ML18106A314

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Forwards QA Program for Hope Creek & Salem Generating Stations,As Documented in Section 17.2 of Respective Ufsars, for NRC Approval
ML18106A314
Person / Time
Site: Salem, Hope Creek  PSEG icon.png
Issue date: 02/13/1998
From: Eric Simpson
Public Service Enterprise Group
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18106A315 List:
References
LR-N980031, NUDOCS 9802240088
Download: ML18106A314 (18)
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Public Service Electric and Gas Company E. C. Simpson Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1700 Senior Vice President - Nuclear Engineering FEB 13 1998 LR-N980031 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

REQUEST FOR CHANGES TO THE QUALITY ASSURANCE 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 In accordance with 10CFR50.54(a)(3), Public Service Electric and Gas Company (PSE&G) hereby submits for your approval 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).

This submittal requests approval to consolidate the existing QA Material and Supplier Plant Support (MSPS) Group and the Nuclear Procurement & Material Management (NP&MM) Department under a single Manager. In this reorganization, the MSPS Group, which is currently part of the QA organization, would be renamed the Procurement

  • Assessment (PA) Group and would report directly to the Manager - NP&MM. Although the PA Group would no longer report directly to a Manager in the QA organization, the proposed changes include adding an indirect reporting relationship that would allow the PA Group Head to report to the Manager - Quality Assessment if a conflict with the NP&MM Department occurred regarding the QA program. In addition, the proposed changes include making the Manager - Quality Assessment responsible for monitoring the ability of the PA group to continuously function independently. As a result, the requirements of 10CFR50, Appendix B would continue to be met.

The submittal also requests approval to transfer the responsibility for review of procedures for special processes from QA and the General Manager to a qualified specialist since qualified specialists in the subject_discipline or special process are most qualified to perform the reviews .. QA would continue to review the approval of procedures identified as acceptable prior to the acceptance of safety related material.

QA would also continue to acknowledge the acceptability of the procedures used in the

  • . manufacturing of material received by the NBU. The requirement for QA monitoring assessments and audits to assure that ~ualification of special processes, equipment and

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  • Document Control Des. FEB 13 1998 LR-N980031
  • personnel have been satisfactorily performed is also maintained. As a result, the*

requirements of 10CFR50, Appendix B would continue to be met.

This letter also requests approval to delete the Hope Creek requirement to perform site grading modification audits. No similar Sa.lem requirement exists. Site grading modifications that could affect safety related equipment are covered under the PSE&G design and configuration change processes and are required to be reviewed by the QA organization. As a result, separate auditing of site grading modifications is considered to be unnecessary. Based on the above, PSE&G concludes that site grading activities would continue to be covered under the operational QA program and that the requjrements of 10CFR50, Appendix B would continue to be met.

Attachment 1 contains a description of the proposed changes, the reasons for the proposed changes, and the bases for concluding that the revised QA Program continues to satisfy the criteria of 10CFR50 Appendix B. Attachments 2 and 3 contain the changes to Section 17.2 of the Hope Creek and Salem UFSARs, respectively. Changes made since the last UFSAR update are shown with the changes proposed in this submittal highlighted in bold font. PSE&G will reyise other sections of the Hope Creek and Salem UFSARs in accordance with 10CFR50.59 after the proposed QA program changes have been reviewed and approved by the NRC.

  • PSE&G requests approval of these changes by March 15, 1998.

If you have any questions regarding this submittal, please do not hesitate to contact us.

