ML18151A973
| ML18151A973 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna  |
| Issue date: | 07/28/1993 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 93-406, NUDOCS 9308030401 | |
| Download: ML18151A973 (49) | |
Text
VrRG-INIA ELECTRIC AND PowER COMPANY RICHMOND, VIRGINIA 23261 July 28, 1993 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 NORTH ANNA POWER STATION UNITS 1 AND 2 OPERATIONAL QUALITY ASSURANCE PROGRAM TOPICAL REPORT VEP 1-5A (UPDATED}
Serial No.
NL&P/EJW Docket Nos.
License Nos.93-406 50-280 50-281 50-338 50-339 DPR-32 DPR-37 NPF-4 NPF-7 Pursuant to 1 O CFR 50.54(a)(3), changes to the Virginia Electric and Power Company Quality Assurance Program are submitted.
These changes do not reduce the effectiveness of the quality assurance program. However, five of the changes reduce the commitments in the quality assurance program description previously approved by the Nuclear Regulatory Commission (NRC) and require NRC approval prior to implementation. The changes are described in the attached Synopsis of Changes, and the specific changes are also attached.
With this update, Chapter 17 of each facility's Updated Final Safety Analysis Report (UFSAR) will be used to distribute the Operational Quality Assurance Program Topical Report, VEP 1-5A.
Appropriately, this topical report has been reformatted to accommodate incorporation into the UFSAR. A reduced distribution of VEP 1-5A will be issued for this update (June, 1993), and the distribution of this topical report will eventually be eliminated.
Future revisions to this topical report which do not constitute a reduction in either the effectiveness of the Quality Assurance Program or in the commitments thereto, will be processed as routine revisions to the affected pages of each station's UFSAR (Chapter 17). Those revisions which require NRC approval prior to implementation will be processed by individual change requests to the Operational Quality Assurance Program Topical Report.
9308030401. 930728
. r
~DR ADOCK osoo~B~o t.
Should you have any questions regarding this submittal, please contact us.
Very truly yours, W. L. Stewart Senior Vice President - Nuclear Attachments 1 )
Synopsis of Changes
- 2)
Changes to the Operational Quality Assurance Program Topical Report - VEP 1-5A (Updated) cc:
United States Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.
Suite 2900 Atlanta, GA 30323 Mr. M. W. Branch NRC Senior Resident Inspector Surry Power Station NRC Senior Resident Inspector North Anna Power Station
ATTACHMENT 1 SYNOPSIS OF CHANGES TO TOPICAL REPORT
- svNOP. OF CHANGES TO TOPICA.EPORT CHANGES WHICH REQUIRE NRC APPROVAL PRIOR TO IMPLEMENTATION:
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DOCUMENT 17.2.6 17.2-73 17.2-27 AUDITS 17.2.18 17.2-90 17.2-44 Regulatory 17.2.0 17.2-10 17.2-55 CONTROL The second sentence of the first paragraph (eighth line) is revised to streamline the process for SNSOC reviews of design changes and revisions to those design changes. The proposed revision will limit required SNSOC reviews to only those changes and modifications which affect nuclear safety. SNSOC may elect to review any design change or revision thereto which they deem necessary. The proposed change can be interpreted as a reduction of the commitment.
However, this change has no impact upon the effectiveness of the operational QA program.
The first paragraph in this Section is replaced to add a requirement for a maximum audit frequency of biennial (2 years) for audits described in each unit's Technical Specifications (TS). Audits mandated by the Code of Federal Regulations are not affected by this change, and the Technical Specification audit frequencies must be complied with until NRC approval of the regulatory reduction Technical Specification Change Request. Since the combined Topical Report and TS changes would reduce the current frequencies for certain audits, this Topical Report change is considered to reduce the commitments associated with the audit program. However, the effectiveness of the audit program will not be reduced as a result of this change.
Guide 1.33 Company Position (2) was revised by providing an alternative to Paragraph C.4.c of Regulatory Guide 1.33.
The alternative provides additional flexibility in auditing the performance, training, and qualifications of the facility staff by basing the frequency of the audit upon performance and safety significance, as stipulated in the revised Section 17.2.18.
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Regulatory 17.2.0 17.2-14 17.2-59 Regulatory 17.2.0 17.2-51 17.2-95 DOCUMENT 17.2.6 17.2-73 17.2-27 Guide 1.33 Company Position (15) and its associated Justification were revised by deleting references to "periodic" procedure reviews in the first sentence of the fourth paragraph of Section 5.2.15 of ANSI N18.7-1976.
The alternative specifically affects routine administrative and technical procedures by deleting the requirement for periodically reviewing those procedures. This is considered appropriate because sufficient administrative controls and management oversight exist to ensure that these routine procedures are maintained adequate, accurate, and current.
Additionally, periodic reviews of procedures which are symptom based, event driven, or otherwise required by Company commitments (Emergency Plan Implementing Procedures, Emergency Operating Procedures, Abnormal Procedures, Annunciator Response Procedures, Security Plan Implementing Procedures, etc.) are unaffected by this proposed change.
A Technical Specification Change Request is also being submitted for North Anna Units 1 and 2 to remove the_ references to periodic reviews of station procedures with the above clarifications.
Guide 1.144 The third and fourth paragraphs are revised to streamline the audit process by removing the requirement for a formal response to audit finding followup activities from the audited organization.
Responses to audit findings which detail the completed and planned corrective actions are still required, as are documented followups by the auditor(s). The effectiveness of the QA Program is not reduced, but the specific commitment to respond to audit followups is deleted. As such, this change requires prior NRC approval.
CONTROL The second sentence in the first paragraph is revised to delete the reference to "periodic review of approved nuclear safety related station procedures" for the same reason as item (25a) above.
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ROUTINE CHANGES TO THE TOPICAL REPORT:
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ABSTRACT ABSTRACT ABSTRACT 17.2-v The ABSTRACT is revised to recognize that each facility's UFSAR will be used for internal distribution of the Operational Quality Assurance Program Topical Report within the Company, to describe the relationship of. the QA Topical Report to the effective and successful operation of the nuclear facilities and to other commitments/documents, and to clarify that various names are used to refer to the Topical Report.
TABLE 17.2.0 and TABLE 17.2.2 11.2*.o 17.2 17.2-53 17.2-65 and 17.2-66 17.2 17.2-99 Regulatory Guide 1.8 17.2.0 17.2-4 17.2-49 Regulatory Guide 17.2.0 17.2-10 17.2-55 1.33 3 of 6 Tables 17.2.0 and 17.2.2 are relocated to Appendix Bat the back of the Topical Report. This significantly enhances the document's readability and reformats the document to 'be consistent with the sections in the UFSAR.
Corrects typographical errors with reference to ANS 3.1 (Draft 12/79).
Company Position (1) is revised to clarify the programmatic controls used to define the areas subject to Independent Reviews. Specifically, the facility Emergency Plan, Security Plan, and Fitness For Duty Program are added to the list of appropriate programmatic controls along with Technical Specifications.
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Regulatory 17.2.0 17.2-10 17.2-55 Guide 1.33 Company Position (2) is revised to clarify the programmatic controls used to define the areas subject to Audits.
Specifically, the facility Emergency Plan, Security Plan, and Fitness For Duty Program are added to the list of appropriate programmatic controls along with Technical Specifications.
Regulatory 17.2.0 17.2-46 17.2-91 Guide 1.144 The first paragraph is revised to delete references to audit observations which are no longer used. Concerns identified during the audit process are either determined to be findings (significant and compliance issues) or enhancements (non-significant issues and recommended improvements).
Regulatory 17.2.0 17.2-48 17.2-93 Guide 1.144 Regulatory Guide 17.2.0 17.2-48 17.2-93 Regulatory Guide 17.2.0 17.2-49 17.2-94 Regulatory Guide 17.2.0 17.2-50 17.2-95 The first paragra.ph is revised to correct a
typographical error.
Specifically, "number" is changed to "member."
1.144 The second paragraph is revised to delete references to audit observations which are no longer used.
1.144 The fifth paragraph (1 Oc) is revised to delete references to audit observations which are no longer used.
1.144 4 of 6 The first and second paragraphs are revised to delete references to audit observations which are no longer used.
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ORGANIZATION 17.2.0 and 17.2.1 Organization description is revised to 17.2 17.2-62 reflect minor internal restructuring and 17.2 17.2-18, 17.2-46, to provide a
more accurate and and 17.2-47 comprehensive description.
Two organizational charts are added as Appendix A to enhance the descriptions of the Corporate nuclear organization and the stations' organization.
