ML20024H421
| ML20024H421 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 05/28/1991 |
| From: | Shelton D CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9106030330 | |
| Download: ML20024H421 (6) | |
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I CENTERIOR ENERGY Donald C. Shehon 300 Masson Avenue Vce PresKbol Nuclear Toledo OH 436520001 Davts B sse (419)249 2300 Docket Number 50-346 License Number NPF-3 Serial Number 1-950 May 28, 1991 United States h!aclear Regulatory Commission Document Con.rol Desk Vashington, D. C.
20555 Subj ec t :
Review of the Revision to the Procnrement Document Review Pincess Gentlemen:
The Toledo Edison Company hereby submits, pursuant to 10 CFR 50.54(a)(3).
Its plans regarding the replacement o' the Engineering Assurance in-1ine quality review of procurement documents with an additional and separate Procurement Engineering technical and quality review at the Davir Jer
- Nuclear Power Station, Unit Number 1.
This change establishes gieatei day-to-day accountability with the technical unit for qual.ity work while returning the assurance role to a more appropriate periodle overviewer.
These changes, as indicated in the attached 10 CFR 50.54(a) reviev, have been identified as a reduction to the ecmmitments identified in USAR Chaptet 17.2, Quality Assurance Program for Station Operation.
Although thene changes have beer. identified as a reduction in commitment, the Ouality Assurance Program continues to satisfy the criteria of 10 CFR 50, Appendix B.
If you have any questions concerning this matter, please call Mr. R. V. Schrauder, Manager - Nuclear Licensing, at (419) 249-2366.
Very truly yours, (o
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'n o 38 JC' ach os o CM A t t achn.en t ou Mo cc:
P. H. Byron, DB-1 NRC Senior Resident Inspector o
A. B. Davis, Regional Administrator, NRC Region III
$cc J. B. liopkins, NRC/NRR DB-1 Seniot Project Manager Q
Utility Radiological Safety P, nard oceeng compantes 0
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TABLE OF CONTENTS I
PROCUREMENT DOCUMENT REVIEV 0F PROCESS REVISION Attachment, page 1 Davis-Besse Unit 1 USAR Section 17.2, page 17.2-23
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Attachment, paFe 2 Proposed revision to procurement document review as described on USAR page 17,2-23 Attachment, page 3 10CFR50.54 review L
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DB Attachment, Page 1 f.
Identification of documents to be preparod, maintained. submitted, or made available for review and/or approval, such as drawings, specifications, procedures, sub-supplier procurement documents, manufacturing and inspection plans, inspection and test records, personnel and procedure qualifications, and material cl.emical and physical test results.
g.
Provisions for Toledo Edison's right-of-access to the suppliers' facilities and records for audits and source inspection.
h.
Requirement for reporting and approval for disposition of nonconform-ing items and adherence to 10CFR21 requirements.
Nuclear fuel is procured through the use of formal contracts signed by an 5
officer of the Toledo Edison Company. An individual has been designated by 5
the Plant Manager as the " Fuel Custodian" and acts in the capacity of the 5
Procurement Manager for the procurement of nuclear fuel.
8 A
l5 17.2.4.3 Procurement Document Reviev m"/\\'
- P rooveement-deeument-e -are-rev4ewed-a e--e-minitmar., by t-he-eesponsible-engineerin1;--
9 eeetien-and-Engineet4ng-Assueenee-prieede-being-aweeded40 - a aupp44etv The 9
Quality Assurance Department will also review selected procurement documents 9
including those that require source inspection or unique receipt inspection 9
activities. Changes to the technical and quality requirements, including 9
supplier selection, are subject to the same degree of review as the original 5
5 Review and approval by the Engineering Department assures that the technical 10 and quality requirements are sufficient, clear and adequately stated: can be 5
inspected and controlled and include adequate accept / reject criteria.
These 5
requirements include regulatory, administrative and reporting requirements:
5 specifications; codes and industrial standards; test and inspection require-5 and special process instructions that must be complied with by suppliers.
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- ments,
.f.n.>etk e ge-
% r e r ice c endue-ted4y - t h e Enginee r4ng-Assu ranse-Sest4on r--and -where-*ppl4eeMer 10 4
the Quality Assurance-Department is pei-formed te atsure-that qua-lity 8
-tequieemente-asc s u f f i elenty -el-ear-e nd-e dequa+el y-eta tedt-in a p e c t a b i1 i t y 5
requirements are satisfied; hold or witness points are adequate:
5 accept / reject criteria are included: the checklist prepared by the 8
Engineering Department la included that describes the characteristics 5
to be inspected at receiving inspection: and that the supplier is 5
l included on a listing of approved vendors.
5 17.2.4.4 Supplier Selection l
Prior to award, potential suppliers are evaluated to determine their ability I
to supply items or services in accordance with the requirements of pro-5 curement documents.
The evaluation also includen 5 ted.uacal evaluation, which may include direct evaluation of the suppliers; facilities and personnel as described in 17.2.7.
17.2-23 REV 10 1/90
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Attachment Page 2 17.2.4,3 Procurement Document Review Insert A Procurement documents are prepared by a procurement engineer and reviewed by.
a separate engineer knowledgeable of technical and quality requirements prior to supervisor approval and award to a supplier.
