ML20045F469
| ML20045F469 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/01/1993 |
| From: | PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20045F467 | List: |
| References | |
| NUDOCS 9307070322 | |
| Download: ML20045F469 (95) | |
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l ATTACHMENT 1 PHILADELPHIA ELECTRIC COMPANY LIMERICK GENERATING STATION, UNITS 1 AND 2 [
1993 QUALITY ASSURANCE PROGRAM DESCRIPTION CHANGES ,
(Program Description Revision 11)
Change Para. No. Description of Chance Classification ,
17.2.1 Changed " fifteen" organizations Organizational to " sixteen," "six" Senior Vice Presidents to "five," " ten" Vice Presidents to " eleven," deleted
" Human Resources."
17.2.1.2 Deleted "four departments." Editorial .
Changed " Nuclear Engineering and Organizational Services" to " Nuclear Engineering and Nuclear Services."
17.2.1.2.2 Changed " Nuclear Engineering and Organizational l Services" to " Nuclear Engineering and Nuclear Services."
Deleted " Nuclear Engineering and Editorial Services is under the direction of '
a Vice President who reports to the Senior Vice President, Nuclear. ;
The Vice President is responsible for the activities which support PECo nuclear facilities." j 17.2.1.2.3 Deleted "the Performance Organizational Assessment Section;" (approved by the NRC by letter dated March 9, 1993).
- 17.2.1.2.3 (h) Changed "Vice President, Nuclear Organizational Engineering and Services" to "Vice President, Nuclear Services." :
Added "the General Manager, Organizational Nuclear Engineering."
1 17.2.1.2.3.1 Changed "four" sections to "three." Organizational i Changed " Quality Assurance" Organizational j (section) to " Assessment." ,
i Deleted " Technical Monitoring" Organizational (section); incorporated into Assessment Section.
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ATTACHMENT 1 (continued) l Change Para. No. Description of Chance Classification 17.2.1.2.3.1.1 Changed " Quality Assurance" to Organizational .
" Assessment."
17.2.1.2.3.1.1 (a) Deleted " Quality Assurance." Editorial (section)
(d) Deleted " Technical Monitoring." Organizational (e), (g) Added "and Technical Monitoring." Organizational (f) Changed " Issue CARS as a result Clarification :
of NQA audit and surveillance activities and verify corrective action," to " Ensure that items requiring corrective action are properly identified and documented in accordance with NQA procedures."
(j ) (k) (1) Added items. Organizational
. 17.2.1.2.3.1.2 (a) Changed "QV Inspection" to Clarification
" Quality Verification (QV)." ;
i (c) Changed " Quality Assurance" to Organizational ;
" Assessment."
Deleted " Technical Monitoring" (Superintendent).
(g) Changed " inspection" to Clarification
" verification." l 17.2.1.2.3.1.3 (b) Changed " Quality Assurance" to Organizational
" Assessment."
Deleted " Technical Monitoring" (Superintendent).
17.2.1.2.3.1.4 Deleted entire Technical Organizational Monitoring Section (combined with l
" Assessment" in 17.2.1.2.3.1.1). l l
Organizational-
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17.2.1.2.3.3 Deleted " Performance Assessment Section;" (approved by the NRC by letter dated March 9, 1993)~.
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i ATTACHMENT 1 (continued) !
Change _3 Para. No. Description of Chance Classification i
17.2.1.2.3.3 '
(new) (was Changed "four" to "three." Organizational 17.2.1.2.3.4)
Changed " Quality Engineering, Organizational Vendor Evaluation" to " Assessment."
17.2.1.2.3.3 (e) Changed " Nuclear Engineering Organizational and Services" to " Nuclear Engineering and Nuclear Services."
17.2.1.2.3.3.1 Changed " Quality Engineering" Organizational (was to " Assessment" (Section).
17.2.1.2.3.4.1) 17.2.1.2.3.3.1 Added item (a). Administrative (b) [was (a)] Added " Directing the ... planning." Clarification i Deleted " technical and/or .
performance based." Added "... and surveillance to assure compliance ,
with the QA Program." -
(c) [was (b)] No change.
Deleted " Verification of NRC Simplification correspondence (as requested)" -
(addressed by 17.2.1.2.3(g)) e (d) [was (e)] Added " modifications interface." Editorial l
(e) (f) (g) Previously (a) (c) and (d) under Organizational former Section 17.2.1.2.3.4.2. }
(h) Previously (b) under former Organizational i Section 17.2.1.2.3.4.4. ,
i 17.2.1.2.3.4.2 Deleted " Vendor Evaluation Section;" ' Organizational (combined with Assessment j in 17.2.1.2.3.3.1).
Last paragraph of section was Editorial !
not included in 17.2.1.2.3.3.1.
The paragraph is not appropriate to this organizational section, i and is a duplication of 17.2.1.8.1.2.
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ATTACHMENT 1 (continued)
Change Para. No. Descriotion of Chance Classification 17.2.1.2.3.3.3 (d) Deleted " Preparation of the Organizational (was NQA Budget."
17.2.1.2.3.4.4)
(a) Deleted " Standardization of Simplification office / site procedures."
(addressed by 17.2.1.2.3(b))
17.2.1.3 Deleted " Methods and Training Organizational Division."
Added paragraph on Fire Organizational Protection Services.
I 17.2.1.4 Deleted " Human Resources." Organizational 17.2.1.4.1 Deleted Employee Services Department. Organizational 17.2.1.4.1.1 Deleted Safety Division. Organizational Deleted description of the Fire Organizational Protection Section; moved to
" Production," Section 17.2.1.3.
17.2.2.11 Changed "QA Plan" to QA Program." Clarification 17.2.2.16 Deleted paragraph on Organizational Performance Assessment.
Appendix 17.2.I Simplified matrix to refer to Simplification series of Nuclear Group procedures rather than specific procedures.
Appendix 17.2.II (c) (18) Added alternative for Periodic Procedure Reviews; (approved by the NRC by letter dated July 14, 1992).
(g) Added item "2" to provide Clarification definition and clarification.
CHAPTER 17 QUALITY ASSURANCE TABLE OF CONTENTS 17.1 QUALITY ASSURANCE DURING DESIGN AND CONSTRUCTION 17.2 QUALITY ASSURANCE DURING THE OPERATIONS PHASE I
17.2.1 Organization 17.2.2 Quality Assurance Program 17.2.3 Design Control 17.2.4 Procurement Document Control 17.2.5 Instructions, Procedures, and Drawings t
17.2.6 Document Control 17.2.7 Control of Purchased Material, Equipment, and Services 17.2.8 Identification and Control of Materials, Parts, and Components ,
t 17.2.9 Control of Special Processes 17.2.10 Inspection 17.2.11 Test Control i i
17.2.12 Control of Measuring and Test Equipment j 17.2.13 Handling, Storage, and Shipping 17.2.14 Inspection, Test, and Operating Status ,
17.2.15 Nonconforming Materials, Parts, or Components 17.2.16 Corrective Action 17.2.17 Quality Assurance Records 17.2.18 Audits !
Appendix 17.2.I 10CFR, Part 50, Appendix B Criterion. ]
Matrix :
l Appendix 17.2.II PEco's Application of Industry Standards and USNRC Regulatory Guides 17-i l
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QUALITY ASSURANCE FIGURES f
i Figure Title 17.2-1 Executive Organization Chart, Philadelphia Electric Company ,
17.2-2 Organization Chart, Nuclear Group, Philadelphia Electric Company $
17.2-3 Organization Chart, Nuclear Services, {
i Philadelphia Electric Company (Deleted) 17.2-4 Organization Chart, Nuclear Quality Assurance, Philadelphia Electric Company 17.2-5 Organization Chart, Nuclear Engineering i Philadelphia Electric Company (Deleted) '
17.2-6 Organization Chart, Production, Philadelphia Electric Company i 17.2-7 INTENTIONALLY LEFT BLANK i
17.2-8 Organization Chart, Human Resources Philadelphia Electric Company (Deleted) ;
17.2-9 Organization Chart, Information Systems and General Services, Philadelphia Electric Company -
17.2-10 Organization Chart, Legal I Philadelphia Electric Company i
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CHAPTER 17 i
QUALITY ASSURANCE ;
i 17.1 OUALITY ASSURANCE DURING DESIGN AND CONSTRUCTION ;
This section is not applicable to the LGS UFSAR.
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LGS UFSAR 17.2 OURLITY ASSURANCE DURING THE OPERATIONS PHRSE Philadelphia Electric Company is responsible for ensuring that Limerick Generating Station (IAS) is operated, maintained, and modified in accordance with applicable regulatory requirements.
The President of the Philadelphia Electric Company has issued a policy statement endorsing the QA Program for nuclear activities. ;
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To ensure the quality of activities affecting safety-related structures, systems, and components of LGS during the operations phase, Philadelphia Electric Company has established a management ;
control plan which complies with 10CFR50, Appendix B. This plan consists of (1) the Quality Assurance Program, which contains i Philadelphia Electric Company's quality assurance commitments to the Nuclear Regulatory Commission, (2) the Nuclear Quality ,
l Assurance Plan (QA Plan) for the above organization, which contains a description of policies and program elements to implement the '
- commitments to the NRC, and (3) organizational unit procedures necessary for the unit to comply with requirements of the QA programs and plans.
Appropriate portions of the program will also be applied to radioactive material packages consistent with the activity and ,
proposed use of the package. !
i The Quality Assurance Program elements described herein shall be implemented by written procedures, which shall be established prior to performing activities applicable to those elements.
Section 13.5 describes the station administrative and implementing f procedures which meet requirements of the Quality Assurance Program i and which will be implemented by the LGS plant staff.
4 The responsibility for the QA Program described herein is retained '
and exercised by PECo exclusively. When specific tasks are delegated to organizations outside of PECo, PECo shall maintain control over the functions through means such as imposing QA I Program requirements, reviewing documents, and performing audits. l The vendor's QA Program shall be reviewed and approved by PECo prior to the vendor performing work. The documents to obtain j 3 vendor services shall clearly define the scope of work, the QA ;
requirements, and the responsibilities being assigned to the i vendor. ;
l The Nuclear Quality Assurance Program is described in Section 17.2.
The program complies with the requirements of 10CFR50, Appendix B d
and is based on the QA-related NRC Regulatory Guides and associated ,
industry standards. Compliance to these Regulatory Guides and standards is addressed in Appendix 17.2.II. i i
B i
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LGS UFFAR 17.2.1 ORGANIZATION The Philadelphia Electric Company corporate structure is shown on the Executive Organization Chart, Figure 17.2-1. Sixteen organizations are directed by five Senior Vice Presidents, and y eleven Vice Presidents. Quality related activities are performed primarily by the Nuclear Group. The following FECo organizations i provide a limited number of quality related ser. ices to the Nuclear i l
Group: Production; Information Systems and Ge.teral Services; and Legal.
17.2.1.1 Office of the Chief Executive The Chairman of the Board and Chief Executive Officer, and the i President and Chief Operating Officer, comprise the Office of the Chief Executive. The President of PECo has the ultimate responsibility for the Quality Assurance Program for PECo nuclear facilities. The President delegates to the Senior Vice President, Nuclear, the authority for instituting and maintaining the Nuclear Quality Assurance Program. ;
17.2.1.2 Nuclear Group I'
The Nuclear Group is under the direction of the Senior Vice President, Nuclear. The Senior Vice President, Nuclear is s responsible for the operation, maintenance, and modification of the PECo nuclear electric generation facilities and the establishnent of the Nuclear Quality Assurance Program goals and objectives.
k The organization of the Nuclear Group is shown in Figure 17.2-2.
- The Nuclear Group is composed of: Nuclear Engineering, Nuclear Services, Limerick Generating Station (LGS), Peach Bottom Atomic j, Power Station (PBAPS), and Nuclear Quality Assurance (NQA). The Nuclear Group is supplied with procurement services, - personnel, ,
maintenance, and other support functions from other Philadelphia il Electric Company organizations and contractors as necessary.
17.2.1.2.3 Station Organization The LGS organization, duties, and responsibilities are described in ;
Section 13.1.2. .
17.2.1.2.2 Nuclear Engineering and Nuclear Services The organization, duties and responsibilities of Nuclear ,
Engineering and Nuclear Services are described in Section 13.
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LGS UFSAR 17.2.1.2.3 Nuclear Quality Assurance Nuclear Quality Assurance (NOA) is responsible for administering ,
the overall Nuclear Quality Assurance Program of the Nuclear Group.
The organization of Nuclear Quality Assurance is shown in Figure 17.2-4.
Nuclear Quality Assurance is headed by a General Manager who reports directly to the Senior Vice President, Nuclear. NQA is i composed of the Peach Bottom Quality, Limerick Quality, and l Corporate Nuclear Quality Divisions; and the Peach Bottom ' and Limerick Independent Safety Engineering Groups. ,
The General Manager, NQA, has the following responsibilities and authorities:
- a. Formulate, develop, and establish Nuclear Quality Assurance policy in areas of Operations, Maintenance, Modifications, In-service Inspection / Testing, >
Surveillance Testing, Fuel Handling, Health Physics, Chemistry, Radiological and Environmental Monitoring, '
Fire Protection, Physical Security, Emergency Preparedness, Radioactive Waste and Material, Training, Procurement, Audits, Records, Nonconformances, and Corrective Action. l l
- b. Administer and coordinate the Nuclear Quality Assurance Program (NQA Program). 1
- c. Furnish overall direction for implementing the NQA ,
Program. !
- d. Provide recommendations for correcting program deficiencies or improving the implementation of the NQA Program, as appropriate.
- e. Require tracking and verification of corrective action and problem resolution for all QA-identified Corrective ;
Action Requests (CARS and MCARs). Require that '
deviations be tracked in accordance with Administrative Procedures.
- f. Direct cessation of work when such work is considered by the General Manager, NQA, to be a serious quality degradation. This stop work authority shall be delineated in applicable procedures.
- g. Determine the on-going status and adequacy of the NQA Program through regular review of NQA Audits, ,
Surveillances, Monitorings and Inspections, 1 identification and investigation of problem areas, determination of timely and effective steps taken to ,
correct deficiencies, and the evaluation of general plant ,
QA/QV performance through such other inputs as are available or are deemed necessary to make a reasonably i objective and confident judgment. _
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- h. Apprise the Senior Vice President, Nuclear; the Vice President, Nuclear Services; the Vice President, Limerick ;
Generating Station; the General Manager, Nuclear Engineering; and the Nuclear Review Board periodically of t the status of the Quality Assurance aspects of Limerick i Generation Station's operations, and immediately of sig,.ficant problems affecting quality. l
- i. Control contents and revisions of the NQA Plan,
- j. Ensure that personnel involved in implementing the NQA procedures are trained and/or qualified, as appropriate. [
- k. Contract for QA/QV consulting services as necessary.
