ML19289F531

Amend 22 to PSAR

ML19289F531
Person / Time
Site:	05000580, 05000581
Issue date:	06/05/1979
From:	OHIO EDISON CO.
To:
Shared Package
ML19289F529	List: ML19289F528 ML19289F531
References
NUDOCS 7906110128
Download: ML19289F531 (16)

Text

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ERIE NUCLEAR PLANT PSAR, AMENDMENT 22 June 4, 1979 Instructions for Inserting Amendment 22 Pages changed by Amendment 22 have the amendment number and date in the lower right-hand corner of the page. New or changed text material is indicated by a vertical bar in the right-hand margin opposite the changed line(s). Insert Amendment 22 into the Erie Nuclear Plant PSAR as follows:

Remove Insert Volume 8 Binder P. 10.4-40A p. 10.4-40a Volume 9 Binder PP. 17.1-5/17.1-8 pp. 17.1-5/17.1-8 Table 17.1-2 (Sheets 1-3) Table 17.1-2 (Sheets 1-5)

Volume 12 Binder

p. 421.74-1

p. 421.75-1

p. 421.76-1 pp. 421.77-1/421.77-2 2230 285 7906110 /2 b d

(3) The steam generator pressure is less than the 600 psig pressure set point in eitner steam generator l22 The safety related control anu instrumentation (SRCI) (see B-SAR-205, Subsection 7.4.1) automatically starts all auxiliary feedwater pumps and initiates auxiliary feeowater flow to both steam generators if either of the following conditions occurs:

(1) A 1 foot low feedwater level in either steam generator (2) Trip or failure of all steam generator feedpumps.

The Auxiliary Feedwater System will also start upon loss of offsite power and coincident turbine trip. 22 Both the engineered safety features actuation system and the safety related control and instrumentation automatically perform the following functions:

(1) Open valves in the flow path from the auxiliary feedwater pumps to the steam generators (2) Align the auxiliary feedwater source with the auxiliary feedwater pumps suction, if required Tne safety related control and instruroentation controls auxiliary feedwater flow to each steam generator.

2230 286 OEC P6AR 10.4-40a AM. 22 (06-04-79)

(4) Construction of electrical generating plants -

Ma nag e r, Generating Plant Construction (5) Operation and maintenance of electrical generating plants - Manager, Production Department (6) Purchasing, except fuel - General Purchasini A9 ent (Paragraph Deleted)

Figure 17.1-2 depicts the Ohio Edison Company organization.

Figure 17.1-2 highlights the Quality assurance Department to show its independence from otner Ohio Edison groups and depicts tne lines of QA communication.

The Manager, Electrical Engineering reports to a nigner level of management tnan the Manager, Quality Assurance.

However, tue Manager, Electrical Engineering performs activities for ENP as requested of the Manager, ENP Project.

The Manager, Quality Assurance and tne Manager, ENP Project report to the same Vice President.

The Manager, Electrical Engineering performs the following duties pertaining to tne Erie Nuclear Plant Project:

(1) Ensures conformance to the OECo Quality Assurance Program by instituting the necessary supportive procedures and instructions within the Electrical Engineering Department; (2) Coordinates the planning ano implementation of electrical engineering work on the Erie Nuclear Plant Project witn the Manager, ENP Project; (3) Performs electrical engineering design activities requested oy tne clanager, ENP Project; (4) Performs engineering studies requested by the Manager, ENP Project in connection with the location, des ig n , construction, and expected operating and maintenance performance of substations ana transmission lines; (5) Provides technical input for the preparation of equipu.ent and material specifications and evaluations of equipment and material proposals associated with suostations, transmission lines and electrical portions of electric generating plants, including tne recommendeu selection of suppliers; (6) Reviews tne procurement of electrical equipment, materials and services relating to the ENP Project; j7) Coordinates the above engineering activities with and 22 d8Sosy~reeeartmen'sandcivisions:

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2230 287 OEC PSAR 17.1-5 AM. 22 (06-04-79)

(d) Ensures tnat proper training is provideo for tne Electrical Engineering Department personnel to attain anc maintain tecnnical proficiency. 22 (Paragraph Deleted) 17.1.1.2 Quality Assurance Program Ohio Edison Company recognizes the funaamental importance of a Quality Assurance Program as a means of assuring quality in nuclear power plant des ig n , procurement and construction activities. Tne Ohio Edison Company Quality Assurance Program complies with the requirements of 10CFR50, Appendix B;

• the NRC Regulatory Guices and American National Standarus Institute (ANSI) 5tancards listed in Table 17.1-1.