Insert _B The multiple reviews conducted by Engineering and where applicable, the Quality Assurance Department are performed to assure that quality requirements are sufficient, clear and adequately stated; t
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Attachment, Page 3 i
10CFR50.54 PEVIEV MAY 15, 1991 PROPOSED REPLACEMLNT OF THE ENGINEERING ASSURANCP. DAY-TO-DAY (IN-LINE) QUAI.ITY REVIEV 0F PROCUREMFRr DOCUMIRl'S VITil AN ADDITIONAL AND SEPARATE PROCUREMPRT ENGINEERING TEcliNICAL AND QUALITY HEVIEV CHANGE NUMBER 1 Paragraph 17.2.4.3, PROCUREMENT DOCUMENT REVIEV. pne 17.2-23.
Description of Change 2.1 Change first sentence in first paragr'aph, " Procurement documents are reviewed..." to " Procurement documents are prepared by a procurement engineer and reviewed by a separate engineer knowledgeable of technical ar.d quality requirements prior to supervisor approval and avard to a supplier."
2.2 Change first sentence in the third paragraph, "The review conducted by..."
to "The multiple reviews conducted by Engineering, and where applicable the Quality Assurance Department, are performed to assure...".
Reason for Change _1 Pursuant to current commitments as identified in USAR Chapter 17.2, Engineering Assurance has been performing a quality review of Nuclear Safety Related (NSR),
ASME and Fire Protection procurement documents.
These commitments were described in the FSAR and restated in references 1, 2 and 3.
During the course of these reviews, numerous procurement procedural upgrades have been promulgated to better control this process.
Key among these changes has been the establishment of a separate Engineering revitv for technical and quality requirements within the Design Engineering Procurement Unit.
During the period from March 1989 through 1990, trend data on the number of unsatisfactory procurement documents has gone from 17 percent to less than 1 percent.
A level of 2 percent or less has been consistently maintained by the Engineering Procurement Unit since July 1990.
Engineering Assurance has analyzed the recent comments. These comments are generally of an administrative nature, which would not result in the ultimate installation of non-conforming material / equipment.
Engineering Assurance's procurement document review effort is now considered to be an unnecessary third level of reviev which can be replaced by the above additional Engineering review.
The cut rent Engineering Assurance responsibili ties for perf orming in-line quality reviews of procurement documents were established under a letter from Mr. D. C. Shelton to the NRC dated October 21, 1988 (Serial Number 1604).
NRC approval of the transfer of responsibilities for quality reviews from the Quality Assurance Department to the Engineering Department was received via letter in November 1988. This proposed change retains the existing commitments for performing quality procurement document reviews consistent with
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Attachment, Page 4 Davis-Besse's original and continuing commitment to ANU N.45.7.11 The proposed change simply transfers the Engineeting Assurr.nce quality review responsibilities to a proceduralized, additional and separate Design Engineering Procurement reviewer. This establishes greater day-tc-day accountability with the technical unit for quali:v vork while returning the assurance role to a more appropriate periodic overviewer.
Engineering Assurance vill continue to supplement Quality Assurance Department's 10CFR50, Appendix B surveillance and audits with periodic assessments of Procurement Engineering documents.
Effect of Change on the Davis-Besse USAR-Cp ptir 17.2 09ality Assurance Program Description Commitments This change reduces the Quality Assurance Program description commitments previously accepted by the NRC.
The proposed change is a change to a quality assurance program description contained in docketed correspondence.
A letter i
from Mr. D. C. Shelton to the NRC dated October 21, 1988 (Serial Number 1604),
l requested NRC approval of the reorganization of the Engineering Assurance function from the Quality Assurance Department to the Engineering Department.
This letter stated the new Engineering Assurance organization vould assume from the Quality Assurance Department the day-to-day quality review of procurement documents. This letter did not, in any way, change Quality Assurance Department functional responsibilities as defined in 10CFR50, Appendix A Criterion I.
Since this proposed change eliminates Engineering Assurance's commitment to perform day-to-day quality reviews of procurement documents, it represents a reduction in commitment. NRC approval is required prior to implementing the proposed change.
The basis for concluding that this change continues to satisfy the criteria of 10CFRSO Appendix B and the Safety Analysis Report quality assurance program description commitments previously accepted by the NRC is as follows:
The proposed change does not affeet the assignment of quality assurance functions as defined in 10CFR50, Appendix A Criterion I.
The Quality Assurance Department retains complete responsibility for assuring that a quality assurance program is established and effectively executed, and for verifying (i.e., by audit, surveillance, or inspection)_that activities affecting the safety-related functions have been correctly performed.
Procurement Engineering activities have and continue to be subject to audit and surveillance by the Quality 1.ssurance Department.
Though the subject change represents a reduction in commitment, it does not affect Davis-Besse's 10CFR50, Appendix B program commitments and continues to meet the requirements of ANSI N45.2.13.
References:
- 1. Serial 1000, Response to Generic Letter 83-28, Required Actions Based on Generic Implications of Salem ATVS, dated November 7, 1983.
- 2. Serial 1182, Davis-Besse Course of Action, dated January 3, l
1986.
- 3. Serial 1604, Reorganization of Davis-Besse Engineering Assurance l
from the Quality Assurance Department, dated October 21, 1988.
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