ML20011D617

Rev 57 to CE-1-A, QA Program

ML20011D617
Person / Time
Site:	Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle, 05000000
Issue date:	12/08/1989
From:	Jigar Patel COMMONWEALTH EDISON CO.
To:
Shared Package
ML20011D613	List: ML20011D612 ML20011D617
References
CE-1-A, NUDOCS 8912280103
Download: ML20011D617 (68)

Text

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LISTING COVERING REVISION OF TOPICAL REPORT CE-1-A Below is a listing of Revision 57 changes to the Commonwealth Edison Company Quality Assurance Program Topical Report CE-1-A dated 12/01/89:

Rev. Content Pages 1-4; Pages 1-2, 1-10, 1-12, 1-41, 1-42, 1-43, 1-44, 1-45, 1-46, 1-47, 1-48, 1-49, 1-50, 2-1, 2-3, 2-6, 2-7; 3-2; 4-1, 4-2, 4-4, 4-5; 5-1; 6-1, 6-2; 7-1; 9-2; i

10-1; 11-1; 12-1, 12-3; 15-1, 15-3; 16-2; 17-1; 18-2.-

Approved: _

[/A/8/87 nager of Quality Assurance /

i Nuclear Safety 12/01/89 9518M 8912280103 8912i3 i

PDR ADOCK 05(X)OO10 i

P PDC if

CONTENTS

,4 TITLE PAGI REY.

DATE INTRODUCTION 1-1 56 09/13/89

1. ORGANIZATION.

A. Basic Organization Responsibilities 1-1 56 09/13/89 1-2 57 12/01/89 B. Organizational Responsibilities for Major Activities 1-3 56 09/13/89 1-4 56 09/13/89 1-5 55-03/27/89 1-6 55 03/27/89 1-7 55 03/27/89 1-8 55 03/27/89 1-9 55 03/27/89 1-10 57 12/01/89 1-11 55 03/27/89 1-12 57 12/01/89 1-13 56 09/13/89 1-14 56 09/13/89 1-15 56 09/13/89 1-16 56 09/13/89 1-17 56 09/13/89 1-18 56-09/13/89-1-19 56 09/13/89 1-20 56 09/13/89 1-21 56 09/13/89 1-22 56 09/13/89 1-23

56 09/13/89 1-24 56

-09/13/89 1-25 56 09/13/89 1-26 56 09/13/89 1-27 56 09/13/89 1-28 56 09/13/89 1-29 56 09/13/89 1-30 56 09/13/89.

1-31 56 09/13/89 1-32 56 09/13/89 1-33 56 09/13/89 1-34 56 09/13/89 1-35 56 09/13/89 1-36 56 09/13/89 1-37 56 09/13/89 1-38 56 09/13/89 1-39 56 09/13/89 1-40 56 09/13/89 1-41 57 12/01/89 1-42 57 12/01/89 i

Page 1

of _.4_

Date:

12/01/89 Rev.-52

-1

, '~

CONTENTS

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TITLE EAGE RG, DATE FIGURES 1

1-0 Organization Chart Related To Q.'A, 1-43 57

-12/01/89 I

1-1 Organization Chart - Quality Assurance /

1-44 57 12/01/89

)

Nuclear Safety Policy and Oversight Dept.

l 1-1-1 Quality Programs and Assessment Department 1-45 57 12/01/89 1-2 Engineering and Construction Department 1-46 57 12/01/89 1-3 Projects Organization and Nuclear 1-47 57 12/01/89 Engineering Department 1-4 Projects Department,(For Future Project -

1-48 57 12/01/89 Currently Inactive) 1-5 System Operational Analysis Department 1 57 12/01/89 and System Materials Analysis Department.

1-7 Station Production Department Organization 1-50 57 12/01/89

2. QUALITY ASSURANCE PROGRAM 2-1 57 12/01/89 2-2

'51 07/07/88 2-3 57 12/01/89 2-4 55 03/27/89 r

2-5 55 03/27/89 2-6 57 12/01/89 2-7 57 12/01/89 i

2-8 55 03/27/89

3. DESIGN CONTROL 3-1 55 03/27/89 3-2 57 12/01/89 3-3 55 03/27/89 3-4 56 09/13/89

4. PROCUREMENT DOCUMENT CONTROL 4-1 57 12/01/89' 4-2 57 12/01/89 4 56 09/13/89 4-4 57

-12/01/89~

4-5 57

-12/01/89

5. INSTRUCTIONS, PROCEDURES AND ORANINGS 5-1 57 12/01/89 5-2

-55 03/27/69 5-3 0

01/76 l

6. DOCUMENT CONTROL 6-1 57 12/01/89 6 57 12/01/89 6-3 55 03/27/89 Page _2_ of 4 Date:

12/01/89~ Rev. El l

CONTENTS TITLE EAGE REY.

DATE

7. CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES 7-1 57 12/01/89 7-2 56 09/13/89 7-3 56 09/13/89 7-4 56 09/13/89 7-5 55 03/27/89 7-6 55 03/27/89

8. IDENTIFICATION AND CONTROL OF MATERIALS,

~

PARTS AND COMPONENTS 8-1 56 09/13/89 8-2 55 03/27/89

9. CONTROL OF SPECIAL PROCESSES 9-1 56 09/13/89 9-2 57 12/01/89 9-3 55 03/27/89

10. INSPECTION 10-1 57 12/01/89 10-2 55 03/27/89 10-3 33 03/13/85

11. TEST CONTROL 11-1 57 12/01/89 11-2 55 03/27/89 11-3 55 03/27/89 11-4 55 03/27/89

12. CONTROL OF MEASURING AND TEST EQUIPMENT 12-1 57 12/01/89 12-2 55 03/27/89 12-3 57 12/01/89

13. HANDLING, STORAGE AND SHIPPING 13-1 26 12/10/83 L

13-2 55 03/27/89

.13-3 55 03/27/89

14. INSPECTION, TEST AND OPERATING STATUS-14-1 55 03/27/89 14-2 26 06/19/85

15. NONCONFORMING MATERIALS, PARTS OR COMPONENTS OPERATIONS 15-1 57 12/01/89 15-2 55 03/27/89 i-15-3 57-12/01/89 l

l

16. CORRECTIVE ACTION 16-1 55 03/27/89 i

16-2 57 12/01/89 t

16-3 15

-01/02/81

17. QUALITY ASSURANCE RECORDS 17-1 57 12/01/89 17-2 55 03/27/89 Page _3_ of 4 Date:

12/01/89 Rev. 52 l

~

CONTENTS TITLE PAGE REY.

DATE-

18. AUDITS 18-1 56 09/13/89 18-2 57 12/01/89 18-3 56 09/13/89 APPENDIX A Quality Assurance Program Manual.

Index A-1 45 06/30/87 Quality Assurance Procedures Manual A-2 56 09/13/89 Index (Engineering and Construction)

+

4 Quality Assurance. Procedures Manual A-3' 56 09/13/89 Index (Operations)

A-4 50 04/08/88 A-5 56 09/13/89 Approved; h

/2/1/#

nager of Quality Assurance /

Nuclear Safety i

i i

Page

'4' of 4 Date:

12/01/89 Rev. 52 9522H

'1 Im i

t EXPLANATION OF CHANGES FOR TOPICAL REPORT - REV 57 COMMONNEALTH EDISON COMPANY PROGRAM TOPICAL REPORT CE-1-A PAGE NO.

EXPLANATION Rev. Content Pages 1-4; Pages 1-2, These revisions are being made to make 1-10, 1-12, 1-41, 1-42, 1-43, 1-44, minor organizational changes and to 1-45, 1-46, 1-47, 1-48, 1-49, 1-50, update the Quality Assurance Program to 1, 2-3, 2-6, 2-7; 3-2; 4-1, 4-2, meet the current organization.

4-4, 4-5; 5-1; 6-1, 6-2; 7-1; 9-2; 10-1; 11-1; 12-1, 12-3; 15-1, 15-3; 16-2; 17-1; 18-2.

• • • NOTE *****

t PAGE 5-3 HAS BEEN INCLUDED IN THIS REVISION TO CORRECT THE REVISION NO.

AND DATE.

THE ACTUAL CONTEXT HAS NOT CHANGED OR REVISED.

0012M 4

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QUALITY ASSURANCE DURING DESIGN, CONSTRUCTION AND OPERATION Introduction This Topical Report has been prepared to delineate the requirements governing the Commonwealth Edison Company Quality Assurance Program for its nuclear generating stations.

Implementation of the Program with Quality Procedures provides the degree of quality assurance commensurate with the requirements of.

ASME Section III, Division 1 and Division 2 for concrete containment and other applicable codes, Nuclear Regulatory Commission requirements and Federal Regulations governing design, procurement, construction, testing, operation, refueling, maintenance, repair and modification of Commonwealth Edison Company's nuclear power generating facilities.

The scope of this Report covers the total Quality Assurance Program for the life of the Commonwealth Edison Company nuclear generating plants and is described in the ensuing 18

• S6 sections of this Report.

1.

Organization A.

Basic Oraanization Resnonsibilities Commonwealth Edison-Company is ultimately responsible for the assurance of quality in all phases of the design, procurement, construction, modification, testing and operation of the Station.

Edison executes this responsibility in accordance with the program set forth in the Company Quality Assurance Manual and described herein and assigns areas of ultimate responsibility to specific Edison organizations and individuals.

Inherent in the delegation of responsibilities is the assignment of corresponding authority required to execute the responsibilities.

Edison has delegated the responsibility for certain phases of the work to the Architect Engineer and the NSSS Supplier, both of whom act as Edison!s agents In the assigned areas.

Edison maintains overall control of the efforts of these organizations by various mechanisms such as design evaluation and audits.

Edison has prime responsibility for controlling the quality of on-site work by fieldicontractors. Also, Edison retains overall-responsibility for procurement,. design, construction certification, modifjcations, and operation of the plant including and stamping in accordatice with the-ASME Code,

~

1-1 t

l Rev. 56 9/13/G9 Commonwealth Edison

. ~

^

The Commonwealth Edison Company Quality Assurance Program for nuclear generating stations covers the organization arrangement whereby the corporate policy and the performance of off-site audits for the area of Quality Assurance involving nuclear and the corporate policy for Nuclear Safety are the responsibility of the Manager of Quality Assurance / Nuclear Safety, who reports to the Chairman and CEO.

Also, the Assistant Vice President (Quality Programs and Assessment), and, in turn, the Nuclear Quality Programs Manager, direct the quality assurance activities for the design, procurement, construction, and operation of the Company's nuclear. power facilities and interface activities with the Nuclear Regulatory Commission, Office of Inspection and Enforcement, Region III, and the Jurisdictional Authority.

The Assistant Vice President (Quality

. Program and Assessment) reports to the Senior Vice President (Nuclear Operations), and functions independently of PHR (Pressurized Hater Reactor) and BHR (Boiling Hater Reactor) operations.

The Construction Manager, supported by Site Construction Superintendents, 4

is responsible for administration of the contracts and for

verification that construction activities carried out by site contractors conform to procurement document requirements which include performance and quality related functions.

Also, the construction site group has responsibility for reviewing site contractor quality control procedures, preparing checklists for

witnessing inspection notification points at vendor plants, inspection and designation of status of incoming material at the

-site, reviewing inspection procedures and monitoring quality control

. activities of contractors at the site.

The Quality Assurance (Construction) site group is I

responsible for assuring that the quality requirements are fulfilled and for final approval of: (1) quality assurance procedures of site contractors; (2) the program, including checklists and reports, for inspections and audits at contractor plants; (3) site receipt inspection of materials performed by others; and (4) for audit of t

contractor inspection activities at the site.

Independent Inspection ~

Agency inspection and testing activities performed directly for

, Commonwealth Edison are under the direction and responsibility of the Site Quality Assurance Superintendent and such Agency shall be staffed with qualified personnel acceptable to Quality; Assurance.

Such Agency has responsibility to identify unacceptable or nonconforming work occurring on-site and, when assigned, at off-site supplier's plants. An Independent Inspection Agency.is assigned responsibilities for inspection and testing, to determine and report whether the item conforms to design, test and specification requirements and to reject unsatisfactory materials, equipment and other items. Such rejection by an Independent Inspection Agency will be'the basis for. action by the Commonwealth Edison site organizations

,to carry out necessary steps to assure repair,-rework or processing of a nonconformance report in accordance with the Quality Assurance Program.

l The Commonwealth Edison Company Quality Assurance Program l

includes the quality assurance requirements for operating nuclear power stations.

The Program covering operations shall-comply with the 18 Criteria of the " Quality Assurance Criteria for Nuclear Power Plants" of Appendix B to 10CFR50 for maintenance, modification and refueling activities and with Criteria 1, 2, 5, 6, 10, 11, 12, 14, 15, l

16, 17 and 18 for operating activities. As supplementary Criteria to y

the 18 Criteria described above for Appendix B to 10CFR50, the Program also complies with Regulatory Guide 1.33 " Quality Assurance Program I

1-2 Rev. 57 12dSMOSnwealth Edison

The Chairman and Chief Executive Officer (CEO) promulgates corporate policy through the President and Chief Operating Officer l

(C00), Senior Vice President for finance, Vice President of Corporate Planning, Vice President of Industrial Relations, Manager of Quality Assurance / Nuclear Safety, Vice President for Public Relations, and Vice President for Legal Affairs.

The President and Chief Operating Officer (C00) directs the activities of the nuclear associated departments responsible for licensing, construction, testing, plant operations, nuclear and other engineering, security, training and environmental affairs.

In this capacity, he is responsible for the activities of the Departments and Divisions concerned with the operations, maintenance and engineering of the Company's nuclear generating facilities as well as control over Power Supply, Divisions and non-nuclear construction, production and engineering activities.