Attachments (3) 95-4933

Document Control LR-N980031 De. ." . FEB 13 1998

  • c Mr. H. 'Miller, Administrator - Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Ms. B. Mozafari, Licensing Project Manager - HC U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. P. Milano, 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 Ms. M. Evans (X24)

USNRC Senior Resident Inspector - Salem Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering P. o. Box415 Trenton, NJ 08625 Mr. D. Jaffe U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 95-4933

Document Control Desk LR-N980031 Attachment 1

    • HOPE CREEK GENERATION STATION AND SALEM GENERATING STATION UNIT NOS. 1AND2 FACILITY OPERATING LICENSES NPF-57, DPR-70, AND DPR-75 DOCKET NOS. 50-354, 50-272, AND 50-311

(

REQUEST FOR CHANGES TO THE QUALITY ASSURANCE PROGRAM DESCRIPTION OF PROPOSED CHANGES A. Procurement Organization Change The QA Material and Supplier Plant Support (MSPS) Group is currently part of the QA Department. The proposed changes would allow the MSPS Group to be incorporated into the Nuclear Procurement & Material Management (NP&MM) Department; however, an indirect reporting relationship with QA would be maintained. In addition, the responsibility for review of procedures for special processes would be transferred from QA and the General Manager to a qualified specialist. A detailed discussion of the proposed changes to Section 17.2 of the Hope Creek and Salem UFSARs is as follows:

Section 17.2 on Page 17.2-2 (HC) & Page 17.2- 2 (Salem)

The responsibility for reviewing, monitoring, and auditing supplier and contractor QA

  • programs is transferred from QA to the Procurement Assessment (PA) Group.

Section 17.2.1.1.1 on Page 17.2-4 and 17.2-5 (HC) & Pages 17.2-4 and 17.2-6 (Salem)

The Manager - Nuclear Procurement & Material Management (NP&MM) is made responsible for the Quality Services activities provided by the PA Group.

The Manager - Quality Assessment is made responsible for monitoring the ability of the PA group to continuously function independently as delineated under the responsibilities of the Manager - NP&MM. In the event of a conflict concerning the implementation of the QA program between NP&MM and PA, the reporting line is designated to be direct from PA to the Manager - Quality Assessment.

Section 17 .2 .1.2 on Page 17 .2-7k (HC) & Page 17 .2- 7i (Salem)

The PA Group is designated, along with QA, as an approver of the QA program.

Section 17.2.1.4 on Pages 17.2-13 and 17.2-14 (HC) & Pages 17.2- 12 and 17.2-13 (Salem)

PA is designated as being responsible for reviewing and analyzing problems affecting quality.

  • The PA Group Head is given the authority to stop work.

Page 1of14

Document Control Desk LR-N980031 Attachment 1

PA is given the responsibility and authority to escalate unresolved quality problems to increasingly higher levels of management, up to the CNO/PNBU, as required.

Section 17.2.3 on Page 17.2-20 (HC) & Page 17.2- 19 (Salem)

The responsibility for reviewing specifications and changes thereto for items covered by the QA program is transferred from Supplier Assessment to PA.

Section 17.2.4 on Pages 17.2-21 and 17.2-22 (HC) & Pages 17.2- 20 and 17.2-21 (Salem)

The responsibility for reviewing procurement documents and changes thereto for the purchase of Q, F, and R designated material, equipment, and services is transferred from QA to PA.

  • Section 17.2.6 on Page 17.2-24 (HC) & Page 17.2- 23 (Salem)

PA is given the responsibility, along with QA, for reviewing design specifications. The responsibility for reviewing procurement documents is transferred from QA to PA.

  • Section 17.2.7 on Pages 17.2-26 and 17.2-27 (HC) & Pages 17.2- 25 and 17.2-26 (Salem)

The responsibility for evaluating the QA program of prospective bidders is transferred from QA to PA.

The responsibility for maintaining a planned inspection, monitoring, and audit program for suppliers is transferred from QA to PA.

PA is given the responsibility to maintain an up-to-date listing of approved suppliers of material, equipment, and services covered by the QA program.

Section 17.2.8 on Page 17.2-29 (HC) & Page 17.2- 28 (Salem)

The responsibility for procurement document controls is transferred from QA to PA. PA is added to the list of organizations responsible for receipt, storage, installation, and test activities.

Section 17.2.9 on Page 17.2-30 (HC) & Page 17.2- 29 (Salem)

The responsibility for review of procedures for special processes is transferred from QA and the General Manager to a qualified specialist.

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Document Control Desk LR-N980031 Attachment 1

  • Section 17.2.15 on Page 17.2-40 (HC) & Page 17.2- 37 (Salem)

PA, in addition to QA, is given the responsibility to verify the satisfactory completion of the disposition of nonconformances.

