ML20043H529
| ML20043H529 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 06/14/1990 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9006260067 | |
| Download: ML20043H529 (18) | |
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e TOLEDO EDISON A Coww Enrgv Ctngeny DONALD C. SHE00N
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Docket Number 50-346 License Number NPF-3 Serial Number 1-922
~ June 14, 1990 h
United States Nuclear Regulatory Commission
~
Document Control Desk Vashington, D. C.
20555
Subject:
10CFR50.54(a) Review of the Reorganization of the Engineering Assurance / Engineering Programs Section Gentlement Tlie Toledo Edison Company hereby submits, pursuant to 10CFR50.54(a)(3), its plans regarding the reorganization and combining of Engineering Services and the Engineering Assurance / Engineering Programs Section at the Davis-Besse i
Nuclear Power' Station, Unit Number 1.
These changes, as indicated in the attached 10CFR50.54(a) review, have been identified as a reduction to the commitments identified in USAR Chapter 17.2, Quality Assurance Program For Station Operation.
Although these changes have been identified as a reduction in commitment, the OA Program continues to satisfy the criteria of 10CFR50, Appendix B.
If you have any questions concerning this matter, please call Mr. R. V. Schrauder, Manager - Nuclear Licensing, at (419) 249-2366.
Very trul yours,
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cci A. B. Davis, Regional Administrator NRC Reg. ion III Senior Resident Inspector T. V. Vambach, DB-1 NRC Project Manager M. P. Phillips, Chief Operational Programs Section, NRC Region III h
9006260067 900614 PDR ADOCK 05000346 rh A
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THE TOLEDO EDISON COMPANY EOISON PLAZA 300 MADISON AVENUE TOLEDO, OHIO 43652 u
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MANAGER - FERFORMANCE ENGINEERING. Manages the activities of the Davis lesse Ferformance Engineering Section to provide direct day-to day engineering j
support of the Davis-lesse Nuclear Power Station in the areas of plant thermal performance monitoring, the Inservice Inspection Program and testing, plant computer systems performance. reactor refueling. core physics testing and operations, fuel performance plant operations assessment, modification testing and special testing. preventive / predictive maintenance, transient assessment and review of all external information (INFO. NOMIS. Network)
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in support of improved performance and reliability and special engineering projects.
1 MANAGER - SYSTEMS ENGINEERING.
Responsible for performing the engineering activities related to the analysis, design. procureatnt, construction.
testing, operating, and maintenance / modification of the assigned systems.
MANAGER - NUCLEAR ENGINEERING. Manages and coordinates department functions g,Ulm related to Reliability and Risk Assessment. Nuclear Reactor Analysis, wb 'Inserf Nuclear Safety Analysis, and Simulator Engineering.
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MANAGER - ENGINEERING ASSURANCE / ENGINEERING PROGRAMS. Manages and l
coordinates programs related to Engineering Assurance and review of engineering related activities on a day to day basis. These activities include review of procurement documents, engineering specifications, and monitoring of work packages to assure that appropriate quality requirements are being specified and adhered to in the design and procurement process.
He is also responsible for participating in the development of procedures governing engineering work to ensure their adequacy. and for conduct of in-depth technical evaluations to asses, the technical adequacy of engineering products.
Also manages development of a Chemistry / Radiochemistry Improvement Program and overview of the Engineering Training Program.
SUPERVISOR - FIRE PROTECTION COMPLIANCE. Reports to the Manager - Systems Engineering and is responsible for the formulation, implementation, and periodical assessment of the effectiveness of the Fire Protection Program.
I 13.1.2.3 Technical Services Deoartment DIRECTOR - TECHNICAL SERVICES.
Reports to the Vice President - Nuclear and L
directs and coordinates activities pertaining to Nuclear Licensing. Nuclear Training and Emergency Preparedness. Environmental Compliance, and Industrial Safety and Hygiene.
HANAGER - NUCLEAR LICENSING.