Certification 17.2.2.7 17.2-68 17.2-22 of Other Support Personnel Material Verification personnel are added to the list of personnel who must be certified in accordance with the approved certification program.
This reflects an organizational change in which the materials verification function and personnel were transferred from the Quality Assurance Department to the Materials Management Department.
CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES 17.2.7 17.2-74 17.2-28 The fifth paragraph is revised to reflect organizational changes in that periodic inspections to assure that applicable material and equipment received at the station meet the requirements of purchase documents is now the responsibility of Materials Management, and Quality Assurance performs an oversight function (monitoring and verification).
CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES 17.2.7 17.2-75 17.2-29 5 of 6 The first paragraph is revised to reflect organizational changes in that the Materials Management representative reviews documentation concerning the quality of material, components, and equipment received for conformance with the purchasing documents.
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INSPECTION 17.2.10 17.2-78 17.2-32 NONCONFORMING COMPONENTS 17.2.15 17.2-84 17.2-38 NONCONFORMING COMPONENTS 17.2.15 17.2-84 17.2-38 The sixth paragraph is revised to update the reference standard used for qualifying NOE personnel.
The updated reference is to Table IWA-1600-1 of the applicable ASME Section XI Code. This is necessary because the applicable Code for Surry Units 1 and 2 will be updated (in October, 1993) to the 1989 Edition which references a later version of standard SNT-TC-1A (1984 edition). Since the 1984 edition of SNT-TC-1 A are considered more stringent than the 1980 edition (current commitment), this change does not involve a reduction in either the effectiveness or commitments of the Operational Quality Assurance Program.
MATERIALS,
- PARTS, AND The fourth paragraph is revised to recognize the use of material hold tags by other groups in addition to Quality Assurance.
MATERIALS,
- PARTS, AND The first, third, and sixth paragraphs are revised to recognize the use of Discrepant Shipment Reports, as well as station Deviation Reports, to identify and address nonconformances of new and reworked materials.
NOTE: Items (1 ), (8), and (23) did not contain sufficient justification for inclusion in the Operational Quality Assurance Program Topical, Report. As such, these item numbers are not listed above.
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CHANGES TO OPERATIONAL QUALITY ASSURANCE PROGRAM TOPICAL REPORT, VEP 1-SA REC'D W/LTR DTD 07/28/93.... 9308030401
-NOTICE-THE* ATTACHED FILES ARE OFFICIAL RECORDS OF THE INFORMATION &
REPORTS MANAGEMENT BRANCH.
THEY HAVE BEEN CHARGED TO YOU FOR A LIMITED TIME PERIOD AND
- MUST BE. RETURNED TO THE RE-CORDS & ARCHIVES.SERVICES SEC-TION P1-22 WHITE FLINT. PLEASE DO NOT SEND DOCUMENTS CHARGED OUT THROUGH THE MAIL. REMOVAL OF ANY PAGE(S) FROM DOCUMENT FOR REPRODUCTION MUST BE RE-FERRED TO FILE PERSONNEL.
-NOTICE-
ATTACHMENT 2 CHANGES TO OPERATIONAL QUALITY ASSURANCE PROGRAM TOPICAL REPORT, VEP 1-5A
TABLE OF CONTENTS Section No.
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Table of Contents 17.2-i List of Figures 17-2-iii List of Tables 17.2-iii List of Amendments 17.2-iv Abstract 17.2-v 17.2 Quality Assurance During the Operations Phase 17.2-1 17.2.0 General 17.2-1
.1 Topical Report 17.2-1
.2 Quality Assurance Standards and Guides 17.2-1 17.2.1 Organization 17.2-3 17.2.1.1 General Description - Organization 17.2-3
.2 Nuclear Management 17.2-4
.3 Organization 17.2-18 17.2.2 Quality Assurance Program 17.2-19 17.2.2.1 General Description 17.2-19
.2 Quality Assurance Program 17.2-20
.3 Identification of Structures, Systems, and Components 17.2-21
.4 Periodic Review of the Operational Quality Assurance 17.2-21 Program
.5 Qualification of Quality Assurance Department 17.2-21 Personnel
.6 Certification of Quality Assurance Department 17.2-22 Personnel
.7 Certification of Other Support Personnel 17.2-22 17.2-i June, 1986
Section No.
17.2.3 17.2.4 17.2.5 17.2.6 17.2.7 17.2.8 17.2.9 17.2.10 17.2.11 17.2.12 17.2.13 17.2.14 17.2.15 17.2.16
.1
.2 17.2.17 17.2.18
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Design Control Procurement Document Control Instructions, Procedures, and Drawings Document Control Control of Purchased Material, Equipment, and Services Identification and Control of Materials, Parts, and Components Control of Special Process Inspection Test Control Control of Measuring and Test Equipment Handling, Storage, and Shipping Inspection, Test, and Operating Status Nonconforming Materials, Parts, and Components Corrective Action Authority to Stop Work Imposition of "Stop Work" Quality Assurance Records Audits 17.2-ii June, 1986
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17.2-23 17.2-25 17.2-26 17.2-27 17.2-28 17.2~30 17.2-31 17.2-32 17.2-34 17.2-35 17.2-36 17.2-37 17.2-38 17.2-40 17.2-41 17.2-41 17.2-43 17.2-44
Figure No.
17.2.1-1 17.2.1-2 Table No.
17.2.0 17.2.2 LIST OF FIGURES (APPENDIX A)
Nuclear Organization Nuclear Station Organization LIST OF TABLES (APPENDIX B)
Conformance of the Company's Operational Quality Assurance Program to NRC Regulatory Guides and ANSI Standards Relationship of the Company's Operational Quality Assurance Program to Appendix B, 10 CFR 50 17.2-iii June, 1986
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17.2-46 17.2-47
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17.2-48 17.2-98
ABSTRACT This topical report describes Virginia Electric and Power Company's, hereafter referred to as the Company, quality assurance program for the operational phase of its nuclear power stations. The report is organized as, distributed, and used for Chapter 17, part 2 - Quality Assurance (Operations) - of the Company's Updated Final Safety Analysis Reports. The Company quality assurance program conforms to applicable regulatory requirements such as 1 O CFR 50, Appendix B and to approved industry standards endorsed therein as clarified within this topical report. Included is' a point-by-point comparison of the program with the 18 criteria of 1 O CFR 50, Appendix B.
This topical report is intended to be a comprehensive up-to-date description of the Company's Operational Quality Assurance Program for nuclear power generating stations.
The Operational Quality Assurance Program is defined as those managerial and administrative policies and controls used to assure the safe and reliable operation of the nuclear facilities. These include all those planned and systematic actions necessary to provide adequate confidence to management and regulatory agencies that structures, systems, and components will perform satisfactorily in service. The Operational Quality Assurance Program encompasses policies, directives, instructions, training, and procedures which ensure compliance with reguations, Codes, standards, licenses, and other Company commitments: As such, this topical report, in conjunction with the applicable operating license, provides the foundation for operating the nuclear facilities in a manner which ensures the safety of the public, employees, and plant equipment. The policies are further defined through the Nuclear Operating Department Standards (NODS), the applicable Safety Analysis Report (SAR), Nuclear Design Control Manual (NDCM), and each facility's emergency plan, physical security plan, radiological protection plan, and fire protection plan.
Administrative and implementing procedures govern the various aspects of day-to-day operation of the nuclear facilities.
The Company's Operational Quality Assurance Program Topical Report is referred to by several generic titles both within this document and within other administrative controls for each nuclear facility. These include Chapter 17.2 of the UFSAR, the [Company's] quality assurance program, the Operational Quality Assurance Program (upper and lower cased letters), the QA Topical Report, VEP 1-5A, Quality Assurance Program - Operational Phase, etc. These are used interchangeably to refer to this document which represents Management's philosophy and methodologies for complying with the 18 criteria of 1 O CFR 50, Appendix B.
17.2-v June, 1986
I.
17.2.1 ORGANIZATION 17.2.1.1 General Description A
Nuclear Organization B.
C.
Nuclear is divided into five distinct groups; Nuclear Operations, Nuclear Engineering Services, Nuclear Services, Nuclear Administrative Services, and Nuclear Quality Assurance. Nuclear Operations, Nuclear Services, Nuclear Administrative Services, and Nuclear Engineering Services are responsible for licensing, operation, and support of the nuclear power stations. Nuclear Quality Assurance has the responsibility to monitor compliance with the Operational Quality Assurance Program.