Section 17.2.18 on Page 17.2-42 (HC) & Page 17.2- 40 (Salem)

PA is identified along with QA as performing audits of PSE&G and supplier organizations that implement the QA program to verify compliance.

Figure 17.2-1 (HC) & Figure 17.2-1 (Salem)

The organization chart would be changed to show the PA Group reporting to the Manager - NP&MM with a dotted line from PA to the Manager - Quality Assessment to indicate that PA reports to the Manager - Quality Assessment if conflicts concerning QA issues arise between PA and NP&MM.

B. Site Grading Audit Elimination The proposed change would delete the requirement to perform audits of modifications to site grading, as listed in Item B.4 of Table 17.2-1 in the Hope Creek UFSAR. The

  • requirement that Item B.4 be covered by a Quality Assurance audit was added to Table 17.2-1 via a PSE&G letter to the NRG dated September 10, 1984.

SUMMARY

OF CHANGES TO SECTION 17.2 SINCE LAST UPDATE There have been numerous changes to Section 17.2 of the Hope Creek UFSAR that have been approved under 10CFR50.59 or 10CFR50.54(a) since the last UFSAR update submitted to the NRG in accordance with 10CFR50.71. Although this submittal is not requesting approval of those changes, the subject changes are reflected in the attached pages. This was unnecessary for Salem since a revision to the Salem UFSAR was just recently submitted on January 30, 1998.

Hope Creek change notices (HCNs) affecting Section 17.2 that have been approved under 10CFRS0.59 and 10CFR50.54(a) since the last UFSAR update include the following:

HCN96-083 This change notice changed the responsible organization for site access training from the Manager - Nuclear Security to the Director - Nuclear Training Center.

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Document Control Desk LR-N980031 Attachment 1

  • HCN96-091 This change notice made changes to the Hope Creek Station organization and included changing the title of the SNSSs to shift superintendents.

HCN96-093 This change notice consolidated the positions of Manager - Quality Assessment - Hope Creek and the Manager - Quality Assessment - Salem into a single position with the title Manager - Quality Assessment.

HCN96-118 This change notice eliminated Policy Procedure NC.VP-PO.ZZ-001 O(Q) and integrated its content into other documents.

HCN96-119 This change notice changed the responsibility for document control from Nuclear Engineering to Nuclear Business Support .

  • HCN97-010. Revision 1 This change notice modified the discussion on calibration standards.

HCN97-013 This change notice implemented organization changes that included creating a centralized Maintenance organization and moving the Licensing and Regulation Department from the QA organization to the Nuclear Engineering organization.

HCN97-017 This change notice incorporated changes to reflect organizational changes approved by the NRG associated with Hope Creek License Amendment 97.

HCN97-022 This change notice transferred the responsibility for the Quality Verification functions from the Manager - Corrective Action & Quality Services to the Manager - Quality Assessment. *

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Document Control Desk LR-N980031 Attachment 1

  • HCN97-026 This change notice transferred the Project Managers and their associated functions from the Nuclear Engineering organization to the Nuclear Business Support organization.

HCN97-043 This change notice restored the responsibilities of the Nuclear Engineering organization with respect to design control to Section 17.2.3. The responsibilities had been relocated to Chapter 13 of the UFSAR in HCN 97-013 but was subsequently determined to be a reduction in commitment.

HCN97-047 This change notice consolidated the QA, Nuclear Training, and Emergency Preparedness Departments under a single Director with the title Director - Quality, Nuclear Training and Emergency Preparedness. This change was approved by the NRC in a letter dated August 4, 1997.

HCN97-062

  • This change notice removed reference to the Nuclear Engineering Manual from Section I 17.2.3 of the UFSAR. I HCN97-063 This change notice modified the discussion on drawing changes to allow the task of transferring approved design change information to be performed by a drafter. The initial preparation in support of a design/configuration change remains the responsibility of a designer and final approval remains with the design supervisor or authorized designee.