The Departments and Divisions and the job position responsible for activity within each are as follows:

q The Senior Vice President (Nuclear Operations) has the primary responsibility of providing overall direction for the safe and efficient operation and maintenance of the operating nuclear power stations and reporting to him are:

The Vice Presidents (PHR and BHR Operations) who are delegated the authority for the line maragement for the day-to-day operation of the nuclear' stations.

The Assistant Vice President (Quality Programs and

• 55 Assessment) who has responsibility for management of all quality verification activities for the nuclear operations.

The General Manager of Nuclear Services who has responsibility for Nuclear Fuel Services, Production Training, Chemistry and Radwaste, Radiation Protection,.

Emergency Preparedness, and Management Services.

The Manager of Engineering and Construction who has responsibility for providing the. planning, design, engineering, and project service for construction, modification and contracted maintenance services to nuclear operations.

The Vice President (or General Manager) (Divisions) is responsible for the activities of the six Operating Divisions, and the Operating Manager.

These Divisions are assigned responsibility for those activities concerned with distribution of power as well as service to customers and public relations within their respective geographical areas including operation and maintenance and inspection of electrical transmission and distribution facilities.

The Operating Manager's responsibility includes the Transmission and Distribution Construction Department which has functional responsibility and control for Division Substation Construction activities.

1-9 Rev. 55 3/27/89 Commonwealth Edison I

c.

_ _ _ _ _ _ _ _ _ ~

~

A Division Vice President is responsible for each Division. A Division Operating Manager reports to the Division Vice President.

The-Divuton Operating Manager is responsible for Division Substation Construction and Division Operational Analysis activities.

The Director of Stores and Materials Management Department is responsible for the General Harehouse material control activities, which includes the procurement, receipt, storage, and release of safety-related items and materials.

. Commonwealth Edison assigns to the Director of Procurement,

'who reports to a Vice President, the responsibility for the procurement of. services, spare parts, materials and equipment in accordance with the purchase requisition and contract specifications requirements and

,for obtaining the required quality assurance documentation for such items.

Corresponding responsibility for the procurement of nuclear

, fuel (including reprocessing) is assigned to the Manager of Fuel, who also reports to a-Vice President.

1.2 Organization The Commonwealth Edison Company organization-as related to Quality Assurance, is shown in Figures 1-0, 1-1 and 1-1-1.

Departmental and divisional organizations showing the Quality Assurance

, functions are shown in Figures 1-2, 1-3, 1-4, 1-5 and 1-7.

Organizations which will-be activated for future plant construction are

'shown in Figure 1-4.

1.3 Stone Specific responsibilities for implementation of the Quality

, Assurance Program are assigned to the Commonwealth Edison Company organizational groups as outlined herein.

The scope of responsibilities involved in a nuclear project is divided into four Phases.

Phase I -

Definitions of system design and quality requirements and acceptance of the quality of design.

t Phase II-Verification that design and quality requirements have been met during construction.

. Phase III-- Baseline in-service inspection; prooperational testing.

Phase IV - Operation, in-service inspection, maintenance, repair, refueling, station modifications, start-up testing and pre-operational testing.

1-10 Rev. 57

(

12/01/89 Commonwealth Edison

-1.4 Engineerina knd Construction ResDonsibilities l.4.1 Nuclear Enaineerina Manaaer The Nuclear Engineering Manager has overall engineering responsibility and, as applicable, assigns responsibilities to' cognizant NED (Nuclear Engineering Department) engineers for specific modification work at the generating stations.

The cognizant engineers have the responsibility to specifically supervise the electrical, mechanical, structural, instrumentation and controls and nuclear engineering activities involving the plant modifications.

These responsibilities include the following:

a.

Review and control the design work involving the electrical, mechanical, structural and instrumentation and control designs of the NSSS vendor and, Architect Engineer to verify that applicable Safety Analysis Report (SAR),

regulatory requirements, ASME Code. requirements, and design bases are properly translated into specifications, drawings, precedures and instructions.

b.

' Review and accept the' specifications and drawings for electrical, mechanical and structural material, equipment and erection work, prepared by the Architect. Engineer and NSSS. vendor, to verify inclusion of inspection, testing and acceptance criteria.

c.

Analyze bids, make purchase recommendations,

• 55 control expenditures, and assure that necessary quality requirements are included in purchase orders and contracts.

d.

Dispositio.n of electrical, mechanical and structural design changes.

e.

Review the Architect Engineer's evaluation of fabricator's and erector's detailed designs, drawings.and work instructions for reasonableness.

__m.

and completeness.

f.

Review and approve resolution of nonconformances relating to electrical.. mechanical and structural portions of the generating station, g.

Establish the plans for the modification test

programs, h.

Provide modification test acceptance criteria for modifications designed by Nuclear Engineering.

1.

Evaluate discrepant modification test results for modifications designed by Nuclear Engineering.

1-11 Rev. 55 3/27/89 Commonwealth Edison

1.4.1 (Continued) j.

Perform detailed design activities and issue design documents in accordance cith approved procedures.

-.l k.

Responsible for engineering design i

l-implementation and overseeing the Site Architect-Engineer field group-.(at those locations where.one is established), review and comment on on-site contractor quality instructions and procedures, and review and l

approval of CECO. Non-Conformance Reports..

i 1.

Notify the jurisdictional authorities of the g

location of permanent records.

m.

Responsible for assuring that CECO personnel certifying Section III design activities are qualified Registered Professional Engineers in accordance with ANSI /ASME N626.3-1979,:as well as assuring that AE's and NSSS Suppliers J

maintain procedures to assure that their-personnel certifying Section III design are qualified Registered Proffesional Engineers in accordance with ANSI /ASME N626.3-1979.

The Nuclear Engineering Manager has overall owner's responsibility for the Form N-3 Data Report.and other CECO. N-type Data Reports, including stamping responsibility for ASME Section III, Division I and 2, covering concrete containments.

1.4.2 The Nuclear Quality' Programs Engineer assigned to the Engineering and Construction Department has the responsibility'to assure that the following quality assurance activities are performed., (Also see l

1.4.7.1.A) a.

Development of quality procedures to be used by the Engineering and Construction Department in conjunction with the Commonwealth Edison Quality Assurance Program.

b.

Review of purchase documents-(i.e.,

specifications, drawings, procedures and-instructions) for. assurance of the inclusion of quality requirements.

Review of fabricator and erector work instructions for inclusion of nondestructive and~

electrical testing requirements.

1.4.3 The Architect Engineer is responsible to the Engineering and Construction Department for the mechanical, structural and electrical design of the plant and for the quality of that design.(except for those portions of that design included within the scope of the Nuclear Steam Supply System (NSSS)).

In this context, the Architect Engineer performs an independent evaluation of vendor proposals, designs, m

vendor and,centractor procedures, test reports and design reports.

The Architect Engineer further 3

performs an independent evaluation'of the'NSSS design =

The Architect Engineer is assigned iresponsibility for the document distribution for i

Phases I, II and.III of the job.

1-12 Rev 57 12/dddHonwealth Edison

-The primary responsibilities of the Superintendent of the-Quality Assurance Central

-l Committee are to:

a.

Develop strategic Corporate Quality Assurance policy for the design, procurement, construction, and operation of the Company's nuclear and fossil power facilities.

- l b.

Develop and obtain approval of inter-departmental agreement documents to facilitate the implementation of Quality Assurance and Nuclear Safety policies, c.

Anticipate potential Quality Assurance problem areas through review of both Company internal and external documentation,

d.. Maintain, in an up-to-date condition, the Quality Assurance Manual for both the nuclear and fossil divisions, e.

Assist Company personnel in the use and l

Interpretation of'the Quality Assurance Manual.

f.

Develop and maintain the training. program requirements and issue certification documents for all personnel filling the,

g position of an audit function, g.

Report difficulties in the implementation of the Quality Assurance Program.or Quality Assurance Policy developed by-the Central-Policy Committee directly'to the Manager of Quality Assurance / Nuclear Safety.

1.11.1.3 Suoerintendent of Off-Site Audits The Superintendent of Off-Site Audits reports to the Manager of Quality Assurance / Nuclear Safety with approval-by the Chairman and CEO.

The responsibilities of the Superintendent of Off-Site Audits are:

a.

Managing the corporate off-site vendor audit program.

b.

Managing the Off-Site Audit Program of the-various organizations of-the Nuclear and Fossil-Stations' Divisions to obtain an-independent assessment of the implementation of the Quality Assurance Programs for these two Divisions.

c.

Managing the Off-Site Audit Program of the Nuclear Steam Supply System (NSSS) Vendors and Architect Engineers (AE).

1 1-41 Rev. 57

'12/01/89 Commonwealth Edison

- - - - - - - - _ = _ - - _

d.

Managing the evaluation program of vendor.

quality assurance progra s (fossil and nuclear).

e.

Maintenance of the Quality Approved Bidders I

List for both fossil and nuclear vendors.

f.

Develop and maintain the training program requirements for all personnel actively participating in audits.

g.

Represent the Company in joint utility audit efforts and manage internal programs for utilization of said joint audits.

h.

Managing the annual assessment of Company adherence to the Quality Assurance Program.

1.

Report significant problems identified s

during the audit process to the Manager of QA/NS.

1.11.1.3.1 Mudtar Fuel Fabrication Inicattor.

The Nuclear Fuel Fabrication Inspector reports to the Superintendent of Off-Site Audits and has the responsibility for survelliance inspection and audit of fuel fabrication at vendor's plant, overview of the fuel control at the nuclear stations and keeping abreast of fuel assembly problems and concerns.

1.12 Purchasino Resnonsibilities 1.12.1 Manaaer of Fuel The Manager of Fuel is responsible for Commonwealth's procurement of nuclear fuel to specifications furnished by the Nuclear Fuel Services Department.

He reports to a Vice President on matters involving such fuel.

1.12.2 Director of Procurement The Director of Procurement is responsible for the procurements of non-fuel goods and services to specificatons prepared by responsible originating departments.

He reports to a Vice President on matters involving such goods and services.

2.0 Division Onerations Resnons1hilitiet 2.0.1 Substation Construction Denartment The Substation Construction Department performs electrical modification at nuclear generating stations as directed by the Production Superintendent, or designee, or the Engineering and Construction Department Construction Superintendent, or designee, and in accordance with the provisions of this Quality Assurance Manual.

Substation Construction Site Specific Procedures are osed to control specific processes and procedures unique to electrical construction and installation.

1-42 Rev. S7 12/01/89 Commonwealth Edison j

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2. QUALITY ASSURANCE PROGRAM 2.1 General The Commonwealth Edison Company has extensive experience with the development, scheduling, design,. construction and operation of electric generating facilities.

It has pioneered in commercial nuclear power. Commonwealth Edison Company and its consultants and vendors have j established designs and specifications for compliance with applicable ) regulations, ASME Code and National Standards to assure installations of i utmost safety and reliability. Commonwealth Edison Company has attained qualified equipment i vendors and contractors through experience, evaluatlon at vendor plants and site surveillance during plant erection. These efforts provide j assurance that compliance with applicable design specifications and codes is maintained and a high level of reliability is achieved. L2 Policy It is the policy of Commonwealth Edison Company to assure a f high degree of functional integrity of the equipment, structures and safety-related systems of its nuclear generating facilities, the performance of which are essential to the prevention of nuclear accidents that could cause undue risk to the. health and safety of the i public, or to the mitigation of the consequences of such a'ccidents in the unlikely event they should occur. These systems, equipment, and structures will be identified, designed, fabricated.. erected, tested and operated to the criteria and requirements of ASME Boiler and Pressure Vessel Code Sections III and XI, as referenced in the SAR appitcable to a specific unit at the time of engineering, construction and major modifications, Appendix B to 10CFR50, Subpart H to 10CFR71, Regulatory [ Guide 1.28, Rev. 3, dated 8/85 and the mandatory requirements of ANSI /ASME NQA-1-1986 with the provision that Ceco suppliers / vendors maintain a quality assurance program which satisfies ANSI /ASME, NQA-1-1986, ANSI N45.2 Standards not covered by ANSI /ASME NQA-1,- and N18.7 Standards (or the ANSI /ASME N45.2 series of standards for previously accepted non-ASME quality programs). The commitments to Regulatory Guides and Standards.shall apply to each respective station as listed below. Also, Commonwealth Edison commits to comply with 10CFR Part 21 " Reporting of Defects and Noncompliance" and with the Regulatory position of the following Regulatory Guides and the requirements of the following ANSI Standards as litted for each station. 2-1 Rev. 57 12/01/89 Commonwealth Edison

i I. Drcsd'n, Quad Citics and Zion Nuejear power Stations f 1.28 - Rev. 3, 8/85; 1.30 (Safety Guide 30 - 8/72); 1.33

• 5i (Safety Guide 33 - 11/72); 1.37 3/73; 1.38 - 3/73; 1.39 -

3/73; 1.54 - 6/73; 1.8 (Safety Guide 8 3/71); ANSI N45.2.8-74 i (Draft 2, Rev. 3, 4/74); ANSI N45.2.5-73 9 Draft 3, Rev. 1, en 1/74) II. LaSalle County Nuclear Power Station 1.28 - Rev. 3, 8/85; 1.30 - Rev. O, 8/72; 1.33 - Rev. 2; 1.37 HR - Rev. O, 3/73; 1.38 - Rev. 2; 1.39 - Rev. 2; 1.54 - 6/73; 1.8 Rev. 1-R; 1.94 - Rev. 1; 1.116 - Rev. 0-R, 6/76 i III. Byron and Braidwood Nuclear Power Stations en 1.28 - Rev. 3, 8/85; 1.30 - Rev. O, 8/72; 1.33 - Rev. 2; 1.37 Rev. O, 3/73; 1.38 - Rev. 2; 1.39 - Rev. 2; 1.54 - 6/73; 1,64 - Rev. 2; 1.8 - Rev. 1-R; 1.94 - Rev. 1; 1.116 R, 6/76

• 51 Exceptions or alternatives to thic Topical Report for specific plants identified in the Safety Analysis Report or Technical Specification will take precedence over commitments in this Topical Report.