Nuclear Operations Nuclear Operations is a line organization responsible for operation and maintenance of the Surry and North Anna Nuclear Power Stations. This organization is comprised of various departments, including Operations, Maintenance, Outage & Planning, Nuclear Operations Support, Station Nuclear Safety, Station Emergency Planning, Station Licensing, Station Procedures, Radiological Protection, Chemistry, Safety & Loss Prevention, Station Records Management, and Nuclear Site Services (maintenance support, modifications, and plant improvement projects).
Nuclear Engineering Services Nuclear Engineering Services is the design authority for the Nuclear Organization and provides design and operational engineering support to the nuclear stations. This organization is comprised of departments for each engineering discipline, including Nuclear Engineering, Electrical Engineering, Civil/Mechanical Engineering, Nuclear Analysis & Fuels Engineering, lnservice Inspection/Non-Destructive Examination (ISI/NDE)
& Engineering Programs, and Special Projects.
D.
Nuclear Services E.
Nuclear Services is an organization responsible for Nuclear Licensing and Programs, Nuclear Business Services, Nuclear Training, Nuclear Materials, and Nuclear Emergency Preparedness.
Nuclear Administrative Services The Nuclear Administrative Services Group is responsible for support functions associated with Personnel Administration, Management Information & Planning, Fitness For Duty, and Nuclear Projects.
17.2-3
F.
17.2.1.2 Nuclear OuaHty Assurance Nuclear Quality Assurance is responsible for independently planning and performing activities to verify the development and effective implementation of nuclear management's quality assurance programs for engineering, procurement, construction, modification, maintenance, and operation activities associated with the Nuclear Stations.
Nuclear Management A.
Senior Vice President - Nuclear The Senior Vice President - Nuclear has corporate responsibility for and I directs the planning and development of the Nuclear Organization staff, organization resources, and nuclear power generation.
- 1. Management Safety Review Committee (MSRC)
The MSRC is the body which performs the offsite safety review function. It reports to the Senior Vice President - Nuclear and provides an inde*pendent review in the areas of station operations, maintenance, reactivity management, engineering, chemistry & radiochemistry, radiological safety, quality assurance practices, and emergency preparedness. The Technical Specifications of _each station further define the function, composition, alternates: consultants, meeting frequency, quorum, reviews, audits, authority and records of this committee.
- 2. Nuclear Oversight Board (NOB)
The NOB functions to provide independent review and oversight of nuclear activities at the senior management level and in an advisory capacity to the Senior Vice President - Nuclear. The NOB reviews nuclear management practices, policy issues, regulatory and performance trends and organizational factors relating to nuclear activities, and provides program oversight through management reports, document reviews, group discussions, and individual experience. Membership consists of senior nuclear utility executives and other members appointed on the basis of industry knowledge and/or expertise. -
B.
Yice President-Nuclear Operations The Vice President - Nuclear Operations is the Corporate individual responsible to the Senior Vice President - Nuclear for the operation of the nuclear power stations. He has overall responsiE>ility for implementing the quality assurance program for the operational phase of the nuclear power stations.
17.2-4 I
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- 1. Assistant Vice President - Nuclear Operations Responsible to the Vice President - Nuclear Operations and provides assistance in the day-to-day operation of the nuclear power stations.
- 2. Station Manager Responsible to the Vice President - Nuclear Operations for the overall safe and efficient operation of the station, and for the implementation of quality assurance requirements in the areas specified by the operational quality assurance program. The Station Manager has supervisory control over all Virginia Electric and Power Company personnel within the station organization and administrative control over all other Company and non-Company individuals within the nuclear site's boundary.
The Station Manager is the local representative of Company management and is empowered to implement all Company policy with regard to operations of the facility, support of Company public relations policy, and employee relations policies. The Station Manager is also responsible for coordinating station functions with offsite (Company and non-Company) agencies and services.
In the absence of the Station Manager, these duties will be assumed I by the _Assist~nt Stati?n M_8:nager (Operations & Maintenance) unle~s otherwise designated in wntmg.
- a. Assistant Station Manager (Operations and.Maintenance)
Responsible to the Station Manager for directing and coordinating all aspects of day-to-day station operations and maintenance. The Assistant Station Manager Operations and Maintenance (O&M) is the Vice Chairman of the Station Nuclear Safety and Operating Committee (SNSOC) and is responsible for planning and coordination of unit outages.
In the absence of the Assistant Station Manager (O&M), the Station Manager assumes the duties of the Assistant Station Manager (O&M). In the absence of both the Station Manager and the Assistant Station Manager (O&M),
these duties will be assumed by the Superintendent - Operations unless otherwise designated in writing.
- a. 1 Superintendent-Operations I
The Superintendent - Operations reports directly to the Assistant Station Manager (O&M) and is responsible for directing and coordinating station operations and fuel handling activities in accordance with 'approved plans, programs, licenses, Technical Specifications, and good operating practices. He is responsible for identifying deviations from the Technical Specifications and Facility Operating License (FOL) and for reporting any unusual occurrences in connection with station operations to the Assistant Station Manager (O&M or NS&L).
17.2-5
The Superintendent - Operations is also responsible for: 1) development and implementation of uniform operating policies and procedures, 2) implementation of on-the-job training for Operations personnel, 3) ensuring that each shift is adequately staffed and sufficient back-up personnel are available, 4) ensuring that all required operating data is properly recorded and retained as appropriate, and 5) being a participating member of the SNSOC.
a.1.1 Supervisor Shift Operations The Supervisor Shift Operations reports to the Superintendent - Operations and provides direct supervision to the Shift Supervisors, operational input to the SNSOC, and identifies any deviations from the Technical Specifications or any unusual events.
The Supervisor Shift Operations must possess a valid Senior Reactor Operator (SRO) license, and may only be relieved by an individual who possesses a valid SRO license.
This position fulfills the function of the "operations. manager" as described in ANS 3.1 (12ll9 Draft}.
a.1.2 Operations Shift Supervisor The Operations Shift Supervisor directs the operations activities of the station for the assigned shift.
He is responsible for maintaining the safe operation of the facility under all conditions and maintaining a broad perspective of the operational conditions affecting the safety of the facility. The Operations Shift Supervisor shall not become totally involved in any single operation when multiple operations are occurring at the facility.
When both units are operating, the Operations Shift Supervisor may have command responsibility for one of the operating units in addition to being responsible for overall command of the facility.
The Operations Shift Supervisor shall perform the initial classification of station deviation reports (e.g.,
"REPORTABLE" or "NON-REPORTABLE"). If any event listed in the administrative procedure for notification requirements is identified, the Operations Shift Supervisor shall notify the Superintendent Operations or the SRO on call.
17.2-6
The Operations Shift Supervisor must possess a valid I SRO license, and may only be relieved by an individual who possesses a valid SRO license.
- a. 1.3 Assistant Shift Supervisor During two unit operation, Assistant Shift Supervisors (Operations) are normally delegated the command responsibility for one of the units and report directly to the Operations Shift Supervisor.
The Assistant Shift Supervisor is responsible for ensuring that unit operations during his shift are conducted in accordance with the requirements of the Technical Specifications, the currently approved operating procedures, and Company policies which apply to his shift.
The Assistant Shift Supervisor must possess a valid SROI license, and may only be relieved by an individual who possesses a valid SRO license.
a.2 Superintendent Maintenance The Superintendent Maintenance reports directly to ttie Assistant Station Manager (O&M) and is responsible for directing and coordinating the mainte*na*nce activities at the station. He is responsible for: 1) ensuring that station facilities and equipment are maintained in accordance with regulatory requirements and station procedures, 2) the development and implementation of uniform policies and procedures for installation, maintenance, and repair of station equipment and systems, 3) ensuring maintenance tasks will be performed in a timely and efficient manner, 4) detailed maintenance planning to support scheduled outages being completed as needed, and 5) participating as a member of the SNSOC.
The Supervisor Electrical Maintenance, Supervisors Mechanical Maintenance, Supervisor Instrumentation & Control, Supervisor Maintenance Support, Supervisor Maintenance Engineering, and Quality Maintenance Team (QMT) Coordinator report to the Superintendent Maintenance.
a.3 Superintendent Outage & Plaooiog I
The Superintendent Outage & Planning reports directly to the Assistant Station Manager (O&M). He is responsible for the overall planning and scheduling of maintenance and maintenance-related work activities such that safe and reliable plant operation is optimized. He is also responsible for the execution of outages, maintenance of plant equipment history, and monitoring of station performance.
17.2-7
The Unit Outage Coordinators, Supervisor Daily Planning, and Supervisor Scheduling report to the Superintendent Outage &
Planning.