HCN97-064 This change notice consolidated the responsibilities of the Manager - Corrective Action the Manager - Emergency Preparedness, and the Manager - Instructional Technology under a single Manager with the title Manager - Corrective Action, Emergency Preparedness and Instructional Technology. The Quality Services functions that were under the Manager - Corrective Actions were transferred to the Director - Quality, Nuclear Training and Emergency Preparedness .

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Document Control Desk LR-N980031 Attachment 1

  • HGN97-074 This change notice changed the assessment and evaluation period for Level Ill personnel performing non-destructive examinations (NOE) and visual examinations (VT) from every three years to every five years. This change was approved by the NRG in a letter dated May 16, 1989.

HGN97-087 This change notice clarified a qualification requirement for the Onsite Independent Reviewers (OIRs) and procedure review requirements for QA.

HGN97-089 This change notice relocated the Nuclear Repair Program from the QA organization to the Nuclear Maintenance organization. This change was approved by the NRG in a letter dated August 4, 1997.

On a page by page basis, the following are the changes made since the last UFSAR update (the associated change notice is referenced for each change):

Section 17.2 on Page 17.2-1 The reference to NG.VP-PO.ZZ-0010(Q) was deleted. (HGN96-118)

Section 17.2.1 on Page 17.2-3 The Quality, Emergency Preparedness, and Nuclear Training organizations were consolidated under a single Director and the Manager - Quality Assessment was designated as being responsible for assuring implementation of the QA Program for the non-QA areas under the control of the Director. (HGN97-047)

Section 17.2.1.1.1 on Pages 17.2-4through 17.2-6 Reference to the responsibilities of the Manager - Licensing and Regulation was deleted because the Licensing Department was moved from the QA organization into the Engineering organization. (HGN97-013)

Implementation of the onsite independent review was added to the responsibilities of the Manager - Quality Assessment. (HGN97-017)

Reference to the responsibilities of the Manager - Nuclear Safety Review was deleted.

(HGN97-017)

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Document Control Desk LR-N980031 Attachment 1

  • A reference to the qualifications of personnel performing the onsite independent review function being described in Section 17.2.1.1.2.4 was added. (HCN97-017)

Knowledge and experience in the area of safety was added to the qualifications of the Director - Quality, NT, and EP. (HCN97-017)

The responsibility for the Quality Verification functions was transferred from the Manager

- Corrective Action & Quality Services to the Manager - Quality Assessment. (HCN97-022)

The responsibility to perform review of weld procedures was transferred from the Manager - Corrective Action and Quality Services to the Manager - Quality Assessment.

(HCN97-022)

The title of the Director was changed to reflect consolidation of the Quality, Emergency Preparedness, and Nuclear Training organizations under a single Director. (HCN97-047)

The responsibility of the Director for verifying compliance with QA Program requirements was modified to include an exception for those non-QA areas under_ his control. (HCN97-047)

  • The title of the Manager - Corrective Action and Quality Services was changed to Manager - Corrective Action. (HCN97-047)

The responsibilities to 1) perform code related inspections and test performance, 2) perform design change package- pre-implementation review and closure review for compliance with inspection hold points (IHPs), and 3) perform performance based inspections was transferred from the Manager - Corrective Action and Quality Services to the Manager - Quality Assessment. (HCN97-047)

Administration of the Nuclear Repair program was deleted from the responsibilities of the Manager - Corrective Action and Quality Services and added to the responsibilities of the General Manager - Nuclear Maintenance in Section 13.1.1.2.1.1 of the UFSAR. (HCN97-047)

The Manager - Quality Assessment was given: 1) the authority and responsibility to stop work when conditions adverse to quality require such action, 2) the freedom and authority to directly access the CNO and P-NBU, and 3) the responsibility and authority for verifying compliance with established requirements of the QA Program for non-QA areas under the control of the Director, including the authority to interpret QA program requirements during the conduct of these activities. (HCN97-04 7)

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Document Control Desk LR-N980031 Attachment 1

  • The Program Manager - NRB was given the responsibility for 1) providing support to the NRB to ensure that it can perform its function, 2) providing management oversight of the NRB subcommittees and NRB independent reviews, 3) verifying that the 10CFR50.59 Safety Evaluations are adequate and that the proposed actions do riot involve an.