It is also the policy of Commonwealth Edison Company to assure a high degree of functional integrity for its generating facilities so as to achieve high availability of these facilities for the' production of electrical power and to maintain overall quality levels which will achieve the foregoing in a safe, effective and economic manner, The Quality Requirements and Quality Procedures of the Company Quality Assurance Program Manual (see Appendix A for Program l Manual Index) as described herein, document the written policies and procedures of the program and are augmented by other written Depart-ment and Station procedures and instructions. In the Quality Assurance Department controlled Quality Assurance ~ Department instructive, directive and procedural type documents are used to further explain in specific detail certain department activities as deemed needed. Such documents may cover items such as training, training program, review of procurement documents, personnel qualification and certification, maintenance and updating of ASME Code information on the computerized Quality Approved Bidders List, etc. In addition, Site Quality Assurance Departments may have controlled Site instructions to provide detailed explanations and methodologies for implementing the Quality Requirements and Quality Procedures, and to provide instructions for other site quality activities as necessary. 4 2-2 Rev. 51 7/7/88 Commonwealth Edison 4

The quality assurance programs of Commonwealth Edison Company, Architect Engineers and Nuclear Steam Supply System vendors include the requirements of ASME Section III Article NCA-4000, the quality assurance criteria for nuclear power plants of Appendix B to 10CFR50 " Quality Assurance Criteria for Nuclear Power Plants," and the mandatory requirements of ANSI N45.2, " Quality Assurance Program Requirements for Nuclear Power Plants"; and ANSI N18.7, " Standards for Administrative Control for Nuclear Power Plants." The requirements are implemented by means of detailed quality procedures delineating the specific methodology to be used. In addition, individual contractors', fabricators' and vendors' Quality Assurance programs will include the applicable portions of the Code, Standards and Appendix B as they affect the total program. The overall Commonwealth Edison Company quality assurance program, as a minimum, provides for engineering design control, procurement, audit and [ surveillance of on-site contractors and off-site vendors, surveillance and audit of the performance and quality assurance procedures of the Architect Engineer and Commonwealth Edison Company Purchasing and Engineering and Construction groups; and for plant operations quality assurance programs covering plant maintenance, repairs, operations, in-service inspections and modifications. For i operating stations, the Corporate Quality Assurance Program activities also are covered by written policies, programs, procedures and instructions included in the Station Procedures Manual and other documents. The Manager of Quality Assurance / Nuclear Safety responsibilities include the establishment and control of the Station Program, preparation and authorization ~of the Quality Assurance Procedures for operations, and audit and verification of station activities as to the adequacy of the Station Program's implementation. The Station Manager provides written procedures and instructions for the Station Procedures Manual and administers the policies, procedures and instructions from the time the Operating License is issued throughout the operating life of the station. The Quality Assurance Program takes into account the need for special controls to maintain the required quality and the need for verification of quality by inspection and test. The Station activities affecting quality are accomplished in accordance with the Corporate Quality Assurance Program using appropriate equipment and suitable conditions, and completing prerequisites. Disputes of a major nature between the Quality Assurance Department and organizations which cannot be resolved will be referred to higher management for resolution. 2-3 Rev. 57 12/01/89 Commonwealth Edison

Achievements of the applicable requirements of the Codes, standards and specifications for materials, structures e.quipment and systems will be verified through independent quality control activities. The control activities will encompass design, procurement specifications, materials, processes, procedures,,1dentifications, testing, nonconformance, corrective action, documentation, handling, storage, operating, maintenance, modifications, in-service inspections ar,d repair. Commenoralth Edison Company personnel involved in Company Quality Assurante activities will be primarily involved in audit and surveillance of quality control and assurance activities performed by l 'various contractors and other Edison personnel. Inspection, testing and examination activities generally will be performed by outside independent testing service contractors. To achieve the necessary background and experience for ' Commonwealth Edison personnel in quality control and assurance activities, indoctrination and training programs will be established by the Manager of Quality Assurance / Nuclear Safety or his delegated

• ss representative to assure such personnel will have adequate knowledge or skill to perform these activities.

These indoctrination and training programs will be an extension of their formal education or work expertence. The training program to qualify and/or certify people for the

• 55 quality assurance work activities they perform will consist of, but not be limited to, the following methods as required:

1. Company Quality Assurance Program Orientation 2. Formal Training Programs - classroom and hands-on 3. On-the-job Training - inspections, auditing, testing, etc. 4. Industry Seminars - concrete, coatings, QA/QC, etc. 5. Inter-and Intra-Departmental Sessions 4 The orientation sessions covering the Quality Assurance Program , ill include engineering, construction, production, Quality Assurance, w purchasing, licensing, System Materials Analysis and System Operational

• ss Analysis personnel. Various personnel at all levels of site and station activities and general functions will be included.

These orientation sessions are intended to acquaint personnel with quality assurance / quality control functions and inter-and intra-departmental responsibilities, and to serve as a feedback mechanism to assess and

• 55 evaluate the Commonwealth Edison Quality Assurance Program.

2-4 Rev. 55 3/27/89 Commonwealth Edison

5 Individuals engaged in the quality assurance program (Engineering, Construction, Production, Quality Assurance, Purchasing, i System Materials Analysis and System Operational Analysis) activities

• 5s will be involved in formal training programs utilizing outside agencies and consultants and, as required, will include the following subjects:

} 1. Quality Assurance / Quality Control principles 2. Codes and Standards 3. Nondestructive Examination (principles and practices) i 4. Special Processes 5. Audits l The "On-The-Job" Training program will involve new personnel working under the tutelage and direction of experienced and qualified quality assurance personnel. In addition, these programs will include i the following as required: i 1. Site and Off-Site Seminars for selected subjects 2. Group discussions and problem reviews l 3. Individual training and tutoring 4. Appropriate company and other educational courses The utt11 ration of Industry Seminars will be made as appropriate 7 for responsibilities and disciplines involved. Edison personnel engaged in testing activities will be assigned l according to'their formal education and on-the-job experience. Additionally, training programs will be developed to indoctrinate and qualify personnel in specific inspection, testing or examination i activities in which they will be engaged. The System Materials Analysis

• 55 Manager will be responsible for the development and execution of these t

programs. i Training will be conducted in a time frame adequate to prepare I personnel for their job responsibilities. When a project or station organization is developed, the Nuclear Quality Programs Manager and

• 55 Quality Assurance Superintendents are responsible for reviewing the adequacy of trained and certified personnel and recommending necessary

{ training programs. Retraining sessions will be scheduled to assure that adequate skills are maintained for qualified and/or certified personnel. Certification records will be maintained by the Quality Assurance Department as well as the department where in the employe performs his activities. Qualification and certifications will be maintained in a current status and will be established to meet the applicable requirements of ASME Code including ANSI /ASME NQA-1 and as provided and committed herein. h i t i l I 2-5 Rev. 55 3/27/89 t Commonwenith Edison

I The training and certification of personnel tssociated with nondestructivA examination will be carried out in accordance with the requirements of SNT-TC-1A and the Code. A Level III certified person will administer this activity and the program will be under the surveillance of the Nuclear Quality Programs Manager and the Superintendent Quality Assurance Central-Committee or their delegated representatives. Likewise, a Level III certified person will administer the concrete containment inspection as applicable under Division 2 of the ASME Code. Training and certification of personnel associated with concrete containment inspection will be carried out in accordance with Appendix VII of ASME Section III, Division 2. The period of qualification shall be a maximum of three years. Near the end of such period, employees will be notified and they will require either retraining and requalification and/or .recertification to renew their qualification status. The period of qualification shall be a minimum of two and a maximum of three years. Near the end of such a period, employes will be notified that they will require either retraining and requalification and/or recertification to renew their qualification status. Contractor personnel engaged in inspection, examination and testing activities will be required to be trained, qualifted and , certified to perform their specific activity in accordance with the above requirements. Such training shall be documented and the record of those receiving training shall include as a minimum the date, duration, fsubject, the name of the person who performed the training, and the 'name of the person being trained. The objectives of the Commonwealth Edison Company Quality Assurance Program are to: (1) establish with confidence that the design, fabrication, erection and operation phases of its nuclear . power generation facilities are performed in a manner consistent with the policies stated above; (2) provide for documenting, retaining documentation and updating design, fabrication, erection and product quality information necessary for Commonwealth Edison Company operation, maintenance, repair, modification, refueling and in-service inspection of the nuclear power factittles: (3) avoid schedule delays and high cost due to poor quality; and (4) achieve high plant reliability and availability. The Quality Assurance Program applies to safety related and 'ASME Section III activities, items and related consumables, plus fire protection, security, emergency plan, meteorology, radioactive material transport packages, and review of environmental qualification of Class IE Equipment and requirements of the Jurisdiction. The classification of structures, systems and componentsJdesignated as " safety related" are listed in the respective Safety Analysis Reports (SAR) of the Stations. A copy of the SAR or the listing will be available in the Operations, 2-6 Rev. 57 12/01/89 Conwnonwealth Edison

) Construction, Quality Assurance and Engineering areas, as necessary, for reference. Distribution of and revisions to this listing are controlled and approved by the Nuclear Engineering Department. The requirements in ASME Section III, Article NCA-4000 shall be applied to Section III systems and components including concrete containments. The 18 Criteria of Appendix B of 10CFR50 will be applied to safety-related systems and components for design, construction, maintenance, refueling, in-service inspection, repair and station J modifications. Criteria 1, 2, 5, 6, 10, 11, 12 and 14 to 18 and Regulatory Guide 1.33 will be applied to operation of safety-related systems and components. The Manager of Quality Assurance / Nuclear Safety will be i responsible for assuring a regular review of' adequacy of the Quality Assurance Program. Periodic written reports will be provided to l Upper management covering activities and problems involving the requirements of the Quality Assurance Program. Also, an overall report will be made annually to upper management for their assessment as to scope, status implementation and effectiveness of the Quality Assurance Program to assure that it is adequate and complies with 10CFR50, Appendix B Criteria. An independent management audit for upper management shall be conducted on a two year cycle to evaluate the status and adequacy of the Quality Assurance Program. This annual assessment is preplanned and documented. Recommendations for corrective action are identified and tracked. The Quality Assurance Programs in the Commonwealth Edison Company Quality Assurance Program Manual and revision thereto are approved and controlled by the Manager of Quality Assurance / Nuclear Safety and may only be revised with his approval. The Quality Requirements Quality Procedures, ASME interface, and Station QA l Manual shall be revised and changes implemented in concert with I editions and addenda of Section III of the ASME Code. This will be accomplished within a 6 month period of the date of such issuance. Such revisions to this Quality Assurance Manual involving ASME Section III shall require acceptance by the Authorized Nuclear Inspector Supervisor, and notification plus evidence of such acceptance to the Authorized Nuclear Inspector concurrently with the issuance of such changes. Submittals to the Authorized Inspection Agency Nuclear Inspector Supervisor shall be by letter, in duplicate, by the Manager of Quality Assurance / Nuclear Safety requesting review and acceptance and return of the carbon copy of the letter with such acceptance indicated to the Manager of Quality Assurance / Nuclear Safety. Concurrently, a copy of the updated Corporate Quality Assurance Manual shall be made available to the Authorized Nuclear Inspector at the stations where Code work is being done. Programmatic changes to the Progr&m are submitted to the NRC Region for acceptance prior to implementation, Organizational changes are submitted within thirty days'of the effective date. Changes which do not reduce commitments must be submitted to NRC at least annually for changes affecting operational stations, and within 90 days of implementation for. changes affecting stations under construction. Changes which reduce commitments must be submitted to and approved by NRC before being implemented. l l 2-7 i Rev. 57 CommonwesNh Edison 12/01/89

O t These requirements also extend to the " principal contractors"-the Architect-Engineer and the Nuclear Steam Supply System vendor for each project. Initial assurance that the current Q.A. program description for each of these contractors has NRC approval, either as a part of the Safety Analysis Report or as a separate Quality Assurance Topical Report applicable to the respective projects, will be established by audits. These Edison audits will also assure that each principal contractor has audited its subcontractors, so that changes in those firms' respective programs have not abrogated commitments in the principal contractors' programs and that such programs continue to meet 10 CFR 50 Appendix B requirements. Quality Assurance Procedures involving engineering, construction, operating, maintenance, modification, in-service inspection and Stores activities, and revisions thereto. .are signed by the Head of the principally involved department (s) and . approved by the Manager of Quality Assurance / Nuclear Safety. Approval of the Quality Assurance Program Manual Indexes indicates approval of respective changes to the individual pages of the Corporate Quality Assurance Manual. Sections 2, 5 and 18 of the Quality Procedures provide the procedures for implementing this section of the Quality Requirements. .i 2-8 Rev. 55 03/27/89 Commonwealth Edison

-l 3. DESIGN CONTROL 3.1 General The fundamental vehicle for design control involves multi-level review and/or evaluation of design documents by i individuals or groups other than the original designer or designer's i immediate supervisor whose authority and responsibility are identified and controlled by written procedures. Also, procedures are established to assure that verified computer codes are certified for use and that their use is specified. The design documents include, but are not limited to, system flow diagrams, design and construction specifications, load capacity data sheets, design t reports, equipment specifications, process drawings. Design calculations are also subject to two or more levels of evaluation or review including that performed by the originator plus review and audit by the Nuclear Engineering Department for modifications where

• 55 design work is performed by the Architect Engineer or other vendors 4

or contractors. Design changes are controlled through document revisions resulting from design change requests and/or design change notices and are reviewed, evaluated and, where applicable, certified in the same way as the basic design documents. These design evaluations or reviews are conducted to written procedures and include consideration of quality standards, quality assurance requirements, materials suitability, process suitability, interface control and suitability of analytical or testing requirements'as appropriate. Also, design verification, except for ASME Code items, may be achieved under a test program by qualification testing of an item under adverse design conditions. Responsibility for overall design and design control of i mechanical, electrical, structural and nuclear related systems and components and compliance of responsibilities to Section III of the ASME Code is assigned to Projects Engineering, where established.