- l. Provide support for QA/QV training and qualification programs, as required, for implementation and execution !
of the NQA Plan. ;
- m. Establish and maintain :he Ivaluated Vendors List (EVL) !
of evaluated and quali fled vendors in accordance with administrative procedures. ,
- n. Perform audit / surveillance of vendor activities as '
j appropriate.
- o. Establish, administer, and coordinate the Nuclear Quality l Assurance Program associated with modifications, and '
capital equipment installation or renewal. ,
- p. Assess, through NQA Audits, Surveillances, Quality i Verifications, and Technical Monitoring, the adequacy and effectiveness of activities covered by the NQA program.
17.2.1.2.3.1 Limerick Quality Division The Limerick Quality Division is under the supervision of a Manager i, who reports to the General Manager, Nuclear Quality Assurance. The
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Division is composed of three sections: Assessment, Quality l Verification, and Quality Support. The Manager, who meets the i
, requirements of ANSI /ANS-3.1-1978, is responsible for: i
- a. Providing technical and administrative direction to the Division.
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- b. Providing single point accountability for all >
site quality activities, i
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- c. Reviewing and approving _ site-generated administrative procedures.
- d. Formulating the site Audit Program.
- e. Conducting audits, surveillances, inspections, and monitorings. i
- f. Identifying specific and programmatic ;
deficiencies, and tracking these items until they are fully resolved, in accordance with Administrative Procedures.
- g. Performing trend analysis.
- h. Providing periodic reports to the General ,
Manager, NQA, on the status and adequacy of the nuclear facility Quality Assurance Program and advising of any problems requiring special attention.
- i. Approving Stop Work directives,
- j. Providing and maintaining a qualified and 6 suitably trained quality assurance staff to carry out required project and staff functions.
17.2.1.2.3.1.1 Assessment Section ,
8 The Assessment Section is under the supervision of a Superintendent ;
. who reports to the site QSality Division Manager. The Superintendent has the following responsibilities:
- a. Provide administrative supervision and technical ,
direction of the activities of the section. ,
i b. Direct the scheduling, planning, and perfow.ance of
. audits and surveillances in accordance with written procedures to ensure compliance with the NQA Plan and Technical Specifications.
- c. Oversee the preparation of NQA audit checklists.
- d. Consult with the Quality Verification and Quality Support ,
Superintendents, and the site Quality Division Manager,
. on significant problems affecting quality.
- c. Review and approve results of audits, surveillances, and technical monitoring.
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LGB UFSAR
- f. Ensure that items requiring corrective action are properly identified and documented in accordance with NQA procedures.
- g. Ensure that personnel involved in performing NQA audits, ,
surveillance, and technical monitoring are trained, 1 qualified and certified.
- h. Assure timely follow-up of committed corrective action.
- i. Assure that corrective action performed in response to previously identified conditions adverse to quality, is adequate and effective to preclude repetition.
- j. Direct the scheduling, planning, and performance of technical monitoring in the areas of operations, health physics, radioactive waste, chemistry, security, postmaintenance/ modification testing, surveillance l testing, maintenance, fire protection, plant modifications, and emergency planning.
- k. Development and approval of Monitoring Guidelines.
- 1. Interface with station management to provide feedback and obtain corrective action to identified problems.
17.2.1.2.3.1.2 Quality Verification Section The Q'ality u Verification Section is under the direction of a Superintendent who reports to the site Quality Division Manager.
I The Superintendent has the following responsibilities:
- a. Provide administrative supervision and technical direction of the activities of the NQA Quality Verification (QV) personnel.
. b. Oversee the inspection activities in the areas of receipt i inspection; radwaste/radmaterial packaging, handling, and shipment; maintenance and modification activities performed on safety-related equipment.
- c. Consult with the Assessment Superintendent, Quality Support Superintendent, and site Quality Division Manager, when significant problems affecting quality are identified.
- d. Overview of the QV Section activities, schedules, and results.
- e. Identify the need for the preparation of NQA procedure supplements relating to QV activities.
- f. Ensure that the personnel involved in the implementation of QV inspection activities are trained, qualified and certified to perform assigned activities.
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- g. Ensure that verification results are ' documented in accordance with NQA procedures, and unacceptable results are identified and rescheduled in inspections, as appropriate.
- h. Review of work requests for inclusion of QA Plan requirements and QV activities. ,
- i. Document conditions adverse to quality resulting from QV ;
activities and verify corrective action.
] j. Provide independent verifications in mechanical, -
electrical, I&C and welding disciplines. ;
l k. Provide visual, liquid penetrant, magnetic particle, and ultrasonic inspections.
[ 1. Coordinate NDE activities with appropriate plant technical and craft supervision personnel.
17.2.1.2.3.1.3 Quality Support Section The Quality Support Section is under the supervision of a !
Superintendent who reports to the site Quality Division Manager. ;
The Superintendent has the fo' lowing responsibilities:
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- a. Provide administrative supervision and technical direction of the activities of the Quality Support Section. j
- b. Consult with the Quality Verification Superintendent, Assessment Superintendent, and the site Quality Division -
- Manager, on significant problems affecting quality,
- c. Ensure that personnel involved in performing NQA Quality ;
Support activities are trained and qualified. l
- d. Review and coordinate revision of NQA Procedures.
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- e. Review of selected Station Administrative Procedures and Implementing Procedures.
- f. Review and approval of procurement documents and technical receipt inspection documents for safety related ;
items and services.
- g. Review NCRs for conditions adverse to quality. j
- h. Tracking and trend analysis 'of Verification and Monitoring Activity reports and CARS.
- i. Document conditions adverse to quality identified during j Quality Support activities.
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- j. Resolve identified training deficiencies,
- k. Maintain NQA personnel qualification records.
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LGS UFSAR 17.2.1.2.3.2 Limarick Independent Safety Engincoring Group i
The Limerick Indepe.' dent Safety Engineering Group (ISEG) composition and responsibilities are described in Section 13.4.5.
17.2.1.2.3.3 Corporate Nuclear Quality Division The Corporate Nuclear Quality Division is under the supervision of :
a Manager who reports to the General Manager, Nuclear Quality -
Assurance. The Division consists of three sections: Assessment, ,
NDE Support and Administration; and a Training Coordinator. The l Manager, Corporate Nuclear Quality, is responsible for all Corporate Nuclear Quality Division activities. This includes:
- a. Manuals and procedures.
- b. Vendor audits and surveillances, I
- c. Training.
- d. Procurement controls.
- e. Oversight of the quality activities of Nuclear Engineering and Nuclear Services. r
- f. Identification of specific and programmatic deficiencies -
and tracking of these items until they- are fully resolved.
- g. Performing trend analysis.
. h. Conducting internal audits at the corporate offices.
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- i. Single point of accountability for all Corporate Nuclear Quality'(CNQ).
17.2.1.2.3.3.1 Assessment Section I
The Assessment Section is under the supervision of a Superintendent who reports to the Manager, Corporate Nuclear Quality Division. ,
The Superintendent's responsibilities include:
- a. Providing administrative supervision and technical ,
direction of the activities of the Section.
- b. Directing the scheduling, planning and performance of internal audits and surveillance to assure compliance !
with the QA Program.
. c. Review and approval of procurement documents and specifications.
- d. Engineering programs overview and modifications ,
interface.
- e. Providing administrative direction for the performance of
, vendor evaluation activities including audits, ,
surveillance and commercial grade surveys.
- f. Maintaining the Evaluated Vendors List. !
- g. Technical direction for the Nuclear Fuel QA Program.
. h. Trending of quality deficiencies, generation of trend reports, and analysis of trend information.
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t LGS UFSAR-17.2.1.2.3.3.'2 NDE Support Section The NDE. Support. Section is under the supervision of a Superintendent, who reports to the Manager, Corporate Nuclear Quality Division. The Superintendent is responsible for:
- a. Supervision and administration of the Section, ,
with NDE Level III capability in: Visual, j liquid penetrant, magnetic particle, !
ultrasonic and radiographic inspection ,
techniques.
- b. Providing technical oversight and assistance in analysis and interpretation of NDE data.
. c. Training, qualification and certification of :
Company personnel who perform visual, liquid .
penetrant, _lagnetic particle, and ultrasonic inspecti: as. ,
- d. Devaloping and maintaining NDE procedures for code compliance.
- e. Procuring vendors to perform all NDE
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- f. Reviewing and approving vendor NDE procedures, personnel certifications and equipment certifications.
- g. Assessing performance of NDE vendor personnel.
. h. Providing incidental NDE, as requested by the Nuclear Group.
17.2.1.2.3.3.3 Administration Section
- f. The Administration Section is under the supervision of a ,
. Superintendent who reports to the Manager, Corporate ' Nuclear Quality. The Superintendent is responsible for:
- a. Generation and distribution of NQA reports.
- b. Maintenance of the quality assurance tracking and '
. trending system for nonconformances.
$ c. Keeping the appropriate NQA Superintendents current on
. the recertification requirements for their personnel.
- d. Resolving identified training deficiencies.
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- e. Maintenance of CNQ personnel qualification records
- f. Maintaining current codes, standards and regulations pertaining to the Quality Assurance Program.
- g. Advising the Corporate Nuclear Quality Manager on the status of regulations, codes and standards which may affect the content of the QA Plan.
- h. Entering NQA records into the Nuclear Records Management ;
System.
- i. Review of NQA administrative procedures.
- j. Review of Nuclear Group administrative procedures,
- 1. Review and revision of the NQA Plan.
17.2.1.2.4 Plant Operation Review Committee (PORC)
The PORC composition and responsibilities are defined in Section 13.4.2.
17.2.1.2.5 Nuclear Review Board (NRB)
The NRB composition and responsibilities are defined in Section 13.4.3.
17.2.1.3 Production The Production organization is under the direction of the Vice
. President, Production. The Vice President is responsible for providing support for nuclear operation activities through the Oregon
- Shop which supplies various mechanical and electrical shop services to PECo generation facilities, including fire protection services.
The organization of Production is shown in Figure 17.2-6.
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LGS UFSAR Fire Protection Services is under the supervision of the Company '
Fire Marshal who reports to the . Manager, Oregon Shop. Fire Protection Services, in conjunction with nuclear plant site personnel, perform or arrange to perform certain fire equipment testing and inspections, both routine and as required by Technical Specifications. In addition, Fire Protection Services is responsible for the procurement, testing, replacement, and record keeping of fire hoses, extinguishers, fire brigade self-contained breathing apparatus, and other fire fighting equipment as required.
The Company Fire Marshal is responsible for the review of fire protection system designs, as requested.
17.2.1.4 Information Systems and General Services l Information Systems and General Services is under the direction of the Vice President, Information Systems and General Services, who
. reports to the Senior Vice President, Finance. The Purchasing Department is the only organization within Information Systems and -
General Services that is involved in nuclear plant activities. The organization of Information Systems and General Services is shown in Figure 17.2-9.
4 17.2.1.4.1 Purchasing Department l The Purchasing Department, under the direction of a Manager who reports to the Vice President, Information Systems and General Services is responsible for purchasing all equipment, - material, spare parts, and services as requisitioned by the LGS staff, or other requisitioning organizations.
The Nuclear Fuel Section is responsible for:
- 1. The purchase of:
. . nuclear fuel assemblies and related services ,
e uranium concentrates
- uranium conversion and enrichment services a radioactive waste disposal services a control rod blades, local power range monitors and fuel channels; 3
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- 2. Contracting for nuclear fuel cycle requirements to meet long term requirements as established by the Fuel Management Section of Nuclear Services.
l 17.2.1.5 Legal Department The Legal Department is directed by the Senior Vice President and General Counsel. The Claims -
Security Division is the only organization in the Legal Department that is involved in nuclear plant activities. The organization of the legal Department is !
shown in Figure 17.2-10. l l 17.2.1.5.1 Claims - Security Division l
The Claims - Security Division is under the direction of the ;
Manager, Claims - Security Division, who reports to the Senior Vice President and General Counsel, Legal Department. The Director of Security, who reports to the Manager, Claims - Security Division, is responsible for advising and assisting all departments of the l company in security related matters. !
l 17.2.2 QUALITY ASSURANCE PROGRAM
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The operating philosophy of Philadelphia Electric Company places emphasis and primary concern on the safety of its employees and the
! public. Other considerations such as continuity of service, equipment protection, economic operation, and environmental effects are recognized as important but are secondary to human safety.
l The Quality Assurance Program described herein applies to those
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l structures, systems, and components of the Limerick Generating Station that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. The specific structures, systems, and components to
. which the QA Program applies are identified through the Project j
Q-List, Quality Assurance Diagrams, and Table 3.2-1.
The Quality Assurance Program elements described herein shall be implemented by written procedures which shall be established at the earliest practical time consistent with the schedule for the activity and in all cases prior to performing activities applicable to those elements.
17.2.2.1.1 Philadelphia Electric Company's many years of en arience operating generating stations has evolved a wide spectrum of management measures directed toward efficient and safe operations.
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LGS UFBAR l
The Quality Assurance (QA) Program for LGS recognizes quality assurance as an interdisciplinary function involving many organizational components (i.e. , departments, divisions, sections, ,
groups, and individuals) and is not regarded as the sole domain of l the Nuclear Quality Assurance (NQA) Department. Quality Assurance !
encompasses many functions and activities and extends to various l levels in all participating organizations. First-line supervision I is responsible for the quality of the work performed under their l supervision. Second-line supervision and qualified craftsmen /
technicians may verify work functions associated with normal operation of the plant, routine maintenance, and certain technical services routinely assigned to the onsite operating organization where necessary to ensure quality. Independent inspections of nonroutine maintenance and plant modifications shall be performed, l as required, by qualified individuals who are organizational 1y
. independent of the individual or group performing the work. The Station Vice President has overall responsibility for the execution
- of the administrative controls at the plant and implementation of responsibilities assigned to plant personnel by the QA Program. An e overview of the QA Program is provided by personnel from Nuclear !
Quality Assurance who are organizationally independent of other l nuclear organizations. NQA shall ensure, through the auditing, '
technical monitoring and quality control programs, that activities affecting quality are accomplished in accordance with the l
. requirements of the QA Program.
17.2.2.2 Management recognizes the need to maintain a competent plant staff and to provide this staff with the support necessary to maintain operational safety. To meet this goal, certain activities
- conducted in the plant have been recognized as important to <
operational safety, and specific management control measures have been set up to ensure quality in these activities.
Personnel shall be trained and indoctrinated in these activities which are pertinent to their job description and responsibilities, with due regard to the effective implementation of the QA Program.
, Management requires that operations be conducted in accordance with approved procedures and has established review and reporting mechanisms which provide prompt and effective action when exceptions occur.
The staffing of the station is such that certain disciplines (e.g. ,
Chemistry, Purchasing, Maintenance) share high level supervision and management with other plants and facilities of the Philadelphia Electric Company. This is an important aspect of the staffing
, which provides a great wealth of experience and knowledge in assuring proper operation of the plant.
O 17.2-19{ [
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LGS UFSAR The station technical group is composed primarily of graduate engineers who assist plant supervision in areas of operational surveillance, maintenance, plant monitoring, and testing.