Directs and coordinates the section's activities in obtaining, maintaining, and revising licenses and permits required for the operation of the DSNPS, and coordinates any activities directly involving the NRC.
MANAGER - NUCLEAR TRAINING. Manages the Company Nuclear Training Program.
l including establishing training programs, courses, supervising course presentation, and evaluating training effectiveness.
13.1 6 REV 9 7/89
','p:go.2 INSgRT A MANAGER - ENGINEERING ASSURANCE / ENGINEERING ~ SERVICES The Manager - Engineering Assurance / Engineering Services reports directly to the Director - DB-Engineering and is responsible'for; managing: the independent quality review of procurement documents, engineering specifications, and plant modifications: Engineering Department self-assessment activities review and evaluation of plant chemistry and radiochemistry issues; and Engineering support services such as design' process control, budget administration, procedure control and administration, engineering training, and vendor document processing.
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TOLEDOE0!$0N DAvlS SESSE NUCLEAR POWER STATION OROANIZAT!ON k
CHART FICURE 13.1 1 REvlSION 9, nu 1989
Attacharnt 1 pcg2 4 D-B DIRECTOR - DB ENGINEERING l9 The Director. Engineering reports directly to the Vice President.
9 Nuclear, and is responsible for all Toledo Edison and contracted engineer.
1 Re f ne, ing activity in support of design control, plant modifications.-and system i
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performance requirements for the Davis-Besse Nuclear Power Station.
1 Inse.rI MANAGER - ENGINEERING ASSURANCE / ENGINEERING FROGRAMS l9 6
The Hanager - Engineering Assurance / Engineering Programs reports directly to 9
the Director - DB Engineering and is responsible for managing the engineering 9
section in the review of engineering activities on a day to day basis.
9 These activities include review of Nuclear Safety Related (NSR) procurement 10 documents, engineering specifications, and monitoring of work packages to assure 9
that appropriate quality requirements are being specified and adhered to in the 9
design and procurement process.
The responsibility also includes participating 9
in the development'of procedures governing engineering work to ensure adequacy 9
and for conducting in-depth technical evaluations to assess the technical 9
adequacy of engineering products.
Also manages development of a 9
Chemistry /r:adiochemistry Improvement Program and overview of the a
engineering training program.
9 MANAGER - NUCLEAR ENGINEERING l10 The Manager. Nuclear Engineering reports to the Director - DB Engineering 9
and is responsible for managing and coordinating department function 9
relating to reliability and risk assessment, nuclear reactor analy.
1 sis, nuclear safety analysis, and simulator engineering.
9 MANAGER - DESIGN ENGINEERING l9 The Manager - Design Engineering reports to the Director - Dr Engineering 9
and is responsible for directing and managing the performance of engineer.
1 ing, safety evaluations, and accident analyses relative to modifications 1
1 for Davis-Besse to assure optimum safety, availability, and reliability.
1 11a also provides engineering support to address non-routine technical 1
issues related to the operation and maintenance of Davis.Besse.
1 MANAGER SYSTEMS ENGINEERING l9 The Manager - System Engineering reports to the Director. DB Engineering 9
i and is responsible for minimizing Davis-Besse forced outage and lost I
capacity by providing systems engineering services to ensure proper 1
installation, operation, maintenance, testing, and problem resolution 1
for optimum system performance and reliability.
1 MANAGER - PERFORMANCE ENGIMEERING l9 The Manager - Performance Engineering reports to the Director - DB Engineering 9
and is responsible for directing the activities of the Performance 9
Engineering Section to provide direct day-to day engineering support 8
in the areas of plent thermal performance monitoring, inservice inspection 5
l 17'2 B QS&l@
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.. Page 5 INSERT B MANAGER - ENGINEERING ASSURANCE / ENGINEERING SERVICES The Manager - Engineering Assurance / Engineering Services reports directly to the Director - DB Engineering and is responsible for managing the independent quality review of procurement documents, engineering specifications, and plant modifications. Engineering Department self-assessment activities; review and evaluation of plant chemistry and radiochemistry issues and Engineering support services such as design process control, budget administration, procedure control and administration, engineering training, and vendor document processing.