Unreviewed Safety Question, and 4) managing and administering the training requirements for NRB personnel. (HCN97-047)

  • A reference to Section 13.1 was added for the description of the responsibilities of the Technical Training/Services Manager, the Operations Training Manager, and the Emergency Preparedness Manager. (HCN97-047)

The responsibilities of the Manager - Corrective Action, the Manager - Emergency Preparedness, and the Manager - Instructional Technology were consolidated under a single Manager with the title Manager - Corrective Action, Emergency Preparedness and Instructional Technology. The Quality Services functions that were under the Manager -

Corrective Actions were transferred to the Director - Quality, Nuclear Training and Emergency Preparedness. (HCN97-064)

The procedure review requirements f~r QA were clarified by indicating that "selected" procedures are reviewed. (HCN97-087)

  • Pages 17.2-7 through 17.2-7k Changes were incorporated to reflect the organizational changes involving creation of the centralized Nuclear Maintenance Department. (HCN97-013)

Changes were made related to the description of the Maplewood Testing Services.

(HCN97-013)

Changes were incorporated to reflect organizational changes approved by the NRG associated with Hope Creek License Amendment 97. (HCN97-017)

The Manager - Quality Assessment was added to the list of individuals required to be notified of a disagreement between SORG and the plant manager. He was also added to the list of individuals required to receive Station Operations Review Committee (SORG) meeting minutes.(HCN97-047)

For onsite independent review issues involving non-QA areas under the Director's control, the Manager - Quality Assessment was authorized to directly advise the CNO.

(HCN97-047)

The qualification requirement for the Onsite Independent Reviewers (OIRs) was clarified.

(HCN97-087)

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Document Control Desk LR-N980031 Attachment 1

  • Section 17.2.2 on Page 17.2-13 A change was made to indicate that the Manager - Quality Assessment is authorized to stop work. The list of designees was deleted. (HCN97-047)

Section 17.2.2 on Page 17.2-14 The reference to management policy was deleted. (HCN96-118)

Section 17.2.2 on Page 17.2-16 The assessment and evaluation period for Level Ill personnel performing non-destructive examinations (NOE) and visual examinatiqns (VT) was changed from every three years to "in accordance with the ASME Code."

Section 17.2.3 on Pages 17.2-17 The responsibility for site access training was transferred from the Manager - Nuclear Security to the Director Nuclear Training Center. (HCN96-083)

The title of the Director was changed to reflect consolidation of the Quality, Emergency

  • Preparedness, and Nuclear Training organizations under a single Director. (HCN97-047)

The reference to the Nuclear Engineering Manual was deleted. (HCN97-062)

Section 17.2.3 on Pages 17.2-17 The discussion on drawing changes has been changed to allow the task of transferring approved design change information to be performed by a drafter. The initial preparation in support of a design/configuration change remains the responsibility of a designer and final approval remains with the design supervisor or authorized designee. (HCN97-063)

Section 17.2.3 on Page 17.2-21 Changes were made to the requirements for preparation of design changes. (HCN97-013)

The organization responsible for determining the safety implications of a license change request or unreviewed safety question was changed from Offsite Safety Review to the NRB. (HCN97-017)

The Project Managers and their associated functions were transferred from the Nuclear Engineering organization to the Nuclear Business Support organization. (HCN97-026)

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Document Control Desk LR-N980031 Attachment 1

  • Section 17.2.5 on Page 17.2-23 The responsibility for issuing specifications, drawings, blueprints, procedures, administrative and technical manuals associated with Q, F, and R-designated structures, systems, and components was transferred from the Senior Vice President - Nuclear Engineering to the Director - Nuclear Business Support. The responsibility for maintaining master lists of current editions or revisions of these documents was transferred from Nuclear Engineering to Nuclear Business Support. (HCN96-119)

The responsibility for assuring that procedures are prepared, approved, and implemented in compliance with the Nuclear Administrative Procedures Manual was transferred from the station General Manager to the appropriate General Manager or Director and the phrase "station procedures" was changed to "procedures". (HCN97-

  • 013)

Section 17.2.6 on Page 17.2-24 and 17.2-25 The responsibility for 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, was transferred from the

  • Senior Vice President - Nuclear Engineering to the Director - Nuclear Business Support.