Additionally, Philadelphia Electric Company's own highly qualified Nuclear Engineering Division, which is responsible for the design and modification of the plant, is readily available for engineering consultation during operation. First- and second-line supervisory positions are normally filled by promotion of qualified personnel.
This procedure assures knowledgeable and experienced checking and inspection of in-progress work activities and is considered a noteworthy aspect of operational safety.
Shift operation at a power plant is an important activity that greatly impacts safety. This activity is concerned with the proper
. performance of the plant processes both during the shutdown and power phases. It involves surveillance of plant variables and
- manipulation of controls to maintain variables at desired levels.
Prompt and effective action during off-normal plant operations is required. Management has taken measures in the area of training and staffing which enhance safety of operation and require mechanisms to be established which provide objective evidence that important operations are being performed in accordance with established procedures. Appropriate objective evidence, in the
. form of check-off lists, log records, and data sheets, is reviewed by appropriate supervision as specified in Administrative Procedures.
Another important aspect of shift operations is corununications.
Communications between shift personnel and plant supervision, between one shift and succeeding shifts, and between staff group
- leaders and shift supervisors must be effective to ensure safe operation. Viable mechanisms are established, where appropriate, to enhance inter-plant group communications to ensure timely and effective communications.
17.2.2.3
, Training and qualification of plant operators is an on-going y
activity required to ensure safety in operation. Training and retraining efforts are formalized and objective evidence is available for auditing purposes. On-the-job hands on" experience is designed into the program to a maximum practical degree.
Records of each operator's important operations are maintained, e.g., reactor startup and shutdown. Qualified instructors and training material are utilized. Evaluations of students' training progression and. requalification status are maintained.
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17.2-20{ } '
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LGS UFSAR The training program ensures competent material selection .and instruction. The requalification program is designed to maintain :
current operator competence and uses current NRC requirements.
Training aids and individual study periods shall be utilized, as appropriate. Formal classroom instruction shall be scheduled.
Evaluation of trainees' progress shall be documented.
The training program also includes provisions for nonlicensed personnel and general employee indoctrination. As appropriate to the duties and responsibilities of an individual, general employee training includes: general description of plant and facilities, job related procedures, radiological health, emergency plan and procedures, industrial safety, fire protection program, quality assurance program, and security plan and procedures. Personnel performing ' quality-related activities shall be trained and qualified in the principles and techniques of the activities being performed. Training shall be in accordance with written procedures to ensure that suitable proficiency is achieved and maintained.
Areas of training include technical training, on-shift training, qualification or certification requirements, and qualifying tests, as appropriate for the job position. Administrative procedures shall delineate the scope, objective and methods associated with the training program, along with requirements for requalification and documentation of the training accomplished. The qualification ,
requirements for plant personnel are described in Section 13.1.3. l predetermined and Philadelphia Electric Company has taken systematic action to assure that IGS operations are conducted in a :
safe,. efficient manner. High employee loyalty evidenced by many years of continuous service and low employee turnover, combined !
- with specialized training programs and other employee benefits are ,
recognized as significant contributors to quality.
17.2.2.4 Surveillance testing of safety systems and instruments as required by the Technical Specifications is an activity which is an
. important contribution to the operational safety of LGS.
Administrative Procedures require that these tests be conducted in a high-quality manner by knowledgeable personnel familiar with test Surveillance Test procedures are reviewed by PORC and procedures.
approved by the Plant Manager or designee. Surveillance tests associated with process cperation are conducted by the shift operations group with review by shift supervision. Approved procedures and documented reports are utilized to assure high quality in this activity.
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17.2-21
17.2.2.5 Work associated with radiation protection, radioactive waste and. '
chemistry is conducted under supervision of the Senior Health Physicist, Senior Radwaste Engineer, and Senior Chemist, respectively, who report through the Services Superintendent to the Plant Manager. The activities are divided into two types: first, those of a routine and uncomplicated nature and second, those of a nonroutine or complex nature. Activities of the first type are generally performed by members of the shift operations group. In this way, this group maintains competence in the area of radiation control and chemistry and provides the capability for 24-hour-per-day radiation and chemistry monitoring.
The more complex studies and tests are performed by members assigned to the technical group. The importance of radiation control (ALARA) and chemistry on nuclear plant operation warrants every effort to establish high quality in this activity.
Mechanisms such as shift and daily written reports, plots, and log books will be reviewed by appropriate supervision as specified in Administrative Procedures. Inspections and reviews will also be conducted by senior plant supervision as defined in Administrative '
Procedures.
t 17.2.2.6 Mechanical, electrical, and instrument and controls maintenance at j LGS will be performed by the Maintenance / Instrument & Control (M/I &C.) Group. The Maintenance /I&C Group reports through its Superintendent to the Plant Manager. Nuclear Quality Assurance, which is organizationally independent of the plant operations 5
staff, shall assign personnel to the station to provide quality control checking and inspection.
Only qualified craftsmen are utilized to perform maintenance work.
First and second level supervision and qualified craftsmen /
technicians have had specific quality training and are recognized
- as an important means of controlling quality. These personnel may verify tr c.>e activities that are evaluated as not requiring i organizational independence.
Installation of new components or the physical change in systems of l a major nature is considered a modification activity which will normally be implemented by the Nuclear Engineering and Services Department. Quality Assurance measures and organization for 4 modifications shall be implemented in a fashion similar to that used during plant design and construction, with the additional I assurance of review and approval by the Plant Operations Review i Committee and, as appropriate, the Nuclear Review Board.
h 17.2-223 p
The procurement of spare parts, materials, and services for LGS is initiated by cognizant personnel in accordance with approved policies and procedures. Materials Management is an independent organization functioning as a service group to the station. The ordering, receipt, storage and issuance of materials and services '
are accomplished in accordance with Materials Management, Corporate, NQA, and plant procedure.s which incorporate suitable measures to ensure quality. Requisitions for materials or services i are transmitted from Materials Management or other authorized PECo entities to the Purchasing Division where buyers execute the order in accordance with Company purchasing procedures and policies. .
Spare parts, materials, and services may also be obtained via a contractor who has been evaluated and is on the Evaluated Vendors List.
17.2.2.8 The QA Program for Limerick Generating Station will be defined in the Nuclear Quality Assurance Plan (QA Plan). The QA Plan i implements the policies and objectives of the Nuclear organization, and applicable codes, standards, and regulations by addressing the managerial and administrative controls in various operational activities such as: Training, Health Physics, Chemistry, Fuel and Invessel Material, Shift Operations, Surveillance Testing,
. Maintenance /I&C, In-Service Inspection / Testing, Procurement, ,
Modifications, Radioactive Waste / Material, Engineering and Design, and Plans.
For each of these activities, the QA Plan shall address the 18 i criteria of 10CFR50, Appendix B, and describe how each activity is
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in compliance with the applicable criteria in Appendix B. In addition, the radioactive waste / material activity shall also address the requirements of 10CFR71, Subpart H, Packaging and
. Transportation of Radioactive Material, Quality Assurance.
Procedures are written to implement all aspects of the QA Plan. A
- matrix of these procedures or documents is presented in Appendix 17.2.I to demonstrate that 10CFR50, Appendix B criteria are fully implemented by documented procedures.
i Also, the QA Plan shall require written procedures to implement the requirements of the Regulatory Guides listed in UFSAR Section 1.8, ,
the General Design Criterion 1 of Appendix A to 10CFR50, and :
NQA, in the review of Administrative Procedures, shall ensure that Regulatory Guide commitments are included in the appropriate procedures.
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17.2-23 -
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LGS UFSAR All Quality Assurance Program activities performed within Philadelphia Electric Company are subject to formal periodic audits '
by NQA. These audits verify that organizations performing these activities are complying with and properly implementing their procedures.
Administrative procedures for the preparation of documents, such as drawings, specifications, and procedures assure that the use of appropriate equipment, suitable environmental conditions, and compliance with necessary prerequisites are considered, as necessary, to perform activities affecting quality under controlled conditions.
The development, control, and use of computer code programs,
. commensurate with its importance, shall be conducted in accordance with the appropriate provisions of this QA Program. Software, commensurate with its importance, used in the operational phase of Limerick Generating Station, shall be subject to verification by Philadelphia Electric Company or other qualified personnel.
Measures shall be established to ensure that the computer codes are appropriate for their specific applications.
The QA Program shall be reviewed periodically by NQA to determine status and effectiveness. The Nuclear organization management is informed on a continuing basis of the status and effectiveness of the quality assurance program through reports at Senior Vice President, Nuclear staff meetings, and through distribution of audit reports (including NQA audits, Joint Utility Management audits, INPO audits, and NRC Inspections and Audits).
17.2.2.9
. The QA Plan applies to activities affecting the quality of systems, components, and structures installed to prevent or mitigate the consequences of an accident which could be harmful to the public.
These structures, systems, and components are identified through the LGS Proj ect Q-List, the Quality Assurance Diagrams and Table 3.2-1. Although the measures discussed apply primarily to Q-listed equipment, they may also be applied in varying degrees to non-Q-
- . listed equipment (e.g., Seismic IIA). The selected application of these quality measures to non-Q-listed systems is intended to enhance operational safety and reliability.
The QA Plan, including revisions thereto, shall be approved by the Manager, Corporate Nuclear Quality; General Manager, NQA; Station
- Vice President; and the Senior Vice President, Nuclear, prior to issue.
e 17.2-24h 1 5 ?
LGS UFSAR 17.2.2.10 Nuclear Quality Assurance is staffed with trained, qualified, and experienced personnel who are organizationally independent of other Nuclear organizations. NQA has the primary responsibility to verify through the review of objective evidence and the performance of observations that the quality assurance activities are being accomplished in accordance with the QA Plan. This verification is accomplished by means of the NQA Audit, Surveillance, Verification, l ,
l and Technical Monitoring programs.
The NQA Training Coordinator, Corporate Nuclear Quality Division, in conjunction with the site NQA training coordinators, is responsible for developing and maintaining a quality assurance indoctrination and training program for NQA personnel to establish
. proficiency in quality assurance / quality control and to qualify personnel in accordance with NQA requirements and procedures.
NQA may involve itself in the planning of quality-related activities as it deems necessary to ensure that quality assurance i requirements are provided.
Resolutions of differences of opinion between audited and auditing personnel, regarding deficiencies or noncompliances identified by
- NQA shall be made by management. NQA management is authorized to stop work when such work is considered to be a serious quality degradation.
17.2.2.11 ,
The quality assurance program for LGS is documented by written policies and procedures and shall be carried out throughout the life of the plant. Administrative procedures shall control the preparation, review, approval, and distribution of these documents. 1 1
NQA shall review and approve all Administrative Procedures that implement the QA Program. l i The administrative and implementing procedures and instructions
. pertaining to quality-related activities are written to accomplish those activities with appropriate equipment under suitable environmental conditions and in compliance with necessary prerequisites.
J 17.2-26 i E f
_ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ . - _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ - _ _ _ _ _ _ _ _ ____m__._.
Information concerning plant conditions and status will be made available to NQA personnel to enable responsible NQA supervision to determine when audits, surveillances, monitoring, or inspections should be performed. This information may be in the form of communications with plant management or staff personnel through daily or periodic meetings. In a'ddition, NQA personnel shall periodically review operating logs, maintenance work schedules, fuel handling operations schedule, ISI/IST inspection program, and modification proposals, to ensure that NQA personnel are involved in day-to-day activities that are important to the safe operation '
of LGS.
. 17.2.2.13 Personnel performing or verifying quality-related activities shall be:
- a. Trained in the purpose, scope, and implementation of quality-related manuals, instructions, and procedures,
- b. Trained and certified in the principles, techniques, and requirements of the performed activity and such certification shall delineate the specific area of expertise and criteria used.
17.2.2.14 The training / certification program sh'all include documentation of the objective, content, enrolled attendees, date of attendance, and examinations given.
17.2.2.15 7 The training / certification program shall provide for retraining, I re-examination, and/or recertification as appropriate.
. 17.2.2.16 )
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The Superintendent, Independent Safety Engineering Group (ISEG), is responsible for reviewing plant operating characteristics, NRC issuances, and other appropriate resources of plant design and operating experience information that may indicate areas for improving plant safety, and for input and closure of ISEG
- recommendations in the PIMS database.
17.2-26 I
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17.2.3 DESIGN CONTROL 17.2.3.1 Measures shall be established and documented to provide for the control of design functions. The provisions shall identify responsibilities and activities to ensure that the following are accomplished, as applicable, for the particular design:
- a. Design bases are translated into design documents such as drawings, specifications, instructions, and procedures.
- b. Appropriate quality standards are specified and deviations from these standards are identified, controlled, and documented.
Design adequacy is checked by means such as design c.
reviews, alternate calculational methods, or testing programs.
- d. Design reviews include appropriate attributes such as accessibility for ISI/IST inspection maintenance, and repair; suitability of application of materials, parts, equipment, and processes; reactor physics, stress, thermal, hydraulic, and accident analysis; delineation of
. acceptance criteria for inspections and tests; and other design work on Q-listed items or systems.
Records of implementation of these design control e.
measures, as defined in the applicable design control procedures, shall be available for review. !
- f. The responsible engineering organizations ensure that design drawings and specifications are prepared, reviewed, and approved in accordance with procedures and that these documents contain the necessary quality
' ;' assurance requirements, such as inspection and test requirements, acceptance requirements, and the extent of documenting inspection and test results.
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17.2 .
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The design procedures include provision to control design "
interfaces and to allow coordination among participating design organizations. These measures shall include procedures for the review, approval, release, distribution, and revision of documents
' involving design interfaces as appropriate. ,
17.2.3.3 Changes to the design, including field-initiated changes, are controlled and subjected to design measures commensurate with those applied to the original design. Where necessary to ensure proper application of design information or changes, a " place-in-effect" statement shall be included in the appropriate procurement or design document.
17.2.3.3.1 Instructions for the design of modifications shall be written to require compliance to regulatory requirements as defined in 10CFR, Part 50.59, and as defined in the license application in accordance with the design basis of the structures, systems, or components.
17.2.3.3.2 Administrative procedures shall be written which require that '
modifications be reviewed after completion of the work to determine if the "as-built" installation differs from the original design, and that drawings and documents are revised, if required, to reflect the actual installation in a timely manner according to procedures.
17.2.3.4 Approval of modifications shall be delineated in the Administrative Procedures. Design documents for modification shall be
- administered, maintained, and controlled in accordance with
? Administrative Procedures.
I 17.2.3.4.1 As-built documents are controlled in accordance with established ,
procedures which describe a definite method to be followed upon completion of any plant modification. This procedure includes notification of completion by field personnel, mark-up on drawings i of any changes from the original design, and approvals of certain as-built drawings equivalent to tne original design.
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17.2-28=1~
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LGB UFSAR 17.2.3.5 ,
Measures shall be established to assure that the modifications meet design, installation, inspection, testing, and quality assurance ?
standards. Testing of modifications assures system integrity and provides for evaluation of performance prior to operation.