,.. pago 6 and testing p1 Cst computer systems perfomance, reactor refueling.
5 core physics testing and operations, fuel performance. plant operations 3
assessment, modification testing and special testing. preventive / predictive S
maintenance. ' transient assessment and review of all esternal information 5
(INP0. NOMIS.. Network) in support of improved performance and reliability i
and special engineering projects.
5
$UPERVISOR. FIRE PROTECTION COMPI,1ANCE l9 The Supervisor. Fire Protection compliance reports to the Manager. systems 9
[
Engineering and is responsible for the formulation. implementation. and 8
periodical assessment of the effectiveness of the Fire Protection Program.
8 i
CENERA1, SUPERv!SOR - ENGINEERING SERVICES g
i The General Supervisor. Engineering Services reports to the Director.
Engineering and is responsible for overall support services for the Engineering Department.
This includes design process control. budget development, cost accounting analysis, procurement activity analyses.
I engineering training, and correspondence and cosmitment control.
j 4 59:5 so6 PARAGMf'W I4 iTS F.r4Ti RETT, l
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pags 7 D-B be performed under the most adverse design conditions as deteruined by analysis.
'Jhen alternate calculaticns are performed to verify the correctness of the original calculations, they include provisions for verifying the appropriateness of assumptions, input data, and code or other calculation 5
method used.
The alternate method when used is required to provide results which are consistent with the original calculation or analysis.
17.2.3.5 Design Package Review Prior to release. the completed design package is reviewed by Nuclear 5
Group Departments affected by the design. All review cossments are document.
6 ed and resolved, and in addition, analysed for potential impact on safety 5
evaluations and design verifications.
Nuclear Safety Related NSR) design 10 package develooment is also monitored on a day to day basis by e Engineering 10 Assurance Eectiolhto ensure the adequacy of engineering documents released for 9
implementation. N 9
hnhntetinf tthtt2 Selected design modifications, documented by one or more design packages, are 9
subjected to design evaluations under the direction of the Engineering Assurance ^
9 Manager to assess the effectiveness of the design process and the technical 9
adequac gof design products.
Design evaluations are conducted by Engineering 10 Assurance GectioTDpersonnel supplemented as necessary by engineering personnel 9
having technical expertise in the areas to be evaluated.
Participating 9
engineering personnel will not have responsibility for the design products to 9
be evaluated, and their selection from within Toledo Editen or as contractors.
9
.is approved by the Engineering Assurance'Hanager.
In addition to correcting 9
identified deficiencies, significant or recurring deficiencies are processed 9
in accordance with Section 17.2.16.
9
/Eng *neerg Se,-v / car 5
17.2.4 PROCUREMENT DOCUMENT CONTROL 5
5 7.2.4.1 General 5
The procurement of materials, components, equipment, consumables, spare 5
and replacement parts, services, etc., necessary for plant operation.
5 refueling, maintenance, and modification are controlled in accordance with 5
procedures established by Procurement, the Engineering Department. Opera-e tions. Quality Assurance and Haterials Management.
These procedures 5
specify measures that describe the process for the preparation and control
- 5 of procurement documents, control of supplier and contractor performance.
5 source evaluation and selection, source verification, receiving inspection 5
and testing, and item or service acceptance.
The requirements of ANSI 5
N45.2.13 and ANSI N45.2.2 are incorporated into their procedures whenever 5
the requirements are applicable.
5 Expeditious procurement activities are defined in procedures to support 10 unanticipated requirements. These procedures contain provisions for material 10 traceability and controls to prevent the declaration of operability of the 5
system until such time that the activity and documentation requirements 5
specified in the approved procurement document have been completed or 5
evaluated by the Engineering Department for operability.
8 i
The procurement of spare or replacement parts for structures, systems and 5
components within the scope of the Nuclear Quality Assurance Program are subject to requirements equal to or greater than the original requirements.