- b. Assistant Station Manager (Nuclear Safety and Licensing)
Responsible to the Station Manager for directing and coordinating nuclear safety issues at the station. The Assistant Station Manager (NS&L) is the Chairman of the Station Nuclear Safety and Operating Committee (SNSOC) and conducts periodic meetings to ensure compliance with station technical specifications, manage licensing activities within the station, interface with the Manager-Nuclear Licensing and Programs on operating experience and safety and licensing issues, manage station procedures and manage station emergency plan activities. The Assistant Station Manager (NS&L) maintains information on industry operating experience, is cognizant of licensing and regulatory issues, administers the Commitment Tracking System (CTS), is responsible for nuclear safety and the Shift Technical Advisors (STAs), administers the Station Emergency Plan, and ensures adequate training for station employees regarding emergency preparedness.
b.1 Supervisor - Station Nuclear Safety (SNS)
- I The Supervisor - SNS reports directly to the Assistant Station Manager (NS&L) and is responsible for providing guidance to and monitoring the performance of the Shift Technical Advisors (STAs).
He is responsible for administration of the station deviation report (DR) program including multidiscipline reviews, reviewing DRs for reportability to the NRC, presentation to SNSOC, and maintenance of the database. The Supervisor -
SNS is also responsible for reviewing DRs for adverse trends and providing periodic trend reports to management, analyzing plant performance following transients or reactor trips, administering the Operation Experience Program, and implementing the Human Performance Enhancement Program.
b.2 Supervisor - ucensiog The Supervisor - Licensing reports directly to the Assistant Station Manager (NS&L) and is responsible for the coordination of licensing activities for the power station to ensure compliance with regulatory requirements. He is responsible for managing the Commitment Tracking System, ensuring that commitments are completed or resolved by the appropriate date, providing interface with regulatory agencies, interfacing with SNS and Corporate Nuclear Licensing and Programs (NL&P), preparing Licensee Event Reports (LERs), presenting LERs to SNSOC, and submitting the LERs to the NRC.
17.2-8
b.3 Supervisor - Station Procedures The Supervisor - Station Procedures is responsible to the Assistant Station Manager (NS&L) for the development, review, and approval of technical procedures used at the station and to ensure the technical and editorial accuracy of the procedure generation and revision processes.
b.4 Station Coordinator - Emergency Planning The Station Coordinator - Emergency Planning reports directly to the Assistant Station Manager (NS&L) and is responsible for the administration and coordination of the Station Emergency Plan.
He coordinates emergency preparedness activities between station departments, corporate support organizations, local political subdivisions, and emergency response groups.
The Station Coordinator - Emergency Planning also assists in developing and conducting emergency preparedness training programs and emergency drills.
b.5 Station Environmental Compliance Coordinator (ECC)
The Station ECC reports directly to the Assistant Statio"n Manager (NS&L) and is responsible for_ the administration and coordination of the environmental issues associated with the station.
He coordinates environmental protection related activities between station departments and corporate support organizations (Air and Water Quality) and assists in the initial determination of environmental event reportability. The ECC also assists in developing and conducting response training for non-radiological environmental events (e.g., oil spills, hazardous substance spills, etc.).
- c. Superintendent Site Services Responsible to the Station Manager for directing all aspects of assigned projects including coordination of activities with station management, engineering, and construction. Support activities such as accounting, procurement planning, scheduling and cost control are also included in these responsibilities.
The Superintendent - Construction, Supervisor - Construction Engineering, Supervisor - Construction Controls, and Supervisor -
Facilities & Support report to the Superintendent Site Services.
17.2-9
- d. Superintendent Radiologjcal Protection Responsible to the Station Manager for administering the Radiological Protection Program at the station. Responsibilities include:
- 1) monitor the radiological effluent programs and personnel radiation protection programs, 2) maintain records of radiological exposures for all persons working or visiting within the station's restricted area, 3) ensure regular surveys of the station, 4) maintain records of background radiation levels, and 5) check all radioactive material releases and shipments from station and maintain appropriate records. The Radiological Protection group is responsible for determining the radiation levels of all work areas, and posting, as needed, areas where sources of radiation exist.
Additionally, the Superintendent Radiological Protection is also responsible for managing the primary and secondary plant chemistry programs and for coordinating activities related to non-radiological environmental protection.
The Superintendent Radiological Protection directs the activities of his group to minimize the exposure of station personnel to excessive doses of radiation and to prevent the spread of radioactive contami!'lation.
All activities in these areas are coordinated with other station groups to ensure full awareness 'of problems through implementation of the station ALARA program.
The Superintendent Radwaste (Surry), Supervisor Radiological Engineering, Supervisor Health Physics Technical Services, Supervisor Health Physics Operations, and Supervisor Chemistry report to the Superintendent Radiological Protection.
The Superintendent Radiological Protection also participates as al member of the SN SOC.
- e. Supervisor Administrative Services The Supervisor Administrative Services reports to the Station Manager and is responsible for managing the activities related to administrative tasks for smooth station operation. These tasks include: planning and budget, station records management, station safety and loss prevention, fire protection, and medical assistance.
The Business Systems Supervisor, Supervisor Records Management, Supervisor Station Safety & Loss Prevention, and Site - Access In-Process Coordinator report to the Supervisor Administrative Services.
17.2-10
- f.
Station Supervisory Personnel Responsible directly to the Station Manager through their respective superintendents, for implementing the operational quality assurance program requirements applicable to their specific areas of responsibility.
- g. Station Staff It is the responsibility of each member of the station staff to adhere to the provisions contained in the operational quality assurance program when performing their work tasks to assure quality workmanship.
Personnel with unescorted access status shall receive training (Nuclear Employee Training) in the use of and adherence to the operational quality assurance program.
- h. station Nuclear Safety and Operating Committee I
Serves in an advisory capacity to the Station Manager. The technical specifications of each station define the responsibilities of this committee.
The Station Nuclear Safety and Operating Committee is separate from operational quality assurance activities in that its authority and responsibilities are not established by the Operational Quality Assurance Program. However, since the prime responsibility of this committee is to provide a continuing review of the operational and safety aspects of the station, it does perform a quality assurance function.
- 3. Manager - Nuclear Operations Support Responsible to the Vice President-Nuclear Operations to manage the system level support involving maintenance, operations, health physics, chemistry, procedures, and outage management services for the operating nuclear power stations.
- a. Director - Health Physics/Chemistry Responsible to the Manager - Nuclear Operations Support for providing health physics and chemistry support services for nuclear stations.
17.2-11
C.
- b. Qi rector - Maintenance Support Responsible to the Manager - Nuclear Operations Support for providing and assessing operations and maintenance programs, coordinating major equipment repair or replacement, reviewing station efficiency, and for making recommendations for improvement.
- c. Director - Methods and Procedures Responsible to the Manager - Nuclear Operations Support for the production and maintenance of corporate and station standards and administrative procedures and for coordinating station production and maintenance of station technical procedures.
Vice President - Nuclear Services I
Responsiple to the Senior Vice President - Nuclear and has corporate responsibility for long-term nuclear operations support activities. As such, he has responsibility for. the system level implementation of tt,e requirements established by the Operational Quality Assurance Program for the nuclear power stations.
- 1. Manager - Nuclear Ucensing & Programs Responsible to the Vice President - Nuclear Services for providing overall direction, coordination and support of activities related to licensing, nuclear safety review and interaction with outside agencies to support safe, reliable and efficient operation of the power stations.
This includes serving as the lead interface with the Nuclear Regulatory Commission on regulatory issues, coordinating communications with outside organizations, such as INPO and NUMARC, and performing independent safety reviews of station activities and programs.
- a. Director - Corporate Nuclear Safety Responsible to the Manager - Nuclear Licensing & Programs for providing overall direction for the,Nuclear Group's independent safety review of station activities and programs. This includes nuclear safety assessments of company events, issues or trends, implementation of the industry operating experience program and performance of independent review of safety evaluations.
17.2-12
a.1 Supervisor - Nuclear Safety Review Responsible to the Director - Corporate Nuclear Safety for providing independent performance based assessments of potentially significant nuclear safety events, issues, or adverse trends to identify underlying causes and recommend corrective actions.
Supervise and support assessments to assure accomplishment of INPO performance objectives and regulatory requirements.
- b. Supervisors - Licensing Responsible to the Manager - Nuclear Licensing and Programs for providing support for the stations in the areas of safety review, NRC issues and actions, and technical and strategic support for licensing and regulatory agency submittals, hearings, and conferences.