17.2.3.6 Written procedures shall provide design reviews which shall be performed by individuals or groups other than the original designer. The design and design review processes shall provide for preparation of documentation to establish that the design process was used to describe the scope, depth, and results of design reviews. ,
17.2.3.6.1 Design adequacy of modifications shall be determined by an independent design review in accordance with Administrative i Procedures. Thece reviews shall be performed by vendors, cognizant engineers on the plant staff, or in the appropriate PECo
, organization. The reviews shall consist of reviewing the design,
- spot checking the calculations or analysis, and assessing the and results against the original design basis functional requirements.
. 17.2.3.6.2 .
When the adequacy of design is to be verified by test only, procedures and instructions will be written which include measures >
to ensure that:
- a. Criteria are provided to specify when verification should
, be by test.
- b. Where applicable, prototype, components, or feature testing will be performed prior to installation of plant
equipment. In the cases where this cannot be met, the testing will be deferred but not beyond the point when the installation would become irreversible.
- c. Tests will be performed under conditions that simulate the most adverse design conditions, as determined by analysis. ,
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17.2-29[ _ f 1
I,GS UFSAR 17.2.3.7 ; :- The requirements for materials, parts, and equipment, including standard, commercial (o f f-the-shel f) items are defined for procurement by means of a specification-type document which is subjected to design review prior to use. 17.2.3.8 The following is a general description of the process used to control modifications. Because modifications differ in scope and complexity, the activities do not necessarily occur in the sequence listed below, and certain activities may not apply to all modifications.
- a. Modification is requested and evaluated and, if the l concept is accepted, the following steps are taken:
- b. Engineering Work Letter is issued to define the modification and responsibilities for its accomplishment.
- c. A Safety Evaluation is performed to determine if an unreviewed safety question or change to the Technical ,
l Specifications is involved.
- d. A design criteria document is developed to establish the design basis for the modification.
- e. Modification drawings are pr.epared and approved to define '
the design and the work.to be accomplished.
- f. Calculations and design analyses are prepared to substantiate the design.
- g. Specifications and procurement documents are prepared and ;
, issued.
; h. Vendor document submittals, as defined in the procurement documents, are reviewed and approved.
- i. Receipt inspection requirements for procured items are i issued by the appropriate PECo organizations for use in performing receipt inspection.
- j. Installation inspection and testing requirements are developed in cases where procedures do not exist or where special instructions are needed.
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1 I i k 17.2 : . . I
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LGS UFSAR 17.2.4 PROCUREMENT DOCUMENT CONTROL 1 17.2.4.1 Measures shall be established and documented to ensure that applicable regulatory requirements, design bases, and other requirements which are necessary to. assure adequate quality, are included or referenced in the documents for procurement of items and services. Changes in procurement documents shall be subject to the same degree of control as was utilized in the preparation of the original document, as described herein. The documents used for procurement shall specify appropriate requirements for:
- a. Submittal of drawings, specifications, procedures, and plans to PECo. The time of submittal (e.g., prior to use) and the purpose of submittal (e.g., review, approval, or information) shall be specified.
- b. Submittal of records to PECo. The time of submittal (e.g., prior to shipment) and the purpose of submittal (e.g., review, approval, or information) shall be specified.
- p. Retention of records by supplier.
- d. PECo's right of access to supplier facilities and records -
for inspection and audit. and source inspection as determined by the responsible engineer.
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- e. Reporting and disposition of nonconformances from procurement requirements when the vendor's proposed disposition is "use-as-is" or " repair."
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- f. Submittal of documentation that identifies the purchased items and the specific procurement requirements (e.g.,
codes, standards, and specifications) met by the item.
- g. Submittal of documentation identifying any procurement requirements that have not been met.
- h. Design basis technical requirements, including applicable regulatory requirements. ,
- i. Appropriate material and component identification requirements.
l 2 , E^ l 17.2-31-- -
r LGS UFSAR
- j. Appropriate test, audit, and inspection requirements. .
- k. Appropriate requirements for fabrication such as special process procedures.
- 1. Appropriate requirements for handling, storage, packaging, and shipping. ,
- m. Lower-tier procurements.
- n. Any additional documentation requirements.
17.2.4.2 To the extent necessary, procurement documents shall require
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vendors to provide a QA program consistent with the pertinent requirements of 10CFR50, Appendix B, or equivalent alternative measures shall be specified to assure the quality of the product. The program implemented by the supplier shall be approved by the Nuclear Quality Assurance Department prior to initiation of the affected activities. Suppliers shall be required to either (a) impose appropriate QA program requirements on their subtier suppliers, or (b) implement equivalent alternative measures to assure product quality. _ 17.2.4'.3 . Requisitions for nuclear safety-related items shall clearly indicate that the request is for " nuclear safety-related" items.
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17.2.4.4 Documents, and revisions thereto, used for procurement, including the procurement of spare or replacement parts as a part of a
.' modification, are subject to the review and approval process described herein.
17.2.4.5
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Administrative Procedures shall require that a cognizant member of the requisitioning organization determine the technical and quality assurance requirements for a nuclear safety-related item or service. The member shall determine the applicable specifications, ~ drawings, details, and code requirements to be applied to the
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procurement document. The member shall also determine any special controls to be applied such as vendor controls, hold points, and i tests to be performed, along with acceptance or rejection criteria, subvendor controls, vendor check points, test data, test results, special labeling, storage instructions, requirements for reporting nonconformances, shipping instructions, and documentation requirements. 1 s
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17.2-32P-i r
LGS UFSAR 17.2.4.6 : Administrative Procedures shall clearly delineate the . responsibilities and sequence for the preparation, review, approval, and control of the documents used in procurement. Technical and quality assurance requirements are defined in procurement documents. These requirements are subjected to the design review process and are referenced in procurement documents. 17.2.4.7 Nuclear Quality Assurance personnel shall review and approve the documents which define the QA program and quality requirements to assure that such requirements are correctly stated, controllable, and inspectable and that adequate acceptance / rejection criteria are defined. This permits verification that the documents to be used for procurement have been prepared, reviewed, and approved in ! accordance with the QA program. 17.2.4.8 The review and approval of the documents discussed above are performed prior to release as a part of solicitation for bids, ; prior to purchase order award, and prior to the issuance of ; changes. 17.2.4.9 Purchase orders shall be issued . tio suppliers whose quality
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assurance programs have been evaluated for adequacy, or other ;
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appropriate measures shall be defined to assure quality. i
- 17.2.4.9.1 The Materials Management Section and Purchasing Department shall process only approved requisitions in accordance with PECo Procurement procedures and policies.
- I 17.2.4.9.2 l
- I The Purchasing Department shall not alter the requisition of any nuclear safety-related item or service without prior approval of the requisitioning source, except for commercial items such as price, quantities, schedule, F.O.B. terms, etc. Prior approval is l' required from the responsible organization for cases where the requisitioning source is not the PECo organization responsible for j the technical and quality aspects of the item or service. I I
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17.2-33i,, ,
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LGS UFSAR 1 17.2.4.10 i Nuclear Engineering procurement documents for modifications shall be controlled in accordance with administrative procedures. 17.2.4.11
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Procurement documents shall be maintained in accordance with Section 17.2.17, 17.2.5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS 17.2.5.1 Activities affecting quality shall be prescribed and accomplished in accordance with documented instructions, procedures,
. specifications, and drawings which are prepared, reviewed, approved, and controlled in accordance with the PECo QA Program.
17.2.5.2 The procedures for preparing the documents discussed above shall include consideration of appropriate quantitative and qualitative acceptance criteria to verify that important activities have been satisfactorily accomplished. . The activity may be prescribed in job specifications, work - instructions, shop drawings, job tickets, planning sheets, operating or procedure manuals, test procedures, or any other type of written form, provided that the activity is adequately
; described. Quantitative criteria, such as dimensions, tolerances, i and operating limits, and qualitative criteria, such as comparative workmanship samples, shall be specified, as appropriate, for !
determining satisfactory work performance and quality compliances. The review and approval of station procedures is described in i Section 13.5. In addition, PORC, whose members are knowledgeable -
; in quality requirements and administrative controls, reviews the l test and maintenance that are developed in the procedures f ; modification process.
17.2.5.3 The Nuclear Quality Assurance Department shall review and approve - I the following and the revisions thereto: !
- a. The Nuclear Quality Assurance Plan I
- b. Nuclear Quality Assurance Procedures I i
N Y 17.2-3(F- . .
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LGS UFSAR 17.2.5.4 : 3 Limerick Generating Station Administrative Procedures shall be reviewed by PORC and approved by the Plant Manager or his designated alternates and the. Manager, Limerick Quality, NQA Department, and shall be distribute'd to predetermined personnel. These administrative procedures shall contain provisions which . clearly delineate the sequence of actions for the preparation, review, approval, and control of activity implementing procedures, instructions, and drawings. 17.2.5.5 aaplementing procedures, instructions, and drawings shall include, as appropriate, quantitative and qualitative acceptance criteria, sign-offs, and inspection points to assure that important activities are satisfactorily accomplished. Appropriate recording documents, such as log books, Maintenance Request Forms, checkoff lists, or data sheets, shall be used, when appropriate, to assure compliance with the instructions, procedures, and drawings. 17.2.5.6 l Engineering notification to field forces and other engineering - groups for implementation of a modification are given in one or more Engineering Work Letters. The Engineering Work Letter (s) - include the following: .
- a. Scope of work
- b. Engineering, design, and procurement responsibilities
- c. Special testing requirements 17.2.5.'7
- Modification Installation Memoranda are issued by the Installation - Section to define to installation personnel the work operations necessary to perform a modification. The Modification Installation Memoranda include or reference the following:
- a. Modification drawings _
- b. Purchase orders for components
- ' c. Major equipment list P
17.2-35 , g:
LGS UFSAR
- d. Special receipt inspection instructions for each :-
component, when applicable
- e. Listing of work operations, including instructions for performing the operations, showing, when neccesary, which operations are te be ' performed in sequence or concurrently .
- f. Inspection instructions for activities affecting quality
- g. Testing instructions for performing tests 17.2.5.8 Procedures may also include applicable reference to vendor ,
equipment manuals, design drawings and specifications, ~j prerequisites, special precautions, and the delineation of the work to be accomplished. Equipment manuals and manufacturers' instructions shall be readily - available for use. 17.2.5.9 Nuclear Quality Assurance Department personnel shall, in the course quality control, and technical monitoring of the auditing, programs, selectively review the adequacy, completeness, and effectiveness of implementing procedures, instructions, and drawings associated with activities performed under the QA Plan, j J 17.2.5.10 Administrative type procedures shall be written by other organizations participating in quality-related activities supporting operation of LGS under the QA Program. These procedures
, shall contain provisions which clearly delineate the sequence of :
actions for the conduct of safety-related activities. The
; Corporate Nuclear Quality Manager, shall review and approve these administrative procedures to assure compliance with the QA Plan.
17.2.6 DOCUMENT CONTROL 17.2.6.1
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Measures shall be established and documented to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto, which prescribe activities i affecting quality. These measures shall ensure that documents, including changes, are reviewed for adequacy and approved for I release by authorized personnel and are distributed to and used at li l the location where the prescribed activity is performed prior to ll commencing the work. These documents shall be submitted to the LGS l Document Administration Center for inclusion in the Nuclear Records 1 Management System.
- r 17.2-36F- .jf
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LGS UFSAR l 17.2.6.1.1 Changes to documents shall be reviewed and approved by the same - organizations that performed the original review and approval The unless other organizations are specifically designated. reviewing organizations shall have access to pertinent background information upon which to base its approval and shall have adequate .. understanding of the requirements ' and intent of the original document. 17.2.6.2 Those participating in an activity shall be made aware of and shall
- use proper and current instructions, procedures, drawings, and specifications for performing the activity. Participating organizations shall have procedures for control of the documents and changes thereto to avoid the misuse of outdated or inappropriate documents. Procedures will also prescribe the methods (such as training reading lists) by which the personnel participating in an activity are made aware of modifications and >
document changes. 17.2.6.3 Document control measures shall provide for:
- h. Identification of individuals or organizations responsible for preparing, reviewing, approving, and -
issuing documents and revisions thereto.
- b. Identifying the proper documents to be used in performing the activity.
- c. Coordination and control of interface documents.
; d. Ascertaining that proper documents ara being used.
- e. Establishing current and updated distribution lists.
r f. A mechanism for temporary and emergency procedural changes. I
- g. Submittal of approved, issued, controlled documents to the Nuclear Records Management System for indexing and -
retention. e L 17.2-37 . h
LGS UFSAR 17.2.6.4 : ; The QA Plan and Nuclear Quality Assurance Procedures and revisions thereto shall be controlled per NQA Procedures under the authority of the General Manager, NQA. 17.2.6.5 , LGS activity instructions, procedures, and drawings, delineated in the document control requirements of the QA Plan, shall be procedurally controlled and approved in accordance with the Administrative Procedures under the authority of designated, responsible management. These controls establish individual responsibilities for the preparation, review, approval, and distribution that apply to the various quality-related activities. 17.2.6.6 The control of documents shall apply to those records delineated in Section 17.2.17. 17.2.7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES 17.2.7.1 Procedures for the control of purchased material, equipment, and services shall provide for the following activities to be performed - prior to the award of a purchase orde,r or contract:
. a. A line organization (such as the station or a division in the Nuclear Engineering & Services Department) shall have ,
. proposed or concurred in the selection of prospective vendors for material, equipment, or services.
- b. The vendor shall have been evaluated and approved by the Nuclear Quality Assurance Department using one or more of the following methods:
r . 1. Evaluation of the vendor's capability to comply
- with the elements of 10CFR, Part 50, Appendix B, that are applicable to the type of material, equipment, or service being procured or to comply with equivalent alternatives. .
- 2. A review of previous records and performance of vendors who have provided similar articles of the
- type being procured.
i ~r 17.2-38 _
= ; ,
LGS UFSAR
- 3. A survey of the vendor's facilities and QA program ;
to determine its capability to supply a product that meets the design, manufacturing, and quality requirements. 17.2.7.2 The results of vendor evaluations and audits are documented and maintained on file. 17.2.7.3 Measures shall be established and documented to assure that purchased items and services conform to the procurement documents.
- These measures shall include provisions for one or more of the
- following techniques, depending upon the quantity, complexity, and importance to safety of the item being supplied:
- a. Quality assurance audits of the vendor.
- b. Witnessing of selected operations, inspections, or tests which are designated with hold points in the f abrication process.
- c. Periodic or continuous shop surveillance.
- d. Receipt inspection which, depending on the item supplied, may include appropriate testing of the finished product. -
- e. Evaluation of objective evidence of quality furnished by the vendor.