(HCN96-119)

Nuclear Operations Services was replaced by Nuclear Maintenance on the list of reviewers for design modification, manufacturing, construction, and installation drawings.

The Purchasing Department was deleted from the list of reviewers for procurement documents. Nuclear Operations Services was replaced by Nuclear Business Support on the list of reviewers for procurement documents. Station Operations was replaced by Nuclear Maintenance on the list of reviewers for maintenance, modification, and calibration procedures for Q, F, and R designated station work activities. Nuclear Operations Services was replaced by Licensing and Regulation on the list of reviewers for the UFSAR. The phrase "station department managers" was changed to "department managers" (HCN97-013)

Section 17.2.8 on Page 17.2-29 Nuclear Operations Support and station operations were replaced by Nuclear Maintenance and Nuclear Business Support on the list of organizations responsible for identification and control of materials, parts, and components. Procurement and Materials Management and station operations were replaced by Nuclear Business Support and Nuclear Maintenance on the list of organizations responsible for receipt, storage, installation, inspection and test activities. (HCN97-013)

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Document Control Desk LR-N980031 Attachment 1

  • Section 17.2.9 on Page 17.2-30 The title Director - Nuclear Operations Services was changed to General Manager -

Nuclear Maintenance in the discussion of responsibility for preparing specifications for processes such as welding, brazing, soldering, and heat treating. (HCN97-013)

The responsibility for reviewing non-destructive examination specifications was transferred from QA to the Nuclear Maintenance Code Assurance Specialist. (HCN97-089)

Section 17.2.11 on Page 17.2-35 and 17.2-36 The Nuclear Maintenance Department was added to the list of organizations responsible for preparation of test procedures incorporating engineering parameters. (HCN97-013)

The sentence stating that system tests performed following modifications to Q, F, and R designated systems require review of test procedures and test results by the SORG was deleted. (HCN97-017)

Section 17.2.12 and Section 17.2.13 on Page 17.2-37 and 17.2-38

  • The discussion of calibration standards was modified. (HCN97-010, Revision 1)

The Nuclear Operations Services Department was replaced by the Nuclear Maintenance Department in the list of organizations responsible for implementing measuring and test equipment calibration controls. Nuclear Maintenance was added to the list of organizations responsible for system cleanliness and handling of equipment during operational maintenance or modification. (HCN97-013)

Section 17.2.15 on Page 17.2-39 The title SNSS was changed to Shift Superintendent in the discussion of the documentation of nonconformances. (HCN96-091)

The title Shift Superintendent/NSS was changed to Operations Superintendent/Control Room Supervisor. (HCN97-055)

Section 17.2.16 on Page 17.2-41 The responsibility for assuring that conditions adverse to quality are promptly identified and corrected was transferred from the station General Manager to the appropriate General Manager or Director. The phrase "by QA" was deleted from the discussion of documenting repetitive deficiencies, procedure or process violations. (HCN97-013)

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Document Control Desk LR-N980031 Attachment 1

  • 6.

7.

8.

Monitoring/auditing of nuclear fuel fabricati.on and installation.

Review of NBU fuel specifications for inclusion of QA requirements.

Perform material evaluation activities on items subject to the QA Program.

The changes would not result in a reduction in the above identified QA Program commitments; however, the changes are considered a reduction in commitment as a result of the change in the reporting relationship of the PA Group from QA to the NP&MM Department. Controls are proposed to ensure that the independence of PA is maintained should there be a conflict concerning implementation of the QA program between PA and NP&MM, and the Manager - Quality Assessment would be made responsible for monitoring the ability of the PA group to continuously function independently.