- 2. Director - Emergency Preparedness Responsible to the Vice President - Nuclear Services for managing the overall scheduling and coordination of emergency testing and training exercises with federal, state, and local agencies.* Works with corporate and nuclear station managers and personnel to ensure emergency plans meet all the requirements and commitments.
- 3. Manager - Nuclear Training Responsible to the Vice President - Nuclear Services for training of personnel who operate or support the nuclear power stations, including Quality Assurance personnel.
Training responsibilites include:
determining the need for training based on information provided by the Nuclear Group, developing performance-based training programs, implementing training programs to support employee and station needs, and evaluating training programs.
- 4. Manager - Nuclear Business Services Responsible to the Vice President - Nuclear Services for programs supporting budgeting, management reporting, document control, records management, publication design, and graphic support for the Nuclear Department.
In addition, Nuclear Business Services is responsible for assessment of the programs' performance and follow-up actions to ensure program objectives are accomplished.
17.2-13 I
D.
- a. Director - Nuclear Document Control Reports directly to the Manager - Nuclear Business Services and is responsible for development, implementation, maintenance and routine assessment of the Nuclear Document Management Program.
- s. Manager - Nuclear Materials Responsible to the Vice President - Nuclear Services for ensuring that necessary parts and materials meeting quality and/or design requirements are available when needed.
The Superintendents - Materials and Director - Materials Management I (Nuclear) report to the Manager - Nuclear Materials.
Yice President - Nuclear Engineering services The Vice President - Nuclear Engineering Services is responsible to the Senior Vice President - Nuclear for civil, electrical, mechanical, and nuclear engineering, incluoing establishment, implementation and maintenance of programs to control design input, final design, desig'n output, internal and external design interface, and.design authority. He is also responsible for procurement engineering, inservice inspection and nondestructive examination programs, nuclear core design, safety analysis, reactor performance evaluation, spent fuel disposition, fuel inspection, and fuel surveillance.
- 1. Manager - Nuclear Engioeenng Responsible to the Vice President - Nuclear Engineering Services for implementing the operational quality assurance program in the following areas:
Implementation of engineering standards for nuclear design control.
Engineering evaluation of generic industry issues.
Management of engineering resources for specific tasks.
Design Basis Documentation Program.
- a. Superintendent - Station Engjneerjng (one at each station)
Responsible to the Manager - Nuclear Engineering for the implementation of the operational quality assurance program in the following areas:
17.2-14 I
Implementation of the design change program at the site including initiating field changes as required.
Providing engineering disposition to Deviation Reports as required.
Managing the drawing update program.
Managing engineering services as requested by station management.
- 2. Manager-Nuclear Analysis and fuel Responsible to the Vice President-Nuclear Engineering Services forl the development and implementation of the operational quality assurance program in the following areas:
Nuclear fuel management and core design Core and system thermal hydraulic analysis Fuel performance analysis Reload safety evaluation Engineering support for spent fuel disposition Post Accident Radiation Dose Calculation Reactor performance evaluation Special nuclear material accountability Inspection and surveillance of nuclear fuel and related items at the stations and vendors Engineering evaluation of fuel vendors Site reactor engineering
- 3. Manager 1$1/NPE & Engineering Programs Responsible to the Vice President - Nuclear Engineering Services for the lnservice Inspection (ISi) Program and the Nondestructive Examination (NOE) Services Program and other engineering programs in the following areas:
17.2-15
Direction of the lnservice Inspection Program relative to sound judgment, company requirements, and regulatory and enforcement authority requirements.
Management and assessment of the effectiveness of the lnservice Inspection Program through reviews, evaluations, and updates.
Development of the inservice inspection programs, plans, and schedules.
Development, maintenance, and implementation of the Nondestructive Examination Services Program.
Performance and the technical aspects of nonde'structive examinations.
Qualification and certification of Virginia Power NOE personnel.
Management and assessment of the effectiveness of procurement engineering.
Control and implementation of General Engineering standards for nuclear design control.
Engineering programs to maintain compliance with regulatory issues.
Reviewing procurement documents.
Managing the commercial grade procurement/dedication process.
Vendor manual control.
Managing the Equipment Data System (EDS) and Bill of Material System (BOM).
Managing the Q-list and equipment and component safety classification programs.
Development and Maintenance of the Corporate Welding Manual.
Provide material and metallurgical assessments and recommendations for existing and proposed new equipment.
Provide material failure analysis and evaluations.
Welding/corrosion engineering and fabrication support on in-house and AE/contractor designed material.
- 4. Managers - (Civil/Mechanjcal and Electrical) Engineering Responsible to the Vice President - Nuclear Engineering Services.
These managers provide engineering services through a project matrix organization to the Manager - Nuclear Engineering. Activities include preparation of design change packages and engineering evaluations, corporate administration of design engineering programs, control and implementation of discipline-specific engineering standards for nuclear 17.2-16
I~
E.
F.
design control, development of procurement specifications, construction drawings, technical reviews, calculations, etc.
Vice President - Procurement I
The Vice President - Procurement is responsible to the Senior Vice President - Corporate Services for the acquisition of all fuels, materials, supplies, services, and transportation.
- 1. Manager - Contracts Manager - Contracts is responsible to the Vice President-Procurement for performing contract administration functions in support of the operational quality assurance program for the nuclear power stations, I except for fuel and fuel-related services.
- 2. Manager - Fuel Procurement Manager - Fuel Procurement is responsible to the Vice President -
Procurement for the purchasing of nuclear fuel and related services, and to adhere to the provisions contained in the operational quality I assurance program applicable to his respective area of responsibility.
- 3. Manager - Purchasing Manager - Purchasing is responsible to the Vice President Procurement to procure the equipment, materials, supplies and general and technical services in support of the operational quality assurance program at the nuclear stations.
Manager-Nuclear Quality Assurance The Manager-Nuclear Quality Assurance is responsible to the Senior Vice President - Nuclear for the establishment of, and monitoring compliance with, the quality assurance program for engineering, construction, and operation activities of Nuclear Operations. The Manager - Nuclear Quality Assurance may make recommendations to the Vice President - Nuclear Operations, the Vice President - Nuclear Services, or other levels of management. If the Manager - Nuclear Qu,ality Assurance disagrees with any action taken by the Nuclear group, and is unable to obtain resolution, the Manager - Nuclear Quality Assurance shall bring the matter to the attention of the Senior Vice President - Nuclear who will determine the final disposition.
17.2-17 I
G.
17.2.1.3
- 1. Manager-Quality Assurance (Station) (one at each site)
The Manager-Quality Assurance (Station) is responsible to the Manager - Nuclear Quality Assurance for monitoring compliance with the operational quality assurance program for the nuclear power stations, conducting assessments of station activities and the technical support of the quality assurance effort associated with the modification, operation, and maintenance of the nuclear stations. The Manager -
Quality Assurance (Station) may make recommendations to the Station Manager or other levels of management. If he disagrees with anyl actions taken by the Station Manager, he shall notify the Manager -
Nuclear Quality Assurance and the Vice President - Nuclear Operations.
- 2. Manager - Quality Assurance <Corporate}
The Manager - Quality Assurance (Corporate) is responsible to the Manager - Nuclear Quality Assurance for monitoring compliance with the quality assurance program, for conducting assessments of corporate and station activities, for scheduling and conducting internal audits, inspection and audit of vendors and contractors, preparatic;m and maintenance of the Safety-Related Vendors List, quality review of safety-related procurement activities, and.
those areas of the operational quality assurance program as may be assigned to his areal of responsibility.
Director - Nuclear Administrative services The Director - Nuclear Administrative Services is responsible to the Senior Vice President - Nuclear for Personnel/Human Resources, Management Information and Planning, and Fitness for Duty. Other responsibilities include: providing staff support to the Senior Vice President - Nuclear and coordinating international information exchange activities.
I Organization I
Each nuclear power station's Technical Specifications contain the company's organizational requirements for facility operation and corporate management. Additionally, duties and responsibilities of keyl positions within the nuclear organization are further defined in the appropriate administrative controls.
17.2-18
17.2.2.6 Certification of Quality Assurance Department Personnel The certification of Quality Assurance Department personnel is accomplished in accordance with the Quality Assurance Certification Program. This program provides for the certification and recertification of Level I, Level II and Level Ill inspectors, and for auditors and lead auditors.
The program outlines the qualification and certification requirements for personnel and requires the individual to be certified prior to performing specified inspection or audit functions.
The Supervisor - Quality has the responsibility to certify/qualify inspection/audit personnel.
