFSAR Revision 15 June 12, 1996
procedures control the application and removal of tags and are designed to prevent operation of valves and/or switches that could result in personnel hazard or equipment damage .
- Valve and equipment status boards or logs are maintained to indicate status.
17.2.15 Nonconforming Materials, Parts, or Components Organizations involved in material receipt, installation, test, design modification, and other operating activities are responsible for identifying and documenting nonconformances. Nonconforming materials, where practical, are segregated to prevent installation or use until proper approvals are obtained. Materials, parts, or components that have failed in service are identified and, where practical, segregated. Procedures control the application and removal of tags. Documentation of the nonconformance includes a description of the nonconformance, review by §.P.;:fl!M:§!p§#j~#ii##Qi~fi'§GNSS-/NSS for Limiting Condition for Operation (LCO) applicability when appropriate and the disposition and inspection or retest requirements, as appropriate. The responsible Engineer dispositions each nonconformance report. Dispositions for repair or "use-as-is" are required to be reviewed and approved by QA prior to implementation. Rework or repair of nonconforming material, parts, or components is inspected or retested, or both, in accordance with specified test and inspection requirements established by the responsible engineering representative, based on applicable requirements. QA shall verify the satisfactory completion of the disposition of nonconformances. QA and other organizations in the NBU review nonconformance reports for quality problems, including adverse quality trends, and initiate reports to higher management, 17.2-37 SGS-UFSAR Revision 15 June 12, 1996
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 implement corrective action for significant conditions adverse to quality and conditions adverse to quality identified within their scope of activity. Such conditions are documented and controlled by the issuance of an action request.
The QA Corrective Action Group reviews responses to action requests for adequacy and monitors these action requests through periodic summary and status reports 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 to correct deficiency and results achieved to date.
- 3. Action taken or to be taken to prevent recurrence.
- 4. Date when full compliance was or will be achieved.
For significant conditions adverse to qualityi! not identified by QJ'., such as LERs and NRC/INPO/CMAP findings, the QA Corrective Action Group is involved in the review of such conditions and provides oversight to assure timely followup and closeout. Items 3 and 4 are optional for conditions adverse to quality. Proper implementation of corrective action is verified through surveillance inspection assessment or audit, as appropriate. The iRWERPEffi!:i#ifstation general manager p:§jj\]j!9$%#$!p§!f\ris responsible for assuring that 17.2-38 SGS-UFSAR Revision 15 June 12, 1996
conditions adverse to quality are promptly identified and corrected for all activities involving station operation, maintenance, testing, refueling, and modification. Administrative procedures that govern station activities covered by the QA program provide for the timely discovery and correction of nonconformances. This includes receiP-t of defective material, failure or malfunction of equipment, deficiencies or deviations of equipment from design performance, and deviations from procedures. In cases of significant conditions adverse to quality, the cause of the condition is determined, and measures are established to preclude recurrence. Such events, together with corrective action taken, are documented and reported as described in Section 17.2.15. Corrective action is initiated by the responsible department head. QA closely monitors station conditions requiring corrective action. Repetitive deficiencies, procedure or process violations at the station that are not classified as operational incidents or reportable occurrences, or nonconformances under the QA program are documented by QA via the issuance of an action request. This request provides a formal administrative vehicle to alert management of conditions adverse to quality that require corrective action. 17.2 .17 Quality A.ssurance Records Records necessary to demonstrate that activities important to quality have been performed in accordance with applicable requirements are identified and maintained in accordance with Regulatory Guide 1.88, as noted in Section 17.2.2. Records shall be considered valid only when authenticated by authorized personnel. Record types, as a minimum, comply with applicable technical specification requirements and include operating logs, maintenance and modification procedures and related inspection results and reportable occurrences. 17.2-39 SGS-UFSAR Revision 14 December 29, 1995
-ji.i:1t}
The NBU is responsible for the permanent storage of station records. The retention period for records; 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 designated location for retention. 17.2.18 Audits-Audits of PSE&G and supplier organizations that implement the QA program are performed by QA to verify compliance with the applicable portions of the program, through personnel interview, observation of activities in process, and review of applicable documents and records as required. Performance based assessment should be an integral part of the auditing program and should evaluate activities on the basis of their effect on the safe and reliable operation of the facility. An annual audit schedule is developed to identify the audits to be performed and their frequency. A dominant factor in audit schedule development is performance in the subject area. Audit schedules are revised so that weak or declining areas receive increased audit coverage and strong areas receive less consistent with the audit schedule frequency requirements of the Code of Federal Regulations and the UFSAR. Audits of the selected aspects of operational phase activities are performed with a frequency commensurate with safety significance and in a manner to assure that at least biennial (2 year) audits of safety related activities are performed. A list of operational phase activities subject to the audit program is provided in \?.~p§@.§#J:aj{;j&,)~J:Wf.iA~W!f.the Teohnieal Speeifieationo and in Table 17.2-1. Audits are conducted by audit teams comprised of a certified lead auditor, certified auditors, and technical specialists (when deemed necessary). Audits are conducted using preestablished written procedures and checklists. Areas of deficiency revealed by audits are reviewed with management and are corrected in a timely manner. Required corrective action is documented and verified. Followup action, including reaudit of deficient areas, is performed. The audit program conducted by QA 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 and requisition documents, instructions, procedures, and drawings.