17.2 11
. page 8 D.B f.
Identification of documents to be prepared, maintained. submitted, or made available for review and/or approval, such as drawings, specifications, procedures, tub-supplier procurement documents, manufacturing and inspection plans. inspectica and test records, personnel and procedare qualifications, and material chemical and physical test results.
5 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 10CyR21 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 l5 17.2.4.3 Procurement Document Reviev Procurement documents are reviewed as a minimum by the responsible engineering 9
section and Engineering Assurance prior to being awarded to a supplier.
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
.ments, and special process instructions that must be complied with by suppliers.
5 The review conducted by Engineering Assurance Emet
- n. and where applicable.
10 the Quality Assurance Department is performed to assure that quality 8
requirements are sufficient, clear and. adequately stated: inspectability 5
requirements are satisfied hold or witness points are adequate:
5 accept / reject criteria are included: the checklist prepared by the 8
Engineering Department is included that describes the characteristics 5
to be inspected at receiving inspections and that the supplier is 5
included on a listing of approved vendors.
5 17.2.4.4 Supplier Selection Prior to award, potential suppliers are evaluated to determine their ability to supply items or services in accordance with the requirements of pro.
curement documents.
The evaluation also includes a techr.ical evaluation, which may include direct evaluation of the suppliers: facilities and personnel as described in 17.2.7.
17.2 23...
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i FIGURE 17.2 1 REVISION 9. JULY 11
.-, page 1 10CPR50.54 REVIEV June 8, 1990 PROPOSED REORGANIZATION OF ENGINEERING ASSURANCE AND ENGINEERING SERVICES CilANGE NUMBER 1 Paragraph 17.2.1, ORGANIZATION, page 17.2-8, subparagraph entitled KANAGER -
ENGINEERING ASSURANCE / ENGINEERING PROGRAMS De'scription of Change
- 1. Changed heading " MANAGER - ENGINEERING ASSURANCE / ENGINEERING PROGRAMS" to
" MANAGER - ENGINEERING ASSURANCE / ENGINEERING SERVICES".
- 2. Changed, in first sentence, " Engineering Assurance / Engineering Programa" to
" Engineering Assurance / Engineering Services".
- 3. Changed, in the description of the Engineering Assurance function, the following:
3.1 " managing the engineering section in the review of engineering activities on a day to day basis. These activities include review of Nuclear Safety Related (NSR) procurement documents, engineering l
specifications, and monitoring of work packages to assure that l
appropriate quality requirements are being specified and adhered to in the design and procurement process." to " managing the independent quality review of specific procurement documents, engineering l
specifications, and plant modifications,".
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3.2 "The responsibility also includes participating in the development of procedures governing engineering work to ensure their adequary, and for conducting in-depth technical evaluations to assess the technical eiequacy of engineering products. Also manages development of a Chemistry / Radiochemistry Improvement Program and overview of the engineering training program." to " Engineering Department self-assessment activities, review and evaluation of plant chemistry and radiochemistry issues,".
- 4. Hoved the description of the Engineering Services function from the subparagraph previously entitled " GENERAL SUPERVISOR - ENGINEERING SERVICES" (s ee Change Number 2 for deletion of previous description of this 1
function).
- 5. Deleted, frim the description of the Engineering services function, "The L
General Supervisor - Engineering Servicer reports directly to the Director L
- Engineering".
l
- 6. Changed, in the description of the Engineering Services function, "and is responsible for overall support services for the Engineering Department.
This includes design process control, budget development, cost accounting analysis, procurement activity analysis, engineering training, and l-correspondence and commitment control" to "and Engineering support services such as design process control, budget administration, procedure control and administration, engineering training, and vendor document processing". - -
.... paga 2 4
Reason for Change
- 1. The Engineering Services organization is being repositioned as a separate Engineering Unit within the Engineering Assurance / Engineering Programs Section and the section being retitled " Engineering Assurance / Engineering Services" to coincide with its major functions.