17.2.2. 7 Certification of Other Support Personnel The certification of Quality Maintenance Team (QMT) personnel, Material Verification personnel, Fuel Accountability and Inspection personnel, and lnservice Testing personnel is accomplished in accordance with the approved certification programs.
These programs -outline the qualification and certification requirements of personnel and require the individual to be certified prior to performing specified functions. The Supervisor - Quality has the responsibility to certify/qualify Quality Maintenance Team (QMT) personnel.
17.2-22
17.2.6 DOCUMENT CONTROL Measures are established and documented within the operating nuclear power stations and at Innsbrook Technical Center describing the control of documents, such as procedures, instructions, and drawings, to provide for their review, approval, and issue, and changes thereto, prior to release and to assure they are adequate and the quality requirements are stated. Provisions call for, among other things, (1) the review and approval of all new station procedures and design changes prior to release, the I review and approval of all changes/revisions to station procedures and all proposed changes or modifications to plant systems or equipment that affect nuclear safety by the Station Nuclear Safety and Operating Committee, (2) policy and procedures for issuance of and changes to station drawings and approval of changes, and (3) the maintenance and distribution of these procedures. Normally changes to documents are reviewed and approved by the same organizations that performed the original review and approval; however, this responsibility may be delegated to other qualified responsible organizations. Approved changes are incorporated into procedures and drawings and other appropriate documents associated with the change. Procedures and drawings and changes thereto are processed, distributed and controlled. The station maintains a record of all holders of procedures and drawings and an index of all procedures and draw~ngs, listing the current revision date. Instructions require that a copy of the appropriate procedure be available at the activity location prior to the commencement of that activity. These measures are addressed in the Technical Specifications and Administrative Procedures for each station.
Administrative procedures list certain documents that require strict administrative control for distribution, revision, and routing. These documents are categorized as "Controlled Documents."
Examples of controlled documents are:
Station Procedures, Station Drawings, and the Precautions, Limitations, and Setpoint Document. Also set forth are the distribution and controlling procedures for design and procurement documents. The Quality Assurance Department makes periodic inspections and audits of documents to verify their status, using a current master copy.
17.2-27
17.2.7 CONTROL OF PURCHASED MATERIAL EQUIPMENT, AND SERVICES An evaluation of suppliers is performed prior to contract award, except in emergency situations where an item or service is needed to preclude development or deterioration of an unsafe condition at the plant, by one or more of the following: (1) A review of the supplier's capability to comply with the elements of 1 O CFR 50, Appendix B that are applicable to the type of material, equipment, or service being procured, (2)
A review or previous records and performances of suppliers who have provided similar articles of the type being procured, (3) A survey of the supplier's facilities and quality assurance program to determine his capability to supply a product or service which meets the design, manufacturing, and quality requirements, or (4) A review of qualification information supplied by another utility or outside organization.
Surveillance of suppliers during fabrication, inspection, testing, and shipment of materials, equipment, and components is planned and performed in accordance with written procedures to assure conformance to the purchase order requirements as applicable. These procedures provide for:
- a. Instructions that specify the characteristics or processes to be witnessed, inspected or verified, and accepted; the method of surveillance and the extent of documentation required; and those responsible for implementing these instructions. Surveillance shall be performed on those items where verification of procurement requirements cannot be determined on receipt.,
- b. Audits and/or inspections which assure that the supplier complies with all quality requirements.
These evaluations are performed under the supervision of the Manager -
Quality Assurance (Corporate), except for surveillance of nuclear fuel related suppliers. The surveillance of suppliers of nuclear fuel and related items is performed under the supervision of the Manager - Nuclear Analysis and Fuel. The results of these actions are documented and filed.
Administrative procedures describe the requirements for controlling purchased material, equipment, and services including commercial grade items for use on safety-related structures, systems, equipment, and components. The requirements applied to spare and replacement parts are at least equivalent to those applied to the original parts. Periodic inspections by the Materials Management Department are made for assuring that applicable material and equipment received at the station meet the requirements of the specifications, purchase orders, code, drawings, or other purchasing documents.
This assurance includes the review of documentation received, physical inspection, cleanliness, packaging, marking or functional testing, as required. Purchased items are normally under the control, of the "on-site" organization.
This organization is authorized to contact system organizations and NSSS, A/E contractors and subcontractors through the auspices of system representatives for assistance as required.
Monitoring and verification of these activities are I performed under the supervision of the Manager-Quality Assurance (Corporate).
Periodic evaluations or monitoring of procurement history of the suppliers are performed to verify continued supplier capability.
17.2-28
Documentation concerning the quality of material, components, and equipment received is reviewed by the Materials Management representative for conformance with the Purchase Requisition and Purchase Order.
The procurement of nuclear fuel is controlled in accordance with procedures that have been developed by the Engineering and Procurement Organizations to address the requisite quality attributes of this function. Monitoring and verification of this activity is performed under the supervision of the Manager - Quality Assurance (Corporate).
17.2-29
17.2.1 o INSPECTION Inspection procedures for those activities affecting quality have been established. These procedures govern the inspection and documentation of activities relating to repairs, modifications, and changes made to safety related systems, structures, and components. Written maintenance procedures are provided which include inspection hold points.
Examinations, measurements, or tests of materials or components associated with safety-related equipment and systems are performed for each work operation, where necessary, to assure quality. If inspection is impossible or inappropriate, indirect control by monitoring methods, equipment, and personnel is provided. Both methods are provided when control is inadequate wi~hout both.
The station safety-related maintenance procedures (including modification procedures) are reviewed by the Supervisor-Quality or designee (Inspections) to determine the need for an independent inspection and the degree and method if such an inspection is required.
Examinations, measurements, or tests that require witnessing are identified as "inspection hold" points in procedures. The inspection performed at a hold point is specific in nature; quality characteristics and acceptance/rejection criteria are included or qualitative criteria such as operability checks, compliance with procedural steps, or cleanliness instructions are specified-.
The inspection is documented by signature or initials on the written procedure form.
Quality Assurance Department performs physical inspections at random intervals to ensure quality requirements are met. These checks are performed as the conditions of the maintenance warrant. These personnel and other inspectors are qualified in accordance with codes and standards as applicable to the function they are performing.
The inspection program requires that inspectors be assigned as appropriate for the activity being inspected. An inspector may be a member of the organization performing the activity. However, they must be qualified and shall not be the person performing the activity or the supervisor directly responsible for the activity.
For example, Quality Maintenance Team personnel when performing Quality Control inspections are under the direction of the Supervisor - Quality (Inspection). Personnel so assigned shall become familiar with the procedure being used and other pertinent documents such as technical manuals and drawings prior to performing the inspection.
Personnel responsible solely for the conduct of nondestructive examination are qualified to SNT-TC-1A as referenced by Table IWA-1600~1 of the applicable Code. In addition, personnel who conduct inservice or preservice examinations meet the additional and/or alternative qualification requirements specified by IWA-2300 for the applicable examination method and qualification level. Audits and reviews of their findings and associated corrective actions are periodically conducted by quality assurance personnel to assure that these procedures are being carried out in a quality manner. The inspectors qualifications are periodically reviewed for recertification.
17.2-32
17.2.15 NONCONFORMING MATERIALS, PARTS, AND COMPONENTS A documented system for controlling nonconformances observed during receipt inspection, storage, fabrication and erection, installation, initial and/or acceptance testing, or initial operation is established and provides for the preparation, issuing, and distribution of Station Deviation Reports and Discrepant Shipment Reports in accordance with prescribed procedures. These procedures apply to new or reworked materials, parts, or components which possess manufacturer/supplier caused nonconformances.
The identification, documentation, segregation, review, disposition, and notification to affected organizations of nonconforming material, parts, or components are described or referenced in station Technical Specifications, Administrative procedures, and/or station operating procedures.
Nonconformance of purchased services are controlled under Section 17.2. 7 Control of Purchased Material, Equipment, and Services; Section 17.2.10 Inspection; and administrative procedures.
Specifically, instructions require that the individual discovering a nonconformance identifies, describes, and documents the nonconformance on a Station Deviation Report or a Discrepant Shipment Report in accordance with administrative procedures.
When a nonconforming item is identified, it is placed in the hold area established in the storeroom or other segregated location, if practical, and identified with a hold tag to prevent its inadvertent use. If material is dispositioned as 'reject' the hold tag shall remain attached to the material/component until loaded for departure I from site and shall only be removed in accordance with approved procedures by authorized personnel at that time.