17.2-40 SGS-UFSAR Revision 15 June 12, 1996
- 3. Inspection programs.
- 4. Indoctrination and training.
- 5. Implementation of operating and test procedures.
- 6. Calibration of measuring and test equipment.
- 7. Fire protection.
- 8. Other applicable activities delineated in Table 17.2-1.
The audit data is analyzed, and a written report of the results of each audit is distributed to appropriate management representatives of the organization(s) audited, as well as other affected management personnel. Included in the report is a statement of QA program effectiveness. QA is audited by independent auditors at least every 2 years to verify implementation of the QA program. Reports of these audits are directed to appropriate PSE&G management personnel. 17.2-41 SGS-UFSAR Revision 15 June 12, 1996
TABLE 17.2-1 SALEM Q-LIST The listing below identifies those activities, services, structures, components and systems to which the Operational Quality Assurance Program applies.
- 1. ACTIVITIES/SERVICES 1.1 Safety Related Activities Delineated in Regulatory Guide 1.33, App. A (See Regulatory Guide for further breakdown of activities) 1.1.1 Administrative Procedures
- a. Security Program (Regulatory Guide 1.17)
- b. Equipment Control (e.g., Locking and Tagging)
- c. Shift and Relief Turnover
- d. Bypass of Safety Functions and Jumper Control
- e. Maintenance of Minimum Shift Complement and Call-In of Personnel
- f. Fire Protection Program including Inspection by Fire Consultants
- g. Communication System
~H:::r::::1=:::ij1w:@~:ew:::::@m~:1:f::mffimu~ri~:~~Miinr:~M~mli@:r;~~::r]~§~gs:~::
- t::n:trtli#$m~~¥t:mimtmw::rn%!*'tmt::~~~¥:~::
- 1.1.2 1.1. 3 1.1.4 1.1. 5 General Plant Operating Procedures Startup, Operation, and Shutdown of Safety-Related Abnormal, Offnormal, or Alarm Conditions Combating Emergencies and Other Significant Events Systems 1.1. 6 Control of Radioactivity
- a. Liquid Radioactive Waste System (including the contaminated floor and equipment drain systems)
- b. Solid Waste System
- c. PWR Gaseous Effluent System
- d. Radiation Protection including Occupational Radiation Exposure per Regulatory Guide 8.8
- e. Area Radiation Monitoring System Operation 1 of 5 SGS-UFSAR Revision 13 June 12, 1994
Table 17.2-1 (Cont)
- f. Process Radiation Monitoring System Operation
- 1.1.7 g.
h. i. Meteorological Monitoring and Data Collection Program Packaging and Transport of Radioactive Material per 10CFR71 Decontamination Technical Specification Surveillance 1.1.8 Performing Maintenance 1.1.9 Chemical and Radiochemical Control 1.2 Additional NRC Requirements 1.2.1 Technical Specification Administrative Controls
- a. SORG
~a. Reportable Occurrences
- 2. EQUIPMENT, COMPONENTS, AND STRUCTURES 2.1 The following are items and systems contained in commitment letters to the NRC.