. 17.2.7.3.1 Where required by code, regulations, or specification, documentary evidence that items conform to procurement requirements shall be available at the plant site prior to installation or use of such items. This documentary evidence shall be retained at the plant
- site and shall be sufficient to identify the specific requirements
; such as codes, standards, and specifications met by the purchased item. The documentary evidence shall be indicated on records traceable to the item or on the item prior to release from receiving. Where not precluded by other requirements, such documentary evidence may take the form of written certifications of conformance which identify the requirements met by the items,
- providing means are available to verify the validity of such certificates.
N 17.2-39 _
= .
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LGS UFSAR 17.2.7.4 { Receipt inspections shall be performed to verify that material components or parts received conform to the purchase order requirements. , 17.2.7.4.1 . Receipt inspection shall be performed by personnel who have access to the pertinent procurement documents and who have an understanding of the technical and quality requirements of the procurement document. Responsibility for receipt inspection shall be delineated in Administrative Procedures. 17.2.7.4.2 _ Receipt inspection shall include, as appropriate, visual
^
examination of physical properties, determination and identification of marking or labeling, and review and inspection of quality assurance documentation to verify conformance with the purchase order specifications and requirements.
; 17.2.7.4.3 Nonconforming items shall be identified, segregated (physically separated and/or conspicuously tagged) and controlled until dispositioned. Control and identification status of the received material, parts, or components shall be accomplished in accordance -
with Administrative Procedures. _ 17.2.7.5 The procurement documents shall define or provide for defining the records to be supplied.
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, 17.2.7.6,
- ; Deviations f rom procurement document requirements, including _ those requirements in vendor drawings and procedures which are approved by PECo, shall be submitted to PECo for review and approval when i -
the proposed disposition of such deviations is either "use-as-is" or " repair." PECo approval shall be required prior to the vendor proceeding. The final records for the procured item shall contain documentation of such deviations and of PECo's approval. _ 6
- e 17.2-40h _
= .
LGS UFSAR 1 17.2.7.6.1 The processing of vendor document submittals, including final records, shall be controlled in accordance with written procedures which will assure that the documents are reviewed and, when required by the procurement documents, approved by appropriate . personnel. . 17.2.7.7 Procurement of items or services from other than " Evaluated Vendors" shall be controlled and shall have the concurrence of the General Manager, NQA Department, or his alternate for establishment of procurement requirements to ensure the quality of the product. 17.2.7.8
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Vendors that are on the " Evaluated Vendors List" are audited triennially by NQA commensurate with the importance, complexity, and quantity of the product or service being purchased. I' d 17.2.8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND ', COMPONENTS 17.2.8.1 . I-Measures shall be estab?ished and documented for the identification ,' and control of materials, parts,_and components, including partially fabricated subat:.semblies. These measures shall provide for assuring that only correct and accepted items are used and ~ and relating an item of production (batch, lot,
, installed, component, part) at any stage, from initial receipt through fabrication, installation, repair or modification, to an applicable i drawing, specification, Engineering Work Letter, installation j procedure, inspection and testing instruction, purchase order, or other p~ertinent technical document. Physical identification shall
; be used to the maximum extent practicable. Where physical identification is either impractical or insufficient, physical i
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separation, procedural control, or other appropriate means shall be employed. Identification may be either on the item or on records . Ii traceable to tho item, as appropriate. 17.2.8.2 ' 4; Where identification marking is employed, the marking shall be clear, unambiguous, and indelible, and shall be applied in such a manner as not to affect the fit, function, or quality of the item. Markings shall be transferred to each part of an item when subdivided and shall not be obliterated or hidden by surface treatment or coatings unless other means of identification are substituted. i'
. 7 '
17.2-417-
=
y
LGS UFSAR When codes, standards, or specifications require traceability of ; materials, parts, or components to" specific inspection or test records, the procedures shall be designed to provide such traceability. 17.2.8.3 Measures shall be established to identify and control materials (including consumables) , parts, or components in accordance with written procedures and instructions and shall apply to the fabrication, storage (including shelf-life), and installation or use of the materials (including consumables), parts, or components. 17.2.8.3.1 Consumables, as addressed above, include, but are not limited to, weld filler material, lubricants, chemicals, reagents, and fuels that impact on safety-related equipment. 17.2.8.3.2 Procedures for installation and inspection shall require that the
+ correct identification of materials, parts, and components is
, verified and documented prior to release for fabrication, assembling, or installation. . 8 17.2.'.4 . The identification and control of mat.erials, parts, or components associated with design change activities shall be delineated in Administrative Procedures and shall cover such items as
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traceability to specifications, purchase orders, quality assurance
- documentation, fabrication and installation inspection and functional verification tests prior to use or placement in operation.
17.2.9 CONTROL OF SPECIAL PROCESSES
- . 17.2.9.1 Measures shall be established and documented to ensure that special processes, such as welding, heat treating, coatings, chemical cleaning, and nondestructive examination, are accomplished under -
controlled conditions in accordance with applicable codes, standards, specifications, criteria, and other special , requirements, using qualified personnel, equipment, and procedures. i I k l y 17.2-42K .
.l r 1
{ l
LGS UFSAR Qualification of personnel, procedures, and equipment shall comply ;_ with the requirements of applicable codes and standards. Documentation shall be maintained for currently qualified . personnel, processes, or equipment in accordance with the requirements of pertinent codes and standards. For special processes not covered by existing codes or standards, or where item quality requirements exceed the requirements of established codes _. or standards, the necessary qualifications of personnel, procedures, or equipment shall be defined. 17.2.9.1.1 Special processes are those that require interim in-process control in addition to final inspection to assure quality. 17.2.9.2 Procurement documents shall specify the requirements imposed on the vendor and subcontracted services for the control of special processes. Included shall be requirements for qualification of procedures, equipment, and personnel. Such special processes shall be performed by qualified personnel in accordance with approved procedures. Records of qualification of procedures, equipment, and l personnel shall be established and filed by the vendor and, as
'- required by the procurement documents, shall be submitted to PECo. .
17.2.9.3 The Nuclear Group is responsible for development of special processes performed under the QA Plan. These processes and the personnel implementing them shall be qualified.
. 17.2.9.4 Drawings, specifications, or installation procedures (as
; appropriate for the activity) shall define the specific requirements for special processes performed by PECo during installation.
t 17.2.9.4.1 The qualification of PECo welding procedures and personnel is the responsibility of the Nuclear Training Division, in conjunction with Nuclear Maintenance Division. Such qualification shall be in ~ accordance with the codes, standards, or special provisions applicable to the work being performed. . I
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-T l
. y ^
17.2-43h . l
- w\
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LGS _UFSAR l Certification of welders performing: activities under the QA Plan :. shall be kept current through rhcords of qualifying tests, recording of welds on current work, retraining and qualifying for specialty work in accordance with Administrative Procedures and Section XI of the ASME B&PV Code. . 17.2.9.5 . Review and approval of special process procedures shall be accomplished in accordance with Administrative Procedures. 17.2.9.6 The nondestructive examination (NDE) procedures for the ISI/IST Inspection Programs shall be written in accordance with applicable codes, standards, and specifications. l 17.2.9.6.1 NDE procedures shall require that personnel performing these examinations be qualified in accordance with the recommendations of the American Society for Nondestructive Testing Practice No. ASNT-TC-1A, " Recommended Practice for Nondestructive Testing Personnel Qualification and Certification." 17.2.9.7 The qualification and certification of PECo nondestructive - examirjation (NDE) personnel and proceflures are the responsibility of the NDE Support Section of NQA. Qualification and certification of NDE personnel shall be accomplished in accordance with
^
established NQA procedures, which follow the guidance of ASNT-TC-1A. The qualification of procedures shall be in accordance with the ASME Code, Section V.
," 17.2.9.8
- . Records of qualification of procedures, ecpipment, and personnel
- ** associated with special processes shall be established, filed, and kept current. Results of special processes performed shall be '
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documented, in accordance with approved instructions and procedures. 17.2.9.9 . The NQA auditing, quality control, and technical monitoring programs provide assurance that the qualificatio1. of special - processes, the equipment used, and the qualifications of personnel are satisfactorily performed. 1 s 17.2-44 .
LGS UFSAR 17.2.10 INSPECTION - ; 17.2.10.1 A program for inspection of activities affecting quality shall be established and executed by the : organization performing the activity to verify conformance to the documented instructions, procedures, and drawings for accomplishing the activity. Inspection activities to verify the quality of work shall be performed by persons other than those who performed the activity being inspected. Such persons shall not report directly to the immediate supervisors who are responsible for the work being inspected. 17.2.10.2 Inspection requirements for purchased materials, parts, and
- components and for installation activities shall be established to verify conformance of quality affecting activities with established requirements. The inspection requirements and inspection results shall be documented.
17.2.10.3
- The inspections to be performed shall be defined in drawings, specifications, Engineering Work Letters, or inspection / _
installation procedures, as appropriate for the activity. The inspections shall be performed in accordance with written . procedures or instructions. The results shall be documented, evaluated, and their acceptabilit determined by qualified
. individuals. Evaluation beyond that given by inspection-level personnel shall not normally be required for go/no-go and pass / fail
. type inspections.
17.2.10.3.1 The inspection procedures or instructions shall:
. i. a. Identify the characteristics and activities to be ,, inspected, including establishment of inspection hold points where appropriate.
- b. Identify the individuals or groups responsible for performing the inspection operation. _
. c. Define the acceptance / rejection criteria.
17.2-45E ~y V F
LGS UFSAR
- d. Provide instructions for- performing the inspection, ;
including the inspection methods, a description of the necessary measuring and test equipment and the appropriate accuracy requirements.
- e. Require recording evidence of completing / verifying the ,
activity and the results. .
- f. Require identification of the inspector / data recorder and recording the results of the inspection.
- g. Be reviewed by qualified personnel knowledgeable in NQA disciplines to ensure inclusion of items listed above.
17.2.10.4 The inspection programs for modifications and nonroutine
- maintenance work shall be accomplished by qualified NQA personnel who are independent of the group or individual performing the work.
17.2.10.4.1
. Examinations, measurements, or tests of items shall be performed j for each work operation where necessary to assure quality.
17.2.10.4.2 _ Modifications for which Nuclear Engineering is responsible shall la . inspected in accordance with Nuclear Engineering Division approved
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requir'ements. 17.2.10.5 Inspection personnel are responsible for assuring that the necessary instructions, drawings, or other documents related to the inspection are current and used. 17.2.10.6
; Where direct inspection cannot be used to verify satisfactory completion of quality affecting activities, indirect methods (such as monitoring process methods, equipment, and personnel) may be used. When necessary, both direct and indirect inspection will be specified.
. 17.2.10.7
. If mandatory inspection hold points, which require witnessing or inspecting and beyond which work shall not proceed are required, the specific hold points shall be indicated in appropriate procedures. Such inspection shall be documented prior to the continuation of work beyond the designated hold point.
1 s 17.2-460E y . .
?
LGS UFSAR The procedures shall include the characteristics to be inspected, ; a description of the method of inspection, acceptance / rejection criteria, a description of necessary measuring and test equipment . (including appropriate accuracy requirements), and the identification of the individual or. group responsible for inspection. Satisfactory completion of inspection points shall be documented and shall be included in the documentation associated with the performance of the work. Verification of equipment operability following maintenance and modification work shall be accomplished, along with inspection of the work area for safety, housekeeping, cleanliness, and health
- physics practices.
17.2.10.8 Appropriate NQA Department management have rufficient authority to stop work. Such authority is defined in administrative procedures. 17.2.10.9 Personnel performing quality control inspections shall be qualified
' - in accordance with applicable industry standards and company training programs. Certification of inspector qualifications shall -
be maintained in accordance with procedures. 17.2.10.9.1 , The code authorized inspector shall assure that the ASME B&PV Code
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inspections are performed in accordance with written approved
. procedures and accomplished by qualified personnel in accordance with ASME Code requirements.
; 17.2.10.10 A program for the required ISI/IST inspection of completed systems,
- structures, and components shall be planned and executed by or for i the organization responsible for operation of the plant.
17.2.10.11 Job performance of each inspector is periodically evaluated to assure that the inspector is performing in accordance with the - qualification specified for the job. Qualification requirements
- for nondestructive testing personnel are described in Section -
- ' 17.2.9.
17.2-47 ( ^ i
LGS UFSAR 17.2.10.12 y NQA shall perform surveillance of selected quality-related
" work-in-progress" activities commensurate with the importance of such activities to verify that certain aspects of the Quality Assurance Program are performed adequately and in compliance with program and procedural requirements. ,
Procedures shall be selectively reviewed, as appropriate, in the course of activities performed during NQA audits, technical monitorings, and inspections to assure that necessary inspection points are included and that a mechanism is provided for the documentation of inspection results. 17.2.10.12.1 If individuals performing inspections are not part of the NQA organization, the NQA Department will assure through the audit, quality control, and monitoring programs that the inspection procedures, personnel qualification criteria, and independence from undue pressure, such as cost and schedule, are acceptable. 17.2.11 TEST CONTROL 17.2.11.1 A test program shall be established to ensure that all testing - required to demonstrate that an item will perform satisfactorily in service is identified and documented. The testing shall be
. performed in accordance with written test procedures, drawings, specifications, or installation procedures which incorporate or
- reference the requirements and acceptance limits contained in applicable Technical Specifications and design documents.
The program for the control of testing shall be established in accordance with Administrative Procedures.
- - 17.2.11.2 t
The test program shall cover all required tests, including, as appropriate, qualifications tests, postmaintenance or modification tests, and operational surveillance tests to verify continued satisfactory performance during operation. Where appropriate, vendor documents and instructions shall be used as input for
- determining required tests. .
17.2.11.3 When such testing is required, approved test procedures shall incorporate or reference: e # 17.2-48% r emme
LGS UFSAR
- a. The requirements and acqeptance limits contained in -
applicable design and procurement documents.
- b. Instruction steps for performing the test.
- c. Applicable test prerequisites such as:
- 1. Use of calibrated instrumentation.
- 2. Adequate and appropriate equipment.
- 3. Identification of responsibilities to perform the test, including any special personnel qualification requirements.
- 4. Completeness and preparation of the item to be tested.
- 5. Suitable and controlled environmental conditions.
- 6. Provisions for data collection, review, and disposition.
l-
- d. Necessary monitoring including mandatory inspection hold points.
- e. Acceptance / rejection criteria.
- f. Methods of documenting or recording test data and results.
I g. Requirements related to evaluation and acceptance of test
. data.
Evaluation beyond that given by testing personnel is not normally required for go/no-go and pass / fail tests. 17.2.11.4 i Measures shall be established such that when an activity involves breaching a pressure-retaining item, the quality of the work can be demonstrated through a functional test. The functional test shall be performed by individuals other than those who performed or directly supervised the work, but can be from within the same group. - 4 17.2-49 _ ,
LGS UFSAR 17.2.11.5 y Test results shall be documented and their evaluation and acceptability determined as defined in the test procedure or in the procurement documents. . Unsatisfactory test results shall be documented as required by ._ procedures, and corrective action shsll be taken in accordance with Administrative Procedures. 17.2.11.6 Modifications, repairs, and replacements shall be tested in accordance with the original design and testing requirements or to
- approved alternatives.