Figure 1 depicts the current and proposed o.ganizational arrangements.
This changed position title matches the new organizational title of this section.
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.2. The Eng neer ng Serv ces organ zat on is being repositioned as a separate organizational unit within the Engineering Assutance/ Engineering Programs Section.
This' changed organizational title coincides with the major functions of this section.
- 3. The reason for these changes are as follows:
3.1 The purpose of USAR Section 17.2.1 " Organization" is to provide a general description of the functions of Davis-Besse organizations. The specific role of these organizations in performing quality assurance functions or in executing quality assurance program requirements are described in further detail in the individual sections which address the criteria of 10CFR50 Appendix B.
The proposed change eliminates ambiguity by providing a more clear, concise summary level description of the Engineering Assurance quality review functions.
Specific details regarding the implementation of these functions are included in subsequent sections.
13.2 The following Engineering Assurance functions currently described in
'the USAR are self-assessment activities:
A. Participation in the development of procedures governing work to ensure their adequacy.
B. Conduct of in-depth technical evaluations to assess the technical adequacy of engineering products.
C. Overview of the engineering training program.
Engineering Assurance also performs other self-assessment activities not specifically described in this paragraph. These are non-regulated activities intended to improve the technical adequacy, quality,-and efficiency of Engineering activities. The scope of these activities was elaborated in a meeting with NRC Region III officials on November 14, 1989. The proposed change is a more inclusive description of these activities allowing the flexibility to vary self-assessment methodologies to address criti al areas.
The Chemistry / Radiochemistry Improvement Program-is no longer in development. This function nov involves ongoing review and evaluation of plant chemistry and radiochemistry issues.
The proposed change is a more current description of this function.
- 4. The Engineering Services organization is being repositioned as a separate organizational unit within the Engineering Assurance / Engineering Programs Section.
This function is more appropriately described under the 1.
', page 3 c
Engineering Departaent manager responsible for that section. The purpose of the prroomed change is to centralize the management of Engineering Departmer tau-tions ~51ch the Engineering Director uses to monitor the technical un,liiv, u<a administrative aspects of Engineering activities.
This or gar.;n.tc on il arrangement simplifies internal communications, focuses direction an! aa >untability at the appropriate management level, nnd enhances the in uneering Director's ability to-effectively and efficiently manage the uepartment.
- 5. The Engineering Services function is being repositioned and vill be headed by the Engineering Assurance / Engineering Services Manager.
Figure 1 depicts the current and proposed organizational arrangements.
This vording.
is no longer appropriate.
- 6. The changes described in this section are editorial. The Engineering Services budget-development, cost accounting analysis, and procurement activity analysis functions are all associated with administration of the Engineering Department budget.
These functions are more clearly described by the term budget administration.
Procedure control and administration is a' current function of Engineering Services inadvertently ommitted from the-description. This function should be included as it is an important Engineering support service.
The correspondence and commitment control-function involves processing vendor correspondence associated with vendor drawings and manuals and coordinating Engineering Department review and approval of these documents. This function is more accurately described as vendor document processing.
Effect of Change on the Davis-Besse USAR -
Chapter 17.2 Quality Assurance Program Description Commitments
- 1. This change does not reduce the quality assurance program description commitments previously accepted by the NRC. This is a title change only.
- 2. This change does not reduce the quality assurance program description commitments previously accepted by the NRC.
This is a title change only.
- 3. This change does not reduce the quality assurance program description commitments previously accepted by the NRC. While no longer a developmental activity, this responsibility is still implemented through the engoing review and evaluation of-plant chemistry and radiochemistry issues.
- 4. This change reduces the quality assurance program description commitments previously accepted by the NRC. The proposed change is a change to an operative quality assurance program commitment contained in docketed correspondence outside of USAR Chapter 17.2..
A letter from Mr. D. C.
Shel. ton to the NRC dated October 21, 1898 (Serial Number 1604), 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 would " report directly to the Engineering Director and function independently of i
_ _ _ _, page 4 u,
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engineeri~ng line activities".