Hold items may be released on a risk basis following the documented approval of such risk release by the Station Manager on a Release on a Risk Basis Form. Each risk release is handled on a case basis and depends on the nature of the hold status.
The basis and conditions of the release are described on the form, including the criteria for clearing the original hold status. Rejected material is not risk released.
A Station Deviation Report or a Discrepant Shipment Report for a nonconforming material, part, or component dispositioned "accept as is" requires an engineering analysis and approval. The results of this review and approval are documented and become a part of station records.
Should the disposition of a nonconformance require the rework or repair of materials, parts, components, systems, or structures, such rework or repair is reinspected or retested by a method which is at least equal to the original inspection or test. method.
The inspection requirements and the inspection, rework, or repair procedures are documented and become a part of station records.
17.2-38
17.2.18 AUDITS The system of audits devised to verify compliance with quality related aspects of the power station is described in the station Technical Specifications. Audits of selected aspects of operational phase activities are performed with a frequency commensurate with safety significance and in a manner which assures that biennial (2 years) audits of safety related activities are completed. The audits are regularly scheduled on a formal preplanned audit schedule. The audit system is reviewed periodically and revised as necessary to assure coverage commensurate with current and planned activities. Additional audits may be performed as deemed necessary by management. The scope of the audit is determined by the quality status and safety importance of the activities being performed. These audits are conducted by trained personnel not having direct responsibilities in the area being audited and in accordance with preplanned and approved audit plans or checklists.
The Quality Assurance Department is delegated the responsibility for conducting periodic audits to determine the adequacy of the station's programs and procedures, that they are meaningful, and comply with the overall Quality Assurance Program.
An audit includes an objective evaluation of quality related practices, procedures, and instructions; the effectiveness of implementation; and the conformance with policy and directives. An audit also includes the evaluation of work area, activities, processes, and items and the review of documents and records.
Provisions are established requiring that audits be performed in those areas where the requirements of Appendix B to 1 O CFR 50 are being implemented. These areas include as a minimum, but are not limited to, those activities associated with operation, maintenance, modification, and repair controls; the preparation, review, approval, and control of design changes, procurement documents, instructions, procedures, and drawings; receiving and plant inspections; indoctrination and training programs; the implementation of the operating and test procedures; and the remaining criteria in Appendix B to 10 CFR 50.
The results of each audit are reported in writing to the distribution delineated in accordance with station Technical Specifications. Additional internal distribution is made to other concerned management levels in accordance with approved procedures.
Management responds to all audits and initiates corrective action where indicated. Where corrective action* measures are indicated, documented follow-up of applicable areas through inspections, review, re-audits, or other appropriate means is conducted to verify implementation of assigned corrective action.
17.2-44
APPENDIX A FIGURES NUCLEAR ORGANIZATION
APPENDI.
NUCLEAR ORGA TION FIGURE 17.2.1-1 Senior Vice President Senior Vice President I
MSRC I
Nuclear NOB I Corporate Services I
17.2.1.2.A.1 17.2.1.2.A 17.2.1.2.A.2 I 17.2.1.2.E 188cretary to Senior 1 I Regulatory Affairs I Vice President Executive I
Advisor Procurement 17.2.1.2.E I
I I
I Vice President Nuclear Vice President Vice President Nuclear Manager Nuclear Director Nuclear Administrative Operations Nuclear Services Engineering Services Quality Assurance Services 17.2.1.2.B 17.2.1.2.C 17.2.1.2.D 17.2.1.2.F 17.2.1.2.G Assistant Vice Manager Nuclear Manager Nudear Manager Quality Supervisor Management Licensing and
-President Nuclear Engineering Assurance information and Planning Operations Programs (Corporate) 17.2.1.2.B.1 17.2.1.2.C.1 17.2.1.2.D.1 17.2.1.2.F.2 Station Manager Manager Nuclear Manager Nudear Manager Quality Personnel Administrator Training Electrical Assurance (Corporate)
Surry Enaineerina (Surry) 17.2.1.2.C.3 17.2.1.2.D.4 L 17.2.1.2.B.2 17.2.1.2.F.1 Assistant Station Manager Nuclear Manager Nuclear Manager Quality Supervisor Nuclear Business Services Analysis and Fuel Assurance Personnel Services Managers (North Anna)
Surrv 17.2.1.2.B.2.a&b 17.2.1.2.C.4 17.2.1.2.D.2 17.2.1.2.F.1 Station Manager Manager Nuclear Manager ISI/NDE Supervisor Nuclear i-Materials and Engineering
.. Personnel Services North Anna Programs North Anna L 17.2.1.2.B.2 17.2.1.2.C.5 17.2.1.2.D.3 Assistant Station Director Emergency Manager Preparedness Civil/Mechanical Managers Engineering 17.2.1.2.C.2 17.2.1.2.B.2.a&b 17.2.1.2.D.4 Manager Nuclear Operations Support 17.2.1.2.B.3 17.2-46
I Assistant Station Manager (O&M) 17.2.1.2.B.2.a Superintendent Operations 17.2.1.2.B.2.a.1
~ Supervisor Shift I Operations 17.2.1.2.B.2.a.1.1 H
Operations Shift Supervisor 17.2.1.2.B.2.a.1.2
~ Assistant Shift Supervisor 17.2.1.2.B.2.a.1.3 Superintendent Maintenance 17.2.1.2.B.2.a.2 Superintendent
- Outage & Planning 17.2.1.2.B.2.a.3
~-
~--
APPEND
- NUCLEAR STATION ORGANIZATION FIGURE 17.2.1-2 I
I Station Manager SNSOC I
17.2.1.2.B.2.h 17.2.1.2.B.2 I
Secretary
~
I I
Assistant Station Superintendent Site Superintendent Manager (NS&L)
Services Radiological Protection 17.2.1.2.B.2.b 17.2.1.2.B.2.c 17.2.1.2.B.2.d Supervisor Station Superintendent Superintendent Nuclear Safety (SNS)
Construction Radwaste (Surry) 17.2.1.2.B.2.b.1 17.2.1.2.B.2.c 17.2.1.2.8.2.d Supervisor Supervisor Licensing Supervisor Construction Radiological Englneerina Engineering 17.2.1.2.B.2.b.2 17.2.1.2.B.2.c 17.2.1.2.B.2.d Supervisor Supervisor Health Supervisor Station Procedures Construction Physics Technical Controls Services 17.2.1.2.8.2.b.3 17.2.1.2.B.2.c 17.2.1.2.B.2.d Station Coordinator Supervisor Supervisor
-Emergency Planning Facilities and Health Physics Support Operations 17.2.1.2.B.2.b.4 17.2.1.2.B.2.c 17.2.1.2.B.2.d Environmental Supervisor CompHance Chemistry Coordinator 17.2.1.2.B.2.b.5 17.2.1.2.B.2.d 17.2-47 Manager Quality Assurance I
17.2.1.2.F.
Supervisors -
Quality I
Supervisor Administrative Services 17.2.1.2.B.2.e
APPENDIX B TABLES
TABLE 1 Standard, Requirem Regulatory Gujde 1,8 - "Personnel Qualification and Training" (Second Proposed Revision 2, 9/80) Endorses ANSI/ANS-3.1 (Draft 12/79)
The applicability of this guide/standard to other personnel in the Company organization is addressed in other sections of the UFSAR and the Technical Specifications of the individual nuclear facility.
The Company's Position Conformance Status Justification The Operational Quality Assurance Program complies with this guide and standard, with one (1) exception, one (1) clarification and three (3) alternatives. They are:
(1) Exceptjon: With regard to Section 4.2.2 of ANS 3.1 I (Draft 12/79) titled Operatjons Manager. Paragraph c.
Trajnjng: The Operations Manager will have or have held a senior operator license.
(2) CJarjfjcatjon: With regard to the term "Bachelor's Degree" as used in the draft the following qualifications may be considered equivalent to a Bachelor's Degree:
A. 6 years of applied engineering experience at a nuclear facility in the area for which qualification is sought, B. 6 years of operational or technical experience/training related to engineering in nuclear power, and
- C. In addition, experience and training requirements shall be met as delineated.
Clarification and Alternative meet or exceed applicable guides and standards.
For Exception: NRC License Amendment Nos. 142 and 125 dated December 4, 1990 for North Anna and NRC License Amendment Nos. 151 and 148 dated December 31, 1990 for Surry approved revisions to the Technical Specifications granting relief from Section 4.2.2 of ANS 3.1 I (Draft 12/79). The exception allows the Superintendent - Operations to hold or have previously held a Senior Reactor Operator License for the facility or a similar designed Pressurized Water Reactor plant. The Supervisor Shift Operations will fulfill the Operations Manager requirements of ANS I 3.1 (Draft 12/79). This change allows the Superintendent Operations to perform management functions and examine training programs.