In subsequent sections of Chapter 17, references to these documents are tne issues noteo in Table 17.1-1.

Preparation of the PSAR and other safety-related activities including design, procurement and safety-related site preparation initiated prior to PSAR suomittal are controlled under the Ohio Edison Company Quality Assurance Program.

Ohio Edison Company has the responsibility to enact a Quality Assurance Program responsive to current government regulations and guides, and to periodically review the status of the Quality Assurance Program and make necessary changes. Unresolved conflicts between the Ohio Edison Company Quality Assurance Department and otners within or without the company concerning matters important to quality shall be brought to tne attention of Ohio Edison Company Executive Management (as defined in the OECo VA Program Manual) for resolution.

The Ohio Edison Company Quality Assurance Program Manual describes now Onio Edison plans to implement a total QA Program for tne Urie Nuclear Plant. The manual is prepared under tne airection of the Manager, Quality Assurance, and approved by Ohio Edison Company Executive Management.

Cnanges are made to tne Ohio Edison Company Quality Assurance Program Manual and SAR Chapter 17 as needed to reflect new requirements and to maintain the program description current. Changes are suo3ect to tne same review and approval given the original issue. The Onio Edison Company Quality Assurance Program Manual consists of QA Directives corresponding to the 18 criteria of 10CFR50, Appendix D. Where there is a direct Onio Edison Company Quality Assurance Department operation or function involving any of the criteria of 10CFx50, Appendix B, a QA Procedure is written for that activity. The procedure indicates, with figures, forms or other aids, how that operation is pe rf o rmed . l22 O

o .

2230 288

\ b.1 Ut OEC PSAR 17.1-6 AM. 22 (06-04-79)

QA Procedures are prepared under tne direction of the Manager, Quality Assurance, and are suosequently reviewed oy the Manager, Quality Assurance. Once a procedure has been approved and issued, it is treated as a controlled document as described in Subsection 17.1.1.6.

The Manager, Quality Assurance, is responsiole for conducting a comprehensive final review of the Quality Assurance Program Manual prior to issuance. The QA Directives receive signature approvals f rom the Vice President (Generating Plant Engineering and Construction) and the Manager, Quality Assurance. The QA Procedures are approved by the Manager, Quality Assurance. The manual is implemented when tne President executes a Policy Statement and tne Vice-President (Generating Plant Engineering and Construction) co-s ig ns tne Statement of Applicability with the Manager, Quality Assurance.

The Policy Statement contained in the Ohio Edison Company QA Program Manual requires Onio Edison Company personnel to execute the Ohio Edison Company QA Program as set forth in the QA Program Manual. Contract documents with principal contractors describe the uancatory requirements , such as quality policies, QA manuals and procedures involvec for the Erie Nuclear Plant Project.

(Paragraph Deleted)

Figure 17.1-4 identifies the governing QA documents for tne Erie Nuclear Plant project. The Ohio Edison Company QA Program Manual is the top ranking document. It is supported by various Ohio Edison Company departmental procedures, including tue LNP Project Procedures, and by the principal contractors' QA documents. The quality assurance procedures (both Quality Assurance Procedures and ENP Project Procedures) are listed in Taule 17.1-2. Included are brief descriptions of scope and references to the criteria of 10CFR50, Appendix B which are satisfiec by the procedures. 22 The structures, systems and components to be covered by the Ohio Edison Company Quality Assurance Prograu are those tnat have a role in preventing accidents or in mitigating the consequences of accidents wnich can cause undue risk to the health and safety of tne public. A detailed list of tne structures, systems and components within the scope of this program is summarized in Section 3.2 of the Safety Analysis Report (SAR). Expenuanle or consumable items necessary for the functional performance of these safety-related s tructures , sys tems ano components are also covered by the QA prog'ygrs ,The,QA program cescribed in Chapter 17 is applied- tolttielfire grotection program to the extent that

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the criteria estaolished in Section 9.5.1 of NUREG 75/087 are satisfied.