With regard to the change in responsibility for reviews of procedures for special processes, PSE&G considers personnel who are qualified in the subject discipline or special process to be the most qualified to perform the reviews. QA would continue to review the approval of procedures identified as acceptable prior to the acceptance of safety related material. QA would also continue to acknowledge the acceptability of the procedures used in the manufacturing of material received by the NBU. The requirement

  • for QA monitoring assessments and audits to assure that qualification of special processes, equipment and personnel have been satisfactorily performed is also maintained. Based on the above information, the requirements of 10CFR50, Appendix B would continue to be met.
8. Site Grading Audit Elimination - Hope Creek Site grading modifications that could affect safety related equipment are covered under the PSE&G design and configuration change processes and are required to be reviewed by the QA organization. As a result, site grading activities would continue to be covered under the operational QA program and the requirements of 10CFR50, Appendix B would continue to be met.
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Document Control Desk LR-N980031 Attachment 2 PROPOSED HOPE CREEK UFSAR CHANGES

Document Control Desk LR-N980031 Attachment 1

  • Section 17.2.18 on Page 17.2-42 The location of the list of operational phase activities subject to the audit program was changed from the Technical Specifications to Section 17.2.1.1.2.3. (HCN97-017)

Table 17.2-1 SORG was added to the list of safety-related administrative procedures. SORG and NSR was removed from the list of Technical Specification administrative controls.

(HCN97-017)

NRB was added to the list of safety-related administrative procedures. (HCN97-047)

Figure 17.2-1 The positions of Manager - Quality Assessment - Hope Creek and the Manager - Quality Assessment - Salem were combined into a single position with the title Manager - Quality Assessment. (HCN96-093)

The NRB Program Manager was added as a direct report to the Director - Quality, NT, and EP, and the Manager - NSR was deleted as a direct report to the Director - Quality,

  • NT, and EP. (HCN97-017)

The Manager - Licensing and Regulation was deleted as a direct report to the Director -

QA. (HCN97-013)

The new organization resulting from consolidating the Quality, Nuclear Training, and Emergency Preparedness organizations was reflected on the organization chart. A dotted line from the Manager - Quality Assurance to the CNO/PNBU indicates the access that the Manager - Quality Assessment has to the CNO/PNBU. (HCN97-047)

The new organization resulting from consolidating the Corrective Action, Emergency Preparedness, and Instructional Technology organizations was reflected on the organization chart. (HCN97-064)

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Document Control Desk LR-N980031 Attachment 1

  • REASONS FOR THE PROPOSED CHANGE A. Procurement Organization Change An organization design review of the Material Supply Chain was performed to evaluate its effectiveness and to identify changes in the products, services and structure of the Chain that would best support the PSE&G Nuclear Business Unit and its customers in the future. The design review determined that the current processes are cumbersome, labor intensive not lending themselves to an efficient integrated flow. The current organization structure within the Material Supply Chain is a key factor to the process inefficiency. One of the solutions is to reorganize the Supply Chain to consolidate NP&MM and MSPS groups under a single Manager.

The responsibility for review of procedures for special processes is transferred from QA and the General Manager to a qualified specialist because a specialist is considered to be the most qualified to perform the review.

8. Site Grading Audit Elimination - Hope Creek The requirement to perform specific audits of site grading modifications was committed to in a letter to the NRG dated September 10, 1984. This letter stated that modifications to
  • site grading would be covered by the operational QA program. During the operating period of a plant, audits of site grading activities provide minimal value and are considered outdated and unnecessary.

BASIS FOR THE PROPOSED CHANGES A. Procurement Organization Change The MSPS Group, which is being renamed as the PA Group, would continue to perform the same functions that it currently performs. These functions are described in Chapter 17 of the Salem and Hope Creek UFSARs and are as follows:

1. Review of engineering documents such as equipment specifications for inclusion of QA requirements.
2. Review and approves specifications for Q-listed materials, equipment, and services.
3. Review of procurement documents for insertion of QA requirements.
4. Conduct of supplier surveys, audits and surveillances .
  • 5. Evaluation of prospective and existing Supplier QA Programs.

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