17.2.11.7 The Technical Specifications establish the requirements for the safe operation of the plant, including provisions for periodic and nonperiodic tests and inspections of various structures, systems, and components. Periodic tests are those test delineated in the
- surveillance testing activity and nonperiodic tests are those proof i~ tests performed following modifications or major maintenance.
1 - 17.2.11.8 Overall control of tests affecting plant operations shall be . , accomplished by Shift Operations personnel to assure that testing of com'ponents, systems, and instruments does not adversely affect
. the safe operation of the plant.
. 17.2.11.9 In addition to the above testing program, an ISI/IST Inspection Program has been developed and shall be implemented to ensure that plant components perform satisfactorily in service. The program shall include baseline examinations and periodic examinations in
) accordance with Technical Specifications.
t 17.2.12 CONTROL OF MEASURING AND TEST EQUIPMENT 17.2.12.1 ,
- Measures shall be established and documented to assure that tools,
- gages, instruments, and other inspection, measuring, and testing -
. ' equipment and devices used in activities affecting quality are of
- the proper range, type, and accuracy to verify conformance to established requirements. To assure accuracy, inspection, measuring, and test equipment shall be controlled, calibrated, adjusted, and maintained at prescribed intervals or prior to use 1 s 17.2-50 .
= , ,
LGS UFSAR against certified equipment having known valid relationships to - nationally recognized standards. If no national standards exist, the basis for calibration shall be documented. This requirement is l not intended to imply a need for special calibration and control ' neasures on rulers, tape measures, levels, and such other devices, ! if normal commercial practices provide adequate accuracy. f l 17.2.12.2 The method and interval of calibration for each item shall be ; defined and shall be based on the type of equipment, stability ' characteristics, required accuracy, and other conditions affecting measurement control. Special calibration shall be performed when accuracy of the equipment is suspect. When inspection, measuring, and test equipment is found to be out of calibration, an evaluation
- shall be nade and documented of the validity of previous inspection or test results and of the acceptability of items previously inspected or tested. If any inspection, measuring, or test equipment is consistently found to be out of calibration, it shall be repaired or replaced.
17.2.12.3 Reference standards used for calibrating measuring and test
- equipment should have an accuracy level, acceptable calibration ranges, and precision that are better than those required of the -
neasuring and test equipment. When this is not possible, reference standards with the same accuracy nay be used if they can be shown . to be adequate for the requirements and if the basis of acceptance is documented and authorized by respohsible management.
- The accuracies of neasuring and test equipment and the reference standards shall be chosen such that the equipment being calibrated l can be calibrated and maintained within the required tolerances.
- Records shall be maintained and equipment suitably marked, or otherwise controlled, to indicate calibration status. Such records shall be traceable and retrievable. \
i l Calibration of measuring and test equipment should be against reference standards that have an accuracy of at least four times j the required accuracy of the equipment or, when this is not possible, has an accuracy that assures the equipment being calibrated will be within required tolerance and that the basis of ; acceptance is documented and authorized by responsible management. -
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8 1 : j 17.2-51 , s :
LGS UFSAR 17.2.12.4
- 1 Laboratories Division is responsible for the The Corporate calibration program and performs a calibration service for the Engineering Operations, Maintenance, Installation, and organizations at LGS.
17.2.13 HANDLING, STORAGE, AND SHIPPING , 17.2.13.1 , Measures shall be established, documented, and implemented to control handling, storage, and shipping, including cleaning,
- packaging, and preservation of material and equipment in accordance - with established instructions, procedures, or drawings, to prevent damage, deterioration and loss before and after receipt. When necessary for particular items, any special coveringc, special equipment, or special protective environments, such as inert gas atmosphere, specific moisture content levels, and tenperature levels, shall be specified and provided, and their existe. ice shall be verified.
j 17.2.13.2 As required by the procurement documents, vendor procedures shall - provide control over cleaning, preservation, packaging, and
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shipping to assure that items are delivered in acceptable - condition. , 17.2.13.2.1
- Storage requirements shall be defined by cegnizant personnel unless y special instructions are provided by the vendor and approved by [l appropriate cognizant personnel. y
)
17.2.13.2.2 , 5 Special handling tools important to nuclear safety shall be i
;. inspected and tested in accordance with written procedures and at specified times, to verify that the tools and equipment are adequately maintained. 9 17.2.13.2.3 _
- Packaging requirements shall be delineated, as necessary to avoid >
- deleterious effects of shock, vibration, physical damage, and -/ -
protection against environments. l T c-17.2-52 -- . j e;
~r 1
LGB UFSAR 17.2.13.2.4 3 Shipping requirements shall be delineated, as necessary, toLabeling provide adequate protection during loading and transit. requirements are to be applied in a manner that is clearly visible or handling and remain legible to specify special controls instructions. . 17.2.14 INSPECTION, TEST, AND OPERATING STATUS 17.2.14.1 identify Measures shall be established and documented to inspection, test, and operation status. Such measures shall provide means for assuring that required inspections and tests are performed and that the acceptability of items with regard to inspections and tests performed is known throughout procurement, installation, and operation to preclude inadvertent bypassing or altering the sequence of such inspections and tests. 17.2.14.2 i Bypassing of, or deviation from (i.e. , altering the sequence of) , required inspections, tests, or operations defined in controlled drawings and installation or testing procedures shall be by - procedures. In general, such actions shall be subject to the same unless other and controls as the original review approval provis. ions are specified. . 17.2.14.3
- Nonconforming items shall be clearly identified to prevent inadvertent use.
17.2.14.4
; A receipt inspection program shall be documented and the physical
? segregation of items which have not satisfactorily completed r receipt inspection shall be employed to assure that the status of
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items can be determined. Items which are found deficient during receipt inspection shall be " hold tagged" until the deficiency is resolved. 17.2.14.5
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During installation and testing, status shall be determinable : through use of the instructions for installation, installation inspection records, and test procedures / records. l
= :
3' I E . 17.2-537- . ,
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LGS UFSAR 17.2.14.6 y The inspection and test status of items shall be maintained through the use of status indicators such as physical location, tags, markings, shop travelers, stamps, or inspection records. The measures shall provide for assuring that only items that have passed the required inspections and tests are used, installed, or operated. 17.2.14.7 Measures shall also provide for indicating the operating status of systems and components of the nuclear power plant, such as by tagging valves and switches, to prevent inadvertent operation.
- 17.2.14.8 The operating status of components under test or inspection shall be indicated and controlled through the use of Administrative Procedures, procedure checklists, or logs to prevent inadvertent use.
. 17.2.14.9
- The application and removal of inspection and status indicators, such as tags, markings, labels, and stamps, shall be controlled by _
procedures for these activities. 17.2.14.10 . Defective material, parts or components shall be promptly
- identified, tagged and recorded or otherwise controlled to indicate cperating status of such equipment and to prevent its inadvertent use.
17.2.14.11 Implementation of these measures shall be verified through the NQA
- '. auditing, quality control, and technical monitoring prograns conducted in accordance with the QA Plan. These activities shall
- assure that the required inspections and tests are procedurally controlled as required by the QA Plan.
e W
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I i j 17.2-54[ _ xf e : '
LGS UFSAR NONCONFORMING MATERIALS, PARTS, OR COMPONENTS ; 17 .2.15 17.2.15.1 Measures shall be established and implemented to control materials, parts, or components which do not conform to requirements to prevent their inadvertent use or installation. The measures established shall include, as appro'priate, administrative and/or for the following functions implementing procedures for nonconforming materials, parts, or components.
- a. Identification. As a guideline, control of nonconforming items by tagging, marking, or other means of identification is acceptable where physical segregation is not practical, although physical segregation and
- marking are preferred.
- b. Segregation where necessary and possible; otherwise, identification will serve this function.
- c. Describe the nonconforming condition (s).
- d. Disposition covering:
- 1. A description of the disposition. _
- 2. Restoration to conforming status. Repaired and reworked items shall be reinspected in accordance .
with applicable procedures, or
- 3. Define the repair method and associated inspection and test requirements for " repair" dispositions.
- 4. Replacement with conforming material, or
- 5. Acceptance for interim use until replaced. Such measures shall provide assurance that the item is !
identified as nonconforming and controlled. The
- measures shall require documentation verifying the acceptability of nonconforming items which have the disposition of " repair" or "use-as-is." A description of the change, waiver, or deviation that has been accepted shall be documented to record the change and denote the as-built t
condition.
- 6. Provide the engineering rationale / justification and -
- independent review for "use-as-is" or " repair"
- dispositions.
- 7. Signature approvals and dates.
1 b 17.2-55k _h 5 f i
LGS UFSAR
- e. Notification to station management and other responsible ; .
organizations of equipment malfunctions or deviations. The notification system shall include provisions for initial and follow-up information until the item is finally dispositioned.
- f. The responsibility and authority for the disposition of ,,
nonconforming items shall be defined for each responsible organization.
- g. Documentation of each item from first identification to final disposition.
- h. Be included or referenced in the records package for the
. affected item.
17.2.15.2 Procurement documents shall require that vendors report deviations from purchase order requirements to PECo. This includes deviations from vendor drawings and procedures that have been approved by PECo. 17.2.15.2.1 Vendor corrective action shall be evaluated and approved by Nuclear - Engineering (for "use-as-is" and " repair" dispositions involving - technical requirements) and by NQA. For "use-as-is" and " repair"
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dispositions which affect particular hardware, a copy of the dispos'itioned report shall be included in the records package for
- the affected item.
. 17.2.15.2.2 Deficiencies identified by PECo during source surveillances/ audits shall be reported in accordance with applicable procedures.
- 17.2.15.3
- i. Nonconforming items identified during receipt inspection shall be
" hold tagged" and reported in accordance with written procedures.
Nuclear Engineering or the Procurement Engineering Group within the Materials Management Section, is responsible for providing/ approving the disposition. _ 2, 17.2-56p _ f {
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LGS UFSAR 17.2.15.4 Nonconforming items identified during installation activities and postinstallation testing activities shall be identified and reported in accordance with administrative procedures. A copy of the dispositioned report shall be included in the records package for the affected item. , 17.2.15.5 Nonconforming materials, parts, or components shall be reported to station management in accordance with applicable procedures. 17.2.15.6 NQA reviews nonconformance reports to confirm that the approved disposition adequately addresses the concern and has been properly implemented; and to identify significant conditions requiring further action. 17.2.15.7 Procedures shall provide for analyzing nonconformances for trends, l for performing a periodic revisc* and assessment of the trending data, and for reporting the results of such reviews to the appropriate level of management. - 17.2.15.8 It is PFCO's policy and intent that non' conforming materials, parts, or components not be installed in LGS. Where technical adequacy is
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demonstrated to PECo's satisfaction, use of some nonconforming
- materials, parts, or components may be permitted. When this is done, a complete record shall be available throughout the life of the material, part, or component. In no case will use of
; nonconforming materials, parts, or components be permitted if a hazard to the health End safety of the public could result from
! their use. Administrative Procedures shall delineate acceptance and approval mechanisms for permitting use of nonconforming i materials, parts, or components.
17.2.15.9 Where rework of a nonconforming item invalidates a previously completed test or inspection, the test or inspection shall be
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reperformed unless the approved disposition specifies otherwise. The testing and inspection of a repair shall be as given in the ' i approved disposition of the nonconforming item. c .# 17.2-57p:_ _
LGS UFSAR 17.2.15.10 3 PECo shall report abnormal occurrences and unusual events to the - USNRC as required by NRC Regulations and LGS Technical Specifications. ~ l 17.2.16 CORRECTIVE ACTION 17.2.16.1 Measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. Conditions adverse to quality are failures, malfunctions, deficiencies, deviations,
- defective material and equipment, and nonconformance to specified ! requirements. Tha measures established shall include the following:
- a. In cases of significant conditions adverse to quality, the cause of the condition shall be determined and documented, and corrective action taken and documented to preclude recurrence, i b. Reports to PORC, NRB, and appropriate levels of
' ' management of the significant condition adverse to quality and documentation of such reports. -
17.2.16.2 Administrative Procedures shall require that modification and repair procedures include the reworking of components, systems, or
~
structures in accordance with original specifications, instruction
- manuals, instructions, prints, and codes and standards. Appropriate testing and inspection requirements shall be included to verify acceptability of the repairs or modifications.
[ 17.2.16.2.1 The above responsibilities are assigned to the LGS staff members
. responsible for the various activities.
17.2.16.3 Procedures shall be established to assure that conditions adverse - to quality are controlled. These procedures shall include the following: W e g h t
.q [
17.2-Sap = u
LGS UFSAR
- a. Identify the individuals or groups who shall authorize
~
the corrective action. - b. Assure that the NQA organization that has responsibility for the job performs a review of the planned corrective action.
- c. Document the cause, if it'can be identified.
- d. Identify and document, if possible, the root cause.
- e. The appropriate staff engineer shall review the corrective action and equipment history to determine equipment performance trends, to identify repetitive
- failures, and to adjust, if applicable, the preventive maintenance program.
~
17.2.16.4 NQA may identify conditions which require corrective action. Such for conditions shall be reported to responsible management corrective action in accordance with applicable procedures. l 17.2.16.4.1 Dependent on factors, such as the nature ofNQA theshall deficiency, the cause, and the corrective action taken, follow-up corrective action of deficiencies identified by NQA to determine - the adequacy and effectiveness of .such action. The follow-up reviews to verify proper implementation of reported corrective actions shall be documented. 17.2.16.4.2 Written procedures shall establish methods for monitoring the
,~ prompt resolution and close-out for each of the mechanisms used to report ~ conditions adverse to quality.
17.2.16.4.3
~
The status of conditions adverse to quality identified by technical monitoring, inspections, audits, or surveillances shall be reported to the Senior Vice President, Nuclear; the responsible Vice President; and the appropriate supervision. . 17.2.16.5 , Corrective action performed in response to an item identified by NQA shall have the documented concurrence of NQA for the adequacy of the corrective action.
= .
17.2-59 h
LGS UFSAR 17.2.16.6 y . Procedures shall require NQA review and concurrence with the adequacy of prescribed corrective action for nonconformance reports. NQA periodic audits of the NCR procedure include verification of proper implementation of corrective action. 17.2.17 QUALITY ASSURANCE RECORDS 17.2.17.1 Sufficient records shall be maintained in accordance with Administrative and Implementing Procedures to provide documentary evidence that activities affecting quality are performed adequately
- and in compliance with the Quality Assurance Program. The requirements shall include required records, collection, filing, storing, and disposition including transmittal responsibilities and processing requirements. These requirements shall comply with the Plan and applicable codes, standards, specifications, or QA regulatory requirements and shall be specified in procurement documents, drawings, and procedures. The procedures to be employed to perform the required activities shall be planned and documented.