For Clarification: ANSI/ANS-3.1 (Draft 12/79) does not provide a clear alternative to formal educational requirements, but does provide guidance. This guidance was utilized to develop clarification to qualify non-degree holding personnel.
17;2-48 June, 1986
TABLE 1 Standard, Requirem Regulatory Gujde 1,33 - "Quality Assurance Requirements (Operation)" (Rev. 2, 2/78) - Endorses ANSI N18.7 - 1976.
The Company's Position Conformance Status The Operational Quality Assurance Program complies with this guide with the following clarifications and alternatives:
Clarifications and alternatives meet or exceed applicable guides and standards.
- 1) Paragraph C.3 ("Subjects Requiring Independent Review") of Regulatory Guide 1.33 (and Section 4.3.4 of ANSI N18.7 - 1976 which it references) will be implemented as required by the applicable nuclear facility Technical Specifications, Emergency Plan, Security Plan, and Fitness for Duty Program which designate the areas subject to independent reviews. I
- 2)
Paragraph C.4 ("Audit Program") of Regulatory Guide 1.33 (and Section 4.5 of ANSI N18.7 - 1976 which it references) will be implemented as required by the applicable nuclear facility Technical Specifications, I Emergency Plan, Security Plan, Fitness for Duty Program, and administrative controls which designate the minimum areas to be audited. The audit program is further defined and will be implemented as required by the commitment to ANSI N45.2.12 as stated in Table 17.2.0 of the Operational Quality Assurance Program.
Paragraph C.4.c of Regulatory Guide 1.33 (and ANSI N18.7 to which it references) will be implemented as clarified in Section 17.2.18 of the Operational Quality Assurance Program Topical Report. Specifically, the frequency for conducting audits of the performance, training, and qualifications of the facility staff may vary based on performance and the safety significance of the audited activity but will not be less frequent than biennial (2 years).
- 3)
Paragraph C.Sa of Regulatory Guide 1.33 (and Section 4.4 of ANSI N18. 7 which it references) will be implemented with the clarification that the Station Nuclear Safety and Operating Committee may perform this activity.
Justification These clarifications are required to ensure that QA program continuity is maintained; i.e., that only one standard or guide is committed to for a particular topic.
17.2-55 June, 1986
The Company's Position
- 15) With regard to Section 5.2.15 of ANSI N18.7 - 1976 titled Review Approval and Control of Procedures: The third sentence in paragraph three is interpreted to mean:
Applicable procedures, as determined by Station Management, shall be reviewed following an accident, an unexpected transient, significant operator error or equipment maHunction.
The first sentence of the fourth paragraph is considered I to be met via procedure reviews as described by administrative procedures.
- 16) With regard to Section 5.2.17 of ANSI N18.7 - 1976 titled lospectjons: Not all inspections will require generation of a separate inspection report. Inspection requirements may be integrated into appropriate procedures or other documents with the procedure or document serving as the record.
However, records of inspections will be identifiable and retrievable.
- 17) With regard to Section 5.3.9 of ANSI N18.7 - 1976 titled Emergency Procedure: As directed by the NRC, the Company follows a format for emergency procedures which is *symptom" based as opposed to "event" based as stipulated in Section 5.3.9J. Since the Company has these "symptom" based procedures; "event" based procedures are not normally provided.
I TABLE 1 Standard, Requirement or Guide Conformance Status Justification The bjennjal review requirement is deleted.
The procedures upgrade program provides a systematic and effective process for developing and revising procedures which encompasses the intent of the biennial review.
17;2-59 June, 1986
The Company's Position Timely basis is interpreted to mean within the framework or period of time for cofl1)1etion of corrective action that is accepted by the QA Organization. Each finding requires f a response and a corrective action completion date; these dates are subject to revision (with the approval of the QA Department) and must be escalated to higher authority when there is disagreement between the audited and the auditing organization on what constitutes "timely corrective action."
- 6)
With regard to Section 3.5 of ANSI N45.2.12 - 1977 titled Scheduling: Subsection 3.5.3.1 is interpreted to mean that the Company may procedurally review qualification of a contractor's or supplier's quality assurance program prior to awarding a contract or purchase order by means other than audit.
- 7) With regard to Section 4.3.1 of ANSI N45.2.12 - 1977 titled Pre-Audit Conference: The Company will comply with requirements of this Section by inserting the word "Normally" at the beginning of the first sentence. This clarification is required because in the case of certain unannounced audits or audits of a particular operation or work activity, a pre-audit conference might interfere with the spontaneity of the operation or activity being audited. In other cases, persons who should be present at a pre-audit conference may not always be available.
Such lack of availability should not be an impediment to beginning an audit. Even in the above examples, which are not intended to be all inclusive, the material set forth in Section 4.3.1 will normally be covered during the course of the audit.
TABLE 1 Standard, Require Conformance Status Justification
- 17.2-91 June, 1986
The Company's Position c) Subsection 4.3.2.5 contains a recommendation which is clarified with the definition of "acknowledged by a member of the audited organization" to mean that a I "member of the audited organization has been informed of the findings."
Agreement or I disagreement with a finding may be expressed in the response from the audited organization.
- 9) With regard to Section 4.3.3 of ANSI 45.2.12 - 1977 titled Post-Audit Conference: The Company will substitute and comply with the following paragraph: "For all external audits, a post-audit conference shall be held with management of the audited organization to present audit 1
findings and clarify misunderstandings; where no adverse findings exist, this conference may be waived by management of the audited organization: such waiver shall be documented in the audit report.
Unless unusual operating or maintenance conditions preclude attendance by appropriate managers/supervisors, a post-audit conference shall be held with managers/supervisors for all internal audits for the same reasons as above. Again, if there are no adverse findings, management of the internal audited I organization may waive the post-audit conference: such waiver shall be documented in the audit report."
TABLE 1.
Standard, Require r Guide Conformance Status Justification
- 17.2-93 June, 1986
The Company's Position
- 10) With regard to Section 4.4 of ANSI N45.2.12 - 1977 titled Regortjng:
a) This Section requires that the audit report shall be signed by the audit team leader; this is not always the most expeditious route to take to assure that the audit report is issued as soon as practical.
The Company will comply with Section 4.4 as clarified in the following opening statement: "An audit report, which shall be signed by the audit team leader, or his supervisor in his absence, shall provide": In cases where the audit report is not signed by the Audit Team Leader due to his absence, one record copy of the report must be signed by the Audit Team Leader upon his return. The report shall not require the Audit Team Leader's review/concurrence/signature if the Audit Team Leader is no longer employed by the Company QA Department at the time the audit report is issued.
b) The Company will comply with subsection 4.4.3 clarified to read: "Supervisory level personnel with whom significant discussions were held during the course of pre-audit (where conducted), audit, and post-audit (where conducted) activities.
c) Subsection 4.4.6 requires audit reports to include recommendations for corrective actions; the Company may choose not to comply with this requirement.
Instead, Audit Team Leaders are required to document all adverse findings on audit I finding forms.
TABLE 1 Standard, Requirem Conformance Status Justification
- 17.2-94 June, 1986
The Company's Position The procedure for processing audit findings allows the Audit Team Leader to document actions which are considered necessary to correct the finding; the Audit Team Leader may also document actions which are considered unacceptable for correcting the finding:
the audit finding with these "Recommendations" is then transmitted to the audited organization. In addition, the Audit Team Leader is required to review the response to the audit finding and determine if it is acceptable. Any disagreements must be escalated to higher management for resolution.
- 11) With regard to Section 4.5.1 of ANSI N45.2.12 - 1977 titled By Audtted Organjzatjon: The Company will comply with the following clarification of this Section:
1 "Management of the audited organization or activity shall review and investigate all adverse findings, as necessary, (e.g., where the cause is not already known, another organization has not already investigated and found the cause, etc.) to determine and schedule appropriate corrective action including action to prevent recurrence.
They shall respond, in writing, within thirty days after the date of issuance.of the audit report.
The response shall clearly state the corrective action taken or planned to prevent recurrence and the results of the investigation if conducted.
In the event that corrective action is not completed by the time the response is submitted, the audited organization's response shall include a scheduled date for completion of planned corrective action.
The audited organization shall take the appropriate action to assure that corrective action is accomplished as scheduled.
TABLE 1 Standard, Require Coriformance Status Justification 17.2-95 June, 1986