2.1.1 Accident Monitoring Instrumentation 2.1.2 AC Control Power Buses and Inverters 2.1.3 All Systems Which Penetrate Containment, up to and including the Containment Isolation Valve (Identified in UFSAR Section 6.2.4) 2.1.4 Anticipatory Reactor Trip on Turbine Trip 2 .1. 5 Auxiliary Building (including Control Room and Diesel Generator Area) 2.1.6 Auxiliary Building Ventilation System (Supply and Exhaust Units) 2.1.7 Auxiliary Feedwater Storage Tank 2.1.8 Auxiliary Feedwater System 2.1.9 Component Cooling System 2.1.10 Chill Water System 2 of 5 SGS-UFSAR Revision 9 July 22, 1989
Table 17.2-1 (Cont) 2.1.11 Containment (including penetrations, concrete shielding, interior structures, air locks, equipment hatch)
- a. Containment Polar Crane 2.1.12 Containment Pressure - Vacuum Relief System 2.1.13 Control Area Air Conditioning System 2.1.14 Control Panels - Class lE circuits 2.1.15 Electrical Cable Tunnels 2.1.16 Emergency Power for Pressurizer Heaters 2.1.17 Emergency Power Supply System
- a. DC Power Supply System
- b. Diesel Generator Area Ventilation System
- c. Diesel Generators (including associated fuel oil, lube oil, starting auxiliary systems, fuel storage and day tanks, jacket cooling, governor, voltage regulation and excitation systems, piping and valves)
- d. Control Boards and Motor Control Centers
- e. Control equipment, facilities and lines required for above items
- f. Power distribution lines to equipment required for emergency transformers and switchgear supplying Engineered Safety Features (includes 4-kV, 460-V and 230-V vital buses) 2.1.18 Emergency Response Facilities (NUREG-0737, Supplement l; document control and verification of functionality only) 2.1.19 Engineered Safety Features
- a. Containment Spray System (including spray pumps, spray header, spray additive tank, connecting piping and valves)
- b. Containment Ventilation System (including fan coolers, distribution ducts, dampers, HEPA filters, and moisture separators)
- c. ECCS (including Safety Injection and RHR pumps, RWST, Accumulators, RHR heat exchangers, containment sump, sump screen vortex suppression devices, and connecting pipes and valves) 3 of 5 SGS-UFSAR Revision 9 July 22, 1989
Table 17.2-1 (Cont)
- d. Portions of the CVCS (including Centrifugal Charging Pumps, Boron Injection Tank, connecting piping) 2.1.20 Expendable and consumable items necessary for the functional performance of critical structures, systems, and components (i.e., weld rod, boric acid, fuel oil, etc) 2.1.21 Feedwater System (to outermost isolation valve)
- 2. 1. 22 Fire Protection System for safety-related areas (hardware) 2.1.23 Fuel Handling Building 2.1.24 Fuel Handling Building Ventilation System (exhaust units) 2.1.25 Fuel Handling System 2 .1. 26 Fuel Transfer Tube 2.1.27 Hydrogen Recombiners, Hydrogen Analyzers, and Supports 2.1.28 Instrument Air System (including accumulators, interconnecting piping and valves) for air-operated valves that perform a safety function
- 2. 1. 29 Instrumentation and Control Systems required for safe shutdown (including safety-related instrumentation) 2.1.30 Instrumentation for detection of inadequate core-cooling 2 .1. 31 Leakage Detection System (as discussed in UFSAR Section 5.2.7) 2.1.32 Main Steam System (to isolation valve) 2 .1. 33 Meteorological Data Collection Program (hardware)
- 2. 1. 34 Missile Barriers (protecting safety-related equipment) 2.1.35 Nuclear Instrumentation System 2.1.36 Plant Shielding 2.1.37 Process Instrumentation and Controls (those portions required for Class I equipment and systems) 2.1.38 Radiation Monitoring System (those portions required for Class I equipment and systems) 2.1.39 Radioactive Waste Disposal Systems 4 of 5 SGS-UFSAR Revision 6 February 15, 1987
Table 17.2-1 (Cont)
- a. Gas Decay Systems
- b. Compressor 2.1.40 Reactor Coolant System (including piping, valves, steam generators, pressurizer, safety and relief valves, block valves, piping to p!'essurizer relief tank, reactor coolant pumps, and supports) 2.1.41 Reactor (including vessel, supports, internals, fuel assemblies, RCC assemblies and drive mechanisms, supporting and positioning members, and in-core instrumentation) 2.1.42 Reactor Protection System
- 2. 1. 43 Residual Heat Removal System 2.1.44 Safety Parameter Display Console (instrument calibration and verification only) 2.1.45 Sampling System (to outermost containment isolation valve)
- 2. 1. 46 Service Water Intake Structure 2.1.47 Service Water System (entire system serving the nuclear portion of the plant, as shown in UFSAR Figures 9.2-lA and B) 2.1.48 Shoreline Dike (for protection against excessive wave action)
- 2. 1. 49 Spent Fuel Pool Cooling System 2 .1. 50 Steam Generator Blowdown System (to outermost containment isolation valve) 2 .1. 51 Switchgear Room Ventilation System 2 .1. 52 Valve operators for all valves incorporated in this list 2.2 Items Required by Regulatory Guide 1. 2 9, "Seismic Design Classifications," Regulatory Position 3.
5 of 5 SGS-UFSAR Revision 9 July 22, 1989
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i PUBLIC SERVICE ELECTRIC AND GAS COMPANY SALEM NUCLEAR GENERATING STATION QUALITY ASSURANCE UUCLEAR SAFETY REVIEW UNITS I & 2 Updated FSAR Figure 17.2*1 Revision 15 ShMI I of I
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