Since the Engineering Services function involves engineering line activities, a reorganization which adds this function to the responsibilities of the Engineering Assurance Manager is 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 10CPR50 Appendix B and the Safety Analysis Report quality assurance progran description commitments previously accepted by the NRC is as follows:
The requirements for organizations performing quality assurance activities are described in 10CFR50 Appendix B, Criterion I " Organization". These requirements state, in part:
"The authority and duties of persons and organizations performing activities affecting the safety-related functions of structures, systems, and components shall be clearly established and delineated in vriting.
These activities include both the performing functions of attaining quality objectives and the quality assurance functions.
The quality assurance functions are those of (a) assuring that an appropriate quality assurance program is established and effectively executed and (b) verifying, such as by checking, auditing, and inspection, that; activities affecting the safety-related functions have been correctly performed.
The persons and organizations performing quality assurance functions shall have sufficient authority and organizational freedom to identify quality problems; to initiate, recommend, or pr" !de solutions; and to verify implementation of solutions.
Such persor; and organizations performing quality assurance functions shall report to a management level such that this required
. authority and organizational freedom, including sufficient independence
.from cost and schedule when opposed to safety considerations, are provided."
The proposed changes do not affect the assignment of quality assurance functions as defined in 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.
Engineering Assurance / Engineering Programs and Engineering Services activities are subject to audit and surveillance by the Quality Assurance Department.
The Engineering. Assurance organization and its personnel maintain sufficient authority and' organizational freedom to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions. The responsibilities of the Engineering Assurance / Engineering Programs Section currently described in the USAR will continue to be autonomously implemented, encompassing all of the activities currently being performed.
Further, there vould be no meterial impact on the execution of activities by Engineering Services as currently described in the USAR.
An Engineering Assurance Supervisor and an Engineering Services Supervisor vill be retained in direct responsible charge of the respective units, providing the Engineering Assurance / Engineering Services Manager the organizational freedom necessary to devote the required attention to quality assurance program commitments.
Individuals in
_, page 5.
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Engineering Assurance responsible for verifying implementation of quality assurance program requirements, such as in the review of procurement documents, do not have direct responsibility for vork being verified.
These individuals vill not be assigned duties-unrelated to the Engineering Assurance function as governed by their position descriptions.
The-Engineering Assurance organization reports to a canagement level which provides the required authority and organizational freedom. The Engineering Assurance / Engineering Services Manager vill continue to report directly to the Engineering Director, maintaining the same level of authority as the highest Engineering Department line manager. The proposed change escalates responsibility for-the Engineering Services function to a higher level of authority vithin the Engineering Department (i.e., from Ge7eral Supervisor to Manager). The Engineering Assurance / Engineering Services Manager vill not have responsibility for any budgetary or schedule decisions which might affect the technical adequacy or quality of Engineering products generated by other Engineering Sections.
The-intent of the October 21, 1988 letter was that Engineering Assurance vould be independent of line activities involving the development of technical-and quality requirements. This intent was elaborated in a meeting with NRC Region III officials on November 14, 1989. The Engineering Services responsibilities currently-described in the USAR include overall support services for the Engineering Department; design process control, budget development, cost accounting analysis, procurement activity' analysis (monitoring of engineering contract services budgets),
engineering training,-and correspondence and commitment control.
Engineering Services is also responsible for coordination and development of Engineering procedures. None of these activities involve line responsibility for development of technical and quality requirements for nuclear safety related engineering procurement documents, engineering specifications, and design work packages. The following is an analysis of the impact of these functions on Engineering-Assurance independence:
A. The design process control function involves the administrative processing of plant modifications, the coordination of modification closure activities, and maintenance of-the configuration management data base (DBCES). The Engineering Assurance commitment for review of modifications is to ensure the adequacy of engineering documents released for implementation and is not associated with this Engineering Services function.