2230 289 OEC PSaR 17.1-7 An. 22 (06-04-79)

The Manager, Quality Assurance prepares and sucaits monthly l21 reports to Onio Eaison Company Executive Management. These reports include:

(1) The status of the Ohio 8dison Company quality assurance audit program (2) Listings of the audits performed by Ohio Edison Company and its principal contractors (3) Findings concerning nonconformances and corresponding corrective action recommended (4) The status of corrective action previously ide ntif ied (5) Any technical or aarainistrative probleus encountered in executing the Onio Edison Company Quality assurance Progran Management Review Committee Meetings are held annually to further assess the adequacy of tne Quality Assurance Program and its compliance with Appendix B. Normal attendance at such meetings includes:

(1) Executive Vice President, acting as committee chairman (2) Vice President (Generating Plant Engineering and Construction), acting as committee vice enuirman (3) Senior Vice President (Engineering and Cons truc tion)

(4) Senior Vice President (Generating Plant and Transmission System Operations)

(5) Vice President ( Adrainis trat ion)

(6) Manager, ENP Project (7) Manager, Quality Assurance Additional personnel may be asked to attend where particular areas of discussion require their knowledge and/or expertise. 21 2230 290 r, c O

\0h t '

3 OEC PSAR 17.1-8 An. 21 (04-02-79)

TABLE 17.1-2 (Sheet 1 of 5) l OHIO EDISON COMPANY QUALITY ASSURANCE PROCEDURES Applicable 10CFR50, Appendix B Procedure Scope Criteria QAP 2.A Establishes methods V, VII, Site Quality for planning and VIII, IX, Assurance reporting construction X, XI Surveillance Planning site surveillance and Reporting conducted by site QA personnel.

QAP 2.B Establishes methods V, VII, Performance of Site for use by the QA VIII, IX, Surveillance staff to monitor X, XI,XIII construction and construction quality control activities.

QAP 2.C Establishes methods to II, V Quality Assurance conduct project Indoctrination and personnel QA training Training and QA staff training.

QAP 2.D Establishes methoc by II, V Management which OECo management Participation reviews a: o assesses the effec: t.veness of implementation and the adequacy of the OECo Quality Assurance Program.

QAP 2.E Es tablishes a method IV, V, Review and Approval for reviewing and VII of Principal approving the principal Contractors' Quality contractors' quality Assurance Programs assurance programs.

2230 291 OEC PSAR AM. 22 (06-04-79)

TABLE 17.1-2 (Continued)

(Sheet 2 of 5) I Applicaole 10CFR50, Appendix B Procedure Scope Criteria QAP 3.A Provides instructions III, V Quality Assurance for reviewing Review of Engineering engineering documents Documents from a quality assurance viewpoint.

QAP 4.A Provides instructions IV, V Quality Assurance for reviewing Review of Procurement procurement documents Documents from a quality assurance viewpoint.

QAP 4.B Establishes quality IV, V, X Quality Assurance assurance requirements XIII, XIV Requirements for of principal Principal Contractors contractors.

QAP 5.A Preparation of QA Establishes a method V Program Manual for preparing the VA Program Manual to assure uniformity of format, review and approval.

QAP 6.A Establishes a method V, VI Control of QA to control the issuance Program Manual and maintenance of tne QA Program Manual. .

QAP 6.B Establishes methods V, VI, XVII Quality Assurance for processing Correspondence and filing QA and Document correspondence and Control documents.

QAP 7.A Establishes a method V, VII, X, Control of for Ohio Edison XI Manufacturing Company to monitor Surveillance and control manufacturing surveillance.

2230 292 OEC PSAR AM. 22 (06-04-79)

TABLE 17.1-2 (Continued)

(Sheet 3 of 5) l Applicable 10CFR50, Appendix B Procedure Scope Criteria QAP 15.A Establishes method by V, XV, XVI Control of which nonconformances Nonconformances are Iaonitored and controlled by Ohio Edison Company.