• 55 during the initial design and construction and to the Nuclear Engineering Department after plant start-up. Quality Assurance shall assure that design control requirements are fulfilled through review and audit.

The extent of the design review and evaluation of the original designs and modifications will be determined by the l complexity of the system and any safety-related function to be performed by that system. Design evaluation of modifications will

• 55 be commensurate with those applied to the original design.

Review and evaluation by the Architect Engineer, the Nuclear Steam Supply System vendor, Projects Engineering and/or the Nuclear Engineering Department, as appropriate, and other CECO. organizations, and

• 55 specially qualified people, such as Level III's for NDE and for concrete inspection and tests, will assure that designs, t

specifications and procedures will conform to the ASME and other applicable codes, standards, regulatory requirements, SAR commitments and appropriate quality standards, as applicable. 3-1 Rev. 55 3/27/89 Commonwealth Edison

Projects Engineering, where established, during initial design, and the Nuclear Engineering Department, after plant start-up, will review and evaluate the overall design for safety, reliability, inspectability, maintainability and constructability. The Vice Presidents (BWR and PWR Operations) are responsible for resiew of designs for operability, inspectability and maintainability. The i i Nuclear fuel Services Departm0nt will be responsible for either performing reactor core design analyses or for reviewing vendor generated analyses. The Nuclear Fuel Services Department is also responsible for the design specifications and design reviews for nuclear fuel and in-core components, including when actual work is i delegated to other areas, t Coordination of the design review and evaluation effort by Projects Engineering and the Nuclear Engineering Department, as t applicable, will be, in part, directed toward the identification and control of design interfaces, radiation and environmental requirements, functions and boundaries, and selection and application of materials, parts, equipment appurtenances and components. Design analysis shall be performed in a planned, controlled and documented manner. Documentation of the design analysis shall include definition of the - objective of the analysis, definition of design inputs and their l Sources, results of literature searches or other applicable background c data, identification of assumptions and indication of those that must - be verified as the design proceeds, identification of any computer calculations, including, computer types, computer program (e.g. name), l revision identification, inputs, outputs, evidence of or reference to computer verification, and the bases (or reference thereto) supporting , application of the computer program to the specific physical problem and code or program validation review and approval. l l Projects Engineering or the Nuclear Engineering Department, as applicable, with assistance from other organizations, contractors or i -vendors, shall apply, as applicable, design review and control measures to items such as: reactor physics; loads and loading combination. transient and accident analysis, compatability of materials, structural . support, accessibility for in-service inspection, maintenance and repair; and delineation of acceptance' criteria for inspections and tests. Projects Engineering or the Nuclear Engineering Department, as applicable, the Architect Engineer or Nuclear Steam Supply System Supplier interpret applicable requirements, standards, guides or codes (including classification of ASME Socion Section III items) and use them as a basis for classifying structures, systems and components and ' establishing boundaries of jurisdiction in each nuclear power plant. Evidence of design evaluation and reviews and use of alternative calculational methods used to assure verification or checking of design adequacy will be documented and retained by Projects Engineering and by the Nuclear Engineering Department, as applicable, or by the Nuclear fuel Services Department for fuel or in-core related matters. Errors and deficiencies discovered shall be documented and 3-2 l Rev. 57 12/01/89 l-6 Commonwealth Edison l T "~- a --m-- m ---.-.-m.

3 l i t i

4. PROCUREMENT DOCUMENT CONTROL The procurement documents include equipment specifications or specifications for services, each of which are reviewed or evaluated as described in Section 3 for design and construction, and design and construction for modifications.

Changes to procurement documents are subject to the same review and approval requirements as the original documents. Contract or purchase order documents are reviewed by the NSSS Supplier for NSSS items and by Edison and the Architect Engineer for non-NSSS 1tems to insure that all i requirements have been incorporated specifically or by reference. Records pertaining to the review and evaluation of procurement documents involving initial plant installations and-plant nodifications will include, in whole or in part, minutes of i meetings, comment letters, design review records,-project quality assurance audits and a copy of the original design document marked with comments or latest revisions. These records will be kept in vendor files and/or applicable Commonwealth Edison Company department files during the Engineering, Construction and Operation phases of the generating station. The quality assurance and engineering requirements Including documentation requirements, will be stated, as applicable, in the bid package, contracts and purchase orders for safety-related and ASME Code related procurements. Also, the review for suitability of application of commercial grade or previously approved materials, parts and equipment that are safety-related will be imposed on vendors. Where material, equipment, systems or i services require contractors to adhere to ASME Code requirements or I have ASME Section III Certificates, these requirements will be I contained in the procurement documents. Quality Assurance Program requirements, as well as requirements for subtier procurements, are included as regulatory, code, standard and design requirements. Similarly, the required methods of identification, preservation and packaging, and methods of controlling conformance to acceptance criteria are covered by these documents. Quality Assurance Program requirements, including subtier program requirements are included in l initial procurement contract and reviewed for acceptability by Quality Assurance to provide for implementation of the accepted quality assurance program, vendor evaluation, inspection and test planning, vendor surveillance, witnessing of inspection control points and inspection documentation. Also, requirements for vendor documents, such as 4-1 Rev. 57 12/01/89 Commonwealth Edison

Instruction, procedures, drawings, specifications and vendor quality assurance records to be prepared, submitted or made available for review or approval are included. In addition, included in the procurement documents are provisions for right-of-access to vendors' fatllities and work documents for inspection and audit and for vendor reporting and disposition of nonconformance from procurement requirements. Procurement control is by Ceco with procurement of major equipment and items being purchased by the General Office Purchasing Gepartment and procurement of standard type materials and items being performed by its satellite purchasing organization, where established .at certain sites. For procurements initiated by Projects Engineering or Nuclear Engineering, the cognizant Project Manager or Design ^ Superintendent / Supervisor, or designee, as applicable, prior to submittal of the Engineering Proposal Request to the Director of

Procurement, prepares a suggested list of prospective bidders for each specification from the applicable Approved Bidders' List using

_ input from the Architect Engineer and the cognizant Purchasing . Department Buyer. The Bidders lists are established using such , factors as past expertence, expertence of other utt11ttes, or . specific qualification surveys. For Code work, the desk survey shall be limited to determination that a supplier or contractor is the holder of a valid ASME Section III Certificate for the scope of work l . involved or for determining if a supplier or contractor is .potentially quallfled. The final list of prospective bidders, as gwell as the person agreeing to the list as indicated on the Nuclear Proposal Request (NVPR), is approved by the cognizant Project Manager .or the Nuclear Engineering Manager for modifications or designated alternates. The persons agreeing to the list are key representatives ,of Projects Engineering and Projects Construction, or the Nuclear LEngineering Manager and the Engineering and Construction Department ,after plant start-up for modifications, BWR/PWR Nuclear Operations, the Purchasing Department and, when requested, the Architect Engineer. Where bids are obtained from prospective bidders other than those listed on the Quality Approved Bidders' List maintained by the Quality Assurance / Nuclear Safety Department for the Purchasing Department, such bids shall be indicated as trial bids and shall be . treated as trial bids until the bidders are evaluated and approved as acceptable prior to award. Upon completion of the evaluation of the proposals from , approved bidders for either original plant or plant modification 'ltems or services, the responsible Project Manager or Design Superintendent / Supervisor shall have prepared and, after final review and approval indication by the cognizant ENC Nuclear Quality Programs Engineer, shall have transmitted to the Purchasing Department a letter of recommendation and a purchase requisition. The purchase requisition and/or letter will 4-2 Rev. 57 12/01/89 ConwnonweaHh Edison

l l l l incorporate, by reference, those documents such as specifications, drawings, proposals, etc., and any conditions of award which form the basis for the evaluation and award. Purchasing, based on the recommendation letter, its own evaluation and the purchase t requisition, shall conduct necessary negotiations and clarifications and make the award to the successful bidder. Any changes evolving from the procurement activities involving technical or quality assurance matters, either for the original purchase or subsequent I change orders, shall be approved by the originator of the purchase i or change order requisition. f The Engineering and Construction Manager will assign authority for technical evaluation of the vendor quality assurance j program to the Director of Technical Services. The quality t evaluation of the vendor's quality program will be the responsibility of the Superintendent of Off-Site Audits. Quality

• 56 Assurance / Nuclear Safety Department shall evaluate and accept all such vendor quality assurance programs.

All evaluations shall bo completed prior to final award of the contract or purchase order. The Superintendent of Off-Site Audits is responsible for assuring r f that the evaluation is carried out and for auditing the manuals of bidders being recommended as acceptable for award as to resolution of comments received by Engineering. As part of the vendor quality assurance program evaluation, the Superintendent of Off-Site Audits

• 56 will assure all vendor quality assurance program deficiencies are resolved.

If the vendor program deficiencies are minor and/or may

• 56 be corrected by specific procedures for the work to be done, the resolution may follow an award and shall be a condition of the award.

l 3 For procurements performed at certain construction sites by the Purchasing Department satellite organization involving safety-and Code-related items, the preparation of the necessary procurement i documents is the responsibility of Projects Construction. Procurements by the site Purchasing organization are under the control and management of the General Office Purchasing Department I and associated procurement documentation packages are formulated from specifications and drawings issued and approved by Engineering. The cognizant Field Engineer or, as applicable, the l Projects Field Engineering Manager, prepares the suggested list of prospective bidders for each procurement package from the Quality Approved Bidders' List with direction from the site Purchasing Department Buyers. The final list of prospective bidders and procurement bid package is approved by the site Projects Construction Superintendent or Projects Engineer or their designated alternate. In addition, such procurement bid packages involving the purchase of ASME Code and safety-related materials and items are 4-3 Rev. 56 9/13/89 i Commonwealth Edison

required to be-reviewed and approved by the Site Quality Assurance Superintendent, or designated alternate, verifying that the l necessary technical and Quality Assurance requirements are included l and the proposed bidders are acceptable. 4 The bids are evaluated by Projects Construction and an award recommendation plus a purchase requisition is prepared and transmitted to Purchasing via the Site Quality Assurance Superintendent, or designated alternate, for final review and concurrence indication. Site Purchasing, based on the recommendation of Projects Construction, its own evaluation and the purchase requisition, conducts necessary negotiations and . clarifications and make the award to a bidder on the Quality , Approved Bidders' list. Any changes evolving from the procurement ' activities involving technical or quality assurance matters, either for the original purchase or subsequent change orders, shall be l approved by the originator of the purchase or change order requisitions as well as Quality Assurance. 'l The Manager of Fuel is responsible for the preparation of , nuclear fuel bid documents, for the evaluation of bids received and _for the purchase of nuclear fuel. The Nuclear Fuel Fabrication Inspector provides quality assurance assistance. The Nuclear fuel , Services Manager, and others as necessary, furnish technical j l assistance to the Nuclear Fuel Agent during the preparation of bid l ~. documents and the evaluation of bids. Mhen the Assistant Superintendent of Maintenance or < Technical Staff Supervisor orders spare parts, material and ' equipment for safety-related items, components and modules to i I' applicable engineering and quality assurance requirements, he g specifies the quality assurance documentation requirements . equivalent to or better than the original design or specification. .When spare parts, material and equipment are ordered by part number or nomenclature without special engineering requirements being specified, appropriate statements are included in the purchase order to assure they are at least equivalent to the original equipment. The Quality Control Supervisor shall review and verify that quality assurance, specification ASME Code and other applicable codes and standards requirements and special requirements are included in the Request for Purchase, The procurement documents are reviewed and processed by the l Support Services staff in the Stores and Materials Management Department. Coded part numbers are assigned to spare parts. The Support Services staff and the Manager of Quality Assurance / Nuclear Safety, or designee, or Nuclear Quality Programs Manager review and approve that the quality requirements for documentation of spare parts, welding materials, material and equipment as outlined above, are included in the procurement request documents and that the items are ordered from the original equipment supplier or an evaluated and approved alternate supplier. 4-4 i Rev. 57 r 12/01/89 Commonwealth Edison i

The bid package and the resulting contracts or purchase order will clearly reference applicable revision dates of appropriate drawings and specifications for the item or service being procured. Appropriate' revisions of ANSI, ASME or other applicable codes and/or standards will be considered a part of the design requirements and be referenced in the bid package, contract or purchase order. The bid package and resulting contract or purchase order will contain the requirements for inspection, testing and inspection documentation. Commonwealth Edison Company, its vendors and sub-vendors will be responsible for their respective programs by which an appropriate review and audit will determine that the requirements of this Section have been met. Procurement documents will identify which records indicative of quality will be transmitted to Commonwealth Edison and the method of dispositioning those which the vendor retains. The bid package and resulting contract or purchase order will contain, as applicable, the requirement for the vendor to have and implement a quality assurance program which has been accepted by Ceco for purchased safety-related and ASME Code materials, equipment and services to an extent consistent with their importance to safety and will state the controls which will exist between the purchaser and seller in requesting and accepting changes under the purchase order or contract. Also, revisions to such quality assurance programs shall be submitted to CECO for review and acceptance during the term of the contract or order. Procurement of spare parts or replacement items will be subject to controls at least equivalent to those used for the original equipment. The procurement of spare parts is governed by i Quality Requirement 7.0, paragraph 7.8. I 4-5 Rev. 57 12/01/89 Commonwealth Edison

o

5. INSTRUCTIONS, PROCEDURES AND DRAHINGS The quality assurance actions carried out for design, construction, testing, and operation activities will be described in documented instructions, procedures, drawings, specifications, or checklists.