Line responsibility for the technical adequacy or quality of plant modifications or the data contained in DBCES rests with the Design Engineering Section.
The Quality Assurance Department retains complete responsibility for verifying (i.e., by audit or surveillance) that plant modifications and other design control activities comply with quality assurance 9
program requirements.
e B. Budget development, cost accounting analysis, and procurement activity analysis are clerical activities and do not involve any technical line management functions or any budget decisions which are opposed to safety considerations. The budget development function is limited to inputting budget data to the computer, and the cost accounting analysis and procurement activity analysis functions are limited to tracking and reporting budget status.. _ -
- Attachment 2. page 6 Budgetary decisions which may affect the outcome of technical Engineering activities or the quality of Engineering products are made exclusively by the Engineering Director and the Engineering technical line managers.
C. The procedure function in Engineering Services involves coordination of procedure development activities and assuring procedures are administratively correct.
Line resporuibility for Engineering procedures rests with techncial discipline managers.
The Engineering Assurance procedure related function in the quality assurance program description involves participation in the development of engineering procedures.
This is a self-assessment function not associated with any quality assurance program commitments.
The Quality Assurance Department retains complete responsibility for verifying (i.e., by audit or surveillance) that procedures comply vith quality assurance program requirements.
Centralizing the management of this Engineering Assurance function and the Engineering Services procedure administration function is
+
considered an enhancement since it vill provide more effective execution of these responsibilities.
D. The engineering training function in Engineering Services involves the development and conduct of training lessons, the-coordination and scheduling of training activities, and training record keeping within the Engineering Department. The purpose of the Engineering-Assurance overview of the engineering training program is to improve
,the content, scope, or method of training when Engineering self assessments indicate the need for such improvement. This is a self-assessment function not associated with any quality assurance program commitments. The Quality Assurance Department retains complete responsibility for verifying (i.e., by audit or surveillance) that training activities have-been correctly performed.
as required by 10CFR50 Appendix B.
E. The correspondence and commitment control function-in Engineering Services involves the coordination of vendor document review and approval within the Engineering Department and periodic vendor contact to ensure vendor manuals are kept current.
Engineering Services has no line responsibility for the technical and' quality review of vendor documentation.
Further, Engineering Assurance has no quality assurance program commitments associated with this function. The_ Quality Assurance Department retains complete responsibility for verifying (i.e., by audit or surveillance) that activities associated with the processing of vendor documentation comply with quality assurance program requirements.
The administrative line activities described above do not involve the development of technical or quality requirements nor are they associated with the assurance functions assigned to Engineering Assurance in the quality assurance program description.
The Engineering Assurance organization vill retain sufficient independence and authority and vill continue to execute its current responsibilities.
Engineering Department
. activities, including those of the Engineering Assurance / Engineering Programs and Engineering Services organizations, will continue to be audited by an independent Quality Assurance Department.
Accordingly, the 1..
., page 7 proposed changes have no direct or indirect effect on the safety-related functions of plant structures, systems, or components.
- 5. This change does not reduce the QA Program description commitments previously accepted by the NRC. The reorganization escalates responsibility for the Engineering Services function to a higher level of authority within the Engineering Department (i.e., from General Supervisor to Hanager). The Engineering Assurance / Engineering Services Manager vill continue to report directly to the Director - Engineering as previously described.
- 6. This change does not reduce the OA Program description commitments previously accepted by the NRC. The Engineering Services organization vill continue to exist as an autonomous organizational unit within the Engineering Department. The editorial changes described above have no effect on the scope or execution of Engineering services activities.
~7-
', page 8 4
CURRENT ORGANIZATION Director DB Engineering-I I
Hanager General Supervisor Engineering Assurance /
Engineering Programs Engineering Services 4
I I
General Supervisor Chemistry Improvement Engineering Assurance PROPOSED ORGANIZATION Director DB Engineering Manager Engineering Assurance /
Engineering Services 1
I Supervisor Chemistry Improvement Supervisor Engineering Assurance Engineering Services Figure 1
- __