QAP 15.8 Estaolishes controls None Evaluating and for the evaluation Reporting Defects and reporting of and Noncompliances defects and in Accordance noncompliances as with 10CFR21 defined in 10CPR21.

QAP 16.A Establishes metnods V, XV, XVI Control of by which corrective Corrective Action actions are monitored and controlled by Ohio Edison Company.

QAP 18.A Establishes methods for I, V, XV, Performance of planning, conducting, XVI, XVIII Audits performing follow-up and docmaenting audits of OCCo principal contractors' and contractors' quality assurance programs and related activities.

QAP 18.B Es tablishes II, XVIII Qualification requirements for of Auditors tne qualification of auditors through training, experience and examination.

2230 293 OEC PSAR AM. 22 (06-04-79)

TABLE 17.1-2 (Continued)

(Sheet 4 of 5)

Applicable 10CFR50, Appendix B Procedure Scope Criteria ENP 3.1 Establishes V, VI Correspondence and responsibilities and Document Control instructions for processing ano filing correspondence and documentation.

ENP 3.2 Establishes the methods V, VI, XVII Documentation used to control the Retention retention of quality assurance records.

ENP 4.1 Establishes methods III, V Project Design for the development Criteria and maintenance of the Project Design Criteria.

ENP 4.2 Specifies the criteria III, V Preparation and and methods utilized Review of Safety for the preparation, Analysis Reports review, and submittal of Safety Analysis Reports.

ENP 4.3 Provides instructions III, V Review of for reviewing Engineering engineering documents Documents f rom a technical viewpoint.

ENP 4.4 Establishes methods by III, V Performance of which the Design Design Verification Verification Committee verifies the adequacy of principal contractors' design through design reviews.

2230 294 OEC PSAR AM. 22 (06-04-79)

TABLE 17.1-2 (Continued)

(Sheet 5 of 5)

Applicaole 10CFR50, Appendix 8 Procedure Scope Criteria ENP 4.6 Delineates the method III, V Design Change Control by which proposed design changes are initiated, processed and disposed of in a controlled manner.

ENP 5.1 Establishes the method IV, V Procurement Document by which procurement Control documents are controllea during review and approval stages, and method by which reviews and approvals of procurement documents are documented.

ENP 5.2 Provides methods to IV, V Qualification of perform pre-bid Principal Contractors evaluations of potential principal contractors for major design and construction contracts associated with nuclear power plants.

ENP 5.3 Es tablishes general IV, V Preparation and methods for the Issuance of Bid preparation and issuance Documents to of the bid inquiry Principal Contractors documents utilized to solicit proposals from prospective principal contractors.

ENP 5.4 Establishes methods for IV, V, VII Principal Contractor evaluation and final Bid Evaluations and selection of a principal Awards contractor and general guidance for contract preparation and award.

2230 295 OEC PSAR AM. 22 (06-04-79)

421.74 On pase 17.1-5, Amenduent 21 of the PSAR deleted the (17.1.1.1) following words:

"The design, engineering, purchasin9 ano construction supervision by the above noted supervisory positions, plus the administrative coordination provided by the Chief Nuclear Engineer as Project Administrator, comprise the first-line project management for Ohio Edison Company on its nuclear projects. Indepencent quality assurance surveillance of Ohio Edison Company project activities and contractors' activities which affect quality is provided by the Ohio Edison Con.panj Nuclear Quality Assurance Department under the direction of the Chief Nuclear Quality Assurance Engi neer. "

Please reinstate these words (modified, as necessary, to reflect organization chanbes) or provide justification for the deletion for our evaluation.

RESPONSE: The referenced paragraph has been deleted for tne following reasons:

The Manager, ENP Project directs project activities of Ohio Edison Coupany. Previously, the Project Administrator was not authorized to direct all project activities. He only provided administrative coordination over the other participatin3 or9anizations. The duties of the Mana9er, ENP Project are discussed in Subsection 17.1.1.1.

The last sentence in the deleted paragraph discussing the Quality Assurance Department is recundant. The activities of the Quality Assurance Department and the Manager, Quality Assurance are discussed prior to the deleted paragraph in Subsection 17.1.1.1.