These documents will assist personnel in assurir.g that important activities have been performed. These documents will also reference applicable acceptance criteria which must be satisfied to assure that the quality related activity has been properly carried out. Activities affecting quality are required by the Edison quality program to be prescribed by documented instructions, procedures or drawings. Procurement documents and the corporate guality assurance. programs of Edison, the NSSS Supplier and Architect Engineer reflect this requirement. Each Edison Department involved in safety-related and ASME Code work shall have documented procedures to implement their responsibilities. Quality Procedures as part of the Commonwealth Edison Company Quality Assurance Manual will be written for design, construction, testing, operations, maintenance, repair, and quality activities. Where appropriate, these procedures will include checklists containing the necessary elements of operation to be observed or measured. These checklists will be used to the maximum extent practical to document the actions performed. Generating Station operations, procedures and instructions will be provided by the Station Manager and will be included in the Station Procedures Manual in a timely manner _ consistent with NRC license requirements for administering the policies, procedures and instructions from the time that the Operating License is issued through the life of the station. These procedures and instructions include: Administrative Procedures Overall Station Procedures System Operating Instructions, Chemical Control Procedures, Emergency Operating Procedures, Surveillance Procedures, Maintenance Procedures, Instrumentation Procedures Radiation Control Standards and Nuclear Operations Directives. Also, a Station Quality Assurance Program for Maintenance, Modification In-Service Inspection and Stores Activities will be provided. The procedures 5-1 Rev. 57 12/01/89 Commonwealth Edison ]

+ include specifications and acceptance criteria as well as vendor documents. Complex procedures include checklists as part of the procedure and caution notes applicable to specific steps in the procedure I are included. I The current revision of the Station Procedures Manual 1s available in the Station Control Room and is additionally provided to key operating and management personnel. Maintenance and repairs to structures and equipment after construction and testing is completed are the responsibility of each Assistant Superintendent of Maintenance and are performed in accordance

• ss with applicable drawings, procedures, instructions, and/or checklists for Code and safety-related work. When ASME Code work is involved, these documents shall be submitted to the Authorized Nuclear Inspector for Insertion of his hold points. Drawings procedures, instructions and/or checklists are used for maintenance and repairs outside the scope of j

normal station craft maintenance capability. When procedures and/or checklists are not available for work outside the scope of normal station maintenance craft capability, an outilne of the steps to be followed will j be prepared to assure proper completion and testing of the maintenance or repair work. These procedures and/or checklists or outlines are supplemented as necessary by instructions from the personnel responsible for directing the. specific maintenance or repair work. Maintenance, modification and inspection procedures and other quality assurance related documents are reviewed by Quality Assurance personnel to assure the ?eed for inspection, identification of inspection personnel, and documentation of inspection results plus necessary inspection requirements, methods and acceptance criteria is provided. Each Station Manager or his designee is also responsible for

• ss preparation of procedures to assure the safe operation and refueling of the Station in accordance with requirements of the NRC operating t

license. The Vice Presidents (BNR and PWR Operations) provide direction

• 55 for the preparation of necessary instructions and procedures to 1

accomplish the station activities in a uniform and systematic manner. Procedures and instruction supplementing the Quality Procedures of the Quality Assurance Manual will be prepared, as required, reviewed and approved within the individual departments, generating stations and construction sites responsible for the activitics involved as the need arises and their use monitored by Quality Assurance administration. Any CECO departmental group involved with nuclear plant design, procurement, construction or operation may propose procedures as necessary to meet regulatory, ASME Code or other applicable code requirements. 5-2 Rev. 55 3/27/89 i Commonwealth Edison

O w The procedures will be independently reviewed and evaluated by other o involved departments with interf ace responsibilities and the comments forwarded to the issuing department. s Rev. 0 1/70 5-3 CosmonweeRh Edson

j l l r

6. DOCUMENT CONTROL

? I 4 A document control system will be used to assure that 4 documents such as specifications, procedures, instructions, and drawings are reviewed for adequacy and approved for release by authorized personnel. Also, this system includes as-built drawings and provisions to assure as-built drawings are kept updated, i properly maintained, and controlled. Such documents will be distributed to and used at the locations where the prescribed ~ activity is performed. Changes to these documents will be handled similarly and will be reviewed and approved by the same organization that performed the original review and approval, unless delegated by i the ortgtnating organization to another responsible organization.. Documentation will identify design documents, provide a schedule for completion, define design milestones or other control l points, and identify design responsibilities with particluar l attention to the definition cf organizational interfaces. Design documents will include ASME Code, seismic and other analysis reports, drawings, equipment specifications, work instructions, test procedures, etc., necessary to achieve proper procurement, installation, start-up and operation of systems and components in accordance with engineering requirements. Docuinent control will include documents containing re fabrication, special processes,quirements for materials, testing, inspection, cleaning, packaging, shipping, storage, maintenance, refueling, operations, and plant modifications, as applicable. The fundamental control vehicles for documentation relating to Safety Category I systems, structures and components are project distribut1on 11sts and required document status reports. The { Architect Engineer acts as the general distribution agency for project documents (except for internal Edison Quality Assurance Procedures) and carries out the distribution in accordance-with a list furnished by Edison for specific types of' documents; Both the Architect Engineer and the NSSS Supplier publish periodic 6-1 Rev. 57 l -12/01/89 l CommonweaHh Edison +

C status reports identifying those documents currently in force. These reports are distributed to all involved parties. Each document recipient is responsible for insuring that only the latest authorized documents are in use and that void documents are so identified. Required inspections and-audits by Quality l Assurance are employed as a final check to assure that the latest authorized documents are in use. Document distributton lists will be used and will I designate recipients'of document copies. This listing shall include document changes, distributions for comments, and/or distribution for_use. Document distribution reviews and approvals for key documents required by ASME Section III, Div. 2 are as stated in tht ASME Code Interface Figure III. L Document distribution lists applicable to each project I -shall be developed by the Projects Engineering Manager or the Nuclear Engineering Manager, as applicable, and will be coordinated with other CECO personnel as deemed appropriate by the cognizant Project Manager or Design Superintendent / Supervisor, as applicable. Each list-will include an issue date, revision date, and number, project identification, types of design documents, listing of various document recipient positions and the number of copies of each position. Each list will be distributed to the-1, Architect Engineer and to all recipients identified on the list , and will be accessible to the Authorized Nuclear Inspector for greview and use. i The distribution of documents will_be made by.the Architect Engineer, or respective Project Manager or Design- ' Superintendent / Supervisor, as applicable,'in accordance with the distribution list for each project. Each recipient lis'ted on the distribution list shall,,

upon receipt of new documents, destroy or segregate and clearly mark all suptrseded documents. 'Each receiving office or-area-shall have a controlled method for checking receipt of new or revised documents, and assuring that the latest revised document is in use.

Status reports will be issued periodically by Projects Engineering or Nuclear Engineering, as applicable, Architect Engineer and NSSS Supplier to all parties on the distribution list stating the latest revision of documents to assist recipients in maintaining up-to-date files. Each document recipient on the , distribution list is responsible for insuring that only~the latest . authorized documents are in use and that-void documents are so ' identified. 1 The responsible Projects Department Project Manager or the Nuclear Engineering Department Design Superintendent / Supervisor.shall periodically have the document j status reports reviewed-to confirm that the latest revisad documents are in use. Also, verification of compliance to this procedure by a physical check of document files, will be periodically perfnrmed by CECO Quality Assurance. 6-2 Rev. 57 12/01/89 Commonwealth Edison i

.~ l [ y.' i I 7. CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES l 7.1 General The control of the quality of purchased material, equipment and services is achieved through the evaluation of. vendors, survell-l lance of their operations and required source inspection, documenta-tion, receiving inspection and retention of quality records. Both Edison and the NSSS Supplier have direct procurement functions for the-Station. The Architect Engineer offers recommendations to Edison on vendor selection and reviews vendor efforts as directed by Edison. Edison will inspe:t and audit the NSSS Supplier's control of purchased material, equipment and services. Edison has the responsibility for-on-site control of Edison and the NSSS Supplier purchased material, equipment and services. Vendors (contractors and suppliers) furnishing material, I equipment and services to Ceco for items within the jurisdiction of this Quality Assurance Program will be selected on the basis of demonstrated capability to provide a product, process or service in accord uce with the design specifications and contract provisions. l The purpose of this Quality Requirement is.to define the I quality sy: tem elements and related policies which assure the quality of purchased material ~, equipment and services through the evaluation of vendors, surveillance of their operations, required I i source inspection, documentation, receiving inspection and retention l of quality records. The Superintendent Off-Site Audits will require-a Quality Assurance Program in accordance with ANSI /ASME NQA-1,. or ASME Boiler and Pressure Code Section III from vendors, consistent with the importance of the procurement to station safety and operation and i the requirements of ASME Section III and 10CFR50, Appendix B. For .ASME Code and safety-related procurements, the applicable vendor's Quality Assurance program shall be identified in-the procurement documents and shall require certification to their QA Program accepted by Ceco and shall identify the QA Program revision and date to which the work or service was performed or item supplied. In addition, Edison procurement documents will provide notification to vendor's that the provisions to 10CFR Part 21 apply. l 7-1 Rev. 57 12/01/89 Commonwealth Edison l

Control and approval of subcontractors' quality assurance programs, procedures and personnel qualifications, are the responsibility of the specific contractor involved. Such contractor actions are to be documented and will be subject to audit by Commonwealth Edison Company. An evaluation of vendor capability will be required for ASME Section III and safety-related items. Where valid records of vendor capability and quality performance are not available to CECO, a survey of the supplier's facilities, capabilities and quality assurance system will be made by CECO or its designated representative. For items requiring ASME Code conformance, vendors must be able to meet ASME Code requirements. Where material manufacturers or suppliers are qualified by CECO by survey, as provided under ASME Section III, and materials or . Items are procured directly from such qualified manufacturers or suppliers by another Certificate Holder on the basis of such survey, the qualification documentation shall be provided to the other Certificate Holder prior to its use of the materials or items. The Superintendent of Off-Site Audits in the Quality

• s6 Assurance / Nuclear Safety Department will be responsible for assuring

'that vendor Quality Assurance Program evaluations are carried out. The Quality Assurance / Nuclear Safety Department, for the Purchasing J Department, prepares and maintains the computerized Quality Approved 3 Bidders' List (QABL) for vendors of ASME, safety and regulatory related ,, items. The Purchasing Department maintains the commercial Approved LBidders List. Addition of vendors to the Quality Approved Bidders List .shall only be made upon approval by the Engineering and Construction

• 56

Manager and the Manager of Quality Assurance / Nuclear Safety, or their designees, as to meeting technical and quality assurance requiements.

s 7For vendors to be placed on the Company Quality Approved Bidders List on

• 56

,the basis of having an accepted Quality Assurance Program for ASME, . safety or regulatory related items or work, a controlled copy of their ' accepted Quality-Assurance Program shall be assigned to the Manager of

• 56 Quality Assurance / Nuclear Safety.

Section 9.0 of this report, " Control of Speclal Processes," estabitshes the evaluation and assessment of certain process and inspection capabilities of the vendor such as welding, heat treatment, and nondestructive examination. 7.2 Evaluation of Vendors i Past performance of a contractor / vendor.will be considered 'during procurement activities by CECO. Prior to contract or purchase

order award, the bidder's capability and quality performance will be

' reviewed relative to the product, process, or service being procured. For suppliers of ASME services or items and for Material Suppliers or Manufacturers who do not have a Quality System Certificate (Materials) l or an ASME Certificate of Authorization with an appropriate scope a-survey of f.'the bidder's facilities prior to award may be required. Such review will verify ASME Code compliance as applicable. 7-2 Rev. 56 9/13/89 l Commonwealth Edison

0 7.3 Surveillance of Vendor Ooerations Source surveillance will be carried out through notification points estab11shed as a condition of procurement of safety-related or ASME Section III items. Special consideration will be given for surveillance during manufacture when one of the following is involved: a. Determination of conformance of the item to purchase order requirements at any other point would require uneconomic disassembly or destructive testing, b. Special instruments, gauges, or facilities required for inspection or test are more readily available at source and would be uneconomic to reproduce at the job site. c. A receiving inspection would destroy or require replacement of special preservation and packing. d. Quality Controls and inspections are integrated into production methods, and inspection at the suppliers plant is necessary to economically verify test reports, inspection records, certifications or other evidence of. quality. Source survel' lance by Commonwealth Edison Company or its agents will not nullify the vendor's responsibilities for maintaining a quality control organization oelivering items conforming to. procurement requirements. Unless otherwise specified, acceptance by Commonwealth Edison Company will be at the nuclear generating station site in accordance with the terms of the contract. The administration, surveillance and' inspection of off-site equipment and material vendors will be the responsibility'of the Engineering and Construction Department, as' applicable with final approval of inspection acceptance reports being vested in the Nuclear Quality Programs Department. 7.4 Receivino Insnection Materials and articles received from vendors will be inspected upon receipt to assure physical integrity and identity plus docmentation compliance with the procurement requirements. For items not source inspected, specific receipt inspection measures such as material and dimensional checks against approved' drawings and specifications and assurance that ASME. Code Data Reports are received-will be performed by qualified personnel in accordance with the applicable CECO or vendor QA program and to checklists approved by appropriate Quality Assurance or Quality Control personnel to verify conformance to procurement requirements. Where receiving inspection requires the use of calibrated instruments and tools, the identity of such equipment shall be recorded on the applicable receiving inspection documents. CECO purchases Code items and turns them over to site Code vendors. In the case where receipt inspection is 7-3 Rev.55 9/13/89 Commonwealth Edison

assigned to a site contractor, CECO provides thea uith applicable procurement documents, such as the Purchase Order, Specification, etc., required to assure that the CECO purchased items meet Code requirements and to perform receipt inspection. Also, for material supplied by non-Certificate holders, the CECO survey data covering such firms is made available to site Code contractors. When CECO performs receipt inspection of such purchases or when CECO upgrades stock material for-ASME Code use, CECO provides these vendors with the applicable Certified Material Test Reports and/or Data Reports plus the Materia) Receiving Report to provide verification that the purchased items supplied by CECO meet Code requirements. Documented evidence that material or equipment conforms to procurement requirements including, for Code items, indication of their compliance to the specified quality program must be retained and available at the site prior to use or installation. Part of this evidence shall be in the form of acceptable documentation such as Certified Matertal Test Reports, Pressure Test Reports, Certificates of Conformance, etc. Documentation requirements will be delineated in the individual equipment specifications. The Construction Materials Receiving Coordinator or designee will be responsible for assuring that receiving inspection is completed where the-Engineering and Construction Department is responsible for the work; ,. receipt acceptance approval will be by Nuclear Quality Programs . Department or its designated agent. Where ASME Section III . components and safety-related materials and equipment are received -by the station Stores Supervisor, station Quality Control will be responsible for receiving inspection and the Quality Assurance Engineer or Inspector for Maintenance shall assure through audit and . surveillance that the receiving inspection is complete and traceability is maintained. ASME Code material transferred from-Stores or another Commonwealth Edison Company station shall meet the trequirements specified for the designated installation. .: Nonconforming equipment will be controlled. 7.5 Sucolier Audit Vendors of safety-related and/or ASME Section III items i will be subjected to survey, audit or surveillance of-their quality 1 . assurance system by CECO, or its agents, at intervals ~ consistent with the importance to safety, complexity, and the quantity of the product or services being furnished in accordance with approved agenda and checklists to assure that the necessary manufacturing processes are being utilized and that quality controls are being maintained. 7.6 Soare Parts and Renacements i Spare parts and replacement items, equipment and components will be purchased to original or better design requirements in accordance with the controls herein. The applicable quality assurance requirements will be included in the procurement documents. 7-4 Rev. 56 9/13/89 Commonwealth Edison