17.2.17.2 _ QA records shall include results of reviews, inspections, tests, and material analysis; operating logs; QA surveillances or audits; - qualification of personnel, procedures, and equipment; and other documentation such as drawings, specifications, procurement
- documents, calibration procedures and reports, reportable
~
occurrences, maintenance and modification procedures, nonconformance and corrective action reports, and other records required by technical specifications. 17.2.17.3 The significance of the event covered by a record type and the contribution of the record to the ability to reconstruct i significant events shall be considered in establishing retention periods. Retention periods shall satisfy applicable statutory requirements. Some types of quality records with minimum retention periods are listed in LGS Technical Specifications. For records not listed in
- the Technical Specifications, the type most nearly describing the
- record in question should be followed with respect to its retention
. > period.
l 17.2-Goh _.
^
{
LGS UFSAR 17.2.17.4 : ,
- i Records retained by PECo shall be identifiable and retrievable; and storage requirements shall be established for the maintenance, preservation, and protection of records from their completion through submittal into the Nuclear Records Management System. The records shall be stored in predetermined locations theft, to prevent and destruction of the records by ' fire, flooding, deterioration by environmental conditions as required by applicable standards, codes, and regulatory agencies.
17.2.17.5 Applicable design specifications, procurement documents, test
- procedures, operational procedures, and other documents shall specify the quality records to be generated. The procurement documents shall specify the records to be provided to PECo, the
- time of submittal, and whether or not PECo approval is required.
All of the above records shall be legible, filled out to the extent required, and adequately identifiable to the item or activity involved. 17.2.17.6 I - When records are retained by vendors, the storage, maintenance, preservation, and protection requirements shall be specified in the - procurement documents and the vendor shall be required to provide PEco with an index of the records not provided with the item. . , 17.2.1'7.7
~
The applicable quality records shall be considered valid only if stamped, initialed, signed, or otherwise authenticated and dated by authorized personnel. These records may be either the original or a reproduced copy and shall be submitted to the LGS Document I Administration Center for inclusion in the Nuclear Records : Management System. 17.2.17.8 , Inspection and test records shall contain the following where 1 . applicable:
- a. A description of the type of observation, including procedure used and revision level. l
\
- b. Evidence of completing the operation. -
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-: 3 E-17.2-61p ...'
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1 LGS UFSAR
- c. Date and results. .
- d. Information related to conditions adverse to quality. i
- e. Inspector or data recorder identification. i
- f. I'vidence as to the acceptability of the results. ,
17.2.17.9 , L NQA and ot he : m:.>nizaticus responsible for record control are defined in th > ,.dt. istredive and Implementing Procedures.
- 17.2.18 AUDITS 17.2.18.1 Compliance with the requirements and guidance for establishing and implementing the Quality Assurance Program is assured through the NQA auditing program for PECo nuclear organizations and vendors.
17.2.18.2 I - The NQA auditing program shall consist of: _
- s. Audits - Documented activities rformed in accordance with ANSI N45.2.12 as described in Appendix 17.2.II. -
15 . surveillances - Documented a'ctivities identical to Audits except that no formal audit plan and audit checklist are
~
generated and no exit interview is conducted if no are
. noncompliances are identified. Surveillances normally initiated on short notice based on plant conditions and may include observation of work in process.
. 17.2.18.3
- . "he aspects covered by the auditing program include designing, purchasing, fabricating, handling, shipping, storing, cleaning, modifying, and erecting, installing, inspecting, testing, maintaining LGS Q-Listed structures, systems, and components. In addition, audits may be performed on non-Q activities that will -
enhance operational safety as determined by appropriate management. Any procedures, instructions, drawings, procurement documents (for
> vendors), activities, work-in-progress, processes, hardware
- documents, or records that are related to the :.tems above are subject to objective audit evaluation for compliance with the PECo QA Program.
1 4 17.2-62h _U fi;
~
LGS UFSAR l 17.2.18.4 NQA is responsible for the planning, performance, reporting, and follow-up of the auditing program for the various aspects of the QA Plan to determine compliance with the elements and effectiveness of the QA Plan. - 17.2.18.5 Audits and Surveillances shall be performed in accordance with written procedures by NQA personnel, who are independent of any direct responsibilities for the performance of activities which they will audit. NQA may request the assistance of personnel from other disciplines or technical specialist who are independent of
- areas being audited.
The General Manager, NQA, shall estaolish the auditing program < personnel qualifications and the requirements for the use of technical specialists to accomplish the auditing of the Quality Assurance Program. Personnel shall be selected for quality assurance auditing assignments based on experience or training which establish that their qualifications are commensurate with the complexity or special nature of the activities to be audited. In selecting personnel for auditing assignments, consideration shall i be given to special abilities, specializedcharacteristics, technical training, and personal prior pertinent experience, education. . 17.2.18.6 _ Audits shall be regularly scheduled on the basis of the status and safety importance of the activities. The following activities of
- the Quality Assurance Program are described in the QA Plan and shall be audited at least every 2 years, except as otherwise indicated:
- a. Training (Unit staff is audited annually)
- b. Health Physics t
- c. Chemistry
- d. Fuel /In-vessel Material
- e. Shift Operations
- f. Surveillance Testing
- g. Maintenance of Instruments l
l t . i 17.2-635::_ r
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LGS UFSAR ISI/IST h.
- i. Maintenanta/I&C
- j. Procurement -
- k. Modifications ,
- 1. Radioactive Waste Material
- n. Plans - Includes:
Fire Protection Plan Emergency Plan (audited annually)
- Physical Security Plan (audited annually) radiological Environmental Monitoring Program (audited annually)
- n. Nuclear Engineering .
Other areas that shall be subject to scheduled audits include preparation, review, approval, and control of specifications, procurement documents, instructions, procedures, and drawings; receiving and installation inspections; and vendor activities. { Regularly scheduled audits may be supplemented by unannounced or - unscheduled audits or surveillances as determined by the NQA.
- 17.2.18.7 .
Audit and surveillance procedures shall require that
~
nonconformances which are identified be documented in sufficient
- detail to assure that required corrective action can be effectively carried out by the audited organization. Corrective action may be recommended, as appropriate, by NQA.
17.2.18.8 Responsible management shall take the necessary action to correct i- any identified deficiencies and to report the cause of the
~
deficiency and the corrective action to NQA. Unless justified in writing as not appropriate, corrective action intended to prevent recurrence shall also be taken and reported.
~
17.2.18.9 When corrective action measures are indicated, follow-ups or
=
re-audits of applicable areas shall be conducted, to assure implementation and effectiveness of corrective actions. u -* E 17.2-64pL . . -
I LGS UFSAR l Im 17.2.18.10 } l The results of the auditing program shall be documented by NQA and e distributed to the appropriate levels of management including the i management of the audited area. Audit results shall be analyzed and a statement regarding the ,_ effectiveness of the QA Program in the areas audited shall be included in the Audit Report. 17.2.18.11 Audits performed under the cognizance of the Nuclear Review Board are discussed in Section 13.4. 17.2.18.12 The auditing program shall be periodically reviewed and revised as necessary to assure that coverage and schedule reflect current activities. 17.2.18.13 l The General Manager, NQA, is responsible to identify overdue
'* corrective action to the appropriate responsible management. .
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LGS UFSAR Apperdix 17.2.1 10cFR50, APPoiDIX B CRITERION MATRIX Page 1 of 1 10CFR50. Annendix 8 Criterion i 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 X X X X X X X Nuclear Group Manual (Vision, Mission, Philosophy, Values, Organization, Policies, and Directives) X X X X X X X X A &inistrative Procedures AA C-Series and A-C-Series X X X X X X Procurement Procedures (P) P-Series X X X X X X X X X X Nuclear Quality Assurance Procedures NCA-Series X X X X X X X X Nuclear Engineering Procedures NED- and NEDP-Series X X Modification Procedures X X X X MOD-Series s
- s<i, X X X 'X X X I N' I Maintenance Procedures X % X X MA-Series and M Series X X X X X Testing Laboratory Procedures TL-Series X X X Nondestructive Examination Procedures NDE-Series X
Welding Procedures WP-Series X X Section XI A &tinistrative Manual X X X X X X X X X X X Station Achinistrative Procedures A-Series l I t i , . . , . :..s. , .
., %,e ,i
LGS UFSAR I i APPENDIX 17.2.II l l PECO'S APPLICATION OF INDUSTRY STANDARDS I AND USNRC REGULATORY GUIDES l Philadelphia Electric Company follows the ANSI Standards and USNRC Regulatory Guides as described below. Documents referenced in ANSI Standards are excluded unless they are addressed separata3y. . 1 Unless stated otherwise, PECo shall comply with the documents l listed below during the operational phases of LGS. PEco shall ! comply with these documents for operational activitier that are I comparable in nature and extent to related design or construction I activities as determined by the following as appropriate, LAS-Vice ! President, General Manger, NQA and Senior Vice President, Nuclear. l l Reculatorv Guide 1.28, March 1978, Quality Assurance
- a. ,
Program Requirements (Design and Construction), j See Regulatory Guide 1.33. Reculatory Guide 1.30, August 1972, " Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electrical Equipment." Endorses ANSI N45.2.4-1972. PECo shall comply with Regulatory Guide 1.30, August 1972, and ANSI N45.2.4-1972, except for the following alternatives:
- 1. ANSI N45.2.4, Section 1.1, Scope - PECo's alternate to classification of Class I and IE electric power, instrumentation, and control equipment is to apply the requirements of this standard to PECo "Q-listed" items (those instruments, equipment, and systems that prevent or mitigate the consequences !
of postulated accidents that could cause undue risk to the health and safety of the public). l I l 17.2.II-1 1 l l
LGS UFSAR
- 2. ANSI N45.2.4, Section 3, Preconstruction Verification - Subsection (3) requires the checking of records of protective measures maintained during ,
storage for conformance to storage requirements. ANSI N4 5. 2. 2-1978, Section 6.4, Control of Items in Storace, requires inspection and examination during the storage period. The responsibility within PECo for these inspections. rests with Materials Management. Compliance with these requirements for checking of records is assured through the auditing and quality control programs conducted- NQA Department personnel along with the monitoring of Materials Management activities by Materials Management supervision.
- 3. ANSI N45.2.4, Section 7, pata Analysis and Evaluation - A program for processing, reviewing, and analyzing electrical equipment and instrumentation inspection and test data for acceptability is provided in the administrative procedures which govern the repair, maintenance, and testing of electrical equipment and instrumentation. Maintenance is controlled through the use of a work request form that has provisions for cognizant personnel sign-off after completion of the work. Functional testing and calibration procedures, include provisions for review, analysis of data, and approval by ' signature of cognizant personnel.
- 4. ANSI N45.2.4, Section 6.2.1, Ecuipment Tests -
Installed items requiring calibration are controlled through the preventive maintenance computer tracking system. Tags or labels are not affixed to the item to indicate calibration status.
- c. Reculatory Guide 1.33, Revision 2, February 1978,
" Quality Assurance Program Requirements (Operations)."
Endorses ANSI N18.7-1976/ANS 3.2. PECo shall comply with Regulatory Guide 1.33, Revision 2, February 1978 and ANSI N18.7-1976/ANS 3.2 during the operational phase except for the following clarifications or alternatives:
- 1. Regulatory Guide 1.33, Section C.4 and ANSI N18.7-1976/ANS 3.2, Section 4.5, Audit Procram - The audit program carried out by the Nuclear Quality Assurance Department shall be performed in such a manner that individual activities of the QA Plan-are investigated within a period of two (2) years.
This investigation shall consist of either audits or surveillances. See Section 17.2.18. , 17.2.II-2
LGS UFBAR
- 2. Regulatory Guide 1.33, Section C.4.c and ANSI N18.7-1976/ ANSI 3.2, Section 4.5, Audit Procram (second paragraph) - The word " performance" means !
t the implementation of the training program, participation in the training program by .; individuals, and the comparison of documented j qualifications with established requirements. ! Activities and records associated with confidential ' employee performance reviews and subjective evaluation of personnel capabilities are ! specifically excluded from the audit program.
- 3. Regulatory Guide 1.33, Section C.S.c and ANSI ,
N18.7-1976/ANS 3.2, Section 5.2.4, Special Orders - and Section 5.2.4, Temporary Procedures - The types , of procedures described in these sections are not : expected to be used at LGS. Administrative- ; Procedures will specify mechanisms for temporary , changes to existing procedures.
- 4. ANSI N18.7-1976/ANS 3.2, Section 4.3, Independent Review Procram - The description and activities of the Nuclear Review Board will be as specified in i the LGS Technical SpeciIications.
- 5. ANSI N18.7-1976/ANS 3.2, Section 4.3.2.2, Meetina [
Frecuency - The " period of initial operation" means "one year after-fuel loadina of Unit 1."
- 6. ANSI N18.7-1976/ANS 3.2, Section - 4.4, Review '
Activities of the Onsite Operatina Orcanization - The word " verify" does not imply review or certification by supervisory personnel of every day-to-day operating activity; rather, the performance of reviews of documents and logs and monitoring activities by supervisory personnel in accordance with station procedures and practices is i considered to meet this requirement.
- 7. ANSI N18.7-1976/ANS 3.2, Section 5.2.1, Responsibilities and Authorities of Operatina Personnel -
Item (4) is changed to read: .. "The responsibility to respond conservatively to l instrument indications including the case in which the credibility of the indication is in doubt." This statement permits the operator to compare Control Room instruments and infer instrument error > without proving it such as by calibration checks. ; P 17.2.II-3 i
LGS UFSAR !
- 8. ANSI N18.7-1976/ANS 3.2, Section 5.2.2, Procedure ,
d Adherence - The term " supervisor in charge of the ' shift" means either the Shift Superintendent or Shift Supervisor. 1 i
- 9. ANSI N18.'7-1976/ANS 3.2, Section 5.2.6, Eauipment control (6th paragraph, last sentence) and Section 5.2.13.2 (4th paragraph) - In order to allow for action other than obtaining the original specified ,
documentation, " disposition by proper authority" is- , the criteria for use of items which have been ' identified as nonconforming. t
- 10. ANSI N18.7-1976/ANS 3.2, Section 5.2.6, Eauipment Control (a) Temporary modification (5th paragraph) - The need for independent verification of Temporary Modifications will be determined on an individual basis considering the complexity '
and impact of he modification. (b) (7th paragraph) requires " operating personnel" to place equipment in operation. Equipment ; may be placed into operational status by personnel not on the operating staff, such as instrument technicians.
- 11. ANSI N18.7-1976/ANS 3.2, Section 5.2.7, Maintenance l and Modifications - The requirement concerning original design bases and requirements, material specifications, and inspection requirements is modified to permit approved alternate requirements which are subject to the design review process.