2230 296 421.74-1 AM. 22 (06-04-79)

421.75 On page 17.1-26, the periodicity of the analyses of non-(17.1.1) confonnance reports to detect adverse quality trends was changed from quarterly to annually. Please revert to quarterly or provide justification for the change for our evaluation.

RESPONSE: A' commitment to quarterly quality analysis of nonconformance reports cannot be justified at this time due to the lack of activity. However, a continuing assessment of activity is made by the Quality Assurance Department and a quality analysis will be performed annually or iaore often if increased activity so warrants. Upon start of safety related construction, the analysis of nonconfonaance reports will be perfonned at least quarterly.

2230 297 421.75-1 AM. 22 (06-04-79)

421.76 Table 17.1-2, " Ohio Edison Company Quality Assurance (Table) Procedures," has been changed and no longer lists procedures for activities such as " reviewing engineering documents from a technical viewpoint," and verifying 'the tdequacy of principal contractors' designs through design reviews."

It appears " Quality Assurance" in the title )f the table now refers to the OECo Quality Assurance Department and not to quality assurance as defined in Appencix 3 to 10CFR Part 50. Please expand Table 17.1-2 su:h that the table lists quality assurance procedures and chair scope for OECo organizations other than the Quality Assurance Department.

RESPONSE: Table 17.1-2 is revised to incorporate the ENP Project Procedures removed in Amendment 21, and Subsection 17.1.1.2 is updated to reference the additional infonaation included in revised Table 17.1-2. -

It should be noted that no procedures have been deleted since the original application was prepared. In the July 1978 Company reorganization and the revision to the QA Program Manual, previously identified QA Procedures were transferred to the control of the Manager, ENP Project as ENP Project Procedures.

2230 298 421.76-1 AM. 22 (06-04-79)

421.77 Figure 17.1-2, " Ohio Edison Company Organization for Design, (Fi 3ure) Procurement and Construction Activities (Overall)," used to show the Chief Nuclear QA Engineer and the Chief Electrical Engineer reporting at the same level. In Amendment 21, this relationship has apparently been changed such that the Manager, Qualitj Assurance reports to a lower level of management than the Manager, Electrical Engineering. Please describe the activities of the Electrical Engineering Department relative to the Erie Nuclear Plant and describe the QA controls over the activities which are important to safety in li 3 ht of the revised reporting relationships.

RESPONSE: The Manager, Electrical Engineering perfonas the following duties pertaining to Erie Nuclear Plant Project:

a. Ensures confonaance to the OECo Quality Assurance Program by instituting the necessary supportive procedures and instructions within the Electrical Engineering Department;

b. Coordinates the planning and iiaplementation of electrical engineering work on the Erie Nuclear Plant Project with the Manager, ENP Project;

c. Perfonas electrical engineering design activities requested by the Manager, ENP Project,

d. Perfonas engineering studies requested by the Manager, ENP Project in connection with the location, desi n,3 construction, and expected operating and maintenance performance of substations anc transmission lines,

e. Provides technical input for toe preparation of equipaent and material specifications and evaluations of equipiaent and material proposals associated with substations, transmission lines and electrical portions of electric senerating plants, including the recommended selection of suppliers;

f. Reviews the procurement of electrical equipnent, materials and services relating to the ENP Project;

g. Coordinates the above engineering activities with other departments and divisions; and

h. Ensures that proper training is provided for the Electrical Engineering Department personnel to attain and maintain technical proficiency.

As noted above, the Manager, Electrical Engineering performs activities for ENP as requested by the Mana3er, ENP Project. The Manager, ENP Project is responsible for directing Ohio Edison Colapany activities for qP a stated on page 17.1-4a. M 299 421.77-1 AM. 22 (06-04-79)

421.77 (Fi gure)

RESPONSE: (cont'd)

The Manager, Quality Assurance and the Manager, ENP Project report to the san.e Vice President. The QA controls relayed to the Electrical Engineering Departiaent are the sanie controls described within Chapter 17 for any other OECo department. The PSAR text has been revised to reflect the duties of the Manager, Electrical Engineering.

Subsection 17.1.1.1 is revised to incorporate the above infonaation.

2230 300 421.77-2 Aa. 22 (06-04-79)