Such spare parts and replacements from vendors will-require documentation by item, component, equipment or part number for iden-tification and traceability. Documentation for material will be in accordance with procurement order requirements. When the procurement order for ASME Section III components and safety-related spare parts, material, and equipment includes a specification or drawings, docu-mentation will be received from the vendor which verifies conformance with those requirements. In the case where the original part, item, component or equipment was procured with no specifically identified quality assur-ante program requirements, or was procured from a vendor who no longer can be retained on the nuclear Quality Approved Bidders list because of an inadequate Quality Assurance Program document, identical spare parts and replacement items, components or equipment may be similarly procured from the original equipment manufacturer (OEM), but care shall be exercised-to assure at least equivalent-performance: that is, a joint technical ~ engineering and quality assurance documented evaluation shall be conducted to established requirements and controls by Technical Staff or Nuclear Engineering and by Quality Assurance personnel. The evaluation shall assure that interfaces, interchangeability, safety, fit and function are not adversely affected or are contrary to applicable regulatory or code requirements. In the use of procurements of safety-related materials', parts and items that are a manufacturer's standard product (commercial grade item), such commercial grade items shall be. Inspected as part of the receipt inspection function to assure that: (1) damage was not sustained during shipment; (2) the item received was the item ordered (i.e., its possesses the required attributes identical, as necessary, to the item specif_ led); and (3) documentation, as applicable to the item, was received and is acceptable plus, after being received,-such a-commercial grade item shall be tested, where applicable to assure that it will perform its intended function (i.e., by means of bench testing and/or functional testing as required). A commercial grade item is one that is not subject to design, specification, or testing requirements by_the supplier that are unioue to nuclear power plants; 1s one that is used in numerous appli, tions other than nuclear power plants; and it is one that can be ordered from the manufacturer / supplier on the basis of j specifications set forth in the manufacturer's published product 1 description (i.e., catalog) or on the basis of its manufacture to national standards. When an item is purchased by specifying the manufacturer's catalog part number, when documentation is required beyond that indicated in the catalog, and when such documentation is not available for items with the same part number obtained from the manufacturer, the item does not meet the definition of a commercial grade item and shall not be treated as a commercial grade item. 7-5 Rev. 55 3/27fgmcewealth Edison

The station Stores Supervisor and station Quality Control Supervisor are responsible for assuring that documentation for spare parts and equipment has been included as part of the shipment. The documentation for the purchased material, equipment, and/or services, after being reviewed and accepted by the Quality Control Supervisor will be retained at the station. When required documentation is lacking for safety-related and/or ASME Section III components or spare parts, the Technical Staff Supervisor will verify that appropriate documentation is obtained or that suitable inspection and testing is performed to verify conformance to procurerent. requirements and that such items are treated as nonconformances. Receipt inspection of spare parts and equipment purchased to ASME Section III and safety-related requirements shall be accepted by the Station Quality Assurance s Engineer or Inspector. i i i 7-6 Rev. 55 3/27/89 i Commonwealth Edison

4

9. CONTROL-OF SPECIAL PROCESSES for some processes, the required level of quality defined in ASME Code and other applicable codes, standards and specifications cannot be assured by inspection of the item alone.

For these processes, quality assurance is-obtained through reliance on personnel qualification-and procedural' control'in force as appropriate for the processes being employed for a specific task in connection with plant contract work, maintenance, repairs and modifications. The application of-these controls is assured through audit /sarveillance activities by CECO or its agent at vendor plants and/or at the site and by-Quality

• s6 Assurance at the operating stations. The Site Quality. Assurance Superintendent or' designee and the Station Quality Assurance Superintendent at the operating station is responsible for assuring that records of qualified personnel are maintained by the contractor for work performed for Edison. These special and construction processes include welding. heat treating, concrete placement, coating, plating, material cleaning and bonding, chemical processes, certain nondestructive testing processes and such additional processes that may be identified in the contract, purchase order or maintenance or modification procedure, as the result of ASME Section III, Division 1 and Division 2-for concrete containment requirements and/or design review.

Procedures for the control of special processes will be maintained for components within the primary system pressure boundary and other safety-related; items and ASME Section III designated components. These procedures will be in accordance with ASME and other applicable codes and specifications. When there is a specific reason to question whether the special process procedure or qualifications of personnel requirements are being met, the Authorized Nuclear Inspector may require requalification. Process control procedures will be used as required by specifications, Code or standards, as applicable.' Supplemental procedures will be prepared as necessary to provide detailed performance and methods for control of special processes and concrete placements for concrete containments. Process control procedures will specify the preparatory steps, processing details, i 9-1 Rev. 56 9/13/89 Commonwealth Edison

conditions to be maintained during the steps of process, inspection and test requirements and records requirements. Process control procedures of contractors and vendors will be submitted to Commonwealth Edison Company for review and. evaluation in accordance with documented Commonwealth Edison Company procedures. Process control procedures will specify the methods of verifying the adequacy of' processing materials, solutions, and equipment, including definitions of their associated control parameters. When the process is conducted in special environments, such as in vacuum or inert gases, the process control procedures will specify the requirements and methods for maintaining such environments. The control and approval of sub-vendor Quality Assurance -and Quality Control procedures are the responsibility of the specific vendor involved (included NSSS vendor). Control procedures for nondestructive examination processes such'as radiography, ultrasonic testing, liquid penetrant inspection, and magnetic particle inspection, will be used by Commonwealth Edison Company and their contractors and vendors to assure that the results provlde accurate, uniform and reproducible a , indications of actual quality. ASME Code related NDE procedures I shall be demonstrated to the satisfaction of the ANI. \\ Commonwealth Edison Company and contractor and vendor-personnel responsible for the performance and verification of special processes and the inspection of concrete placement involving aconcrete containments and other inspection and test activities w11.1

be certified as required by specifications. ASME Code or other applicable codes and standards. Certification of personnel for such i

tprocesses and concrete inspection and other inspection and test

activities will include necessary training followed by an examination of each individual.

The period of validity for i certifications shall be specified, and each individual shall be. j 'recertified at the end of such a period by retesting or by-demonstration of satisfactory performance. Personnel falling retest shall be removed from operations pending requalification. Personnel who have not performed inspection, examination and test activities in'the quallfled area for a period of one year shall be re-evaluated i ~to re-establish required capability. Training, testing, and 1 qualification of personnel shall be in accordance with criteria described in ASME Code. standards and specifications. Process control records will provide objective evidence 'that special processes were performed in compliance with approved process control procedures by qualified personnel. Process. records will specify the inspection and test data to be verified. Results-of nondestructive examinations will be recorded in accordance with ' applicable specifications, codes and' standards. These records will be retained by Commonwealth Edison Company or when the work is contracted, they will be retained by the vendor and then supplied to Commonwealth Edison Company as required by procurement documents. 9-2 l Rev. 57-12/01/89 s Commonwealth Edison. i

)

10. INSPECTION

-Inspection Programs will be established to provide assurance that the quality control surveillance, inspections and tests defined in the applicable equipment and concrete containment J specifications are performed. Quality Assurance inspection and testing will be conducted at vendor facilities, at the site during a construction, and at the station during operation, maintenance and modification activities to verify conformance to applicable drawings, instructions, and procedures as necessary to verify quality. In addition, in-service inspection will be carried out in conformance with requirements of ASME Section XI. Inspection and test control points, to be witnessed by the Authorized Nuclear Inspector, and Commonwealth Edison Company or its representative, will be established as required to assure quality of items and effectiveness of the inspection programs. Individuals performing Inspections shall have the necessary qualifications and shall be independent of the individual directly responsible for performing the specific activity. Quality Assurance personnel will. periodically review the inspection activities to establish their capability and to assure that required qualifications are met and l kept current. Inspection personnel shall be quallfled and certified in accordance with procedures which shall meet the l requirements of the ASME Code and ANSI /ASME NQA-1, for Code and safety-related inspection activities.- Equipment and material. contracts with off-site vendors are administered by the Engineering and Construction Department. Under the' inspection programs administered and conducted by the Engineering and Construction Department of off-site vendors for purchased materials, an inspection and test plan will be. prepared for purchased Code and safety-related procurements based on specified engineering requirements and the specific fabrication techniques and sequences to be used for such procurements. Approval of such a plan and approval as to,the quality requirements being satisfied is the'responsiblitty'of the Site Quality Assurance Superintendent and the Station Quality Assurance Superintendent, or designees, as applicable. Inspections may take l the form of source inspection, receiving inspection or both, depending on the nature, importance and quantity of the item (s) procured. Inspections will be performed to written procedures or checklists for inspections approved by Quality Assurance. Procurement documents shall_contain provisions for Edison's-right-of-access to vendors' and subvenders' facilities and records for source inspection and audit. The NSSS Supplier will conduct inspections on items procured under the NSSS contract. This does not preclude Edison inspections of those same items. 10-1 Rev. 57 12/01/89 l Commonwealth Edison

i j q The Edison Site and Station Quality Assurance Superintendent or designee, as applicable, will-assure that surveillance of contractors' j activities is performed in accordance with Quality Assurance approved surveillance procedures, and inspection and audit program and-checklists. Edison establishes inspection notification points, including i certain points designated by Quality Assurance which cannot be waived by Engineering and Construction without approval of Quality Assurance, which

• 55 will be witnessed by Edison, or its designated agent. The applicable l

Edison Site Quality Assurance Superintendent or Station Quality Assurance Superintendent, or designees will assure that required inspection of purchased items as required and determined by Engineering is carried out, that inspection procedures, instructions or checklists specify the j necessary measuring and test equipment including accuracy requirements, that contractor test procedures approved by Edison or the Architect Engineer are judiciously implemented and that procurement requirements are being fulfilled. In preparing an inspection notification point t . witnessing plan, Edison will take into account applicable codes, ' standards, specifications and-contractor quality control procedures.'The plan for each inspection will also identify, for example, the parameters to be checked, accept / reject criteria, equipment needed for the inspection or contractor documentation-to be reviewed. Inspections associated with normal operation of the plant such as routine maintenance, surveillance and tests on safety-related mechanical and electrical equipment and systems is followed by functional or operational 7 tests conducted in accordance with approved procedures by operations i personnel. Acceptance criterion must be met before the equipment is declared operational. Inspection and test plans shall be prepared by respective contractors, vendors or organizations having responsibility for.the item (s) involved, either as a separate document identified with the parts, components or assemblies; or as an integral _part of work instruction and procedure documents. Inspection and test plans shall consist of a flow chart, diagram or narrative ~ description of the sequence of procurement, fabrication, processing, assembly, inspection and test-activities and shall specify the inspection points. The criteria for selection of testing methods will be based on those needed to verify design requirements. Sampling inspection methods may be used when tests _are destructi.ve or when the quality records and the inherent inspection characteristics of the' item indicate-that a reduction in inspection or testing can be achieved without jeopardizing the assurance of quality. Sampling methods for Code items require prior approval of CECO or its representative as required by contract and approval shal1~be based on the use of a nationally recognized' sampling method. 10-2 Rev. 55 3/27/89 I Commonwealth Edison

~ s

11. TEST CONTROL Test programs will be established to assure that design and performance criteria have been satisfied..The test programs.

will include, as appropriate, procedures to evaluate structures,- systems, subsystems and components. The program will include, as applicable, proof tests prior to installation, construction, preoperation, and start-up tests as required for a new plant and operational tests, as well as those tests applicable involving and -following plant maintenance or modifications. Appropriate testing is performed and documented by. personnel quallfled and certified in accordance with procedures which shall meet the requirements of the ASME' Code and ANSI /ASME NOA-1 to assure'that applicable ASME Code and safety related structures, systems and components perform satisfactorily-in service. The test program will consist essentially of four testing stages: yendor Testing: Consists of source testing such as hydrostatic testing, seismic testing, performance testing and environmental testing as appropriate and as reflected in the specific procurement documents. ,for a given item or items. Approved written procedures will be required forLthese tests arid the-test results will be evaluated. For items procured-under the NSSS contract, the NSSS vendor will'act as Edison's agent in this regard subject to inspection and audit by Edison or its designated-agent. For non-NSSS items, the Architect Engineer may. participate with Edison Engineering.or act as-Edison's agent in approving test procedures and data. Construction Testino: Consists of on-site component testing such as hydrostatic testing, pressure proof testing, pump and valve testing, actuation to verify proper installation and electrical continuity verification. Written procedures or checklists will. be employed and the status 11-1 Rev. 57 12/01/89 Commonwealth Edison

J l- ~ \\ of equipment both before and after testing will be documented, j The various on-site service contractors will generally perform - 4 these tests. Control and management of the tests is the responsibility of the Construction Department Field Engineer.