- 12. ANSI N18.7-1976/ANS 3.2, Section 5.2.7.1, Maintenance Procrams (a) Emergency maintenance to Q-listed equipment (work which must proceed immediately to correct a degraded condition) may be performed concurrent with procedure preparation and documentation of steps actually taken. Such maintenance may be performed with the authorization of designated personnel and subsequent procedure review by the PORC. ,
l
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17.2.II-4
. LGS UFSAR ;
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-- (b) The cause of repetitive malfunctions should be j determined; however, it is not practical, and may not be -possible, to ' determine the cause- of .I every malfunction. q
- 13. ANSI N18.7-1976/ANS- 3.2, Section 5.2.10, Housekeepino and Cleanliness Control .l (a) Control measures to prevent contamination withL j foreign materials will'- be specified .in '
I Administrative P Oedures' and will include, as. appropriate, act s control. i (b) Second paragraph, first and second sentences i are taken to mean: "Where needed to prevent i contamination...." .;
- 14. ANSI N18.7 . 1976/ANS 3.2, Section 5.2.11, d Corrective-Action, Administrative and implementing j procedures will delineate the responsibility for the determination of which conditions adverse -- to- !
quality. are significant. Significant conditions- -l adverse to quality shall be reported to the Plant '; Operations Review Committee and the Nuclear Review Board."- -
- 15. ANSI' N18.7-1976/ANS 3. 2, Section 5. 2.12,- ' Plants ~ [
Records Manacement - Retention periods will' satisfy- i statutory requirements for the record. The- 7 significance of the event covered by the record and the contribution of the ~ record to - the . abilityL to - , reconstruct significant events will.-be considered. .
'in est'ablishing retention periods.
]
- 16. ANSI N18.7-1976/ANS 3.2, Section 5.2.13, i Procurement and Material Control - Item.~(1) -
i Administrative Procedures shall specify the means - for control of procurement of commercially "off- , the-shelf" . items. The Administrative Procedures : shall describe the receipt inspection,' storage, and .! handling prior to installation and operation. Off- ; the-shelf (catalog). ' items are evaluated by' ; qualified personnel for their intended. use. The l Administrative Procedures restrict the use of catalog items- for' only. these evaluated ; applications. The purchase order shall require the - vendor to notify the requisitioning organization:of- l a change in an item described in the catalog.--
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LGS UFSAR
- 17. ANSI N18.7-1976/ANS 3.2, Section 5.2.13.1, Procurement and Document Control, (second sentence)
- QA Program requirements or alternate approved methods will be used to ensure quality. Examples of alternates for suppliers without QA programs include: material analysis, sample testing, in-process inspection and monitoring, and design review by PECo.
- 18. ANSI N18.7-1976/ANS 3.3, Section 5.2.15, Review, Approval and control of Procedures - The frequency '
of review of plant procedures is discussed in UFSAR Section 13.5, except for the following alternative: 1 (a) Programmatic controls and processes described in UFSAR Section 13.5 are used to assure that procedures are current. These controls take the place of scheduled periodic reviews.
- 19. ANSI N18.7-1976/ANS 3.2, Section 5.2.17, Inspections - The results of inspections are not always subject to a further evaluation. For >
example, evaluation beyond that given by inspection-level personnel is not normally required for go/no-go and pass / fail type inspections.
- 20. ANSI N18.7-1976/ANS 3.2, Section 5.3, Preparation of Instructions and Procedures (last sentence) -
The clarification regarding emergency maintenance ' in Item 12, above, applies. ,
- 21. ANSI N18.7-1976/ANS 3.2, Section 5.3.10, Test and Inspection Procedures, (first paragraph) - The <
clarification regarding test result evaluations in Item 19, above, applies. r
- 22. ANSI N18.7-1976/ANS 3.2, Section 5.3.10, Test and Inspection Procedures, (second paragraph, last sentence) -
These procedural aspects will be included when appropriate. For example, "as-found condition" is not applicable to all test and inspection procedures.
- d. Beaulatory Guide 1.37, March 1973, " Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants." 1 Endorses ANSI N45.2.1-1973.
Decontamination and cleanup of radioactively contaminated systems and components are not included in the scope of , this response. ! 17.2.II-6 i
LGS UFSAR PECo shall comply with Regulatory Guide 1.37, March 1973 and ANSI N45.2.1-1973 except for the following alternatives:
- 1. ANSI N45.2.1, Section 3.2, Water Ouality Recuirements - pH measurements are not required for conductivity values less than or equal to 1 micromho/cm. PECo utilized pH limits of 5.2 to 8.6 at 25 degrees centigrade, uncorrected for CO2 and may apply conductivity measurements in place of total dissolved solids.
- 2. ANSI N45.2.1, Section 3.1.2, Class B - The flushing velocity may be as specified in other approved documents associated with the maintenance or modification, as well as procurement documents,
- e. Reculatory Guide 1.38, Revision 2, May 1977, " Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Water-Cooled Nuclear Power Plants." Endorses ANSI /ASME N45.2.2-1972.
PECo shall comply with Regulatory Guide 1.38, Revision 2, May 1977, and ANSI /ASME N45.2.2-1978, except for the following clarifications or alternatives:
- 1. ANSI /ASME N45.2.2, Section 2.7, Classification of-Items -
Philadelphia Electric Company does not classify items into the four (4) levels described in this standard. 'However, the specific guidance and recommendations which are appropriate to each class are applied to those items packaged, shipped, received, stored, and handled through the use of procedures, original specifications, instructions, and drawings, as applicable.
- 2. ANSI /ASME N45.2.2, Section 3, Packacinq and Section 4, Shionina -
Philadelphia Electric Company utilizes the packaging and shipping requirements delineated in the original equipment specifications as part of our procurement requirements to suppliers or manufacturers. Those requirements and recommendations of Section 3 and 4 are included in the original specifications as appropriate for the item being procured. Receipt inspection activities are in accordance with Section 5 of this standard and are sufficient to identify packaging and - shipping nonconformities.
~
17.2.II-7
LGS UFSAR i
- 3. ANSI /ASME N45.2.2, Section 6, Storace. -
Philadelphia Electric Company does not classify items into four (4) levels for storage purposes, as delineated in Section 6.1.2. Stored items are .. placed in limited access controlled areas, and are segregated with respect to the Q-list classification of the item (s). The specific -i' guidance and recommendations which are appropriate to each class are applied to those items stored through the use of procedures, specifications, and > manufacturers' recommendations and instructions. -
- 4. ANSI /ASME N45. 2.2, Section 6. 4. 2 (7) ,. Care of Items i The rotating of certain electrical motors in storage, which must be energized to release an '
electrical brake, will be stored and maintained in ; accordance with manufacturers' recommendations. Other motors, which can be rotated without energizing, will be maintained in accordance with the requirements of Section 6.4.2 (7) of the standard,
- f. Reculatory Guide 1.39, Revision 2, September 1977,
" Housekeeping Requirements for Water-Cooled Nuclear Power Plants." Endorses ANSI N45.2.3-1973.
PECo shall comply with Regulatory Guide 1.39, September . 1977, and ANSI N45.2.3-1973 except for the following alternatives:
- 1. ANSI N45.2.3, Section 2.1, Plannina - Zone II requirements for clean gloves, shoe covers, and head coverings will be determined by health physics personnel under the radiation protection program and specific requirements listed on the Radiation Work Permit for entry in Zone II areas.
- 2. ANSI N45.2.3, Section 2.1, P.lannina - Material accountability for Zones II and III shall be controlled by procedural requirements, periodic inspections and surveillance of areas for acceptable housekeeping practices. Implementing procedures for activities such as maintenance and modifications require housekeeping and cleanliness inspections of areas and equipment to eliminate foreign materials that may have a detrimental effect. Postmaintenance or modification inspections for housekeeping and cleanliness shall be conducted and documented in accordance with administrative controls.
I 17.2.II-8
]
LGS UFSAR t
- 3. ANSI N45.2.3, Section 2.1, Plannina - Personnel accountability for Zone III will be controlled as determined by the administrative controls for locked doors and radiation work permit requirements in lieu of specific access registers.
- g. Reaulatory Guide 1.54, June 1973, " Quality Assurance Requirements for Protection Coatings Applied to Water-Cooled Nuclear Power Plants." Endorses ANSI N101.4-1972.
PECo shall comply with Regulatory Guide 1.54, June 1973, and ANSI N101.4-1972, for major modifications except for the following alternatives: l
- 1. ANSI N101.4-1972, Paragraphs (5) and (6) -
a procedure (s) will be implemented prior to coating that will ensure satisfactory application and inspection of coatings applied to Nuclear Facilities.
- 2. ANSI N101.4-1972, Paragraph 3.2.2 - Class I Service Level will become Service Level 1, and is defined, ,
from ASTM D5144-91, as follows: " Areas where coating failure could adversely affect the operation of post-accident fluid systems and, thereby, impair safe shutdown. With few exceptions, Coating Service Level i 1 applies to coatings inside primary containment." r
- h. Reculatory Guide 1.58, Revision 1, " Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel." Endorses ANSI /ASME N45.2.6-1978.
PEco shall comply with Regulatory Guide 1.58, Revision 1, and ANSI /ASME N45.2.6-1978, except for the following clarification and alternatives:
- 1. Regulatory Guide 1.58, Revision 1, Section C.1, and i ANSI /ASME N45.2.6-1978, Subsection 1.2, states that the standard applies to " personnel who perform inspections, examinations, and tests." Philadelphia Electric Company personnel who inspect equipment as part of plant maintenance, in other than quality '
control function, and plant staff personnel (as defined in the LGS Technical Specification), and who ; approve test procedures and tests results and direct , or supervise the conduct of individual tests, will be ! qualified in accordance with ANSI /ANS 3.1-1978 in lieu of ANSI /ASME N45.2.6-1978. ; i
- 2. ANSI N4 5. 2. 6-1978, Subsection 3.5, presents experience recommendations for candidates. Experience in maintenance, modification, and operating activities is considered related experience because such experience ;
provides training in the safety aspects of the facility. 17.2.II-9 7
LGS UFSAR
- i. Reaulatorv Guide 1.64, Revision 2, June 1976, " Quality Assurance Requirements for the Design of Nuclear Power Plants." Endorses ANSI N45.2.11-1974.
PECo shall comply with Regulatory Guide 1.64, June 1976, and ANSI N45.2.11-1974 except for the following clarification and alternative: Clarification -
- 1. Modifications are defined in appropriate-adminintrative procedures.
Alternative -
- 1. Regulatory Guide 1.64, Section C.2, design verification can be performed by the designer's immediate supervisor under the following circumstances:
(a) When the supervisor is the only technically qualified individual. (b) The need is individually documented and approved in advance by the supervisor's management. (c) QA audits cover frequency and effectiveness of use of supervisors as design verifiers to guard ~against abuse.
- j. Beaulatory Guide 1.74, Revision 0, February 1974,
" Quality Assurance Terms and Definitions." Endorses ANSI N45.2.10-1973.
PECo shall comply with Regulatory Guide 1.74, Revision 0, February 1974, and ANSI N45.2.10-1973, except for the following alternative: The word " examination" also means an exercise to examine progress or status of knowledge or qualification.
- k. Reculatory Guide 1.88, Revision 2, October 1976, !
" Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records." PECo shall comply with ANSI /ASME N45.2.9-1979, except for the following alternatives:
17.2.II-10 ;. l l
LGS UTSAR l Section 3.2.6, Supplemental
- 1. ANSI /ASME N45.2.9, Information to Records -
Supplements and corrections to records will be in accordance with i procedures, but will not necessarily require review i or approval by the organization that originated the record. t
- 2. ANSI /ASME N45.2.9, Section 5.3, Storace, Item 3.
This item implies the use of a transmittal document. Philadelphia Electric Company will use such documents as determined by the type of record ; being stored.
- 1. Regulatory Guide 1.94, Revision 1, April 1976, " Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structure Steel during ,
the Construction Phase of Nuclear Power Plants." Endorses ANSI N45.2.5-1974. PECo shall comply with Regulatory Guide 1.94, Revision 1, April 1976, and ANSI N45.2.5-1974, except for the following clarification:
- 1. ANSI N45.2.5-1974 will be implemented by PECo by initiating a procedure, prior to any work, that l will assure satisfactory installation nspection, and testing of structural concrete or structural steel.
- m. Regulatory Guide 1.116, Revision O-R, May 1977, " Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems." Endorses ANSI N45. 2. 8-197 5, except for the following alternatives:
- 1. ANSI N45.2.8, Section 2.2, Procedures and Instructions -
UFSAR Section 13.5 addresses ; compliance with ANSI N18.7-1976/ANS 3.2 and Regulatory Guide 1.33. These requirements provide adequate controls for the Procedures and Instructions addressed in this section. *
- 2. ANSI N45.2.8, Section 2.3, Results -
PECo's commitment to ANSI 18.7-1976/ANS 3.2 provides - adequate guidance for the documentation and review of the results of inspections and tests. , 17.2.II-11 -
~1
LGS UFSAR
- 3. ANSI N45.2.8, Section 3.4, Physical Condition -
PECo's response to ANSI N45.2.1, N45.2.2, and N45.2.13 provides adequate guidance and control for the requirement that mechanical items are in accordance with specified requirements and that the quality has been maintained,
- n. Regulatory Guide 1.123, Revision 1, July 1977, " Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants." Endorses ANSI N45.2.13-1976.
- o. Reaulatory Guide 1.143, Revision 1, October 1979, " Design Guidance for Radioactive Waste Management Systems, Structures, and Components Installed in Light-Water-Cooled Nuclear Power Plants.
PECo shall comply with Regulatory Guide 1.143, Revision 1, October 1979, for major modifications, subject to the exceptions and clarifications listed in Table 3.2-1, Note 18.
- p. Reaulatory Guide 1.144, September 1980, " Auditing of Quality Assurance Programs for Nuclear Power Plants."
Endorses ANSI /ASME N45.2.12-1977. PECo shall comply with Regulatory Guide 1.144, September 1980, and ANSI /ASME N4 5. 2.12-1977, with the clarification discussed in Item 1 under Regulatory Guide 1.33 and with the following alternatives:
- 1. ANSI /ASME N45.2.12, Section 4.2.4, Audit Notification and Section 4.3.1, Preaudit Conference Preaudit notification is given to plant management in an informal manner due to daily contact and communications between Nuclear Quality ,
Assurance Department personnel and plant personnel. ,
- 2. Section 4.3.3, Postaudit Conference - A postaudit conference will be held if unsatisfactory findings are identified during the audit.
- 3. ANSI /ASME N45.2.12, Section 4.4.6, Reportina - The
- audit report shall be issued within 30 working days after the postaudit conference. 17.2.II-12 7
LGS UFSAR
- q. Recrul atory Guide 1.146, August 1980, " Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants." Endorses ANSI /ASME N45.2.23-1978.
PEco shall comply with Regulatory Guide 1.146.
- r. Branch Technical Position (BTP) CMEB 9.5-1 For modification work performed by the Nuclear Engineering Department during the operations phase, the Nuclear Engineering Department will maintain compliance
, with the requirements of CMEB 9.5-1 in accordance with ' Section 9.5.1. i l 17.2.II-13 ;!}}