• ss The Site.and Station Quality Assurance Superintendent or designee, as applicable, will be responsible for determining and assuring that proper calibrated inspection equipment is

.J utilized, that equipment.is properly released for testing, inspections.and tests are done under suitable environmental conditions, that data documentation is in compliance with 1 procedures and that retention control of test data documentation is adequate. The Authorized Nuclear Inspector shall be notified of all ASME Code hydrostatic or pneumatic tests prior to conducting them.to to permit his witnessing of such tests. Eteoptrational Testino: Consists of system performance tests performed prior to (or in tome cases, after) core Ioading and are performed on completed or essentially completed systems. Preoperational tests which~are performed on. critical Safety Category I equipment, are controlled by approved written procedures and are evaluated in accordance with the Edison-Quality Assurance Program. The Site Quality Assurance-Superintendent or designee will perform a final review of all equipment releases to assure that all-comments and exceptions have been resolved and will sign the release for equipment i turnover to operations. Also, Quality Assurance shall monitor such tests to assure they are performed properly and evaluated by the correct people. Preoperational Testing is performed by the contractor or Edison station operating personnel. Start-Un Testing: Consists of-those single.and multi-system tests beginning with fuel loading which are intended to-demonstrate.overall plant performance. These tests include the low-power physics tests and the power escalation testing j' operation will be conducted under a program having the same program. Those tests. essential to demonstration of safe requirements as the formal preoperational tests, Non-safety-related-testing, if performed, will be controlled in .a manner similar to component demonstration tests. Start-up tests will be performed by station operating personnel. 11-2 Rev. 55 3/27/89 Commonwealth Edison

^ i 1 l,o i 12.0 CONTROL OF MEASURING AND d l TEST EQUIPMENT 1 L [ / L 12.1 GENERAL ] l Measuring and test equipment which is used to determine j the acceptability of materials, parts, components, fabricated items, and completed construction assemblies, and to perform the l pre-operational testing and to ascertain the proper indications in the operation of generating station equipment will be periodically calibrated or adjusted and properly handled and stored to assure I that accuracy is maintained within necessary limits in order to verify design requirements. Such measuring and test equipment will be calibrated against standards in accordance with approved procedures having tolerance not greater than one-fourth the tolerance of the measuring and test equipment being calibrated. In situations where it is impractical to comply with the above, a standard of greater than one-fourth the tolerance but equal to or-closer than the tolerance of the measurement and test equipment described will be used with proper documentation and approval. Inspection, measuring and test equipment will be adjusted and calibrated using documented procedures at scheduled intervals against certified standards having known valid relationships to recognized standardsi Such procedures will provide criteria for determining the accuracy requirements of test equipment and crit 6ria for determining when a test is required or how and when testing activities are performed. Calibration intervals for items will be based upon the type of equipment, accuracy, use and other conditions affecting measurement control. Commonwealth Edison or its contractors and vendors, may l provide calibrations of measuring and' test equipment, or use the 1 services of an approved calibration laboratory. In either case, approved standard procedures will be used for calibration work. Standards will be maintained and used in an environment with temperature, humidity and cleanliness controls compatible with maintaining accuracy and operating characteristics of the standards. l History records for' measuring and test equipment will be l used to indicate calibration status, condition, correction to be L applied and repair events. As a minimum, these records shall l include, the equipment and Standard serial numbers, date of last I calibration, due date of next calibration, calibration data and results of as-found condition, repairs performed and, out of tolerance notification as required, and the procedure and revision utilized. 12-1 Rev. 57 12/01/89 l Commonwealth Edison

o Traceability records will be maintained in the System ?. Operational Analysis Department for nonradioactive certified standards to show that calibrations are traceable to recognized national standards. Also, records will be maintained in the System Operational Analysis Department for-company standards as well as calibration records for inspection, measuring and test equipment. If no national standards exist, the basis for calibration will be documented. Further, the construction site or station shall maintain necessary calibration records and status and identification tagging. Reputable commercial calibration laboratories shall be 1 employed when needed and their standards will be traceable to recognized national standards. 12.2 EOUIPMENT CONTRO1 The basic control measure employed for measuring and test

• SS equipment consists of periodic calibration using appropriate standards and documented procedures.

The control includes documentation and recording of calibrations, tagging or equivalent methods to show calibration status, and, when necessary, written . procedures for the use of equipment. For each piece of test and + measurement equipment, the date of last calibration, the calibration data, and the due date of next calibration shall accompany the piece

of equipment at the time of calibration and shall remain with the sequipment until the next calibration.

These items shall be identified by use of tags or stickers. Inspection and testing sequipment utilized for acceptance measurements shall be identified sby serial number as part of the documented inspection and testing. -data. When measuring and test equipment is found to be out of calibration, an evaluation shall be made and documented of the

validity of previous inspection or test results and of the j

acceptability of items previously inspected or tested. The Station-l Maintenance Department (or the Engineering and Construction

• SS Department) will be notified by an out of calibration report to the user for corrective action, and to QA for correction action verification. Written procedures appropriate to the item (s) of i

measuring and test equipment involved will be used to specify preoperations checks, environmental requirements, step-wise instructions for use, and instructions for shut-down and layaway. Suppliers and contractors to Commonwealth Edison Company are- . required to have and employ similiar appropriate control measures 1 which Commonwealth Edison Company will assure through surveillance, audit and approval of contractor procedures. The System Operational Analysis Department will be +55 responsible for calibration and maintenance of Commonwealth Edison Company measuring and test equipment. Assistance-in this activity' will be obtained from vendors or~ laboratories who have the necessary capabilities. 12-2 Rev. 55 i 3/27/89-i Commonwealth Edison

-j ~ The Master Instrument Hechanic is responsible for the calibration and control of station instrumentation and for the j accuracy of tools, gauges, instruments and other devices used in ) measuring and testing such instrumentation as well as documentation of such calibration and control. The Assistant Superintendent of Maintenance similarly is responsible for the calibration and control of tools, gauges and instruments used in maintenance activities. To maintain accuracy within necessary limits, the measuring and test equipment used in activities affecting quality is periodically. I calibrated and adjusted in accordance with Quality Procedures for j test equipment and system instrumentation. All pressure test gauges used in ASME pressure testing shall be calibrated against a standard dead weight tester or a calibrated master gauge prior to each test or series of tests. Charpy V Notch testing machines shall be calibrated at least once each year in accordance with ASTH-E-23-72 anc employing standard specimens obtained from the National Institute of Standards i and Technology (NIST) Gaithersburg, MD. The associated temperature instruments-shall be calibrated at least once in three month intervals or, when utilized with longer periods between use, such calibrations may be performed prior to being used. The Master Instrument Mechanic and Assistant Superintendent of Maintenance develop a master list of equipment to be calibrated. For each piece of equipment on the list, the Master Instrument Mechanic, Assistant Superintendent of Maintenance or System Operational Analysis er System Materials Analysis Departments or their contractors maintain the primary standards used in the calibration of the equipment; calibrate the equipment; maintain records traceable to the instruments, tools and gauges showing the date of the last calibration, the calibration data and the.due date of the next calibration; and provide records of calibration data for che station files. The Master Instrument Mechanic performs the instrument surveillance testing as required by the Technical Specifications to assure the accuracy of station process instrumentation in accordance i l with Instrumentation Procedures. 'i Instrumentation Procedures and documentation are 1 established per the Instrumentation Procedures of the Station Procedures Manual. 12-3 l Rev. 57 12/01/89 j i Commonwealth Edison

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15. NGNCONFORMING MATERIALS, PARTS OR COMPONENTS-AND OPERATIONS l

l L Items or conditions involving construction, maintenance l and modifications which are found nonconforming to the engineering ' requirements or specifications, drawings and instructions for I modifications or workmanship standards or which are lacking required documentation upon receipt will be controlled to prevent their inadvertent use or installation. Nonconforming items are + identified, documented E d segregated for disposition. The disposition of items that cannot be brought into conformance with design requirements will be determined after a technical disposition and justification. Technical disposition and justification.will be performed I by qualtfled personnel to determine whether a nonconforming item may be accepted "as-is" repaired to an acceptable condition, or whether the item must be rejected. Items =may be reworked to conform with design and/or specification requirements without l technical disposition and justification. When items are accepted "as-is," technical disposition and-justification will be performed to assure that the final condition of nonconforming items will not. adversely affect safety, Code requirements, operability or maintainability Of the items, or of the component or system in which it is installed. Where ASME Code requirements are involved, disposition acceptance by the Authorized Nuclear Inspector shall-be required. Nonconforming items accepted "as-is," or reworked to an acceptable condition shall be identified through documentation records and in a manner that will establish the condition as-installed. Where an item is in non-conformance with ASME Code requirements it shall not be dispositioned as "use-as-is". When the responsible Ceco personnel authorizes acceptance of the item "as-is," or rework of the nonconforming item, the action will be documented. Such action involving vendor product prior to shipment to the site.will be identified in shipping documents or certificates of conformance and reviewed and approved'by the Site Quality Assurance Superintendent or the Station Quality Assurante Superintendent or their designees to assure that nonconformance has been resolved and corrective action completed. 15-1 1 Rev. 57 12/01/89 Commonwealth Edison

m 1 w Rejected items shall be identified by tagging and I-immediately removed from construction or installation areas (unless physical size prohibits this) and segregated in a controlled area to prevent its-uncontrolled use or installation. 1 Commonwealth Edison Company will make a-technical evaluation of pertinent data relating to the nonconformity, including the cause, l where known, and corrective action either taken or planned to prevent recurrence. Also, items which are found to contain defects which i could create a substantial safety hazard will be reported in i accordance with the provisions of 10CFR Part 21 and as provided in implementing procedures. Construction deficiencies involving material or equipment are documented and reported to the Nuclear Regulatory Commission and

to Commonwealth executive management.

The Projects Construction

• 55 l

Superintendent or the Engineering and Construction Department Construction Superintendent, or designee, is responsible for this reporting. The Station Manager is responsible for investigating and reporting operating occurrences. An. Investigative Report is prepared for occurrences or departures from the safety limits -prescribed in the Station Technical Specifications. Occurrences and < departures from the safety limits are documented and reported to the -NRC as required by the Technical Specifications. The Station Manager appoints personnel to investigate the occurrence and issue an Investigative Report in accordance with the Technical Specifications and a Quality Procedure. This report is distributed to the Vice-Presidents (BNR and PHR Operations) and

• 55 Station Managers.

Reports of occurrences that result in significant damage or have significant safety implications are reviewed with the Vice President (BNR or PHR Operations), or his designee, and then '55 forwarded to other executive management. The appointed personnel are responsible for determining.the cause of the occurrence, developing recommendations intended to preclude recurrence and issuing a report which shall include: a detailed description of the occurrence, the findings and recommended measures for corrective action. When deviation from accepted normal operation of a reactor and its associated equipment occurs, or when a reactor scram occurs (other than those associated with a reportable occurrence), the Station Technical Staff investigates the deviation and issues a Deviation Repor.t covering the nature of the deviation (e.g., process difficulty, equipment inadequacy, procedure inadequacy), its cause, the hazard or potential hazard to operations and recommendations for corrective action. 15-2 Rev. 55 3/27/89 Commonwealth Edison

F-g. I The report documents the deviation and provides a record from which to establish a trend in the operation. Such reports are distributed 3 to the Vice Presidents (BHR and PHR Operations), the Production Superintendent, Technical Staff Supervisor, Nuclear Quality Programs Manager, and Manager of Quality Assurance / Nuclear Safety. -The . Assistant Superintendent of Maintenance and Master Instrument Mechanic receive a copy of the deviation report if maintenance or instrumentation work is involved in the correction of the deviation. Reports involving significant reactor safety considerations are reviewed with the cognizant Vice President (BHR and PHR Operations) and then forwarded to other executive management. Such deviations will be reported to the Nuclear Regulatory Commission as required by the Technical Specifications. During construction, the Projects Department Project Manager and, during plant modification, the Nuclear Engineering i Department Design Superintendent / Supervisor, has responsibility for resolution of CECO nonconformances and such resolution will be approved by the Site Quality Assurance Superintendent or designee at-i the construction site or by a Station Quality Assurance -Superintendent or-designee at the operating station. Nonconformance to system oper* son and technical specification requirements will be resolved through actions by the Production Superintendent with the approval of the Station Manager. 15-3 Rev. 57 12/01/89 i t i i Commonwealth Edison

+ A. 4 { ? -t 16.0 CORRECTIVE ACTION A corrective action system will be used to assure that such items as failures, malfunctions, deficiencies, deviations, defective material and equipment, nonconformances and programatic deficiencies which are_ adverse to quality and might affect the safe operation of a nuclear generating station are promptly identified and corrected. Corrective action measures for nonconformances are included in the design, source fabrication and on-site construc-tion, erection and operational phases. Corrective action measures involving design will be processed as design change requests. Corrective action. measures in the source fabrication phase are required in the quality assurance programs of individual vendors including the NSSS Supplier. For construction undertaken by Projects Engineering and

• 55 for modifications installed under the direction of Engineering and Construction, on-site corrective action measures shall. consist-of a program for: -(1) reporting nonconformances to Engineering by Construction; (2) recording nonconformance reports (NCR's) in a log for follow-up by Quality Assurance as to resolution and satisfactory completion; (3) prompt resolution and approval of corrective' actions by Engineering; (4) assurance by Construction that the corrective action has-been taken (5) sign-off approval and close-out of NCR's by Site Quality Assurance that' satisfactory-corrective action has been taken; and (6) issuance by-Engineering of monthly reports indicating the status of all NCR's submitted for resolution.

Implementation of corrective action will be accomplished at the source of deficiency by appropriate contractor personnel as found necessary by the contractors or as directed by cognizant Edison engineers. Projects Construction or Engineering and

• 55 Construction, as applicable, has responsibility for implementation of the correction. Quality Assurance is responsible for follow-up-and final approval that the nonconformances have been corrected satisfactorily.

For corrective action nonconformances, the Edison Site Quality Assurance Superintendent or designee will establish and maintain a Nonconformance Report (NCR) Station Log to monitor the prompt resolution and closing of all NCR's plus maintain a file of all NRC's or equivalent documents that are submitted by the site for CECO resolution and approval. l 16-1 Rev. 55 3/27/89 Commonwealth Edison

+ a0 / ). The cumulative monthly deviation report, which indicates the NCR number, deviation description and resolution, such as reject, replace, use-as-is or repair, approval status, date of resolution and whether corrective action is completed, is distributed to involved corporate and line management for l Information, review and possible action. The responsible manager l brings significant nonconformances to the attention of corporate j management for action where satisfactory resolution cannot be achieved by_ Engineering with a contractor. 1 for Operations, corrective action identified from nonconformances, incidents and deviations, trend studies and audits i are vertfled for satisfactory completion to preclude repetition. When corrective action is required to correct nonconformance to Code requirements, such corrective action shall be made available to the Authorized Nuclear Inspector. Any revision to Travelers or other process control documents involved with corrective action related to nonconformance for station modifications shall be reviewed with the Authorized Nuclear IInspector for his review and insertion of hold points'. The Technical Staff Supervisor verifles completion of ' corrective actions for maintenance, repair, refueling and operation ^ activities. The Station Quality Assurance Superintendents, or -designees, issue reports indicating the status of corrective action in progress. These reports are routed to the Vice Presidents (BNR and PHR Operations), the Nuclear Quality Programs Manager, and the Manager of Quality Assurance / Nuclear Safety and reviewed-to ensure prompt implementation of the corrective action. I-This system will provide follow-up to assure that corrective measures are effectively' implemented.. Also, significant conditions are reported by the responsible manager and nonconforming l items are routinely reported to appropriate _ levels of, management. Site contractors and off-site vendors will be required to ' follow-up on corrective' action commitments within their quality l I program. The Site Quality Assurance Superintendent or designee will be responsible for surveillance of site corrective action.' The Projects Department Project Manager is responsible for assuring that. review and evaluation of nonconformance reports are carried out to determine the need of corrective action. Quality Assurance is l ' responsible to track and verify completion of corrective action taken for audit deficiencies including programmatic deficiencies identified in audits. 16-2 Rev. 57 12/01/89 L Commonwealth Edison-

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17. QUALITY ASSURANCE RECORDS 1

Quality assurance records will be maintained either by I ! Edison or by an agent of Edison, under Edison's control. The 1 location, means of identification, duration of retention and means of retrieval will vary depending on the nature of the individual records. Quality assurance records will be stored in a predetermined location as necessary to meet the requirements of applicable standards, codes and regulatory agencies. The storage. location or facility shall be adequate for the maintenance, preservation and protection of the quality assurance record flies from the time of receipt untti their ultimate disposal-. Fabrication and construction authenticated documentation. is generated by contractors and vendors for. Commonwealth Edison Company, and will be available at the construction site or as directed by procurement documents. Required documentation is identified when records are stored at locations other than the site, a record will be maintained at the site to identify these records and their location 9e.g., NSSS equipment documentation).. Records generated during site construction, testing, operations and plant modifications will be available at the station as originals or reproduced copies. Upon completion of construction-records will be turned over to the station for retention for.the life of the plant or.otherwise required retention periods'provided. by Regulations or the ASME Code. Records are retained and maintained in accordance with a ' Quality Procedure to furnish evidence of activities affecting quality. The station quality assurance records are retained and maintained by the station personnel in accordance with written station procedures and regulatory and national Standard requirements. The methods of storage, preservation and safekeeping of the records are selected to minimize' damage, deterioration or loss. Quality assurance records are to be legible, indexed, identifiable, reproducible and retrievable as l well as complete and accurate as to material respects. -This l quality assurance records system shall include: a) a description of the storage facility; b) the filing system to be used; c) a method for verifying that the records received are in agreement with the transmittal document and that the records are legible; d).a method of verifying that the records are those designated; e) the rules governing access to and control of the files; f) a method for maintaining control and accountability for records removed from the storage facility; g) the method of filing supplemental information and disposing of superseded records. 17-1 Rev. 57 12/01/89 Commonwealth Edison

$a ',, y .These authenticated records include items which are related to the safe operation of the station; which document the as-built l ~ requirements of equipment and systems for use in maintaining, reworking, repairing or modifying station equipment; which can assist in determining the cause of a malfunction of an item that provides protection to the health and safety of the public; and which provide inspection data for in-service inspection. The lifetime quality assurance records, including audit reports are those continually maintained for the operating life of particular ASME Code and safety-related item or component while it is installed in the Station or stored for future use. Records to be mkept as required for the life of the plant shall be designated. For ASME ltems, lifetime and nonpermanent records shall be maintained as provided by Section III of the ASME Code. The Nuclear Quality Programs Manager will be responsible for assuring that records are retained by-Construction during engineering and construction. Following start-up, the Station Manager will be responsible for the retention of station operating, ' maintenance and modification records for the life of the plant or for the period of time established by Commonwealth Edison Company Procedures, t Quality records will be received, evaluated, stored and retrievable. The certified design specification and a copy of acceptance

verification for the design reports for safety-related and ASME

'Section III Division 1 items.and the certified design and

construction specifications, and certified design and construction l

-reports for ASME Division-2,-concrete containment, will become part t of the permanent records file to be retained for the life of the ettem or the life of the plant, at the plant site,_the manufacturing plant, the Architect Engineer or other designated locations. Files shall be maintained current, complete and available for audit by Commonwealth Edison Company or its agents, the Nuclear Regulatory Commission and the Authorized Nuclear Inspector at any reasonable time during the retention period. Contractors and suppliers shall retain their quality records as required by applicable codes, standards and contract requirements. At the end cof the required retention period, the contractor or supplier shall transfer these records to the Commonwealth Edison Company Projects ' Construction Superintendent or Engineering and Construct 1on LCanstruction Superintendent or designee for transfer to the Station Manager or filing for the life of the plant. In no case will the . file be destroyed by the contractor or vendor without written instruction by Commonwealth Edison. 17-2 Rev. 55 03/27/89 Commonwealth Edison i

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18. AUDITS Audits will be performed by Commonwealth Edison Company and/or its vendors and sub-vendors to verify the implementation

• s6 and effectiveness of quality programs under their cognizance.

The number and experience of persons participating in audits will vary according to the nature and significance of the audit. Audits under the responsibility of the Nuclear Quality Programs Manager and the Superintendent of Off-Site Audits will cover-quality systems for engineering, construction, operations,

• ss

} modifications, maintenance, in-service inspection and Stores activities. Audits will be performed to evaluate the implementation of the quality assurance programs, the adherence to procedures and controls and the fulfillment of requirements. Certifications:and records will also be evaluated. Product audits assess the effectiveness of in-progress work, inspections and tests that are specific to the fabrication, installation, y construction,, testing and operation of an item. M The performance and compliance of each operating station to the Quality Assurance Program is assured through review surveillance and audit of operations by the Quality Assurance Engineers or Inspectors under the direction of the Station Quality Assurance Superintendent, who is responsible through review, surveillance and audit of operating, maintenance, modifications. Stores and in-service inspection activities by Quality Assurance Engineers or Inspectors to the Nuclear Quality Programs Manager and the Superintendent of Off-Site Audits. Audits are performed to audit schedules which are approved by the Manager of Quality Assurance / Nuclear Safety. These schedules include the minimum audits required. Other audits will be performed as directed by-Quality Assurance supervision. The Audit Team Leader's auditing organization shall

• s6 develop and document an audit plan for each audit.

This plan shall identify the audit scope, requirements, audit personnel,. activities to be audited,4 organizations to be notified, applicable documents, schedule, and. written procedures or checklists.. Audits will be conducted using checklists or an agenda approved by trained, qualified and responsible Quality Assurance supervisory personnel and will be' conducted with sufficient authority and organizational freedom to evaluate compliance with all applicable aspects of the Quality Assurance Program and specified requirements _ Audits will be initiated early to assure effective quality assurance during design, procurement, manufacturing, 18-1 Rev. 56 9/13/89 Commonwealth Edison V

{ -construction and installation, inspection and test and be performed o-efficiently in order to achieve a minimum of interference with work O in progress and alnimua disruption of organizations being audited. ,,. h An audit plan will be maintained in order to schedule audits of site ), vendors. Audits of off-site vendors generally will be conducted in conjunction with plant visits for witnessing inspection points by a quallfled Audit Team Leader. Also, periodically Quality Assurance will participate in such audits or perform independent audits to assure effectiveness of the program, compliance to the program and fulfillment of procurement requirements. The elements in the quality program, in procurement docu-ments and in related codes and standards, are subject to systems audits. Also, items received, fabricated and constructed or installed for use by Commonwealth Edison Company in its nuclear power plants are subject to audits. Audits will be performed selectively at various stages of contracts on a varying frequency, based on the nature and safety significance of the work being done to verify compliance and determine the effectiveness of procedures, inspections, tests, process controls and documentation. For Code materials, when a Material Manufacturer or Material Supplier, as applicable, does not hold a Quality System Certificate (Materials), the CECO audit frequency shall be.at least once annually during the interval in 'which CECO purchased material is being controlled by the Material ' Manufacturer or Material Supplier. In addition to these audits, . Quality Assurance will conduct approximately annually, overall (system audits of the NSSS vendor, the Architect Engineer, site

contractors, vendors of services, and involved Edison Departments.

(Audits of CECO are also performed by the Authorized Inspection ' Agency as required by the ANSI N-626 series of Standards. Commonwealth Edison Company's active participation in joint ? utility audit programs provides an alternative means to fulfilling ' CECO's responsibility of auditing active vendors. To accomplish Lthis task, the completed joint utility audit report will be reviewed ,by the QA/NS Off-Site Audit staff for adequacy and compliance to CECO and regulatory requirements and for applicability and adherence to CECO specifications. Results of the QA/NS review and a copy of said audit report will be distributed internally to designated ~ personnel. Audits of CECO are also performed by the Authorized Inspection Agency as required by ASME/ ANSI-N626 Standard. For operating stations, periodic Quality Assurance audits will 'be performed to verify compliance with, and the effectiveness of, j the program. Audits covering operating will be performed in-accordance with the Technical Specifications under the direction and responsibility of the Nuclear Quality Programs Manager and the Superintendent of Off-Site Audits, as applicable, independent of the Production Department. Surveillance, review and audits covering maintenance, modifications, in-service inspection and Stores activities performed by the station organizations will-be performed under the direction and responsibility of the Nuclear Quality i Programs Manager and the Superintendent of Off-Site Audits, as applicable, where maintenance and modifications are performed by vendors or other organizations under the direction of the Engineering and Construction Department for the stations. Audit-results and recommendations of corrective action will be documented and reviewed with the management of the Station. Deficiencies 4 18-2 $U0lN9

^l {-l requiring prompt corrective action are reported immediately to { management of the audited organization. Verification of the completion of corrective action reconnended in audit reports.will be performed by the Technical Staff Supervisor or Quality Control 1 j Supervisor. Follow-up of open station items is tracked by the Action Item Records'(AIR) System. Where an audit item is placed under the AIR system for tracking completion, approval as to satisfactory completion of corrective action shall be obtained from ) the responsible station Quellty Assurance Engineer or Inspector. Audits will be established and conducted by qualified personnel who are familiar with written procedures, standards and processes appilcable to the area being audited, but who do not have direct responsibilities in the areas being audited. An audit report shall'be written for each audit. An audit l' report package consisting of Summary Sheet, Attachment Sheet, Checklists or Agenda and any additional pertinent details recorded on additional sheets necessary to support a finding (s) will be on i flie. The audit report will be reviewed, signed, and dated by the 1 Audit Team t.eader. The audit shall be reviewed for acceptability by i a supervisor. The audit report shall be sent, as applicable, to the V President, Senior Vice President (Nuclear Operations), Manager of Engineering and Construction, the Nuclear Engineering Manager, Manager of Quality Assurance / Nuclear Safety and Superintendent of Off-Site Audits, Assistant Vice President (Quality Programs and Assessment) and the Nuclear' Quality Programs Manager, and'the Vice Presidents (BWR and PWR Operations) for management review and-action. The above stated system audits are also sent to the Chairman and CEO and the President and Chief Operating Officer for review and evaluation and action as deemed necessary by the Manager of Quality Assurance / Nuclear Safety. Also, monthly to bi-monthly periodic reports on quality assurance activities are submitted to top management. Such reports, in part, provide bases for-periodic top management reviews and discussions of quality assurance t activities, implementation status and effectiveness. Such reviews and discussions are held by the Chairman and President with the Manager of Quality Assurance / Nuclear Safety and with other i executives. Audtts shall be scheduled and follow-up review of deficient areas or adverse conditions and follow-up on corrective' action commitments shall be performed by Quality Assurance to assure effective corrective action and implementation have been carried out. Deficiencies in the execution or implementation of t corrective action will be brought to the attention of the person who is responsib1'e in the area involved. Continued deficiencies, or failure to implement corrective action will be reported in writing by Quality Assurance to appropriate executives within Commonwealth 3 l Edison Company. 1 i 18-3 Rev. 56 denunonwealth Edison } s

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